Procesamiento de los datos (personales) por parte de la entidad encargada del procedimiento de candidatura de empleo en línea
Privacy policy
In the following Privacy Policy, you will find a differentiated detail on the processing of personal data that is carried out through the website and the App. Due to its nature, it is expressly informed that the data processing carried out through the Website is carried out on behalf of HEYTRADE TECH, S.L. C/Serrano 88, 2°, 28006, Madrid (hereinafter HEYTRADE), and the data collected through the App is data relating to the investment contracting process in which HEYTRADE acts as agent for BEKA FINANCE, SOCIEDAD DE VALORES, S. A. C/ Marqués de Villamagna nº 3, 28001 Madrid (hereinafter, BEKA) in which BEKA will be Data Controller and HEYTRADE will act as Data Processor.
1. Personal Data Protection Delegate
The main function of the Data Protection Delegate (DPD) is to advise and supervise compliance with current legislation on the protection of personal data, as well as to serve as a liaison between the data controller and the Spanish Data Protection Agency.
- For questions concerning HEYTRADE processing, please contact the DPD at the following e-mail address: dpo@heytrade.com.
- For questions regarding BEKA’s processing, please contact the DPD at lopd.sv@bekafinance.com.
2. Processing of data obtained through the Web site
2.1. Who is responsible for the processing of your data that are made through the Web site?
In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 and with the rest of the applicable legislation in Spain regarding the protection of personal data, we hereby inform you that the personal data provided when completing and sending the forms published on the Website will be processed by HEYTRADE as data controller.
2.2. For what purpose and on what basis do we process the data obtained through the Web site?
- To respond to queries for information about HEYTRADE. Legal basis of legitimacy: the express consent you provide by ticking the acceptance box on the web form (Art.6.1 a) RGPD).
- For the management of resumes of job candidates. Legal basis of legitimacy: the express consent you provide by ticking the acceptance box on the web form (Art.6.1 a) RGPD).
- For sending the newsletter. Legal basis of legitimacy: the express consent provided by ticking the acceptance box on the web form (Art.6.1 a) RGPD).
2.3. To whom will we communicate your personal data as a web user?
- To external technology service providers, such as maintenance services and IT services, legal services, and consulting services, who will process your data strictly in accordance with HEYTRADE’s instructions.
- Where appropriate, to third parties such as bodies, agencies and institutions of the General State Administration, regional and local administrations; jurisdictional bodies, and State Security Forces and Corps.
2.4. How long will we keep your data as a user of the Web?
- Personal data obtained through the contact form or request for information will be kept only for the time necessary to attend and follow up on your request.
- Personal data relating to job applicants will be retained for a period of one year from the date of completion of the selection process. However, in the event that the candidate is selected, his or her curricular data will be kept for the purpose of managing the employment relationship.
- Personal data processed for the purpose of sending communications will be processed until the user opposes or withdraws consent to continue receiving them.
3. Processing of data obtained through the App
3.1. Who is responsible for the processing of your data through the App?
In this case HEYTRADE, as agent, acts on behalf of BEKA, so BEKA will be responsible for the processing of the data and HEYTRADE in this process acts as Data Processor.
3.2. What data is processed as a user of the App?
HEYTRADE, in the name and on behalf of BEKA will process data of an identifying nature, socio-economic data, solvency and risk data, fraud and, if so chosen, may also process biometric data, derived from the established procedure of identity verification of natural persons through the video-identification system that is provided by a service provider specialized in this type of solutions.
The data that are subject to processing are obtained through the following means, if applicable: (i) those that the User provides at the time of registration, specifically the email and user, as well as the telephone number – if applicable, (ii) the information generated from their use and interaction with the App such as metadata, comments, suggestions, complaints, telephone conversations, queries, requests or contracting of any product, of any transaction or operation, etc., (iii) forms for obtaining information, (iv) from third party databases for money laundering and fraud prevention purposes, (v) from various public sources and (vi) from public agency records.
The personal information that is mandatory for each form is identified as such. The refusal to provide such information will prevent communication to the user and, where appropriate, the impossibility of providing the requested information and/or contracting.
3.3 What is the purpose and legitimacy of the processing of your data as a user of the App?
As detailed above, HEYTRADE will be in charge of the processing of the data related to the fulfillment of legal obligations and the provision of investment services under the responsibility of BEKA. In the case of contracting these services, you will be informed in more detail about the processing of your personal data in the Custody and Administration Agreement of financial instruments, as well as in the General Conditions of the contract for the provision of the service of reception and transmission of orders.
