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Privacy Policy

Version: November 2020

Every time you visit our website, use any of our services, subscribe to our newsletter, access any of our platforms, or contact us, you will be subject to the application of the Privacy Policy in force at all times, and you should review this text to verify that you are satisfied with it.

This Privacy Policy is intended to help you understand what data we collect and what we do with it. Our Privacy Policy explains:

what information we collect and why we collect it;
how we use that information;
the choices we offer, including how to access and update information.

1. Entity Responsible for Processing

CONTINUING EDUCATION INSTITUTE FOUNDATION (hereinafter, "UPF-BSM" or the "Foundation"), in its capacity as Data Controller, takes the privacy of users very seriously and undertakes to make every effort in their power to respect it.

For the purposes of this policy, we understand as user any category of interested parties included in this document.

When users visit the website https://www.bsm.upf.edu/es, as well as any of our Electronic Resources that we make available to you (hereinafter the "Site" or "Website" and/or the Electronic Resources), request information, request or contract any of our services, or subscribe to our newsletter, UPF-BSM can process your personal data.

The UPF-BSM identification details are:
Identity: CONTINUING EDUCATION INSTITUTE FOUNDATION
CIF: G-60414182
Registry of Foundations: number 766 by virtue of a resolution issued on 25 March 1994 by the Counsellor of Justice.
Address: Balmes 132–134, 08008, Barcelona
Telephone: +34 93 542 18 00
Email: rgpd@bsm.upf.edu

2. Personal data that we process

We collect personal data in the following ways:

Personal data that you provide to us: when you fill in any of the forms available to you on our Website or in our Electronic Resources or any physical form, whether for registration or attendance at activities, or when you register and/or access our Website or our Electronic Resources, when you contract any of our activities, services and programing or when you subscribe to our newsletter.
Through Cookies and similar technologies: when you visit our Website or our Electronic Resources, we use various technologies to collect and store information and this may include the use of cookies or similar technologies to identify your browser or device. We also use these technologies to collect and store information when you interact with services that we offer (such as paying the reservation fee for tuition), or other Google functions that may appear on other sites. You can obtain more information about how we process your personal data obtained through cookies in our Cookies Policy.

Said personal data can be generally grouped into the following categories:

Identifying data: name, surname, physical address and email address, marital status, image.
Academic data: academic record, qualifications, degrees, level of languages.
Economic-financial data: information on economic and financial situation (income, financial and fiscal situation, current account).
Professional data: CV, company where you work, occupation.
Data for profiling: interests, hobbies.
Data that identifies connection data: IP, logs.

Likewise, we process personal data of different categories from interested parties which, by way of example and not limited to, include the following:

Users of the Website and Electronic Resources: personal data of users who contact UPF-BSM through our Website or who use any of the Electronic Resources to which we give them access or, failing that, to any resources that they can freely access or who subscribe to the UPF-BSM newsletter.
Students: personal data of individuals enrolled in the academic programs organized and taught by UPF-BSM, directly and/or in collaboration with third parties (whether they are other educational entities in higher education or entities of any kind with activities related to the teaching of the program or with the field of knowledge that the program deals with), using any channel (open training or in-company training) and in any modality (face-to-face, blended or online).
Alumni: alumni of any of the programs organized or taught by UPF-BSM.
Collaborators/suppliers: academic collaborators, speakers, lecturers, service providers of any kind.
Client companies: companies that contract training from UPF-BSM for their employees or collaborators.

3. Purposes of Processing, Legal Basis, and Period of Preservation of Personal Data

As we have previously mentioned, we process personal data obtained through various channels. Likewise, regarding said personal data, we process based on the different categories of the interested parties and in accordance with different purposes:

3.1. Purposes of processing for USERS of the Website and Electronic Resources

The personal data obtained through the Website and the UPF-BSM Electronic Resources will be processed for the following purposes:

1. Responding to requests for information and/or inquiries made by the user.

Preservation period: during the resolution of the request and/or inquiry made by the user, up to a maximum of 5 years, after the appropriate prescriptive period has elapsed.

