INICIATIVAS INNOVADORAS, S.A.L. (hereinafter, ‘INICIATIVAS INNOVADORAS’) makes available to you through its website www.cocoreado.eu this data protection policy with the purpose of informing you in detail about how we process your personal data and protect your privacy and the information you provide. Should we introduce changes in our policy, we shall inform you through our website or by other means so that you are aware of the new privacy terms and conditions.
Pursuant to Regulation (EU) 2016/679 Of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons and Ley Orgánica 3/2018 of 5 December 2018 on the protection of personal data and the guarantee of digital rights, you are informed of the following:
Pursuant to the provisions of the regulations governing data protection, it is a requirement for any person accessing this website to be over 14 years of age. If you are under 14 years of age and you have accessed this website please do not provide any personal data. Responsibility and liability for the truthfulness of the data shall remain with you. If INICIATIVAS INNOVADORAS finds out that this requirement is not satisfied, it is entitled to ignore the information request. Under no circumstances shall professional or financial information or data regarding the privacy of other members of the family be collected, without their prior consent.
INICIATIVAS INNOVADORAS processes the personal information provided directly by the user.
INICIATIVAS INNOVADORAS shall process personal data provided directly by the user.
In general, we shall process identification details (such as name(s), surname(s), Tax ID no., telephone number, address, e-mail, IP address).
The user guarantees the authenticity, accuracy and truthfulness of all the information he or she provides, and undertakes to keep his or her personal data updated so that they match at all times his or her actual situation. The user shall be solely responsible for any untruthful or inaccurate declarations and for any eventual damages that could arise therefrom.
The personal data you provide within the framework of the provision of our services are mandatory and are the minimum necessary for us to handle your request.
The personal data you provide may be used for one or several of the purposes described below, driven by factors such as your relationship with INICIATIVAS INNOVADORAS or with the project partners or by the means used to submit the data. Below is a description of the data processing covered by this policy, without prejudice to further data processing operations which you may be informed of or regarding which we may ask for your authorisation:
A. Compliance with legal obligations
Processing of your personal data may be required to comply with certain legal obligations. Particularly, legislation on data protection, taxes, statistics, insurances, etc.
B. Execution and performance of the contract
The personal data of the person concerned are processed for the purposes of handling the contractual relationship, fulfilling the terms of the contract and complying with tax legislation, while fulfilling, controlling and performing the provision guaranteed by the contract.
The data you provide by e-mail, through instant messaging applications, or when lodging a complaint, are only used to respond to your request.
D. Provision of commercial communications by any means where additional consent is granted
If you explicitly give your consent, we may share your data with our collaborators for the purposes of informing you by any means for promotional or advertising purposes of the services, products or events we organise or participate in.
We gather your personal information by different means, but you will always be aware of such data collection by means of notices informing you of the person responsible for processing the data, the purpose of and the legal grounds for the processing, the recipients of the data and the conservation period, as well as how to exercise your rights on data protection.
In general, the personal data we process are limited to identification details (name(s) and surname(s) and e-mail).
We only keep your information for the period time required to fulfil the purpose for which it was collected, comply with statutory obligations and to fulfil the responsibilities that could arise from attaining the purpose for which the data were collected. Your personal data shall be kept during the currency of the contractual and/or legal relationship and following such period, provided you have not exercised your right of erasure, they shall be kept considering the legal deadlines applicable in each case, the type of data and the purpose of the processing.
In the event that you exercise your right of erasure and such right is applicable, your data will be blocked pursuant to article 32 of LOPDGDD, and they shall only be available to the Courts of Justice, the Ombudsman’s office, the Public Prosecutor or the competent administrative authorities during the limitation period of the actions that could arise, following which period they shall be fully deleted.
Our processing of your personal data shall be lawful, fair, transparent, appropriate, pertinent, limited, accurate and updated. This is why we undertake to take all reasonable measures to have them deleted or rectified without delay when inaccurate.
Depending on our relationship and therefore on the purpose of the processing, the legal grounds may differ. Below is a presentation of the different legal grounds applicable depending on the type of processing:
- CONTRACTUAL RELATIONSHIP: For the contracted provision.
- LEGITIMATE INTERESTS: Among others, profiling, quality and opinion surveys, web maintenance or hotlines.
- LEGAL OBLIGATION: Compliance with legal obligations laid down in any applicable legislation.
