BASIC INFORMATION ON PERSONAL DATA PROTECTION
RESPONSIBLE
Empresa de Alumbrado Eléctrico de Ceuta Distribution, S.A. (“EAEC Distribución”).
PURPOSES AND BASIS OF LEGITIMIZATION
Treatments required for the execution of the RTA contract:
- To process requests for the establishment of new supply points, including those necessary for their connection or the development of the necessary actions for such purpose.
- Manage and process requests, claims or inquiries you make in relation to the contract, the provision of service or customer services, or new supply points.
- Take the consumption readings you have made and proceed to verify them.
- Repair and inspection of installed metering equipment and reading of consumption.
- Attention to requests for modification of the service contracting conditions.
- To carry out, with the commercializing company with which you have a supply contract, the necessary communications for the economic management of the contract and the payment of the service.
- To send you relevant communications related to the terms of service.
- Share with the supplier with whom you have a supply contract, the necessary data to inform about the impossibility of billing.
Processing necessary for EAEC Distribution to comply with its legal obligations:
- Compliance with the functions of distribution companies as set forth in the electricity sector regulations, such as: providing the distribution service correctly, building, operating and maintaining the distribution network, analyzing applications for connection to the distribution network, maintaining the database of supply points, or billing and collecting tolls for access to the transmission and distribution networks, among others.
- Detect fraud situations.
- Communicate identification, technical and consumption data to the commercialization company with which you have a contractual relationship.
- Communicate the information related to your consumption to the National Markets and Competition Commission for its incorporation into the supply point information system, as well as to Red Eléctrica de España for the latter's compliance with its obligations as system operator.
- Communication of data to Security Forces and Corps, Judicial Bodies, Public Prosecutor's Office and competent Administrations, in compliance with the applicable legal obligations.
Tratamientos basados en el consentimiento del interesado:
- Communicate your consumption to the marketers you have consented to.
- Send you notices about the scheduled interruption of the electricity supply of any of the supply points you own, when you have voluntarily subscribed to EAEC Distribución's alert service.
- Manage your registration as a User in EAEC Distribución's web page.
- Attend to your requests, queries or claims as interested party when you are not a user or client of EAEC Distribución.
Treatments based on the vital interest of the person concerned:
- Management of supplies considered essential or electro-dependent.
- Proactively send you alerts from the alert service with information about the scheduled interruption of the electricity supply of any of the supply points of which you are the owner, in the event that you have declared yourself to be electro-dependent.
TARGET
EAEC Distribución may communicate your personal data to the following entities (i) to the commercialization company with which it is necessary to enter into the ATR contract necessary for the provision of the service you have contracted; (ii) to the Security Forces and Corps, the Public Prosecutor's Office and the Courts and Tribunals when we are required to do so by Law; and (iii) to the bodies to whose supervision EAEC Distribución is subject.
Finally, we will provide access to your data to service providers that EAEC Distribution contracts or may contract and have the status of processors (it is possible that some of these processors are located outside the European Economic Area).
RIGHTS
Access, rectification, cancellation, limitation of processing and portability of data. If you have given your consent for any of the purposes described above, you may withdraw it at any time. To exercise these rights, you may contact Ribera del Loira street, no. 60, 28042 Madrid with the subject “Data Protection”, providing the name and surname of the interested party, address for notifications, photocopy of the ID, passport or any other identification document, and a petition specifying the request.
ADDITIONAL INFORMATION
You can consult more information about EAEC Distribution's data protection policy in the DATA PROTECTION POLICY drop-down menu.
In Empresa de Alumbrado Eléctrico de Ceuta Distribución, S.A. we are committed to guarantee the use of the personal data of our customers in a transparent and secure manner, so we want you to know that you have control over them at all times. As a Client of EAEC Distribución or User, you will be able to decide, as long as the regulations in force allow us to do so, what your personal data will be used for and to whom it will be transferred, under what conditions and for what purpose.
