Privacy Policy

1. General Information

DRAGADOS, SA, with registered office at Avenida del Camino de Santiago, 50, 28050 Madrid (Spain), NIF A 15139314 and telephone +34 91 343 93 00 (hereinafter, Dragados), is committed to the protection of the personal data it processes in the development of its activities.

The processing of personal data carried out by DRAGADOS is adequate, relevant and not excessive in relation to the purposes for which it is processed, and is carried out in compliance with current data protection regulations, in particular Regulation (EU) 2016/679, General Data Protection Regulation (GDPR), Organic Law 3/2018, on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD) and other applicable regulations.

2. Categories of interested parties

DRAGADOS processes personal data from different categories of data subjects, depending on their relationship with the company and the corresponding purposes. The main groups are:

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Employees.

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Own legal representatives.

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Suppliers.

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Visitors to offices and corporate facilities.

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Legal representatives and contact persons of other entities or persons.

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Employee insurance beneficiaries.

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Users of the Ethics Channel.

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Job applicants.

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Users of the corporate website.

The personal data of each of these groups may be processed and, where appropriate, shared with different natural or legal persons, depending on the specific purpose of each processing, as indicated in this Policy.

DRAGADOS does not use personal data under any circumstances for decision-making based solely on automated processing, including profiling.

3. Security applied to data processing

In accordance with applicable regulations, DRAGADOS has implemented appropriate technical and organizational measures to ensure the integrity, availability and confidentiality of the personal data processed, taking into account the nature, scope, context and purposes of each processing, as well as the risks that may arise for the rights and freedoms of individuals.

In general, and without being exhaustive, the following measures have been adopted:

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Assignment of access permissions according to the functions performed.

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Physical and logical access controls.

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Backups and recovery mechanisms.

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Appointment of a Data Protection Officer.

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Management and control of media containing personal information.

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Designation of security officers.

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Development of internal data protection policies and protocols.

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Encryption of sensitive information and periodic audits in those data processing that present a higher level of risk.

In addition, DRAGADOS periodically carries out verification processes aimed at evaluating the effectiveness of the measures implemented and ensuring their continuous improvement, taking into account technological evolution.

4. Rights of interested parties

Interested parties have the right to obtain confirmation as to whether or not DRAGADOS is processing personal data concerning them and, where applicable, to exercise the following rights:

• Right of access, rectification and erasure

Access your personal data, request the rectification of inaccurate data or, where appropriate, request its deletion when the data is no longer necessary for the purposes for which it was collected.

• Right to restriction of processing

Request the limitation of the processing of your data in the legally provided cases, in which case they will only be kept for the exercise or defense of claims.

• Right to object

You have the right to object to the processing of your data for reasons related to your particular situation, unless there are compelling legitimate grounds or it is necessary for the establishment, exercise or defense of legal claims.

• Right to portability

Receive the personal data provided in a structured, commonly used and machine-readable format, or request its transmission to another controller when the processing is based on consent or a contract.

• Withdrawal of consent

Withdraw the consent given at any time, without this affecting the lawfulness of the processing based on the consent prior to its withdrawal.

• Exercise of rights

To exercise these rights, the interested party may contact DRAGADOS, SA, by:

Email: LOPD@dragados.com

Postal address: Avenida del Camino de Santiago, 50, 28050 Madrid (Spain)

You are also informed of your right to file a complaint with the Spanish Data Protection Agency (www.aepd.es) or with the competent supervisory authority.

5. Data Protection Officer

For any questions relating to the processing of personal data, interested parties can contact DRAGADOS' Data Protection Officer through:

Email: LOPD@dragados.com

Postal address: Avenida del Camino de Santiago, 50, 28050 Madrid (Spain)

6. Data protection for the website and job applicants

a) Purpose

The personal data provided through the website is processed for the following purposes:

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To answer inquiries or requests submitted by users and provide the requested information.

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Manage the receipt of resumes and participation in personnel selection processes.

b) Legal basis

The legal basis for the processing is the user's consent when voluntarily providing their data, as well as the application of pre-contractual measures in the case of job applications.

c) Data retention

Contact details will be kept for the time necessary to process the request made and, subsequently, for the legally required periods.

Data relating to job applications will be kept for a maximum period of five (5) years, unless the interested party requests its deletion beforehand or there is a legal obligation to retain it.

d) Recipients

No data transfers or international transfers are foreseen, except to entities of the DRAGADOS Group / ACS Group when necessary for the purposes indicated or by legal obligation.

7. Protection of user data of the Ethics Channel

Personal data processed through the Ethics Channel is used for the proper management of communications, the coordination of regulatory compliance systems, the detection and prevention of illegal conduct and, where appropriate, the defense of DRAGADOS' rights and legitimate interests.

The processing is based on compliance with legal obligations, public interest and the legitimate interest of DRAGADOS, and is carried out with strict confidentiality guarantees.

The data will be kept only for the necessary time, and will be deleted from the channel system within a maximum period of three (3) months, unless it is necessary to keep them for the processing of investigations or compliance with legal obligations, in which case they will be duly blocked.

The data may be communicated, when necessary, to the compliance body, external advisors, the channel platform provider and competent authorities.

8. Privacy Policy Update

DRAGADOS reserves the right to modify this Privacy Policy to adapt it to regulatory or jurisprudential changes, or to the processing activities carried out. Modifications will be published on this same page.