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Policy of Privacy

€TcmAdvisory€ informs to the users into the website on their policy with respect to the treatment and protection into the personal character data into the users and clients who can be successfully obtained by navigation, acquisition of products or hiring of services through their website. In this sense, €TcmAdvisory€ guarantees the fulfillment of the effective norm in the matter of protection of personal data, reflected in Statutory law 15/1999 of 13 of December, Protection of Personal Character data and in Real Decreto 1720/2007, of 21 December, by that the Regulation of Development of the LOPD is approved, and in General Regulation of Protection of Datos (RGPD) (the EU) 2016/679.


In accordance with the effective legislation in the matter of protection of data, one inquires to the users into which, in €TcmAdvisory€, the technical and organizational measures according to the arranged thing in the normative mentioned one have been adopted. The personal data that take shelter in the forms are treatment object, only, on the part of the personnel of €TcmAdvisory€ or of the Ones in charge of the Treatment here established. The suitable safety measures to the data have been adopted that are facilitated and, in addition, have settled all the means and technical measures to their reach to avoid the loss, evil use, alteration, nonauthorized access and robbery of the data that they facilitate to us.


The Client or User declares that all the data facilitated by him are certain and correct and is committed to maintain updated them, communicating, to €TcmAdvisory€, any modification of the same. The user will respond of the veracity of his data and will be the only person in charge of whichever conflicts or litigations could be by the falsification from the same. It is important that, so that we can maintain the up-to-date personal data, the usuary report to €TcmAdvisory€ whenever there has been some modification in the same. On the contrary, we cannot respond of his veracity.


The LOPD and the RGPD grant interested to the possibility of exerting a series of rights related to the treatment of its personal data. While the data of the user are object of treatment on the part of €TcmAdvisory€, these will be able to exert their rights. For it, the user will have to go, contributing documentation that credits its identity (national identity document or passport), by means of e-mail to info@tcmadvisory.com, or by means of written communication to the direction that appears in our legal warning. This communication will have to reflect the following information: Full name of the user, the accrediting request of request, address and data.

The exercise of rights will have to be realised by the own user. However, they could be executed by an authorized person as legal representative of the authorized one. In such case, the documentation will be due to contribute that credits this representation of the interested one.

The user will be able to ask for the exercise of the following rights:

  • Right to ask for the access to the personal data.
  • Right to ask for its rectification (in case they are incorrect) or suppression.
  • Right to ask for the limitation of their treatment, in which case the exercise or the defense of claims will only be conserved by €TcmAdvisory€ for.
  • Right to be against to the treatment: €TcmAdvisory€ will stop treating their data, unless by legitimate reasons or the exercise or the defense of possible claims they must continue trying.
  • Right to the portability of the data: in case it wants that their data are treated on the other signature, €TcmAdvisory€ will facilitate the portability to him of their data to the new person in charge.

In case the consent for some specific purpose has been granted, the user must right to retire the consent at any time, without it affects to the legality of the treatment based on the previous consent to its retirement.

If a user considers that there is a problem with the form in which €TcmAdvisory€ is handling their data, it can direct to his claims to the Person in charge of Security or the authority of protection of data that corresponds, being the Spanish Agency of Protection of Data the indicated one in the case of Spain.


The released data will be conserved without term of suppression. As far as the data of Clients, the period of conservation of the personal data will vary based on the service that the Client contracts. In any case, it will be the necessary minimum, being able to even stay:

  • 4 years: Law on Infractions and Sanctions in the Social Order (obligations in the matter of affiliation, discharges, losses, quote, payment of wages€¦); Arts. 66 and sig. General law Tributaria (accounting books€¦)
  • 5 years: Art. 1964 Civil Code (personal actions without special term)
  • 6 years: 30 Art.s Code of Commerce (books of accounting, invoices€¦)
  • 10 years: 25 Art.s Law of Prevention of the Financing and Money laundering of the Terrorism.

The users of mail lists or raised by €TcmAdvisory€ pages or the profiles of RRSS, will conserve themselves until the user retires the consent.

Data of candidates (H.P.), having them: In case the candidate is not selected, €TcmAdvisory€ will be able to maintain stored to their curriculum a maximum of two years to incorporate it to future calls, unless the candidate pronounces himself in opposite.


