DATA PROTECTION AND PRIVACY POLICY

In compliance with regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 regarding the protection of natural persons with regard to the processing of personal data, which repeals Directive 95/46/EC (hereinafter the GDPR) of law 34/2002 of 11 July for information society and electronic commerce services (hereinafter the LSSI-CE) of Spanish organic law 3/2018 regarding the protection of personal data and guaranteeing digital rights (hereinafter the LOPDGDD), the Homeless Film Festival guarantees the protection and confidentiality of personal data of any kind provided by our clients, in accordance with the General Data Protection Regulations.

Data provided will be processed under the terms set forth in the GDPR, along these lines the Homeless Film Festival has adopted the levels of protection that are legally required and they have installed all the technical means within their reach to avoid loss, misuse, alteration, unauthorised third party access described below. Nevertheless, users must be aware that security measures are not impenetrable.

Controller
name: Homeless Film Festival
FIN: G48260111
Address: Langaran 14, bajo
Telephone: 946087008
Email: bizitegi@bizitegi.org

Purposes of processing
All data provided by our clients or visitors to the Homeless Film Festival or its staff will be included in a record of personal data processing activities created and maintained under the responsibility of the Homeless Film Festival that are essential for providing the services requested by users or to resolve doubts or questions from our visitors. Our policy is to not create profiles of the users of our services.

Legal basis of processing

  1. Contractual relationship: This relationship applies when one of our products is purchased or one of our services is hired.
  2. Legitimate interest: Responding to questions or complaints and to manage the collection of debts owed.
  3. Consent: If you are a user of our Web Site, by marking the box that appears on the contact form you authorise us to send you any communications necessary to respond to the question or request for information you have made.

Recipients
We do not share personal data with anyone, except public or private entities to which we are obligated to provide data to for the purposes of complying with a law. For example, under Spanish tax law it is required to provide certain information about economic transactions that exceed a specific amount to the tax office.

In the event that, aside from the situations described above, we need to share your personal information with other entities, we will ask for your permission beforehand with clear options that let you make a decision in this regard.

Communication
We do not do any international transfers of your personal data for any of the purposes indicated.
(INTERNAL NOTE: THIS PARAGRAPH NEEDS TO BE CHANGED BY THE CONTROLLER IF THERE REALLY ARE INTERNATIONAL TRANSFERS. WE RECOMMEND ASKING FOR ADVICE IF YOU DO NOT KNOW HOW TO CORRECTLY STATE THAT YOU ARE COMPLYING WITH THE REGULATIONS.)

Conservation
We will only conserve your personal data for the time needed to fulfil the purposes for which the data was collected. When determining the opportune period for conservation, we will examine the risks involved in processing as well as our contractual, legal and regulatory obligations, the internal data conservation policies and our legitimate business interests described in this Privacy Notice and Cookies Policy.

Along these lines, the Homeless Film Festival will conserve personal data after they finish their relationship with you, properly blocked, for the statute of limitation of the actions that may derive from maintaining the relationship with the interested party.

After blocking, your data will be inaccessible to the Homeless Film Festival and will not be processed except for making it available to the government, judges or the courts to attend to possible responsibilities derived from processing and to exercise and defend complaints made to the Spanish Agency for Data Protection.

Security
We make every reasonable effort to maintain the confidentiality of the personal data processed in our systems. We maintain strict levels of security to protect the personal data we process against accidental loss and unauthorised access, processing or leaks, in view of the status of technology and the nature and risks data is exposed to. Nevertheless, we cannot claim responsibility for the use you make of the data (including usernames and passwords) you use on our Web Site. Our staff follows strict privacy rules and if we hire third parties to provide support services, we demand that they adhere to the same rules and that they let us audit them to verify compliance.

Your rights
We inform you that you may exercise the following rights:

  1. Right to access your personal data to know which data is being processed and the processing operation done with it.
  2. The right to rectification of any inaccurate personal data.
  3. The right to erasure of your personal data, when possible, (for example under legal obligation).
  4. The right to limitation of the processing your personal data when the accuracy, legality or need for processing the data seems questionable, in which case we may conserve the data in order to exercise or defend against complaints.
  5. The right of opposition to processing of your personal data when the legal basis that allows us to process it is our legally justified interest. “Company Name” will stop processing your data unless it has a legally justified interest in doing so or it is necessary to defend against complaints.
  6. The right to data portability when the legal basis that allows us to process the data is the existence of your consent or a contractual relationship.
  7. The right to withdraw consent granted to the Homeless Film Festival.

To exercise your rights, you may do so free of charge at any time by contacting us at Langaran 14, bajo and including a copy of your identification card.

Protection of rights
In the event you feel your rights have been ignored by our entity, you can lodge a complaint with the Spanish Data Protection Agency (AEPD) using one of the following means:

  • Electronic portal: https://www.aepd.es
  • Mail: Agencia Española de Protección de Datos, C/ Jorge Juan, 6, 28001, Madrid
  • Telephone: 901.100.099 y 912.663.517

Lodging a complaint with the Spanish Agency for Data Protection does not incur any costs and a barrister or lawyer is not required.

Updates
The Homeless Film Festival reserves the right to modify this privacy policy to adapt it to new laws or jurisprudence that may affect compliance with it.