This Privacy Policy has been developed taking into account the provisions of current legislation on data protection: Regulation 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 the movement of such data, (hereinafter RGPD); and Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights (hereinafter LOPDyGDD).

The purpose of this Privacy Policy is to bring to the attention of the holders of personal data, in respect of which information is being collected, the specific aspects relating to the processing thereof, in compliance with the principle of transparency and the duty of information, regulated both in article 13 of the RGPD and in article 11 of the LOPDGDD.

Joint controllers of the processing:

The personal data collected and generated by the Aragón European DIH programme (Aragón EDIH) will be processed by the following joint data controllers (Article 26 of the RGPD):

Confederation of Employers of Aragón (CEOE Aragón)

• CIF: G50115989
• Address: Avda. César Augusto 20 - 50004 Zaragoza
• Mail: ceoearagon@ceoearagon.es

Confederation of Small and Medium-sized Enterprises of Aragon (CEPYME)

• CIF: G50336585
• Address: Plaza Roma, F1 offices, 2nd floor - 50010 Zaragoza
• Mail: cepyme@cepymearagon.es

Aragonese Council of Official Chambers of Commerce, Industry and Services (CÁMARAS ARAGÓN)

• CIF: Q5000838B
• Address: Paseo Isabel la Católica, nº 2 - 50009 Zaragoza
• Mail: secretaria@camarasaragon.com

Aragonese Institute for Development (IAF)

• CIF: Q5095004G
• Address: C/ Tte. Coronel Valenzuela 9 - 50004 Zaragoza
• Mail: info@iaf.es

University of Zaragoza (UNIZAR)

• CIF: Q5018001G
• Address: C/ Pedro Cerbuna Nº 12 - 50009 Zaragoza
• Mail: dpd@unizar.es

Aragon Institute of Technology (ITAINNOVA)

• CIF: Q5095008H
• Address: Calle María de Luna 7-8 - 50018 Zaragoza
• Mail: info@itainnova.es

Cluster of ICT, Electronics and Telecommunications Companies of Aragon (TECNARA)

• CIF: G99311086
• Address: C/María de Luna nº11, Edificio CEEI Aragón, Nave. 6 - 50018 Zaragoza
• Mail: tecnara@tecnara.es

Data processing

The personal data requested, where appropriate, will consist only of those strictly necessary to identify and respond to the request made by the owner of the data, hereinafter referred to as the data subject. Such information shall be processed in a fair, lawful and transparent manner in relation to the data subject. Furthermore, personal data will be collected for specific, explicit and legitimate purposes, and will not be further processed in a manner incompatible with those purposes.

The data collected from each data subject shall be adequate, relevant and not excessive in relation to the relevant purposes for each case, and shall be updated whenever necessary.

The data subject shall be informed, prior to the collection of his or her data, of the general points regulated in this policy so that he or she may give express, precise and unequivocal consent to the processing of his or her data, if necessary and in accordance with the following aspects.

Purposes of processing

The explicit purposes for which each of the processing operations are carried out are set out in the informative clauses included in each of the data collection methods (web forms, paper forms, contracts, posters, etc.).

The joint data controllers will collect and process the personal data generated by the Aragón European IHL programme (Aragón EDIH) for the sole purpose of carrying out the purposes of the programme. The responsibility will be joint responsibility of all the parties except in those data processing operations that any of the co-responsible parties carries out individually, in which case the responsibility for these will fall on the body that has carried them out.

Thus, in general, the purpose of the collection and processing of data is as follows:

- The maintenance of the relationship established between the owner of the data and those jointly responsible for the processing.

- The execution, maintenance and management of any relations that may be maintained between the joint controllers and the data subject: commercial, administrative, accounting, training, marketing and any other provision of services requested of the joint controllers by the Data Subject, within the framework of the Aragón EDIH.

- The periodic sending of the Aragón EDIH newsletter, for interested parties who have subscribed to it or who have given their consent to receive it.

- Management of the adhesion to Aragón EDIH.

- The sending of advertising and promotional information, related to the services of the Aragon EDIH project, provided that you have given your consent to it or there is a previous commercial/contractual relationship and it refers to the sending of commercial communications concerning products or services similar to those that were initially contracted with the client (article 21.2 of Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce).

The data will not be used for purposes other than those for which they were collected.

Legitimation

As a general rule, prior to the processing of personal data, the unequivocal consent of the data subject shall be obtained by means of the incorporation of informed consent clauses in the different information collection systems.

However, in the event that the consent of the data subject is not required, the legitimate basis for the processing is the performance of the contractual relationship established, our legitimate interest in the development of the project, in the case of commercial promotion and prospecting or compliance with a law authorising or requiring the processing of the data subject's data.

If your consent has been requested for any of the processing that we are going to carry out (such as sending the newsletter), we inform you that you can withdraw it at any time.

Recipients

The data will not be communicated to any third party, except:

the Data Controller has given his/her consent to this effect,
the transfer is authorised by law,
in the case of entities with which we have a relationship and by virtue of data processor contracts entered into with them,
in the case of dissemination, external publication and programme justification tasks
in the case of public bodies that require it for the purposes of intervention, audits, certifications, etc.

International data transfers

No international data transfers are foreseen.

Retention periods

The information collected from the data subject will be kept for as long as it is necessary to fulfil the purpose for which the personal data were collected, so that, once the purpose has been fulfilled, the data will be cancelled. Said cancellation will give rise to the blocking of the data, which will only be kept at the disposal of the Public Administrations, Judges and Courts, in order to attend to any possible liabilities arising from the processing, during the period of limitation of these, after which time the information will be destroyed.

For information purposes, the legal periods for the conservation of information in relation to different matters are set out below:

Rights of data subjects

Any person has the right to obtain confirmation as to whether or not personal data concerning him/her are being processed within the framework of the Aragón European IHL Programme (Aragón EDIH).

Interested parties have the right to access their personal data, as well as to request the rectification of inaccurate data or, where appropriate, to request its deletion when, among other reasons, the data is no longer necessary for the purposes for which it was collected.

In certain circumstances, data subjects may request the limitation of the processing of their data, in which case we will only keep it for the exercise or defence of claims.

In certain circumstances and for reasons relating to their particular situation, data subjects may object to the processing of their data. In this case, the data will no longer be processed, except for compelling legitimate reasons, or for the exercise or defence of possible claims.

There is also the possibility of lodging a complaint with the Spanish Data Protection Agency (aepd.es) if the data subject considers that their data is not being processed appropriately.

The INSTITUTO TECNOLÓGICO DE ARAGÓN, calle María de Luna 7-8, 50018, Zaragoza, is designated as the point of contact for data subjects, and data subjects may obtain additional information on data protection by sending an e-mail to lopd-ita@itainnova.es.

Data subjects may also exercise their rights under current legislation on data protection before any of the parties jointly responsible for data processing, for which purpose the following contact addresses are designated:

• For the IAF: info@iaf.es
• For the Instituto Tecnológico de Aragón: lopd-ita@itainnova.es
• For the University of Zaragoza: dpd@unizar.es
• For the Zaragoza Chamber of Commerce: lopd@camarazaragoza.com
• For the CEOE: lopd@ceoearagon.es
• For CEPYME: cepyme@cepymearagon.es
• For TECNARA: tecnara@tecnara.es