Residencias de Estudiantes SL’s Whistle-blowing Channel.

Start

Step 1/5 Categorize concern

To facilitate the further handling of your submission, please help us to categorise it as best as possible.

In which category does your submission best fit?

Competition

Consumer protection

Financial interests of the Union

Food safety

Harassment, assault and/or violence

Prevention of money laundering

Product safety

Protection of privacy and personal data

Protection of the environment

Public health

Public procurement

Security of network and information systems

Others

Do you suspect any of the following areas might be involved?

HR Manager

Legal department

RESA employee

I am not aware of any involvement of these persons

I have read the Terms of use and agree to them in accordance with the notice.

Information

Step 2/5 Personal information

If you prefer not to give your personal details, you can do so by indicating that you want the report to be anonymous.

What is your relationship with the company being reported?

Do you wish to report anonymously?

Yes

This channel requires the whistleblower's identification data are mandatory.

The selected category requires the identification data to be mandatory

First name

Last name

Following the email validation policy, you must validate this email before filing the report.

Contact telephone number

This channel is confidential. Your personal data will not be shared. If someone from the organisation needs to know your data, they will request it through the channel and they will only be able to see it if you authorise it.

Details

Step 3/5 Detailed information

Describe in as much detail as possible the event you wish to report, giving as much information and attaching evidence, if available.

Indicate which person or persons are the subject of the report

First and last name

Position

Have you discussed this with any member of management?

Yes

I do not remember

Are there any witnesses? Please indicate their names.

First and last name

Position

Tell us what you want to report in detail

Would you like to attach any additional documents?

Image (png, jpg, gif), Audio (wav, mp3), Video (ogg, mp4, mov, avi, wmv, mpg, mpeg) or PDF document up to 20Mb. Attention! If you report anonymously, make sure that the attachments do not include information in the content or metadata that could identify you.

Confirm

Step 4/5 Confirmation

As the last step of the process, you must indicate a secret code that only you will know. This password, together with the identification code that we will give you at the end of the process, will be the only way to follow the progress of your submission

Password

Password confirmation

Email address validation

According to the validation policy of this channel, we must validate the indicated email address. To do so, we will send you an email with a validation email with a code that you must indicate in the following field.

Verification code check received

Finish

Step 5/5 Finalize

You have now entered all the information necessary to start the report management process.

The information is ready to initiate the process of determining accountability. The persons or facts reported will be investigated and the resulting actions will be taken.

The whistleblower undertakes that the information provided in this submission is true. Otherwise, the company reserves the right to take legal action against the whistleblower.

This is the last form in the process. When you click on Send, the investigation will begin and the resolution of your claim will be shown on the platform within a maximum period of 3 months.

I have read the Data Protection and Consent Notice and agree to the processing of my personal data in accordance with the provisions of this notice.

Terms of Use

1- IDENTIFICATION DATA

In compliance with the duty of information established in Law 34/2002, of July 11, 2002, on Information Society Services and Electronic Commerce (hereinafter, "LSSI"), the following information is provided below: the owner of www.resa.ethic-channel.com (hereinafter, the "Website") is RESIDENCIAS DE ESTUDIANTES S.L. with Tax ID B60109188, company domiciled in Calle Serrano nº 41 4ª planta 28001 Madrid, entity registered in the Mercantile Register of Madrid, Volume 37046, Folio 153, Page M-661.710. (Hereinafter, the Entity or RESA).

Contact details:

Telephone: 933943500.

E-mail: [email protected], [email protected] o [email protected].

2- OBJECT

These are the Conditions (hereinafter "General Conditions") that regulate the access, navigation, use of the Web Site, and the responsibilities derived from the use of the same.

This Website may only be used to send communications on actions or omissions that could imply an illicit act or be contrary to the regulations in force or contravene the principles and values of RESA's Code of Ethics,

3- USERS AND THEIR RESPONSIBILITY

By using the services of the Website, the user accepts the present General Conditions, which define the rights and obligations of the RESA Website. These are the only General Conditions applicable to the use of the Website. Any person accessing this Website assumes the condition of User, undertaking not to use the Website or the information contained in it to carry out activities contrary to the Law, morality or public order and, in general, to use it in accordance with the General Conditions established by RESA.

