PRIVACY POLITY, DATA PROCESSING AND PROTECTION

This business privacy declaration made by Black Terra Resources (hereinafter, “the declaration”) is issued on behalf of the data controller, Black Terra Resources, with its business address at Carr. 57 km. 11.9 11950 Leopoldo De La Rosa St. Cd. Nav Coahuila, CP. 2770 (hereinafter “BTR” or “we”). It is addressed to any party with whom BTR interacts, including visitors to and users of BTR’s websites, applications (in web and mobile formats) and online services (hereinafter, “the online services”), current and potential customers, members of suppliers’ managements and personnel, corporate customers and BTR’s personnel. When we include the words “you” in this declaration we collectively refer to all the parties whose personal data we process. In the carrying out of its function as data controller BTR will process information concerning you in both printed and electronic formats, which we refer to as “personal data”. You assume responsibility for and guarantee that the personal data you provide to BTR are true and, as appropriate, that you have received the owner’s corresponding authorization.

BTR will process your personal data in compliance with the requirements of the current legislation, particularly the following:

A new Data Protection Regulation has been in force since 25 May 2018. EU Regulation 2016/679 harmonizes the legislation on data protection throughout the European Union, increasing the protection of natural persons owning personal data and giving them greater control over them. The data collected by BTR via its different channels (the website, email and electronic and paper forms) within the framework of its commercial activity and the provision of its services are incorporated into a processing file managed by BTR itself.

Purposes for which the data are collected:

Provision of training services: BTR records the data of the companies to which it provides training services, the employees who apply for BTR’s training activities and the contact persons in customers’ organizations responsible the formalization of the pre-enrolment and enrolment processes, the sending of useful information and the processing and issuance of qualifications and certificates. BTR’s customer company with regard to the provision of a training service assumes liability for and guarantees that the personal data concerning its personnel supplied to BTR are true and, as appropriate, have received the owners’ due authorization.

Provision of other customer services: BTR records the data of new customers that procure services and manages any additional data that may be generated as a result of the commercial relationships with said customers. The essential data are requested during the procurement process, which should include the bank payment data. These relationships entail further processing, such as the incorporation of the data into the accounting and invoicing and the sending of information to the tax authorities.

Personnel management: BTR processes the data of its workforce in order to perform proper human resource management and to comply with any resulting administrative, tax and legal obligations. Similarly, we collect and safeguard the CVs sent to us by people interested in working for us and we process personal data when we conduct personnel selection processes in order to analyse the suitability of candidates’ profiles for vacant or newly-created positions.

Suppliers: We record and process the data of the suppliers from whom we obtain services and goods. These may be the data of people who act as self-employed workers or data of representatives of legal persons. We obtain the data essential for preserving the commercial relationship. Said relationship involves further processing, such as the incorporation of the data into the accounting and invoicing and the sending of information to the tax authorities.

Conservation of the data

The period for the conservation of the data chiefly depends on whether they are necessary for fulfilling the purposes for which they have been collected in each case. In addition, they are retained to cover potential liabilities resulting from the processing of the data byBTR and to attend to the requirements of the public administrations and judicial bodies. Consequently, the data must be retained for the time required to preserve their legal or informative value and to demonstrate compliance with legal obligations. In the case of information that certifies the training received by the students, the data shall be retained on a permanent basis in order to preserve the rights of said students. In the case of data that are processed exclusively upon the basis of the consent of the person in question, they shall be retained until the person withdraws said consent.

Legitimation of the processing

The data processed by BTR include those obtained with the consent of the interested party and those voluntarily provided by the interested party by any means: data necessary for the maintenance of a contractual relationship (service provision contracts, labour and commercial contracts, etc.), for the provision of training services (registrations, enrolments, files, qualifications, etc.), for compliance with a pre-contractual or contractual relationship, for compliance with legal and tax obligations, for requirements of the public administration and for a legitimate interest.

Data recipients

Generally speaking, BTR only assigns data in compliance with its legal obligations. In addition, BTE obtains the services of companies or people that provide us with their experience and specialization for certain tasks, and on occasions the latter have to access personal data. In the terms of the General Data Protection Regulation, this does not involve a transfer of data but rather a processing order. We only procure services from companies that guarantee compliance with this regulation. Their confidentiality obligations are formalized and their actions are monitored at the time of the procurement. This may occur in the case of data hosting services on servers, computer support services and legal, accounting and tax consultancy firms.

Rights of data holders:

Everyone has the right to know whether BTR is processing their data or not and whether it has the right to access their personal data, to request the rectification of any inaccurate data, to request their deletion when, among other reasons, the data are no longer necessary for the purposes for which they are collected, to oppose the processing of their data for reasons related to their particular situation, requesting that they should not be processed by BTR, and to withdraw the consent they have granted, without the above affecting the lawfulness of the processing which has been performed prior to said consent being withdrawn.
When the rights of suppression, opposition, limitation and withdrawal of consent are exercised, BTR shall cease to process the data, unless there are compelling legitimate reasons for doing so or unless it does so in the exercise or defence of potential claims.
The owner of the data may exercise the rights envisaged in Chapter III of the General Data Protection Regulation, as well as those in the LOPD (the Spanish Data Protection Act) by writing to BTR at info@blackterraresources.com. Whenever the above rights are exercised, a copy of the applicant’s ID card or an equivalent document proving his/her identity must be attached to the application.

Provenance of the data:

In most cases the data come directly from the interested parties and we obtain them chiefly via the forms prepared for said purpose. We also obtain data on open days, during informative sessions and by means of face-to-face relationships, exchanges of business cards and other channels, such as the receipt of emails, our website, telephone calls, subscriptions to blogs and our profiles on social media.

Data categories:

The data collected by BTR are basically identification data, electronic addresses, commercial information, and the data of users of our website (*). Specially protected data are not processed.
(*) The browsing system and the software that enables our website to operate collect the data which are commonly generated in the use of Internet protocols. This data category includes the IP address or domain name of the computer used by the person who connects to the website. This information is not associated with specific users and is used for the sole purpose of obtaining statistical information on use of the website. Our website uses cookies to facilitate browsing and to provide us with information on our users and their interests (more information in the Cookie Policy).

Sending of commercial correspondence:

In accordance with the Law on Information Society Services and Electronic Commerce you can unsubscribe from any of the services and exercise your right of opposition to receiving commercial information by sending a request to info@blackterraresources.com accompanied by a copy of the applicant’s ID card or an equivalent document proving his/her identity.

Security measures

BTR hereby informs you that it implements the security measures required to prevent the theft or alteration of the data or unauthorized access to them, taking into account the state of the art, the implementation costs and the nature, scope, context and purposes of the processing, as well as risks of varying probability and seriousness concerning the rights and freedoms of natural persons, while, in the case of the outsourcing of services, it shall require and ensure that the data controller implements the appropriate technical and organizational measures to guarantee a level of security suited to the existing risks, as set forth in Article 32 of the General Data Protection Regulation.

Notice of Privacy