PRIVACY POLICY

PRIVACY POLICY (www.fundacionexcelentia.org)

EXCELENTIA MÚSICA S.L. is committed to protecting the privacy of users who access this website and/or any of its services. The use of the website and/or any of the services offered by EXCELENTIA MÚSICA S.L. implies acceptance by the user of the provisions contained in this Privacy Policy and that their personal data will be treated as stipulated. Please note that although there may be links from our website to other websites, this Privacy Policy does not apply to other companies or organizations to which the website is redirected. EXCELENTIA MÚSICA S.L. does not control the content of third-party websites and accepts no responsibility for the content or privacy policies of these websites.

  1. INFORMATION ON THE HOLDER

In compliance with Article 10 of Law 34/2002 of 11 July on Information Society Services and Electronic Commerce, the following are the identification details of the Holder:

WEB

www.fundacionexcelentia.org

HOLDER

EXCELENTIA MÚSICA S.L.

ADDRESS

C/ALMAGRO, 28010-MADRID

CIF

B85530756

TELEPHONE

+34914583089

E-MAIL

info@fundacionexcelentia.org

REGISTRATION DATA

Registered in the Mercantile Register of MADRID Volume 26.291. Folio 11 Section 8 Page: M473789 Entry 1

 

  1. APPLICABLE LAWS

This privacy policy is based on Spanish and European regulations in force regarding the protection of personal data on the Internet. Specifically, it respects the following rules:

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 (GDPR).

Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights (LOPD-GDD).

Law 34/2002 of 11 July on Information Society Services and Electronic Commerce (LSSI-CE).

  1. PRIVACY ISSUES

In compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR) and Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights, we provide you with the following information on the processing of personal data that you may provide to us:

Responsible for the File:

EXCELENTIA MÚSICA S.L.

Our contact details can be found at the top of this legal notice.

Register of Personal Data:

In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by EXCELENTIA MÚSICA S.L. through the forms provided on its pages will be incorporated and processed in our file in order to facilitate, expedite, and fulfill the commitments established between EXCELENTIA MÚSICA S.L. and the user, or the maintenance of the relationship established in the forms that the user fills out, or to respond to a request or query from the user. Likewise, in accordance with the provisions of the GDPR and the LOPD-GDD, unless the exception provided for in Article 30.5 of the GDPR applies, a register of processing activities is kept which specifies, according to its purposes, the processing activities carried out and the other circumstances established in the GDPR.

Legal basis for processing:

The legal basis for the processing of personal data is consent. EXCELENTIA MÚSICA S.L. undertakes to obtain the express and verifiable consent of the user for the processing of their personal data for one or more specific purposes. The user shall have the right to withdraw consent at any time. It shall be as easy to withdraw consent as it is to give it. As a general rule, withdrawal of consent shall not condition the use of the website. On those occasions when the user must or may provide their data through forms to make inquiries, request information, or for reasons related to the content of the website, they will be informed in the event that the completion of any of them is compulsory due to the fact that they are essential for the correct development of the operation carried out.

Other bases of legitimacy:

Compliance with legal obligations.

Legitimate interest: sending own advertising.

Data categories:

The categories of data processed by EXCELENTIA MÚSICA S.L. are solely identification data. Under no circumstances are special categories of personal data processed within the meaning of Article 9 of the GDPR.

Origin of your data:

Data provided by the clients receiving the services by any means.

Data provided by users through the different services offered on the website.

Data included in the forms on the website.

Data collected through cookies to improve the browsing experience as reported in the Cookies policy.

Retention period of personal data:

Personal data will only be retained for the minimum time necessary for the purposes of their processing and, in any case, only for the following period: the data will be retained for the period necessary for the purpose of processing, which in any case may not exceed the legally established period or until the user requests the right of cancellation, opposition, or limitation to the processing. However, we will keep certain personal identification and traffic data for a maximum period of 2 years in the event that it is required by the Courts or in order to initiate internal actions arising from the improper use of the website. At the time personal data is obtained, the user will be informed of the period for which the personal data will be retained or, where this is not possible, the criteria used to determine this period.

