Privacy Policy

In compliance with Regulation (EU) 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 on the free movement of such data (GDPR), as well as the provisions of Organic Law 3/2018 of 5 December, of Protection of Personal Data and Guarantee of Digital Rights (LOPD-GDD), you are hereby informed that the Data Controller of your personal data is:

Company name: DZW LIMITED

Registered office: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ

Company Number: 7221273

Email: editorial@bridgingthegap.ink

As Data Controller, DZW LIMITED, hereinafter THE ASSOCIATION, informs its users of the following PRIVACY POLICY;

THE ASSOCIATION, as the data controller, will request, prior to the provision of your personal data, your consent in relation to the Privacy Policy set out herein, in the cases that it is necessary. Likewise, THE ASSOCIATION undertakes to request your consent in relation to any aspect that requires prior authorisation by virtue of the law and regulations in force.

All personal data provided by the interested party and collected by THE ASSOCIATION, whatever the means (contracts, requests for information, e-mails or any other source) are subject to automated processing and are incorporated into the files that THE ASSOCIATION maintains in accordance with the provisions of current legislation.

The services and website of THE ASSOCIATION are not directly aimed at minors in accordance with Spanish law. By accepting the Privacy Policy of THE ASSOCIATION, the client or user declares and guarantees that they are of legal age in accordance with the aforementioned legislation.

WHAT PERSONAL DATA DO WE COLLECT?

To browse https://www.bridgingthegap.ink/ you do not need to provide any personal data. The cases in which you do provide your personal data are the following:

By contacting through the contact form or sending an email.

Name and surname

Email address

IP address, date and time you accessed our services, number of times you accessed, pages you visited on our website and how long you were on them, location, the device used to access our website.

Any other information or data you choose to share with us.

WHY AND FOR WHAT PURPOSE DO WE PROCESS YOUR DATA?

We process the information provided by interested parties for the following purposes, with the essence of information and marketing, duly differentiated, as well as others specific to the activity of THE ASSOCIATION. When you connect to the Website to send an email to the Owner, subscribe to their newsletter or make a contract, you are providing personal information for which the Owner is responsible. The processing of Personal Data of associates, potential associates and/or information requesters, collected through the https://www.bridgingthegap.ink/ website will be carried out for the following purposes:

AFFILIATION TO THE ASSOCIATION through the website of THE ASSOCIATION, the purpose will be to formalise the contractual relationship, maintain the contractual relationship, as well as the management, administration, information, provision and improvement of the service;

SENDING OF REQUESTED INFORMATION through the forms provided on the website of THE ASSOCIATION, the purpose will be to maintain the relationship with the applicants for information in order to respond to messages, doubts, complaints, comments or concerns that may exist regarding the services or information included on the website or the processing of their personal data;

SENDING INFORMATION OF INTEREST. If the express sending of advertising is accepted, newsletters may be sent, as well as commercial communications of promotions and/or advertising from THE ASSOCIATION in order to respond to your request.

TO GUARANTEE COMPLIANCE WITH THE CONDITIONS AND SECURITY MEASURES ESTABLISHED AND EXPLAINED ON THE WEBSITE. This may include developing tools and algorithms that help this website ensure the confidentiality of the personal data it collects; support and improve the services offered by this website; or similar.

The personal data and the purpose of the processing by the Owner are different depending on the information capture system:

Contact forms: THE ASSOCIATION requests personal data which may include: Name and surname and email address in order to respond to your queries.

There are other purposes for which your personal data may be requested:

To analyse navigation. The Owner collects other non-identifying data that is obtained through the use of cookies that are downloaded to your computer when you browse the website, the characteristics and purpose of which are detailed in the Cookie Policy.

To manage social networks. THE ASSOCIATION has a presence on social networks. If you become a follower on the Owner’s social networks, the processing of personal data will be governed by this section, as well as by those conditions of use, privacy policies and access regulations that belong to the social network that is appropriate in each case and that you have previously accepted.

We inform you that the personal data obtained as a result of your registration as a user will be part of the Register of Processing Activities and Operations (RAT), which will be updated periodically in accordance with the provisions of the GDPR.

LEGITIMATION

The legal basis for the processing and collection of Personal Data is:

Express consent granted by the user in a free, specific, informed and unequivocal manner through a clear affirmative action such as the ticking of a box provided for this purpose, or that requested by THE ASSOCIATION and granted by the same [art. 6.1 a) of the GDPR];

Establishment of a pre-contractual or contractual relationship between THE ASSOCIATION and the client [art. 6.1 b) of the GDPR], without the withdrawal of such consent conditioning the execution of the contractual relationship where applicable;

Legitimate interest in the processing of our customers’ data in direct marketing actions and express consent of the interested party for all matters relating to possible automatic assessments and profiling [art. 6.1 f) of the GDPR], and;

Compliance with legal obligations for invoicing, fraud prevention, communication with public authorities and third-party complaints (Art. 6.1 c) GDPR).

RIGHTS OF THE DATA SUBJECT (THE CONSUMER OR USER WHO PROVIDES THEIR DATA)

We remind you that you can oppose the sending of commercial communications by any means and at any time, as well as reject the automated processing of the personal data collected and/or exercise the rest of your ARCO rights by sending an email to the editorial@bridgingthegap.ink email address.

