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I. INTRODUCTION

FUNDACIÓN EDUARDO NARANJO reserves the right to modify this Policy in order to adapt it to new legislation, case law, sector practices, or the entity’s interests. Any modification to it will be announced with due notice, so that you are fully aware of its content.

In order to provide you with certain services, it is necessary to manage your personal data. To this end, such data will be incorporated into the corresponding processing activities of FUNDACIÓN EDUARDO NARANJO and will be processed for the specific purpose of each processing, in accordance, mainly, 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, which repeals Directive 95/46/EC (General Data Protection Regulation), and Organic Law 3/2018 of 5 December on Personal Data Protection and the Guarantee of Digital Rights (LOPD-GDD).

II. GENERAL INFORMATION

Below, FUNDACIÓN EDUARDO NARANJO provides general information regarding the safeguarding of privacy and the protection of personal data applied to the processing activities it carries out on the Portal, as well as through other means:

Who is the Controller of your personal data?

FUNDACIÓN EDUARDO NARANJO is the Controller, with registered office for these purposes at Camino de Mesoncillos 14. 28109 Alcobendas, Madrid, Spain.

Contact email: info@fundacioneduardonaranjo.org

For what purposes do we process your personal data?

The purposes of the collection and processing of personal data, through the various forms owned by FUNDACIÓN EDUARDO NARANJO, made available to Users, correspond, depending on the specific case, to:

SENDING ADVERTISING COMMERCIAL COMMUNICATIONS: by electronic or physical means, present or future, that make it possible to carry out commercial communications. These communications will be carried out by FUNDACIÓN EDUARDO NARANJO and will be related to the services of FUNDACIÓN EDUARDO NARANJO, or of its collaborators or providers with whom it has reached a promotion agreement. In this case, third parties will never have access to the personal data.

ACTIONS REQUESTED BY THE USER: To process requests or any type of request made by the user regarding the services of the Website, through any of the contact forms made available to them.

DATA STORED DURING YOUR VISIT: When you visit our Website, our web servers generally store, among other data, information about the browser and operating system you use, the web page from which you visit us, the pages you visit on our website, and the date of your visit. For security reasons —for example, in order to be able to detect possible attacks on our website— the IP address assigned to you by your Internet service provider is also stored for a period of seven days.

NEWSLETTER SUBSCRIPTION: In the event of subscription to any of our newsletters, present or future, AND provided that you have given your consent to the use of your personal data for the sending of advertising or the carrying out of other marketing actions, such data will be stored and used on an ongoing basis for such purposes.

SUBMISSION OF CURRICULUM VITAE BY CANDIDATES: In the event of submitting a Curriculum Vitae to the FUNDACIÓN EDUARDO NARANJO email address, the applicant authorizes FUNDACIÓN EDUARDO NARANJO to analyze the documents they submit in order to assess their candidacy and, where appropriate, offer them a position. In the event that the candidate is not selected, FUNDACIÓN EDUARDO NARANJO may keep their CURRICULUM VITAE stored in order to incorporate it into future calls, unless the candidate indicates otherwise.

What is the legal basis that legitimizes the processing of your personal data? That is, what justifies or enables us to process your personal data?

The legal bases that legitimize us to process your personal data are the following: (i) the consent granted by you through the signature or acceptance of the relevant forms, for one or several specific purposes; and (II) where applicable, the execution of a contract to which you are a party, in the capacity of contractor or awardee.

For how long do we keep your personal data?

We will keep your personal data for the period corresponding to maintaining a record of attention and managing our services efficiently, and until the data subject requests its deletion.

Even once deletion has been requested, the data will be kept blocked for the necessary time, with its processing limited, only for one of the following purposes: to comply with any legal/contractual obligations to which we are subject and/or during the legal periods provided for the statute of limitations of any liabilities on our part and/or the exercise or defense of claims arising from the relationship maintained with the data subject.

  1. Who must keep the data up to date?

On the other hand, in order for the data contained in our files, computerized and/or on paper, to always correspond to reality, we will endeavor to keep them updated. To this end, the User must make the changes directly, when enabled to do so, or by contacting, by reliable means, the corresponding area or department of FUNDACIÓN EDUARDO NARANJO.

  1. Who may be the recipients or addressees of your personal data?

Personal data will not be transferred or communicated to third parties, except in cases necessary for the development, control, and fulfillment of the stated purpose(s), in the cases provided for by Law.

Security of personal data

FUNDACIÓN EDUARDO NARANJO will adopt in its information system the appropriate technical and organizational measures, complying with the principle of proactive responsibility, in order to guarantee the security and confidentiality of the stored data, thereby avoiding its alteration, loss, processing, or unauthorized access; taking into account the state of the art, the costs of implementation, and the nature, scope, context, and purposes of the processing, as well as the variable risks of probability and severity associated with each of the processings.