Legal basis: application of pre-contractual measures based on your request and/or inquiry, so that UPF-BSM can attend to it.

2. Enabling the use of the functionalities made available on the Website, including the contracting of and/or subscription to the academic programs offered therein, which include user attendance at events (conferences and information sessions, or other acts of a similar nature) promoted through the Website and the request for pre-registration or information about the different courses/masters/postgraduate courses and conferences offered on the Website or in the different Electronic Resources, as well as the sending of the newsletter to those who have subscribed to it.

Preservation period: as long as the contractual and/or pre-contractual relationship between the user (candidate, student, or subscriber to the newsletter) and the UPF-BSM is maintained. And once completed, the period necessary to comply with applicable legal obligations (Organic Law 6/2001, of 21 December, on Universities and further regulations, including regulations issued by the Pompeu Fabra University and/or the UPF-BSM itself).

Legal basis: execution of the contractual and/or pre-contractual obligations assumed by the user and UPF-BSM through the Website.

3. In the event that the user sends UPF-BSM their CV and/or a job application, their data will be processed in order to attend to said request and, where appropriate, allow them to participate in the selection processes for a job position at UPF-BSM.

Preservation period: all CVs are destroyed after a year has elapsed from their receipt, so if the user wishes to continue being part of the UPF-BSM database for possible future vacancies, they must resend their CV once this period has passed.

Legal basis: user consent when submitting their CV and/or a job application.

4. Registering donations: we will record the data of users who are donors of funds for scholarships or funds for the financing of the Institution and its activities. Your data will be processed following the usual procedures for donations to foundations: accounting, issuance of certificates, and communication to the tax administration, as well as registration and preservation of documentation for the purposes of compliance with obligations regarding the prevention of money laundering.

Preservation period: the prescriptive period necessary to meet the obligation to send to the Tax Administration an informative statement on the certifications issued for the donations and contributions received during each calendar year, as well as obligations with regards to transparency and preservation of registration data, and supporting documentation required by the regulations on the prevention of money laundering

Legal basis: necessary for compliance with legal obligations applicable to UPF-BSM (Law 49/2002, of 23 December, on the tax regime of non-profit entities and tax incentives for Sponsorship, Law 19/2014 of 29 December on transparency, access to public information and good governance, Law 10/2010 of 28 April on the prevention of money laundering and terrorist financing, and any others that may be applicable).

3.2. Purposes of processing for STUDENTS

1. Management of applications for enrolment in the programs offered by UPF-BSM.

Preservation period: as long as the academic relationship between the student and UPF-BSM is maintained. And once completed, the period necessary to comply with applicable legal obligations (Organic Law 6/2001, of 21 December, on Universities and further regulations, including regulations issued by the Pompeu Fabra University and/or the UPF-BSM itself).

Legal basis: execution of the academic and contractual obligations assumed by the student and UPF-BSM, within the framework of the training programs taught by the latter.

2. Formalizing, enrolment, administrative management, execution, and development of training programs, and access to the Electronic Resources in which, wholly or in part, the teaching of the programs, and all teaching activities of the UPF-BSM are carried out.

Legal basis: execution of the academic and contractual obligations assumed by the student and UPF-BSM, within the framework of the training programs taught by the latter.

3. Management of scholarships and aid for studies for our university community.

Preservation period: as long as the relationship between the student and UPF-BSM is maintained. And once completed, the prescriptive period necessary to meet the obligation to justify the expenses paid out.

Legal basis: necessary for compliance with legal obligations applicable to UPF-BSM (Law 35/2006, of 28 November, on Personal Income Tax and, as applicable, Law 38/2003, of 17 November, General Subsidies).

4. Professional guidance services (Careers/External academic internships/Job Bank).

Preservation period: regarding the services provided by professional careers and external academic internships, as long as the academic relationship between the student and UPF-BSM is maintained. And once completed, the period necessary to comply with applicable legal obligations (Organic Law 6/2001, of 21 December, on Universities and further regulations, including regulations issued by the Pompeu Fabra University and/or the UPF-BSM itself). Regarding Job Bank services, until the moment the student withdraws their consent for said processing, the data being able to be kept for a maximum of five (5) years, after the appropriate prescriptive periods have elapsed.