ARCO RIGHTS. The interested parties have the right to request access to their personal data, its rectification, deletion or portability, the limitation of its processing, to oppose the processing, by sending a request, accompanied by a copy of an official identity document, to the address of THE ASSOCIATION. They may also file a complaint with the supervisory authority.

CONSERVATION AND TRANSFER

The conservation of the data of users and customers will last as long as their contractual relationship remains in force, once the contractual relationship that binds the parties has ended, the information will only be kept until the expiry of the limitation period of the responsibilities that THE ASSOCIATION may have incurred for its processing. If, on the other hand, the processing in question is based on the consent of the client or user and the client or user revokes it, in which case they will be kept until the final revocation of said consent.

As an exception to all this, we will find cases in which the conservation is established by legal imperative or because it is necessary for the defence of possible claims, within what is permitted by current legislation, as well as for the period during which legal liabilities may arise for the services provided

During the period of storage of the Personal Data, these will only be transferred either at the time you expressly request it to the person in charge of THE ASSOCIATION by the aforementioned means of communication (email); as well as in response to the exercise by you of rights before the Spanish Data Protection Agency and always to accredit our obligations before said entity; or before any other public or private entity by legal imperative in compliance with the obligations that may be contracted with the different Public Administrations, State Security Forces and Corps and Judicial bodies.

OBLIGATIONS OF THE ASSOCIATION

THE ASSOCIATION undertakes, in accordance with the law and specific regulations, not to make Personal Data public, as well as to its due custody and application of all technical and organisational protection measures and systems in order to guarantee the security of the same, the non-alteration, non-access or unauthorised processing, the loss and due destruction at the relevant time due to the exercise of their rights by the interested party or due to the expiry of the established storage period. Likewise, in order to ensure the confidentiality of the information provided, you are informed that THE ASSOCIATION maintains continuous supervision, control and review of its processes to guarantee the security of said information in accordance with international security standards.

In the same way, you are informed that when THE ASSOCIATION is acting as a Data Processor, it will be subject in the same way to the obligations provided for by law and regulations, and must process the data in accordance with the instructions established by the data controller(s). In any case, THE ASSOCIATION is obliged not to use, for purposes other than those contractually agreed with the data controller, the personal data that may be accessed by the habitual exercise of its professional activity.

For their part, in turn, the client or user is responsible for the veracity, authenticity and accuracy of the data provided, in such a way that the presumption of good faith of THE ASSOCIATION as the owner of the website and service provider is established. If the data turns out to be false or belongs to third parties who have not consented to their delivery, THE ASSOCIATION reserves the right to destroy them as a measure to protect the rights of the owner or owners of the same, exempting itself from responsibility for the irregular obtaining of the personal data in question.

SOCIAL NETWORKS

Through our website you can access the social networks Facebook, X, Instagram or YouTube that are open to all users. These are websites where the user can register and follow us for free. In these social networks, users will be able to learn about our activities, opinions, access photos and videos. Users of these social networks should be aware that this place is independent of the https://www.bridgingthegap.ink/ website and is open, that is, it is visible to all its users, and the privacy policies to be applied to these contents are those set by META, xAI or Google. THE ASSOCIATION is not the owner of the data of these social networks.

DATA PROCESSORS OF THE WEB

As data processors, we have contracted the following service providers, having committed to compliance with the regulatory provisions applicable to data protection, at the time of hiring:

WordPress.org. run by Automattic, located at 660 4th Street, No 119 San Francisco, CA 94107, United States, provides WEBSITE SUPPORT and EMAIL services.

You can consult the privacy policy and other legal aspects of the company at the following link: https://wordpress.org/about/privacy/

Based on the processing of your web data, THE ASSOCIATION uses the services of the cookie provider companies mentioned in the cookies policy document and consequently, these will be in charge of the processing of THE ASSOCIATION, so international data transfers will be made with the USA under the EU-US Privacy Shield agreement. – Information available at: https://www.privacyshield.gov/participant?id=a2zt0000000TOWQAA4

Social Networks. THE ASSOCIATION makes use of the US social networks Facebook, X,  Instagram and YouTube, to which an international transfer of data, of an analytical and technical nature is carried out in relation to the website, being on their servers where THE ASSOCIATION processes the data that, through them, users, subscribers or navigators deliver to THE ASSOCIATION or share with it.

In relation to the retention of data in accordance with the LSSI, THE ASSOCIATION informs that our Data Processor mentioned above, as a data hosting service provider and by virtue of the provisions of Law 34/2002 of July 11 on Information Society Services and Electronic Commerce (LSSI), retains for a maximum period of 12 months the information essential to identify the origin of the hosted data and the time when the provision of the service began. The retention of this data does not compromise the secrecy of communications and may only be used within the framework of a criminal investigation or for the safeguarding of public security, and will be made available to judges and/or courts or the Ministry that requires it.

COOKIES POLICY

For this website to function correctly, it needs to use cookies, which are pieces of information stored in your web browser. On the Cookies Policy page you can consult all the information regarding the collection policy, the purpose and the processing of cookies.

