Data Protection Policy

At Enery [sic] Environment and Sustainability S.L.U., (hereinafter “ENSO”) we want to be transparent with all users, registered or otherwise, who visit our website and use our app. For this reason, we want to tell you about the use of personal data in accordance with this Data Protection Policy:

• What information may we have about you and how may we obtain it?

• Why and how are we going to use it?

• How can you view and administrate the data we may end up having about you?

• Who can you contact for any privacy-related questions?

The personal data (hereinafter “Personal Data”) we may end up processing will be contact data (name, postal address, email address, phone number), your IP address and data about your browsing on our websites or mobile applications.

Any personal data we have about you may be obtained:

Because you provide them to us, for example, when you ask to register on our website to receive information.

From your use of our services, in compliance with the law at all times.

You agree that the data you provide to us will be correct, accurate and current, and assume any liability that may arise from providing incomplete, erroneous or inaccurate data.

At ENSO we will process your Personal Data for different purposes, for example, to manage the information about the products and services you have requested from us, to ensure that the website and app will work properly to be able to offer you personalised attention, to comply with our legal obligations and, out of a legitimate interest, to offer our users a better service.

In addition, your Personal Data may be processed to do studies and/or analysis for the promotion of products and/or services marketed directly by ENSO.

We will therefore process your data to register you as a user of the ENSO website and for the timely development, management and upkeep of the relationship we have with you, as well as any communications we may have to send you while you are a user.

The data that we have specified in the form as “required” are necessary in order to maintain your relationship with ENSO. Accordingly, failure to provide them to us would make it impossible for us to attend to your request.

Please note that if you do not supply us with certain personal data we will not be able to provide some of the services, functionalities and/or information you have requested from us.

In order to meet your expectations, improve our products and services and increase your level of satisfaction and experience as a user, ENSO will process your personal data to conduct surveys and market studies or to produce internal statistics and commercial reports.

In addition, and if you are acting on behalf of a business interested in collaborating with us, ENSO will process your contact details solely for purposes of maintaining the communications necessary for the management of the collaboration request, and to carry out this collaboration normally if it becomes formalised.

At ENSO, based on a legitimate interest, we may perform the processing described above while respecting your privacy and rights at all times. In any event, remember that you can always exercise your right to object, as we describe in this document.

At ENSO we may view your data on our own internal sources in order to detect and prevent situations of potential fraud (such as unauthorised access to users’ personal information, potential identity theft or any situation that might be construed as fraudulent or undesirable use of the account) in order to protect the interests of our users.

If any attempted fraud is detected, and unless there is a matter of public interest at stake, we will inform you about this, review the information available and, if applicable, ask you for additional information. Additionally, as a precaution and until we make the relevant checks, any decision, automated or otherwise, will be halted.

For the necessary reasons and situations outlined below:

To provide any information you might request about the various products and services we offer through our channels, to prevent potential situations of fraud and to produce internal statistical studies. In these cases, ENSO processes your Personal Data because it has a legitimate interest in using the information you provide to us.

To comply with certain legal obligations to be able to manage any products and services you may request from us.

Energy Environment and Sustainability S.L.U. is responsible for the website or app that you are accessing and is the controller of the Personal Data that may be linked to it. It is ENSO who collects, uses, preserves and, if applicable, cancels the Personal Data.

ENSO will never transfer to third parties who do not belong to the ENSO Group information about Personal Data to which it has access unless required to do so by law (for example, to the State Security Forces and Bodies or the Courts), or unless we are seeking to detect and prevent potential attempts at fraud or you have expressly authorised us to do so.

We also wish to inform you that ENSO works with third-party service providers that occasionally may have access to your Personal Data.

These providers who work with ENSO follow strict selection criteria and always do so at our request and instructions. Under a processing contract in accordance with the applicable regulation they are contractually bound to fulfil appropriate technical and organisational measures and to erase or return any data to which they may have access when it is no longer necessary to provide the service.

At ENSO we keep the Personal Data to which we have access only as long as is strictly necessary and, when we no longer have any reason to process them, we will keep them duly blocked at the order of the Courts and other bodies, in case of any claim.

You have and will be able to exercise the following rights:

• Right of access: you have the right to obtain confirmation as to whether or not ENSO is processing personal data that concern you and, in such case, to access them.

• Right to portability: you have the right to receive the personal data you have provided to us in a legible, structured common-use format, and to transfer them to another entity.

• Right to rectification: you have the right to ask for the data to be rectified if they are inaccurate.

• Right to erasure: you can ask to have the data erased when, among other reasons, the data are no longer necessary for the purposes for which you gave them to us.

• Right to object: under certain circumstances, you may object to the processing of your personal data. In that case, ENSO will stop processing the data, unless there are compelling legitimate reasons or to bring potential claims.

• Right to restriction of processing: under certain circumstances established by the current data-protection regulation, you may ask to have the processing of your data restricted.

• Right to not be subject to decisions based solely on automated means: in the event that you have authorised the creation of a profile and this is carried out entirely through an automated procedure, you may request the personal involvement of one of our analysts, express your viewpoint and challenge the decisions based on that profile.

And of course, you have the right to withdraw, at any time, any specific authorisations you may have given us to use your Personal Data.

If you are interested in administrating rights to Personal Data, we offer several alternatives for you to get in touch with us:

Email us at gdpr.enso@enso.energy

Write to us by mail at “Energy Environment and Sustainability S.L.U., C/ Ombú 3 – 10ª planta, 28045, Madrid”.

Lastly, you can bring a claim to ENSO and/or the Spanish Data Protection Agency [Agencia Española de Protección de Datos] (as the competent data protection supervisory authority), particularly if you have not obtained satisfaction in the exercise of your rights, by sending a letter to the aforementioned address or through the webpage https://www.aepd.es.

All information relating to the use of cookies and the data we collect from your browsing on our website through them (what information we collect, what we use it for, and what you can do about it) can be found in more detail in our “Cookie Policy” at: www.enso.energy

You can contact our Legal & Compliance Department, which is responsible for protecting your privacy and intimacy and ensures that the various legal requirements contained in the regulation (both Spanish and European) with respect to personal data protection are met, at the following email address: gdrp.enso@enso.energy

Last updated on: 1/11/2020