We also inform you that our information retention policies are in accordance with the time periods established by the different legal responsibilities for the purposes of prescription:

General Rule: Pursuant to Article 30 of the Commercial Code, all company documents and/or information shall be retained for 6 years unless other criteria are met. This concerns all accounting, tax, employment, or commercial documentation, including correspondence.

Specific deadlines: Our company must also set minimum deadlines depending on the type of data involved and taking into account the different limitation periods of which each of the departments must be aware.

You will not be subject to decisions based on automated processing which produce effects on your data.

Purposes of treatment:

The purposes of the data processing carried out are detailed below:

CUSTOMER MANAGEMENT: To be able to provide the services contracted within the natural activity of each company and to invoice them. The data provided will be kept for as long as the business relationship is maintained or for the years necessary to comply with legal obligations.

PROJECT MANAGEMENT: In order to correctly provide the contracted services, it is necessary to be able to manage those projects and documentation necessary within these services. The data provided will be kept for as long as the commercial relationship is maintained or for the years necessary to comply with legal obligations.

EVENT ORGANISATION: To be able to organise events (courses, talks, competitions, and other dissemination activities) by any of the Data Controllers. The data provided will be kept as long as you do not request the cessation of the activity or for the years necessary for the justification of the activity.

  1. DATA RECIPIENTS

The user’s personal data will not be shared with third parties. In any case, at the time the personal data is collected, the user will be informed about the recipients or categories of recipients of the personal data.

  1. PERSONAL DATA OF MINORS

Respecting the provisions of Articles 8 of the GDPR and 7 of the Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights, only those over 14 years of age may give their consent to the processing of their personal data in a lawful manner by EXCELENTIA MÚSICA S.L. In the case of a minor under 14 years of age, the consent of the parents or guardians will be required for the processing and this will only be considered lawful to the extent that they have authorized it. If this is not the case, the legal representative must inform you as soon as possible.

  1. RIGHTS ARISING FROM THE PROCESSING OF PERSONAL DATA

The user may exercise the following rights recognized in the GDPR and Organic Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights against the Data Controller:

Right of access: This is the user’s right to obtain confirmation of whether or not EXCELENTIA MÚSICA S.L. is processing their personal data, and if so, to obtain information about their specific personal data and the processing that EXCELENTIA MÚSICA S.L. has carried out or will carry out, as well as, among other things, the information available about the origin of said data and the recipients of the communications made or planned for said data.

Right of rectification: This is the user’s right to have their personal data amended if it proves to be inaccurate or, having regard to the purposes of the processing, incomplete.

Right of erasure (“the right to be forgotten”): This is the user’s right, unless otherwise provided by law, to obtain the erasure of their personal data when the personal data are no longer necessary for the purposes for which they were collected or processed; the user has withdrawn their consent to the processing and the processing has no other lawful basis; the user objects to the processing and there is no other legitimate reason to continue the processing; the personal data have been processed unlawfully; the personal data must be erased in compliance with a legal obligation; or the personal data have been obtained as a result of a direct offer of information society services to a child under 14 years of age. In addition to erasure, the controller shall, taking into account available technology and the cost of its implementation, take reasonable steps to inform controllers who are processing the personal data of the data subject’s request for erasure of any link to those personal data.

Right to restriction of processing: This is the user’s right to restrict the processing of their personal data. The user has the right to obtain the limitation of processing when they contest the accuracy of their personal data; the processing is unlawful; the controller no longer needs the personal data but the user needs it to make claims; and when the user has objected to the processing.

Right to data portability: Where processing is carried out by automated means, the user shall have the right to receive from the controller their personal data in a structured, commonly used, and machine-readable format and to transmit it to another controller. Where technically feasible, the controller shall transmit the data directly to such other controller.

Right of opposition: This is the user’s right not to have their personal data processed or to stop the processing thereof by EXCELENTIA MÚSICA S.L.

Right not to be subject to a decision based solely on automated processing, including profiling: This is the user’s right not to be subject to an individualized decision based solely on automated processing of their personal data, including profiling, unless otherwise provided for by law.

