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 AP SOLUTIONS GMBH, SUCURSAL EN ESPAÑA (hereinafter, “AP SOLUTIONS” or “we”) capital company duly registered in the Companies Register of Madrid, Sheet number M-842041, Entry 1, with C.I.F. W0328067D, and domiciled at C/Ramírez de Arellano, number 35, 28043, Madrid, Spain.

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 AP SOLUTIONS 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 AP SOLUTIONS, 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 AP SOLUTIONS.

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: AP SOLUTIONS GMBH, SUCURSAL EN ESPAÑA
Registered address: C/Ramírez de Arellano, número 35, 28043, Madrid, España
Physical address/office: C/Ramírez de Arellano, número 35, 28043, Madrid, España
Contact phone no/s: +34 91 748 67 68
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 AP SOLUTIONS?

AP SOLUTIONS 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: C/Ramírez de Arellano, número 35, 28043, Madrid, España
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, AP SOLUTIONS, other companies of the Allianz Group 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?

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?

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 AP SOLUTIONS, 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 AP SOLUTIONS (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 AP SOLUTIONS 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 AP SOLUTIONS 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, AP SOLUTIONS 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 AP SOLUTIONS 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?

Your personal data will be processed within the European Economic Area (EEA). In the event that they are communicated outside the EEA, it will always be in accordance with applicable data protection laws and regulations. We will not disclose your personal data to recipients who are not authorised to process it.

In the event that we transfer your personal data outside the EEA to another company in the Allianz Group, to which AP SOLUTIONS belongs, we will do so in accordance with and in accordance with the provisions of the approved binding corporate rules of Allianz ("BCR ALLIANZ") which provide adequate protection for the processing of personal data and are legally binding on all companies in the Allianz Group. The document and the list of Allianz Group companies that comply with them can be accessed and consulted at the following link https://www.allianz-partners.com/allianz-partners---binding-corporate-rules-.html. Where Allianz's BCRs cannot be applied, we will instead take steps to ensure that the transfer of your personal data outside the EEA always receives an adequate level of protection as it does in the EEA.

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

In accordance with the applicable legal provisions, you have the right to:

• Access your personal data and know the origin of the data, the purposes and purposes of the processing, the categories of personal data processed, the identification data of the data controller and the recipients or categories of recipients to whom the data may be communicated.
• Update or correct your personal data so that it is always accurate.
• Delete your personal data from our records in case it is no longer needed for the purposes stated above.
• Limit the processing of your personal data to certain circumstances, such as where you have disputed the accuracy of your personal data for the period necessary to verify its accuracy.
• Obtener una copia de tus datos personales objeto de tratamiento en formato electrónico para el titular y a transmitirlos a otro responsable del tratamiento que nos indiques.
• Withdraw your consent at any time in cases where the processing of your personal data is carried out based on the express consent given.
• In the cases permitted by applicable law or regulation, you have the right to object to the processing of your personal data or to request that the processing cease for any of the purposes indicated. Once we have received your request, we will cease processing your personal data, except in the cases and cases permitted by law.

You can request the exercise of your rights, by writing to the email dpd@multiasistencia.com.

You may submit a complaint or claim regarding your rights and interests in the field of data protection at any time to the Spanish Data Protection Agency (https://www.aepd.es), C/ Jorge Juan, 6 (28001) Madrid.

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, AP SOLUTIONS 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 AP SOLUTIONS when necessary.

13. CHANGE OF THE PRIVACY POLICY

AP SOLUTIONS 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, AP SOLUTIONS 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 DPO at the below contact details:

Address for correspondence: C/Ramírez de Arellano, número 35, 28043, Madrid, España
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 AP SOLUTIONS 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.