The PRIVACY POLICY is part of the Legal Notice which regulates this Website, alongside the Regulations on the Use of Cookies.
The website belongs to GRUPO CYCLUS (Inversiones Evfran, S.L.), which includes Innovaciones Técnicas y Recursos Constructivos, S.A. (ITERCON); Infraestructuras y Servicios Servitria, S.A. (SERVITRIA) and Alondra Servicios Inmobiliarios, S.L. (ALONDRA) and meets the requirements derived from Law 34/2002, of 11 July, on the Information Society and Electronic Commerce Services, and current legislation regarding personal data protection and in particular 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, and Organic Law 3/2018, of 5 December, on Personal Data Protection and the guarantee of digital rights.
GRUPO CYCLUS (Inversiones Evfran, S.L.), which includes Innovaciones Técnicas y Recursos Constructivos, S.A. (ITERCON); Infraestructuras y Servicios Servitria, S.A. (SERVITRIA) and Alondra Servicios Inmobiliarios, S.L. (ALONDRA) reserves the right to modify or adapt the present Privacy Policy at any time. Therefore we recommend that you review this every time you access the Website. In the event that a user has registered on the website and accesses their account or profile, when accessing this, they will be informed in the event that substantial modifications have been made regarding the processing of their personal data.
Who is the DATA CONTROLLER?
The data collected or which is voluntarily provided via the Website, whether by browsing it, or by data provided in contact forms, via email or by telephone, will be collected and processed by the Data Controller, whose details are shown below:
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Identity: |
GRUPO CYCLUS (Inversiones Evfran, S.L.), which includes Innovaciones Técnicas y Recursos Constructivos, S.A. (ITERCON); Infraestructuras y Servicios Servitria, S.A. (SERVITRIA) and Alondra Servicios Inmobiliarios, S.L. (ALONDRA). |
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TAX ID CODE: |
B97791826 |
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Postal address |
C/.Jesús, 81 entresuelo – 46007 – Valencia (VALENCIA) |
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Telephone number |
963804304 |
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datos@grupocyclus.com |
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URL: |
servitria.com |
If, for any reason, you want to contact us (our Data Protection Officer) regarding any issue related to the processing of your personal data or privacy, you can do this via any of the aforementioned means.
When, why, who, how, for what and how long will your personal data be processed?
When and why?
You can browse most of our webpages without providing any personal information, but in some cases this information is necessary to provide you with the electronic services you request.
If we need to collect personal data in order to provide a service, we will process the information according to the policy explained in this document and the condition specified for the specific service in question (if any), which contain specific privacy statements on the use of data and inform you of why, what for, how, and for how long your personal data will be processed and the security measures we implement.
Who collects your data?
The collection and processing of the personal data you provide will be carried out by our organization or, if applicable, by the data processors.
In the latter case, the processors are third parties who are contractually required to ensure that their activity respects the law, and to implement appropriate security measures to protect this data.
What for?
The personal data we request, or which you provide on the basis of your browsing, allow us to manage, provide and improve the services you have requested.
For example, we process your personal data to be able to deal with the queries you send, to manage your participation in staff selection processes, to send you electronic communications in the event you request this and, where appropriate, to prepare statistics.
In this sense, we ask for an email address when you use our website’s contact forms. We only collect the personal data from the sender which is required to reply to them.
When you subscribe to our newsletters we also ask for an email address to be able to provide you with the service; in any event you can unsubscribe from the service when you choose and we will provide ways to do so.
How do we process your data?
We only collect personal data to the extent required to accomplish a specific purpose. The information will be not used for a purpose other than that described.
We only reveal the information to third parties where necessary to comply with the purpose of the service and only to the people who need to know this. The aim of all this is to ensure that the service processing your personal data is provided confidentially and with discretion, in accordance with current legislation.
In any case, our organization adopts security measures to protect data against possible abuse or unauthorised access, alteration or loss.
How long do we keep your data for?
We only keep the data for the time required to fulfil the purpose of its collection or subsequent processing. This data retention period will depend on the service and the duration of the personal data processing will be indicated for each service.
