This policy applies to visitors to this website (our Website), to users of the services that ADVANTIA ASSESSORS provides for the purposes described in section 4 of this policy (the “Services”), and to anyone whose personal data (such as their images) may appear on our Website or in connection with the services.

As stated in section 4, the party that is solely responsible for the use of your personal data is the owner of this Website:

Assessors Andorrans G&G SL (ADVANTIA ASSESSORS), with NRT L-708153-F and registered office at Carrer Bonaventura Armengol, 15, 3º 3ª, AD500 Andorra la Vella (Principality of Andorra).

We have an external Data Protection Delegate whom you can contact by email at dpd@parkpiolets.ad.

Additionally, if you are in the European Union, it will be of interest to you to know that our representative for the purpose of data protection is the company COMPLIANCE GAP MITIGATION, with registered office at Calle Ferraz 28, 2º Izq. 28008 Madrid, (Spain), whom you can contact by telephone on (+34) 917589441 and (+34) 915482701, or (preferably) by email at advantia@compliancegapmitigation.com 

ADVANTIA ASSESSORS is not responsible for the activities of other websites, even if they are linked to our website. Therefore, we strongly encourage you to carefully read the information provided by these other responsible parties before providing them with your personal information (in particular, the privacy and cookie policies of each website you visit), and to contact the relevant responsible party if you have any concerns or questions.

In general, you are the one who directly provides us with your personal information, for example by completing the forms on this website. The only exceptions to this rule are:

• Your image, if captured by our video surveillance cameras or our presence sensors;
• Information provided to us by third parties who request our services on your behalf (as a beneficiary);
• Contact details provided to us by our service and product providers when you are their representative;
• The last four digits of your credit or debit card, which will be returned to us by our payment service provider along with the amount of the purchase and the transaction number in the event that you wish to view or cancel the transaction;
• Photographs of events that we participate in or organise in which you may appear;
• Images relating to news stories where we consider that the public interest and the right to information outweigh any interests that may be held by the individuals whose image or other personal data are published on our website;
• The personal data that may appear about you in the emails that we receive; and
• The cookies of this website, about which you can find more information in our cookie policy.

To establish and maintain relationships with our suppliers
If you are representing a supplier of products or services, we will ask you to provide your contact details and to sign the form to:
a) Manage our relationships with the supplier you represent
b) Manage the addition of the supplier to our approved supplier list
c) Manage the budgets and invoices of the supplier you represent
The processing activities linked to purposes a) and b) are legitimised by the employment or service contract you have signed with the supplier you represent and by our legitimate interest in contacting them. And the processing activities linked to purpose c) are legitimised because they are necessary for the execution of the contract(s) you have signed with us.

To establish and maintain relationships with our clients
We collect your information that we receive verbally or in writing directly from you, or a third party you represent or for whom you are a beneficiary, when you contract a product or service from us, for the purpose of administering that contract.
We also inform you that, as a result of this contractual relationship, we may provide you with commercial information, either verbally or in writing, relating to the products or services you have contracted from us.
The processing of these data is legitimate since it is necessary for the execution of the contract for the services or products in which you have expressed an interest, and due to our legitimate interest in keeping you informed about the products or services you have purchased.

To maintain security with video surveillance
We capture your image through our video surveillance systems to ensure the safety of people, property and facilities.
The legal basis for the aforementioned processing is the public interest in public safety, our legitimate interest in the security of our facilities, and the legitimate interest of third parties who wish to seek judicial protection against a crime that may be evidenced by a section of a recording.

To select and hire our staff
We process the CV data you voluntarily submit to us in order to manage our relationship with you in regard to your application for employment with ADVANTIA ASSESSORS, including the process of searching, filtering and storing your CV as a potential candidate, the recruitment process and the hiring process.
The legal basis for the aforementioned processing activities is your consent which you provide when you send us your CV, the performance of pre-contractual measures, and, if we do not have an ongoing selection process or you are not recruited and we believe that you may be suitable for future selection processes, our legitimate interest in retaining your CV for the purpose of including it in such future processes. You may withdraw your consent or object to our legitimate interest as set out in section 7 of this policy. Doing so will have no effect other than the destruction of your CV (if you withdraw your consent) or limiting its storage to the selection process for which you sent us your CV.
We inform you that we will share your CV with Advantia Real Estate S.L. (the other company that is part of Advantia Assessors) and that the basis of the lawfulness of this transfer of data is our legitimate interest in offering you the opportunity to join the staff of this other company that is so closely associated with us. You may object to this transfer in accordance with clause 7; if you do so there will be no repercussions other than you will not be considered for any vacancies at this other Advantia Assessors company.

To send you news and information about our sector (newsletters)
We collect your email address when you subscribe to our newsletter for the purpose of keeping you updated on news and updates relating to our services or industry.
The legal basis for this processing is your consent, which you may withdraw at any time by exercising your rights, as set out later in this policy, or by clicking on the link at the bottom of each email. The only consequence of withdrawing your consent is that you will no longer receive the information we send you by email.

