Privacy Policy

Through this Privacy Policy, Fundación Telefónica notifies website users that their personal data will be processed in accordance with the principles of transparency, purpose limitation, data minimisation, accuracy, completeness and confidentiality, as well as respecting the other obligations and guarantees established in 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 personal data processing and the free movement of such data, as in Organic Law 3/2018, of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights.

Users’ personal data will be collected, depending on each case, either through this website or through personal data collection forms. Fundación Telefónica informs you, as a user of this website, of the following aspects regarding your right to the protection of personal data in order to comply with the aforementioned regulations and to help you, as a user of this website, to understand how your personal data is collected, used, processed and protected.

WHO PROCESSES YOUR DATA? DATA CONTROLLER

This website and the corresponding forms for collecting your personal data, within the framework of enlightED, will be processed by Fundación Telefónica, a company with tax identification number G-82086810 and registered in the Register of Cultural Foundations of State Competence, of the Protectorate of Foundations of the Ministry of Education and Culture, under number 359. Its registered office is at calle Gran Vía nº 28, 7ª planta (C.P. 28013), Madrid.

WHAT IS PERSONAL DATA AND WHAT DATA DO WE PROCESS?

Personal data is any information relating to an identified or identifiable natural person. In this regard, an identifiable natural person is understood as any person who can be identified, directly or indirectly, by an identifier such as a name, an identification number, location data, an online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Fundación Telefónica processes the personal information provided by users of this website, through specific forms, for different purposes, related to the interest of such users to receive information on the activities carried out by Fundación Telefónica (as in the case of enlightED), or the management of their attendance and participation in the aforementioned event. On the basis of the principle of minimisation, the data that we may process will be adequate, relevant and limited to what is necessary for the purposes for which they are processed, and always respecting your wishes as a user.

The data that Fundación Telefónica will be able to process, within the framework of this website and enlightED, will refer to:

• Identifying data, such as name, surname, e-mail address and, in some cases, postal address or mobile phone number.
• Images of the user (photographs or audio-visual recording) captured by Fundación Telefónica, in the event that the user attends enlightED in person.
• Visiting and browsing data, obtained through the device with which you access this website by means of cookies, as described in the following link.

However, prior to the processing of your data by Fundación Telefónica, you will be informed of the specific categories of data and the specific privacy conditions that will be applicable, and your consent will be sought, if necessary, in accordance with the applicable regulations.

WHY DO WE PROCESS YOUR DATA?

At Fundación Telefónica we process your personal data solely for the purposes for which you authorise us, in accordance with the terms set out in this Privacy Policy or in the corresponding specific conditions, which will be communicated to you as appropriate, and you will be duly informed at the time of collection of said data.

As a user and data subject, you are solely responsible for all information you provide to us, ensuring that you are entitled to and have obtained the consent required for its provision. In any case, Fundación Telefónica accepts no responsibility for the use of false, inaccurate, incomplete or out-of-date data provided by a user.

Under no circumstances will automated decisions be taken on the basis of your personal data, nor will they be processed for profiling purposes.

WHAT IS THE LEGAL BASIS FOR THE PROCESSING?

The legal basis for the processing of your personal data by Fundación Telefónica will be duly detailed in the specific conditions that govern in each case, with a distinction being made between three cases:

• Express consent: you will be able to provide, normally by means of a form, the specific data requested by Fundación Telefónica, which will be strictly necessary for the purpose for which they are collected. Prior to granting such consent, you will be informed of the identity of the data controller, its purpose, legal basis, rights that you may exercise, possible transfers to third parties, storage periods for such data, as well as whether there will be, where appropriate, international transfers. Your personal data will only be processed in accordance with the specific purpose for which they were collected.

You may withdraw your consent to such processing in accordance with the provisions of the “Exercise of Rights” section of this Privacy Policy.

• Legitimate interest: this assumption constitutes a legitimate basis for processing, provided that this interest has been adequately weighed, in advance, by Fundación Telefónica. The right to object to processing operations based on this legitimate basis may be exercised by sending the relevant notification to the addresses listed in the “Exercise of Rights” section of this Privacy Policy.
• Compliance with a legal obligation applicable to Fundación Telefónica, in its capacity as data controller.

HOW LONG WILL WE KEEP YOUR PERSONAL DATA?

Fundación Telefónica notifies that, in compliance with the principle of limitation of the storage period, the data will be processed only and exclusively for the time necessary and for the purposes for which they have been collected at any given time. They will therefore be kept in such a way as to permit the identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.

Once the time periods foreseen in each case have elapsed, the data may be destroyed, blocked or anonymised, as appropriate, and in accordance with the provisions of the applicable legislation.

If deletion is requested, the data will be kept blocked for the necessary time, limiting its processing, only for one of the following reasons: to comply with legal/contractual obligations of any kind to which we are subject and/or during the legal periods foreseen for the prescription of any responsibilities on our part, and/or the exercise or defence of claims arising from the relationship maintained with the owner of the data. 

