Privacy Policy
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Privacy Policy

The following is the privacy policy (hereinafter, “web privacy policy” or “policy”) governing the Web Platform https://club.holabank.es/ (hereinafter, “the Platform”), owned by MULTIASISTENCIA, S.A. (hereinafter, “MULTIASISTENCIA” or “we”) entity domiciled in Ronda de Poniente, 7, 28760, Tres Cantos (Madrid), with Tax ID no (CIF) A- 82261553 and registered in the Companies Register of Madrid, Volume 13,985, Folio 1, Page number M-229.242, Entry 1.

PLEASE TAKE A FEW MINUTES TO READ OUR PRIVACY POLICY, IT WON'T TAKE LONG. WE WISH TO EXPLAIN IN A SIMPLE, CLEAR AND TRANSPARENT WAY HOW WE PROCESS AND PROTECT YOUR PERSONAL INFORMATION AND YOUR RIGHTS. YOUR SECURITY AND THE SECURITY OF YOUR PERSONAL DATA IS ESSENTIAL FOR MULTIASISTENCIA AND WE ARE VERY SERIOUS ABOUT ITS ADEQUATE PROTECTION.
WE ALSO ADVISE YOU TO READ CAREFULLY OUR COOKIES POLICY.

1. WHO IS THIS POLICY AIMED AT AND APPLIED TO?

This policy applies to all users of the platform and in particular, to the beneficiaries of the HolaBank Club programme (hereinafter, indistinctly, “the user” or “the users”) who are considered natural persons. By personal data, we mean any information about an identified or identifiable natural person.

If you are already a customer of MULTIASISTENCIA, for having signed a contract with us, you should also refer to the information contained in the contract on the specific terms of privacy.

This platform is aimed at users over 18 years of age, its use is prohibited for children under this age. The user also acknowledges in a responsible manner that he or she has the necessary legal capacity to subscribe, where appropriate, to the services offered by MULTIASISTENCIA.

2. IF YOU BROWSE OR USE OUR WEB PLATFORM, WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL DATA?

We are responsible for the processing your personal data:

Full name of the entity: MULTIASISTENCIA, S.A.
Registered address: Ronda de Poniente, 7, 28760, Tres Cantos (Madrid)
Physical address/office: Ronda de Poniente, 7, 28760, Tres Cantos (Madrid)
Contact phone no/s: +34 91 832 98 98
Contact email: holanbankclub@multiasistencia.com

If you have any questions regarding the protection of your personal information, please send an e-mail to: privacy@multiasistencia.com or dpd@multiasistencia.com

3. WHO IS THE DATA PROTECTION OFFICER (DPO) OF MULTIASISTENCIA?

MULTIASISTENCIA has appointed a DATA PROTECTION OFFICER (DPO), with whom users, if required, may contact regarding all matters relating to the processing of their personal data and for exercising their rights under the provisions of the GDPR. Please find below the contact details of our DPO:

Correspondence address: Ronda de Poniente, 7, 28760, Tres Cantos, Madrid
Contact email: dpd@multiasistencia.com

4. WHAT TYPE OF DATA DO WE PROCESS?

Your data is processed in order to give you access to the contents and/or functionalities of the platform or, if you so require, to be able to provide you with the services available through the platform. In this regard, we are committed to processing your personal data in a lawful and consistent manner in accordance with the principles and legal obligations set out in the applicable data protection laws.

When you browse through our platform and, especially, when you interact or register with us, you provide us with data directly, for example, when you fill in any form or application provided online pursuant to the processing purposes indicated in each case.

The data you provide to us on such forms or applications, through the means provided by us, may vary depending on the type of form or request in question. Notwithstanding the foregoing, different categories of personal data may be collected through the platform and its various forms/applications, although we will always ask you for data that is adequate, relevant and limited to what is necessary for the aforementioned processing purposes (principle of minimisation of personal data):

  • Personal data to identify the user as a beneficiary of the HolaBank Plan ancillary services (i.e. DNI, NIE or passport, name and surname and language);
  • Personal contact details provided by the user for handling the subscription and membership of the programme (telephone number, e-mail address and details derived from the services requested).
  • Personal data (needs or associated queries, for example, indicated through our contact email).

Similarly, when you browse our platform you should be aware of the cookies that are installed on your terminal or device as this involves the processing of your personal data according to the type of cookies reported and their specific purposes (see cookies policy). You can configure your preferences on the use of such cookies used on our Platform through the configuration panel enabled, as indicated in the aforementioned cookies policy.