To make this possible and in accordance with the best practices of Corporate Governance and Compliance, within our processes of constant review and improvement, we update our Data Protection Policy, replacing the previous one, in order to renew your trust with us and to let you know how we collect, treat and protect your personal data.
1) Who can process your data?
2) Definitions
3) What personal data do we process?
4) Why do we process the data and on what legal basis?
5) How long do we keep your data?
6) Do we process data of minors?
7) What security measures are applied?
8) What information do we share with third parties?
9) What rights do I have in relation to the processing of my personal data?
10) How can I contact the Data Protection Officer of EAEC Distribution?
11) Changes in the Data Protection Policy
1) Who can process your data?
The person responsible for the processing of your personal data is Empresa de Alumbrado Eléctrico de Ceuta Distribución, S.A. (“EAEC Distribución”) with CIF A51004166. The contact details of the data controller are as follows:
Postal address: C/ Beatriz de Silva, 2, 51001, Ceuta / Apartado de correos 13, 51080, Ceuta.
Telephone: 956 51 19 00
2) Definitions
In order for you to better understand our Data Protection Policy, we define below the concepts included in it:
· Customer: natural person who is the holder of the contract whose supply point is located in the EAEC Distribution network.
· Contract: agreement regulating the terms and conditions applicable to the contracting.
· Third Party Network Access Agreement (“TPA Agreement”): is the contract formalized between the distribution company and the customer so that the latter can access the network and it is possible to bill the corresponding tolls and charges.
· CUPS: Universal Supply Point Code. It is the alphanumeric code that uniquely identifies an address to certify the energy supply. Each home has one for electricity supply and another for natural gas supply. It is permanent and invariable, i.e., it does not change, even if the tariff or supplier is changed.
· EAEC Distribution: Empresa de Alumbrado Eléctrico de Ceuta Distribución, S.A. company dedicated to the development of electric power transmission and distribution activities.
· Commercialization Company: is the company with whom you directly contract an electricity or gas tariff and who issues and collects the bills. It is the company that, by accessing the transmission or distribution networks, buys the energy for sale to the company that generates it and pays the distribution company what it costs to transport it from the generation plants to the homes, companies, businesses, etc.
· Distribution Company: is the company responsible for distributing energy to your home. In the Spanish electricity market, by law, citizens cannot choose their distribution company, which is determined by the area where you live.
· Data Processor: a natural or legal person who processes personal data on behalf of the Controller.
· Interested party: any identified or identifiable natural person.
· LOPDGDD: Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights.
· Data controller: natural or legal person who, alone or jointly with others, determines the purposes and means of processing.
· RGPD: 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 repealing Directive 95/46/EC.
· Supply Point Information System (“SIPS”): The technical, consumption and commercial data base for each of the supply points connected to the network of each electricity or natural gas distributor.
· Web user: registered user on EAEC Distribution website or application
3) What personal data do we process?
EAEC Distribución will process the personal data that is provided to it, directly by you or through your Distributor on your behalf, on the occasion of the signing of the ATR Contract, as well as those that derive from the execution and development of the aforementioned contract, specifically: name and surname, DNI/NIE/Passport, postal address, email address, telephone, CUPS number and IBAN number.
In EAEC Distribución we only process the data that are strictly necessary for the specific purposes set out in this Data Protection Policy and only for the time required for this purpose, as specified in paragraph 5, always respecting all the principles and obligations contained in both the RGPD, as in the LOPDGDD.
In the questions below we explain in detail why and how we treat your data.
4) For what purposes do we process your data and on what legal basis?
1. Data processing for the proper management and development of the ATR contract.
EAEC Distribution will process your personal data for the management, maintenance and control of the relationship arising from the conclusion of the ATR contract, which includes processing related to:
· The processing of requests for the establishment of new supply points, including those necessary for their connection or the development of the necessary actions for such purpose.
· The management of any complaints, requests or queries that you may direct to EAEC Distribution in relation to the provision of the service and the provision of customer services.
