Privacy Policy

by admin

In accordance with Article 10 of Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce, we hereby inform you CIRCULAR PACKAGING, SL with C.I.F. B10519379

and address at C/ ALBORAYA, 42 – PTA 2


is responsible for the management and operation of the site WWW.CIRCULARPACKAGING.NET


If you wish to contact us, you can do so by post to the address above or by e-mail to INFO@CIRCULARPACKAGING.NET

Access to our domain can be done directly or through any existing redirection, being the Privacy Policy applicable to this domain;


This Privacy Policy describes how we process your personal data (e.g. collection, use, disclosure, retention and protection of your personal information) and provides information about your rights as a data subject;

CIRCULAR PACKAGING, SL is responsible for the processing, as well as for the collection, use, communication, conservation and protection of your personal data, in accordance with the General Data Protection Regulation, internal rules and policies or any applicable national regulations.


In compliance with the Organic Law 3/2018 of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD), as well as the new General Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, by means of the present document, CIRCULAR PACKAGING, SL informs:



Identity and contact details of the person in charge;


Our identifying information:

CIRCULAR PACKAGING, SL You can contact us


By post: C/ ALBORAYA, 42 – PTA 2 46010 (VALENCIA)

  • By telephone: 96 297 20 13



Categories of personal data

We process the following categories of personal data:


  • Identification data– name and surname, ID card or equivalent
  • Administrative data – Company name, address, bank details and contact persons
  • Contact details– email, telephone number and address;
  • Digital data – cookies, IP address, websites and social networks and other data publicly accessible on the Internet, etc.
  • Employment data – data of own employees, curriculum, studies, professional experience and health;
  • Business data –suppliers, customers, managers and partners;
  • Other data necessary for processing–For more information on the category of personal data in the course of our Business, you can consult our Register of Activities at URL “Category of Data”;



How do we collect your data?

We collect information about you from the following sources:


  • When communicating or interacting with you by telephone, e-mail or other means of contact from our company;
  • Through the Contact form on the website;
  • Through our social networks (see section in this document);
  • Through a commercial visit;
  • When you visit our facilities;
  • Through time control tools;
  • When you provide us with a curriculum vitae;


For more information on the different data collection mechanisms in the development of our Activity, you can consult our Register of Activities at WWW.CIRCULARPACKAGING.NET.


How long do we keep your data?


The data will be kept for as long as there is a commercial, contractual or professional relationship with the data subject and thereafter for the years necessary to comply with the corresponding legal obligations in each case; Without prejudice to the foregoing, they shall be kept for as long as they are necessary for the processing and the data subject does not request their deletion;


With regard to data of an employment nature or related to social security, documentation or the registers or computer media on which the corresponding data have been transmitted that accredit compliance with the obligations in terms of affiliation, registrations, deregistrations or variations that, where applicable, may occur in relation to such matters, as well as the contribution documents and receipts justifying the payment of salaries and the delegated payment of benefits, according to Article 21 of Royal Legislative Decree 5/2000, of 4 August, which approves the revised text of the Law on Infringements and Penalties in the Social Order, they shall be kept for 4 years.


With regard to accounting and tax documentation, for tax purposes, the accounting books and other compulsory books and records in accordance with the relevant tax legislation (IRPF, IVA, IS, etc.)and the supporting documents justifying the entries in the books (including computer programs and files and any other tax relevant supporting documents)must be kept, at least, for the period in which the Administration has the right to check and investigate and, consequently, to settle the tax debt, according to Articles 66 to 70 of the General Tax Law, which is 4 years;


With regard to accounting and tax documentation, for commercial purposes, books, correspondence, documentation and supporting documents relating to its business, duly ordered as of the last entry made in the books, except as provided for by general or special provisions, this commercial obligation extends to both the compulsory books (income, expenditure, investment goods and provisions), in addition to the documentation and supporting documents for the entries recorded in the ledgers (invoices issued and received, tickets, corrective invoices, bank documents, etc.)., according to Article 30 of the Commercial Code, shall be 6 years;


The data relating to the time controls of workers shall be kept, as established in Royal Decree-Law 8/2019, of 8 March, on urgent social protection measures to combat precariousness in the working day, for 4 years;


For more information on the conservation of data in the development of our Activity, you can consult our Register of Activities at WWW.CIRCULARPACKAGING.NET, section “Period of suppression”;


To whom do we give your data?

