WEBSITE PRIVACY POLICY

www.fifcyl.com

1. PRIVACY AND DATA PROTECTION POLICY

Respecting the provisions of current legislation, Castilla y León International Photography Festival (hereinafter also referred to as the Website) commits to adopting the necessary technical and organisational measures according to the level of security appropriate to the risk of the data collected.

Laws included in this privacy policy

This privacy policy is adapted to current Spanish and European regulations regarding the protection of personal data online. It specifically adheres to the following regulations:

• 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 the processing of personal data and on the free movement of such data (GDPR).
• Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights (LOPD-GDD).
• Royal Decree 1720/2007 of 21 December, which approves the Regulations for the development of Organic Law 15/1999, of 13 December on the Protection of Personal Data (RDLOPD).
• Law 34/2002, of 11 July, on Services of the Information Society and Electronic Commerce (LSSI-CE).

Identity of the person responsible for the processing of personal data

The party responsible for the processing of personal data collected at Castilla y León International Photography Festival is: Fundación Siglo para el Turismo y Las Artes de Castilla y León, with NIF number: G47463823. Their contact details are as follows:

Address: Avda. Real Valladolid, 2 47015 Valladolid

Telephone: 983213886

Email: fundacion.siglo@jcyl.es

Record of Personal Data

In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by Castilla y León International Photography Festival through the forms provided on its pages will be incorporated into and processed in our file in order to facilitate, expedite and comply with the commitments established between Castilla y León International Photography Festival and the User or the maintenance of the relationship established in the forms that the User completes, or to attend to a request or query from the User. Likewise, in accordance with the provisions of the GDPR and the LOPD-GDD, unless the exception provided for in article 30.5 of the GDPR applies, a record of treatment activities is kept that specifies, according to its purposes, the processing activities carried out and other circumstances established in the GDPR.

Principles applicable to the processing of personal data

The processing of the User’s personal data will be subject to the following principles set forth in article 5 of the GDPR and in article 4 and subsequent articles of Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights:

• Principle of legality, loyalty and transparency: the User’s consent will be required at all times following the provision of completely transparent information of the purposes for which the personal data is collected.
• Purpose limitation principle: personal data will be collected for specific, explicit and legitimate purposes.
• Principle of data minimisation: the personal data collected will only be strictly necessary in relation to the purposes for which they are processed.
• Principle of accuracy: personal data must be accurate and always up to date.
• Principle of limitation of the conservation period: personal data will only be kept in a way that allows the identification of the User for the time necessary for the purposes of its treatment.
• Principle of integrity and confidentiality: personal data will be treated in a way that guarantees its security and confidentiality.
• Principle of proactive responsibility: the Data Controller will be responsible for ensuring that the above principles are met.

Personal data categories

The data categories processed on Castilla y León International Photography Festival are only identifying data. In no case are special personal data categories processed within the meaning of article 9 of the GDPR.

Legal basis for the processing of personal data

The legal basis for the processing of personal data is consent. Castilla y León International Photography Festival commits to obtaining the express and verifiable consent of the User for the processing of their personal data for one or more specific purposes.

The User will have the right to withdraw their consent at any time. It will be as easy to withdraw consent as it is to give it. As a general rule, the withdrawal of consent will not determine the use of the Website.

On the occasions on which the User must or may provide their data through forms to make inquiries, request information or for reasons related to the content of the Website, they will be informed in the event that the completion of any of these is mandatory because they are essential for the correct development of the operation carried out.

Purposes of the processing for which the personal data are destined

Personal data are collected and managed by Castilla y León International Photography Festival in order to facilitate, expedite and fulfil the commitments established between the Website and the User or the maintenance of the relationship established in the forms that the latter completes or to attend to a request or inquiry.

Likewise, the data may be used for the commercial purpose of operational and statistical personalisation and activities of the company purposes of Castilla y León International Photography Festival, as well as for data extraction, storage and marketing studies to adapt the Content offered to the User, as well how to improve the Website’s quality, operation and navigation.

At the time the personal data is obtained, the User will be informed about the specific purpose or purposes of the processing for which the personal data will be used; that is to say, of the use or uses that will be given to the information collected.

Retention periods of personal data

Personal data will only be retained for the minimum time necessary for the purposes of its processing and, in any case, only during the following period: 12 months, or until the User requests its deletion.

When the personal data is obtained, the User will be informed about the period during which the personal data will be kept or, when this is not possible, the criteria used to determine this period.

Recipients of personal data

The User’s personal data will not be shared with third parties.

In all cases, at the time the personal data is obtained, the User will be informed about the recipients or categories of recipients of the personal data.

Personal data of minors

Respecting the provisions of article 8 of the GDPR and article 7 of Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights, only those over 14 years of age may grant their consent for the lawful treatment of their personal data by Castilla y León International Photography Festival. In the case of a child under 14 years of age, the consent of the parents or guardians will be necessary for data processing, and this will only be considered lawful to the extent that they have authorised it.

Confidentiality and security of personal data

Castilla y León International Photography Festival undertakes to adopt the necessary technical and organisational measures, according to the level of security appropriate to the risk of the data collected, in such a way that the security of personal data is guaranteed and accidental destruction, loss or alteration is avoided or illicit personal data transmitted, stored or otherwise processed, or unauthorized communication or access to such data.

