Privacy Policy

1. Introduction

Holaluz works to offer the user the best possible experience through its products and services. In some cases, it is necessary to collect information to achieve this.

Therefore, and for the purposes of the provisions of REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 (hereinafter, "GDPR") on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and the Law 34/2002, of July 11, 2002, of Information Society Services and Electronic Commerce (hereinafter, "LSSI"), HOLALUZ-CLIDOM S.A. informs the user that, as responsible for the treatment, it will incorporate the personal data provided by the users in an automated file.

2. Person in charge of the treatment

HOLALUZ-CLIDOM S.A. (hereinafter, "Holaluz" or the "Company") is the creator of this web page, as well as the company responsible for the processing of personal data that the user shares with us. The following is general information about the Company:

Identity: HOLALUZ-CLIDOM S.A.
Address: Passeig Joan de Borbó 99-10, 4th Floor, 08039 Barcelona, Spain
Tax ID: A65445033
Email: lopd@clidom.es

Holaluz has designated a Data Protection Officer in its organization. If you want to make a query regarding the processing of your personal data, you can contact us through the email indicated above. For any question related to the functions granted to the Data Protection Officer, you can send us an email directly to dpd@holaluz.com.

3. Personal data collection and processing

The personal data that may be processed on the website, as well as the legal basis that justifies such data processing, are set out below.

Contracting: In order to manage any type of contract offered through the Website, different personal data may be processed depending on the type of contact you choose:

by telephone: your cell phone number will be processed;
via the web form: your name, e-mail address, and telephone number will be processed and you will be required to provide your last utility bill, which contains personal data.

Customer Zone: To manage your access and use of the Customer Zone we will process your identification, consumption, contractual, and billing data.
Producer Zone: To manage your access to the Producer Zone we will process your identification, contractual, billing, and production metrics data.
Collaborations: To manage your collaboration form with Holaluz it is necessary to process the following contact data: Name and surname, email, telephone, province, type of professional (legal or natural person), and tax identification.
Commercial communications: In order to manage any commercial communication and/or newsletter subscription of Holaluz products and services, your name and surname, email and/or cell phone number will be treated as well as any other personal data required to manage such treatment.
Customer Service: In order to manage any kind of support in case of doubts related to the services offered or breakdowns, data such as cell phone number will be processed, as well as any other information that you decide to communicate through the phone call. This may be recorded for quality reasons.
Work with us" form: In order to manage any job application, your data such as name and surname, e-mail, telephone number, curriculum vitae, as well as, optionally, your photograph will be processed. There is the option to manage your application through the LinkedIn provider. To opt for this option you must accept their Privacy Policy to consent to the transfer of data to Holaluz.
Activities of sweepstakes, promotions and/or campaigns: In order to manage activities related to sweepstakes, promotions and/or advertising campaigns through our website or social networks where Holaluz is active, we may require the personal treatment of your data to fulfill such activity. Depending on the activity, different personal data may be requested, so we reserve for each occasion the fulfillment of the duty to inform you specifically when such activities are active.

4. Legal basis for the processing of your data

The legal basis justifying the processing of the aforementioned data is:

Consent of the interested party for:
- Apply for a job application;
- Commercial communications;
- Newsletter subscriptions;
- Customer Service;
- Sweepstakes, promotions and/or campaigns;
- Process of optional cookies accepted by the user, as defined in the Cookies Policy.
Contractual Relationship for:
- The subscription and/or execution of the contractual relationship between Holaluz and its Customers;
- Verification of the customer's solvency by consulting the solvency and credit files and registration if necessary.
Compliance with legal obligations for:
- Fraud prevention;
- Communication with public authorities and third-party claims;
- Prevention of money laundering and financing.

5. Conservation of your personal data

We only keep Personal Data for the time necessary for the purposes for which it was collected with your express consent, to meet your needs, to fulfill the contractual relationship and/or to comply with applicable legal obligations.

To determine how long we retain personal data, we use the following criteria:

Personal data obtained when contacting Holaluz in relation to an inquiry or request: during the time necessary to resolve the inquiry;
Personal data obtained by giving consent to send commercial communications will be kept for a period of 2 years from the last communication unless the interested party exercises his or her right to object in accordance with his or her rights;
Personal data obtained by giving consent to apply for a job application will be kept for a period of 2 years from the application unless the candidate exercises his right of opposition in accordance with his rights;
The personal data provided for the contracting of services will be kept by Holaluz for the time necessary for everything related to the service to be provided. The data will be deleted within 5 years from the end of the contractual relationship, in order to comply with tax and sectorial regulations.

Some of the Personal Data may be retained to comply with legal or regulatory obligations, as well as to administer Holaluz's rights (e.g., to file claims in court) or for statistical or historical purposes.

Once the legally mandated periods of conservation of your Personal Data have elapsed, Holaluz will proceed to delete them from the systems and/or records or anonymize them so that the user can no longer be identified.