At the end of this document, we provide a table with the specific retention periods.
What PURPOSES do we process your personal data for?
– Customers:
We process your personal data for the purpose of (1) managing your purchase or service provided; (2) maintaining the contractual and pre-contractual relationship for invoicing, creating quotes and following them up, in addition to sending information electronically regarding your request; (3) sending communications electronically regarding sales information which may be of interest, provided express consent has been given; (4) creating a sales profile based on the information provided, in order to be able to offer you products and services in accordance with your interests. No automated decisions will be made based on this profile.
– Suppliers:
We process your personal data for the purpose of (1) invoices, (2) maintaining business contact and, where appropriate, (3) sending information electronically about our products or services.
– Contacts on the website or by email:
We process your personal data for the purpose of (1) replying to your queries or requests; (2) managing the service requested or processing your order; (3) sending commercial information electronically which may be of interest, provided express consent has been given; (4) creating a sales profile based on the information provided in order to be able to offer you products and services in accordance with your interests. No automated decisions will be made based on this profile.
– Contacts via social media:
We process your personal data for the purpose of (1) replying to your queries or requests, (2) managing the service requested, replying to your request or processing your order and (3) interacting with you and creating a community of followers.
– Job seekers:
We process your personal data for the purpose of (1) involving you in hiring selection processes, (2) setting up job interviews and evaluating your application, (3) sharing your CV with companies in the group, collaborators or similar with the sole objective of having them participate in your selection processes, provided you have given your consent to do so.
– Participants in our competitions:
We process your personal data for the purpose of managing your participation in the competitions we organize, as well as publicizing the winners of the competition and the prize award ceremony.
The winners may be photographed or recorded by video and broadcast on any of the media, our website or other means of communication. Accordingly, the participants’ image may be captured, recorded and/or reproduced as an accessory to the main activity.
– Users of the website:
When browsing our website, we collect information about your browser, your device and the use you make of our website as well as any other information you provide us with when using our website. We may record the IP address (identification number for the device’s access to the internet, which allows devices, systems and servers to recognize and communicate with each other) in an anonymized or aggregated form.
The purpose of the processing is (1) to obtain practical understanding of how users use our webpage, allowing us to improve it; (2) make statistical analyses, helping us to improve our sales strategy; (3) analyse web performance and (4) for technical safety and systems diagnosis.
The data obtained is not linked to a specific user and will be stored on our database.
The aforementioned data, together with any personal data in the event that this is provided, is stored as cookies, which are collected in a pseudonymous format and subject to objections of this personal data being presented, as detailed in the Cookies Policy.
You may consult the Cookies Policy in the corresponding section.
Information on your browsing may be stored via Google Analytics, which is why we refer to Google’s Privacy Policy, since it is they who collect and process this information. Política de Privacidad de Google, ya que éste recaba y trata tal información.
Likewise, Google Maps can be used from our website, which may have access to your location, in the event that you allow this, in order to provide you with greater specificity regarding the distance and/or routes to our offices. In this regard, we refer to the privacy policy used by Google Maps, in order to understand the use and processing of this data. política de privacidad utilizada por Google Maps, con el fin de conocer el uso y tratamiento de tales datos.
In order to offer information or services of interest on the basis of the User’s location, we may access data on the geolocation of the User’s device in cases where the user’s settings for that purpose allows this.
The Website may offer functions in order to share content via third-party applications such as Facebook, Instagram or Twitter. These applications may collect and process information related to the user’s browsing on different websites. Any personal information collected via these applications may be used by third-party users of the same. Your interactions are subject to the privacy policies of the companies which provide the applications.
The website may host blogs, forums, and other applications or social network services in order to facilitate the exchange of knowledge and content. Any personal information provided by the user may be shared with other users of the service, which we do not have any control over.
– Video surveillance:
You are also informed that we have a video surveillance system, the purpose of which is to ensure the safety of people, assets and installations. Current regulations legitimise processing performed on the basis of legitimate interest, so your image may be recorded by the simple act of accessing our installations.
This data may be communicated to the State Security Forces where necessary. The images will be kept for the maximum period of one (1) month after recording.
