Privacy policy

This Privacy Policy (hereinafter, the “PRIVACY POLICY”) governs, in general terms, the collection and processing by CENTRO INTERNACIONAL DE CULTURA CONTEMPORÁNEA, S.A. (hereinafter, “TABAKALERA”) of (i) the personal data that you provide to us as a user of the website accessible via the domain name www.kulturgileak.eus (hereinafter, the “WEBSITE”), including services which may be available at any time via the WEBSITE; and (ii) other data collected through other collection systems duly identified below. The aforementioned is without prejudice to the specific provisions established in certain sections, forms or services available on the WEBSITE for the purposes of providing you with relevant information and, where applicable, to gather your consent.

TABAKALERA reserves the right to modify the PRIVACY POLICY in order to adapt it to new legislation, case law and/or administrative changes, as well as to practices that it may engage in via the WEBSITE at any point, taking into account your rights and interests at all times.

In any event, TABAKALERA shall provide you with suitable technical resources so that you may access the PRIVACY POLICY in order to ensure proper compliance with the relevant data obligations that we must fulfil pursuant to current data protection law.

1. Who is Data Controller?

The Data Controller is CENTRO INTERNACIONAL DE CULTURA CONTEMPORÁNEA, S.A., a company whose registered address is in San Sebastián (Gipuzkoa), Plaza de las Cigarreras, No. 1, and which is listed in the Commercial Register of Gipuzkoa under volume 2.787, folio 73, sheet SS-20175, and which holds TIN A-20762233.

If you have any questions relative to the PRIVACY POLICY and/or how we process your personal data, you can contact us at the aforementioned postal address or by sending an email to pribatutasuna@tabakalera.eus.

2. How have we obtained your personal data?

The data we process at TABAKALERA have been obtained from you by means of (i) the various forms which you complete while browsing our WEBSITE or through other channels (e.g. registering as a user of the WEBSITE (where applicable), contact forms, registration forms for courses, events and/or activities organised by TABAKALERA; (ii) via email queries sent by you; or (iii) via other duly identified collection systems, such as the video surveillance system deployed in our installations.

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

Furthermore, we hereby inform you that we may process data pertaining to you relative to social networks by means of the corporate profiles used by TABAKALERA on each social network it uses, within the terms and conditions established in each one.

3. What type of data do we process?

The data we process at TABAKALERA comprise the information which you have provided to us while browsing our WEBSITE, via the forms we use to formalise our contact with you and/or by email, as well as other information which, where applicable, we obtain via TABAKALERA’s corporate profiles on the social networks we use.

In particular, TABAKALERA processes the following categories of data:

Identity and contact details (e.g. name, surname(s), national identity number (DNI), postal and email addresses, phone number, etc.).
Banking and financial transaction details.
Codes and passwords identifying you as a registered user of the WEBSITE.
Internet browsing data (e.g. IP address, visits to web pages, connections to wifi networks, etc.).
Images captured within the context of an event or activity organised by TABAKALERA.
Images captured by the video surveillance system deployed at the accesses to our installations.

4. For what purpose do we process your personal data and on what legal grounds?

Your data is processed for the following purposes:

To manage and process your registration as a user of the WEBSITE, when this is possible.
To manage your access to and use of the content and services provided by TABAKALERA to you through the WEBSITE, including blogs, social networks or any other functionality that may be accessible from the WEBSITE at any time.
To process and manage the procurement of services which, if applicable, you formalise with TABAKALERA via the WEBSITE and, in general, to maintain, manage and monitor the contractual relationship you establish with us as an acquirer of our products or services.
To process and manage requests for information, suggestions, complaints or the exercise of rights made via the WEBSITE or by email.
To manage your subscription to our newsletter and send the corresponding electronic communications, provided you have given your consent to receiving these.
To manage your registration and participation in the courses, events and/or activities organised by TABAKALERA on which you have voluntarily registered.
In cases where it has been accepted, to manage and publicise activities and events organised by TABAKALERA.
To guarantee the safety and integrity of persons and property by capturing images via the video surveillance system deployed at the accesses and in the interior of our installations.

