Privacy Policy

To be able to receive and process your report, you must confirm that you have read this Privacy Notice. If you do not accept the conditions set out in the notice, you will not be able to submit the report. Please remember that this channel is not intended for communicating emergencies.

The whistleblowing channel is managed by PAP Tecnos Innovación SAU (hereinafter, the COMPANY), using the ithikios platform, owned by Digital Products Development SL, a company specialized in providing internal whistleblowing management systems for companies. It maintains a contractual relationship with the COMPANY as a data processor for the purpose of receiving, storing, and forwarding communications to the Company’s Compliance team. Ithikios guarantees security and confidentiality for the purpose of the contracted processing.

Below, we present the basic information about how we process your personal data:


Basic information on privacy and data protection

Data Controller

PAP Tecnos Innovación SAU (hereinafter, the COMPANY), with registered office at Av. de las Estaciones, 8. 28850 Torrejón de Ardoz, Madrid, and Tax ID No. A80923139. Registered in the Commercial Registry of Madrid, Volume: 9,522, Book: 0, Folio: 214, Section: 8, Sheet: M-132050, Entry: 10.

Data Protection Officer

You can contact us by email: [email protected]

Data subject to processing and source

The following data may be processed:

  • Your contact details, if you provide them (full name, email, phone number)
  • Name and position of the persons mentioned in the report
  • Information (regardless of its nature) regarding the reported facts

Purpose of processing and lawful basis

In accordance with current data protection regulations, the Company informs you that your personal data will be collected and processed for the following purposes:

  • To analyze, process, and investigate the reported facts confidentially
  • To manage the inquiry you submit to us
  • To exchange information in order to supplement your request
  • To interview you to clarify the reported facts, if applicable

Our legitimate interest is to ensure compliance with policies, rules, and/or applicable legislation.

Recipients of disclosures

Those required by law and the service providers acting as data processors.

No personal data will be transferred to other third parties, except where legally required.

Recipients of international transfers

Those arising from the processing of the report, inquiry, or concern itself, as well as those deriving from our relationship with the provider that manages the Whistleblowing Channel, under the safeguards set out in the Privacy Policy.

Rights of data subjects

Access, rectification, erasure or right to be forgotten, restriction, portability, objection, and the right to file complaints with supervisory authorities.