Processing of personal data:
Prevention of money laundering

Information about personal data processing

Data Controller: The personal data you provide will be processed by Sacyr, S.A. (henceforth SACYR or the company), with registered offices at Calle Condesa de Venadito, 7, 28027, Madrid, as the data controller.

Purpose of the processing: Your personal data will be processed in order to manage your submission, conduct an investigation of the reported events, adopt the relevant corrective measures, and notify you the results of the procedure.

You should know, in relation to the possibility of send anonymous complaints, that the company will investigate them properly, provided they contain sufficient information to do so.

Lawfulness of processing: Some Sacyr Group companies are bound by Anti-money laundering and terrorist financing regulations. In an effort to prevent operations related to these crimes, regulations include requirements for internal control and risk management policies that apply to bound subjects and include the establishment of reporting channels, among other obligations. Therefore, the legitimate basis for processing personal data in these cases is compliance with legal obligations.

At the same time, the users of this Channel express their consent to the processing of their data by marking the relevant box indicating that they have understood and accept the processing of their personal data in the terms provided in this privacy policy.

Retention data period: The data will be retained for the period necessary to reach a decision about launching an investigation into the reported events. Data will be kept no longer than is necessary to conduct the investigation.

The company also reserves the possibility, in order to be able to execute its defense rights with all guarantees, to keep the complaint files duly blocked for the statute of limitations that applies in each case to the criminal offense reported.

Recipients or categories of recipients of the personal data: Personal data will be treated confidentially. Access to this data will be limited exclusively to those who perform internal control and compliance functions, or the processors designated for that purpose.

However, that the identity of the complainant will in any case be reserved, it is possible that in order to investigate and clarify the facts duly reported, your data may be communicated to:

  •  Authorities and Public Administrations who may intervene in the investigation or potential legal proceedings.
  •  Individuals who may be involved in the investigation itself, if the proper management of this depends on it, in a proportional, adequate, and suitable manner.
  •  Third parties that may provide the Sacyr Group support for this Channel: data hosting platforms, people to whom the investigation may be delegated, lawyers and other advisors.

Exercise of data rights: At any time, you may exercise your rights of access, rectification, erasure, objection, restriction, and portability about your personal data by post at the address indicated or by email at protecciondedatos@sacyr.com, including a copy of your national identification document and identifying yourself as a user of the Prevention of Money-Laundering Channel.

In the event you consider your data protection rights violated, you may contact the Sacyr Group’s Data Protection Officer (dpo@sacyr.com) or file a claim with the Spanish Data Protection Agency (www.aepd.es).

Additional information: If you need to ask for additional information on any specific aspect of the processing of your data within the framework of this Channel, you can contact dpo@sacyr.com at any time.

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