Legal basis: regarding the services provided by professional careers and external academic internships, the execution of the academic and contractual obligations assumed by the student and UPF-BSM, within the framework of the training programs taught by the latter. Regarding the Job Bank, the specific and affirmative consent given by the student when requesting enrolment in any of the professional guidance services.

5. Segmentation and profiling, statistical study of the services and content used, tastes and preferences, and surveys or forms.

Preservation period: until the moment in which the student withdraws their consent for said processing, the data being able to be kept for up to a maximum of one (1) year, after the appropriate prescriptive periods have elapsed.

Legal basis: Consent of the student.

3.3. Purposes of processing for ALUMNI

1. Maintenance of the UPF-BSM Alumni program for managing relations with alumni.

Preservation period: as long as the contractual and/or pre-contractual relationship between the Alumni and UPF-BSM is maintained and also in accordance with the legal obligations that UPF-BSM has as a postgraduate higher education and continuous training centre. And once completed, the period necessary to comply with applicable legal obligations (Organic Law 6/2001, of 21 December, on Universities and further regulations, including regulations issued by the Pompeu Fabra University and/or the UPF-BSM itself).

Legal basis: execution of the contractual and/or business obligations assumed by the Alumni and UPF-BSM, within the framework of the Alumni program offered by the latter and also in accordance with the legal obligations that UPF-BSM has as a postgraduate higher education and continuing education centre.

2. Organization of activities and events for former students.

Preservation period: as long as the contractual and/or pre-contractual relationship between the Alumni and UPF-BSM is maintained and also in accordance with the legal obligations that UPF-BSM has as a postgraduate higher education and continuous training centre. And once completed, the period necessary to comply with applicable legal obligations (Organic Law 6/2001, of 21 December, on Universities and further regulations, including regulations issued by the Pompeu Fabra University and/or the UPF-BSM itself).

3. Management of the Alumni portal.

4. Guidance and professional development services (Job Bank).

Preservation period: regarding the professional guidance and development services other than the Job Bank, as long as the contractual and/or pre-contractual relationship between the Alumni and UPF-BSM is maintained and also in accordance with the legal obligations that UPF-BSM has as a postgraduate higher education and continuous training centre. And once completed, the period necessary to comply with applicable legal obligations (Organic Law 6/2001, of 21 December, on Universities and further regulations, including regulations issued by the Pompeu Fabra University and/or the UPF-BSM itself). Regarding Job Bank services, until the moment the Alumni withdraws their consent for said processing, the data being able to be kept for a maximum of five (5) years, after the appropriate prescriptive periods have elapsed.

Legal basis: regarding the professional guidance and development services other than the Job Bank, execution of the contractual and/or business obligations assumed by the Alumni and UPF-BSM, within the framework of the Alumni program offered by the latter and also in accordance with the legal obligations that UPF-BSM has as a postgraduate higher education and continuous training centre. Regarding the Job Bank services, the specific and affirmative consent given by the student when requesting enrolment in any of the professional guidance services.

3.4. Purposes of processing for COLLABORATORS/SUPPLIERS

1. Managing orders established in the contract, including the planning of activities and the administration of remuneration and other relevant benefits for the collaborator/supplier.

Preservation period: as long as the contractual and/or pre-contractual relationship between the collaborator/supplier and UPF-BSM is maintained. And once completed, up to a maximum of five (5) years, after the appropriate prescriptive periods have elapsed.

Legal basis: execution of contractual and/or business obligations assumed by the collaborator/supplier and UPF-BSM.

3.5. Purpose of processing for CLIENT COMPANIES

1. Managing orders established in the contract, including the planning of activities and the administration of the fees to be paid.

Preservation period: as long as the contractual and/or pre-contractual relationship between the client company and UPF-BSM is maintained. And once completed, up to a maximum of five (5) years, after the appropriate prescriptive periods have elapsed.

