Privacy policy

Last update: Febrero 2024

Contact information

Comercial designation
Legal entity	GENE VECTOR BARCELONA, S.L. and any of its Affiliates (collectively, “Gene Vector” or “we”).
Location	C/ de Pallars, 179 – 185, 08005, Barcelona
CIF	B-67734137
Email	info@genevectorbcn.com
Phone number	+34 93 788 23 00
DPO	aalonso@badia-adv.com

Welcome

We welcome you to our Privacy Policy intended for any Interested Party.

In this Policy we explain what Personal Data we process in the development of our activities, or derived from the use you make of our Website(s) or App(s), or when you interact in any other way with Gene Vector.

To facilitate its understanding, the Policy includes terms in capital letters whose meaning you can consult in the “definitions” section.

Remember that you have the right to file a claim with a Control Authority. However, we would appreciate it if you contact us first, to have the opportunity to resolve any questions, complaints, suggestions or comments that you wish to send us.

What Personal Data we process and for what purposes

Professional contacts

• Our team (employees, interns, interns, managers, collaborators, advisors, participants in selection processes, etc.).
• Suppliers, clients and investors.

Data Origin

Gene Vector obtains the Personal Data from the Interested Party himself and/or from the entity in whose organization the Interested Party carries out his professional work (clients, suppliers, advisors and other interlocutors of Gene Vector).

We do not obtain data from other third parties or other sources.

Recipients

We do not share Personal Data with third parties, except with public administrations to the extent necessary to comply with legal obligations (for example, labor or tax).

Legal Bases

Consent

• We will request your Consent to send you commercial communications electronically, unless you have requested them, or unless to inform you about news related to our products and services in the event that you are already a client or user, always offering you the possibility of telling us, simple and free, that you do not wish to continue receiving such commercial communications.
• Likewise, we will request your Consent to use Cookies that are not strictly necessary.
• In all cases where we process your Personal Data based on your Consent, you have the right to withdraw it at any time.
• The withdrawal of Consent will not affect the legality of the Treatment based on the Consent prior to its withdrawal.
• We strive to make it as easy for you to withdraw Consent as it is to give it, if you have any problems contact us.

Execution of a contract

We may process data that is necessary for the execution of a contract in which you are a party as an Interested Party or for the application at your request of pre-contractual measures.

Compliance with a legal obligation

Some of the data we process for the management of labor relations is necessary for the fulfillment of obligations and the exercise of specific rights of Gene Vector or the Data Subject in the field of Labor Law and Social Security.

Legitimate interest

• Treatment of professional contacts with suppliers, clients and other interlocutors for the management of the respective professional relationships.
• Processing of technical or usage data of our Website(s) and App(s) to the extent necessary for their functionality and security.

Direct marketing, Automated decisions, Profiling and International Transfers

Our product(s) are not intended for natural persons.

We do not carry out commercial actions aimed at natural persons, nor Automated decisions or Profiling.

Nor do we transfer Personal Data outside the European Union, except for pure storage on the platforms of our technology providers whose server location does not depend on us; If we carry out any International Transfer, it will be to countries with an adequacy decision confirmed by the European Commission, or failing that, with adequate guarantees (such as the signing of standard data protection clauses adopted by the European Commission or a Supervisory Authority, a code of conduct or a certification mechanism together with binding and enforceable commitments to apply appropriate safeguards, including those relating to the rights of Data Subjects), and provided that Data Subjects have enforceable rights and effective legal actions.

Minors

Our Website(s) and App(s) and this Privacy Policy are not directed to minors.

Our Website(s) and App(s)

This Privacy Policy applies to our Website www.genevectorbcn.com and any other of our Websites, unless otherwise indicated or a specific privacy policy is included.

Our Websites and Apps may include links to third-party websites and applications. Clicking on those links or enabling those connections may allow third parties to collect or share Personal Data about you. We do not control these third-party websites and applications and are not responsible for their privacy policies or practices.

Your rights and how we protect them

The Applicable Regulations recognize the following rights to the Interested Party:

• Access to your Personal Data that we process, and to receive information about the categories of data, purposes, Recipients, expected conservation periods or criteria for its determination, etc.
• Rectification of inaccurate Personal Data that concerns you, and for incomplete data to be completed.
• Deletion (“forgetting”) of Personal Data that is no longer necessary in relation to the purposes for which it was collected or otherwise processed; or in cases where you withdraw your Consent; or in certain cases of opposition; or if the Personal Data has been processed unlawfully.
• Limitation of temporary blocking of your data in certain cases (inaccuracy, illegality, non-necessity, opposition), so that they can only be used with your Consent.
• Portability right to receive your Personal Data in a structured, commonly used and machine-readable format, or to transmit it to a third party that you indicate, in cases where the treatment is based on Consent or a contract and the treatment is carried out by automated means.
• Opposition to your Personal Data being processed based on our legitimate interest, for reasons related to your particular situation, particularly when the purposes are direct marketing, Profiling, scientific research or statistical purposes.
• Right to human intervention in the processing of your Personal Data, and in particular not to be subject to Automated decisions, including Profiling.

We promise to respond to your requests quickly, and in any case, within one month.

If the complexity or the number of requests received requires it, we may need to extend our response times, a maximum of another two months, in which case we will inform you of the corresponding extension and the reasons for the delay.

