1. Data Controller

• Company Name: Cirvexa S.L.
• Commercial Registry Number: 000946807
• Tax Identification Number (NIF): B22754089
• Registered Office: Arquitecto Rodríguez Street, 41, Door 6, 46019 Valencia, Spain
• Contact Email Address: info@cirvexa.es

2. Purpose of Video Surveillance

Cirvexa S.L. operates a video surveillance system on its premises for the purpose of:

• Ensure the safety and protection of people, assets, and facilities
• Prevent criminal activities and unauthorized access
• Investigate incidents affecting security
• Safeguard legal claims and defend the company's interests

The video surveillance system NO is used for systematic monitoring of employee performance or productivity.

3. Legal Basis for Processing

The processing of personal data through video surveillance is based on:

• Legitimate interest of the data controller (Article 6.1.f GDPR) in the protection of individuals, assets, and facilities
• Compliance with Organic Law 3/2018, on Personal Data Protection and Guarantee of Digital Rights (LOPDGDD)
• Guidelines established by the Spanish Data Protection Agency (AEPD)

4. Personal Data Processed

The video surveillance system captures and records:

• Visual images of individuals (employees, customers, visitors) present in monitored areas
• Date and time of recordings
• Location information (specific camera zones)

The system does not perform audio recording.

5. Monitored Areas

Video surveillance cameras are installed in the following areas:

• Main entrance and reception area
• Open workspaces
• Corridors and common circulation areas
• Storage facilities and warehouse
• Balconies and window areas

Cameras are NOT installed in: Toilets and restrooms

6. Retention Period

Video recordings are retained for a maximum period of 30 days from the recording date, after which they are automatically deleted.

Exception: Recordings may be retained beyond 30 days when:

• An incident investigation is underway
• Legal proceedings require evidence preservation
• Authorities (police, courts) request access for criminal investigations

7. Access to Recordings

Access to video surveillance recordings is strictly limited to:

• Authorized internal personnel: IT administrators and company directors
• Storage Location: Calle Arquitecto Rodríguez 41, Pta. 6, 46019 Valencia, Spain
• Remote Access: Secure remote viewing enabled via encrypted internet connection
• Access log: All viewing activities are recorded in system logs

8. Recipients and Data Transfers

Video recordings are not shared with third parties except in the following circumstances:

• Legal obligation: When required by State Security Forces and Agencies
• Judicial requirements: When ordered by Courts and Tribunals
• Authorized third parties: Data may be transferred to specifically authorized entities for security purposes under strict confidentiality agreements

No international data transfers are performed.

9. Security Measures

Cirvexa S.L. implements technical and organizational security measures, including:

• Password-protected access to viewing and management systems
• Encryption of network communications and data storage
• Physical security of recording equipment in restricted access areas
• Privacy masks applied to cameras viewing public thoroughfares
• Automatic deletion of recordings after the retention period
• Audit logs that track all system access and operations
• Regular security assessments and updates

10. Your Rights

In accordance with the GDPR and Spanish data protection legislation, you have the following rights:

• Right of Access: Request confirmation of whether your personal data is being processed and obtain a copy of recordings in which you appear
• Right to Rectification: Request the rectification of inaccurate personal data
• Right to Erasure: Request the erasure of recordings in specific circumstances
• Right to Restriction of Processing: Request restriction of processing in certain situations
• Right to Object: Object to processing based on legitimate interests
• Right to Lodge a Complaint: File a complaint with the Spanish Data Protection Agency (AEPD) at www.aepd.es

11. How to Exercise Your Rights

To exercise any of your data protection rights, please contact us:

• By email: info@cirvexa.es
• By postal mail: Cirvexa S.L., Calle Arquitecto Rodríguez 41, Pta. 6, 46019 Valencia, Spain

Required information:

• Full name and identification document
• Clear description of your request
• Preferred contact method for response

Response period: We will respond to your request within one month of receipt. In complex cases, this period may be extended by two additional months with prior notification.

12. Informative Signage

Warning signs are displayed at all entry points to monitored areas, containing:

• Clear camera icon indicating video surveillance
• Identity of the data controller (Cirvexa S.L.)
• Contact information for exercising rights
• Reference to this privacy policy for additional information

13. Updates to This Policy

This privacy policy may be updated to reflect changes in:

• Video surveillance system configuration
• Legal requirements and regulatory guidelines
• Data protection best practices

The current version is always available upon request at info@cirvexa.es.

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