EXERCISE OF RIGHTS

Fundación Telefónica notifies users that they have the following rights, which may be exercised against it, in accordance with applicable legislation:

• Access: allows the owner of the data to obtain information on whether Fundación Telefónica processes personal data concerning him/her and, if so, the right to obtain information on his/her personal data subject to processing.
• Rectification: this allows errors to be corrected and data that is inaccurate or incomplete to be modified.
• Deletion: this allows data to be deleted and no longer processed by the Fundación Telefónica, unless there is a legal obligation to keep it and/or other legitimate reasons for its processing do not prevail.
• Limitation: under the legally established conditions, this allows the processing of data to be stopped in such a way as to prevent future processing by the Fundación Telefónica, which will only keep the data for the exercise or defence of possible claims.
• Opposition: in certain circumstances and for reasons related to their particular situation, data subjects may oppose the processing of their data. Fundación Telefónica will cease to process the data, except for compelling legitimate reasons, or for the exercise or defence of possible claims.
• Portability: this allows the data subject to receive the personal data concerning him/her that he/she has provided to Fundación Telefónica, and to be able to transmit it directly to another data controller in a structured, commonly used and machine-readable format. A valid e-mail address must be provided by the requester in order to exercise this right.
• Revoke the consent previously granted to Fundación Telefónica.

Fundación Telefónica guarantees to adopt the necessary measures to ensure the exercise of these rights free of charge.

You, as a user, may exercise the aforementioned rights in two ways, always indicating in the request which right you are exercising and, at least, your e-mail address and minimum personal data for your identification (name and surname), the processing of which you have consented to Fundación Telefónica processing:

• By post, addressed to Fundación Telefónica, FTO: Head of Privacy, calle Gran Vía nº 28 (C.P. 28013), Madrid (Spain)
• By e-mail, by writing to the address rgpd@fundaciontelefonica.com

As established by current legislation, the exercise of these rights will be dealt with by Fundación Telefónica within a maximum period of one month. However, depending on the complexity of the request, the full implementation of certain rights may require a longer period, which in no case will exceed an additional two months.

In addition, if you have not received a satisfactory response in exercising your rights, you can also file a complaint with the Spanish Data Protection Agency:

Spanish Data Protection Agency

C/ Jorge Juan, 6 – 28001 Madrid, Spain

Phones numbers: (+34) 901 100 099 / (+34) 91 266 35 17

www.aepd.es

WHO WILL MY DATA BE SHARED WITH?

 Unless otherwise indicated in the specific information that Fundación Telefónica provides to a user, prior to the collection of their personal data, such data will not be transferred to third parties and, under no circumstances, will international transfers take place.

All of the above except in those cases in which such communication of data is obligatory in application of current legislation.

On the other hand, and in order to comply with the processing purposes described in each case, Fundación Telefónica may facilitate the processing of your personal data by third parties, as service providers (for example, to make audio-visual recordings, manage access control to the enlightED facilities, etc.). In such cases, Fundación Telefónica guarantees the observance and fulfilment of the strictest criteria for the selection of such service providers, in order to comply with its obligations in terms of data protection, and subscribes to this end the applicable data protection agreements.

SECURITY AND CONFIDENTIALITY WHEN PROCESSING YOUR PERSONAL DATA

Fundación Telefónica is committed to guaranteeing the security, secrecy and confidentiality of your data, communications and personal information. Therefore, as part of our commitment and in compliance with current legislation, we have adopted the most appropriate security measures and technical means to prevent their loss, misuse or unauthorised access.

When we receive personal data, we use rigorous procedures and security features to prevent unauthorised access. Thus, Fundación Telefónica has adopted the appropriate technical and organisational measures in its information system, complying with the principle of proactive responsibility and privacy by design, in order to guarantee the security and confidentiality of the data stored, and thus prevent their alteration, loss, unauthorised processing or access. All the above considering the current state of technology, the costs of implementation, and the nature, scope, context and purposes of the processing, as well as risks of varying likelihood and severity associated with each of the processing operations.

COOKIES

This website, like other Internet portals, uses a technology called “cookies” to collect information about users’ interactions and how they use this site.

If you wish to obtain detailed information on how Fundación Telefónica uses cookies, you can consult the Cookies Policy here.

DATA PROCESSING OF MINORS

Fundación Telefónica expressly prohibits users under the age of 16 from providing their personal data without the prior consent of their parents, guardians or legal representatives.

In the event that a user consents to the processing of personal data of a minor under 16 years of age, as the person responsible for the same, he/she shall be responsible for authorising and deciding before Fundación Telefónica on the processing of the data of the same in the terms set out in this Policy.

If the parents, guardians or legal representatives of these minors detect unauthorised data processing, they may submit their queries or complaints by writing to rgpd@fundaciontelefonica.com.

CHANGES TO THE PRIVACY POLICY

Fundación Telefónica may update this Privacy Policy at any time. Any such update will be made public by Fundación Telefónica in any case, and will be communicated directly to each user in the event that it affects their rights or freedoms. For example, the inclusion of a new processing operation that requires the consent of the data subject will be made public, given that such consent must be explicitly accepted, and users will be directly notified of the amendment to the scope of the legitimate interest affecting the processing of their data.

MISCELLANEOUS

The conditions set forth herein constitute the Privacy Policy of Fundación Telefónica within the framework of the enlightED event, and are also formed both by this document and the specific privacy conditions that may be applicable in each case. In this same section of this website, “Privacy Policy”, you can consult the specific conditions of the different cases and purposes for which Fundación Telefónica, with your prior consent, may request the collection of your personal data, always within the framework of enlightED.

In the event that any of the provisions of this Privacy Policy, or any part thereof, is declared illegal, invalid or inapplicable by a competent administrative or judicial body, it shall be deemed not to have been applied, without affecting the other provisions.

The user is informed below of the aspects applicable to each of the forms or tools through which personal data may be provided, and the specific conditions relating to each case: