Welcome to our Internal Information System, through which you can send us any information you may have regarding violations of current regulations, under the terms set forth in Law 2/2023, of February 20, regulating the protection of persons who report regulatory violations and the fight against corruption, as well as our code of ethics and other internal regulations of our company.
The compliance model is a strategic part of Aire’s corporate culture, where we are firmly committed to the principles of ethics, integrity, and transparency in all our actions. Therefore, we require all our professionals to always act honestly and responsibly.
Below, we provide a series of questions and answers so that you can learn about your rights and how this reporting tool works:
It is a channel through which anyone (informant) who is or has been related to our company in a work or professional context can bring to our attention, either anonymously or by identifying themselves, of any facts or conduct in which any professional linked to Aire has been directly or indirectly involved and which may constitute a crime and/or a serious or very serious administrative offense, violations of European Union law, violations of labor law, or which constitute or may constitute a violation of our code of conduct and other internal regulations.
This channel is managed in accordance with the provisions set out in the Policy on reporting irregularities and protecting whistleblowers and its corresponding annexes.
No, in accordance with the legislation governing the protection of persons who report regulatory violations, it is not possible to submit complaints, claims, or suggestions through this channel.
If you wish to contact us regarding these matters, please write to https://airetech.es/contacto or send an email to info@airetech.es.
Likewise, if you wish, you can request a face-to-face meeting with the managers of the control body or send your complaint by post to the following address:
Compliance Department: C/Santiago Ramon y Cajal No. 11, Elche Business Park, Postal Code: 03203 Elche (Alicante), Spain.
You can also contact us at the following email address: canaldenuncias@airetech.es.
There are also external information channels that you can use if you consider it appropriate. Among others, you can use the reporting channel of the National Securities Market and Competition Commission (CNMC), the Independent Whistleblower Protection Authority, the Spanish Data Protection Agency (AEPD), and the Valencian Anti-Fraud Agency.
Yes, we provide you with the following email address canaldenuncias@airetech.es so that you can send us any questions or queries of an ethical nature, as well as any irregularities of potential significance, indications or suspicions of behaviour that is contrary to the law or that may involve the materialisation of a criminal risk. Please note that this medium is a different channel from the internal information system and, in this case, does not guarantee anonymity.
1. Who is responsible for processing your personal data?
The data controller for the data collected through this reporting channel or internal information system (hereinafter, channel or internal system) is Aire Networks del Mediterráneo S.L.U. (hereinafter, Aire Networks), with registered address at C/ Santiago Ramón y Cajal Número 11, Elche Parque Empresarial, 03203 Elche (Alicante).
You can contact our Data Protection Officer (DPO) at the following email address: rgpd@airetech.es or by writing to the postal address indicated above.
2. Why do we process your data?
When you report a possible breach through the channel, your data will be processed for the management of the irregularities presented, which involves receiving, recording, resolving, and carrying out whatever actions are necessary to clarify the facts and, if necessary, subsequently communicating them to the competent authorities.
We will use the information you provide to investigate and manage your report in the most appropriate manner in accordance with the law, maintaining confidentiality as far as possible.
We will process your personal data and any third-party data you provide, including identification, contact, and professional data. Depending on the content of your report, we may also process special categories of data, i.e., personal data that r
In any case, you can always report a possible breach anonymously.
No automated decisions will be made.
3. ¿Cuál es la base de legitimación para tratar tus datos?
The legal basis for processing your data is compliance with a legal obligation under Article 6.1.e) of the General Data Protection Regulation, in cases where you report actions or omissions that may constitute a criminal offense, a serious or very serious administrative offense under internal policies and procedures, a violation of EU law, and/or any irregularities and violations of our organization’s code of conduct.
In the event of the processing of special categories of data, as indicated in section 2, the data will be processed for reasons of substantial public interest, always respecting the right to data protection in a proportionate manner and applying the necessary security measures to protect the rights and interests of the whistleblower.
Likewise, in the event that the processing of data results from a public disclosure, the processing will be presumed necessary for the fulfillment of a mission carried out in the public interest.
4. Who has access to your data?
Access to personal data reported through this channel will be limited to the relevant personnel within the scope of their powers and duties, specifically the SII Manager and the Compliance control body.
No transfer of your data is envisaged except:
In the case of complaints of workplace harassment, sexual harassment, or gender-based harassment, access to personal data will be limited to the entity’s personnel within the scope of their powers and functions, such as the head of the human resources department.
Likewise, the necessary technical and organizational measures have been implemented to guarantee the security of your personal data and prevent its alteration, loss, unauthorized processing, or access.
No international data transfers are planned, given that the corresponding functions of the control body and the system controller are located within the European Economic Area.
5. How long will we keep your data?
Your personal data related to the information submitted will be processed for the time necessary to fulfill the stated purposes, and in no case will personal data that is not necessary for the knowledge and investigation of the reported conduct be processed.
If it is necessary to initiate an investigation into the reported information, the period for handling the reported irregularities will not exceed three months from the date the communication is sent.
If it is considered that an investigation should not be initiated, or if the maximum retention period has expired without the investigation being completed, the data will be deleted from the channel, unless the purpose of the retention is to leave evidence of the functioning of the internal information system.
6. What are your rights?
In accordance with data protection regulations, you can exercise the following rights:
However, your rights may not apply in certain cases, such as when the identity of the whistleblower is requested in exercising the right of access, given that such communication is limited to the competent judicial authorities, or, for example, if the right to object is requested in communications relating to public disclosure, given that there are compelling legitimate grounds that justify such processing. In any case, we will inform you of how we can satisfy your request regarding your rights.