  1. What are your data protection rights and how can you exercise them?

You may exercise the rights of access, rectification, erasure, limitation, portability or, where applicable, objection. To this end, you must submit a written request to FUNDACIÓN EDUARDO NARANJO, Camino de Mesoncillos, 14. 28109 Alcobendas, Madrid. In the written request, you must specify which of these rights you are requesting to be satisfied and, in turn, you must show or, in the case of postal submission, attach a photocopy of your ID card (DNI) or equivalent identification document. In the event that you act through a legal or voluntary representative, you must also provide a document accrediting the representation and the identification document of the same. Likewise, if you consider your right to personal data protection violated, you may file a complaint by contacting info@fundacioneduardonaranjo.org or, where applicable, with the Spanish Data Protection Agency (www.aepd.es).

Below, more information is provided regarding the exercise of your data protection rights:

  • What are my rights?
  • Who can exercise these rights before FUNDACIÓN EDUARDO NARANJO?
  • How and where can I exercise these rights?
  • Additional information

What are my rights?

Data protection regulations allow you to exercise, before the controller, FUNDACIÓN EDUARDO NARANJO, the rights of access, rectification, objection, portability, erasure (“right to be forgotten”), limitation of processing, and not to be subject to individual automated decisions, in accordance 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, which repeals Directive 95/46/EC (General Data Protection Regulation, hereinafter “GDPR”) and Organic Law 3/2018 of 5 December on Personal Data Protection and the Guarantee of Digital Rights (LOPD-GDD):

Right of access

You have the right to know:

  • Whether or not we are processing personal data concerning you.
  • The origin of your data, if you did not provide them to us.
  • The purposes of the processing of your data.
  • The categories of data concerned.
  • The recipients or categories of recipients to whom the personal data were communicated or will be communicated.
  • Where possible, the intended period of retention of the personal data (or, if not possible, the criteria used to determine this period).
  • The right to lodge a complaint with a supervisory authority.
  • Whether we make automated decisions —including profiling— using your personal data.

Right of rectification

You have the right to have your personal data rectified:

  • By completing them, if they were incomplete.
  • By updating or rectifying them, if for any reason they were no longer in accordance with current reality or were inaccurate.
  • Through the exercise of the right of rectification, we will ensure that all your personal data are accurate and complete.

Right of erasure

You have the right to have your personal data erased when any of the following conditions applies:

  • Such data are no longer necessary in relation to the purposes for which they were collected or processed.
  • You withdraw the consent on which we base the processing of your data, and it cannot be supported by another legal basis.
  • You have successfully exercised the right to object to the processing of your data.
  • The personal data have been processed unlawfully.

Right to limitation of processing

You shall have the right to obtain the limitation of the processing of your personal data (that is, that we retain them without using them for the intended purposes).

Right to object

You shall have the right to request that we stop using your personal data, for example, when you believe that the personal data we hold about you may be incorrect or that we no longer need to use them.

Right to data portability

When the processing of your data is based on consent or is necessary for the execution of a contract or pre-contract and is carried out by automated means, you shall have the right to the portability of your data, that is, to have them delivered in a structured, commonly used, and machine-readable format, and even to have them transmitted to a new controller; for this reason, FUNDACIÓN EDUARDO NARANJO will facilitate the portability of your data to the new controller.

  1. b) Who can exercise these rights before FUNDACIÓN EDUARDO NARANJO?
  • You, as the data subject or holder of the personal data, acting in your own name and right.
  • Through another person who acts, duly accredited, as legal representative (e.g., when the holders of parental authority or guardianship act on behalf of a person under 14 years of age, or when acting as legal representative of a person with functional diversity) or voluntary representative (a person to whom you have freely and voluntarily granted powers of representation for these purposes).
  1. c) How and where can I exercise these rights?

By postal mail

You may submit the written request by sending it to the following postal address: Camino de Mesoncillos, 14, Alcobendas, Madrid.

By internet

You may submit the written request by sending an email to the following address: info@fundacioneduardonaranjo.org.

In both cases, you must:

  • Provide the data and information sufficient to process the request. To this end, you may use the form templates made available to you by the Spanish Data Protection Agency at https://www.aepd.es/es/derechos-y-deberes/conoce-tus-derechos.
  • Sign the printed document by hand or, where applicable, and if you have a recognized digital certificate, sign it electronically.
  • Attach a photocopy of your ID card (DNI), passport, NIE, or other equivalent identification document. In the event of acting on behalf of a third party, a copy of their ID card or equivalent identification document must also be included, as well as the document accrediting the representation of the data subject.
  • Send the form and documents accrediting your identity by any of the aforementioned means.
  1. d) Additional information

FUNDACIÓN EDUARDO NARANJO will analyze whether or not the request complies with the law. It will inform the petitioner of the decision adopted, proceeding accordingly: if favorable, it will adopt the appropriate measures according to the right exercised; if unfavorable, it will indicate the legally established system of appeals. In the event that the requests are manifestly unfounded or excessive (e.g., of a repetitive nature), FUNDACIÓN EDUARDO NARANJO may: (i) charge a fee proportional to the administrative costs incurred, or (ii) refuse to act.

For more information or clarification regarding your rights in personal data protection, you may contact info@fundacioneduardonaranjo.org.