The processing of personal data by TABAKALERA, according to the applicable regulations, is based (i) on your consent, granted at the moment when your personal data is recorded which you have provided voluntarily by means of the mechanisms set up for these purposes on the WEBSITE; (ii) on the relationship established with us in the event of contracting our products and services; or (iii) on TABAKALERA’s legitimate interest as regards the video surveillance system deployed in our installation and other processing that can be understood to be legitimised by the same.

Where the processing of data requires your consent, you may withdraw your consent freely at any time, at no cost, under the terms indicated in Section 7 that follows.

5. With whom do we share your data?

Your personal data may be communicated to the following third parties:

Public bodies and administrations to which TABAKALERA is under a legal obligation to communicate your data, where applicable.
When you have consented to it, your image shall be accessible by third parties through TABAKALERA’s website and/or through other means, even outside the territory of the European Union, within the scope of the dissemination of activities and events.

On the other hand, we inform you that TABAKALERA uses the services of third-party entities (Data Processors) located in the United States to manage the sending of communications included in the “Newsletter” service and other e-commerce communications, meaning that the contact details of the recipients of such communications shall be the subject of an international transfer of data protected by the existence of an Adequacy Decision by the European Commission.

Regardless of the above, no other international transfers of your data are contemplated.

6. For how long will we keep your data?

In general, your personal data shall be kept until such time as you withdraw your consent for the processing of your data or request its erasure, and for as long as necessary to meet TABAKALERA’s legal obligations.

In any case, TABAKALERA has internal data cleansing policies to control the length of time during which it holds personal data. Said data may be erased when they are no longer required and/or suitable for their original purpose.

In particular, and regarding the video surveillance system deployed in our installations, it is hereby stated that the images recorded shall be erased within a maximum period of 20 days.

7. What are your rights?

Current data protection law grants you a series of rights relative to your personal data. You may exercise these rights while your data is being processed. Your rights are as follows:

Access to your data: you have the right to access your data to find out what personal data pertaining to you we hold.
Request rectification or erasure of your data: under certain circumstances, you have the right to rectify inaccurate data pertaining to you that we process, or to request its erasure when, among other reasons, the data is no longer necessary for its original purpose.
Request restriction to the processing of your data: under certain circumstances, you have the right to request that we restrict the processing of your data. In this case, we will only store your data for the purposes of exercising or defending complaints, as set out in current data protection law.
Portability of your data: under certain circumstances, you have the right to receive the personal data pertaining to you that you have provided to us. The data will be provided to you in a structured, commonly-used, machine-readable format that can be shared with another data controller.
Object to the processing of your data: under certain circumstances, and for reasons related to your particular situation, you have the right to object to the processing of your data. In this case, we will cease to process your data except where it must be held on compelling legal grounds, or for the purpose of exercising or defending possible complaints.

You also have the right to withdraw your consent at any time, without prejudice to the lawfulness of processing based on the consent originally provided.

You may exercise these rights in writing to TABAKALERA at the address indicated in Section 1 or by emailing pribatutasuna@tabakalera.eus.

Lastly, you may submit a complaint to the competent Supervisory Authority (in Spain, the Spanish Data Protection Agency), particularly when you have not been able to exercise these rights to your satisfaction. You can contact the aforementioned Authority via their website: www.aepd.es.

8. Safety Measures

TABAKALERA will at all times process your data in a strictly confidential manner and will uphold the mandatory duty of secrecy, pursuant to the provisions of the relevant data protection legislation. TABAKALERA will adopt the necessary technical and organisational measures to guarantee the security of your data and to avoid their alteration, loss, or unauthorised access thereto or processing thereof, taking into account the state of technology, the nature of the data stored, and the risks to which they are exposed.

9. Cookies policy

You can access the TABAKALERA Cookies Policy via the following link.