· The verification, repair and inspection of the metering equipment installed for the verification of the consumption made and the reading of the consumptions made.
· The attention of your requests for modification of the service contracting conditions, such as, for example, the modification of the contracted power.
· The economic management of the contract and the processing of the payment of the service, if applicable, with the supply company you have contracted.
· The sending of communications that are relevant in relation to the conditions for the provision of the service.
· Share the necessary data (CUPS, dates of the billing period and dates of entry and exit of the standby circuit) with the supplier with whom you have a contract in force to inform about the impossibility of billing because it has not been possible to access the consumption reading, while waiting for the stipulated period to elapse to receive the reading or to proceed to its estimation.
2. Processing of personal data associated with the fulfillment of legal obligations and functions under the regulations of the electricity sector.
EAEC Distribution will process your personal data in order to comply with the legal obligations and functions set out in the regulations of the electricity sector for distribution companies, among which the following are worth mentioning:
· To provide the distribution service on a regular and continuous basis, and with the quality levels determined by the regulations in force.
· To build, operate and maintain the distribution network, as well as, if applicable, interconnections with other networks.
· Analyze applications for connection to your distribution network and manage the connection according to established regulatory criteria.
· Expand distribution facilities when necessary to meet new electricity demands, ensuring an adequate level of service quality at all times.
· Maintain a database of supply points (SIPS) in accordance with regulations.
· To apply, invoice and collect tolls for access to the transmission and distribution networks.
· Detect situations of fraud in access to electricity supply and other anomalous situations in compliance with Article 40.2.s of Law 24/2013, of December 26, of the Electricity Sector.
Likewise, in compliance with the applicable obligations included in the sector regulations, EAEC Distribución will provide the identification and technical data of your supply point, as well as your consumption data (hourly load curve) to the Distribution Company with which you have signed the electricity supply contract.
Likewise, in accordance with the regulations governing the electricity sector, it will provide the information referring to your consumption to the National Commission of Markets and Competition for its incorporation into the SIPS, which may be accessed by marketing companies other than the one with which you have contracted the electricity supply, for the purpose of sending you commercial offers on electricity supply.
You may, at any time, oppose to your data included in the SIPS being provided to the marketers, communicating it to EAEC Distribución through the channels established for the exercise of your rights, as explained in the section “Rights of the interested parties”.
Furthermore, also in compliance with the legal obligations established by the electricity sector regulations, EAEC Distribución will communicate the data referring to your consumption (hourly load curve) to Red Eléctrica de España (REE), in order for the latter to comply with its obligations as System operator.
The treatments and communications that have been indicated are carried out in compliance with the legal obligations contained in Article 40 of Law 24/2013, of December 26, 2013, of the Electricity Sector, its implementing regulations or any other rule that could modify or replace the current regulatory framework.
The data processed or communicated by EAEC Distribución for these purposes are those established in said regulations.
Finally, EAEC Distribución will communicate, in compliance with its legal obligations, your personal data to meet the information requirements that may be addressed to it by the Security Forces and Corps, Judicial Bodies, the Public Prosecutor's Office and the competent Administrations in matters of regulation and supervision, such as the National Commission for Markets and Competition, the Ministry for Ecological Transition and the Demographic Challenge or the Spanish Data Protection Agency.
3. Treatments based on your consent
When the legal basis that allows the processing of your personal data is your consent, your data will only be processed for the purpose you have expressly permitted, in which case you will have the right to revoke your consent at any time and free of charge, without retroactive effect, by sending your request to any of the addresses indicated in this Privacy Policy for the exercise of data protection rights.
· Specifically, EAEC Distribution will communicate the complete information related to your consumption (hourly load curve) to the marketers to which you have consented, and they must provide reliable proof of the provision of such consent, which will be the legal basis for the aforementioned communication.