You can exercise your rights by contacting the Aire DPO at the following email address: rgpd@airetech.es, or by writing to the DPO at the following address: C/ Santiago Ramón y Cajal Nº 11, Elche Parque Empresarial, 03203 Elche (Alicante).
You also have the right to lodge any complaint with the competent supervisory authority, which is the Spanish Data Protection Agency, without prejudice to the powers that other regional or supranational entities may have, in accordance with the Data Protection Regulation and national legislation.
CTO
Joan sees technology as a lever to enable everyone to access knowledge and facilitate real-time communication between people. Since he started working at Grupo Aire, when he was in the last year of university, he has strived to overcome the technical challenges he has faced, with the desire to learn and get to the bottom of each project. As CTO, he applies this experience, his vision, drive and attention to detail to different areas of work. He says the main highlights in the projects he works on are their technological vocation and the team, for their human quality and problem-solving approach.
CHR & Integration Officer
For Manuel Rivera, technology and people are intimately connected, and he sees them as drivers of change. His passion for telecommunications led him to study Engineering in this field. His professional career has spanned roles in engineering, commercial operations, and Human Resources, where he has focused on transforming technological organizational structures both in the local market and across Europe. He joins Grupo Aire as Director of Human Resources and Transformation, bringing his vision and experience to tackle the numerous challenges organizations face in today’s world.
CFO
Her work in different positions in technology companies has led her to always be surrounded by engineers and to breathe that techie atmosphere on a daily basis. This experience in the sector, together with her knowledge and vision of the strategic financial function, is what Rosa brings to Grupo Aire. As well as best practices and support to the shareholders and management team for decision making. All of this with the aim of leading the company towards the goals proposed in the business plan.
Aire stands out for its capacity for innovation and development; the high volume of proprietary solutions and how deeply rooted the project is in the sector.
CIO
Despite growing up in a small town with limited access to technology, it was no obstacle for Zigor to immerse himself in the technology sector from a very young age, and later commencing a degree in Computer Engineering with the intention of continuing to deepen everything he had been learning in a self-taught way over the years.
His dream of dedicating himself to the world of connectivity became a reality when he joined the company, where he made the project his own from the get go, and sharing in its successes and learning from its failures.
With a great sense of teamwork, Zigor works daily to help in the decision-making process by contributing his vision and experience, and by taking on all the challenges he may encounter along the way and maintaining the company’s DNA in which technology, teamwork and innovation are essential.
General Manager
Santi Magazù has more than 20 years of experience in the telecommunications and IT services sector, having held management positions in multinationals such as Telefónica, where he held various positions, such as IT services engineering director for Spain and commercial director of Cloud Computing for the entire Group. He has also worked as Marketing Director at the regional operator Grapes, and as CEO and COO in technology startups, including PlayGiga, the first company acquired by Facebook in Spain. He began his career as a strategy consultant at Monitor Co, currently part of Deloitte.
He holds a degree in industrial engineering from the Politecnico di Milano and an MBA from INSEAD (France).
In Aire he is General Manager.
Adviser
Curiosity and passion for technology are the driving force behind a professional career that began at no less than the age of 4, fixing a broken cable of an iron that had stopped working. From that precocious impulse, Miguel Tecles’ biography is marked by multicolored wires, programming lines, radio waves, Internet signals when they hardly existed, numerous high voltage circuits and the occasional unexpected electric shock.
Today, holding the position of Chief Technology Officer at Aire Networks, Miguel Tecles is one of its fundamental pillars.
No one better than him personifies the company’s commitment to its customers: to always take technology to the next level, doing what no one else does, in a pioneering way and going where no one else goes, as well as providing services that generate value for all.
President
Passionate about technology and the inner workings of everything around him from an early age, Raúl began his first steps in the world of electronics and programming at the age of 14, when he made his first invoicing, accounting and warehouse management programme for the family business.
With this and the arrival of the Internet, he entered the world of telecommunications, studying Computer Engineering, where he met his first business partner, Miguel Tecles, through what was then one of the first social networks, IRC. After more than two years working together and improving their know-how, they met Emilio Gras, the third business partner in the current company, where they started their first ServiHosting project in 1996, thereby embarking on a journey that would take them to where they are today.
Raúl is a fundamental pillar in Aire, not only through his experience, but also through the values he brings and implements in the company, such as his future visions, accepting challenges and achieving goals. In addition, his commitment to the most minute details and the team spirit he brings makes the company tick.
CEO
With more than 20 years of experience in the telecommunications and technology sectors, Javier firmly believes that technology must solve real problems and generate competitive advantages with tangible results for the business.
He has held relevant executive positions in companies such as Amena and Orange, where he led strategic planning, marketing and go-to-market areas. He was CEO of PlayGiga, the first Spanish technology startup acquired by Meta (Facebook). Before joining Grupo Aire as CEO, he led Grupo AIA, a company specialising in artificial intelligence, with a focus on advanced analytics and predictive algorithms.
He has also been an advisor and consultant in multiple technology companies backed by venture capital and private equity funds, in sectors such as cloud, cybersecurity and blockchain.
Previously, he developed his career in the field of strategic consulting as a Principal at Monitor Company, where he advised large corporations on growth, internationalisation and operational efficiency.