If we consider that it is not appropriate to process your request, we will inform you without delay (maximum 1 month) of the reasons and the possibility of submitting a claim to a Control Authority and taking legal action.

All communication with us to exercise your rights will be free of charge. However, if your request is manifestly unfounded or excessive, especially due to its repetitive nature, we may charge a reasonable fee based on the administrative costs incurred to provide the information or communication or perform the requested action, or refuse to act in respect of it. application.

If we have reasonable doubts regarding your identity as an applicant individual, we may request that you provide us with additional information to confirm your identity. Please note that there may be situations in which we have deleted any identifying data of yours if it is no longer necessary for the purposes that initially justified its Treatment, and therefore in such cases we will not be able to respond to your request unless you provide us with additional information that allows your identification .

Organizational and security measures

Access to our information systems is protected by individual user accounts and passwords.

We establish means to protect information from possible external intrusions and data loss through appropriate measures, including antivirus, backup copies for both data stored locally and in the cloud, periodic changes of keys or others such as encryption or double authentication systems as appropriate. possible.

In cases of Security Breaches, we will adopt the appropriate technical and organizational protection measures, and if appropriate in accordance with the Applicable Regulations, we will communicate it publicly or individually, and without undue delay, when it is likely to entail a high risk, making every effort to ensure that you have clear information about the nature of the Security Breach including, a) where possible, the categories and approximate number of Data Subjects and Personal Data records affected; b) the contact details of our Data Protection Officer or other contact point where further information can be obtained; c) the possible consequences; and d) the measures adopted or planned.

Conservation periods

We retain the data for the periods necessary to:

• Compliance with a legal obligation: Treatment (conservation) is necessary for compliance with a legal obligation, in accordance with the provisions of article 17.3. b) of the GDPR.
• Archiving purposes in the public interest, scientific and historical research, statistical purposes: When the data is processed for these purposes, it may be retained under articles 17.3.d) and 89 of the RGPD.
• Exercise or defense of claims: As established in article 17.3.e) of the RGPD in relation to article 24 CE (right to effective judicial protection), data may be kept when necessary for the exercise of rights or defense against claims.

Definitions

The following terms used in this Privacy Policy have the meaning assigned to them below:

Affiliates

It means the entities that are part of the “Gene Vector” group at any given time, as reported on our Website(s).

Control Authority

Means an independent public authority established by a Member State of the European Union in accordance with the provisions of the General Data Protection Regulation.

In Spain, it is the Spanish Data Protection Agency (AEPD) whose website is https://www.aepd.es/.

Security Breach

Means any incident that compromises the security of Personal Data causing the accidental or unlawful destruction, loss or alteration of Personal Data transmitted, preserved or otherwise processed, or unauthorized communication or access to said data.

Consent of the Interested Party

It means any free, specific, informed and unequivocal expression of will by which the Data Subject accepts, either through a declaration or a clear affirmative action, the Processing of Personal Data that concerns him or her.

Cookies

Cookies are small text files that websites place on your device while you browse. They are processed and stored by your web browser. In themselves, cookies are harmless and perform crucial functions for websites. Cookies can usually also be viewed and deleted easily.

In general, there are three different ways to classify cookies: what they are for, how long they last and where they come from.

You can consult our Cookies Policy below.

Personal information

It means all information about an Interested Party.

Automated decisions

These are decisions that may affect the Interested Party and that are based solely on automated means, such as algorithms and artificial intelligence, that process their Personal Data, without human intervention.

Addressee

Means the natural or legal person, public authority, service or other body to which Personal Data is communicated.

ePrivacy Policy

Means Directive 2002/58/EC of the European Parliament and of the Council, of July 12, 2002, on the processing of personal data and the protection of privacy in the electronic communications sector.

Creating Profiles

Means any form of automated processing of Personal Data consisting of using Personal Data to evaluate certain personal aspects of a natural person, in particular to analyze or predict aspects related to professional performance, economic situation, health, personal preferences, interests, reliability, behavior, location or movements of said natural person.

Interested

Means any identified or Identifiable natural person whose Personal Data is the subject of Processing by Gene Vector.

Applicable regulations

As a company of Spanish nationality, Gene Vector is bound at the European level by the General Data Protection Regulation and the ePrivacy Directive, and by Spanish regulations, especially by Organic Law 3/2018, of december 5, of Protection of Personal Data and guarantee of digital rights, and Law 34/2002, of July 11, on information society services and electronic commerce.

Identifiable natural person

Means any person whose identity can be determined, directly or indirectly, in particular by means of an identifier, such as a name, an identification number, location data, an online identifier or one or more elements of physical, physiological, genetic, psychological, economic, cultural or social of said person.

Privacy Policy

Means this Privacy Policy.

General Data Protection Regulation

Means Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 regarding the protection of natural persons with regard to the processing of personal data and the free circulation of these data and by which repeals Directive 95/46/EC.

GENE VECTOR BARCELONA, S.L. and any of its Affiliates (collectively, “Gene Vector” or “we”).

B-67734137

International transfers

Means the transfer of Personal Data outside the European Union.

Treatment

Means any operation or set of operations carried out on Personal Data or sets of Personal Data, whether by automated procedures or not, such as collection, registration, organization, structuring, conservation, adaptation or modification, extraction, consultation, use, communication by transmission , dissemination or any other form of enabling access, collation or interconnection, limitation, deletion or destruction.

Website(s)

Means the website www.genevectorbcn.com and any other Gene Vector website(s).