- CONSENT: When you provide your data through contact forms available on our website or when you submit your request for our newsletter.
You should be aware than whenever we request your consent for processing purposes, your non-granting – or any eventual subsequent withdrawal of your consent, shall have no adverse consequences for you.
In the event of third-party data provision, you declare you have the consent of the holders of the data for such data provision or that you are their legal representative, thus exempting INICIATIVAS INNOVADORAS and its partners from any responsibility or liability.
The categories of data processed are
- Contact: identifying data (name, organisation, email and IP address).
- Commercial communications-newsletter: identification data (email).
Depending on the services we provide to you, your personal data may be disclosed to third parties, where such disclosure is necessary for the adequate fulfilment of legal and/or contractual obligations. Said providers shall not process your data for their own purposes or for purposes other than those previously informed of by INICIATIVAS INNOVADORAS.
Where access to personal data is granted to third parties for the sake of better management and provision of services, INICIATIVAS INNOVADORAS guarantees that personal data shall remain confidential during the data processing. In any case, the user shall be conveniently made aware of any such transfer of personal data, including the identity of the recipient and the purpose of the transfer.
Your data may be passed on to our partners in this project which you can find out more about here.
Channels of attention
You have the right to request confirmation that your personal data are being processed by INICIATIVAS INNOVADORAS.
C/ Zabalgaina nº 3 -1º Oficinas 4/5 31.180 Zizur Mayor (Navarra)
You have the right to obtain the rectification of inaccurate personal data.
You have the right to obtain the erasure of personal data.
You may request that your data be not processed.
Restriction of processing
You have the right to obtain restriction of processing of your personal data:
You may receive, in electronic format, the personal data that you have provided us with and those obtained from your contractual relationship with INICIATIVAS INNOVADORAS, as well as the right to transfer them to another entity of your choice.
You have the right to withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
All requests shall be responded within one month of receipt of the request. That period may be extended by two further months, taking into account the number and complexity of the requests.
If you feel that your request have not been properly met you may contact the Spanish Data Protection Agency (Agencia Española de Protección de Datos – www.agpd.es) and lodge a complaint.
When exercising your rights, attach to your request a copy of your national identity card, alien identity card, passport or any other proof of identity.
Exercising these rights is free of charge.
Characteristics of these rights:
- Exercising these rights is free of charge, unless the requests are manifestly unfounded or excessive (e.g. because of their repetitive character), in which case INICIATIVAS INNOVADORAS may either charge a reasonable fee taking into account the administrative costs or refuse to act.
- You may exercise your rights directly or through your legal or authorised representative.
- We shall respond to your request within one month. That period may be extended by two further months, taking into account the number and complexity of the requests.
- We are obliged to inform you of the means to exercise these rights. Such means must be accessible and we may not refuse the exercise of your right on the sole ground that you have chosen another means. If the request is made by electronic means, the information shall be provided by the same means where possible, unless otherwise requested.
- If INICIATIVAS INNOVADORAS does not take action on the request, we shall inform you, within one month, of the reasons for not taking action and on the possibility of lodging a complaint with a supervisory authority.
In order to facilitate their exercise, we provide links to the application form for each of the rights:
- Form for exercising the right of access
- Form for exercising the right of rectification
- Form for exercising the right to object
- Form for exercising the right to erasure (“right to be forgotten”)
- Form for exercising the right to restriction of processing
- Exercise of the right to portability form
- Form for exercising the right not to be subject to automated individual decisions
We at INICIATIVAS INNOVADORAS are committed to protecting your personal data. We use reasonably reliable and effective physical, organisational and technological measures, controls and procedures aimed at preserving the integrity and security of your data and to safeguard your privacy.
Furthermore, all our staff having access to personal data has been properly trained and is aware of their obligations regarding the processing of your personal data.
All these security measures are reviewed from time to time to ensure their adequacy and effectiveness.
However, absolute security cannot be guaranteed as no security system is impenetrable. Therefore, if any data subject to processing under our control should be compromised as a consequence of a security breach, we shall adopt appropriate measures to investigate the incident, report it to the supervisory authority and, where applicable, to the users who may have been adversely affected so that they may adopt appropriate measures.
INICIATIVAS INNOVADORAS informs you that it complies with Ley 34/2002 of 11 July 2002 on information society services and e-commerce and does not engage in spam activities. We shall request your consent to process your e-mail address or mobile phone number for commercial purposes on each occasion.