Privacy policy
Glovo
DATA PROTECTION POLICY
1. DATA CONTROLLER
Your personal data will be processed by:
| Information | |
|---|---|
| Data Controller | Glovoapp23, S.L. - N VAT number B-66362906 |
| Postal address | Calle Pallars 190, 08005, Barcelona, Spain |
| Phone number | (+34) 932694744 |
| Contact form | https://glovo.c-etico.es/?locale=en |
| Data Protection Officer (DPO) Contact | [email protected] |
2. PROCESSED PERSONAL DATA
Whether you provide us with your personal data directly or if it is provided to us by a third party, we will process the following personal data:
| Data subjects | Categories of data and data subject to processing |
|---|---|
| Nominal whistleblower |
a) Identification data: name and surname. b) Contact information: email and phone number c) Information related to the potential unlawful behaviour, e.g. employment data, tax data, economic data, etc. d) Evidence: photographs or documents that may help demonstrate the denounced behaviour. |
| Anonymous whistleblower (Reports in which the whistleblower can provide the following information) |
a) Pseudonym. b) Contact information: email and phone number. c) Evidence: photographs or documents that can demonstrate the denounced events. |
| Confidential whistleblower (Reports in which the whistleblower does not want to disclose his/her/their identity. In this case, the provided identification data will only be managed by the Law firm Ribas as managers of the Glovo Ethical Channel) |
a) Identification data: name and surname. b) Contact information: email and phone number c) Data related to the behavior reported: employment data, tax data, economic data, etc. d) Evidence: photographs or documents that can demonstrate the denounced events. |
| The person against whom an allegation has been made |
a) Identification data: name, surname, ID, etc. b) Data related to the reported behaviour: employment data, tax data, economic data, etc. c) Evidence: photographs or documents that can demonstrate the denounced events. |
| Witness |
a) Identification data: name,surname, ID, etc. b) Contact information: email, phone number, address, etc. c) Data related to the reported behaviour: employment data, tax data, economic data, etc. d) Evidence: photographs or documents that can demonstrate the denounced events. |
| Third parties |
a) Identification data: name, surname, ID, etc. b) Contact information: email, phone number, address, etc. c) Data related to the reported behaviour: employment data, tax data, economic data, etc. d) Evidence: photographs or documents that can demonstrate the denounced behaviours. |
3. PURPOSE
The data will be processed in order to manage Glovo’s reporting “Ethical Channel”, follow-up reports, carry out investigations, protect the whistleblowers from retaliation and provide adequate remedies if they are not treated correctly and fairly in relation to their whistleblowing, take measures to address the raised. and initiate legal actions against the wrongdoer in accordance with Glovo’s compliance model and its Code of Ethics.
In the case of inquiries, also to resolve them and facilitate their response to the interested party.
4. LEGITIMATE BASIS
The processing of personal data with regard to the whistleblowing procedure is legitimate since it is necessary for the performance of a task carried out in the public interest.
Glovo will process personal data to answer enquiries on grounds of the consent provided by the whistleblower upon completion and submission of the “Risk or non-compliance communication form”.
5. DATA COMMUNICATION
Glovo will not disclose your data to any third party, except for its service providers, who carry out certain activities on its behalf and who are bound by confidentiality agreements (for example, legal or IT providers), but under no circumstance for their own purposes.
6. PROFILING AND AUTOMATED DECISIONS
In no case will Glovo make automated decisions with your data or create profiles.
7. INTERNATIONAL TRANSFERS
Glovo has international providers, so your data may be processed outside the European Union or the European Economic Area.
In any case, Glovo will ensure that data processing is always protected with the appropriate guarantees, which may include:
- Standard Clauses approved by the EU: these are contracts approved by the European regulator, and which provide sufficient guarantees to guarantee that the processing complies with the requirements established by the European Data Protection Regulation.
- Third-party certifications: framework agreement between the EU and a third state that establishes a standardized framework for data processing in accordance with the requirements of the European Data Protection Regulation.
8. DURATION OF THE PROCESSING
Glovo will keep the provided personal data within the channel for a maximum of three (3) months, to decide on the on the pertinence of initiating an investigation of the reported events or behaviours. Upon expiry of said period, Glovo will delete the personal data.
However, in case an investigation is deemed necessary, Glovo is entitled and will keep the provided personal data outside the reporting channel for a longer period for as long as necessary to conduct the investigation.
In the event that the investigation leads to the implementation of certain measures against the investigated person, the data will be kept for as long as the criminal, civil or labor actions continue. Once the corresponding conservation period ends, either for completing the investigation or for adopting measures against the investigated persons, the data will be duly blocked and kept in order to prove compliance with the Glovo compliance model and, where appropriate, for the fulfillment of legal obligations. Once this period has expired, the data will be deleted.
In the case of enquiries, personal data will be kept for as long as necessary to answer the interested party. Once the corresponding conservation period expires, the data will be duly blocked and kept in order to prove compliance with Glovo's compliance model and, where appropriate, for the fulfillment of legal obligations. Once this period has expired, the data will be deleted.
9. EXERCISE OF YOUR RIGHTS
You may exercise your rights of access, rectification, deletion, opposition, limitation or portability by communicating by email to [email protected].
If you have any questions about how Glovo processes the provided personal data or on any other issue related thereto, you may contact our DPO also at [email protected] .
Additionally, you are also entitled to submit a complaint to the relevant Data Protection Authority if you consider that Glovo has processed your data in contravention of this Data Protection Policy and/or any other relevant applicable regulations.