Privacy Policy

PRIVACY POLICY AND PERSONAL DATA PROTECTION FOR THE ZINEUSKADI WEBSITE

Zineuskadi is committed to complying with laws in force on personal data protection and information security, in order to guarantee that the collection and processing of data provided complies with EU Regulation 2016 on Personal Data Protection (GDPR) and national laws on the matter. For this reason, we provide you as follows with information on the data protection policy applied to

personal data processing stemming from requests to access Zineuskadi's Archives:

 

1. Data controller

 

The data controller is Zineuskadi

 

Address: Tabakalera, 3ª planta. Plaza de las cigarreras, 1.

City: Donostia / San Sebastián (Spain)

Phone number: +34 943 287 406

Email: info@zineuskadi.eu

2. Applicable law

 

The basic regulation on personal data protection applicable to the data processed by Zineuskadi is:

1. EU Regulation 2016/679 of the European Parliament and the Council of 27 April 2016 on the protection of natural persons regarding personal data processing and the free circulation of these data, repealing Directive 95/46/EC ("GDPR").

3. Organic Law 3/2018 of 5 December on Personal Data Protection and guarantee of digital rights ("LOPDGDD").

3. Complementary and implementing regulations.

 

3. Websites and social network channels

 

Zineuskadi's official website is located at www.zineuskadi.eu         Zineuskadi's main official channels on professional and social networks are: Facebook, Twitter, YouTube, Flickr, and Instagram.

4. Purposes and legal basis

 

In compliance with laws in force on Personal Data Protection, the users are hereby informed that personal data they provide by any means located on the website or through official channels on social networks belonging to Zineuskadi (by email, forms, messages, etc.) or as a result of their use may be added to Zineuskadi's data processing systems.

The purposes of data processing that may occur on Zineuskadi's website are:

1. Email marketing campaigns

Primary legal basis: Legitimate interest of the Data Controller (GDPR art. 6.1)

5. Duty of secrecy

The Data Controller is committed to the privacy and protection of users' data. Their personal data shall be processed confidentially and in compliance with this regulation.

6. Personal data collection

 

The Data Controller does not require personal data to be provided to access the website. Notwithstanding, there may be forms (contact, etc.) on the website whose use requires the user to provide personal data, mainly identifying or contact data. The user provides their personal data freely and voluntarily. Zineuskadi does not request any personal information that is not necessary to carry out the requested service.

Users who send/include any kind of content (data, documents, blueprints, texts, videos, sound, photographs, graphics, messages, or other material) declare and guarantee that they do so pursuant to the conditions contained here within and laws in force. Users who include third-party personal data declare that they have their express and demonstrable consent for processing said data. The inclusion of third-party data without their express consent is prohibited.

Users are the sole party liable for the truthfulness, accuracy, and legitimate processing of included data, exempting Zineuskadi from all liability in this regard. In any event, users guarantee and answer for the exactness, validity and authenticity of personal data provided, and commit to keep said data duly updated.

Not completing or improperly completing fields marked mandatory on website forms may lead to the consequence that the Data Controller cannot attend to the users' request.

The Data Controller shall collect personal data adequately, and as pertinent for the purposes, uses, services, or benefits included on the website, in a determined, explicit, and legitimate fashion. As such, under no circumstances shall fraudulent, disloyal or illicit means be used, or means that in any way jeopardise the legitimate rights of users.

Sending information through the website necessarily entails express authorisation to process the data described in this privacy policy and the website's general conditions.

7. Collection of minors' data

 

The products, services, and activities of the Data Controller are not specifically intended for minors. In the event that any of our products or services were specifically oriented toward minors, the Data Controller would request authorisation from parents or legal guardians to collect their personal data, or if applicable, to automatically process said data.

The Data Controller recommends that users see different materials developed by control authorities on the protection of personal data belonging to children and youth. This information (recommendations, user manuals for new technologies, educational videos, etc.) is available on the Basque Spanish Data Protection Agencies' websites.

8. Registrations and subscriptions

 

If subscribing to informational bulletins or similar services that entail processing personal data, users may request de-registration from these services whenever they wish by sending a request to the email address (info@zineuskadi.eu)  or by using any other means that Zineuskadi provides to this end, such as the mechanism called “Darse de baja” or “Unsubscribe”, located at the end of the informational bulletins themselves..

 

9. Job applicants at Zineuskadi

 

Individuals who provide their curriculum vitae to apply for a job at Zineuskadi through forms, email, social or professional network channels, or similar mechanisms, are hereby informed, pursuant to provisions in Personal Data Protection regulations, that the data provided through their job application shall be added to our data processing file called "Curricula and Staff Hiring."

Your data may be used so you can participate in Zineuskadi's future staff hiring processes, which may be conducted in-house or by companies outside Zineuskadi hired to conduct staff hiring processes.

Zineuskadi shall save these curricula for an approximate period of one year. After this period has passed, the data shall be destroyed, applying necessary security measures to guarantee confidentiality.

If you do not agree with any of the aforementioned purposes, we request that you inform us in writing as soon as possible. Additionally, if there are any modifications to your data, we request that you keep us informed. You may exercise your personal data protection rights (deletion, access, correction, processing limitation, portability, opposition, etc.), as well as any other request related to this matter, as stipulated in the section "Rights of Interested Parties" in this Privacy Policy.

10. Link to social networks and website channels

 

This website may offer links to social networks (such as: Facebook, Twitter, YouTube, Instagram, and Flickr) and external websites and channels. Zineuskadi shall not be held liable in any way in relation to these linked sites. Users accessing social networks and external web channels and sites, related to Zineuskadi, from the links located on this website, or in any other way, are hereby expressly informed beforehand that the terms of use, privacy policies, cookie policies and any other conditions or regulations depend on the entities responsible for said social networks and web channels and sites, and never on Zineuskadi.