5. FOR WHAT PURPOSES DO WE USE YOUR DATA?

The personal data that you provide us will be processed for the purpose stipulated in detail in this privacy policy and, where appropriate, in the various data forms provided therein. In this regard, the collection of data serves the following processing purposes:

  • Enable you to browse our platform, thereby allowing access to information and content provided therein.
  • Manage the subscription or registration and membership of the HolaBank Plan, which includes: i) the identification of users as beneficiaries of the benefits and services associated with this Plan, ii) manage the services requested during the term of the Contract that links you to us, iii) manage any incidents, queries, suggestions, complaints and claims, and iv) send the necessary communications related to the HolaBank Plan and its ancillary services (changes to the programme, facilitate the contracting process, etc.).
  • Quickly and efficiently resolve your doubts concerning the services of the HolaBank Club programme through the different channels provided for this purpose (email, telephone, etc.).
  • Enable the uses associated with cookies on the Platform as described in our cookies policy.
  • If you give your express consent to do so, by ticking the box specifically provided for this purpose, we will process your personal data to send you information, by any means, including electronic, about the products, services, benefits, offers and promotions of the HolaBank Plan, Multiasistencia, other companies in the business group to which Multiasistencia belongs (https://multiasistencia.com/empresas- del-grupo-multiasistencia/) and/or entities collaborating with Holabank Club.
  • Analytical purposes for the improvement of the Plan, its services and the User experience. We will process your personal data to understand the performance of the services and how they are used, and, ultimately, to optimise and personalise them, facilitate their use and make them more valuable, as well as to expand the services offered and further develop new programmes and/or services based on such information, all in accordance with the applicable regulations. Likewise, we occasionally carry out quality activities and surveys aimed at finding out the degree of satisfaction of our users.
  • Take whatever protection measures are applicable pursuant to current laws, including the likely anonymisation of your personal data by applying the appropriate techniques available for this purpose. Therefore, in this scope, anonymisation and pseudonymisation may also be carried out to better protect your personal data.
  • To apply the relevant security, technical and organisational measures to your personal data, focusing on the risk that exists at all times, including pseudonymisation or encryption of personal data through our platform.

6. ON WHAT BASIS DO WE LAWFULLY PROCESS YOUR DATA?

Processing purposes Lawful basis for processing
Enable you to browse our platform, thereby allowing access to information and content provided therein. Your consent and where applicable, to meet the lawful interests of yourself or third parties associated with the proper management, maintenance, development and evolution of the platform, related tools, network and information systems, enabling their correct functioning, features, access to content and services, as well as the overall security of all of the above.
Manage the subscription or registration and membership of the HolaBank Plan. The execution of the contract (Terms and Conditions) signed with Multiasistencia or, as the case may be, the execution of pre- contractual arrangements at the request of the user.
Clear your doubts about our services in an agile and efficient manner. Your consent and, where applicable, execution of pre-contractual measures at the request of the user.
If you have accepted the cookie policy provided for this purpose, to allow the development of the processing purposes associated with them. Your consent.
If you have accepted the cookie policy provided for this purpose, to allow the development of the processing purposes associated with them. Your consent.
Analytical and quality purposes for the improvement of the Plan, its services and the user experience. There is a legitimate interest in analysing the usability of the Plan's services and the degree of beneficiary satisfaction to the extent that the processing of this data is of added value for the beneficiaries, taking into account that it results in the improvement of the service and the user experience.
Take whatever protection measures are applicable pursuant to current laws, including the likely pseudonymisation and anonymisation of your personal data by applying the appropriate techniques available for this purpose. Compliance with a legal obligation (REGULATION (EU) 2016/679 of the European Parliament and of the Council dated 27 April 2016 on the protection of individuals on the processing of personal data and on the free movement of this data and repealing Directive 95/46/EC (hereinafter the “General Data Protection Regulation” or the “GDPR”) https://www.boe.es/doue/2016/119/L00001- 00088.pdf. In terms of processing aimed at ensuring the security of the platform, the network and the related information system, fulfilment of the lawful interest of MULTIASISTENCIA or, where applicable, of a third party may be invoked, where appropriate (Recital 49 of GDPR).
To apply the relevant security, technical and organisational measures to your personal data, focusing on the risk that exists at all times. Compliance with a legal obligation (REGULATION (EU) 2016/679 of the European Parliament and of the Council dated 27 April 2016 on the protection of individuals on the processing of personal data and on the free movement of this data and repealing Directive 95/46/EC (“General Data Protection Regulation” or “GDPR”) https://www.boe.es/doue/2016/119/L00001- 00088.pdf. In terms of processing aimed at ensuring the security of the platform, the network and the related information system, fulfilment of the lawful interest of MULTIASISTENCIA or, where applicable, of a third party may be invoked, where appropriate (Recital 49 of GDPR).

