ReportingChannel

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Canal de comunicaciones

Este canal es confidencial, permite comunicaciones anónimas y es de gestión externa. En el caso de proporcionarnos sus datos, estos serán tratados con la máxima confidencialidad.
Conforme a lo establecido en la Ley 2/2023, de 20 de febrero, reguladora de la protección de las personas que informen sobre infracciones normativas y de lucha contra la corrupción, mediante el presente Canal interno se pueden plantear comunicaciones sobre todos los asuntos graves relacionados con dichas materias que afecten a nuestra organización, todo ello de forma confidencial y segura, e incluso de forma anónima.
Le informamos que sus datos serán tratados por Lupicinio Abogados (como gestor de la plataforma) y Audiovisual Fianzas, SGR y sólo podrán ser utilizados para gestionar la investigación necesaria. La base de legitimación principal del tratamiento de datos personales es la obligación legal (artículo 6.1.c del RGPD). Sus datos no serán cedidos a terceros a no ser que tengan que ser puestos a disposición del Ministerio Fiscal, Jueces y Tribunales. Sus datos sólo serán conservados durante el tiempo imprescindible para decidir sobre la procedencia de iniciar una investigación sobre los hechos denunciados. En todo caso se eliminarán físicamente transcurridos 3 meses, salvo que la finalidad de la conservación sea dejar evidencia del funcionamiento del modelo de prevención de la comisión de delitos por la persona jurídica en cuyo caso se anonimizarán. Más información en la  "Privacy Policy".
LEGAL PRINCIPLES
Principle of legality, fairness and transparency Consent will always be required for the processing of personal data for each specific purpose, always providing clear and transparent information.
Data minimisation principle Only strictly necessary data will be requested in relation to third parties for the purposes for which they are required, with an effort to minimize their quantity.
Principle of limitation of the conservation period Data will be retained no longer than necessary for the purposes of the processing, depending on the purpose, and informing about the corresponding retention period. If there are subscriptions or newsletters, the records will be periodically reviewed, eliminating outdated and inactive ones after a set period of time.
Principle of integrity and confidentiality: Data will be processed in such a way as to ensure adequate security of personal data and guarantee confidentiality. All necessary precautions will be taken to prevent unauthorized access or misuse of user data by third parties.

Ethical and responsiblemanagement

CREA SGR's principles of action are based on transparency in all professional contacts and collaboration agreements with third parties, confidentiality and privacy in the information requested, in the processing of personal data and ethical behaviour in relations with employees, partners, administration and institutions and with all stakeholders that form part of our activity.

Commitments to its stakeholders and to the SDGs focus on ethical commitments, which go beyond compliance with national and international laws in force, having developed commissions and manuals on money laundering and financing of terrorism, prevention of corporate criminal liability, conflict of interest, assessment of the suitability of the Board of Directors, appointments and remuneration, credit risk management policies and the figure of the data protection officer.

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Commitments to society
by supporting and collaborating with Schools, Festivals, Awards, and associations to promote and enhance the cultural industry.

Commitments to partners
CREA SGR's relationship with its partners is based on truthful and honest advice, always offering the best economic conditions in its contractual relationship.

A data protection officer is in place to deal with the confidentiality of the data we work with and an ethical complaint resolution channel has been established for members.

Commitments to employees
CREA lleva a cabo una política de Recursos Humanos sostenible y responsable basada en la igualdad de oportunidades, promoción y no discriminación. Del número total de empleados, el 51,72% son mujeres. Contamos con un Código General de Conducta (desde 2015, complementado con el Régimen disciplinario en 2018) y un Protocolo de prevención del acoso laboral y sexual (desde 2017).

Code of Conduct

Code of Good Practices

The regulatory compliance of Crea SGR covers the following areas

Protection of personal data.

Prevention of Money Laundering and Financing of Terrorism.

Occupational Health and Safety.

Corporate Criminal Liability

Code of good practices.

Conflict of Interest Protocol

CREA SGR currently has collaboration agreements signed with the following financial institutions:

Privacy Policy

In Europe and Spain, there are data protection regulations designed to protect your personal information, which our organization is obliged to comply with.

Therefore, it is very important for us that you understand perfectly what we will do with the personal data we ask for.

Thus, we will be transparent and give you control over your data, with simple language and clear options that will allow you to decide what we will do with your personal information.

Please, if you have any questions after reading this information, do not hesitate to ask us.

Thank you very much for your cooperation.


About us

  • Owner: Audiovisual Fianzas Sociedad de Garantía Recíproca.
  • C.I.F.: V-84550359
  • Our main activity is: Granting personal guarantees in favor of participating members for the operations they carry out within the companies they own.
  • Our address: C/ Luís Buñuel, 2. 2º. Ciudad de la Imagen. Pozuelo de Alarcón. 28223, Madrid. (España)
  • Our contact phone number is: 915 123 048
  • Our contact email is: correo@creasgr.com
  • Our website is: www.creasgr.com
  • For your confidence and security, we inform you that we are a financial entity subject to the supervision of the Bank of Spain, registered in the corresponding special administrative register maintained by the Bank of Spain with the number 9848 and in the Mercantile Register of Madrid, volume 22,131, page 128, sheet M-394807.

We are at your disposal. Please feel free to contact us.


