Privacy Policy

- Last updated: August 1, 2022 –

- This version is only a translation of easier use. The Spanish version of this policy is the only official one and will be referred to whenever interpretation is needed. -

1. Purpose of the Policy

In compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC, hereinafter GDPR,  as well as the Spanish Organic Law 3/2018, of December 5, on the Protection of Personal Data and Guarantee of Digital Rights, hereinafter LOPDGDD, AGTIC Consulting (AGTIC hereinafter), establishes this privacy policy to inform in a concise, transparent, intelligible and easily accessible way how it collects, uses and guards the personal data of those people who relate to it (interested persons hereinafter).

2. Common characteristics of the processing of personal data

The following are the aspects of general application to any processing of personal data:

2.1. Data Controller

Any data subject who provides personal data to AGTIC will be informed that the processing of their data is carried out by AGTIC Consulting SL, with CIF B66766528, address at C/ Balmes, 191 Entl. 3 08006 Barcelona and e-mail address

2.2. Lawfulness for data processing

The processing of personal data by AGTIC is usually carried out under one of the following basis:

  • The consent of the data subject, according to Article 6.1.a) of the GDPR.
  • Compliance with a legal obligation, according to Article 6.1.c) of the GDPR;
  • The execution of a contract, according to Article 6.1.b) of the GDPR;
  • Satisfy legitimate interests pursued by the controller, according to Article 6.1.f) of the GDPR;

AGTIC is entitled to process personal data based on the provisions of article 6.1.c) of the GDPR, that is, when the treatment is necessary for complying with a legal obligation applicable to the person responsible for the treatment.

On the other hand, the provisions of article 6.1.b) of the GDPR will also apply, when the treatment is necessary for the execution of a contract to which the interested person is a party or there are pre-contractual provisions.

Additionally, the consent of the interested person will be necessary, according to article 6.1.a) of the GDPR, when the processing of personal data is not covered by any of the aforementioned causes. In this case, the persons concerned may withdraw that consent at any time.

Finally, AGTIC, in accordance with article 6.1.f) of the GDPR, reserves the right to use, always in an adequately justified manner, the legitimacy of the treatment based on its legitimate interest, provided that the interests or fundamental rights and freedoms of the interested party do not prevail over these interests.

2.3. Purposes for data processing

In the case of the treatments carried out with the personal data provided by the users of the web portal belonging to AGTIC, the collection and automated processing of personal data is intended to follow up on the queries raised or the treatment of the information provided by the interested persons. Additionally, the terms related to personal data protection information will be displayed in the corresponding informative clause.

Through the AGTIC website, personal data will not be collected from users without their consent, nor will they be given to third parties except legal obligation.

In the case of the treatments carried out based on the relationship of provision of services that will be carried out for the coordination and execution of the contract that, where appropriate, regulates the conditions of order of the treatment, AGTIC will treat data exercising the role in charge of the treatment under the responsibility of its clients.

In the case of AGTIC personnel, the processing of personal data is necessary for the maintenance of labor relations and compliance with the regulations governing the matter.

2.4. Origin of personal data

In general, the personal data processed by AGTIC will come directly from the person concerned. If the personal data come from sources other than the one mentioned, the source of obtaining the information will be indicated in the information clause.

2.5. Communications of personal data

It is not planned to communicate data to third parties, unless it is a legal obligation, or the consent of the interested party is available.

If within the framework of the processing of personal data, AGTIC makes transfers of data to third parties, the information clause that characterizes the object of the transfer and its recipients will be indicated in the informative clause of the treatment.

In the event that an international transfer of personal data is carried out, it will be governed by the provisions of the GDPR, the LOPDGDD and its implementing rules, the resolutions of the Data Protection Control Authorities, especially of the Spanish Agency for Data Protection, within the scope of the respective competences, applying the appropriate security measures to ensure a level of data security comparable to that applied in European territory.

2.6. Data retention period

The personal data will be kept for the time necessary to comply with legal obligations or, in case of treatment subject to the consent of the interested party, until the fulfilment of the informed purpose or when he requests its revocation and is legitimized for it.

This information can be consulted for each processing of personal data in the informative clause on the treatment.

2.7. Data subject’s rights

Data subjects may exercise any of the following legally provided rights:

  • Right of access, that is, to consult and obtain a copy of the personal data subject to treatment, if they are stored in AGTIC's information systems.
  • Right to rectification of personal data when they are inaccurate and both the inaccuracy and legitimacy of the new data subject to rectification are adequately justified.
  • Right to erasure of data (right to be forgotten), which consists of the right to the deletion of certain data if there is no legal obligation that does not allow it.
  • Right to object to processing, i.e., not to have your personal data processed for certain purposes.
  • Right to restriction of processing, which means that, at the request of the data subject, the processing operations that would correspond in each case should not apply to their personal data. This right can only be requested in some cases:
    • While the challenge to the accuracy of the data is verified.
    • When the processing is unlawful, but the person concerned objects to the deletion of their data.
    • When AGTIC does not need to process the data, but the interested party needs them to be maintained for the exercise or defense of claims.
    • When the interested party has objected to the processing of their data for the satisfaction of a legitimate interest, while verifying whether the legitimate reasons for the treatment prevail over those of the interested party.
  • Right to portability, which implies an advanced form of the right of access by which the copy provided to the interested party must be offered in a structured format, of common use and mechanical reading that allows him to contribute them to another data processor and this incorporate them into his information systems.
  • Right not to be subject to automated individual decisions, including profiling that produces legal effects that affect you or that significantly affect you in a similar way.
  • Right to lodge a complaint with the supervisory authority in matters of data protection. In this case, the competent authority is the Spanish Agency for Data Protection with address at C/ Jorge Juan, number 6, 28001 – Madrid and website:

2.8. Exercise of the data subject’s rights

The interested party may exercise their rights by written communication addressed to the postal address C/ Balmes, 191 Entl. 3 08006 Barcelona or at the electronic address in which you identify, indicate which right of those contemplated in section 2.7 of this Policy you exercise and provide the rest of the details you consider appropriate to be able to meet your request properly.