Privacy Policy
2.1 Data controller
The data controller for the processing of personal data in connection with the Palex League is PALEX HEALTHCARE GROUP, S.L., with registered address at C/ Almagro, nº 3, 6º izq, 28010 Madrid, Spain.
For any questions related to personal data protection, users may contact the Palex Data Protection Department at: dataprotection@palexhealth.com
2.2 Scope of this Privacy Policy
This Privacy Policy explains how Palex processes personal data in connection with the Palex League platform, including registration, access, participation, scoring, ranking, winner communication and prize delivery.
This policy applies only to the Palex League initiative and does not replace other Palex Group privacy notices that may apply to employees, internal tools, HR processes or other corporate systems.
2.3 Personal data processed
Depending on the platform configuration and the user’s participation, Palex may process the following categories of personal data:
- Identification and professional data: first name, surname, corporate email address, company, department, country and/or business unit, and avatar or profile picture where selected by the user, uploaded manually or retrieved from the user’s corporate Microsoft profile, depending on the final technical configuration of the platform.
- Access and participation data: registration status, login/access records, Basecamps completed, games played, answers submitted and participation timestamps.
- Scoring and ranking data: points, correct answers, completion status, speed/time criteria where applicable, badges, weekly/Basecamp rankings and final overall ranking.
- Winner and prize data: winner status, prize type and value, delivery information and related internal administrative records.
- Communication data: messages sent in relation to the competition, reminders, winner announcements and user support requests.
- Technical data: device/browser information, IP address, session data and cookies or similar technologies required for platform operation, as further described in the Cookie Policy.
Users may choose one of the predefined avatars available on the platform or upload their own profile picture manually. If corporate Microsoft account sign-in is implemented, the platform may also allow the user’s corporate Microsoft profile picture to be displayed, depending on the final technical configuration. The use or display of a profile picture within the platform is intended only for identification, engagement and leaderboard purposes within the Palex League initiative.
The Palex League is not intended to collect special categories of personal data, such as health data, political opinions, religious beliefs or similar sensitive information. Users should not submit such information through the platform.
2.4 Purposes and legal bases
| Purpose | Examples | Legal basis to be validated |
|---|---|---|
| Platform access and administration | Registering users, enabling login, providing access to games and Basecamps. | Employee’s consent |
| Competition management | Recording participation, answers, points, badges, rankings and completion status. | Legitimate interest of Palex in managing the initiative transparently and fairly. |
| Winner selection and communication | Identifying weekly/Basecamp winners and final winners; announcing results internally where appropriate. | Legitimate interest of Palex in recognising participation and performance. |
| Prize management and delivery | Coordinating prize purchase, delivery and internal administrative records. | Legitimate interest and, where applicable, compliance with internal, tax, accounting or legal obligations. |
| Internal communications | Sending reminders, updates, launch messages, ranking updates and final announcements. | Legitimate interest in communicating about the internal initiative. |
| Security and technical operation | Maintaining platform integrity, preventing misuse, investigating technical incidents. | Legitimate interest in ensuring security and proper functioning of the platform. |
2.5 Ranking visibility and winner announcements
The platform displays a global leaderboard showing the Top 100 players worldwide, as well as an additional leaderboard filtered by country. For participants shown in the leaderboard, the platform displays full name, country flag, avatar or profile picture, where selected, uploaded or retrieved from the corporate Microsoft profile depending on the final technical configuration, and total score. Company or business unit information is not displayed in the platform leaderboard.
There is no separate “Winners” page on the platform. Once a user completes the full journey, the platform displays a completion screen showing the user’s personal score and final position, together with a link to the shared global leaderboard.
Palex may also announce Basecamp winners and final winners through internal communication channels, such as email, SharePoint or other internal platforms. Such announcements may include name and surname, department, country/company, picture, ranking position and/or score, in accordance with the principle of data minimisation and applicable internal policies.
2.6 Who may access personal data
Personal data may be accessed only by authorised persons or providers who need it for the purposes described above. This may include:
- authorised Palex Corporate Marketing & Communications team members;
- authorised local or corporate stakeholders involved in the initiative, where necessary;
- Evidenze and/or other technical providers supporting the platform, acting as data processors where applicable;
- IT, hosting, support or security providers necessary for the operation of the platform;
- Legal, HR, Finance or Compliance teams where required for prize management, internal validation, incident management or legal obligations.
Personal data will not be sold or used for unrelated commercial purposes.
2.7 International transfers
The Palex League may involve employees located in different countries. Where personal data is processed or accessed outside the European Economic Area, Palex will apply appropriate safeguards as required by applicable data protection law, such as adequacy decisions, standard contractual clauses or equivalent mechanisms, where necessary.
2.8 Data retention
Personal data will be kept only for as long as necessary to manage the Palex League, validate results, communicate winners, deliver prizes and comply with applicable internal, legal, accounting or audit requirements.
Participation, scoring and ranking data will be retained for the duration of the competition and for up to 90 days after the end of the competition. After this period, the data will be deleted or anonymised, unless a longer retention period is required for legal, tax, audit, dispute management or internal compliance purposes.
2.9 User rights
Users may exercise their data protection rights in accordance with applicable law, including the rights of access, rectification, erasure, restriction of processing, objection, portability where applicable, and the right to withdraw consent where processing is based on consent.
Requests may be sent to the Palex Data Protection Department at dataprotection@palexhealth.com. Users also have the right to lodge a complaint with the competent data protection authority.
2.10 Automated decision-making
The Palex League ranking and winner selection may be calculated automatically based on the scoring rules of the competition. This scoring does not produce legal effects or similarly significant effects on employees. It is used only for the purposes of the internal competition, recognition and prize allocation.
2.11 Security
Palex and its providers will apply appropriate technical and organisational measures to protect personal data against unauthorised access, alteration, loss, disclosure or misuse, taking into account the nature of the data and the risks associated with the processing.