Privacy Policy

In order to receive and process your report, you must confirm that you have read this Privacy Notice. If you do not agree to the terms and conditions as set out in the notice, you will not be able to make a report.

Please note that this channel is not intended for reporting emergencies.

The ethic channel is managed by PGA GOLF DE CALDAS, S.A. (hereinafter, the "Company"), using the Ithikios platform, owned by DIGITAL PRODUCTS DEVELOPMENT, S.L., a company specialised in offering internal report channel management systems for companies. It maintains a contractual relationship with the Company as the processor, for the purpose of receiving, storing, and sending communications to the Company's Compliance Department. Ithikios guarantees security and confidentiality for the purpose of the contracted processing.

Below you will find the basic information on how we process your personal data:


Basic information on privacy and data protection

Controller

PGA GOLF DE CALDAS, S.A. (hereinafter, the “Company”), with registered office in Caldes de Malavella (17455 – Girona), Carretera N-II, km 701, and with Tax Identification Number (NIF) A-58.376.104. It is duly registered in the Commercial Registry of Girona, volume 2344, sheet 191, page GI-39.173.

Data protection officer

You may contact the following email: [email protected]

Data subject of the processing and its origin

They will be the following:

· your contact details if you provide them (name and surname, email, telephone number)

· name and position of the persons mentioned in the report

· information (regardless of its nature) on the reported facts

Purpose and legal basis of the processing

In accordance with current legislation on data protection, the Company informs you that your personal data will be collected and processed for the purpose of:

· Analysing, processing and investigating the facts communicated in a confidential manner.

· Managing the enquiry you submit to us.

· Exchanging information with the aim of complementing your request.

· To interview you in order to clarify the reported facts, if appropriate.

Our legitimate interest is to ensure compliance with policies and regulations and/or applicable law.

Recipients of the transfers

As required by law, service providers in their capacity as data processors. In the course of an investigation, it may also be necessary for us to share the facts you report with another group company, if this company is involved in the facts; your anonymity will always be preserved.

Personal data will not be passed on to other third parties, unless legally obliged to do so.

Recipient of international transfers

Those arising from the processing of the report, enquiry or concern to any other company of the group, as well as those arising from our relationship with the provider that manages the Ethic Channel with the guarantees set out in the Privacy Policy.

Rights of the interested parties

Access, rectification, erasure, restriction, portability, objection, and not to be the subject of automated individual decision-making.