Privacy Policy*

This Privacy Policy (hereinafter, the “PRIVACY POLICY”) governs, in general, the collection and treatment by ELHUYAR FUNDAZIOA (hereinafter, the “ENTITY”) of (i) the personal data that you provide us with as a user of the website accessible via the domain name hiztegiak.elhuyar.eus (hereinafter, the “WEBSITE”), including the services that are available at any time through the WEBSITE; and (ii) other data collected through other collection systems duly identified below. All of the foregoing is without prejudice to the specific provisions established in certain sections, forms or services available on the WEBSITE in order to provide you with the relevant information and, where appropriate, obtain your consent.

The ENTITY reserves the right to modify the PRIVACY POLICY to adapt it to legislative, jurisprudential and/or administrative changes as well as to all practices developed through the WEBSITE, taking into account your rights and interests at all times.

In any case, the ENTITY will provide you with the appropriate technical resources so that you can access the PRIVACY POLICY, in our compliance with information obligations in accordance with the applicable regulations on data protection.

1. Who is your Data Controller?

The Data Controller is ELHUYAR FUNDAZIOA, an entity domiciled in Usurbil (Gipuzkoa), Zelai Haundi, 3, Polígono industrial Osinalde, registered in the Mercantile Registry of Gipuzkoa in volume 1.972, folio 69, page SS-21.026, and with CIF No. B-20779161.

For any questions related to the PRIVACY POLICY or to the treatment of your personal data, you can contact us at the postal address indicated above or via the email address datuensegurtasuna@elhuyar.eus

2. How have we obtained your data?

The data that we process at the ENTITY have been obtained from you through (i) the different forms that you fill out whilst navigating the WEBSITE or through other channels (e.g. registration as a WEBSITE user - if applicable -, contact forms, registration forms for contests, events or activities organised by the ENTITY, etc.); (ii) by sending an email enquiry.

In the event that the personal data provided belongs to a third party, you guarantee that you have informed said third party of the PRIVACY POLICY and have obtained their authorisation to provide their data to the ENTITY for the purposes indicated below.

Additionally, we inform you of the possible processing of your social network data through the corporate profiles of the ENTITY on each social network in which it is present, under the terms and conditions established in each social network.

3. What type of data do we process?

The data processed by the ENTITY are those provided by you whilst navigating the WEBSITE, through the relevant forms that we use to enter into contact with you, or through email, as well as data that, if applicable, we obtain through the ENTITY’s corporate profiles on the social networks in which we are present.

The ENTITY processes the following type of data in particular:

• Identification and contact details (e.g. name, surname, ID number, postal address and email address, telephone).
• Bank and economic transaction details.
• Identification keys and codes as a registered user of the WEBSITE
• Internet browsing data (e.g. IP address, visits to web pages, connections to Wi-Fi networks, etc.)
• Images captured in relation to contests, events or activities organised by the ENTITY.

4. Why do we process your data and on what legitimate grounds?

We process your personal data for the following purposes:

• To manage and process your WEBSITE user registration, where possible.
• To manage your access and use of the contents and services made available to you by the ENTITY through the WEBSITE, including blog services, social networks and any other features that are accessible via the WEBSITE.
• To process and manage the purchase of any of the ENTITY’S products or services that you may make through the WEBSITE, the delivery of said products and, in general, to maintain, manage and control the contractual relationship that you establish with us as the purchaser of our products or services.
• To process and manage any requests for information, suggestions, complaints or claims that you make via the WEBSITE or email address.
• To send you by different means, including electronic, commercial and advertising communications related to the ENTITY and other entities of the business group to which it belongs (duly indicated on the website www.elhuyar.eus, regarding products, services, offers, promotions and any other relevant information regarding said entities, provided that you have consented to it.
• To manage your subscription to the newsletter or similar services, as well as the sending of the corresponding electronic communications, provided that you have consented to it.
• To manage your participation in contests, activities and events organised by the ENTITY for which you voluntarily register.
• Where you have given your consent, to manage and disseminate information about the contests, activities and events organised by the ENTITY.

The processing of your personal data by the ENTITY, in accordance with the applicable regulations, is based (i) on your consent, granted at the time of collecting the personal data that you voluntarily provide us with via the systems provided for this purpose on the WEBSITE; (ii) on the relationship established with us if you contract our products or services; or (iii) on the legitimate interest of the ENTITY.

Where the processing of your data is based on your consent, you may at any time revoke it freely, and free of charge, under the terms indicated in Section 7 below.

5. To whom do we disclose your data?

We inform you that your personal data may be communicated to the following third parties:

• Organisations and Public Administrations to which, where appropriate, the ENTITY has a legal obligation to communicate your data.
• If you have given your consent, to other entities within the business group to which the ENTITY belongs (duly indicated on the website www.elhuyar.eus), for the purpose of responding to your requests and enquiries or sending you commercial communications regarding said entities and their respective activities or products.
• If you have given your consent, to client entities or collaborators of the ENTITY, for the adequate dissemination of the contests, events or activities organised together with the ENTITY on their own channels. These entities will be indicated at the time of collecting the data.

We do not envisage any international transfer of your data.

6. How long do we keep your data?

In general, personal data is stored for as long as you do not revoke your consent to its processing or request its deletion, as well as for the time necessary for the ENTITY to comply with the legal obligations.

In any case, we inform you that the ENTITY has established internal data cleaning policies aimed at controlling the retention periods of the personal data in its possession, so that these may be deleted when no longer necessary or suitable for the purpose for which they were obtained.

7. What are your rights?

The applicable regulations on data protection grant you a series of rights related to your personal data that you may exercise during their processing thereof. These rights are as follows:

• To access your data: you have the right to access your data to know what personal data we are processing.
• To request the rectification or erasure of your data: in certain circumstances, you have the right to request rectification of your inaccurate personal data being processed by us, or even to request that we delete them when, among other reasons, said data are no longer required for the purposes they were obtained for.
• To request the restriction of the processing of your data: in certain circumstances you have the right to request the restriction of the processing of your data, in which case we inform you that we will only keep your data for exercising or defending claims as established in the applicable regulations on data protection.
• Data portability: in certain circumstances you have the right to receive the personal data concerning you, and that you have provided us, in a structured, commonly used and machine-readable format, and to transmit them to another data controller.
• To object to the processing of your personal data: in certain circumstances, and on grounds relating to your personal situation, you have the right to object to the processing of your personal data, in which case we would stop processing them except where, for compelling legitimate reasons or for exercising or defending against potential claims, said data must be kept.

You also have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

You may exercise these rights by writing to the ENTITY at the postal address indicated in Section 1 or by sending an email to datuensegurtasuna@elhuyar.eus.

Finally, you may file a claim with the relevant Supervisory Authority (in Spain, the Spanish Data Protection Agency), in particular, when you have failed to obtain satisfaction in the exercise of your rights. You can contact said Authority through its web page: www.aepd.es.

8. Security Measures

The ENTITY will treat your data with strict confidentiality at all times and shall abide by the mandatory duty of secrecy regarding said data, in accordance with the applicable legal provisions on data protection, adopting for said purpose any technical and organisational measures that may be required to guarantee the security of your data and to avoid its alteration, loss, unauthorised processing or access, having due regard to the state of technology, the nature of the stored data and the risks to which they are exposed.

9. Cookies policy

Additionally, we remind you that the ENTITY has established a Cookies Policy which is accessible via the following link.