What is the LEGAL STANDING for processing your data?
– Customers:
The legal basis for processing your data is (1) the execution of a contract and maintenance of the contractual relationship and (2) your consent which is requested to send offers of products and services electronically, without the withdrawal of this consent conditioning the execution of the contract under any circumstances.
– Suppliers:
The legal basis for processing your data is the execution of a contract which the interested party is party to, or to apply pre-contractual measures.
– Contacts on the website or by email:
The legal basis for processing your data is the consent of the interested party.
In cases where it is necessary to fill in a form and click on the send button to make a request, this necessarily implies that you have been informed and have expressly granted your consent to the contents of the clause attached to this form or acceptance of the privacy policy.
- All our forms have a verification checkbox which it is necessary to tick in order to access the services offered..
- b)The purposes of the processing will be the following:
The personal data provided by this means will not be communicated to third parties, with GRUPO CYCLUS (Inversiones Evfran, S.L.), which includes Innovaciones Técnicas y Recursos Constructivos, S.A. (ITERCON); Infraestructuras y Servicios Servitria, S.A. (SERVITRIA) and Alondra Servicios Inmobiliarios, S.L. (ALONDRA) replying directly to this type of queries.
– Contacts via social media:
The legal basis for processing your data is the acceptance of the contractual relationship with the provider of the corresponding social network, declared by signing up to their application and in line with their privacy policies, which is external to us.
– Work with us
In the event that you provide us with your CV, whether via the Website, email or physically at the headquarters or any office of GRUPO CYCLUS (Inversiones Evfran, S.L.), which includes Innovaciones Técnicas y Recursos Constructivos, S.A. (ITERCON); Infraestructuras y Servicios Servitria, S.A. (SERVITRIA) and Alondra Servicios Inmobiliarios, S.L. (ALONDRA), this will be included on our database. The CV will be stored for a period of 1 year, after which, in the event that we have not contacted you, it will be deleted.
The legal basis for this processing is based on the express consent given by the interested party for the data contained in their CV to be processed when sending it and by checking the box provided for this purpose.
The purpose of the processing is to include it in present and future selection processes at GRUPO CYCLUS (Inversiones Evfran, S.L.), which includes Innovaciones Técnicas y Recursos Constructivos, S.A. (ITERCON); Infraestructuras y Servicios Servitria, S.A. (SERVITRIA) and Alondra Servicios Inmobiliarios, S.L. (ALONDRA), or any organization belonging to this business group.
In the event that the interested party eventually becomes an employee of GRUPO CYCLUS (Inversiones Evfran, S.L.), which includes Innovaciones Técnicas y Recursos Constructivos, S.A. (ITERCON); Infraestructuras y Servicios Servitria, S.A. (SERVITRIA) and Alondra Servicios Inmobiliarios, S.L. (ALONDRA) or any of the organizations belonging to this business group, their details will be included on a database belonging to the same, with the purpose of internally managing the employee-employer relationship.
– Sending newsletters(Newsletter):
On the website there is the option to subscribe to the newsletter of GRUPO CYCLUS (Inversiones Evfran, S.L.), which includes Innovaciones Técnicas y Recursos Constructivos, S.A. (ITERCON); Infraestructuras y Servicios Servitria, S.A. (SERVITRIA) and Alondra Servicios Inmobiliarios, S.L. (ALONDRA). To this end, we need you to provide an email address to send this to..
This information will be stored on a database pertaining to GRUPO CYCLUS (Inversiones Evfran, S.L.), which includes Innovaciones Técnicas y Recursos Constructivos, S.A. (ITERCON); Infraestructuras y Servicios Servitria, S.A. (SERVITRIA) and Alondra Servicios Inmobiliarios, S.L. (ALONDRA), where it will be recorded until the interested party requests to unsubscribe from the same or, where appropriate, GRUPO CYCLUS (Inversiones Evfran, S.L.), which includes Innovaciones Técnicas y Recursos Constructivos, S.A. (ITERCON); Infraestructuras y Servicios Servitria, S.A. (SERVITRIA) and Alondra Servicios Inmobiliarios, S.L. (ALONDRA) stops sending the newsletter.
