Privacy notice

1.     Introduction

This Notice ("Privacy Notice" or "Notice") contains information on the processing of personal data by ProFuturo Foundation of the Users of its Digital Educational Platform. This Privacy Notice is addressed to Users of the online version of the platform. If you are a User of the offline version, you have the information on the processing of your data in section 7 of this Notice.

 

2.     Who is the Data Controller of your data?

The Data Controller is ProFuturo Foundation, with Tax Identification Number G-87620134, and registered in the Registro de Fundaciones de Competencia Estatal [State Foundations Register] under number 1,856 (hereinafter "ProFuturo").

Postal address: Calle Ronda de la Comunicación s/n, Edificio Norte 3 Planta Baja, 28050 Madrid (Spain).

Contact Privacy Team protecciondedatos@fundacionprofuturo.org

On the other hand, the collaborating entity of ProFuturo ("Partner") associated with the project you are enrolled in will be the joint controller of the processing of data related to the monitoring and management of the training courses in which you participate. You can find the list of Partners, along with their contact information at the following link: Where We Are - ProFuturo.

Both ProFuturo and its Partners have signed the corresponding joint responsibility agreement, which defines the respective responsibilities to comply with Article 26.2 of the GDPR.

You can obtain additional information by sending an email to protecciondedatos@fundacionprofuturo.org.

 

3.     Purpose and basis of legitimacy of the processing

Your data will be processed by ProFuturo, as a Data Controller, for:

  • Management of the contact form on the ProFuturo websites. When the User chooses to use and enter their data in the "contact form" on our web pages, ProFuturo may process this data in order to manage the reported incidents, as well as to respond to the requests sent. The legal basis we rely on to carry out this purpose is the consent given when voluntarily contacting us. The management of requests may be coordinated with the Partner to which the User belongs, meaning the Partner may have access to the data of your request.
  • Sending communications concerning ProFuturo's projects and activities. Provided that you have given your consent, ProFuturo and its Partners will send you communications concerning projects or activities in line with your interests by any telematic means.
  • Anonymisation of data for statistical and behavioural modelling purposes. ProFuturo may carry out anonymization procedures, after which it will no longer be able to identify you. The purpose of these procedures is solely to use the anonymized information for statistical purposes and to develop behavior models based on its legitimate interest as the owner of the Platform, in order to analyze and evaluate its performance and take necessary actions based on the results obtained.
  • Sending out satisfaction surveys. ProFuturo, based on a legitimate interest of the organisation, may send you satisfaction surveys, in order to find out about the experience received as a participant of the training courses or user of our services, and to be able to incorporate the corresponding improvements to our services and operations based on the analysis of the same. In any case, in order to not endanger your data protection rights, you may object to such processing through the channels provided for this purpose.
  • Regulatory compliance. To comply with applicable law, custom and practice, to provide information to appropriate agencies for the purposes of fraud prevention, credit risk reduction, to cooperate with law enforcement and other governmental authorities, or to protect the rights, property or safety of visitors of the Platform or the general public.
  • Control and management of training courses. When User attends and participates in the training courses, ProFuturo may process their data in order to carry out the necessary procedures for the training courses, as well as to keep track of attendance.
  • Management of the educational community. ProFuturo provides its Users with a discussion forum for the entire educational community to facilitate discussion and debate in training activities and to encourage the participation of all its members. The legal basis we rely on for this processing is the execution of the educational activity in which the User is a participant. The Partner may sometimes act as a moderator in these forums and may therefore have access to the information you share through this medium.

If you participate in these forums provided by ProFuturo, you acknowledge and accept that other Users of the Platform may have access to your identification data and profile image.

  • Audit. For audit purposes, to verify that the number of users on the Platform corresponds to unique and truthful Users. The audit may be conducted by an allied entity, in which case we will share the data with that entity to fulfill the same purpose.

 

4.     How long will we keep your data?

ProFuturo will comply with the provisions of current legislation regarding the duty to delete personal information that is no longer necessary for the purpose or purposes for which it was collected, blocking it, in order to deal with possible liabilities arising from the processing of the data, and only during the periods of limitation of such liabilities. Once these deadlines have expired, the information will be permanently deleted by secure means.