Depending on the purpose of the processing, your personal data may be transferred or processed to different categories of recipients:


  • Collaborators or external professionals (Labour and Tax Consultants, Mutual Insurance Company in charge of health surveillance, Occupational Risk Prevention Company, …).
  • Public administrations (the General Social Security Treasury, the State Public Employment Service, the Ministry of Labour, the Ministry of Finance, the and entities or bodies granting aid or subsidies of interest to the company, which will use them in the legitimate exercise of their powers).


However, we transfer your data only to the extent strictly necessary and in the manner required to carry out the purposes described in this privacy policy and only to entities with which we have signed agreements protecting your rights and freedoms in relation to your personal data, these entities and/or professionals considered as Processors will be governed by the provisions of Art. 28 of the GDPR and this entity is responsible for taking all necessary security measures in accordance with Art. 32 of this GDPR;

For more information on the transfer of data to third parties in the development of our Activity, you can consult our Register of Activities at WWW.CIRCULARPACKAGING.NET section “Category of Recipients”;


Where do we process your data?

In order to carry out our business, the provision of our services, we process your personal data in accordance with the conditions set out in this privacy policy within the European Union (EU);


For more information on where we process data in the course of our business, you can consult our Register of Activities at WWW.CIRCULARPACKAGING.NET, section “International Transfer”;


For what purposes do we process your data?


Your data will be collected for the relevant processing operations for the following purposes:


  • Receive contact information or other requests made by you through any of our communication channels;
  • Administrative tasks derived from the sale of our products;
  • Add your CV to our job bank;
  • Time and attendance of employees;



For more information about the purposes of data processing in the development of our Activity, you can consult our Register of Activities at WWW.CIRCULARPACKAGING.NET section “Purposes of Processing”;


You may withdraw your consent at any time free of charge by exercising your rights by sending your request in writing and duly identified by a supporting document to our address C/ ALBORAYA, 42 – PTA 2 46010 (VALENCIA) or by e-mail to INFO@CIRCULARPACKAGING.NET. For more detailed information on the exercise of your rights you can consult our Register of Activities at WWW.CIRCULARPACKAGING.NET

Why may we process your data?


The use of your data under the conditions described above is permitted by European and Spanish data protection regulations in accordance with the following legal bases:

Art.6. RGPD

  • The data subject consented to the processing of his or her personal data for one or more specific purposes;
  • The processing is necessary for the performance of a contract to which the data subject is party or for the implementation of pre-contractual measures at the request of the data subject
  • The processing is necessary for compliance with a legal obligation applicable to the controller;

For more information on the legal basis for the processing of data in the development of our Activity, you can consult our Register of Activities at WWW.CIRCULARPACKAGING.NET The “Legitimation of the processing” section;


What and what are your rights?


Data protection regulations allow you to exercise your rights of access, rectification, objection, erasure (“right to be forgotten”), restriction of processing, portability and the right not to be subject to individualised decisions


Any interested party has the right to be provided, BEFORE their data is collected, with basic information at a first level, in summary form, at the same time and in the same medium in which their personal data is collected and, on the other hand, to be provided with the rest of the information, in a medium more suitable for its presentation and comprehension;


The information to be provided by layers or levels would be as follows:


Information 1st Layer


  • The identity of the Controller;
  • What data will be processed?
  • For what purpose;
  • Where and how they were obtained;
  • The legal basis for the processing;
  • Whether they will be communicated, transferred or processed by third parties;
  • Reference to the procedure for the exercise of rights;


Information 2nd Layer


  • Contact details of the person in charge; Identity and details of the representative (if any); Contact details of the data protection officer (if any);
  • Extended description of the purposes of the processing; Time limits or criteria for data retention; Automated decisions, profiling and applied logic;
  • Details of the legal basis for the processing, in cases of legal obligation, public interest or legitimate interest; Obligation or not to provide data and consequences of failure to do so;
  • Addressees or categories of addressees; Adequacy decisions, guarantees, binding corporate rules or specific applicable situations;
  • How to exercise the rights of access, rectification, erasure and portability of data, and the limitation or opposition to their processing;
  • The right to withdraw consent;
  • Right to complain to the supervisory authority;



(The following table indicates what your rights are);


Right of access To know which of your data is being processed, for what purpose it is being processed, where the data has been obtained and whether it will be communicated or has been communicated to someone else
Right of rectification To modify your inaccurate or incomplete information;
Right of cancellation To cancel your inappropriate or excessive data
Right to object To prevent the processing of your data or to stop the processing of your data, but only in the cases provided for by law;
Right to restriction of processing To request the suspension of data processing in the cases established by law;
Right to data portability To be able to receive your provided data in a structured, commonly used electronic format and to be able to transmit it to another Data Controller;
Right not to be subject to individualised decisions In order that no decision is taken about you that produces legal effects or affects you based solely on the processing of your data;