The User assumes responsibility for the use of the Website in a legitimate manner and in accordance with the present Conditions. By way of example and without limitation, the User is responsible for:

Use the Website in accordance with the Object described in these General Conditions.
Providing all the information requested through the Web Site's complaint form. The Website allows communication in an anonymous way, so the User must review the information provided in case he/she wishes to preserve his/her identity completely.
The User may choose to send a communication providing contact and identification data or not to provide them. In both cases, the Website will provide the User with a unique identification number and a password that will allow him/her: (i) to know at all times the status of the communication made; (ii) to download a certificate containing all the information communicated and the result of the investigation. It is important for the User to record such information in a safe place. For security reasons, if this information is lost, the User will not be able to recover it. RESA is not responsible for the loss of such information.
Not to make use of the Website in bad faith and to provide truthful information to the best of their knowledge and belief. If the entity ascertains that the User has submitted the complaint in bad faith and/or with knowingly false information or documentation, it reserves the right to take legal action if the complainant has been identified.

The User will be liable for any damage or harm of any kind that RESA may suffer, directly or indirectly, as a consequence of an improper use of the Website, a breach of the present Conditions or a breach of the law in force.

Likewise, the User will not be able to hold RESA responsible for any damages that may derive from such activities beyond its control and of which it is effectively unaware.

4- RESPONSIBILITY OF RESA

The entity shall not be liable for any errors in accessing the Web Site or its contents but will do its best to ensure that they do not occur.

The entity reserves the right, without prior notice, to temporarily suspend access to the Website in the event that maintenance, repair or improvement work is required.

5- EXCLUSION OF WARRANTIES AND LIABILITY

The entity is not responsible, in any case, for damages of any nature that may be caused by Users, including but not limited to: errors or omissions in the contents and / or lack of availability of the portal or the transmission of viruses or malicious or harmful programs in the contents, despite having taken all the necessary technological measures to prevent it.

6- INTELLECTUAL AND INDUSTRIAL PROPERTY

All contents of the Web Site (including, but not limited to, databases, images, drawings, graphics, text files, audio, video and software) are the property of the entity and are protected by national and international intellectual and industrial property laws, and all rights are reserved.

The trademarks, signs, distinctive signs or logos appearing on the Website are the property of the entity. The texts, graphic drawings, videos or audio supports that can be found in this Web Site, now or in the future, are property of the entity, so it is not allowed its:

Reproduction, distribution or modification, unless authorized by the entity or it is legally permitted.
Any infringement of the rights of the entity or of the legitimate owners of the same.
Use for any commercial or advertising purposes other than those strictly permitted.
Any attempt to obtain the contents of the Website by any means other than those provided to the Users, and those normally used on the Website.

RESA does not grant any license or authorization of use of any kind on its intellectual and industrial property rights or on any other property or right related to the Website, and under no circumstances will it be understood that access and browsing by the Users implies a total or partial waiver, transmission, license or transfer of said rights by RESA.

Any use of these contents not previously authorized by RESA will be considered a serious breach of the intellectual or industrial property rights and will give rise to the legally established responsibilities.

7.- PROTECTION OF PERSONAL DATA

RESA processes users' data, always in compliance with the provisions of 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 (General Data Protection Regulation or GDPR) and Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights (LOPDGDDD).

For more information on the processing of the data of users of the Channel, you can consult the Privacy Policy.

8- VALIDITY OF THE CONDITIONS OF USE

The entity will be able to modify at any time the conditions determined here. The validity of the aforementioned conditions will depend on their exposure and will be in force until they are modified by others duly published.

9- MODIFICATIONS

The entity reserves the right to make unannounced changes it deems appropriate in its Web Site, and may change, delete or add content provided through it, as well as the way in which they are presented or located on its Web Site.

10.- SAFEGUARD CLAUSE

All the clauses or extremes of these conditions of use must be interpreted independently and autonomously, not being affected the rest of the stipulations in case that one of them has been declared null by judicial sentence or firm arbitral resolution. The affected clause or clauses shall be replaced by another or others that preserve the effects pursued by the present General Conditions.

