General Data Protection Regulation

This Privacy Policy clarifies the nature, scope and purpose of the processing of personal data (hereinafter referred to as “Data”) in the course of the provision of our services, as well as our online offerings and related websites, features and content, and external online presence, such as our Social Media Profile (collectively referred as “Online Offering”). With regard to the terminology used, e.g. “Processing” or “Responsible”, we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).

Responsible

Fundación Comparte

Erasme de Janer 8,
oficina 10,
08001 Barcelona,
Spain

E-Mail: info@comparte.org

Director: Señor Claudio Lavanchy

Types of processed data

  • Inventory data (e.g., person master data, name or address).
  • Contact information (e.g., e-mail, phone numbers).
  • Content data (e.g., text input, photographs, videos).
  • Usage data (e.g., websites visited, interest in content, access times).
  • Meta / communication data (e.g., device information, IP addresses).

Categories of affected persons

Visitors and users of the online offer (hereinafter we refer to the affected persons as “users”).

Purpose of processing

  • Provision of the online offer, its functions and contents.
  • Answering contact requests and communicating with users.
  • Safety measures.
  • Reach Measurement / Marketing

Used terms

“Personal data” means any information relating to an identified or identifiable natural person (hereinafter refered to the “data subject”); A natural person is considered as identifiable, which can be identified directly or indirectly, in particular by means of assignment to an identifier such as a name, to an identification number, to location data, to an online identifier (e.g. cookie) or to one or more special features, are the expression of the physical, physiological, genetic, mental, economic, cultural or social identity of this natural person.

“Processing” means any process performed with or without the aid of automated procedures, or any such process associated with personal data. The term goes far and includes virtually every handling of data.

“Pseudonymisation” means the processing of personal data in such a way that the personal data can no longer be assigned to a specific data subject without additional information being provided, provided that such additional information is kept separate and subject to technical and organizational measures to ensure that the personal data not assigned to an identified or identifiable natural person.

“Profiling” means any kind of automated processing of personal data that involves the use of such personal information to evaluate certain personal aspects pertaining to a natural person, in particular aspects relating to job performance, economic situation, health, personal to analyze or predict preferences, interests, reliability, behavior, whereabouts, or relocation of that natural person.

“Responsible person” means the natural or legal person, public authority, body or body which, alone or in concert with others, decides on the purposes and means of processing personal data.

“Processor” means a natural or legal person, public authority, body or body that processes personal data on behalf of the controller.

Relevant legal bases

In accordance with Art. 13 GDPR, we inform you about the legal basis of our data processing. For users within the scope of the General Data Protection Regulation (GDPR), i. the EU and the EEC, unless the legal basis in the data protection declaration is mentioned, the following applies:

The legal basis for obtaining consent is Article 6 (1) lit. a and Art. 7 GDPR. The legal basis for the processing for the performance of our services and the execution of contractual measures as well as the response to inquiries is Art. 6 par. 1 lit. GDPR; The legal basis for processing to fulfill our legal obligations is Art. 6 par. 1 lit. GDPR; In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. GDPR as legal basis.

The legal basis for the processing required to carry out a task in the public interest or in the exercise of official authority which has been delegated to the controller is Article 6 (1) lit. e GDPR. The legal basis for processing in order to safeguard our legitimate interests is Article 6 (1) lit. f GDPR. The processing of data for purposes other than those for which they were collected is governed by the provisions of Article 6 (4) GDPR. The processing of special categories of data (pursuant to Art. 9 (1) GDPR) is governed by the provisions of Art. 9 (2) GDPR.

Safety measures

We will take appropriate technical and organizational measures in accordance with legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing and the different probability of occurrence and severity of the risk to the rights and freedoms of individuals to ensure a level of protection appropriate to the risk.

Measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as their access, input, disclosure, availability and segregation. In addition, we have established procedures to ensure the enjoyment of data subject rights, the erasure of data and the response to data threats. Furthermore, we consider the protection of personal data already in the development or selection of hardware, software and procedures, according to the principle of data protection through technology design and privacy-friendly default settings.