La base legal para el tratamiento de estos datos personales es el consentimiento expreso prestado por todos aquellos interesados que se suscriban en este servicio marcando la casilla destinada a tal efecto.
The legal basis for processing this personal data is the express consent given by all interested parties who subscribe to this service when checking the box intended for that purpose.
– Participants in our competitions:
The legal basis for processing your data is your consent when registering for the competition and accepting the privacy policy and rules of the competition.
The personal data collected will not be ceded to third parties.
– Users of the website:
The legal basis for processing your data is (1) our legitimate interest in understanding the ways our users browse, in order to adapt to their interests and improve our relationship with them, and (2) their consent given by browsing our website and accepting the terms and conditions of use for cookies.
Which RECIPIENTS will be informed of your data?
Your data will not be ceded to third parties external to the service provided, except due to legal obligation. Specifically, they will be communicated to the Tax Agency, banks, and financial entities to charge for the service provided or product acquired.
Your data may also be communicated to our service suppliers where necessary to execute the contract. In these cases, the data processor is under contract to use the data only for the purpose justified by the processing and to adhere to appropriate security measures.
What SECURITY MEASURES do we apply?
You can rest assured that we have adopted suitable organizational and technical measures to guarantee confidentiality, integrity and availability in the processing we perform on your personal data, specifically those preventing the loss, improper use, alteration, unauthorised access and theft of personal details.
What are your RIGHTS when you provide us with your data?
You can exercise your rights to access, rectification, erasure, portability, restriction of processing or objection to data processing, including the right to withdraw consent given, as detailed below:
Right of access: : You can ask us whether we are processing your data and in what way.
Right of rectification: : You can ask us to update your personal details if they are incorrect, and delete them if you wish.
Right to restrict processing: : In this case, they will only be kept by us for the exercise or defence of claims.
Right to object:: After your objection to processing request, we will stop processing your data in the form you indicate, unless for overriding legitimate reasons, the exercise or defence of possible claims, it must continue to be processed.
Right to data portability: : In the event that you would like your data to be processed by another company, we enable the portability of your data to the new processor.
Right to erasure: : You can request that we delete your data when it is no longer necessary for processing, when you withdraw your consent, the processing is unlawful or there is a legal obligation to do so. We will analyse the case and apply the law.
If you need more information on which rights are recognised by the law and how to exercise them, we recommend you contact the Spanish Data Protection Agency (Agencia Española de Protección de Datos (AEPD), which is the regulatory authority for data protection.
Where appropriate, you can contact the Data Protection Officer prior to filing a claim with the SDPA against the data controller.
In the event that we have not dealt with the exercise of your rights, you can file a claim with the SDPA.
We have forms available for the exercise of these rights, which can be requested at the aforementioned email address, and those created by the SDPA or third parties may also be used. These forms must be signed electronically or be accompanied by a photocopy of your ID.
Similarly, if you act through a representative, it must be accompanied by a copy of your ID or electronic signature.
The maximum time period for resolving this is one month starting from when the request is received.
How long do we KEEP your data for?
Your personal data will be kept for as long as you maintain a connection with us.
When this ends, the personal data processed for each of the purposes mentioned will be kept for the legally established period. In the event that this legal period does not exist, until the interested party requests their erasure or revokes the consent given, or during the period that a judge or court may require them, based on the limitation period for judicial measures.
We provide you with a specific period for each type of data or processing, which can be consulted in the following table:
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Data regarding |
Document |
Retention |
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Customers and suppliers
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Invoices |
4 years (time limitation), art. 66 Ley 58/2003, General Taxation. 10 years (time limitation), Law 34/2015, of 21 September, partially modified by Law 58/2003, General Taxation (Art. 66 bis). Checks and investigations by the administration. |
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Contracts |
5 years |
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Documents and records with tax implications |
General Law on Taxation, articles 66 to 70 4 previous financial years (years) |
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Obligated parties Law on Preventing Money Laundering, supporting documents for fulfilling PML obligations |
Law 10/2010 art. 25 10 years |
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Human Resources |
Nóminas, TC1, TC2, etc. |
10 years, LO 7/2012 |
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Curriculums |
Until the end of the selection process, and up to one additional year unless the interested party revokes consent or requests erasure. |
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Documents on compensation due to dismissal. Contracts. Data on temporary employees. Worker’s file.
