Privacy Policy

The General Data Protection Regulation (GDPR), Regulation (EU) 2016/679 of The European Parliament and of the Council, of 27 April 2016, presents a set of rules regarding the protection of natural persons concerning the processing of personal data and on the free movement of such data. Thus, companies that have their establishment in the European Union territory, regardless of their location, are subject to the application of the GDPR, even if the data processing is outside the EU.

  1. OWEN & BABBAGE’s commitment

OWEN & BABBAGE, in the context of its attributions, proceeds to the processing of personal data, aiming to ensure rigor, efficiency, and security to protect all the data entrusted to it daily. This Privacy Policy describes how personal data is treated and how data subjects can exercise their rights.

  1. Controller of the data

OWEN & BABBAGE is the responsible entity for collecting and processing personal data processed and stored in an automated and non-automated way. OWEN & BABBAGE has a data controller who can be contacted by email at The data controller is responsible, in particular, for monitoring the compliance of activities involving the processing of data with the applicable legal and regulatory standards. The data controller is also the contact point with the National Control Authority, customers, and users in personal data processing matters.

  1. Personal data, Personal Data Subjects, and Personal Data Categories

What is Personal Data?

Personal Data is all information of any nature, collected on any type of support, relating to a natural person, identified or identifiable. The set of information that can lead to the identification of a particular person is considered identifiable, namely by reference to an identifier (such as, for example, an identification number or location data).

From whom do we collect Personal Data?

Owing to the functions and duties of OWEN & BABBAGE, most of the data processed are from natural and legal persons, namely within the scope of recruitment and selection processes in various areas of activity. In this way, to carry out its duties, data from the following types of natural persons can be collected and processed (it should be noted that this is a non-exhaustive list):

  • Customers/investors and their employees;
  • Service providers and their employees;
  • Candidates for job/internship offers.

How is Personal Data collected?

OWEN & BABBAGE only collects appropriate, relevant, and limited data to what is strictly necessary for the performance of its attached functions. Data collection can be done orally, in writing (namely through forms and contracts), and through the institutional website. To carry out the different purposes, we may collect the following types of personal data:

  • Identification data (such as name, place of birth, citizen’s card, or date of birth);
  • Contact details (such as mobile phone, address, or email);
  • Qualification and professional status data (such as education level and other data included in CVs);
  • Bank, financial and transaction data (such as IBAN or tax identification number). 
  1. Fundamentals and Purposes of Personal Data Processing

Why and on what basis do we use your Personal Data?

All data collected and processed by OWEN & BABBAGE are based on one of the following conditions of legitimacy:

  • Consent: when the collection is preceded by your express, specific and informed consent, through written support or via the web;
  • Execution of contracts or pre-contractual steps: when processing is necessary for the fulfilling of a contract to which you are a party or for pre-contractual actions;
  • Compliance with legal obligations: when treatment is necessary to fulfill a legal obligation. This includes, for example, the communication of data with other public institutions (national and community), tax or judicial;
  • Legitimate interest: when the treatment is necessary to pursue legitimate interests of the entity responsible for the treatment or those of third parties, without prejudice to its customers’ or users’ rights and freedoms. This includes treatments that result from assignments conferred by law.

What are the Purposes for Data Collection?

The personal data collected is processed for specific, explicit, and legitimate purposes. Whenever personal data are collected, they are intended exclusively for the purposes expressly identified at the time of collection. Some of the main objectives that justify the collection of personal data by OWEN & BABBAGE:

  • Communication with customers;
  • Contracting for services;
  • Newsletters and other announcements;
  • Applications for job offers.
  1. Period of Retention of Personal Data

OWEN & BABBAGE treats and retains data only for as long as necessary to pursue or complete the purposes of the treatment for which they are intended. Namely, to comply with contractual, legal, or regulatory obligations. Other circumstances, such as the fulfillment of specific legal or regulatory obligations (for example, to comply with tax obligations, the personal data related to billing must be kept for a maximum period of ten years from the practice of the act), as well as the pending of a judicial process, may legitimize the data to be kept for a longer period. At the end of the conservation period, the above data will be eliminated.

6.Rights of the Data Subject

Under the terms of the legislation, from the moment the data is collected and processed, a set of rights that, at any time, the data subject can apply to OWEN & BABBAGE, namely:

    • Right of Access by the data subject: the right that allows you to obtain information regarding the treatment of your data and its characteristics; 
    • Right to Rectification: the right that allows you to request the rectification of your data, demanding that they are accurate and current, for example, when you consider that they are incomplete or out of date;
    • Right to Erasure (“Right to be Forgotten”): the right that allows you to request the deletion of your data when you consider that there are no valid grounds for the preservation of the data, and as long as there is no other valid ground that legitimizes such processing (such as the performance of a contract or the fulfillment of a legal obligation or regulatory);
    • Right to Restriction of Processing: the right that allows the suspension of the treatment or the limitation of the treatment to specific categories of data or purposes;
    • Right to Data Portability: the right through which you can request the sending of your data in digital format and updated, allowing its reuse. Alternatively, you can request the transmission of your data to another entity that will be responsible for processing them;
  • Right to Object: the right that allows you to oppose specific purposes, provided that no legitimate interests prevail over yours. One example of this right concerns opposition to the purposes of direct marketing.
  • Right to Withdraw Consent: the right that allows you to withdraw your consent, but that can only be exercised when your consent is the only condition of legitimacy.

How can you exercise these rights? 

All the aforementioned rights may be exercised, with the limitations of the applicable legislation, upon written request. Likewise, you can send questions related to your data’s treatment directly to the Data Controller through the email indicated in point 2 above.

  1. Data transmitting

Who Do We Share Your Personal Data With?

Owing to the inherent functions, and depending on the respective purpose, the collected data may be shared with third parties, including private entities, to comply with legal, regulatory, or contractual obligations.

  1. Cookies Policy 

What are Cookies?

Cookies are small text files with relevant information downloaded by your access device (computer, mobile phone/smartphone, or tablet) through the internet browser when the user visits a website. They are used to store information about user visits. Depending on how long the user stays on the page, cookies can be classified as session or permanent cookies. The first type of cookies expires when the user closes the browser. The second type of cookies expires when their goal has been completed or when they are manually turned off. The cookies used by OWEN & BABBAGE on its website do not collect personal information that allows the user to be identified. The cookies used are:

  • Analytical - collect information about the browsing experience of users on the website, anonymously, although sometimes they also allow a user to be identified, uniquely and unequivocally to obtain information about the interests of the user in the services provided by the website;
  • Advertising - persistently active, but for a limited period, to collect information from the user about Internet browsing habits so that the advertising viewed by the user corresponds to their needs and interests;
  • Third-party - allow the site to remember browsing preferences, language, region and collect information from users to direct advertising to their interests.

Disable Cookies

All browsers allow the user to accept, refuse or delete cookies by selecting the appropriate settings in their browser. Thus, users can disable the use of cookies on the website, at any time, by modifying the browser settings. However, it is important to note that disabling cookies may prevent some web services from functioning correctly, affecting navigation, in whole or in part.

  1. Legislation 

The processing of users’ and customers’ data performed by OWEN & BABBAGE, as well as the sending of commercial communications carried out by electronic means is following the national and community legislation in force, namely The General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and the Council).