Collaboration with contract processors, joint controllers and third parties

If, in the context of our processing, we disclose data to other persons and companies (contract processors, joint controllers or third parties), transmit them to them or otherwise grant them access to the data, this will only be done on the basis of a legal permission (e.g. if the data is transmitted to third parties, such as payment service providers, to fulfill the contract), users have consented to a legal obligation to do so or on the basis of our legitimate interests (e.g. the use of agents, webhosters, etc.).

Provided as that we disclose data to other companies in our group of companies, or otherwise grant access to them, this is done in particular for administrative purposes as a legitimate interest and, in addition, based on a legal basis.

Transfers to third countries

If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA) or the Swiss Confederation) or in the context of the use of third party services or disclosure, or transfer of data to other persons or companies This will only happen if it is to fulfill our (pre) contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to express consent or contractually required transmission, we process or disclose the data only in third countries with a recognized level of privacy, including those certified under the Privacy Shield, or on the basis of specific warranties such as: contractual obligation by so-called standard protection clauses of the European Commission, the existence of certifications or binding internal data protection regulations (Art. 44 to 49 GDPR).

Rights of data subjects

Right to information: You have the right to request a confirmation as to whether the data in question is being processed and for information about this data as well as for further information and copying of the data in accordance with legal requirements.

Right to rectification: You have the right, in accordance with the law, to request the completion of the data concerning you or to correct these (if applied) incorrect data.

Right to cancellation and limitation of processing: In accordance with the statutory provisions, you have the right to demand that the relevant data be deleted immediately, or alternatively, demand a restriction of the processing of the data in accordance with statutory provisions.

Right to data portability: You have the right to receive data relating to you, that you have provided to us in accordance with legal requirements in a structured, common and machine-readable format or to request their transmission to another person in charge.

Complaint to the supervisory authority: Furthermore, in accordance with the statutory provisions, you have the right to file a complaint with the competent supervisory authority.

Withdrawal

You have the right to revoke granted consent with effect for the future.

Right to object

You have the right at any time, for reasons that arise from your particular situation, against the processing of personal data relating to you which, on the basis of Art. 6 para. 1 lit. GDPR takes an objection, this also applies to profiling based on these provisions. If the personal data relating to you are processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for the purpose of such advertising. This also applies to profiling insofar as it is associated with such direct mail.

Cookies and right to object to direct mail

“Cookies” are small files that are stored on users’ computers. Different information can be stored within the cookies. A cookie serves primarily to store the information about a user (or the device on which the cookie is stored) during or after his visit to an online offer. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online service and closes his browser. In such a cookie, electronic information can be stored such as like e.g. the contents of a shopping cart in an online shop or a login status. “Persistent” refers to cookies that remain stored even after the browser has been closed. Thus, e.g. the login status will be saved if users visit it after several days. Likewise, in such a cookie the interests of the users can be stored, which are used for range measurement or marketing purposes. A “third-party cookie” refers to cookies that are offered by providers other than the person responsible for providing the online offer (otherwise, if only their cookies are called “first-party cookies”).

We can use temporary and permanent cookies and clarify this in the context of our privacy policy.

If we ask users for consent to the use of cookies (for example, in the context of a cookie consent), the legal basis of this processing is Art. 6 para. 1 lit. GDPR. Otherwise, the personal cookies of the users according to the following explanations in the context of this privacy policy on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 par. 1 lit. GDPR) or if the use of cookies to provide our contractual services is required, in accordance with Art. Art. 6 para. 1 lit. GDPR, or if the use of cookies is required for the performance of a task that is in the public interest or in the exercise of official authority, in accordance with. Art. 6 para. 1 lit. GDPR, processed.

If users do not want cookies stored on their machine, they will be asked to disable the option in their browser’s system settings. Saved cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.

A general objection to the use of cookies used for online marketing purposes can be found in a variety of services, especially in the case of tracking, via the US website https://www.aboutads.info/consumers or the EU site https://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by switching the concerned “Cookies” setting off in the settings of the browser. Please note that not all features of this online offer may be used.