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Law on infractions and sanctions in the social order (RD 8/2000): art. 21 4 años
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Daily record of the working day.. |
RD ley 8/2019 4 años |
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Documentation or computer records accrediting compliance with OHS regulations.
Required documentation for the obligation to pay Social Security contributions. |
RDL 5/2000 art. 4 5 years |
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Digital tachograph: transfers and copies of data stored in the memory. |
Royal Decree 125/2017, of 24 February. 1 year |
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Márketing |
Databases or website visitors |
During data processing |
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Access control and video surveillance |
Visitor register |
Instructions 1/1996 SDPA 30 days |
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Video surveillance.
When dealing with an educational centre. (Placed in communal areas of the educational centre to protect minors). |
Art. 22.3 Spanish Organic Law 3/2018 of 5 December on the Protection of Personal Data and guarantee of digital rights. 30 días
SDPA Legal report 475/2014 10 días |
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Accounting |
Ledgers and accounting records. Member and board of director agreements, company bylaws, minutes, board of directors and delegate committees’ regulations.. Financial statements, audit reports. Records and documents related to grants. |
Commercial Code art. 30. 6 years |
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tax |
Time limitation on the verification of tax bases and deductions. |
10 years, Law 34/2015, of 21 September, partially modifying Law 58/2003, General Taxation (art. 66bis) |
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Accounting books and other obligatory record books (IRPF [personal income tax], IVA [VAT], IS [corporate tax], etc.) as well as supporting documents which justify the notes made in the records. Overseeing company administration, rights and obligations regarding the payment of taxes. Administration of dividend payments and tax retention. |
4 years, articles 66 to 70, General Law on Taxation. |
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Health and Safety |
Workers’ Medical Records. |
5 years |
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Environment |
Information on chemical or substantially hazardous substances |
10 años |
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Documents related to environmental permissions. For the duration of the activity. |
3 years after the activity ends 10 years (prescription of the offence) |
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Records on recycling or waste disposal. |
3 years |
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Grants for cleaning operations: documents of rights and obligations, bills and payments must be kept |
4 años |
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Accident reports. |
5 años |
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Insurance |
Insurance policies./p> |
6 years (general rule) 2 years (damages) 5 years (personal) 10 years (life) |
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Purchases |
Register all goods delivered or services provided, intracommunity acquisitions, imports and exports for VAT purposes. |
10 years |
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Legal |
Intellectual and Industrial Property documents. Contracts and agreements. |
5 años |
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Permits, licences, certificates |
6 years from the expiry date of the permit, licence or certificate. 10 years (criminal prescription period) |
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Confidentiality and non-competition agreements. |
Always for the duration of the obligation or confidentiality |
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Data protection regulations |
Records and documents accrediting compliance with the data protection legislation requirements (audits, reports, processor agreements, etc.) |
During data processing and afterwards for a period of 3 years |
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Documentation accrediting that requests from interested parties exercising their rights are handled |
For 3 years after the request |
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Logs/records of access to IT systems. |
2 years |
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If the processing is based on consent from the interested party, proof of consent |
During data processing and afterwards for a period of 3 years |
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Complaints channel |
Internal complaints
Regulatory compliance programme (corporate criminal liability) |
LOPDGDD 3/2018, art. 24.4 3 months, unless the purpose of the retention is to leave evidence of the operation of the crime prevention model by the legal entity. 10 years (criminal prescription period) |
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Money laundering |
Obligated parties must keep the documentation in which compliance with the obligations established in this Law is formalised for a minimum period of ten years.
