In accordance with the provisions of European Data Protection Regulations, we wish to inform you of the following aspects:
Identity of the Data Controller:
Identity: METRO LIGERO OESTE S.A.
Address: Calle Edgar Neville, 9, 28223 Pozuelo de Alarcón, Madrid
Telephone: 915 03 16 00
Data Protection Officerdpd@metroligero-oeste.es
1. General Clauses
a) Why we process your personal data:
The aim of our processing is to manage the relationship between Metro Ligero Oeste S.A. and users, requested by either of the parties through the website, through the contact form or any other type of printed matter, or via a request by e-mail, the use of interphones or phone calls to Metro Ligero Oeste, S.A.
This request may entail, but is not limited to, managing a suggestion, complaint, information inquiry, incident, special travel card top up, lost property, participation in contests, events or workshops, irregularities and/or infringement of rules, incident reports, staff recruitment, CCTV surveillance or vendor relationships, subscription to the company newsletter, visits to the facilities of Metro Ligero Oeste, S.A., as well as any other interaction between you and METRO LIGERO OESTE S.A. which is intended to meet your needs. Any data requested are necessary to deal with the request.
Likewise, the data provided may also be processed to send you commercial information about our products and services which may interest you, by post, e-mail, SMS, or any other equivalent means of correspondence. If you do not want your data to be processed in this way, you will be able to object to receiving commercial correspondence by not ticking the relevant box on the information or contact form itself, or even by exercising your right to object at the abovementioned address.
We will keep information about you while the commercial relationship or your interest in reading this policy (e.g. you have sent a CV or subscribed to a newsletter) is effective, unless you ask for your data to be erased during the limitation period of the activities that may arise in your relationship with Metro Ligero Oeste, S.A. or because of a complaint we may receive from official bodies pursuant to legal requirements. While your data is in our possession, they may be placed at the disposal of the competent government agency if requested on justified grounds.
c) Information to send you commercial correspondence
We also wish to use your data to offer you products and services relating to those you request, by any means, including electronically, even when the business/ contractual relationship is over
The personal data provided for sending commercial correspondence authorised by you will be stored until you withdraw your consent, all of the above without prejudicing your right of erasure or objection.d) Legal basis for processing your data
The legal basis for processing your data is your express consent, according to the terms and conditions set down in these clauses. All the data we request are obligatory in nature; hence, failure to provide some of them may prevent us from providing the services we offer
Your data may only be used for the purposes they were collected for, in accordance with transparency and purpose limitation principles..
With respect to the mailing of commercial correspondence by electronic means – resulting from a previous contractual relationship - the legal basis is the legitimate interest of METRO LIGERO OESTE S.A. by virtue of section 21.2 of the Information Society Services Act.
You will also be entitled to withdraw your consent at any time by informing the processing officer at the following address email@example.com) Data communication or assignment and international data transfer
Your data will be transferred in any cases in which it is legally required to do so to public entities competent in the subject. Please take note that your data may also be shared with the Consorcio Regional de Transportes de Madrid, if necessary for managing the service
Nevertheless, if at any time in your relationship with Metro Ligero Oeste, S.A., it should be necessary to share your data with third parties for other purposes, they will only be shared when METRO LIGERO OESTE S.A. has prior consent to do so and in the manner required by law.
We do not transfer your personal data abroad.f) Rights:
Anyone is entitled to obtain confirmation about whether, at METRO LIGERO OESTE S.A., we are processing personal data that concern them, and in such case, the right to access their personal data, the purpose of the processing and the categories of the personal data in question.
They will also be entitled to request the correction of inaccurate data or, where appropriate, their erasure when they are no longer necessary for the purposes they were collected for; if they have withdrawn the consent on which the processing was based or they object to the processing; the personal data has been processed illegally, or they must be erased in order to fulfil a legal requirement set down in the laws of the European Union or its member states.
They may request a limitation on processing their data when they contest the accuracy of the personal data during the time that enables the data controller to check their accuracy; the processing is illegal and the data subject objects to the erasure of the personal data and requests, instead, a limitation on their use; the data controller no longer needs the personal data for the processing purposes, but the data subject needs them to file, exercise or defend complaints; or the data subject has objected to the processing, while it is checked whether the legitimate reasons of the data controller prevail over those of the data subject. In such cases, we shall only hold data on file for exercising and defending claims.
In certain circumstances, and for reasons relating to your specific situation, you may object to the processing of your data. METRO LIGERO OESTE S.A. shall cease to process the data, save on compelling legal grounds, or in exercising or defending possible claims.
You shall be entitled to receive the personal data that concern you, and which you have provided, in a structured format, and transfer them to another data controller without the controller you gave them to preventing this when the processing is consent-based; or the processing is carried out via automated means.
When data subjects exercise their rights of access, rectification, erasure and objection, processing limitation and data portability, unless they are subject to automatic individualised decisions, they shall notify such circumstance by e-mail to the following address: firstname.lastname@example.org
You may also file a complaint with the Spanish Data Protection Agency, especially when you have not received satisfaction on exercising your rights, through the electronic office at https://www.aepd.esg) Origin :
The personal data we process at METRO LIGERO OESTE S.A. come from the data subjects themselves.
In any case, the data subject guarantees and is accountable for the truthfulness, accuracy, validity and authenticity of the Personal Data provided and shall keep them properly updated.