Deletion of data

The data processed by us will be deleted or restricted in accordance with legal requirements. Unless explicitly stated in this privacy statement, the data stored by us will be deleted as soon as they are no longer necessary for their intended purpose and the deletion does not conflict with any statutory storage requirements.

Unless the data is deleted, because it is required for other and legally permitted purposes, its processing will be restricted. That the data is blocked and not processed for other purposes. This applies, e.g. for data that must be kept for commercial or tax reasons.

Changes and updates to the privacy policy

We ask you to inform yourself regularly about the content of our privacy policy. We will adjust the Privacy Policy as soon as the changes to the data processing we make require it. We will notify you as soon as the changes require your participation (e.g. consent) or other individual notification.

Agency services

We process our clients’ data as part of our contractual services that include training planning and training services.

We process stock data (e.g., customer master data, such as names or addresses), contact data (e.g., e-mail, telephone numbers), content data (e.g., text input, photographs, videos), contract data (e.g., subject matter, term), usage and metadata (e.g. in the context of the evaluation and success measurement of marketing measures). In principle, we do not process special categories of personal data, unless these are components of a commissioned processing. Those affected include our customers, prospects and their customers, users, website visitors or employees as well as third parties. The purpose of the processing is the provision of contract services, and our customer service. The legal basis for processing results from Art. 6 para. 1 lit. GDPR (contractual services), Art. 6 para. 1 lit. GDPR (analysis, statistics, optimization, security measures). We process data necessary for the establishment and performance of the contractual services and indicate the necessity of their information. Disclosure to external parties will only be made if required by an contract. In the processing of the data provided to us within the framework of an order, we act in accordance with the instructions of the client as well as the legal requirements of a order processing according to Art. 28 GDPR and process the data for no other purpose than the order.

We delete the data after expiration of legal warranty and comparable obligations. The necessity of keeping the data is checked every three years. In the case of legal archiving obligations, the deletion takes place after its expiration. In the case of data disclosed to us in the context of an order by the client, we delete the data according to the specifications of the order, in principle after the end of the order.

Contractual services

We process the data of our contractual partners and interested parties as well as other customers, clients, or contractual partners (uniformly referred to as “contractual partners”) in accordance with Art. 6 para. 1 lit. GDPR in order to provide you with our contractual or pre-contractual services. The data processed, the nature, scope and purpose and necessity of their processing are determined by the underlying contractual relationship.

The processed data includes the master data of our contractual partners (e.g., names and addresses), contact data (e.g. e-mail addresses and telephone numbers) as well as contract data (e.g., services used, contract contents, contractual communication, names of contact persons).

In principle, we do not process special categories of personal data, unless these components are the subject of a commissioned or contractual processing.

We process data that are necessary for the establishment and fulfillment of the contractual services and point out the necessity of their information, if this is not evident for the contractual partners. Disclosure to external persons or companies will only be made if required by a contract. When processing the data provided to us within the framework of an order, we act in accordance with the instructions of the client as well as with the legal requirements.

As part of the use of our online services, we can save the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the interests of the user in the protection against misuse and other unauthorized use. A transfer of this data to third parties is not, unless it is to pursue our claims according to Art. 6 para. 1 lit. GDPR required or there is a legal obligation Art. 6 paragraph 1 lit. GDPR.

The data is deleted if the data is no longer required for the fulfillment of contractual or legal duties of care and for handling any warranty and comparable obligations, whereby the necessity of keeping the data is reviewed every three years. Otherwise the statutory storage obligations apply.

Administration, financial accounting, office organization, contact management

We process data in the context of administrative tasks and organization of our business, financial accounting and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process in the course of rendering our contractual services. The processing principles are Art. 6 para. 1 lit. GDPR, Art. 6 para. 1 lit. GDPR. The processing affects customers, prospects, business partners and website visitors. The purpose and interest in processing lies in administration, financial accounting, office organization, data archiving, that is, tasks that serve to maintain our business, perform our duties and provide our services. The deletion of the data with regard to contractual services and contractual communication corresponds to the information provided in these processing activities.

Furthermore, based on our business interests, we store information about suppliers, promoters and other business partners, e.g. for later contact. We generally store this majority of company-related data permanently.