These rights are characterised by the following:


  • It is free of charge;
  • You may exercise your rights directly or through a legal representative;
  • If the application is submitted by electronic means, the information shall be provided by electronic means where possible, unless the data subject requests otherwise;
  • Before exercising your rights, we must identify you in order to protect your personal data against fraudulent attempts;
  • Your application will be decided within one month;


If the requests are manifestly unfounded or excessive (e.g. repetitive nature), the controller may:

  • The data controller is obliged to inform you about the means to exercise these rights; These means must be accessible and this right cannot be denied on the sole ground that you choose another means;
  • If the controller does not comply with the request, it shall inform, at the latest within one month, of the reasons for its failure to act and the possibility to complain to a supervisory authority;


If you wish to exercise any of the rights described above, you may contact us through our Internal Data Protection Officer:

  • By postal address:


Att. Data Protection Officer



Cookies are files that are downloaded to your computer to collect standard Internet log information and information about browsing habits; This information is used, for example, to track visitor usage of the website and compile statistical reports on website activity;

You can set your browser not to accept cookies; However, some first party cookies are necessary to enable the website user’s session to use our services;

For more information, please visit the website’s Cookie Policy;

Social networks

CIRCULAR PACKAGING, SL has a presence in different media or social networks, such as: Facebook, Twitter, Youtube and Instagram, the purpose of the processing of personal data being those established within the conditions affecting the service. In the event that the registration to certain services is made through personal data associated with a user account, we inform you that we will share certain information contained in your account; CIRCULAR PACKAGING, SL

remember that you should be aware of the privacy policies of those media or social networks where you are registered in order to avoid sharing unwanted information;

You have the privacy and account management settings on social networks to manage your privacy, identity, advertising and other related preferences;

In the event that the registration to certain services is made through personal data associated with a user account, we inform you that we will share certain information contained in your account;

Detailing each of the social networks, atFacebookWhen a user becomes a fan of the official Fan Page through the “Like” button, he/she authorises that his/her personal data will be used only on this Facebook platform for the management of the “Fan Page” and the communications that are maintained in a bidirectional way with said followers through chat, publications, comments, messages or other means of communication that the social network allows now and in the future. This treatment will be subject to the privacy policies of this social network, which the user can consult at the following link: By becoming a fan you will have access to the list of members or followers who have joined the Fan Page; It is also reported that when a user becomes a fan, the news that are published will also appear on your home page and that if the user fan makes comments on these publications, will be accessible by other fans both his comment and the name of your profile and, where appropriate, the photograph you have in the same or according to your privacy settings, or biography and tagging. In any case, the use of the social network is the responsibility of the user;

In relation toTwitterWhen a user follows our profile by clicking on the “Follow” button, you will have access to the profile page of the people who follow you, specifically, the user’s name, photograph (if the user has put a photograph on the profile), and comments or “Tweets” or replies made by the user or by others mentioning the user, as well as other information that has been published on the user’s profile such as users who are followed, their followers or favourites on the profile; The data of users who follow our profile on Twitter are used only to manage and respond to the “Tweets” or messages exchanged between the two; The privacy policy governing this social network can be consulted at the following link:

In relation toLinkedIn, when a user publishes his profile as a professional, we will have access to the public data incorporated by this in this social network; We will also be able to communicate with them through it; The privacy policy governing this social network can be consulted at the following link:

With respect to Whatsapp, when a user joins us as a contact, we will have access to their public data and their status updates. In addition, we will be able to communicate with them through it; The privacy policy can be consulted at


CIRCULAR PACKAGING, SL adopts organisational and technical measures with the aim of guaranteeing the security of personal data and avoiding its alteration, loss, unauthorised processing or access, taking into account the state of technology, the nature of the data stored and the risks to which they are exposed;

UpdatesWe keep our privacy policy under review and may change it from time to time (primarily to comply with legal and data protection practices);

Updated versions will be published on our website;

Applicable law and competent courts

The terms and conditions governing this web site, as well as the relationships that may arise are protected and are subject to Spanish law; For the resolution of any type of controversy, dispute or discrepancy that may arise between the user and CIRCULAR PACKAGING, SL by the use of this website, it is agreed to submit the same to the Courts and Tribunals of VALENCIA, Spain.