· Additionally, in the event that you have voluntarily subscribed to the EAEC Distribución alert service, your consent will be the basis of legitimacy on which your data will be processed in order to give you advance notice of the scheduled interruption of the electricity supply of any of the supply points of which you are the owner, due to the safety of the workers who carry out improvement and maintenance work in EAEC Distribución's facilities.
4. Processing to protect the vital interests of the data subject or of another natural person
EAEC Distribución may collect special data such as health data necessary to manage supplies considered essential or electro-dependent, provided by the Supplier with which you have entered into the electricity supply contract, in order to proactively receive alert service notifications with information on the scheduled interruption of the electricity supply of any of the supply points of which you are the owner, for the safety of the workers who carry out improvement and maintenance work at EAEC Distribución facilities.
5) How long will we keep your data?
The personal data associated with the fulfillment of legal obligations and functions included in the regulations of the electricity sector will be kept for the period in which they are necessary to comply with such legal obligations and the functions included in the regulations of the electricity sector for the distribution companies applicable in the Autonomous Community in which it is established.
Specifically, in accordance with the provisions of Royal Decree 1048/2013, of 27 December, which establishes the methodology for the calculation of the remuneration of the electricity distribution activity, the personal data corresponding to the supply points connected to the EAEC Distribution network, including those contained in the metering equipment, will be kept for twelve (12) years from the time the contract was no longer in force.
The data processed for the management of your status as a registered user of the website will be kept for as long as you continue to hold such status. However, if it is detected that you have not used or interacted with your account for a period of two (2) years, your account will be cancelled and the data will be kept in a blocked state for five (5) years for the statute of limitations period for personal actions that do not have a special statute of limitations period.
Finally, the data processed for the processing of requests and queries sent through the website by those who do not have the status of users of the same will be kept as long as they are necessary to carry out the processing of such requests and queries and, thereafter, will be kept in a blocked situation for five (5) years for the period of limitation of personal actions that do not have a special period of limitation.
As soon as these periods have elapsed in accordance with the provisions of the applicable legislation, the data will be definitively deleted.
6) Do we process data of minors?
In EAEC Distribution ensures the proper use of the data of minors, ensuring respect for the laws applicable to them and using the measures that may be reasonably appropriate, and therefore, no personal data of minors are collected without the prior consent of their parents, guardians or legal representatives.
7) What security measures are applied?
EAEC Distribución, in order to make its Data Protection Policy effective and efficient, has adopted the necessary technical and organizational security measures to prevent the alteration, loss, misuse, unauthorized access and processing or theft of the same, depending on the state of technology, for all channels in which personal data may be processed, including, therefore, all web pages, telephone services and, where appropriate, face-to-face channels.
8) What information do we share with third parties?
1. Data transfers
EAEC Distribution will not make any data communications other than those mentioned in the section “Purpose and basis of legitimacy” and always in the cases where it is required by applicable law or you have given your consent to do so.
Specifically, EAEC Distribution may carry out the following transfers of your data:
• Communication to the Commercialization Company with which you have a contract in force, as well as to those with which you have given your consent, of the necessary identification and technical data of your supply point and your consumption data (hourly load curve).
• Communication of the information related to your consumption expressly established in the regulations governing the electricity sector to the National Commission of Markets and Competition for its inclusion in the SIPS, which may be accessed by marketing companies other than the one with which you have contracted the electricity supply, in order to send you commercial offers on the electricity supply.
• Communication of your consumption data (hourly load curve) to Red Eléctrica de España (REE), for the latter to comply with its obligations as System Operator.
• Communication of your personal data to the Security Forces and Corps, the Judiciary, the Public Prosecutor and the competent authorities in the field of regulation and supervision, such as the National Commission for Markets and Competition, the Ministry for Ecological Transition and the Demographic Challenge or the Spanish Data Protection Agency, in response to requests for information that they may direct to EAEC Distribution.
2. Access to personal data by service providers (data processors)
Your personal data may be accessed by third party service providers that collaborate with EAEC Distribución in the development of its activity providing, for example, the following services: Quality and Environmental management, reading of metering equipment (service included in Multiservicios MTBT), meter inspection and energy recovery, backoffice and customer service.