When the legitimate basis for the processing of your personal data is your consent, we wish to remind you that you have the right to revoke it at any time in a simple and free manner by writing to us at privacy@multiasistencia.com or dpd@multiasistencia.com.

7. HOW LONG DO WE STORE YOUR DATA?

Personal data related to the purposes of the informed processing Time limits or criteria for storing your personal data
Data related to the user's browsing on our platform. - In general, your data will be stored for these purposes for as long as it is indispensable and necessary to enable you to correctly browse and use our platform and the content available on it. -With regard to the data related to your browsing profile, in relation to the analytical type of cookies that , if any, you have accepted as stated in MULTIASISTENCIA's cookie policy, you must refer to the section on their temporality (see cookies policy).
Manage the subscription or registration and membership of the HolaBank Plan. - They will be stored for the duration of the contractual relationship that you have with us, for the time required to provide you with the benefits and services associated with HolaBank Club.
Clear your doubts about our services in an agile and efficient manner. - For the time necessary to respond correctly to your specific petitions and requests based on each case. -If they involve at your request executing pre-contractual measures or signing a contract with MULTIASISTENCIA, your data will be stored for as long as necessary to meet such pre-contractual measures or service contracts between the parties.
If you have accepted the cookie policy provided for this purpose, to allow the development of the processing purposes associated with them. As long as you do not request to object to the processing for commercial purposes or the deletion of your personal data, it will be understood that you continue to be interested in receiving such communications from us.
Analytical and quality purposes for the improvement of the Plan, its services and the user experience. - They will be stored for the duration of the contractual relationship that you have with us, for the time required to provide you with the benefits and services associated with HolaBank Club.
To take as many protection measures as may be applicable in accordance with current laws. While processing personal data of the user, including the storage of such data for the legal periods provided and regardless of the legitimate basis for processing that MULTIASISTENCIA uses.
To apply the relevant security, technical and organisational measures to your personal data, focusing on the risk that exists at all times. While processing personal data of the user, including the storage of such data for the legal periods provided and regardless of the legitimate basis for processing that MULTIASISTENCIA uses.

In any case, and without prejudice to the foregoing, the user is also informed of the following:

  • In accordance with current legislation on the protection of personal data, with regard to the correct processing of personal information by MULTIASISTENCIA, this entity will also be able to store the information for three years in a secure manner from the time it is collected (prescription periods for infringements in this area).
  • Regarding the storage time of cookies, we recommend the user to read our cookies policy (temporality section).
  • In general, when personal data are no longer necessary for the processing purposes for which they were collected, they will be blocked and will be available only to the competent authorities for the potential discharge of legal liabilities during their processing, always in accordance with applicable law and they may not be used for purposes other than these. Once the corresponding legal periods have elapsed in the event of blocking, the personal data shall be deleted in accordance with the applicable regulations and, if applicable, may also be securely anonymised by MULTIASISTENCIA (anonymised/non-personal data).

8. WHAT HAPPENS IF YOU DO NOT PROVIDE US YOUR DATA?

We try to request or apply the bare minimum and essential data for the processing of personal data that we perform for fully conducting our corporate purposes. All the above is in accordance with the principles contained in the applicable regulations.

However, failure to provide your personal data could lead to: 1) you may not browse our website correctly (disable technical or session cookies); 2) you may not certain content or services (for example, if you do not provide us with your details, we will not be able to provide you with the services requested); 3) you may not process your specific petition or request (for example, due to the lack or insufficient filling out of the relevant form or application).

In any case, the information and personal data you provide, as the case may be, must be always:

  • Sufficient, albeit adjusted, limited and proportionate to the legitimate purposes of processing informed in each case, with full respect for the principles of limitation of purpose and minimisation of personal data.
  • Accurate, updated and truthful, in order to be able to adequately verify the identity, capacity and, where appropriate, representation, as well as to be able to adjust, in each case, the data processing carried out to your specific needs and your true situation. All this in accordance with the principle of accuracy of personal data.