On the other hand, we will try to keep the data in our files up to date so that they always correspond to reality. For this purpose, the User must make the changes directly, when so enabled, or by notifying ProFuturo by a reliable means.

 

5.     Who will your data be shared with?

ProFuturo will communicate your data for processing, in the context of the purposes explained above, to the following recipients:

  • Public administration bodies, when it is legally obliged to provide them.
  • Collaborating entities that have been informed. These entities may be located outside the European Economic Area ("EEA") and international transfers of data may occur. These transfers would be made on the basis of the signature with these entities of standard data protection clauses adopted by the European Commission for international transfers.

Likewise, the Partners may have access to your data in order to monitor your activity on the Platform. These entities may communicate your data in the following cases:

·        By appointing their own or external staff to tutor the progress of the courses in which you are enrolled, in order to certify the completion of the corresponding course.

·        Governmental bodies and public administration entities, which may require proof of completion of the corresponding course or where it is necessary to demonstrate such compliance.

On the other hand, in order to carry out all the purposes described above, ProFuturo can count on the collaboration of third-party service providers who may have access to personal data as a consequence of the execution of the contracted services. In any case, ProFuturo follows strict criteria for the selection of these third parties in order to comply with its data protection obligations and signs with them the corresponding data protection agreement, where these third parties are obliged to comply with their data protection obligations, and specifically, to comply with the legal, technical and organisational measures for the processing of personal data for the agreed purposes, and the prohibition of processing such personal data for other purposes or its transfer to third parties.

 

6.     Processing of data of Users of the offline version of the Platform

ProFuturo Foundation is not responsible for the User's Personal Data in the offline version of the Platform. ProFuturo Foundation will not have access to or make any use of this data, stored on devices outside the Foundation.

Notwithstanding the foregoing, collaborating entities may provide such data to ProFuturo Foundation solely for the following purposes:

-         For auditing purposes, to check that the number of users of the Platform corresponds to unique and truthful Users.

-         To resolve technical incidents regarding the offline operation of the Platform, for which ProFuturo Foundation may only access and view the Personal Data that you have provided when registering to the Platform.

Only in these cases, ProFuturo Foundation will make use of your Personal Data, whose responsibility falls to the collaborating entity to which you belong and/or with which you collaborate. ProFuturo Foundation only processes this data on behalf of this entity and assumes no responsibility for them, in the sense given by the GDPR.

 

7.     What are your rights when you provide us with your data?

We inform you that you may exercise the following rights:

  • the right of access to your personal data to know which personal data is being processed and the processing operations carried out on it;
  • the right to rectify any inaccurate personal data;
  • the right to erasure of your personal data, where possible;
  • the right to request the restriction of the processing of your personal data where the accuracy, lawfulness or necessity of the processing is in doubt, in which case we may retain the data for the purpose of pursuing or defending claims;
  • the right to the portability of your personal data, so that they are sent directly to the entity designated by you in a structured, commonly used and machine-readable format.
  • the right to object to the processing of your personal data, where the legal basis is legitimate interest. For these purposes, we will stop processing your data unless we have a compelling legitimate interest or for the formulation, exercise or defence of claims.
  • the right to withdraw your consent at any time.

You may exercise all of the above rights against ProFuturo by sending an e-mail to the following address protecciondedatos@fundacionprofuturo.org

Likewise, if you consider it necessary, you may lodge a complaint with the Spanish Data Protection Agency, at Calle Jorge Juan 6, 28001 Madrid, or at the following web site www.aepd.es.

 

8.     Personal Data security

ProFuturo will adopt appropriate technical and organisational measures in its information system, in compliance with the principle of proactive responsibility, in order to guarantee the security and confidentiality of the data stored, thus avoiding its alteration, loss, unauthorised processing or access; taking into account the state of the art, the costs of implementation, and the nature, scope, context and purposes of the processing, as well as risks of varying probability and severity associated with each of the processing operations.