These suppliers will act as EAEC Distribución's data processors, always following the instructions provided by EAEC Distribución at all times, without being able to use the data for other purposes, and guaranteeing, at all times, the confidentiality, security and secrecy of the information to which they have access. To this end, EAEC Distribution has analyzed that these suppliers have adopted measures to ensure the protection of personal data and has formalized with them the corresponding contracts, in which they undertake to treat personal data to which they have access in accordance with the requirements of the RGPD and the LOPDGDD.
It is also possible that some of these third parties acting as data processors are located in countries outside the European Economic Area that have not been declared States with an equivalent level of data protection. In particular, EAEC Distribution has contracted fully trusted suppliers located in: Morocco, Colombia, Peru and the United States. In any case, EAEC Distribution has assessed that the processing of your personal data in these countries complies with the same guarantees required by the European regulations and has adopted the appropriate safeguards necessary to ensure the protection of your data, in particular by subscribing with these suppliers to the standard contractual clauses approved by the European Commission. You can request information on the safeguards adopted by EAEC Distribution for the international transfer of your personal data, including a copy of these safeguards, by contacting dpd@electricadeceuta.com .
9) What rights do you have regarding the processing of your personal data?
The RGPD and the LOPDGDD include the following rights in relation to the processing of your personal data that you can exercise before EAEC Distribution:
· Access: allows you to confirm whether we are processing your personal data and, if so, which ones.
· Correction: allows you to help us correct errors and modify data that may be inaccurate or incomplete.
· Deletion: allows you to request the deletion of your data, which will mean that EAEC Distribución will stop processing them unless there is a legal obligation to keep them or there are other legitimate reasons for us to process them.
· Opt-out: allows you to ask us to stop processing your personal data in respect of which we may consider that we have a legitimate interest in processing, based on the grounds that you provide us with.
· Limitation of processing: You may ask EAEC Distribución to limit the processing of your data in the following cases:
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- While a challenge to the accuracy of your data that you have submitted to us is being checked.
- Where the processing is unlawful, but you object to the erasure of your data.
- When EAEC Distribution does not need to process your data but you need it for the exercise or defence of claims.
- When you have objected to the processing of your data for the performance of a task carried out in the public interest or for the fulfilment of a legitimate interest, while verifying whether the legitimate grounds for the processing outweigh yours.
· Portability: allows you to receive your personal data in a structured, commonly used and machine-readable format so that you can transmit it to another Data Controller.
· Revocation of consent: allows your data to stop being processed for a purpose that you previously authorised, for example, registration in the private area of the EAEC Distribución website.
To exercise these rights you can contact EAEC Distribución by sending a written and signed request through any of the following channels: By post, by sending a letter to the following address: C/ Beatriz de Silva, 2, 51001, Ceuta, or by e-mail to the following address: comunicacioneslopd@electricadeceuta.com.
We would also like to remind you that the regulations in force allow you to file a complaint with the Spanish Data Protection Agency, whose contact details are as follows:
Spanish Data Protection Agency
Calle Jorge Juan, 6 - CP: 28001, Madrid.
Telephone numbers: 901 100 099 / 91 266 35 17
10) How can I contact the EAEC Distribution Data Protection Delegate?
If you have any questions regarding the processing of your personal data, you can contact our Data Protection Officer.
EAEC Distribución has appointed a Data Protection Delegate to whom you can report any questions regarding the processing of your personal data and whose contact details are as follows: / Beatriz de Silva, 2, 51001, Ceuta and e-mail dpd@electricadeceuta.com .
11) Changes to the Data Protection Policy
Whenever EAEC Distribución updates this Data Protection Policy, in particular, as a result of new processing of personal data, the new Data Protection Policy will be made available to Customers and Users.
Thank you for the trust you have placed in EAEC Distribución.