Users will be fully responsible for the data and personal information they provide to MULTIASISTENCIA in connection with the platform and, where appropriate, for the services they require or contract from us.

9. DO WE SHARE YOUR PERSONAL DATA WITH THIRD PARTIES?

If you request a HolaBank Plan service provided by a third party company specialising in the sector, the personal identification data strictly needed to provide this service may be shared with third parties providing HolaBank Plan services, with which Multiasistencia has reached collaboration agreements in the interest and for the benefit of HolaBank Plan beneficiaries, and whose identification data will be made known to the user when requesting the corresponding service. If you would like to know more information about our partners, you may write to privacy@multiasistencia.com.

Similarly, MULTIASISTENCIA has several people in charge of processing personal data under its control, allowing access to them as trusted suppliers, and insofar as it is strictly necessary for the provision of the services contracted with them. Such data processors operate under a service contract under the terms, conditions and guarantees listed in Article 28 of GDPR, and MULTIASISTENCIA performs the relevant controls, inspections and audits in this area to check that such data processors strictly comply with the contracts signed for this purpose and the applicable regulations.

10. IS YOUR PERSONAL DATA TRANSFERRED INTERNATIONALLY?

Please note that, in general, no international transfers of your personal data are planned. MULTIASISTENCIA takes the necessary measures and guarantees in this area in accordance with current legislation on the protection of personal data.

11. WHAT RIGHTS DO YOU HAVE, WHAT DO THEY MEAN AND HOW CAN YOU EXERCISE THEM?

Your rights What it is? How to exercise them?
Information rights The right to be provided with appropriate information by MULTIASISTENCIA, both at the time your personal data has been collected (whether obtained from you or through a third party) and at any time later for the processing of your personal data. You decide about your personal information. Refer to articles 12 to 14 of GDPR. MULTIASISTENCIA tries to provide you all the necessary information regarding the processing of your personal data in application of articles 12 to 14 of GDPR. However, if you have any questions or doubts about our privacy and cookies policies, please feel free to send us an email: privacy@multiasistencia.com or dpd@multiasistencia.com and we will respond to your request for additional information.
Right of access The right to obtain from MULTIASISTENCIA confirmation of whether your personal data is being processed, and basic information regarding such processing (article 15 of GDPR), as well as to obtain a copy of the personal data being processed. By sending a written request via e-mail: privacy@multiasistencia.com or dpd@multiasistencia.com with Ref. “Exercise Rights” enclosing, if necessary a copy of your national identity document or equivalent identification document (passport, NIE, etc.) to certify your identification.
Right of rectification Right to have your personal data rectified without undue delay by MULTIASISTENCIA under the terms of article 16 of GDPR. By sending a written request via e-mail: privacy@multiasistencia.com or dpd@multiasistencia.com with Ref. “Exercise Rights” enclosing, if necessary a copy of your national identity document or equivalent identification document (passport, NIE, etc.) to certify your identification.
Right of deletion Right to have your personal data deleted without undue delay by MULTIASISTENCIA under the terms of article 17 of GDPR. By sending a written request via e-mail: privacy@multiasistencia.com or dpd@multiasistencia.com with Ref. “Exercise Rights” enclosing, if necessary a copy of your national identity document or equivalent identification document (passport, NIE, etc.) to certify your identification.
Right to limitation of processing Right to have your data processing limited by MULTIASISTENCIA when: -You challenge the accuracy of your personal data, for a period that allows MULTIASISTENCIA to check its accuracy. -The processing is unlawful and you oppose its deletion (and instead, request its limitation). -MULTIASISTENCIA no longer needs personal data, but needs them to formulate, exercise or defend claims. Its exercise will be limited to the provisions of article 18 of GDPR. By sending a written request via e-mail: privacy@multiasistencia.com or dpd@multiasistencia.com with Ref. “Exercise Rights” enclosing, if necessary a copy of your national identity document or equivalent identification document (passport, NIE, etc.) to certify your identification.
Right to data portability Right to receive personal data concerning you that you have provided to us in a structured format, commonly used and machine-readable, or to transfer it to another processing controller when technically possible under the terms described in article 20 of GDPR. By sending a written request via e-mail: privacy@multiasistencia.com or dpd@multiasistencia.com with Ref. “Exercise Rights” enclosing, if necessary a copy of your national identity document or equivalent identification document (passport, NIE, etc.) to certify your identification.
Right to oppose Right to oppose at any time the processing of your personal data, including profiling, when this is done to meet the legitimate interest of MULTIASISTENCIA or a third party as described in article 21 of GDPR. By sending a written request via e-mail: privacy@multiasistencia.com or dpd@multiasistencia.com with Ref. “Exercise Rights” enclosing, if necessary a copy of your national identity document or equivalent identification document (passport, NIE, etc.) to certify your identification.
Right not to be the subject of a decision based solely on automated processing (including profiling) Right not to be subject to a decision based solely on automated processing, including profiling, which has legal consequences for you or significantly affects you in a similar manner under the terms of Article 22 of GDPR. By sending a written request via e-mail: privacy@multiasistencia.com or dpd@multiasistencia.com with Ref. “Exercise Rights” enclosing, if necessary a copy of your national identity document or equivalent identification document (passport, NIE, etc.) to certify your identification.
Right to revoke consent granted You have the right to withdraw your consent at any time. The withdrawal of consent will not affect the lawfulness of the processing carried out by MULTIASISTENCIA based on your consent prior to its withdrawal. This revocation may be made through the forms, contents and private settings provided by MULTIASISTENCIA, depending on each case (for example, requesting cancellation of the newsletter service requested through the link provided at the end). However, you can always send this request via e-mail: privacy@multiasistencia.com or dpd@multiasistencia.com so that your right can be properly enforced as described in the applicable regulations.
Right to file a complaint with the competent supervisory authority (AEPD) It means the ability to approach the supervision authority if you believe your rights of protection of personal data have been breached (articles 13 and 14 of GDPR). We recommend that before filing any complaint or claim with the Spanish Data Protection Agency (AEPD), contact us in order to analyse the specific situation and try, where appropriate, to find an effective and friendly solution. Apart from the above, if you wish, you can also refer to the AEPD website. www.aepd.es