Provision of our statutory and business services

We process the data of our members, supporters, prospects, customers or other persons in accordance with Art. 6 para. 1 lit. GDPR, if we offer them contractual services or in the context of an existing business relationship, e.g. members, or are themselves recipients of services and benefits. Incidentally, we process the data of affected persons in accordance with. Art. 6 para. 1 lit. GDPR based on our legitimate interests, e.g. when it comes to administrative tasks or public relations.

The data processed, the nature, the scope and the purpose and the necessity of their processing are determined by the underlying contractual relationship. This includes generally inventory and master data of the persons (e.g., name, address, etc.), as well as the contact data (e.g., e-mail address, telephone, etc.), the contract data (e.g., services used, communicated contents and information, names of contact persons).

We delete data that is no longer necessary for the performance of our statutory and business purposes. This is determined according to the respective tasks and contractual relationships. In the case of business processing, we retain the data for as long as they may be relevant to the transaction, as well as with regard to any warranty or liability obligations. The necessity of keeping the data is checked every three years. Otherwise the statutory storage obligations apply.

Contact

When contacting us (for example, by contact form, e-mail, telephone or via social media), the information of the user to process the contact request and their processing according to Art. 6 para. 1 lit. (in the context of contractual / pre-contractual relationships) GDPR, Art. 6 para. 1 lit. f. (other inquiries) GDPR processed. User information can be stored in a Customer Relationship Management System (“CRM System”) or a comparable system of administrated requests.

We delete these requests, if they are no longer required. We check the requirement every two years. Furthermore, the legal archiving obligations apply.

Google Analytics

We use Google Analytics, a Google Ireland Limited web analytics service. Located at Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). Google uses cookies. The information generated by the cookie about the use of the online offer by the users are usually transmitted to a Google server in the USA and stored there.

Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offering and to provide us with further services related to the use of this online offer and the internet usage. In this case, pseudonymous user profiles of the processed data can be created.

We only use Google Analytics with activated IP anonymization. This means that the IP address of the users is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there.

The IP address submitted by the user’s browser will not be merged with other data provided by Google. Users can prevent the storage of cookies by setting their browser software accordingly; Users may also prevent the collection by Google of the data generated by the cookie and related to their use of the online offer as well as the processing of such data by Google by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

If we ask users for consent (for example, in the context of a cookie consent), the legal basis of this processing is Art. 6 (1) lit. GDPR. Otherwise, the personal data of the users are processed on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Article 6 (1) (f) of the GDPR).

As far as data is processed in the US, we point out that Google is certified under the Privacy Shield Agreement, thereby ensuring compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active) ,

For more information about Google’s data usage, hiring and disparaging options, please read Google’s Privacy Policy (https://policies.google.com/privacy) and Google’s Ads Ad-Settings (https://adssettings.google.com/authenticated).

The personal data of users will be deleted or anonymized after 14 months.

Online presence in social media

We maintain online presence within social networks and platforms in order to communicate with customers, prospects and users active there and to inform them about our services.

We point out that data of the users outside the area of ​​the European Union can be processed. This may result in risks to users because, e.g. the enforcement of user rights could be made more difficult. As for US providers certified under the Privacy Shield, we point out that they are committed to upholding the EU’s privacy standards.

Furthermore, the data of the users are usually processed for market research and advertising purposes. Thus, e.g. user profiles are created from the user behavior and the resulting interests of the users. The usage profiles may in turn be used to e.g. place advertisements inside and outside the platforms that are allegedly in line with users’ interests. For these purposes, cookies are usually stored on the computers of the users, in which the user behavior and the interests of the users are stored. Furthermore, in the usage profiles, data can also be stored independently of the devices used by the users (in particular if the users are members of the respective platforms and logged in to them).

The processing of personal data of users is based on our legitimate interests in an effective information of users and communication with users in accordance with. Art. 6 para. 1 lit. GDPR. If the users are asked by the respective providers of the platforms for a consent to the above-described data processing, the legal basis of the processing is Art. 6 para. 1 lit. GDPR & Art. 7 GDPR.