In any case, the archive system of obligated parties must ensure appropriate management and availability of documentation, both for the purposes of internal control, and for correct and timely attention to the authorities’ requirements. |
10 years
Article 25 of Law 10/2010 of 28 April, on the prevention of money laundering and the financing of terrorism. |
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Medical records |
Health centres have the obligation to preserve clinical documentation in conditions which guarantee their proper conservation and security, although not necessarily in the original format, for adequate assistance to the patient for the time appropriate in each case and for at least five years starting from the registration date of each healthcare process.
Clinical documentation will also be kept for legal purposes in accordance with current legislation. It will also be kept when there are epidemiological, research or organizational reasons, or those related to the functioning of the National Health service. Its processing will be done in such a way as to avoid the identification of those affected, as far as possible.
To ensure future use of the clinical history, especially healthcare, it will be kept for the minimum period established in basic state legislation, starting from the registration date of each healthcare process, or from the death of the patient. |
5 years (minimum))
Article 17 of Law 41/2002, of 14 November, on patient autonomy and rights and obligations regarding clinical information and documentation.
Law 10/2014, of 29 December, in the Community of Valencia (Health) |
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Traffic data regarding internet connections, emails and landline and mobile phone calls. |
User identification, IP address (origin/destination), telephone number, IMSI and IMEI (origin/destination), date and time of the communication (start/end), identification of the type of service or communication used (voice, data, SMS or MMS…) |
1 year
Article 5 of Law 25/2007, of 18 October, on data retention regarding electronic communications and public communications networks. |
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Accounts audit. |
The accounts auditors and accounts auditing companies will keep and safeguard the documentation relating to every accounts audit performed by them, including the auditor’s paperwork which constitutes the evidence and support for the conclusions given in the report, for the period of five years./p> |
5 years
Article 24 of RD Leg. 1/2011 of 1 July, approving the revised text on the Law of Accounts Auditing. |
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Access control to buildings. |
Data included on the automated files created to control access to buildings must be cancelled one month after obtaining it. |
1 month
Fifth rule from Instruction 1/1996, of 1 March, from the Data Protection Agency, on automated files established with the purpose of controlling access to buildings. |
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Documents in lawyer’s files |
Since the actions that can be taken to demand professional liabilities from the lawyer are of a personal nature and do not have a special one designated, as of October 7, 2015, the limitation period for them is five years, so completed files must be kept for at least this period of time (except for interruptions in their calculation). |
5 years
Art. 1964.2 Civil Code, as amended by Law 42/2015, of 5 October, reforming the LEC |
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Record books and entrance reports in hotel establishments. |
Entrance reports will be grouped in record books of a minimum of 100 and a maximum of 500 sheets. These record books must be kept for three years at the disposal of the Security Forces, and then discarded in such a way that no access is given to the personal information contained therein.
The records include details of children under 14 years old: the report is signed by the minor when they are 14, but if they are under 14, it will be signed by the person accompanying them.
The details to be requested include: landline telephone, mobile telephone, email address, number of travellers, family relationship, whether the establishment has an internet connection.
The details also include payment details: type (cash, credit card, payment platform, transfer…), identification of the means of payment (type and number of card, IBAN bank account, mobile payment solution, etc.), holder of the means of payment, card expiry date, payment date.
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3 años
OM INT/1922/2003 of 3 July, on record books and entry reports on travellers in hostelry establishments and other similar establishments.
3 years
The data from the computer records must be kept for a period of three years starting from the end of the service or provision contracted (non-professional hosting is exempt from registration and communication must be made)
Royal Decree 933/2021, “Obligations for documentary records and information for natural or legal persons who carry out lodging and motor vehicle rental activities.” Updates Order INT/1922/2003, including new types of lodging activities: short-term tourist housing, internet websites.
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Driving assessment centres. |
The centre must keep the content of the reports issued for a ten-year period, including the opinions of the clinicians, doctors and psychologists who participated in the assessment, the complementary reports presented (if applicable) and additionally, in the case referred to in section 2 of article 3, the documents provided by the interested party. |
10 years
Article 15.5 of Royal Decree 170/2010, of 19 February, which approves the Regulation of assessment centres intended to verify drivers’ psychophysical aptitudes. |
