PRIVACY POLICY

“Fellowship Barcelona” is deeply committed to compliance with Spanish and European regulations regarding the protection of personal data and guarantees the full compliance with the obligations established, as well as the implementation of the security measures provided in the General Data Protection Regulation (GDPR) (EU) 2016/679, of April 27, and in Organic Law 3/2018, of December 5, on the Protection of Personal Data and Guarantee of Digital Rights (LOPD and GDD, hereinafter LOPD).

In accordance with these regulations, we inform you that the use of our website may require the provision of certain personal data through contact forms or by sending emails, and these will be subject to processing by “Fellowship Barcelona,” the Data Controller, whose details are as follows:

Legal Name: Barcelona Shoulder Fellowship, S.C.P. Tax ID: J02900280 Registered Address: C/Gaudí, 44, 2nd, 2nd – 08243, Manresa, Barcelona, Spain Phone: 606 708 653 Email: info@fellowshipbarcelona.com

Collection and Processing of Personal Data

Personal data refers to any information related to an individual, such as name, email, address, phone number, ID number… Additionally, when a user visits our website, certain information is automatically stored for technical reasons, such as the IP address assigned by their Internet service provider.

“Fellowship Barcelona,” as the Data Controller, is responsible for informing users of its website about the collection of personal data that may be carried out, either by sending emails or by completing the forms on the website.

Only the necessary data will be obtained to provide the contracted service or to respond adequately to the information request made by the user. The collected data are identifying and represent a reasonable minimum to carry out the activity. In particular, no highly protected data will be collected at any time. Under no circumstances will the data be used for purposes other than those for which they were collected.

Contact forms/email

Purpose: Responding to your information request made through our contact form(s).

Legitimacy: The legal basis for this processing is the user’s consent, which can be revoked at any time.

Data transfer: Personal data will be processed through servers managed by Its Development Solutions Provider, S.L., which will be considered a Data Processor.

Newsletter signup forms

Purpose: Sending communications, some of which may be commercial, of interest to users based on the website’s theme. As stated in the LSSICE, “Fellowship Barcelona” commits not to send commercial communications without identifying them as such. For this purpose, information sent to customers to maintain an existing contractual relationship will not be considered a commercial communication.

Legitimacy: The legal basis for this processing is the user’s consent, which can be revoked at any time.

Data transfer: Personal data will be processed through servers managed by Mailchimp, which will be considered a Data Processor.

Minors

Only individuals over the age of 14 can provide personal data on this website. In accordance with the LOPD and GDD, in the case of individuals under 14 years of age, the consent of their parents or legal guardians is mandatory for the processing of their personal data.

Furthermore, only individuals over 18 years of age can use our services. In the case of individuals under 18, the consent of their parents or legal guardians is mandatory to use the services offered, unless the minor is emancipated.

Security Measures

Users of the “Fellowship Barcelona” website are informed that security measures, both technical and organizational, have been implemented to prevent the loss, misuse, alteration, unauthorized access, and theft of data, ensuring the confidentiality, integrity, and quality of the information contained therein, in accordance with the current data protection regulations. Personal data collected in the forms are processed only by “Fellowship Barcelona” staff or by appointed Data Processors.

The “Fellowship Barcelona” website also has SSL encryption, which allows users to securely send their personal data through the contact or registration forms on the website.

Data Accuracy

The user declares that all data provided by them are true and correct and agrees to keep them up to date. The user is responsible for the accuracy of their data and will be solely responsible for any conflicts or disputes that may arise due to the falsity of the data. To keep personal data updated, the user should inform “Fellowship Barcelona” whenever any changes occur.

Data Transfer

“Fellowship Barcelona” will not transfer or disclose your data to any third party, except as required by law or when strictly necessary for the provision of a service. Specifically, data may be transferred to:

Providers of technological or IT services Payment service providers Courier and parcel companies Third parties or intermediaries, as service providers, operating on our behalf (management, consultancy, etc.).

Data transfers will be carried out with the utmost confidentiality, using the necessary measures, such as signing confidentiality contracts or adhering to their privacy policies published on their respective websites. The user may refuse to transfer their data to Data Processors through a written request, using any of the means mentioned above.

In addition, in cases where necessary, customer data may be transferred to certain bodies in compliance with a legal obligation, such as the Spanish Tax Agency, Labor Inspection, etc.

User’s Rights

The LOPD and the GDPR grant individuals the possibility to exercise a series of rights related to the processing of their personal data. To do so, the user must submit a request, along with documentation proving their identity (ID card or passport), by email to info@fellowshipbarcelona.com or by written communication to the address listed in our Legal Notice. This communication should include the following information: the user’s name and surname, the purpose of the request, their address, and supporting data.