Legitimacy for data processing

The legal basis for the processing of your data is: consent.

TERMS OF USE

In relation to the intellectual property of the software to which collaborators are given access, the user must respect the third-party programmes made available by THE ASSOCIATION, even if they are free and/or publicly available.

In relation to the intellectual property of the hosted contents, the use contrary to intellectual property legislation of the services provided by THE ASSOCIATION is prohibited and, in particular: Use that is contrary to Spanish law or that infringes the rights of third parties.

The publication or transmission of any content that, in the opinion of THE ASSOCIATION, is violent, obscene, abusive, illegal, racial, xenophobic or defamatory.

Cracks, serial numbers of programmes or any other content that violates the intellectual property rights of third parties.

The collection and/or use of personal data of other users without their express consent or in contravention of the provisions of Regulation (EU) 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 on the free movement of such data. The use of the domain’s mail server and email addresses for the sending of unwanted mass mail.

The user is responsible for complying with the laws and regulations in force, as well as the rules governing the operation of the online service, e-commerce, copyright, maintenance of public order, and universal principles of Internet use.

The user or consumer will indemnify THE ASSOCIATION for the expenses generated by the imputation of the latter in any case for which the user or consumer is responsible, including legal defence fees and expenses, even in the event of a non-final judicial decision.

WHO IS RESPONSIBLE FOR THE ACCURACY AND VERACITY OF THE DATA PROVIDED?

The user is solely responsible for the veracity and correctness of the data included, exonerating THE ASSOCIATION from any liability in this regard. Users guarantee and are responsible, in any case, for the accuracy, validity and authenticity of the personal data provided, and undertake to keep them duly updated. The user agrees to provide complete and correct information in the registration or subscription form.

THE ASSOCIATION reserves the right to terminate the contracted services that have been entered into with users, in the event that the data provided is false, incomplete, inaccurate or not updated.

THE ASSOCIATION is not responsible for the veracity of information that is not of its own elaboration and for which another source is indicated, so it does not assume any responsibility for hypothetical damages that may arise from the use of said information.

THE ASSOCIATION reserves the right to update, modify or delete the information contained in its web pages, and may even limit or not allow access to said information. THE ASSOCIATION is exonerated from liability for any damage or harm that the user may suffer as a result of errors, defects or omissions in the information provided by THE ASSOCIATION, provided that it comes from sources other than the ASSOCIATION.

Likewise, the user certifies that they are over 18 years of age and that they have the necessary legal capacity to provide consent regarding the processing of their personal data.

CONTENT FROM OTHER WEBSITES

The pages of this website may include embedded content (e.g., videos, images, articles, etc.). Embedded content from another website behaves in exactly the same way as if you had visited the other website.

These websites may collect data about you, use cookies, embed an additional third-party tracking code, and monitor your interaction using this code.

HOW WOULD WE PROCESS THE PERSONAL DATA OF MINORS?

As we have already specified and warned repeatedly, our services are not aimed at minors and with the acceptance of the Privacy Policy of THE ASSOCIATION you have declared that you are of legal age in accordance with Spanish legislation.

However, in the event that you have proceeded to use the website of THE ASSOCIATION, governed by the provisions of article 8 of the GDPR and article 7 of LO3/2018, of December 5 (LOPDGDD), THE ASSOCIATION, in the event of discovering that the user is under 14 years of age, will require valid consent, free, unequivocal, specific and informed of their legal guardians to process the personal data of minors and to be able to continue with the existing relationship. In this case, the ID card or other form of identification of the person giving consent will be required.

In the case of persons over fourteen years of age, but minors, the data may be processed with the consent of the user, except in those cases in which the Law requires the assistance of the holders of parental authority or guardianship.

WHAT SECURITY MEASURES DO WE APPLY TO PROTECT YOUR PERSONAL DATA?

THE ASSOCIATION has adopted the legally required levels of security for the protection of Personal Data, and seeks to install any other means and additional technical measures at its disposal to prevent the loss, misuse, alteration, unauthorised access and theft of the Personal Data provided to THE ASSOCIATION.

THE ASSOCIATION is not responsible for hypothetical damages that may arise from interferences, omissions, interruptions, computer viruses, telephone breakdowns or disconnections in the operational functioning of this electronic system, caused by causes beyond the control of THE ASSOCIATION; of delays or blockages in the use of this electronic system caused by deficiencies or overloads of telephone lines or overloads in the Data Processing Centre, in the Internet system or in other electronic systems, as well as damages that may be caused by third parties through illegitimate interference beyond the control of THE ASSOCIATION. However, the user must be aware that Internet security measures are not impregnable.

NOTICE

The Privacy Policy of THE ASSOCIATION may be modified in accordance with possible legislative variations by which it is affected, as well as changes in the address of THE ASSOCIATION. In this regard, THE ASSOCIATION will inform you of any modification that may occur in our Privacy Policy, of possible changes in the processing of your personal data and of any modification of internal policies that are related to your personal data so that, if mandatory, you can proceed to grant your consent or revoke it.