I. PRIVACY AND DATA PROTECTION POLICY
Respecting the provisions of current legislation, MEDIA CREATIVA 2020 S.L. (hereinafter also Website) undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected.
- 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).
- The Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights (LOPD-GDD).
- Royal Decree 1720/2007, of 21 December, approving the Regulations for the development of Organic Law 15/1999, of 13 December, on the Protection of Personal Data (RDLOPD).
- Law 34/2002, of July 11, 2002, on Information Society Services and Electronic Commerce (LSSI-CE).
Identity of the person responsible for the processing of personal data
The party responsible for the processing of personal data collected on THE MEDIA CREATIVA WEBSITE is: MEDIA CREATIVA 2020 S.L., with CIF: B95770525 (hereinafter, the Data Controller). Its contact details are as follows:
Address: Lutxana 6-2º izqda. dpt. B – 48008 Bilbao (Spain)
Contact telephone number: +34 94 400 11 00
Contact email: info @ mediacreativa.eu
Personal Data Registry
In compliance with the provisions of the RGPD and the LOPD-GDD, we inform you that the personal data collected by MEDIA CREATIVA 2020 S.L., through the forms provided on its pages will be incorporated and will be treated in our file in order to facilitate, expedite and fulfill the commitments established between MEDIA CREATIVA 2020 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. Also, in accordance with the provisions of the RGPD and the LOPD-GDD, unless the exception provided for in Article 30.5 of the RGPD applies, a record of processing activities is kept which specifies, according to their purposes, the processing activities carried out and other circumstances established in the RGPD.
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 RGPD and in Article 4 and following of Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights:
- Principle of lawfulness, fairness and transparency: the consent of the User will be required at all times after fully transparent information of the purposes for which personal data is 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 those strictly necessary in relation to the purposes for which they are processed.
- Principle of accuracy: personal data must be accurate and always up to date.
- Principle of limitation of the storage period: personal data will only be kept in such a way as to allow the identification of the User for the time necessary for the purposes of their processing.
- Principle of integrity and confidentiality: personal data will be treated in a way that guarantees its security and confidentiality.
- Proactive accountability principle: the Controller will be responsible for ensuring that the above principles are complied with.
Categories of personal data
The categories of data processed by MEDIA CREATIVA 2020 S.L. are only identification data. In no case, special categories of personal data within the meaning of Article 9 of the RGPD are processed.
Legal basis for the processing of personal data
The legal basis for the processing of personal data is consent. MEDIA CREATIVA 2020 S.L. undertakes to obtain the express and verifiable consent of the user for the processing of personal data for one or more specific purposes.
The User shall have the right to withdraw consent at any time. It will be as easy to withdraw consent as it is to give it. As a general rule, the withdrawal of consent shall not condition the use of the Website.
On the 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, you will be informed if the completion of any of them is mandatory because they are essential for the proper development of the operation performed.
Purposes of the processing for which the personal data is used
Personal data are collected and managed by MEDIA CREATIVA 2020 S.L. in order to facilitate, expedite and fulfill the commitments established between the Website and the User or the maintenance of the relationship established in the forms that the latter fills or to respond to a request or inquiry.
Likewise, the data may be used with a commercial purpose of personalization, operational and statistical, and activities of the corporate purpose of Personal data are collected and managed by MEDIA CREATIVA 2020 S.L. in order to facilitate, expedite and fulfill the commitments established between the Website and the User or the maintenance of the relationship established in the forms that the latter fills or to respond to a request or inquiry.
At the time the personal data is collected, the User will be informed about the specific purpose(s) of the processing for which the personal data will be used, i.e. the use(s) to which the collected information will be put.
Retention periods of personal data
Personal data will only be retained for the minimum time necessary for the purposes of its processing and for a reasonable time to demonstrate that we are complying with our duties and obligations, or until the User requests its deletion.
Recipients of personal data
The User’s personal data will be shared with the following recipients or categories of recipients:
Server where the website is hosted and the results of some contact or training forms, such as questionnaires on lessons given on the website or downloadable from this website. EÑUT COMUNICACIÓN, S.L., with registered office at Ribera de Axpe Etorbidea, 11B, 2ª Planta – Oficina 210, 48950 Erandio.
Personal data of minors
Respecting the provisions of Articles 8 of the RGPD and 7 of the Organic Law 3/2018 of December 5, 2018, on the Protection of Personal Data and guarantee of digital rights, only those over 14 years of age may give their consent for the processing of their personal data in a lawful manner by MEDIA CREATIVA 2020 S.L. In the case of a minor under 14 years of age, the consent of parents or guardians will be required for the treatment, and this will only be considered lawful to the extent that they have authorized it.
Secrecy and security of personal data
MEDIA CREATIVA 2020 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, so as 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, and in return, is fully encrypted or encoded.
However, because MEDIA CREATIVA 2020 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 there is a breach of security of personal data that is likely to pose a high risk to the rights and freedoms of individuals. 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 to ensure by means of a legal or contractual obligation that such confidentiality is respected by its employees, associates, and any other person to whom it makes the information accessible.
Rights deriving from the processing of personal data
The User has over MEDIA CREATIVA 2020 S.L and may, therefore, exercise against the Data Controller the following rights recognized in the RGPD and the Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights:
- Right of access: This is the User’s right to obtain confirmation as to whether or not MEDIA CREATIVA 2020 S.L is processing their personal data and, if so, to obtain information about their specific personal data and the processing that MEDIA CREATIVA 2020 S.L. has carried out or is carrying 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, taking into account the purposes of the processing, incomplete.
- Right of deletion (“the right to be forgotten”): This is the User’s right, unless otherwise provided by applicable law, to obtain the erasure of his or her personal data when the personal data is no longer necessary for the purposes for which it was collected or processed; the User has withdrawn his or her 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 deleted 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 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 limitation of processing: This is the User’s right to limit the processing of his or her personal data. The User has the right to obtain the limitation of processing when he/she contests the accuracy of his/her 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 his or her 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: It is the right of the User not to carry out the processing of their personal data or cease the processing of the same by MEDIA CREATIVA 2020 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 his or her personal data, including profiling, unless otherwise provided by law.
Thus, the User will be able to exercise his rights by means of a written communication addressed to the person in charge of the treatment with the reference “specifying:
- Name, surname of the User and copy of ID card. In cases where the representation is admitted, it will also be necessary the identification by the same means of the person representing the User, as well as the document proving the representation. The photocopy of the ID card may be replaced by any other means valid in law that proves identity.
- Request with the specific reasons for the request or information you want access to.
- Address for notification purposes.
- Date and signature of the applicant.
- Any document that proves the request you are making.
This application and any attachments may be sent to the following address and/or e-mail address: info @ mediacreativa.eu
Links to third party websites
The Website may include hyperlinks or links that allow access to third party websites other than MEDIA CREATIVA 2020 S.L, and therefore are not operated by MEDIA CREATIVA 2020 S.L. The owners of these websites will have their own data protection policies, being themselves, in each case, responsible for their own files and their own privacy practices.
Complaints to the supervisory authority
In the event that the User considers that there is a problem or infringement of the regulations in force in the way in which his/her personal data is being processed, he/she will have the right to effective judicial protection and to lodge a complaint with a supervisory authority, in particular, in the State in which he/she has his/her habitual residence, place of work or place of the alleged infringement. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (http://www.agpd.es).