Data Protection Policy

INICIATIVAS INNOVADORAS, S.A.L. with CIF A-31679806, with address in C/ Zabalgaina nº 3 -1º Oficinas 4/5 31.180 Zizur Mayor (Navarra), telephone: +34 948 281 270 and e-mail address: info@iniciativas-innovadoras.es – presano@intiasa.es

INICIATIVAS INNOVADORAS processes the personal information that the user provides directly to us.

In general, we will process identifying data (such as name, e-mail or IP address).

The user guarantees the authenticity, accuracy and truthfulness of all information provided, undertaking to keep personal data updated so that they respond, at all times, to their actual situation. The user will be solely responsible for false or inaccurate statements and the damages that they may cause.

The data you provide may be used for one or more of the purposes indicated below, which will be determined by factors such as your relationship with INICIATIVAS INNOVADORAS or by the means used to send the data. Below, we set out the processing referred to in this policy, without prejudice to the fact that there may be others for which you will be informed or asked for the appropriate authorization:

1. Compliance with legal obligations
   It may be necessary to process personal data in order to comply with applicable legal requirements. In particular, in order to comply with data protection, tax, statistical, insurance, etc. legislation.
2. Communication-contact
   We use the information you send us by e-mail to answer your request.
3. Sending of commercial communications by any means in case of additional consent.
   If you explicitly consent, your data may be transferred to our partners in order to inform you by any means for promotional and advertising purposes of this project.

We collect your personal information through different means, but you will always be informed at the time of collection through informative clauses about the person responsible for the processing, the purpose, as well as how you can exercise your rights regarding data protection and where to find additional information about the processing of your data.

In general, the personal information we process is limited to identifying information (name, e-mail and IP address).

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Depending on the relationship we have and therefore the purpose of the processing, the legal basis may be different. Below, we set out the different applicable bases depending on the processing carried out:

• LEGITIMATE INTEREST: Among others, for profiling, quality or opinion surveys, web maintenance, telephone service, or contact to maintain professional relationships under the terms of art. 19 LOPDGDD.
• LEGAL OBLIGATION: For compliance with the obligations established in any other applicable regulation.
• CONSENT: When you provide us with your data, you should know that in those processing operations in which you are asked to give your consent, its non-granting or eventual withdrawal at a later date will not have negative consequences for you.

In the event that third party data is provided, you declare that you have the consent of the owners of such data for the aforementioned communication of data or, if applicable, that you are their legal representative, exempting INICIATIVAS INNOVADORAS and the rest of its partners from any liability.

The categories of data processed are

• Contact: identification data (name, email and IP address).
• Commercial communications-newsletter: identification data (email).

Depending on the services we provide, your personal data may be communicated to third parties, such communication being necessary for the proper fulfillment of legal obligations and / or contractual. These providers will not process your data for their own purposes that have not been previously informed by INICIATIVAS INNOVADORAS.

In those cases where, for better management and provision of services, access to data is provided by third parties, INICIATIVAS INNOVADORAS guarantees the maintenance of confidentiality in the processing of personal data. In any case, these transfers will be duly notified to the user, detailing the identity of the Transferee and the purpose of the transfer.

These rights are characterized by the following:

• Its exercise is free of charge, except in the case of manifestly unfounded or excessive requests (e.g. repetitive nature), in which case INICIATIVAS INNOVADORAS may charge a fee proportional to the administrative costs incurred or refuse to act.
• You may exercise your rights directly or through your legal representative or volunteer.
• We must respond to your request within one month, although, taking into account the complexity and number of requests, the deadline may be extended by another two months.
• We are required to inform you of the means to exercise these rights, which must be accessible and we may not deny you the exercise of the right solely because you choose another means. If the request is submitted electronically, the information will be provided electronically whenever possible, unless you ask us to do otherwise.
• If INICIATIVAS INNOVADORAS does not act on the request, it will inform you, within one month at the latest, of the reasons for its failure to act and the possibility of complaining to a Control Authority.

In order to facilitate their exercise, we provide links to the application form for each of the rights:

• Form to exercise the right of access
• Form for exercising the right of rectification
• Form for exercising the right to object
• Form for exercising the right of deletion (“right to be forgotten”)
• Form for exercising the right to limit the processing of personal data
• Form for exercising the right to portability
• Form of exercise of the right not to be subject to automated individual decisions

IN INICIATIVAS INNOVADORAS is committed to protecting your personal information. We use physical, organizational and technological measures, controls and procedures, reasonably reliable and effective, aimed at preserving the integrity and security of your data and ensure your privacy.

In addition, all personnel with access to personal data have been trained and are aware of their obligations in relation to the processing of your personal data.

All these security measures are reviewed periodically to ensure their adequacy and effectiveness.

However, absolute security cannot be guaranteed and no security system is impenetrable, so in the event that any information under our control and under our control is compromised as a result of a security breach, we will take appropriate steps to investigate the incident, notify the Control Authority and, where appropriate, those users who may have been affected to take appropriate action.

INICIATIVAS INNOVADORAS informs you that it complies with Law 34/2002 of July 11, 2002, of Services of the Information Society and Electronic Commerce and does not engage in SPAM practices, and therefore will request your consent to the processing of your email or cell phone for commercial purposes at all times.

INICIATIVAS INNOVADORAS reserves the right to modify its privacy policy or conditions of use of its services for reasons of adaptation to current legislation, or other reasons, when this occurs, we will notify you of any changes and ask you to re-read the latest version of our policy and if necessary to confirm your acceptance. The absolute confidentiality and privacy of the personal data collected is assured and therefore security measures have been adopted in order to avoid alteration, loss, treatment or unauthorized access, and thus guarantee its integrity, availability and security. However, INICIATIVAS INNOVADORAS shall not be liable for any incidents that may arise in relation to personal data when these are derived: either from an attack or unauthorized access to the systems in such a way that it is impossible to detect or prevent it even if measures are adopted according to the current state of technology.