Finally, the interested parties have the right to file a complaint with the competent Control Authority (AEPD) in the event that the user considers that there is a problem or infringement of the regulations in force in the way in which their personal data are being processed.

You may exercise the above rights by sending us a written request enclosing a copy of a document that identifies you to our address or e-mail address (listed at the beginning of this text).

  1. PRINCIPLES APPLICABLE TO THE PROCESSING OF PERSONAL DATA

The processing of the user’s personal data will be subject to the following principles set out in Article 5 of the GDPR and in Article 4 and following of the LOPDGDD:

Principle of legality, fairness, and transparency: The consent of the user is required at all times after fully transparent information on the purposes for which the personal data are collected.

Principle of purpose limitation: Personal data will be collected for specified, explicit, and legitimate purposes.

Principle of data minimization: The personal data collected will be only that which is strictly necessary in relation to the purposes for which it is processed.

Principle of accuracy: Personal data must be accurate and always up to date.

Principle of limitation of the retention period: Personal data will only be kept in a form that allows identification of the user for as long as is necessary for the purposes of the processing.

Principle of integrity and confidentiality: Personal data will be processed in a manner that ensures their security and confidentiality.

Principle of proactive responsibility: The controller of the website shall maintain and regulate the necessary technical and logistical means sufficient to ensure that all applicable processing principles are complied with.

  1. WHAT SECURITY MEASURES DO WE APPLY?

We apply the security measures established in Article 32 of the GDPR. Therefore, we have adopted the necessary security measures to ensure a level of security appropriate to the risk of the data processing we carry out, with mechanisms that allow us to guarantee the confidentiality, integrity, availability, and permanent resilience of the processing systems and services. Some of these measures include:

Information on data processing policies to staff.

Regular backups.

Data access control.

Regular verification, evaluation, and assessment processes.

  1. SECRECY AND SECURITY OF PERSONAL DATA

EXCELENTIA MÚSICA S.L. undertakes to adopt the necessary technical and organizational measures according to the level of security appropriate to the risk of the data collected to ensure the security of personal data and prevent the accidental or unlawful destruction, loss, or alteration of personal data transmitted, stored, or otherwise processed, or unauthorized communication or access to such data. The website has an SSL (Secure Socket Layer) certificate which ensures that personal data is transmitted securely and confidentially as the transmission of data between the server and the user is fully encrypted.

However, because EXCELENTIA MÚSICA S.L. cannot guarantee the impregnability of the Internet or the total absence of hackers or others who fraudulently access personal data, the data controller undertakes to notify the user without undue delay when a breach of security of personal data occurs that is likely to involve a high risk to the rights and freedoms of natural persons. In accordance with Article 4 of the GDPR, a breach of security of personal data means any breach of security resulting in the accidental or unlawful destruction, loss, or alteration of personal data transmitted, stored, or otherwise processed, or the unauthorized disclosure of or access to such data. Personal data will be treated as confidential by the data controller, who undertakes to inform and ensure by means of a legal or contractual obligation that such confidentiality is respected by its employees, partners, and any other person to whom it makes the information accessible.

  1. LINKS TO THIRD-PARTY WEBSITES

The website may include hyperlinks or links that allow access to websites of third parties other than EXCELENTIA MÚSICA S.L., which are therefore not operated by EXCELENTIA MÚSICA S.L. The owners of these websites have their own data protection policies, being themselves responsible for their own files and their own privacy practices.

  1. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

It is necessary that the user has read and agrees with the conditions on the protection of personal data contained in this Privacy Policy, as well as that they accept the processing of their personal data so that the data controller can proceed in the manner, during the periods, and for the purposes indicated. The use of the website implies acceptance of the Privacy Policy.

EXCELENTIA MÚSICA S.L. reserves the right to modify its Privacy Policy according to its own criteria or motivated by a legislative, jurisprudential, or doctrinal change of the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the user. The user is recommended to consult this page periodically to keep abreast of the latest changes or updates.

 

Last updated: 29/12/23

EXCELENTIA MÚSICA S.L.