Privacy Policy

  1. Who is the controller of your data?

Postal Address: Plaza Europa 9-11 (Edificio Inbisa planta 20) 08908
LHospitalet de Llobregat (Barcelona)
Telephone:+34 934 670 650

  1. Why do we process your data?

COMINTER PAPER shall process your data to respond to enquiries and requests made via the Website, whether you submit queries or contact us to send your CV.
In the event of a contractual relationship with clients, suppliers and collaborators of COMINTER PAPER, the personal data processed under such relationship shall be used to enable an optimal execution thereof.

The data shall be processed for the following purposes:

  1. a) To respond to your enquiries or requests as a user of the Website.
    b) Customer service, when required.
    c) If you have sent your CV to us, it shall be processed to cover our staffing requirements, where necessary.
    d) Managing the registration of clients and suppliers and managing the performance of their contracts.
  2. How long shall your data be retained?

The personal data provided shall be stored, as a general rule, for a minimum period of six years from the date of termination of the contractual relationship existing between the clients, suppliers, collaborators and COMINTER PAPER. The maximum storage period for the data shall be ten years, except in special cases where the data must be stored for a longer period.

The storage period for the data is shown in the table below:


Data processed Storage periods
CLIENT AND SUPPLIER DATA As a general rule, the data shall be destroyed between six and ten years after terminating the provision of the services. Depending on the case.
JOB APPLICANT DATA One year after the receipt of the CV.
THIRD PARTY AND CONTACT DATA The deletion is not envisaged except in the case of withdrawal of consent.
GENERAL DEADLINE. In those cases where the data are necessary subject to some type of statutory liability, or are requested by law enforcement authorities or an administrative or judicial authority, the data shall be stored for the time limits laid down in applicable legislation, and shall solely be used for such purpose.
  1. Why are we allowed to process your data?

Firstly, because they are necessary for the development of the relationship with COMINTER PAPER. When you conclude a contract with us, we must process the necessary personal data for the provision of the contracted service.

In such case, the contract concluded constitutes the legal ground for the processing.

b.- Because you have given us your consent.

In different cases, as a user, you voluntarily give us your consent to process your data.

This occurs:

▪ When you submit a query, suggestion or a request for specific information.
▪ When you voluntarily submit your CV data, expressing your interest in working with us.

In all of these cases, our legal ground for the processing of your data is your consent.

c.- Because we have a “legitimate interest in processing your data”

According to the General Data Protection Regulation, the processing of personal data for direct marketing purposes may be regarded as carried out for a legitimate interest. This means that we may carry on marketing activities for a better understanding of client preferences or to personalise offers, respond to client requests, enhance business activities.

However, we always process these data safeguarding the interests of our clients, who have the freedom to object to these types of processing.

d.- Because it is required by a Law

There are different cases where the processing of personal data may be required by a law, such as, for example, in the event of a request for collaboration from law enforcement authorities or courts and public prosecutors, or the compliance with tax obligations, as well as in conciliation procedures provided for by law related to consumers and users.


  1. To what third parties shall your data be disclosed to?

The data shall be disclosed to:


Data processed Recipients





JOB APPLICANT DATA No transfers of data are envisaged to third parties other than Cominter, however they may be disclosed to companies within the COMINTER PAPER Group to meet the staffing requirements.

The companies within the Group are:

Kartogroup España S.L.
Production and handling of tissue paper.

Cominter Tisu S.L.
Production of pure cellulose and recycled tissue paper rolls.

Comcenter Barcelona Centre de Negocis, S.L.


  1. Rights to which you are entitled when you provide us with your data

Everyone is entitled to know whether or not COMINTER PAPER is processing their personal data. Likewise, data subjects are entitled to request the rectification of incorrect data, or where appropriate, request their deletion, among other reasons, when the data are no longer required for the purpose for which they were collected.

Data subjects may also request, where certain grounds apply, the restriction of processing of their data, in which case they shall be retained for exercising the defence of legal claims. Finally, data subjects shall have the right to request the transmission of their data to a third party designated by them, where technically feasible.

In any event, the rights are briefly summarised below for a clearer understanding:


Right What am I entitled to do?
Access You may consult your personal data included in the database of COMINTER PAPER.
Rectification You may request the amendment of your personal data, when you so desire, or when they are incorrect.
Erasure You may request the deletion or erasure of your personal data.
Objection You may request us not to process your data for specific purposes, where your rights take precedence.
Restriction By exercising your right to restriction, you may:


A. Request the suspension of the processing of your data:

·       Where you challenge the accuracy of the personal data for a period enabling us to verify its accuracy.

·       Where you have objected to the processing of your personal data on the basis of our legitimate interest or in the public interest, pending the verification of whether our legitimate grounds override yours.

B. Request us to store your data:

·       Where the processing is unlawful and you have objected to the erasure of your personal data and you have requested the restriction of their use instead.

Where you no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims.

Portability By exercising this right, you shall have the right to receive, in electronic format, the personal data that you have provided and those obtained from your contractual relationship with COMINTER PAPER

You shall also have the right to have the personal data transmitted directly to another company.

You may send any concerns or suggestions that you may have related to your personal data to the following email address:

Likewise, you may directly contact the Supervisory Authority (The Spanish Data Protection Agency) through their website:

You shall be required to submit proof of your identity in order to exercise any of these rights. To that purpose, you may:

·       Attach a copy of your Id. Document to the request

·       Attach a copy of a document equivalent to your Id. Document to the request as proof of your identity (e.g. passport).

·       Justify, where appropriate, the data that should be amended, and/or the grounds for the erasure or opposition to the processing.

·       Where the right is exercised on behalf of a third party, a child or a disabled person, proof of the relevant legal representation must be submitted.