Introduction:
Fundación Banco Santander,(hereinafter, “FBS”) fully complies with the regulations on the protection of personal data and in particular with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard of the processing of personal data and on the free movement of such data (hereinafter, “GDPR”), and the processing of personal data of the contact persons (hereinafter, the “Data Subject”) of each User using the CreaSus platform (hereinafter, the “User”, “Participant” or “You). These data have been provided by Data Subjects through the Platform of the Creasus Project.
In compliance with the legislation in force, FBS has implemented the appropriate technical and organizational measures to guarantee an adequate level of security, as well as to prevent the loss, misuse, alteration, unauthorized access and theft of the data provided by the Data Subject. FBS guarantees that it complies with its duty of secrecy and confidentiality with respect to the personal data provided by the Data Subject.All the terms not expressly defined herein should have the meaning given in the Terms and Conditions. This CreaSus Platform Privacy Policy should be read together with the CreaSus Platform Terms and Conditions (“Terms and Conditions”) in order to ensure a comprehensive and complete understanding of the project.
The data requested is, in general, mandatory to fulfill the purposes for which it is being collected. Therefore, if the User does not provide them or does not provide them correctly, the User’s requests cannot be met.
The User declares to have been informed of and complies with the conditions on protection of personal data, accepting the content of this Privacy Policy.
Basic information on Data Protection
Data controller
Name: Fundación Banco Santander
Registered office and postal address: Calle Serrano 57, 28006 Madrid.
Contact details of the Data Protection Officer:
privacidadfundacionbs@gruposantander.com
Personal data processed and origin
FBS will process the name and surname; corporate email and telephone number; job position; name, city and country of the company/organization of the contact person of each Participant provided during the registration process or any other form to be filled in (“Personal Data”).
If the Personal Data of the Data Subject are provided by a third person, such third parties should be aware that, prior to the communication of the Personal Data, they are obligated to inform the Data Subject of the processing, specially of the information set out in this Notice. Where appropriate they are obligated to have obtained authorization of the Data Subject and any other requirements that may be applicable for the correct transfer of the personal data to FBS and the processing activities described in this Notice, so that no additional action of FBS is needed in regard to the processing. In this sense the Participant must be able to prove the compliance of such duties upon demand.
Purposes and legal basis
FBS will process the personal data will accordance with the Terms and Conditions and this privacy policy to:
- create a user profile which provides the Participant access to the Platform and the different CreaSus project resources contained in it
- manage the participation of the User within the Project (including the organization of a dissemination session, a launching session of the piloting process and a national event of the project, as well as for sending communications related to the piloting process for all the Participants not included in section “Data Sharing with third parties”.
The legal basis for the processing is the contractual relationship of the Participant with Fundación Banco Santander, which has been created with the registration of the Participant in the Platform and with the acceptance of the Terms and Conditions.
How long will we keep the Personal data?
FBS will process the Personal Data until the end of the CreaSus project on 30th September 2026, and, once it ends, during the limitation period for legal actions arising from the aforementioned request.
FBS will store, duly encrypted, the Personal Data for 10 additional years after the final payment of the grant awarded by the European Education and Culture Executive Agency (“EACEA”). During this period, FBS will not carry out any processing other than storing the data to make it available for the competent public administrations, judges and courts, or the public prosecutor’s office, for any possible liabilities arising from the contractual relationship maintained or related to the data’s processing and demonstrate duty compliance of the project duties agreed with the EACEA, including record-keeping, reviews, audits, extension of findings, and impact evaluation reasons.
Data Sharing with third parties
The Platform is developed and maintained in Spain by Tempesta Media, S.L. (“La Tempesta”), which acts as personal data subprocessor of FBS.
In order to ensure compliance with the data protection obligations, La Tempesta has signed a processing agreement with FBS, binding it to the following obligations: applying appropriate technical and organizational measures to protect data; processing personal data for the purposes agreed and only in accordance with documented instructions from the FBS; and deleting or returning the data to FBS once the services have been provided.
Additionally, in the framework of the Project FBS could perform Personal Data transfers to the other Partners as explained below, always subject on the consent of the Data Subject. In this regard FBS has signed with each Partner the corresponding Data sharing agreement.
The Participant assumes that prior to the communication of the personal data, and guarantees having received the consent of the Data Subject, and it must be able to demonstrate and proof to FBS the obtention of such consent upon:
- Through clicking the corresponding box , the Data Subject gives FBS its express consent to share the name and surname; corporate email and telephone number; job position; name, city and country of the company/organization for the organization of a dissemination session, a launching session of the piloting process and a national event of the project, as well as for sending communications related to the piloting process to the corresponding Partner depending on the registration country of the organization, in accordance with the following table:
| Registration country of participant | Data Receiving Partner |
|---|---|
| Italy | University of Bari, Dipartimento di Economia, Management e Diritto dell’Impresa Largo Abbazia Santa Scolastica 53, Bari, Italy direzione.demdi@pec.uniba.it |
| Greece | Mosaic. Culture and Creativity Ermou 112, 26225, Patras, Greece hello@mosaic-hub.gr |
| Ireland | Westbic 11 Galway Technology Centre Mervue Business & Technology Park Wellpark Road Galway, H91 E2W5 IRELAND info@westbic.ie |
| Other countries | Data not shared |
- In the case of Italian Users, such information can be considered as pseudo-anonymized personal data. Taken in to account the foregoing, if the Data Subject of an Italian Participant clicking the corresponding box, it gives FBS consent to share with the University of Bari the city and country of the organization to elaborate a study on sustainability trends in the cultural and creative sector in Europe, as explained in the Terms and Conditions point V.
- Through clicking the corresponding box, the Data Subject gives its express consent to FBS to share with ENCATC (Avenue Maurice 1, 1050 Brussels, Belgium; info@encatc.org) your Personal Data for the purpose of managing the Participation Benefits corresponding to your Participant as described in the Terms and Conditions and for the dissemination of the CreaSus project final event.
These consents may be revoked at any time by sending an e-mail to privacidadfundacionbs@gruposantander.com, without such revocation affecting any processing previously carried out and without prejudice to any of your rights of redress that may arise for data.
International data transfer
FBS will not transfer data outside the European Economic Area.
However, we recommend the revision of the privacy policy corresponding to each Partner and the relevant data sharing in accordance to the sharing of data exposed above.
Rights
Data subjects may at any time exercise their rights of access, portability, rectification, restriction and erasure of data and to object to processing of their data through the e-mail address:
privacidadfundacionbs@gruposantander.com
Additional information
If the Data Subject considers that any of its rights have been violated, the Data Subject may file a complaint with the Spanish Agency for Data Protection – AEPD.