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Privacy Policy

In compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR) and Organic Law 3/2018 (LOPDGDD), at GUY Incógnito & Asociados S.L. (hereinafter, Incógnito or the website owner) we are committed to protecting the privacy and personal data of our users, clients, candidates, and visitors who access the website https://factorincognito.com/.

Data Controller and Data Protection Officer (DPO)
Company name: GUY Incógnito & Asociados S.L.
Postal address: Calle Doctor Esquerdo, 217, 28007, Madrid (Spain).
Contact phone: +34 91 737 9950
Contact email: contact@factorincognito.com
Data Protection Officer (DPO): rgpd@hidalgoasociados.com

The controller guarantees that the data provided will be processed lawfully, fairly, transparently, adequately, relevantly, and limited to what is necessary in relation to the purposes for which it is processed.

Purposes of Data Processing
Personal data collected through the website, contact forms, subscriptions, the employment section, or direct contact channels will be processed for the following purposes:

  • Managing inquiries and requests: To attend to, process, and respond to questions, collaboration proposals, or requests for information made by users through the available forms or channels.
  • Managing candidates and selection processes (“Work with us” / Employment): To receive, analyze, and manage the CVs, cover letters, and academic/professional data provided by candidates through the specific employment form, in order to evaluate their profile and consider them for the agency’s current and future selection processes.
  • Managing Newsletter and commercial communications: To send periodic newsletters with specialized content, articles, podcasts, events, success stories, service offers, and Incógnito news, provided the user has given express consent.
  • Recording IP address for security and spam prevention: When submitting any form (contact, candidates, or subscription), the user’s IP address is automatically recorded for strict technical purposes of security, traceability, abuse control, and spam prevention.
  • Direct communication channel (WhatsApp and messaging): To facilitate smooth communication with clients, users, or candidates for resolving questions or following up on projects via instant messaging applications, upon request or express consent.

Legal Basis for Processing
The legal basis that legitimizes the processing of your personal data includes:

  • Consent of the data subject (Art. 6.1.a GDPR): By checking acceptance boxes, submitting contact forms, subscribing to the Newsletter, or voluntarily sending a CV through the candidates’ form.
  • Application of pre-contractual measures (Art. 6.1.b GDPR): In the case of the candidates’ form, for participation in personnel selection processes requested by the data subject themselves.
  • Legitimate interest of the controller (Art. 6.1.f GDPR): For recording and controlling IP addresses in order to guarantee the security of the website against malicious access, cyberattacks, and automated spam prevention.
  • Compliance with legal obligations (Art. 6.1.c GDPR): In tax, accounting, labor matters, and in response to administrative or judicial requirements.

Categories of Data Processed
Depending on the user’s interaction with the website, we may collect the following categories of data:

  • Identifying data: First and last name.
  • Contact data: Email address, phone number (including WhatsApp), postal address, and digital professional profile (e.g., LinkedIn).
  • Academic and professional data (Candidates): Education, work history, prior experience, skills, aptitudes, and any other data or document (such as a CV in PDF) voluntarily provided in the employment form.
  • Professional and company data: Company and position (in corporate forms).
  • Technical and browsing data: IP address of the device, connection data, access logs, and data derived from cookie use.
  • Any other data voluntarily provided in messages, comments, or interactions with the agency.

Data Retention

  • Inquiry and contact data: Retained for the time strictly necessary to attend to and manage the request made.
  • Candidate data (CVs): Retained for a maximum period of 1 year, unless the candidate withdraws consent or requests deletion beforehand.
  • Newsletter data: Retained as long as the user does not withdraw consent or request unsubscription from the newsletter service (an easy unsubscribe link will be included in each communication).
  • IP and security records: Kept for the technical and legal statute-of-limitations periods applicable to cybersecurity liability.

Afterward, data will be duly blocked for the periods legally required in tax, commercial, labor, or legal matters.

Recipients and Providers (Transfers and Processors)
As a general rule, data will not be shared with third parties except where legally required. However, for the proper development of our activity and website operation, we work with technology service providers acting as data processors (hosting services, website maintenance, candidate management tools, newsletter distribution platforms, and analytics), under strict confidentiality contracts compliant with the GDPR.

Note on international transfers: The use of third-party platforms or technology tools integrated into the website may involve international data transfers outside the European Economic Area (EEA), which are carried out under the appropriate safeguards required by European regulations (such as standard contractual clauses).

Cookie Policy (Detailed Purposes)
This website uses cookies (small data files downloaded to the user’s device) to ensure the website functions properly, analyze browsing, personalize content, and manage advertising campaigns. The purposes of the cookies used by Incógnito are:

  • Technical or Necessary Cookies: Ensure the website works correctly, secure browsing, traffic control, and session or form management (including contact, candidate, and subscription forms). Without them, the website cannot operate optimally.
  • Analytics or Measurement Cookies: Allow quantifying the number of users and statistically analyzing how they use the services offered (e.g., most visited pages, time spent, or browsing paths), with the aim of introducing improvements based on usage data analysis.
  • Personalization Cookies: Remember user preferences (language, regional settings, or display) to offer an adapted, personalized experience to each visitor.
  • Advertising and Behavioral Cookies: Effectively manage the offering of advertising space on the website or external platforms, analyzing the user’s browsing habits to display advertising related to their interest profile and measure campaign effectiveness.

The user can configure, accept, or reject cookies at any time through the cookie settings panel available on the website or through their own browser settings.

Rights of Data Subjects
Any person has the right to obtain confirmation as to whether Incógnito is processing personal data concerning them. Users may exercise the following rights at any time:

  • Access, rectification, and erasure of their data.
  • Restriction of or objection to processing.
  • Data portability.
  • Withdrawal of consent given (including unsubscribing from the Newsletter or withdrawing a CV).

To exercise these rights, requests may be submitted in writing, attaching a copy of an identity document, through any of the following channels:

Additionally, if you believe the processing does not comply with current regulations, you have the right to file a complaint with the competent supervisory authority, the Spanish Data Protection Agency (AEPD) (https://www.aepd.es).

Security Measures
Incógnito applies appropriate technical and organizational measures to ensure a level of security suited to the risk, protecting users’ personal data (including CVs, subscription databases, and IP records) against loss, alteration, unauthorized access, theft, or improper processing.

Changes to the Privacy Policy
Incógnito reserves the right to modify this Privacy Policy to adapt it to legislative, jurisprudential, or technical developments, or to criteria set by the Spanish Data Protection Agency, and recommends periodic review.