Through this Policy (hereinafter, the "Privacy and Cookies Policy"), the privacy and cookies policy of the Web Platform www.southsummit.co/en (hereinafter, the "Platform") is regulated, under the ownership of SPAIN STARTUP AND INVESTOR SERVICES, S.L. (“SPAIN STARTUP”), a Spanish company registered in the Madrid Mercantile Register. With registered office located at calle Monte Esquinza 28, 28010 Madrid, with Tax ID B-86685294.
The Platform is a mechanism for interaction, communication and support that SPAIN STARTUP makes available to Internet users in order to provide them with sufficient, legal and adequate information on their activities, products and services in relation to their legitimate economic and business activities, which are governed by the applicable Spanish regulations and, as far as they are concerned:
To the provision of information society services, on a basic basis, by Law 34/2002, of 11 July, on information society services and electronic commerce.
The processing of personal data, by the current Spanish and European regulations on the protection of personal data of individuals. In particular, Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (hereinafter referred to as "RGPD") shall apply directly as from 25/05/2018, in accordance with the provisions of this Regulation.
In any case, the user undertakes to make appropriate and lawful use of the Platform and the contents, products and services available from it, in accordance with the applicable legislation at all times.
Likewise, the user of the Platform is specifically committed to the following:
Guarantee the authenticity, truthfulness, timeliness and accuracy of all the data that you communicate to SPAIN STARTUP, such user being the only responsible party in the opposite case.
To use the platform exclusively for the purposes and functionalities provided by SPAIN STARTUP, presenting such functionalities as they are on the part of SPAIN STARTUP, and the user is prohibited from using the Platform for any other purpose or means.
Make legal and legitimate use of the Platform, avoiding any unauthorised, fraudulent, illegal or illegitimate use of the Platform and/or the contents and information made available through it, avoiding any violation of this policy and the applicable regulations, and damaging the rights and legitimate interests of SPAIN STARTUP, or any other third party that may be affected as a result of such action.
Not to cause damage to the systems or elements associated with the Platform, its suppliers or third parties, or to attempt to breach the security or authentication measures of the same, to carry out any action that causes a disproportionate or unnecessary saturation in the infrastructure or communications environment related to the Platform or attacking it in any other way. SPAIN STARTUP may adopt any preventive or corrective measures that may be necessary to protect its interests in order to ensure the correct functioning of the Web Platform and the specific functionalities provided in each case.
Not to introduce or spread through the Platform computer viruses or malware that are likely to cause damage.
Not to attempt to access, use and/or manipulate the data of SPAIN STARTUP or under its responsibility, or of third party providers and other users.
In particular, the user undertakes not to transmit, disseminate or make available to third parties any information, data, contents or messages that may constitute a violation of the rights of SPAIN STARTUP or of third parties.
Not to access without authorization or interact with a false identity, impersonating or not impersonating third parties or using a profile or performing any other action that may generate confusion or mislead about the correct identification of the user in question.
In any case, it should be noted that this Platform is intended for users over 18 years of age.
The information and personal data provided by users who intend to browse or register on the Platform must be:
Sufficient, although adjusted, limited and proportionate to the legitimate purposes of processing informed by SPAIN STARTUP, with the utmost respect for the principles of purpose limitation and minimisation of personal data (Articles 5.1(b) and (c) of the RGPD).
Accurate, up-to-date and truthful, in order to be able to properly verify identity, capacity, and, when appropriate, representation of the user concerned, as well as being able to adjust, in each case, the data processing carried out to the specific needs and actual situation of the users. All of this is in accordance with the principle of accuracy of personal data (5.1.d) of the RGPD).
Users are fully responsible for the correct use of their user accounts and the keys associated with them. If the registered user considers that the security of his/her account and associated passwords may have been compromised, he/she must immediately contact SPAIN STARTUP using the contact details provided at the beginning of this Policy and report the situation or incident in question so that SPAIN STARTUP can take the appropriate measures as from the moment of the communication made by the user. All liability for damages and losses associated with improper use and personal management of the associated accounts and keys shall be borne by the users who hold such accounts, and SPAIN STARTUP shall be absolutely exempt as a result of the foregoing.
In compliance with the current personal data protection regulations, and with particular regard to the provisions of Articles 12 to 14 of the RGPD, you are hereby informed of the following:
That the data controller is SPAIN STARTUP AND INVESTOR SERVICES, S.L., with registered office and fiscal address at calle Monte Esquinza 28, 28010 Madrid and with Tax Identification Number B-86685294 and website https://www.southsummit.co/en and contact e-mail address: email@example.com
To enable users to navigate through it, thus allowing them to access the information and contents available on the Platform, including information on promotional or advertising campaigns aimed at contracting SPAIN STARTUP products and services.