However, because Castilla y León International Photography Festival cannot guarantee the impregnability of the internet or the total absence of hackers or others who fraudulently access personal data, the Data Controller undertakes to notify the User without undue delay when a violation of personal data security occurs that is likely to pose a high risk to the rights and freedoms of individuals. Following the provisions of article 4 of the GDPR, a violation of the security of personal data is understood to mean any violation of security that causes the destruction, loss or accidental or illegal alteration of personal data transmitted, stored or otherwise processed, or unauthorised communication or access to said data.

Personal data will be treated as confidential by the person in charge of processing, who undertakes to report on and guarantee through legal or contractual obligation that this confidentiality is respected by their employees, associates, and any person to whom the data is accessible.

Rights derived from the processing of personal data

In regard to Castilla y León International Photography Festival, the User has the rights and may, therefore, exercise the following rights recognised in the GDPR and Organic Law 3/2018, of 5 December on the Protection of Personal Data and guarantee of digital rights:

• Right of access: It is the User’s right to obtain confirmation of whether or not Castilla y León International Photography Festival is processing their personal data and, if so, to obtain information about their specific personal data and the processing that Castilla y León International Photography Festival has carried out or is carrying out, as well as, among other things, about the information available on the origin of this data and the recipients of the communications made or planned thereof.
• Right of rectification: It is the User’s right to modify any personal data that turns out to be inaccurate or, taking into account the purposes of the processing, incomplete.
• Right of erasure (“the right to be forgotten”): It is the User’s right, provided that current legislation does not establish otherwise, to obtain the erasure of their personal data when these are no longer necessary for the purposes for which they were collected or processed; when the User has withdrawn their consent to the processing and this does not have another legal basis; when the User opposes the processing and there is no other legitimate reason to continue with it; when the personal data has been unlawfully processed; when personal data must be deleted in compliance with a legal obligation; or when the personal data has been obtained as a result of a direct offer of services from the information society to a person under 14 years of age. In addition to deleting the data, the Data Controller, taking into account the available technology and the cost of its application, must adopt reasonable measures to inform those who are processing the personal data of the interested party’s request to delete any link to those personal data.
• Right to limitation of processing: It is the User’s right to limit the processing of their personal data. The User has the right to obtain the limitation of processing when they challenge the accuracy of their personal data; when the processing unlawful; when the person Responsible for the processing no longer needs the personal data, but the User needs it to make claims; and when the User opposes the processing.
• Right to data portability: In the event that the processing is carried out by automated means, the User will have the right to receive their personal data in a structured format, of common use and machine readable, from the person in charge of the processing and to transmit these to another person in charge of processing. Whenever technically possible, the Data Controller will directly transmit the data to that other controller.
• Right of opposition: It is the User’s right for their personal data not to be processed or to cease their processing by Castilla y León International Photography Festival.
• Right not to be the subject of a decision based solely on automated processing, including profiling: It is the User’s right not to be the subject of an individualised decision based solely on the automated processing of their personal data, including the creation of profiles, existing unless current legislation establishes otherwise.

Thus, the User may exercise their rights through written communication addressed to the Data Controller with the reference “RGPD- www.fifcyl.com” specifying:

• User’s name, surname and copy of National Identification Card (DNI). In the cases in which representation is admitted, it will also be necessary to identify the person representing the User by the same means, as well as the document proving this representation. A photocopy of the DNI may be replaced by any other legally valid means that proves the User’s identity.
• Request with the specific reasons of the request or information to which access is required.
• Address for notification purposes.
• Applicant’s date and signature.
• Any document that proves the request made.

This request and any other attached documents may be sent to the following address and/or email:

Postal address: Avda. Real Valladolid, 2 47015 Valladolid

Email: fundacion.siglo@jcyl.es

Links to third party websites

The Website may include hyperlinks or links that allow access to web pages of third parties other than Castilla y León International Photography Festival, and that are therefore not operated by Castilla y León International Photography Festival. The owners of these websites will have their own data protection policies, being themselves, in each case, responsible for their own files and their own privacy practices.

Claims before the supervisory authority

In the event that the User considers that there is a problem or violation of current regulations in the way in which their personal data is being processed, they will have the right to effective judicial protection and to file a claim with a control authority, particularly in the State in which they have their habitual residence, place of work or where the alleged offence took place. In the case of Spain, the control authority is the Spanish Agency for Data Protection (http://www.agpd.es).

1. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

It is necessary that the User has read and agreed to the conditions on the protection of personal data contained in this Privacy Policy, as well as that they accept the processing of their personal data so that the person responsible for their processing can proceed to do so in the form, for the periods and for the purposes indicated. The use of the Website will imply the acceptance of its Privacy Policy.

Castilla y León International Photography Festival, reserves the right to modify its Privacy Policy, according to its own criteria, or motivated by a legislative, jurisprudential or doctrinal change of the Spanish Agency for Data Protection. Changes or updates to this Privacy Policy will not be explicitly notified to the User. It is recommended that the User consults this page periodically to be aware of the latest changes or updates.

This Privacy Policy was updated to adapt to 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 the processing of personal data and on the free movement of such data (GDPR) and Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights.