Identity of the Data Controller: Clúster de Movilidad y Logística, MLC ITS Euskadi Avenida de Tolosa 75, 1º. 20018 Donostia-San Sebastian

In accordance with data protection legislation and any other relevant and applicable legislation in force, the user is informed that any personal data provided, where applicable, will be incorporated into an automated file, which will be used solely for the purposes described in the corresponding forms, contracts, pre-contracts or offers.

Data relating to members Where you have provided your data as a contact person for a member company of the Association or as a sole trader, we inform you that the Cluster will use the data exclusively for maintaining the contractual relationship and will not transfer it to third parties, unless such transfer is necessary for the fulfilment of the contractual relationship with the data subject or their company. The data provided will be retained for as long as the contractual relationship is maintained or for the years necessary to comply with legal obligations. In addition, we inform you that, as a member, the Cluster may send you commercial information via the means you have provided, including email, on the basis of Legitimate Interest as regulated by the General Data Protection Regulation.

Data relating to former members, collaborators and potential members Where you have provided your data as a contact person for a company that is no longer a member of the Cluster, we inform you that the Cluster will continue to use the data relating to the company’s contact person on the basis of the legitimate interest established by the Organic Law on Data Protection and Guarantee of Digital Rights. Likewise, where you have provided your data as a potential member or collaborator, the Cluster will process your data on the basis of legitimate interest. The data will be processed in order to contact you and to send you information that we consider to be of interest via the means you have provided, including email, based on Legitimate Interest. The data provided will be retained until you object to its processing. If you do not want your data to be processed by the Cluster, you may exercise your rights via the means indicated in this Privacy Policy.

Data relating to contacts Where you have provided your data as a contact person for an organisation, a media outlet or any similar entity, we inform you that the Cluster will use the data exclusively to contact you for purposes appropriate to the type of data, namely to contact you or the entity or media outlet you represent regarding possible events or to publicise events organised by the Cluster. Such data will not be transferred to third parties, unless such transfer is necessary to comply with legal obligations. The data provided will be retained until you object to its processing. In addition, we inform you that, as a member, the Cluster may send you commercial information via the means you have provided, including email, on the basis of Legitimate Interest as regulated by the General Data Protection Regulation.

Data relating to event attendees Where you have provided your data as an attendee at any events organised by the Cluster, we inform you that the Cluster will use the data to organise the event and to continue informing you about other events that we consider may be of interest to you. The legal basis for processing as an attendee is the contractual relationship or, failing that, your consent in wishing to attend the event, and in the case of sending information related to the Cluster’s activities, legitimate interest. We remind you that, as an attendee, at the time you registered for the event, you were informed that your data may be shared with other attendees, as well as with event organisers or sponsors. The legal basis is legitimate interest, as you are a contact person interested in the activities of the Cluster. You may at any time object to the Cluster sharing your data with event participants, sponsors, attendees or organisers by indicating this in the relevant event registration form or by contacting the Cluster through the means indicated in this policy.

Newsletter: marketing and communications of interest
We inform you that the Cluster uses the contact details of member companies, potential members, former members, collaborators, or individuals who expressly request to subscribe to the Newsletter, to send information related to the Cluster’s activities.
In this regard, recipients may include members, former members, potential members, collaborators, event attendees or contacts previously engaged by the Cluster. If a data subject is receiving this type of information, they will fall within one of the aforementioned categories. The information sent by the Cluster is considered to be of interest to the recipient and is always related to the Cluster’s services, in which the data subject has shown some level of interest. The legal basis for processing data for this purpose is the Cluster’s legitimate interest. This legitimate interest is balanced by ensuring that you are informed at all times of the possibility to unsubscribe from such communications, given that these are contact details of individuals acting within legal entities, and that the purpose pursued by the Cluster is always business-related, with communications relating solely to the Cluster’s services in which the data subject has shown interest. You may object to the processing of your data for the purposes described at any time by sending an email to mlcluster@mlcluster.com. The Cluster will retain your data for as long as the business or contractual relationship is maintained, or until you indicate that you no longer wish to receive such information.

Data relating to suppliers Where you have provided your data as a contact person for a supplier company of the Association or as a sole trader, we inform you that the Cluster will use the data exclusively for maintaining the contractual relationship and will not transfer it to third parties, unless such transfer is necessary for the fulfilment of the contractual relationship with the data subject or their company. The data provided will be retained for as long as the contractual relationship is maintained or for the years necessary to comply with legal obligations.

