PRIVACY POLICY


Smart Process Management S.L. (hereinafter, SMARTPM) Privacy Policy is governed by compliance with current legislation on personal data protection.



Data processing manager

Personal data which may be directly collected from the data subject will be processed confidentially and included the corresponding processing activity of the owner SMARTPM with registered office at Calle Morkaiko 1, 20870 Elgoibar, Gipuzkoa (Spain).

The user may contact the Data Protection Officer to solve any queries related to the processing of his/her personal data at the foregoing postal address or via e-mail to info@smartpm.es addressed to the Data Protection Officer.

The purpose of processing your personal data

Data provided via the different forms included in the SMARTPM web or any of its departments’, likewise, via the different administrative procedures which may be started by SMARTPM, will be solely and exclusively processed for the purposes of each form or administrative procedure and for inclusion in the Body’s information systems.


Data processing purposes corresponds to each of the processing activities performed by SMARTPM

Moreover, when you visit our web, data are automatically sent from your browser to our server to optimise our services and improve your user experience.


 For further information see the Cookies Policy

Types of data

Personal data may be collected via digital and physical forms housed on this web site, via email; and automatically via cookies on visiting our web site.


The types of data recorded via forms and email address are:

  • CV submission Form: Personal identification data, Personal contact data, Professional profile, CV, Candidate’s message.
  • Contact form: Personal identification data, Personal contact data, Business Unit consulted and Query.

In addition, via the web page, data may be collected regarding the user’s IP address, time and date of visit, URL of the web site visited, pages visited on our web site or regarding the browser used. For further information see the Cookies Policy.

Data source

The source of data contemplated in the processing object of this document is the data subject in question or his/her legal representative, considering natural persons or corporate bodies acting on his/her behalf; private bodies who have his/her express prior consent to use his/her data and convey them to us; Public Administrations; likewise sources with public access (official gazettes, official web sites of private bodies, Administrations and Public Bodies, etc.)


On conveying data they guarantee they are enabled to provide information; which is certain, true, accurate and up-to-date; and that it does not involve identity theft.

Should this not be the case, the data subject undertakes to accept liability for any infringement or fine which might be imposed on SMARTPM due to said non-compliance with regulations on personal data protection.

Legal Basis for Data Processing

Processing of users’ data is to ensure the quality of the services SMARTPM offers or the execution of a contract. It may also be based on the consent of the data subjects, which must be given via a clear affirmative action.


The legal bases of each of these activities of processing data collected can be consulted in the legal disclaimers attached to each form.



Your data storage periods

The personal data provided will be stored for the necessary period to comply with the purpose for which they were collected and to determine possible liabilities which might derive from the purpose, as well as the time periods established in the file and documentation regulations.

Addressees to whom we can notify your data

Data provide by you to us may be disclosed to third parties in compliance with those purposes directly related to legitimate functions of both parties, as well as to those bodies or institutions where there is a legally mandatory obligation to disclose data.

Furthermore, we hereby inform you that SMARTPM has subcontracted the services for hosting, supporting and maintaining the systems which carry out the personal data processing to data processors located in the European Union.

In the event of suppliers located outside the EU having access to personal data to render any auxiliary service, we shall carry out a selection ensuring sufficient guarantees are established to uphold the European requirements on data protection.

Security measures

SMARTPM will adopt the necessary organisational and technical measures to ensure the security of the personal data and prevent their change, loss, unauthorised access and processing, taking into account: the state-of-the-art technology, the nature of data stored and the risks to which they are exposed, all be they are due to human action or the natural or physical medium.

Data subject rights

Moreover, pursuant to the rights granted under current data protection legislation, you may exercise the rights of access, rectification, restriction of processing, erasure, portability and objection to the processing of your personal data. To this end, you must make a signed written request attaching a photocopy of your ID (DNI, etc.) or any other document accrediting your identity to the foregoing postal address or via Email info@smartpm.es. Should you wish to modify your personal data, you must also notify the same via any of the aforementioned addresses.

Likewise, the data subject may contact the competent Control Authority (the Basque Data Protection Agency, Basque Country) to lodge any complaint deemed appropriate. Should you require further information regarding the rights you may exercise and to request forms to exercise your rights, visit the Basque Data Protection Agency web page, http://www.avpd.es.