Basic Data Protection Information

 

DATA CONTROLLER:

3WALKS
Cristina Ortega Nuere
Tax ID (NIF): 30638184E

 

PURPOSES

To respond to enquiries; manage professional and contractual relationships; organise activities, training courses and events; process applications; and, where authorised, send informational communications.

 

LEGAL BASIS

Consent; steps taken prior to entering into a contract or performance of a contract; legal obligation; and legitimate interest, depending on the specific processing activity.

 

RECIPIENTS

Service providers that provide services to 3WALKS, and public authorities or other third parties where there is a legal obligation. Personal data will not be disclosed to third parties for their own purposes without a valid legal basis.

 

INTERNATIONAL TRANSFERS

International transfers may take place in connection with technology providers, subject to the safeguards required by the GDPR.

 

RIGHTS

Access, rectification, erasure, objection, restriction of processing, data portability, withdrawal of consent and the right to lodge a complaint with the Spanish Data Protection Agency (AEPD).

 

CONTACT

info@3walks.com

 

1. Purpose and scope

This policy explains how 3WALKS processes the personal data of individuals who visit www.3walks.com, use its forms, request information, participate in projects, activities or events, or maintain a professional relationship with 3WALKS.

Personal data will be processed in accordance with Regulation (EU) 2016/679 (GDPR), Spanish Organic Law 3/2018 (LOPDGDD) and any other applicable legislation.

​

2. Data controller

 

Identity:

3WALKS
Cristina Ortega Nuere

Tax ID (NIF): 30638184E

Address: Calle San Vicente, 8, Edificio Albia 1, 3rd floor, Department 9, 48001 Bilbao, Bizkaia, Spain

Telephone: +34 946 056 151

Privacy email: info@3walks.com

​

3. Data processed and sources

Depending on the relationship with 3WALKS, the following categories of personal data may be processed:

• Identification and contact details: first name, surname, email address, telephone number, organisation and position.

• Data included in enquiries and communications: subject, message, preferences and contact history.

• Professional, academic or application-related data: experience, education and training, languages, CV and documentation provided voluntarily.

• Data relating to the management of projects, training and events: registration, attendance, invoicing, organisational requirements, and image or voice recordings where appropriate and where a valid legal basis exists.

• Financial and transactional data necessary for contractual relationships, invoicing and payments.

• Technical browsing data: IP address, online identifiers, device, browser, logs and data derived from cookies, in accordance with the consent settings selected.

• Personal data is obtained primarily from the data subject, from the organisation they represent, through contractual relationships and, where lawful, from publicly available sources or project partners.

​

3.1 Information where personal data is not obtained directly from the data subject

Where 3WALKS obtains personal data from a source other than the data subject, it will provide, in addition to the general information contained in this policy, information on the categories of personal data processed and the source from which the data originated, including, where applicable, whether the data came from publicly accessible sources. Information will also be provided on the purposes of the processing, its legal basis, recipients, international transfers, the applicable retention period or criteria, applicable rights, legitimate interests where relevant and, where applicable, the existence of automated decision-making.

This information will be provided within a reasonable period and, at the latest, within one month of obtaining the data. If the data is used to communicate with the data subject, the information will be provided no later than the first communication; and if disclosure to another recipient is envisaged, no later than the time when the data is first disclosed.

The exceptions provided for in Article 14(5) of the GDPR will apply only where their requirements are effectively met.

Special categories of personal data are not requested. Should such data be required for a specific activity, specific information will be provided and the appropriate safeguards will be applied.

Personal data may be retained in a restricted form for the applicable limitation periods in order to address potential liabilities and requests from public authorities. Once those periods have expired, the data will be securely deleted or anonymised.

​

4. Mandatory nature of data

Fields marked as mandatory are necessary to manage the request or provide the service. Where appropriate, 3WALKS will indicate whether providing specific data constitutes a legal or contractual requirement, or whether it is necessary to enter into a contract, as well as the consequences of failing to provide it. If the necessary data is not provided, 3WALKS may be unable to respond to the request or provide the service.

​

The data subject guarantees that the information provided is accurate and undertakes to notify 3WALKS of any changes.