To manage your requests, enquiries or complaints
We collect the personal data you provide to us in your emails, by telephone or through the form on the Contact Us page, or through requests to exercise your rights, in order to respond to your requests, enquiries or complaints relating to our services or the rights you have over your personal data.
The legal basis for these processing activities is the consent you provide when you send or provide us with these data, our legal obligation to comply with your requests and our legitimate interest in serving you. The provision of your personal data is therefore voluntary, but if you do not provide them, we will not be able to process your request, query or complaint. You may withdraw your consent at any time, although any such withdrawal will make it impossible for us to process your request, enquiry or complaint.

To manage any future complaints
We retain the data that may be necessary to manage your potential complaints or claims, or ours, based on our legitimate interest in defending ourselves in order to protect our rights.

To ensure the functioning of our website (functional cookies)
We use functional cookies to collect, store, retrieve and process personal information (linked to you via unique identifiers or IP addresses) from the browser on your device to ensure the proper functioning of our website.
Since these are cookies that are necessary for the proper functioning of the website, their use does not require your express consent and the basis on which we may use them is our legitimate interest in being able to provide you with the services of our website.
For more information about these cookies, please refer to our cookie policy.

To compile aggregate statistics about the use of our website (analytics cookies)
We use analytics or statistics cookies to identify the least- and most-visited pages, to analyse which content is of most interest to our visitors and to measure the success of our information campaigns, all with the aim of improving the services we offer you through this website. All of these purposes provide aggregate results that do not identify the interests of any specific individual.
Since these are analytics cookies, we will not use them without your consent, and withdrawing or not providing your consent will have no effect other than inhibiting our aim of improving the website through the analysis of aggregated statistics on the browsing habits of our visitors.
For more information about these cookies, please refer to our
cookie policy.

To make the advertising you receive more interesting (advertising cookies)
We use advertising cookies from third parties.
These files help such third parties to infer your interests based on the pages you visit, the content you click on and other actions you take online.
Since these are not essential cookies, we will not use them without your consent. Failure to provide or the withdrawal of consent will have no effect, other than that your visit to our website may not be used to make the advertisements you receive more relevant to you.
You can find more information about these cookies in our cookie policy.

To enable the use of Google services

Additionally, as an obligation that Google LLC, a company of which Google Ireland Ltd is a subsidiary, imposes on entities like us that use the Google Analytics and Google Ads tools, we inform you that these two services are operated by Google Inc., with registered address at 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, and that Google Inc. is a beneficiary of these services.

The information generated by the cookies about your use of this website and your advertising preferences is generally transferred to and stored by Google on servers in the United States. If you wish to obtain more information, you may consult the page that describes how Google uses the information from our website and/or Google’s privacy policy regarding the aforementioned services.

We inform you that we have enabled the IP anonymisation feature on the Google service in order to add additional safeguards to the standard contractual clauses that protect this international transfer of data to the United States. Google will therefore shorten your IP address before sending it to the USA (the process of disguising your identity).     Only in exceptional cases is the full IP address sent to a Google server in the USA and shortened there. Google guarantees that it will not associate the IP address provided by your browser with any other data held by Google.

You can check the categories of personal data processed by these services at privacy.google.com/businesses/adsservices

For other purposes that are not incompatible with the above

We may also use your personal data for other purposes that are not incompatible with those listed above (such as archiving for reasons of public interest, scientific or historical research purposes, or statistical purposes), where permitted by applicable laws on the protection of personal data and, of course, in compliance with these and other applicable regulations.

We do not provide your personal data to anyone, unless:

• We are requested to do so by you.
• We are legally obliged to do so.
• You purchase our products or services through intermediaries (such as your adviser or agent) to whom we must deliver products or services which they have purchased on your behalf, either with your consent or because you have expressly instructed us to do so.
• You send us your CV and we think that it may be of interest to the other company that is part of Advantia Assessors: Advantia Real Estate SL.
• We are jointly responsible for data collection so that others can process it on our behalf, always with your consent. This is the case with:
  • Google Ireland Ltd, with registered office at 4 Gordon House Street, Barrow, Dublin, Ireland, to whom we have entrusted the processing of data from the cookies necessary to use its reCAPTCHA, Analytics and Ads services. Google Ireland Ltd acts as an independent controller for all processing carried out on its behalf in accordance with its Privacy Policy. We transfer data to Google Ireland Ltd on the basis of the data protection agreement that this EU-based company includes in the addendum to the standard contract for GDPR-compliant countries, such as Andorra, to which we add the additional safeguard of activating the anonymisation of the IPs that the cookies collect. Our cookie policy tells you which analytics and advertising cookies we use and how to configure them.
• We need to protect your rights, our rights, the rights of our employees, or the rights of third parties (who may require disclosure to the police for security reasons, or to health authorities to prevent the spread of disease, for example through contact tracing). For example:
  • If our video surveillance cameras record a theft on our premises; or
  • If a third party requests video surveillance images from us on the basis of their legitimate interest in seeking effective judicial protection with regard to the perpetration of a crime or compensation for damages that will be evidenced by the images provided, and with a commitment from said third party to use them exclusively for the purpose of reporting such crime or claiming the damages suffered, and to limit the transfer of images to the minimum necessary to achieve the purpose pursued.
• We require them to be processed by our service providers on our behalf and in accordance with the terms of the relevant data processor’s contract.