- Provision of the service: managing and maintaining your registration on the Platform. The basis that legitimizes this treatment is the execution of the contract (art.6.1 b) RGPD).
- Compliance with legal obligations: HEYTRADE will process personal information that is necessary to comply with the legal requirements demanded by the regulations indicated, as a guideline, the Law on the Prevention and Fight against Money Laundering and Terrorist Financing, MIFiD regulations or tax regulations that will involve prior assessment of whether the product is suitable for the needs of this investor and various communications of data to both national and international authorities (art.6.1 c) RGPD).
- Recording of telephone and electronic communications: Also in compliance with the applicable regulations, it may record telephone conversations or electronic communications that are held both for the purpose of providing information on the investment services provided and during the use of the same (art.6.1 c) RGPD).
- Sending communications in compliance with the regulation: Communications will be carried out in compliance with MIFID regulations with the aim of improving the quality of the information made available to the client(art.6.1 c) RGPD).
- Sending of commercial communications: BEKA may, on the basis of Law 34/2002 of Services of the Information Society and Electronic Commerce, send commercial communications about products and services similar to those contracted. In the event that you do not wish to receive such communications, you may oppose to such treatment by sending an e-mail to the address privacy@heytrade.com. This opposition can be exercised at the time of recruitment as through the mechanism contained in each communication you receive.
3.4. To whom will we communicate your personal data as an App user?
Your data may be communicated:
- To those third parties, public bodies and institutions of the General State Administration, regional and local administrations, the National Securities Market Commission, the Tax Agency, SEPBLAC, including the jurisdictional bodies to which it is legally obliged to provide them.
- Distributors of the investment instruments and investment platforms and the SGIIC and the investment depositary.
- Likewise, in order to carry out all the purposes described above, HEYTRADE (as agent of BEKA) may count on the collaboration of third party service providers that may have access to personal data as a consequence of the execution of the contracted services such as technological services necessary for the App, as well as electronic identification. In any case, HEYTRADE follows strict criteria for the selection of such third parties in order to comply with its data protection obligations and signs with them the corresponding data protection contract, where these third parties are obliged to comply with their data protection obligations, and specifically, to comply with the legal, technical and organizational measures, to process personal data for the agreed purposes, and the prohibition of processing such personal data for other purposes or transfer to third parties.
No international data transfers are foreseen.
3.5. About the conservation of data as a user of the App
The personal data of customers will be retained for as long as the contractual relationship with them is maintained. In this sense, HEYTRADE, in the name and on behalf of BEKA, will keep the personal data duly blocked once the contractual relationship is terminated, for the period of limitation of the actions that may arise from the relationship maintained with the interested parties, specifically, 10 years. Except for your email, which will be kept until you object to the processing of this for sending commercial communications.
4. Processing of biometric data
Biometric data will not be used for purposes other than verification of your identity. Biometrics is a facial identification tool that helps us to prevent fraud, increases the reliability of operations and helps us to ensure that the person is the holder of the ID that is being shared with us. The basis of the legitimacy of the processing of biometric data is the consent of the person who wants to open an account (art.6.1.a) of the RGPD), since when the contracting occurs, the user accepts to open the account with biometric data.
- Opening an account with biometric data is a quick process that can be completed in just a few minutes.
We store the biometric data (photos and video) to verify your identity.
5. Information about cookies
We inform you that we use cookies to facilitate your navigation on the website and the App, to know how you interact and even send you advertising based on your browsing habits.
The acceptance of some of these cookies may involve the transfer of data to third countries necessary for the operation of the services of our suppliers. You can learn more about this in our Cookie Policy.
If you want to know more detail about the cookies we use, their purpose and other information of interest, see our Cookies Policy.
6. What are your data protection rights?
The interested parties have the right to access, rectify, delete, oppose, limit the processing, request the portability of their personal data and not to be subject to automated individual decisions in the terms specified in the applicable regulations on data protection, by means of a communication addressed to privacy@heytrade.com or to the postal address indicated in the first section, proving their identity and specifying the right they wish to exercise. In the event that the exercise of such rights is related to processing carried out by HEYTRADE in the name and on behalf of BEKA, HEYTRADE will transfer to the latter to respond to any request received on its behalf or you can exercise them directly to BEKA through the address info@bekafinance.com.
We inform you that in the event that you consider that any of your rights relating to the protection of your data have been violated, you may file a complaint with the Spanish Data Protection Agency www.aepd.es.
7. Commitments of the User
The user undertakes to inform HEYTRADE of any changes to the information provided. In order to make such communication, you may contact the account privacy@heytrade.com.