You also guarantee that you are over the age of 14. If you submit personal data that you do not own, before including them, you shall inform the owners of the points contained in the previous paragraphs. In these cases, you guarantee that the data provided belong to people over the age of 14 and that the information is accurate and true. METRO LIGERO OESTE S.A. shall be exempt from any liability resulting from your non-compliance with these requirements.
In the case of persons under the age of 14, it is understood that the personal data we process at METRO LIGERO OESTE S.A. come from the data subject’s legal representative.
METRO LIGERO OESTE S.A. has adopted the legally required security levels for protecting Personal Data and has installed all the means and technical measures available according to the state of technology to prevent the loss, misuse, alteration, unauthorised access and theft of the Personal Data provided.
You can rely on the confidentiality and non-disclosure undertaking of the employees of METRO LIGERO OESTE S.A. and of anyone who processes your data acting for and on its behalf. Notwithstanding the above, you should be aware that the security of online correspondence may be vulnerable2. Additional staff recruitment clause
In addition to the general clauses, the following clauses apply to the processing of staff recruitment:a) Why we process your personal data:
At METRO LIGERO OESTE S.A., we process the personal data you send to us in order to manage the information on your CV so that you can take part in open selection processes.
The personal data provided shall be held on file as long as you do not ask for them to be erased or for 6 months following the last confirmation of interest. b) Legal basis for processing your data
The legal basis for processing your data is the unequivocal consent of the data subject which results from your own initiative on sending your CV. As a consequence, it is understood that the data subject grants the company consent to process the information contained in their CV on submitting it deliberately.c) Data communication or assignment and international data transfer:
Staff are recruited directly by the company.
METRO LIGERO OESTE S.A. also employs Data Processors whose legal basis for processing data is execution of the work order agreement, whose purposes include staff recruitment
No personal data subject to this processing will be shared with third parties.
No other international transfers of data take place outside the European context.3. CCTV surveillance
In addition to the general clauses, the following specific clauses apply to processing CCTV surveillance:a) Why we process your personal data
At METRO LIGERO OESTE S.A., we process your personal data in order to manage the security of our facilities, which will include but is not limited to: remote surveillance from metro station command posts, vehicles, track sections at depots and offices, security and control of vehicle accesses, control of travel card validation and investigation of accidents and incidents by METRO LIGERO OESTE S.A through a CCTV surveillance system. The personal data provided shall be kept on file for a maximum of 30 days.b) Legal basis for processing your data
Valid legal interest, based on the Private Security Act, in which the processing of images on security grounds is covered by its section 5.1., as well as fulfilment of legal requirements, specifically the Passenger Regulations of the Madrid Metropolitan Railway (Decree 49/1987 of May 8, of the Autonomous Community of Madrid), applicable to Metro Ligero Oeste through Decree 57/2006 of June 29 and amended by Decree 56/2017, of May 24, 2017, of the governing council of the Autonomous Community of Madrid.c) Data communication or assignment and international data transfer
The personal data of your picture, captured by the CCTV surveillance system, shall only be transferred by judicial order or to national law enforcement bodies when established by law.
Please be advised that Metro Ligero Oeste, S.A. has signed data processor agreements with several companies whose legal basis for processing is the execution of their work order agreement with Metro Ligero Oeste, S.A.4. Managing complaints, suggestions and lost property
In addition to the general clauses, the following specific clauses apply to processing management of complaints, suggestions and lost property:a) Legal basis for processing your data
The legal basis for processing your data is fulfilment of legal requirements, specifically the Passenger Regulations of the Madrid Metropolitan Railway (Decree 49/1987 of May 8, of the Autonomous Community of Madrid), applicable to Metro Ligero Oeste through Decree 57/2006 of June 29 and amended by Decree 56/2017, of May 24, 2017, of the governing council of the Autonomous Community of Madrid.
Data may only be used for the intentions described in the previous heading, in accordance with transparency and purpose limitation principles.5. Relationship with users of Metro Ligero Oeste, S.A.
In addition to the general clauses, the following clauses apply to processing relating to users of Metro Ligero Oeste, S.A, (among others, suggestions, complaints, information inquiries, incidents, lost property or incident reports): a) Legal basis for processing your data:
The legal basis for processing your data is fulfilment of legal requirements, specifically the Passenger Regulations of the Madrid Metropolitan Railway (Decree 49/1987 of May 8, of the Autonomous Community of Madrid), applicable to Metro Ligero Oeste through Decree 57/2006 of June 29 and amended by Decree 56/2017, of May 24, 2017, of the governing council of the Autonomous Community of Madrid.6. Irregularities/ Infringement of passenger regulations
In addition to the general clauses, the following clauses apply to processing relating to irregularities or infringement of passenger regulations:a) Purpose
At METRO LIGERO OESTE S.A., we process your personal data in order to correctly manage irregularities or infringements legally foreseen in the Passenger Regulations of the Madrid Metropolitan Railway passed by Decree 49/1987 of May 8, applicable to Metro Ligero Oeste through Decree 57/2006 of June 29 and amended by Decree 56/2017, of May 24, 2017, of the governing council of the Autonomous Community of Madrid.b) Legal basis:
The processing of your personal data is legalised for fulfilment of the legal requirements foreseen in the abovementioned Passenger Regulations of the Madrid Metropolitan Railway.