1. DATA CONTROLLER
This Whistleblower Channel is the responsibility of LOOKIERO STYLE, S.L with CIF B95810826, company domiciled in Polígono El Calero, ZAD II, Nave 4, 48980, Santurtzi, Bizkaia (hereinafter LOOKIERO).
We inform you that LOOKIERO has designated a Data Protection Delegate who can be contacted at the following e-mail address [email protected]
2. MOTIVATION
LOOKIERO makes this Whistleblower Channel available to its stakeholders in compliance with the recent Law 2/2023 regulating the protection of persons who report regulatory infringements and the fight against corruption (hereinafter, " Whistleblower Protection Law ").
In addition, LOOKIERO fully complies with the current regulations on the protection of personal data; specifically, with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter, " GDPR ") and Organic Law 3/2018 of 5 December on data protection and guarantee of digital rights (hereinafter, " LOPD ").
3. PERSONAL DATA PROCESSED
As indicated in the previous section, LOOKIERO's Whistleblower Channel allows the submission of anonymous complaints.
However, if the informant wishes to submit the complaint in a nominative way, LOOKIERO may collect, within the framework of a communication, the following types of data from the informant and, where appropriate, from the persons involved in the communication:
· Identifying data: Name and surname(s).
· Contact data: Telephone and e-mail.
· Professional data: Professional position.
Additionally, LOOKIERO may process other types of data by virtue of the allegedly criminal or irregular facts reported and the supporting documentation that may be appropriate to investigate the reported conduct.
No personal data shall be collected if it is not clearly relevant to the processing of specific information. In the event that irrelevant data is accidentally collected, such data shall be deleted from the Whistleblower Channel without undue delay.
If it is proven that the information provided or part of it is not truthful, it will be deleted immediately as soon as this circumstance becomes known. In the event that this lack of truthfulness may constitute a criminal offense, the information will be kept for the necessary time during the legal proceedings.
4. PURPOSES OF DATA PROCESSING
LOOKIERO shall process the data to which it may have access as a result of the communications received for the following purposes:
· Receiving and deciding on the admission for processing of communications received through the Complaints Channel.
· Once the communications have been admitted for processing, to carry out the investigation of the reported facts and to adopt, if appropriate, the pertinent corrective measures.
· Keeping the complainant informed about the admission, or not, of his communication as well as the progress and results of the investigation process in the event that there are sufficient grounds to admit his communication for processing.
5. LEGITIMACY FOR DATA PROCESSING
According to the conduct reported through this Whistleblower Channel, LOOKIERO has the following legitimate bases for the processing of data:
· Compliance with legal obligations applicable to LOOKIERO if the communication refers to the breaches provided for in the Whistleblower Protection Act:
o Breaches of European Union law,
o Commission of crimes or serious or very serious administrative offenses or any violations of the regulations for the prevention of money laundering;
6. RECIPIENTS OF THE INFORMATION
The data to which LOOKIERO may have access due to the communications received through the Whistleblower Channel, may be communicated to:
· When necessary for the investigation or the adoption of disciplinary or corrective measures to LOOKIERO Group entities listed in Annex I where the reported facts have occurred.
· Public bodies or institutions, judges and courts when necessary for the adoption of disciplinary measures, for the processing of legal proceedings, if any, or in those cases in which it was legally required.
· To the Public Prosecutor's Office, when the procedure is within its competence.
Regarding the communication of the informant's personal data, LOOKIERO will guarantee that his identity, and all those personal data that LOOKIERO may have about his person, will be in any case reserved and that they will not be communicated to the persons to whom the reported facts refer nor to third parties, respecting in any case the fundamental rights of the person, without prejudice to the actions that, if necessary, may be taken by the competent judicial authorities .
7. TIME LIMITS FOR THE STORAGE OF DATA
The personal data to which LOOKIERO may have had access as a result of the communications received through the Complaints Channel, will be processed for the time necessary to decide on the appropriateness of initiating an investigation into the facts reported and for the management of the communication provided that it is admitted for processing.
Specifically, LOOKIERO will process the personal data within a maximum period of three months from receipt of the communication, except in cases of particular complexity, in which case it could be extended for an additional three months.
Once the aforementioned period has elapsed without any investigation actions having been initiated, the data will be deleted from the communication system, except for the purpose of maintaining evidence of the operation of the system and in an anonymized form.
In the case of communications that have not been sent, they will be kept in an anonymized form, completely eliminating the personal data.
8. USER RIGHTS
The regulations for the protection of the informant guarantee Users the following rights recognized in the data protection regulations, which may be exercised whenever applicable:
However, the exercise of these rights is limited to those whistleblowers who have identified themselves at the time of submitting the communication. If LOOKIERO has reasonable doubts about the identity of the informant requesting the right, he/she may request information that allows him/her to prove his/her identity.
Whenever applicable, they may exercise the aforementioned rights before LOOKIERO by mail to the above address or by e-mail to [email protected].
If the informants wish further information in this regard or consider that their right to data protection has been violated, they may contact the Spanish Data Protection Agency (www.aepd.es) or the Data Protection Delegate of LOOKIERO [email protected].
9. SECURITY MEASURES
In compliance with the aforementioned current regulations, [CLIENT] has incorporated the appropriate technical and organizational measures to guarantee the protection of the rights and freedoms of those affected by the processing of their personal data, including the corresponding data security measures, reinforced, among other aspects, with respect to the necessary confidentiality and, singularly, the disclosure of the identity of the informant, data protection and secrecy of communications, in order to prevent the loss, misuse, alteration, unauthorized access and theft of the data provided by the informant.
10. ACCURATE AND TRUTHFUL INFORMATION
LOOKIERO informs the complainant that the communication transferred through the Whistleblower Channel may lead to the initiation of internal or external investigations and may have negative consequences for those affected.
For this reason, you should only provide us with information that is believed to be correct to the best of your knowledge and belief and that is relevant to the detection of a compliance violation.
LOOKIERO may initiate any disciplinary and/or legal action it deems appropriate whenever the communication is manifestly unfounded or there are, in the opinion of LOOKIERO reasonable indications that the information has been obtained through the commission of a crime.
- LOOKIERO STYLE, S.L, (as a holding company of LOOKIERO) with Tax Identification Number B95810826 and Registered Company Name Polígono El Calero, ZAD II, Nave 4, 48980, Santurtzi, Bizkaia
- LOOKIERO TECH, S.L, with CIF B95953907 and Registered Company Name CAMINO URIBARRI-ERANDIONDO, 3 - 48950 ERANDIO (Bizkaia)
- LOOKIERO STYLE GERMANY GMBH with CIF HRB236139B and Registered Company Name Rahel-Hirsch-Str. 1010557 Berlin
- LOOKIERO STYLE SWEDEN AB with CIF 559466-0820 and Registered Company Name c/o Licke Pro AB Box 3080 103 61 Estocolmo
- LOOKIERO STYLE ITALY SRL with CIF IT10964540966 and Registered Company Name VIA BISCEGLIE 76, 20152, Milano
- LOOKIERO STYLE THE NETHERLANDS BV with CIF and Singel 250, 1016 AB, Amsterdam
- LOOKIERO STYLE UK LTD with CIF GB314385218 and Registered Company Name 6th Floor 25 Farringdon Street, London, United Kingdom, EC4A 4AB