12. ARE THERE SECURITY AND PROTECTION MEASURES IN PLACE FOR YOUR PERSONAL DATA?

Considering the nature, scope, context and the indicated purposes of processing, as well as the risks of diverse probability and seriousness for your rights and freedoms, MULTIASISTENCIA takes (and will take) appropriate technical and organisational measures in order to ensure the due security and protection of your personal data according to privacy criteria by design and by default, as well as applying a concurrent risk approach system that will be reviewed and updated by MULTIASISTENCIA when necessary.

13. CHANGE OF THE PRIVACY POLICY

MULTIASISTENCIA reserves the right to change this policy to adapt it to new laws, doctrines or case law that may apply in the future, or owing to technical, operational, commercial, corporate and business reasons, informing you beforehand and in a reasonable manner of any changes that may occur whenever possible. In any case, we recommended you to read this policy in detail each time you visit this platform, as any changes will be published through it.

Likewise, MULTIASISTENCIA may inform you personally and beforehand of the changes listed in this policy before it comes into force, provided that this is technically and reasonably possible.

14. DO YOU NEED TO CONTACT US?

In case of any question or suggestion that you wish to send us regarding this policy, please feel free to contact our DPD at the below contact details:

Address for correspondence: Ronda de Poniente, 7, 28760, Tres Cantos, Madrid
Contact email: dpd@multiasistencia.com

15. APPLICABLE LAW AND JURISDICTION

In general, any controversy and conflict shall be preferentially brought to the notice of the parties for the purpose of seeking a friendly and mutually agreed solution through the use of the channel and e-mail provided in section 14 of this policy. If this is not possible, in accordance with the criteria set out in the GDPR for determining the competence of the leading or principal authority in order of acknowledgement of any conflict, controversy or claim regarding this privacy policy, at least through administrative channels, it is hereby informed that such authority shall be the Spanish Data Protection Agency (AEPD), and in all cases the provisions of article 56 of GDPR shall be complied with. With regards to the right to effective legal protection against MULTIASISTENCIA in these cases, the provisions of article 79.2 of GDPR shall also apply, and relevant actions may be brought before the Judges and Courts of the City of Madrid to the extent that the liable entity is a company based in Spain. The current Spanish and European regulations applicable in this area shall be complied with.