DATA PROTECTION POLICY

INICIATIVAS INNOVADORAS, S.A.L. holding Tax ID No. A-31679806, with registered offices in C/ Zabalgaina nº 3 -1º Oficinas 4/5 31.180 Zizur Mayor (Navarre), telephone: +34 948 281 270 and e-mail address: info@4cemed.eu

INICIATIVAS INNOVADORAS shall process personal data provided directly by the user.

In general, we shall process identification details (such as name(s), surname(s), Tax ID no., telephone number, address, e-mail, IP address).

The user guarantees the authenticity, accuracy and truthfulness of all the information he or she provides, and undertakes to keep his or her personal data updated so that they match at all times his or her actual situation. The user shall be solely responsible for any untruthful or inaccurate declarations and for any eventual damages that could arise therefrom.

The personal data you provide within the framework of the provision of our services are mandatory and are the minimum necessary for us to handle your request.

The personal data you provide may be used for one or several of the purposes described below, driven by factors such as your relationship with INICIATIVAS INNOVADORAS or with the project partners or by the means used to submit the data. Below is a description of the data processing covered by this policy, without prejudice to further data processing operations which you may be informed of or regarding which we may ask for your authorisation:

a) Compliance with legal obligations

Processing of your personal data may be required to comply with certain legal obligations. Particularly, legislation on data protection, taxes, statistics, insurances, etc.

b) Execution and performance of the contract

The personal data of the person concerned are processed for the purposes of handling the contractual relationship, fulfilling the terms of the contract and complying with tax legislation, while fulfilling, controlling and performing the provision guaranteed by the contract.

c) Communication-contact

The data you provide by e-mail, through instant messaging applications, or when lodging a complaint, are only used to respond to your request.

d) Provision of commercial communications by any means where additional consent is granted

If you explicitly give your consent, we may share your data with our collaborators for the purposes of informing you by any means for promotional or advertising purposes of the services, products or events we organise or participate in.

We gather your personal information by different means, but you will always be aware of such data collection by means of notices informing you of the person responsible for processing the data, the purpose of and the legal grounds for the processing, the recipients of the data and the conservation period, as well as how to exercise your rights on data protection.

In general, the personal data we process are limited to identification details (name(s) and surname(s) and e-mail).

Our website uses cookies to collect personal information relating to your browsing. If you want to know clearly and precisely the cookies we use, their purposes, how to configure or disable them, check our Cookie Policy.

We only keep your information for the period time required to fulfil the purpose for which it was collected, comply with statutory obligations and to fulfil the responsibilities that could arise from attaining the purpose for which the data were collected. Your personal data shall be kept during the currency of the contractual and/or legal relationship and following such period, provided you have not exercised your right of erasure, they shall be kept considering the legal deadlines applicable in each case, the type of data and the purpose of the processing.

In the event that you exercise your right of erasure and such right is applicable, your data will be blocked pursuant to article 32 of LOPDGDD, and they shall only be available to the Courts of Justice, the Ombudsman’s office, the Public Prosecutor or the competent administrative authorities during the limitation period of the actions that could arise, following which period they shall be fully deleted.

Our processing of your personal data shall be lawful, fair, transparent, appropriate, pertinent, limited, accurate and updated. This is why we undertake to take all reasonable measures to have them deleted or rectified without delay when inaccurate.

Depending on our relationship and therefore on the purpose of the processing, the legal grounds may differ. Below is a presentation of the different legal grounds applicable depending on the type of processing:

• CONTRACTUAL RELATIONSHIP: For the contracted provision.
• LEGITIMATE INTERESTS: Among others, profiling, quality and opinion surveys, web maintenance or hotlines.
• LEGAL OBLIGATION: Compliance with legal obligations laid down in any applicable legislation.
• CONSENT: When you provide your data through contact forms available on our website or when you submit your request for our newsletter.

You should be aware than whenever we request your consent for processing purposes, your non-granting – or any eventual subsequent withdrawal of your consent, shall have no adverse consequences for you.

In the event of third-party data provision, you declare you have the consent of the holders of the data for such data provision or that you are their legal representative, thus exempting INICIATIVAS INNOVADORAS and its partners from any responsibility or liability.

The categories of data we process are the following:

• Contact: identification information (name, e-mail and IP address).
• Contractual performance: identification information; information on personal characteristics; academic and professional information; employment information; commercial information; economic, financial and insurance information; information on goods and service transactions; health information.
• Commercial communications/newsletter: identification information (e-mail).

Depending on the services we provide to you, your personal data may be disclosed to third parties, where such disclosure is necessary for the adequate fulfilment of legal and/or contractual obligations. Said providers shall not process your data for their own purposes or for purposes other than those previously informed of by INICIATIVAS INNOVADORAS.

Where access to personal data is granted to third parties for the sake of better management and provision of services, INICIATIVAS INNOVADORAS guarantees that personal data shall remain confidential during the data processing. In any case, the user shall be conveniently made aware of any such transfer of personal data, including the identity of the recipient and the purpose of the transfer.

