EU Regulation 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



Identity: CLECE, S.A. – A-80364243
Address: CLECE, S.A., C/ Quintanavides, 19 – Bloque 4 – planta 2 (28050-Madrid)
Contact: 917459100
Data Protection Delegate (DPD):


We process the information you provide for the purpose of:

  • Data processed to provide the contracted service.
  • Financial, economic, accounting, administration and management.
  • Management and maintenance of court proceedings.
  • Remittance of trade information concerning the purpose of the existing contract.
  • Remittances of trade information on products and services (prior consent)
  • Managing and developing activities relating to fraud prevention and control.
  • Ethics channel Dealing with communications received through the various media or channels made available, such as the email address on the company’s website, telephone (24/7) and the web platform managed by the contracted data processor, with the guarantee of maintaining the sender’s absolute confidentiality and that no reprisals of any kind will be taken for acting in good faith.

Management of trade exclusions. Base with minimum data to avoid sending trade communications to persons who have not consented to or who have recalled their consent.


  • Enforcement of a contract
  • Legitimate interest
  • Prior consent
  • Public interest (Ethics channel): The communications channel (Ethics channel) is based on the existence of a public interest, in the terms established in article 6.1.e) of the General Data Protection Regulation, on detecting and preventing complaints and the corresponding prevention of damages and risks of liability to CLECE and as defined in article 24 of Organic Law 3/2018.



  • For trade purposes: Accounting and tax documentation: 6 years  – Art. 30 Trade Code.
  • For trade purposes: 4 years – Articles 66 to 70 General Tax Law.
  • Royal Decree 1619/2012, of 30 November, which approves the Regulation that regulates the billing obligations: 5 years
  • Corporate preservation term: 10 years considering requirements by competent authorities on the matter

Ethics channel Will be held in the complaints reception system solely for the length of time needed to ascertain the facts reported. In any event, the information must be removed from the system three months after it was entered. However, it may be processed outside of the system to investigate the facts reported for as long as is necessary until such time as the matter is concluded. Once the investigation of the communication has concluded and any appropriate actions have been taken, the data pertaining to said complaints that have been processed will be held and duly blocked in compliance with any applicable legal obligations. If the decision is made not to take the complaint filed any further, the information may be held in said system in anonymised form.


Their data may be legally notified to:

  • Public Administrations with competence on the matter.
  • Financial institutions in terms of managing payment and collections resulting from contractual relationships.
  • Social Security administration departments, the tax administration, and judges and courts.
  • State security forces.
  • Social Security administration departments, the tax administration, and judges and courts.
  • Insurance companies, and insurance and reinsurance brokers, in terms of managing accidents and/or incidents, including the processing of special personal data.
  • Service providers, in certain contracted circumstances, to provide services on our behalf. In these cases, when necessary, data processing agreements are formalised, in accordance with data protection standards.



The persons concerned have the right to obtain confirmation regarding whether the company is processing their personal data.

They have the right to request:

  • Access to their personal data.
  • Amendment of inexact data.
  • The elimination when, among other reasons, the data are no longer needed for the purposes for which they were obtained.
  • The limitation of the processing of their data, in which case we will only preserve them in order to exercise or defend claims.
  • To object to the processing of their data, in certain circumstances and for reasons relating to their personal situation.  The company will cease to process the data, except for imperative legal reasons, or the exercise or defence of possible claims.

The rights recognised in the EU Regulation 2016/679, may be exercised directly or by means of legal or voluntary representative.

You may request the exercise of rights by electronic means to contact e-mail of the Data Protection Delegate or sending your request to the address of the Responsible Person, indicated above.

To obtain information regarding your rights, you may visit:

If you have not obtained satisfaction in exercising your rights, you may submit a claim at the Spanish Data Protection Agency