For a detailed description of the respective processing and the possibilities of contradiction (opt-out), we refer to the following linked information of the provider.

Also in the case of requests for information and the assertion of user rights, we point out that these can be claimed most effectively from the providers. Only the providers have access to the data of the users and can directly take appropriate measures and provide information. If you still need help, then you can contact us.

Integration of services and contents of third parties

Based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 (1) lit. GDPR), we make use of content or services offered by third-party providers in order to provide their content and services, such as including videos or fonts (collectively referred to as “content”).

This always presupposes that the third-party providers of this content perceive the IP address of the users, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of this content. We endeavor to use only content whose respective providers use the IP address only for the delivery of the content. Third parties may also use so-called pixel tags (invisible graphics, also referred to as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information, such as visitor traffic, on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may include, but is not limited to, technical information about the browser and operating system, referring web pages, time of visit, and other information regarding the use of our online offer.

Youtube

We embed the videos from the YouTube platform of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Privacy Policy:
https://policies.google.com/privacy, opt-out: https://adssettings.google.com/authenticated.

Google ReCaptcha

We bind the function to detect bots, e.g. when entering into online forms (“ReCaptcha”) of the provider GGoogle Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Privacy Policy: https://www.google.com/policies/privacy/, opt-out: https://adssettings.google.com/authenticated.

Google Maps

We include maps from the Google Maps service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The processed data may include, in particular, users’ IP addresses and location data, but these are not collected without their consent (usually as part of the settings of your mobile device). The data can be processed in the USA. Privacy Policy: https://www.google.com/policies/privacy/, opt-out: https://adssettings.google.com/authenticated.

WPForms

We bind in the possibility to contact the responsible organisation for participation regarding the concerning event by using the WordPress plugin “WPForms” by WPForms LLC. The processed data include, in particular, name, name of organisation / institution / company (if applied), sex, E-Mail, phone number, postal address and personal comments. The concerned data will be only processed and stored by the provider of this online service within the European Union.

Use of Facebook social plugins

On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 (1) lit. GDPR) we use social plugins (“plugins”) of the social network facebook.com, which operated by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland (“Facebook”). For this, e.g. content such as pictures, videos or text and buttons belong, with which users can share contents of this online-offer within Facebook. The list and appearance of Facebook Social Plugins can be viewed here: https://developers.facebook.com/docs/plugins/

Facebook is certified under the Privacy Shield Agreement, providing a guarantee to comply with European privacy legislation (https://www.privacyshield.gov/participantid=a2zt0000000GnywAAC&status=Active).

When a user invokes a feature of this online offering that includes such a plugin, their device establishes a direct connection to the Facebook servers. The content of the plugin is transmitted by Facebook directly to the device of the user and incorporated by him into the online offer. In the process, user profiles of the processed data can be created. We therefore have no influence on the extent of the data that Facebook collects with the help of this plugin and therefore informs users according to our level of knowledge.

By integrating the plugins, Facebook receives the information that a user has accessed the corresponding page of the online offer. If the user is logged in to Facebook, Facebook can assign the visit to his Facebook account. If users interact with the plugins, for example, press the Like button or leave a comment, the information is transmitted from your device directly to Facebook and stored there. If a user is not a member of Facebook, there is still the possibility that Facebook will find out and save their IP address. According to Facebook, only an anonymous IP address is stored at our websserver, located in France.

The purpose and scope of the data collection and the further processing and use of the data by Facebook, as well as the related rights and setting options for protecting the privacy of users, can be found in Facebook’s privacy policy: https://www.facebook.com/about/privacy/

If a user is a Facebook member and does not want Facebook to collect data about him via this online offer and link it to his member data stored on Facebook, he must log out of Facebook and delete his cookies before using our online offer. Other settings and inconsistencies regarding the use of data for promotional purposes are possible within the Facebook profile settings: https://www.facebook.com/settings?tab=ads or via the US-American site https://www.aboutads.info/choices/ or the EU page https://www.youronlinechoices.com/. The settings are platform independent. This means, that they are adopted for all devices, such as desktop computers or mobile devices.

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