To attend the specific requests that users may make in this field, specifically the purchase of tickets and registration for the various events organized by SPAIN STARTUP, as well as the registration of participants in the Startup Competition.
Adopt all applicable protection measures in accordance with current legislation, including the possible anonymisation of your personal data by applying the appropriate techniques available for this purpose. Therefore, in this area, anonymization and pseudonymization treatments may also be performed for the best protection of your personal data.
To apply the pertinent security, technical and/or organisational measures on the personal data of the users that are appropriate in view of the risks detected in relation to their rights at all times by SPAIN STARTUP, including the encryption of personal data and other measures that may involve certain processing of the data of the users of the Platform.
In the event that you do not agree to such processing purposes, we urge you to leave our Platform immediately. Otherwise, for example, by accepting this policy, or simply by continuing to browse the Platform, with prior knowledge of the information contained in this policy, it will be understood that the user unequivocally consents to the purposes of treatment previously informed. For this purpose, the provisions of paragraph 4 of this policy regarding consent and the rights of users in this area shall also be complied with.
That the legitimate basis for processing is, primarily, the consent of the user, so that, once informed of this policy, if the user accepts it, or simply continues browsing the Platform will be understood to give their consent to the processing of their personal data for the purposes indicated. Therefore, if a user does not agree with this policy or the informed processing purposes, as indicated above, he/she is urged not to continue browsing and to leave the Platform immediately. In the event of a specific request or contract by users for certain content, products or services through the Platform, the main basis for processing shall be that relating to the necessary application of pre-contractual measures at the request of the interested party, when this is the case, or that relating to the execution of a contract in the event that the user finally contracts the content, product or service that runs on the Platform.
When personal contact details are collected from startups participating in the competition through the Platform, they may be transferred to collaborating entities, promoters, organisers and other participants in the competition ("Partners") of STARTUP SPAIN with the aim of promoting your company and contacting you due to the interest generated as a result of your participation in the competition.
Apart from these cases, the personal data of the users will not be transferred to any other third party, except with the consent of the user or, where applicable, any other basis for legitimating the processing as provided for in article 6 of the RGPD, such as, for example, the due fulfilment of a legal obligation by SPAIN STARTUP (lawfulness of processing).
That, in general, there are no plans for international transfers of your personal data, and that the necessary measures in this area will be taken in accordance with the RGPD if this is not the case.
That you may exercise your rights of access, rectification, deletion, limitation of processing, data portability and opposition by sending a written communication to firstname.lastname@example.org with the Ref. "Exercise Rights" accompanying your request with a copy of your national identity card or equivalent identification document (passport, N.I.E.....). If your personal rights are not duly taken into account, you may file a complaint with the competent supervisory authority, in this case the Spanish Data Protection Agency.
The user will be able to choose the processing and destination of his/her data, according to his/her specific interests and needs in each case, so that, when the processing is based on his/her consent, he/she will have the right to withdraw it at any time, although such withdrawal will not in any way affect the lawfulness of the prior processing carried out by SPAIN STARTUP.
In any case, SPAIN STARTUP may prevent the use of the Platform and the services, contents and functionalities associated with it if the user does not accept this policy or does not consent to the processing of his/her personal information in accordance with its provisions.
The acceptance of this policy is independent of the possible acceptance of the legal terms and conditions of a particular type that may govern the specific contracting by users of the services and products available through the Platform.
SPAIN STARTUP has adopted and applies the levels of security required by the applicable legislation with respect to personal data under its responsibility, in accordance with the corresponding risk approach adopted, and endeavours to install and/or apply additional technical or organisational means and measures of protection in order to reinforce the general security of processing with personal data, systems, communications environment and corporate organisation, as well as to guarantee due protection against unauthorised or illicit processing and against loss, destruction or incidental damage (principle of integrity and confidentiality). However, the user must be aware that Internet security measures are by no means impregnable and are in keeping with the state of the art at all times and the cost of their application.
To this end, it shall give special consideration to the application criteria and security measures and other security obligations associated with the RGPD, with special attention to the provisions of Article 32 of the RGPD.
SPAIN STARTUP undertakes to comply with the duty of secrecy and confidentiality with regard to the information and personal data provided by the users of the Platform, and that is under its control and responsibility, in accordance with the applicable legislation and the risk approach that corresponds at all times.
7.1. Applicable legislation:
Article 22 of Law 34/2002, of 11 July, on Information Society and Electronic Commerce Services (LSSICE), concerning the rights of recipients in commercial communications by electronic means, service providers may only use data storage and retrieval devices on the recipient’s terminal equipment when they have given their prior informed consent.