€TcmAdvisory€ must have to inform to the users of their website about the collection of personal character data that can be carried out, or is by means of the shipment of e-mail or when complimenting the forms including in the website. In this sense, €TcmAdvisory€ will be considered as Person in charge of the data successfully obtained by means of means previously described.

€TcmAdvisory€ informs as well to the users into which the purpose of the treatment of the successfully obtained data contemplates the attention of requests realised by the users, the inclusion in the agenda of contacts, the product benefit or services and the management of the trade relation. The technical operations, managements and procedures that are realised of automated or not automated form and which they make possible the collection, the storage, the modification, the transference and other actions on personal character data, have the consideration of personal Data processing.

The Website of €TcmAdvisory€ counts on a coding SSL, that allows the User the safe shipment of its personal data through the forms of contact of the website.

€TcmAdvisory€ puts at the disposal of the users a series of telematics mechanisms for the collection and treatment of their personal data, with the predicted purposes previously. The personal data provided of way Telematics, or are through email, of the forms of contact of this Web or hirings online the clients and users of the company will be used for the commercial and administrative management of. These data, will be treated through servers managed by https://www.overant.com/ and https://www.cyberneticos.com/, that also is the lending company of services of e-mail, and, that will have the consideration of In charge of the Treatment.

As it establishes the LSSICE, €TcmAdvisory€ is committed not to send commercial communications without identifying them as such. To this end, the information sent to the clients for the maintenance of the existing contractual relation will not be considered as commercial communication.

In any case, the data precise will only be obtained to be able to realise the contracted service, or to be able to respond suitably to the request for information realised by the user.

Sometimes, the personal data will be provided through connections to websites of third parties. In this case, at no moment the personnel of €TcmAdvisory€ will have access to the personal data that the Client facilitates to these third parties.


€TcmAdvisory€ counts on profile in main the social networks of Internet (Facebook), being clear in all the cases Responsible for the treatment of the data of their followers, fans, subscribers, commentators and other profiles of users (in future, followers) published by €TcmAdvisory€. The treatment that €TcmAdvisory€ will carry out with these data within each one of the referred networks will be the one that the social network allows the corporative profiles.

€TcmAdvisory€ will be able to inform to their followers, when the law does not prohibit it, by any route that the social network allows on its activities and supplies, as well as to serve customized of attention to the client. In no case €TcmAdvisory€ it will extract data of the social networks, unless the consent of the user for it were obtained specifically precise and (for example, for the accomplishment of a contest).


The aspiring who sends electronic communications to €TcmAdvisory€, in order to accede to the processes of selection of personnel of the Organization, authorizes to us to analyze the documents that sent (for example, the H.P.), all the content that is directly accessible through finders of Internet (for example, Google), the profiles that maintains in professional social networks (for example, LinkedIn), the data collected in the access tests and the information that reveals in the work interview, with the aim of valuing its candidacy and power, where appropriate, to offer a position to him. In case the candidate is not selected, €TcmAdvisory€ will be able to maintain stored their H.P. during a maximum of two years, to incorporate it to future calls, unless the candidate shows the opposite.


€TcmAdvisory€ will not yield nor will communicate to any third party your data, except in the legally anticipated cases or when the benefit of a service implies the necessity of a contractual relation with the one in charge of treatment, and always in agreement with the general conditions approved by the user prior to the hiring of the same. Thus, when contracting our services, the user accepts that some of the same can be, total or partially, subcontracted to other people or companies, that will have the consideration of In charge of the Treatment, with which has been suitable the corresponding contract of confidentiality, or adhered to his policies of privacy, settled down in his respective webpages. Also he accepts that some of the successfully obtained personal data are facilitated these Ones in charge of the Treatment, when is necessary for the effective accomplishment of the contracted service. The user will be able to refuse to the cession of your data to the Ones in charge of the Treatment, by means of written request, by anyone of previously referenced means.


The information provided by the client will have, in any case, the consideration of confidential, without it can be used for other aims that related to the services contracted or acquired products €TcmAdvisory€. €TcmAdvisory€ is commited not to disclose nor to reveal information on the pretensions of the client, the reasons for the asked for advising or the duration of their relation with this.


This policy of privacy and protection of data has been written up by EXPERTS LOPD