Your data may be transferred to our partners in this project:

• Alma Mater Studiorum – Universidad de Bolonia (Italia)
• Consejo de Investigación Agrícola y Análisis de la Economía Agrícola (Italia)
• Instituto Nacional de Investigación Agronómica de Argelia (Argelia)
• Cooperativas Agroalimentarias (España)
• Compañía Camelina España (España)
• Institut du Végétal (Francia)
• Centro de Fuentes de Energía Renovable (Grecia)
• Bios Agrosystems (Grecia)
• Centro Internacional de Investigaciones Agrícolas en zonas áridas (Marruecos)
• Instituto Nacional de Investigación Agrícola de Túnez (Túnez)

Right	Content	Means of contact
Access	You have the right to request confirmation that your personal data are being processed by INICIATIVAS INNOVADORAS.	info@4cemed.euC/ Zabalgaina nº 3 -1º Oficinas 4/5 31.180 Zizur Mayor (Navarra)
Rectification	You have the right to obtain the rectification of inaccurate personal data.
Erasure	You have the right to obtain the erasure of personal data.
Objection	You may request that your data be not processed.
Restriction of processing	You have the right to obtain restriction of processing of your personal data: ü  While the accuracy of your personal data is being verified. ü  When the processing is unlawful and you oppose the erasure of your personal data. ü  When INICIATIVAS INNOVADORAS no longer needs to process your personal data, but you require them for the exercise or defence of legal claims. ü  When you have objected to the processing of your personal data based on the legitimate interests of INICIATIVAS INNOVADORAS, pending the verification whether such legitimate interests override your rights and freedoms.
Portability	You have the right to receive, in electronic format, the personal data you have provided to us and those obtained from your contractual relationship with INICIATIVAS INNOVADORAS, and to have them transmitted to another controller of your choice.
You have the right to withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
All requests shall be responded within one month of receipt of the request. That period may be extended by two further months, taking into account the number and complexity of the requests.
If you feel that your request has not been properly met you may contact the Spanish Data Protection Agency (Agencia Española de Protección de Datos – www.agpd.es) and lodge a complaint.
When exercising your rights, attach to your request a copy of your national identity card, alien identity card, passport or any other proof of identity.
Exercising these rights is free of charge.

Characteristics of these rights:

Exercising these rights is free of charge, unless the requests are manifestly unfounded or excessive (e.g. because of their repetitive character), in which case INICIATIVAS INNOVADORAS may either charge a reasonable fee taking into account the administrative costs or refuse to act.

You may exercise your rights directly or through your legal or authorised representative.

We shall respond to your request within one month. That period may be extended by two further months, taking into account the number and complexity of the requests.

We are obliged to inform you of the means to exercise these rights. Such means must be accessible and we may not refuse the exercise of your right on the sole ground that you have chosen another means. If the request is made by electronic means, the information shall be provided by the same means where possible, unless otherwise requested.

If INICIATIVAS INNOVADORAS does not take action on the request, we shall inform you, within one month, of the reasons for not taking action and on the possibility of lodging a complaint with a supervisory authority.

 

In order to facilitate the exercise of your rights, below you will find links to request forms for each right:

• Form for exercising the right of access
• Form for exercising the right to rectification
• Form for exercising the right to object
• Form for exercising the right to erasure (‘right to be forgotten’)
• Form for exercising the right to restriction of processing
• Form for exercising the right to data portability
• Form for exercising the right not to be subject to automated individual decision-making

We at INICIATIVAS INNOVADORAS are committed to protecting your personal data. We use reasonably reliable and effective physical, organisational and technological measures, controls and procedures aimed at preserving the integrity and security of your data and to safeguard your privacy.

Furthermore, all our staff having access to personal data has been properly trained and is aware of their obligations regarding the processing of your personal data.

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

However, absolute security cannot be guaranteed as no security system is impenetrable. Therefore, if any data subject to processing under our control should be compromised as a consequence of a security breach, we shall adopt appropriate measures to investigate the incident, report it to the supervisory authority and, where applicable, to the users who may have been adversely affected so that they may adopt appropriate measures.

INICIATIVAS INNOVADORAS informs you that it complies with Ley 34/2002 of 11 July 2002 on information society services and e-commerce and does not engage in spam activities. We shall request your consent to process your e-mail address or mobile phone number for commercial purposes on each occasion.

INICIATIVAS INNOVADORAS reserves the right to modify its privacy policy or its conditions of use of the services on the grounds of adaptation to the legislation in force, or on other grounds. When this occurs, we shall inform you of any change and shall ask you to read again the latest version of our policy and, if applicable, to confirm your acceptance. To ensure absolute confidentiality and privacy of the personal data collected by us, security measures have been adopted to prevent their alteration, loss, unauthorised processing or access and to guarantee their integrity, availability and security. However, INICIATIVAS INNOVADORAS shall not be responsible for any occurrence or eventuality that may arise regarding personal data when they are the result of: an attack or an unauthorised access to the systems in such a way that it is impossible to identify or prevent it even though measures are in place according to the current state of technology.