11- APPLICABLE LAW AND JURISDICTION

The relationship between the entity and the User shall be governed by the Spanish legislation in force and any dispute shall be submitted to the Courts and Tribunals of Madrid.

Data protection and consent to RESIDENCIAS DE ESTUDIANTES, S.L.

ÍNDEX

1. DATA CONTROLLER

2. MOTIVATION

3. PERSONAL DATA PROCESSED

4. PURPOSES OF DATA PROCESSING

5. LEGITIMACY FOR DATA PROCESSING

6. RECIPIENTS OF THE INFORMATION

7. TIME LIMITS FOR THE STORAGE OF DATA

8. USER RIGHTS

9. SECURITY MEASURES

10. ACCURATE AND TRUTHFUL INFORMATION

1. DATA CONTROLLER

This Whistleblowing Channel is the responsibility of RESIDENCIAS DE ESTUDIANTES S.L., with TAX number B60109188, company domiciled at Calle Serrano nº 41 4ª planta 28001 Madrid, entity registered in the Mercantile Registry of Madrid at Book 37046, Page 153, sheet M-661.710 ] (hereinafter, RESA).

2. MOTIVATION

RESA makes this Whistleblower Channel available to its stakeholders in compliance with the recent Law 2/2023 regulating the protection of persons who report regulatory infringements and the fight against corruption (hereinafter, " Whistleblower Protection Law ").

Additionally, RESA fully complies with the current regulations on the protection of personal data; specifically, with 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 (hereinafter, " GDPR ") and Organic Law 3/2018, of 5 December, on data protection and guarantee of digital rights (hereinafter, " LOPD ").

3. PERSONAL DATA PROCESSED

RESA's Whistleblower Channel allows the submission of anonymous reports. However, if the informant wishes to submit the complaint in a nominative way, RESA may collect, within the framework of a communication, the following types of data from the informant and, if applicable, from the persons involved in the communication:

· Identification data : Name and surname.

· Contact details: Telephone and e-mail.

· Professional data: Professional position.

Additionally, RESA may process other types of data by virtue of the allegedly criminal or irregular facts reported and of the supporting documentation that may be appropriate to investigate the reported conduct.

No personal data will be collected whose relevance is not evident in order to process specific information. In the event that irrelevant data is accidentally collected, such data shall be deleted from the Whistleblower Channel without undue delay.

If it is proven that the information provided or part of it is not truthful, it will be deleted immediately as soon as this circumstance becomes known. In the event that this lack of truthfulness may constitute a criminal offense, the information will be kept for the necessary time during the legal proceedings..

4. PURPOSES OF DATA PROCESSING

RESA will process the data to which it may have access as a consequence of the communications received for the following purposes:

· To receive and decide on the admission for processing of the communications received through the Whistleblowing Channel.

· Once the communications have been admitted for processing, to carry out the investigation of the reported facts and to adopt, if appropriate, the pertinent corrective measures.

· Keeping the complainant informed about the admission, or not, to process the communication as well as the progress and results of the investigation process in case there are sufficient grounds to admit it for processing.

5. LEGITIMACY FOR DATA PROCESSING

In view of the conduct denounced through the present Whistleblower Channel, RESA has the following legitimate bases for the processing of the data:

· Compliance with legal obligations applicable to RESA if the communication refers to the breaches foreseen in the Whistleblower Protection Law:

o Breaches of European Union law,

o Commission of crimes or serious or very serious administrative offences or any infringements of the regulations for the prevention of money laundering;

· Legitimate interest of RESA in ensuring that the corporate behaviors provided for in RESA's Code of Ethics or Code of Conduct are respected, without the processing of data in this framework entailing an imbalance for the rights of the data subjects and without the processing being likely to cause them prejudice.

· RESA's public interest when the Complaints Channel is not mandatory or the processing is carried out within the scope of public disclosure.

6. RECIPIENTS OF THE INFORMATION

The data to which RESA may have access on the occasion of the communications received through the Whistle-blower Channel may be communicated to:

· Public bodies or institutions, judges and courts when necessary for the adoption of disciplinary measures, for the processing of the judicial proceedings that, if any, may be applicable or in those cases in which it is legally required.