11. Zineuskadi's presence on social and professional networks

 

Zineuskadi may have profiles on social and professional networks, with the main purpose of sharing its services and activities. The posts offered through these channels are for guidance purposes.

When users register on Zineuskadi's profiles with their professional or social network profile, they grant express consent to Zineuskadi to process their personal data pursuant to this Privacy Policy.

Information and personal data voluntarily provided by users through Zineuskadi's social or professional networks can be processed for the purpose of contacting the user and responding to consultations and requests sent by said user, sending informative and sales communications, managing events, invitations, and similar activities, learning the user's opinion or rating of Zineuskadi and its publications, and, in general, managing its presence on social and professional networks.

Users are hereby informed that information and contents (data, texts, videos, sound, photographs, blueprints, graphics, comments, messages, or other material) published through Zineuskadi's social networks (including, if applicable, personal data) may be made publicly available to other users of these social and professional networks, and me be visible, commented on, and freely shared by visitors, under the terms set forth by the social or professional network.

By going to the user profile settings for each social or professional network, the user can configure which information they wish to make public in each circumstance, see permissions granted, eliminate or deactivate them, and manage publications based on their criteria and rules for use of each social or professional network.

Users shall be the sole party liable for their posts following laws in force, rules of use, and privacy policies established by the social or professional network in question and by Zineuskadi, who shall not be held liable in any way for posts made by each user. Zineuskadi shall unilaterally delete content without prior notice that it deems breaches established laws in force, rules of use, and privacy policies, or that it deems unsuitable.

Zineuskadi may follow other profiles on Twitter, Facebook, and other social or professional networks, this not entailing any relationship of any kind with them.

In turn, Zineuskadi's channels on Twitter, Facebook, and other social or professional networks may be followed by other users of these networks, this not entailing any kind of relationship with them.

Zineuskadi reserves the right to not respond to messages or comments received through these channels. Zineuskadi may modify or delete posts issued on its social networks at any time and without prior notice.

When you become a follower or click "Like" (or similar) on social or professional networks, you consent to having your personal data processed within the setting of the social or professional network in question, pursuant to its privacy policies, Zineuskadi's access to data contained on contact lists, and for its posts, expressly including its commercial posts, to appear in your feeds and notifications.

If the user wishes to cease following Zineuskadi's official social or professional network channels, they must do so by using the tools set forth to this end by each network.

12. Security measures

 

Zineuskadi shall process the personal data contained in its data processing with the technical and organisational measures necessary to guarantee security and prevent them from being altered, lost, processed or accessed without authorisation, bearing in mind the state of technology, the kind of data stored, and the risks to which they are exposed, either from human action or from the physical or natural environment, pursuant to current law applicable to security measures for processing data that contains personal information. However, users are hereby informed that IT security measures are not impregnable and possible illegal and improper intrusions are possible, for which the Data Controller would not be liable.

In order to guarantee the security and privacy of the user, this website uses encryption technology based on secure connection layer protocols (https), making browsing as safe as possible.

13. Security breaches

 

Users must immediately inform Zineuskadi of any incident, security breach, and inappropriate or unauthorised access detected in relation to the website, private areas, login passwords, presence on social networks, or any other circumstance that jeopardises the security and confidentiality of information or proper website operation.

Preferred reporting methods are the telephone number +34 943 287 406 and the email address info@zineuskadi.eu

 

14. Storage period

 

Personal data provided shall be stored for the period necessary to fulfil the purpose for which they were collected, determine possible liabilities that could stem from this purpose, or for the period that applicable regulations establish in each case (accounting, tax, commercial, etc.), after which the data shall be deleted, using necessary security measures to guarantee confidentiality.

15. Rights of interested parties

 

You may exercise rights related to the protection of your personal data (access, correction, deletion, processing limitation, portability, and opposition), and withdraw consent granted or make any other request on this matter by addressing Zineuskadi in writing, at Tabakalera, 3ª planta. Plaza de las cigarreras,1. 20012 Donostia / San Sebastián (Spain), or at the email address info@zineuskadi.eu.

 

The request must have an attached copy of the document proving the requester's identity. If an individual acting as legal representative makes the request, in addition to the copy of the document proving the requesting party's identity, a document proving this power of attorney must be attached.

The control authority whom you may address if you disagree with the resolution of the requests, or to file a complaint, is the Spanish Data Protection Agency: www.aepd.es

16. Validity and modifications

 

The Data Controller reserves the right to modify their privacy policy at its discretion, based on legislative or judicial changes. If the Data Controller makes any modification, the new text shall be posted on this same website, where the user can see it. In any event, the relationship with users shall be governed by the regulations in force at the exact time the website is accessed. For this reason, the Data Controller recommends that you visit this privacy policy every time you connect to the website.

17. Jurisdiction

 

The relations established between Zineuskadi and the User shall be governed by stipulations in governing regulations on applicable legislation and jurisdiction. Notwithstanding, in cases where regulations stipulate the possibility of parties submitting to one certain jurisdiction, Zineuskadi and the user, expressly waiving any other jurisdiction that may be applicable to them, submit to the Courts and Tribunals of Donostia San Sebastian (Gipuzkoa).

Zineuskadi shall take action against breach of this Privacy Policy, as well as any inappropriate use of the contents on this website, with all civil and criminal actions applicable per the law, including those of an economic nature.

18. Language applicable to the Privacy Policy

The languages applicable to the Privacy Policy are Spanish and Basque. If versions are provided in other languages, such as English, this is merely out of courtesy and for the user's greater convenience. In the event of contradiction, the Spanish and Basque versions shall prevail.