To this end, these recipients and end-users shall be provided with clear and complete information on their use, in particular on the purposes for which the data are processed, in accordance with the provisions of the personal data protection legislation. Therefore, where technically possible and effective, the consent of the recipient to the processing of the data may be given by using the appropriate parameters of the browser or other applications.
This shall not prevent any technical storage or access for the sole purpose of carrying out the transmission of a communication over an electronic communications network or, to the extent strictly necessary, for the provision of an information society service expressly requested by the recipient.
7.2. User consent and cookies: general rule and exception
Only those that allow, exclusively, communication between the user’s equipment and the network and, strictly speaking, those used to provide a service requested by the user, are exempt from such consent. For example, the so-called "technical cookies" (e.g., those required for the same navigation on the platform or application); "personalization or configuration cookies" (e.g., those that allow the page to recognize the user’s language, etc.); and "security cookies" (e.g., those that detect repeated and erroneous attempts to connect to a site) would be excluded.
7.3. What are the cookies you use on the platform?
Cookies are used on the Platform, i.e. files or devices that are downloaded to the user’s terminal equipment (personal computer, a smartphone, a tablet, mobile terminals and devices, etc.), regardless of their nature, and with the main purpose of guaranteeing the correct operation of the Platform (remembering the selected language, and similar functions). Thus, in general, and without prejudice to the provisions below, cookies will allow browsing the Platform, as well as certain utilities and services provided on the same, so you are warned that their disabling or blocking may affect browsing or the correct or widespread use of it by the user.
7.4. What cookies do we use on the Platform?
Cookies may be owned by us and third parties. Own cookies are those that are sent or served to the user’s terminal equipment from the Platform (editor) being managed by the Platform, while third party cookies are those that are sent or served to the user’s terminal equipment from other domains or equipment not managed by the Platform (editor), but by another entity that processes the data obtained through cookies.
Also, the above cookies may be session cookies or persistent cookies. The first are a type of cookie designed to collect and store data while the user accesses the Platform with the main purpose of storing information that is only interested in keeping for the provision of the service requested by the user on a single occasion. However, with the latter, the data remains stored in the user’s terminal and can be accessed and processed for a period defined by the person responsible for the cookie.
Cookies can also be technical by allowing the user to navigate through the Platform and use the different options or services available through it, for example, to control traffic and data communication, identify the session, access restricted areas, remember the elements that make up a contractual request, use security elements during navigation, store content for video or sound broadcasting or share content through social networks.
They can also be personalised, referring to those that allow the user to access the service with some predefined characteristics according to certain criteria associated with their own terminal, for example, the type of browser through which they access the service, the regional configuration from which they access the service, etc.
Likewise, they may have a statistical or informative purpose for the publisher regarding the particular use that users make of its Platform and the contents or services available through it.
Below is an informative summary table of the specific cookies that SPAIN STARTUP currently uses on the platform:
|Session||Technical||Own||Session||Guarantee the correct functioning of the site, maintaining the user’s session.|
|Language||Customization||Own||Permanent||Store the user’s preferred language so as not to ask for their preferences each time they access the website.|
|Remember me||Customization||Own||Permanent||To remind the connected user, avoiding entering their credentials every time they access the site. Upon user’s request.|
|Google Analytics I||Statistic||Alien||Permanent||Generate a unique user identifier, which is used to count how many times a user visits the site, as well as as the date of the first and last time that visit the web.|
|Google Analytics II||Statistic||Alien||Session||Allow to distinguish users|
|Google Analytics III||Statistic||Alien||Session||Limit the percentage of requests|
The information that is collected through the cookies that are served through the Platform may be used, either by the owner of the same, or by a third party that provides a service to this owner.
7.6. Management and configuration of cookies.
Based on the information provided in this policy, we offer you information on how you can manage the cookies used on the Platform through the different options offered by the most common browsers.
SPAIN STARTUP reserves the right to modify this policy in order to adapt it to future legislative, doctrinal or jurisprudential changes that may be applicable, or for technical, operational, commercial, corporate and business reasons, informing users in advance and reasonably of any changes that may occur whenever possible. In any case, it is recommended that each time you access this Platform, you read this policy in detail, as any changes will be published through it. SPAIN STARTUP may also inform users personally and in advance of any changes to this policy prior to its entry into force, provided that this is technically and reasonably possible, in particular when they are considered to be registered users or customers of SPAIN STARTUP.
The protection of your rights is important to SPAIN STARTUP, so if you have any questions or suggestions regarding this policy, please do not hesitate to contact us at the following e-mail address: email@example.com