Any international transfer that we may need to make will be in accordance with the regulations that apply to us at any given time.

ADVANTIA ASSESSORS will only store your personal data for as long as is necessary to fulfil the purposes for which they were collected and, thereafter, for as long as is necessary to comply with any legal obligations that may be imposed on us as a result of such processing (including the obligation to be able to demonstrate that we have complied with your request for the erasure of personal data).

For example, we will retain CCTV footage for a maximum of 30 days if there are no incidents and, exceptionally, if a security incident occurs during this period or there is evidence that a crime has been committed (for example, theft), we will extract a copy of the section of the footage that shows the incident and retain it until it is handed over to the police or to the data subject who requests it from us in order to support their application for legal protection.

We will destroy your CV once it is more than five years old, as we then consider it to be out of date in relation to the purpose for which it would be used.

If we no longer have a legitimate purpose for processing some of your personal data, we will erase or anonymise them and, if this is not possible (for example, because they are stored on back-up copies), we will ensure that they are kept secure and blocked to isolate them from any further processing until they can be erased.

You have the right to obtain confirmation as to whether or not we have any of your personal data.

We remind you that when we share personal information with other data controllers, you must exercise your rights directly with them by following the instructions in their own privacy policies. Specifically, in relation to the data that our cookies share with Google, we inform you that you can install the add-on to prevent the sending of data from Google Analytics or Google Ads to Google Inc. on your Chrome, Internet Explorer, Safari, Firefox and/or Opera browser.

We explain the other rights you have and how to exercise them below.

Your rights

You can request that we enforce the following rights:

• Access to your personal data.
• Rectification of some of your personal data, specifying the reason.
• Erasure of some or all of your personal data.
• Restriction of the processing of your data, specifying the reason for the limitation.
• Opposition to the processing of your personal data.
• Portability of your data when the legitimate basis for collection has been consent or a contract.
• The right not to be subject to automated individual decision-making.

Where and how you can exercise your rights

You can exercise your rights:

1. 1. By sending a written request to ADVANTIA ASSESSORS, at our postal address indicated in section 2 of this policy, indicating a means of contact with you to enable us to respond to your request, or to request more information from you should this be necessary. Please mark the envelope “Exercise of personal data protection rights”.
   2. By sending an email or the form associated with the right you wish to exercise to the email address dpd@advantia.ad, indicating in the subject “Exercise of personal data protection rights”. You will find these forms below, in the relevant section of this privacy policy.

   In both cases, if it is not possible for us to verify that you are who you claim to be, we will ask you to kindly send us proof of your identity, this way we can ensure that we only respond to the data subject or their legal representative.

   Finally, and especially if you believe that you have not obtained full satisfaction from the attention given to the exercise of your rights, we inform you that you can submit a complaint to the national control authority, by contacting the Andorra Data Protection Agency (APDA).

Forms for exercising your rights

• In order to make it easier for you to exercise your rights, we recommend that you use one of the forms below:

  • Form for exercising the right of access
  • Form for exercising the right to rectification
  • Form for exercising the right to object (model A and model B)
  • Form for exercising the right to erasure
  • Form for exercising the right to restriction of processing
  • Form for exercising the right to data portability
  • Form for exercising the right not to be subject to automated individual decision-making

By providing us with your information, you guarantee that it is accurate and complete. You also confirm that you are responsible for the veracity of the personal data that you provide to us and that you will keep them up to date so that they correspond to your true circumstances, and that you will be liable for any false or inaccurate personal data that you may provide to us, as well as for any direct or indirect damage that may arise from your inaccuracy.

You may not provide us with the personal data of other persons unless this is justified in relation to the services you request from us. In any event, if you provide us with the personal data of a third party, it is your responsibility to inform such third party before providing them to us. The information that you are required to provide to third parties whose data you provide to us must include all the provisions set out in this Privacy Policy and you are responsible for ensuring that such personal data are lawful and for informing the data subjects of their rights in relation to their personal data.

In cases where you need to provide us with the personal data of a minor under the age of 16 or of a person whose rights are limited, you are obliged to obtain the authorisation of the holders of parental authority or guardianship. Without such authorisation, you are prohibited from providing us with any personal data relating to such persons.

We are committed to protecting your privacy and personal information. We have recorded all the personal data processing activities we carry out, we have analysed the risk that each of these activities may pose to you and we have implemented the appropriate legal, technical and organisational safeguards to prevent, as far as possible, the alteration, misuse, loss, theft, unauthorised access or unauthorised processing of your personal data. We conveniently keep our policies up to date to ensure that we provide you with all the information we have about the processing of your personal data, and to ensure that our staff are given appropriate guidance on how they should handle your personal data. We have signed privacy clauses and data processor agreements with all of our service providers, taking into account the need for each of them to process personal data.

We restrict access to personal data to those employees who require knowledge of such information in order to carry out any of the activities described in this policy, and we have trained them and made them aware of the importance of maintaining the confidentiality, integrity and availability of the information, as well as the disciplinary measures that would result from any breach of this policy.