The following rights may be exercised by the user:

Right to request access to personal data, which is the right to obtain information about whether their personal data is being processed, the purpose of the processing, the origin of the data, and the communications made or planned for such data. Right to request rectification, if personal data is incorrect or inaccurate, or deletion of data that is inappropriate or excessive. Right to request restriction of processing, in which case “Fellowship Barcelona” will only keep the data necessary for the exercise or defense of claims. Right to object to processing: this refers to the right of the data subject to prevent the processing of their personal data or to stop it in cases where their consent is not required for the processing, or when it concerns commercial prospecting files or decisions regarding the data subject and is based solely on automated processing of their data, unless there are legitimate reasons for continuing the processing, or for the exercise or defense of possible claims. Right to data portability: if you wish to have your data processed by another company, “Fellowship Barcelona” will provide you with your data in an exportable format.

If consent has been given for a specific purpose, the user has the right to withdraw their consent at any time without affecting the lawfulness of the processing based on the consent prior to its withdrawal.

We commit to execute all of these rights within the maximum legal deadline (1 month).

If a user believes that there is a problem with how “Fellowship Barcelona” is handling their data, they can address their complaints to the Data Protection Officer or the relevant data protection authority, with the Spanish Data Protection Agency being the relevant authority in Spain.

Data Retention

The personal data of users who use the contact form or send us an email requesting information will be processed for the time strictly necessary to respond to the information request or until the consent granted is revoked.

The personal data of customers will be processed until the contractual relationship ends. The retention period for personal data will be kept to a minimum and may be maintained for the following periods:

4 years: Law on Social Order Infringements and Sanctions (affiliation, enrollments, cancellations, contributions, wage payments, etc.); Arts. 66 and following of the General Tax Law (accounting records, etc.). 5 years: Art. 1964 Civil Code (personal actions without a special term). 6 years: Art. 30 Commercial Code (accounting records, invoices, etc.). 10 years: Art. 25 Money Laundering and Terrorism Financing Prevention Law. Indefinite: disaggregated and anonymized data.

For users who subscribe to the newsletter, their data will be retained indefinitely until the granted consent is revoked.

In the case of data processing of candidates (CV), “Fellowship Barcelona” may keep their curriculum vitae for a maximum of two years for future job openings, unless the candidate expresses otherwise.

Social Media

“Fellowship Barcelona” has profiles on some of the major social media platforms on the internet (Instagram, Twitter), and, in all cases, “Fellowship Barcelona” is recognized as the Data Controller for the data of its followers, fans, subscribers, commentators, and other user profiles (hereinafter, followers) published by “Fellowship Barcelona.”

The purpose of data processing by “Fellowship Barcelona,” where the law does not prohibit it, is to inform its followers about its activities and offers through any means permitted by the social media, as well as to provide personalized customer service. The legal basis for this processing is the consent of the interested party, which can be revoked at any time.

In no case will “Fellowship Barcelona” extract data from social media unless the user has given express and specific consent for this (e.g., for a contest).

International Data Transfers

“Fellowship Barcelona” uses the electronic communication services of the company Mailchimp, which is located in the United States. Standard contractual clauses approved by the European Commission have been signed with this entity to ensure the adequate level of protection in the processing of your personal data, in accordance with the criteria established by the GDPR.

By accepting this privacy policy, the user expressly and unequivocally consents to the international transfer of their data to this/such service provider/s.

Personnel Selection

Candidates who send electronic communications to “Fellowship Barcelona” with the aim of participating in the selection processes of the Data Controller authorize us to analyze the documents sent (e.g., CV), all content that is directly accessible through Internet search engines (e.g., Google), professional social media profiles (e.g., LinkedIn), data obtained in access tests, and information disclosed in job interviews in order to evaluate their application and, if applicable, offer them a job. If the candidate is not selected, “Fellowship Barcelona” may keep their CV for a maximum of two years, unless the candidate indicates otherwise. The legal basis for this processing is the consent of the interested party, which can be revoked at any time.

Confidentiality

The information provided by the user will always be considered confidential and cannot be used for purposes other than those described here. “Fellowship Barcelona” commits not to disclose or reveal information about the user’s intentions, the reasons for the requested advice, or the duration of their relationship with us.

Validity

This privacy and data protection policy was drafted by ExpertosLOPD®, a data protection company, on November 16, 2022, and may change depending on changes in regulations and jurisprudence. It is the responsibility of the data subject to read the updated document to understand their rights and obligations at any given time.