Holaluz has a Data Retention Policy. For more information, please contact us by e-mail at lopd@clidom.es.

6. Recipients to whom your data is disclosed

In some cases, only when necessary, Holaluz will provide user data to third parties. However, the data will never be sold to third parties. The external service providers that Holaluz relies on to provide auxiliary services for the processing of the data may have access to the data in accordance with the instructions indicated by Holaluz and with the sole purpose of correctly executing the contractual relationship that exists between Holaluz and its suppliers.

To obtain information regarding the suppliers that access your personal data, you can send an e-mail to lopd@clidom.es.

Holaluz seeks to ensure the security of personal data when it is sent outside the company and ensures that third-party service providers respect confidentiality and have adequate measures in place to protect personal data. These third parties have an obligation to ensure that the information is treated in accordance with data privacy regulations. In order to comply with these safeguards, Holaluz enters into data processor agreements with such providers in accordance with Article 28 of the GDPR.

In some cases, the law may require that personal data be disclosed to public bodies or other parties, only what is strictly necessary for the fulfillment of such legal obligations will be disclosed.

Additionally, Holaluz may transfer personal data to other companies of the Holaluz Group for the management of the contract or for the sending of commercial information. Specifically, for those who contract the service related to the electricity supply and financing and supply of the self-consumption installation, Holaluz may transfer the data to other Holaluz Group companies for the overall management of such service, including the issuance of invoices and the management of other contracts that the Customer may have with any other Holaluz Group companies.

Finally, we inform you that for the mobile application, Holaluz will only transfer personal data to the company's own domains.

7. Storage of your personal data

In general, data is stored within the EU. However, in the event that the processing of your data means an international transfer of data outside the European Economic Area (EEA) Holaluz undertakes to implement the necessary security measures to ensure an adequate level of safeguarding of such transfers by means of data processor contracts and, where appropriate, will ensure that they offer an adequate level of protection, either because they have Binding Corporate Rules (BCR) or because we have subscribed to the model clauses of the European Commission. For more information on service providers, please contact us at the following e-mail address: lopd@clidom.es.

8. Exercise of rights and how can you exercise them

You can send your communications and exercise your rights by sending a request to the following e-mail address lopd@clidom.es.

Under the GDPR you can request the following:

Right to information: you may request information about personal data held about you.
Right of rectification: you can communicate any change in your personal data.
Right of deletion and right to be forgotten: you can request the prior blocking of the deletion of personal data.
Right to limitation of processing: this is to restrict the processing of your personal data.
Right to data portability: in some cases, you may request a copy of personal data in a structured, commonly used, machine-readable format for transmission to another data controller.
Right to object and automated individual decision-making: you may request that decisions based solely on automated processing, including profiling, that produces legal effects or significantly affect the data subject not be made.

In some cases, the request may be denied if you request the deletion of data necessary to comply with legal obligations. Also, if you have a complaint about data processing, you may file a complaint with the competent data protection authority (Agencia Española de Protección de Datos or "AEPD").

9. Responsible for the accuracy and veracity of the data provided

The user is the one responsible for the veracity and correctness of the data included, exonerating Holaluz from any responsibility in this respect. The user guarantees and responds, in any case, to the accuracy, validity, and authenticity of the personal data provided, and undertakes to keep them updated. The user agrees to provide complete and correct information in the registration or subscription form Holaluz reserves the right to terminate the services contracted with the users, in the event that the data provided is false, incomplete, inaccurate, or not updated.

Holaluz is not responsible for the veracity of the information that is not of its own elaboration and of which another source is indicated, and therefore Holaluz does not assume any responsibility for hypothetical damages that may arise from the use of such information.

Holaluz reserves the right to update, modify or delete the information contained in its web pages and may limit or deny access to such information.

10. Security measures implemented to protect your personal information

Holaluz has adopted the legally required security levels for the protection of personal data and tries to install those additional technical means and measures within its reach to avoid the loss, misuse, alteration, unauthorized access, and theft of the personal data provided to Holaluz.

Holaluz is not responsible for the hypothetical damages that could derive from interferences, omissions, interruptions, computer viruses, telephone breakdowns, or disconnections in the operative functioning of this electronic system, caused by causes beyond the control of Holaluz of delays or blockages in the use of this electronic system caused by deficiencies or overloads of telephone lines or overloads in the Data Processing Center, in the Internet system or in other electronic systems, as well as damages that may be caused by third parties through illegitimate intromissions beyond the control of Holaluz. However, the user must be aware that the security measures on the Internet are not impregnable.

In particular, the website is secured with a TLS certificate with RSA encryption, which means that all information sent to the website is encrypted with an HTTPS protocol.

11. Contact and modification of the Privacy Policy

This privacy policy is subject to change. It is recommended to review it from time to time.

Last revision: August 2023