· To the Public Prosecutor's Office, when the proceedings fall within its competence.

· The company(ies) owner(s) of the residence(s)/establishment(s) with which the parties involved in the communication have a relationship, provided that this communication is essential for the investigation of the reported facts.

With regard to the communication of the informant's personal data, RESA will guarantee that his identity, and all those personal data that RESA may have about his person, will in all cases be reserved and not communicated to the persons to whom the facts reported refer, nor to third parties, respecting in all cases the fundamental rights of the person, without prejudice to the actions that, where appropriate, may be taken by the competent judicial authorities and for which RESA assumes no responsibility .

7. TIME LIMITS FOR THE STORAGE OF DATA

The personal data to which RESA may have had access as a consequence of the communications received through the Whistle-blowing Channel, will be processed for the time necessary to decide on the appropriateness of initiating an investigation on the reported facts and for the management of the communication, provided that the same is admitted for processing.

Specifically, RESA will process the personal data within a maximum period of three months from the receipt of the communication or, if no acknowledgement of receipt was sent to the informant, three months from the expiry of the seven calendar days that RESA has to acknowledge receipt of the communication. The aforementioned period may be extended by a further three months in cases of special complexity.

Once the aforementioned period has elapsed without any investigation actions having been initiated, the data will be deleted from the communication system, except for the purpose of maintaining evidence of the operation of the system and in an anonymized form.

In the case of communications that have not been sent, they shall be kept in an anonymized form, completely eliminating the personal data.

8. USER RIGHTS

The regulations of protection to the informant guarantee to the Users the following rights recognized in the regulations in the matter of protection of data; that will be able to be exercised whenever they turn out to be of application:

· Access : Allows interested parties to know what information is held, from where it has been obtained, to whom it has been provided and for what purposes it has been processed.

· Rectification : Allows interested parties to rectify any erroneous or outdated data.

· Deletion : Allows interested parties to stop the processing of their data.

· Opposition : Allows interested parties to stop the use of their data for a specific purpose. In the case of the person to whom the facts related in the communication refer, it will be presumed that, unless proven otherwise, there are compelling legitimate reasons that legitimize the processing of their personal data.

· Limitation : Allows data subjects to restrict the processing of their data, but in such a way that they are retained for some subsequent purpose.

· Portability : Allows data subjects to obtain a copy of their data in electronic format and, under certain circumstances, to request that it be communicated to another service provider. It is only applicable for computerized processing carried out with the User's consent or for the fulfillment of a contract.

· Revocation of consent : Allows interested parties to withdraw the consent, if any, given for the processing of their data.

However, the exercise of these rights is limited to those informants who have identified themselves at the time of submitting the communication. If RESA has reasonable doubts as to the identity of the informant requesting the right, it may require additional information that will allow it to accredit his or her identity.

Whenever applicable, the aforementioned rights may be exercised before RESA by mail to the above-mentioned address and to the attention of the Ethics Committee or by e-mail to [email protected] .

If the informants wish further information in this regard or consider that their right to data protection has been violated, they may contact the Spanish Data Protection Agency ( www.aepd.es ).

9. SECURITY MEASURES

In compliance with the aforementioned regulations in force, RESA has incorporated the appropriate technical and organizational measures to guarantee the protection of the rights and freedoms of those affected by the processing of their personal data, including those corresponding to the necessary confidentiality and respect for the identity of the informant in the event that the report is nominative, the protection of data and the secrecy of communications, with the aim of avoiding the loss, misuse, alteration and/or unauthorized access to the data provided by the informant.

10. ACCURATE AND TRUTHFUL INFORMATION

RESA informs the informant that the communication transferred through the Whistle-blowing Channel may lead to the initiation of internal or external investigations and may have negative consequences for those affected.

For this reason, he/she must only provide us with information that is believed to be correct, to the best of his/her knowledge and belief, and that is relevant to detect a breach of regulatory compliance and/or of RESA's Code of Ethics or Code of Conduct.

RESA may initiate any disciplinary and/or legal action it deems appropriate whenever the communication is manifestly unfounded or there are, in RESA's opinion, reasonable indications that the information has been obtained through the commission of a crime.