​

5. Recipients and data processors

3WALKS will not sell personal data or disclose it to third parties for their own purposes, except where consent has been given or there is another sufficient legal basis. Personal data may be accessible to:

• Providers of web hosting, forms, email, storage, IT support, project management, videoconferencing, registration, invoicing or communication services, acting as data processors.

• Partner organisations, funding bodies, educational institutions, speakers, venues or collaborators where necessary for an activity or project and where the data subject has been informed accordingly.

• Public authorities, courts, law enforcement agencies and other bodies where required by law or pursuant to a valid request.

• Advisers, auditors, insurers or other professionals subject to confidentiality obligations, where necessary for the management or defence of legal rights.

 

3WALKS will enter into the agreements required under Article 28 of the GDPR with its data processors and will require appropriate confidentiality and security measures.

​

6. International transfers

Some technology providers may process personal data outside the European Economic Area. Where this occurs, 3WALKS will ensure that an adequacy decision, Standard Contractual Clauses, Binding Corporate Rules or another valid safeguard under the GDPR is in place, together with supplementary measures where appropriate.

Information about international transfers and the applicable safeguards may be requested via the privacy email address specified in Section 2.

​

7. Rights of data subjects

Where applicable, data subjects may exercise the following rights:

• Access: to know whether 3WALKS processes their personal data and to obtain a copy.

• Rectification: to correct inaccurate data or complete incomplete data.

• Erasure: to request the deletion of personal data where there is a legal basis for doing so.

• Objection: to request that processing based on legitimate interest cease, including direct marketing.

• Restriction: to request that processing be restricted in the circumstances provided for by law.

• Data portability: to receive the data provided in a structured format and transmit it to another controller where applicable.

• Withdrawal of consent: to withdraw consent at any time, without affecting the lawfulness of processing carried out prior to its withdrawal.

• Right not to be subject to automated decision-making: to request human intervention where a decision based solely on automated processing produces legal or similarly significant effects. 3WALKS does not envisage making this type of decision.

 

To exercise these rights, a request may be sent to info@3walks.com or to the postal address specified in Section 2, indicating the right to be exercised and providing the information necessary to identify the request. Identification documents will only be requested where necessary to verify the identity of the applicant.

 

As a general rule, 3WALKS will provide information on the action taken in response to a request to exercise rights within one month of receipt. This period may be extended by a further two months where necessary, taking into account the complexity and number of requests. In such cases, the data subject will be informed of the extension and the reasons for it within the first month.

If you believe that the processing of your personal data does not comply with applicable legislation, you may lodge a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos – AEPD) at www.aepd.es. Before lodging a complaint, you may contact 3WALKS to seek to resolve the matter.

​

8. Minors

The website’s general services are not specifically intended for children under the age of fourteen. If an activity may involve their participation, 3WALKS will provide specific information and obtain authorisation from those exercising parental responsibility or guardianship where legally required.

​

9. Cookies and similar technologies

The website may use necessary technical cookies and, only with consent where required, analytical or other types of cookies. Detailed information on their name, provider, purpose, duration, international transfers and how to accept, reject or withdraw consent must be provided in the Cookie Policy and the cookie settings panel.

Rejecting non-essential cookies must not prevent access to the website’s essential content.

​

10. Security and confidentiality

3WALKS will implement technical and organisational measures appropriate to the level of risk in order to protect personal data against destruction, loss, alteration, unauthorised disclosure or unauthorised access. Staff and collaborators with access to personal data will be subject to confidentiality obligations and will receive appropriate instructions.

In the event of a personal data breach, 3WALKS will act in accordance with the GDPR, including notifying the supervisory authority and, where appropriate, the affected data subjects.

​

11. Third-party data

Anyone providing another person’s personal data declares that they are authorised to do so and that they have informed that person of this policy. Personal data relating to third parties that is not necessary for the relevant purpose should not be provided.

​

12. Third-party links and services

The website may include links to third-party websites or services. Their respective operators apply their own policies, and users are therefore advised to review them before providing any personal data.

​

13. Changes to this policy

3WALKS may update this policy to reflect changes in legislation, technology or its data-processing activities. The current version will be published on the website together with the date on which it was last updated. Where a change is significant, it will be communicated through reasonable means.