What is the purpose of processing your personal data?

AUDIOVISUAL FIANZAS, S.G.R. will process all personal data that you provide us through our pages for the following purposes:

a) Execute the contract or apply the corresponding pre-contractual measures

We will process your data with the purpose of evaluating and managing the operations that you request or contract with us.

b) Comply with legal obligations:

We will also process your data to fulfill any legal obligations. In particular:

  • Law 44/2002, of November 22nd, on Financial System Reform Measures.
  • Law 10/2014 on the Organization, Supervision, and Solvency of Credit Institutions.
  • Law 10/2010 on the Prevention of Money Laundering and the Financing of Terrorism.
  • Law 3/2018 on the Protection of Personal Data and Guarantee of Digital Rights.
  • Data communications to the Risk Information Center of the Bank of Spain (CIRBE).

c) Legitimate interest

Other processing of your personal data may also be carried out that does not arise from the need to execute a contract or comply with a legal obligation.

  • Communication to solvency and credit files and consultation of such files.
  • Consultation of your data in the Central Credit Register of the Bank of Spain (CIRBE).
  • Consultation of denied requests for future applications.
  • For statistical purposes.
  • Commercial shipments of own products similar to those contracted.

d) Consent

We will request your consent for:

  • to properly manage the website.
  • to provide answers to your questions.
  • Surveys, information, or advertising offers about products, services, collaboration agreements, special promotions, related to the Financial Sector and Guarantees.

e) Public interest

In case of using the ethical channel (Internal Information Channel), we will process the data for the investigation of possible irregularities reported.


For how long do we process your personal data?

The personal data provided will be kept as long as the contractual relationship is maintained and its deletion is not requested in compliance with current legislation. Once it has ended, the data will be kept for a period of 10 years to comply with the obligations established in Law 10/2010 on the Prevention of Money Laundering and Terrorist Financing.

Similarly, the data from denied applications of potential clients may be processed for six months, with the purpose of using said data for the processing of future applications and to avoid duplication of formalities. Subsequently, it will also be properly blocked while the obligations related to compliance with data protection regulations (3 years) do not expire. Once these periods have been fulfilled, the data will be deleted.


Are data profiling or automated decision-making processes performed?

For legitimate interest, we create profiles to make the decision to evaluate the requested operation, where the financial capacity of the parties involved will be considered, as well as any debts that may appear in common delinquency files, risk indicators, and data from public registers. Automated decisions can be made based on this profile, and you may request at any time that these decisions be manually reviewed.

Similarly, we create profiles to provide personalized offers of financial and insurance products and services. No automated decisions will be made based on such profiles that could have legal consequences.


What recipients will your data be transferred to?

The data from the transactions may be transferred to:

  • CERSA (Compañía Española de Re-afianzamiento S.A.) with the purpose of carrying out the re-guarantee of the arranged guarantees. This assignment is necessary to obtain such re-guarantee, in compliance with the contract between the S.G.R. and CERSA.
  • CERSA as the Coordinator of the contract signed between the European Investment Fund (EIF), Audiovisual Fianzas, S.G.R. and the Compañía Española de Reafianzamiento SME S.A., in operations that benefit from the support of the InvestEu Fund program, as well as to the EIF to comply with the legal obligations arising from the contracts signed by Audiovisual Fianzas S.G.R., which, as an intermediary, signs with the latter entity.
  • The financial entities involved in those operations where the participation of such an entity is necessary for the formalization of the arranged guarantee (guarantees of loan operations, credit, or any other of a financial nature).
  • Files related to the compliance with monetary obligations in case of non-payment of the agreed terms (BADEXCUG file from EXPERIAN and/or ASNEF from Equifax).
  • The Credit Risk Information Center of the Bank of Spain (C.I.R.B.E.) due to the existing obligation to report the necessary data to identify individuals with whom they have, directly or indirectly, credit risks, as well as the characteristics of these individuals and risks, including, in particular, those that affect the amount and recoverability of these risks.
  • And where applicable, to the Madrid City Council/Community of Madrid/Basque Government/Cabildo of Gran Canaria/Ministry of Culture for the purpose of carrying out the re-guarantee of the arranged guarantees. This assignment is necessary to obtain such re-guarantee, which may or may not be complementary to the one mentioned above, and always in compliance with the Collaboration Agreement signed between the S.G.R. and the aforementioned entity and/or the regulations governing the relationships between Audiovisual Fianzas, SGR, and the corresponding entity.

What are your rights when you provide us with your data?

You have the right to exercise your rights of access, rectification, erasure, restriction, portability, and objection by contacting Audiovisual Fianzas, S.G.R., at C/ Luis Buñuel nº 2, 2º CIUDAD DE LA IMAGEN, Pozuelo de Alarcón (Madrid), or by email at correo@creasgr.com. If you believe that we have not processed your personal data in accordance with the regulations, you can contact our data protection officer at dpd@informaconsulting.com. In any case, you have the right to file a complaint with the Spanish Data Protection Agency (www.agpd.es).

We inform you that, in cases where it is necessary to include personal data of individuals other than the person providing them, you are obligated to inform them, prior to their inclusion, about the communication of their data, as well as that you are responsible for the accuracy of the data provided and for keeping it up to date.


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