3.6. Processing purposes common to all categories of interested parties (web and platform users, students, Alumni and collaborators/suppliers).

1. Keeping the interested party informed, including by electronic means, about the products, services, UPF-BSM news, publications, invitations, programmes, newsletter, activities, and events of the institution provided that said user has conveyed their express consent to said processing or it is covered by any of the cases authorized by law (e.g. Article 21.2 Law 34/2002 on services for the information society and electronic commerce).

Preservation period: until the moment in which the interested party withdraws their consent for the receipt of said communications, with the data being able to be kept for up to a maximum of one (1) year, after the appropriate prescriptive periods have elapsed.

Legal basis: the existence of a prior contractual relationship in the terms provided for in Article 21.2 of the Information Society Services Law or the consent of the interested party, provided that they have not expressed their opposition.

4. Destination

In accordance with the provisions of the processing purposes indicated in the previous point, the personal contact data of users of the Website and Electronic Resources, students, Alumni, collaborators/suppliers, and client companies will be communicated to the Pompeu Fabra University and/or the educational authorities and/or regional, state and/or international quality agencies, as well as national or international accreditation agencies or institutions, always in execution of the contractual or pre-contractual obligations assumed between said interested parties and UPF-BSM or in compliance with the legal obligations imposed on UPF-BSM as a centre attached to a public university in accordance with the regulations in force at all times. You can consult the details of these third parties by requesting it from rgpd@bsm.upf.edu.

Regarding the personal data of users who may make donations in favour of UPF-BSM, such data will be provided to the Tax Agency in compliance with UPF-BSM's tax obligations, as well as to appropriate control authorities or bodies, if deemed necessary or when imperatively required by the regulations on the prevention of money laundering.

Regarding the personal data of students and certain collaborators/suppliers, we may communicate their data to academic entities collaborating in international or European programmes to which said student has subscribed or in which said collaborator/supplier participates. Said communication will be made based on the programme's own management and execution.

Likewise, we inform you that your Personal Data may be accessed by third parties acting on behalf of UPF-BSM, provided that such access and data processing is essential for the provision of a specific service to the Foundation. Under this scenario, UPF-BSM will in all cases sign the corresponding processing manager contract with each of the said third parties, who will process said data exclusively for the purposes that UPF-BSM determines in each case.

As such, for the sending of commercial communications, we may use the MailChimp platform, which implies transferring the user's data to a data controller located in the United States, The Rocket Science Group LLC, the company that owns said platform, which is a member of Privacy Shield (www.privacyshield.gov) with relation to the protection of personal data. Likewise, Mailchimp collects connection data (including your email and IP address) through its tracking technologies, which may also be transferred.

5. Rights

Interested parties may exercise the following rights related to their personal data and UPF-BSM: access; rectification; deletion; limitation of processing; data portability; and opposition.

Similarly, with regards to the processing of user data whose legitimacy is based on consent given by the user, the user has the right to withdraw such consent at any time, without affecting the legality of the processing based on the consent prior to its withdrawal.

In order to exercise such rights, the interested party should send their request, attaching a copy of their ID, passport, or other valid document that identifies them, to Balmes 132–134, 08008, Barcelona; or by using the following email address: rgpd@bsm.upf.edu.

In the event that you believe we have failed to comply with our data protection obligations, you have the right to file a complaint with the Spanish Data Protection Agency (www.aepd.es).

Finally, we remind you that if you provide us with data relating to another natural person, you must, prior to their inclusion, inform them of the points contained in this Policy.

6. Data Protection Officer

The Data Protection Officer (DPO) is the person who oversees compliance with our data protection policy, ensuring that data is processed properly and that the rights of individuals are protected. The Officer's functions include answering any questions, suggestions, complaints, or claims from the people whose data we process. You can contact the Data Protection Officer by writing to our postal address or directly to dpd@bsm.upf.edu.

Changes or modifications to our privacy policy

We may change or modify this Privacy Policy from time to time and post the most current version on our website. We will inform you in the event that your rights are appreciably affected as a result of a change or modification.