Data relating to candidates Where you have provided your data to the Cluster as a potential candidate to join it, we inform you that the Cluster will use the data exclusively to manage your application for any vacancies that may arise and will not transfer it to third parties. The data provided will be retained for a maximum period of two years. The legal basis is your consent in submitting your CV.

Your data on the Cluster management platform We remind you that the Cluster has a contact and data management platform on which data relating to members, former members, collaborators and potential members are processed. These data, as previously informed, may be shared among all platform users. The legal basis for processing these data and for the possibility of sharing them among users is the Cluster’s legitimate interest. In this regard, the Cluster considers that there is a balanced legitimate interest, as your data correspond to contact persons of entities with which the Cluster has or seeks to maintain a relationship. We remind you that you may object to the processing of your data for the purposes described at any time by sending an email to mlcluster@mlcluster.com. The Cluster will retain your data until you object to such processing. In addition, the platform will also process contact data relating to attendees or contacts from the press or other Cluster contacts, such as collaborators, suppliers or similar; however, these data will not be shared with other platform users. At all times, as a user of the platform, you have access to its terms of use, which are binding.

Contact forms Personal data provided in the existing forms will be used to respond to the queries raised in the form itself and will not be transferred to third parties, unless your query requires such communication and solely for that purpose. The legal basis for processing is your consent when completing the form. In addition, we inform you that personal data will be retained by the Cluster until you object to their processing. As mentioned above, these data may also be used to send commercial information based on a balanced legitimate interest.

Exercise of rights applicable to all personal data
The data subject has the right to obtain confirmation as to whether the Cluster is processing their personal data and therefore has the right to access their personal data, rectify inaccurate data or request its erasure when it is no longer necessary, as well as to object to the processing of their data for any of the purposes described herein, such as the sending of commercial information. You have the rights of access, rectification, erasure, objection, restriction of processing and data portability, which you may exercise via:

  • Email: mlcluster@mlcluster.com
  • Post: Clúster de Movilidad y Logística, MLC ITS Euskadi. Avenida de Tolosa 75, 1º. 20018 Donostia-San Sebastián

In any case, the data subject may contact the relevant supervisory authority to lodge any complaints deemed appropriate; if located in Spain, this is the Spanish Data Protection Agency.

Accuracy and updating of data The Cluster assumes that the personal data provided through the various channels and media are accurate, supplied directly by the data subject, that the data subject is who they claim to be, that the data are up to date, and that the data subject will communicate any changes to their data as soon as they occur.

Duty of confidentiality Persons involved in processing data concerning natural persons and who access, directly or indirectly, the files will at all times maintain confidentiality regarding the personal data they become aware of in the course of their work. The duty of confidentiality constitutes an obligation for the Cluster, members of its governing and management bodies, employees under employment law, and professionals providing services under commercial law. It also constitutes an obligation for suppliers of goods and services and their employees, data processors and their employees, as well as subcontractors engaged by the data processor and their employees. The duty of confidentiality continues after the termination of the employment or commercial relationship with the Cluster, the data controller, and after the expiry of employment, commercial or other contracts binding employees and/or professionals with the data processor and suppliers providing goods or services to the Cluster.

Recommendation of websites/pages Where the Cluster recommends or links to any website/page, it considers these to be of interest to the user. The Cluster has no obligation to monitor the websites/pages it links to or recommends. These are created by legal or natural persons or entities with no legal personality and are not related to the Cluster. The Cluster does not intervene in their management, finance them, decide on the content included, or manage or participate in the services provided by the linked or recommended websites/pages. The Cluster will remove any link and discontinue recommending any website or page when it becomes aware, on reliable grounds, that the website and/or its services are unlawful or infringe the rights or property of third parties, and which may give rise to a right to compensation.

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Data security The Cluster has implemented in its workplaces, premises, systems, communication infrastructures, etc., the security measures required by personal data protection regulations. It has also adopted logical, physical, organisational and contractual measures to prevent unauthorised third-party access to data, as well as their destruction, alteration, reproduction, disclosure, transmission or reuse.

Validity and modification of the Privacy Policy The Privacy Policy established by the Cluster is in force from the date of its publication on the relevant website; the user may store and/or reproduce it. The Cluster reserves the right to amend its Privacy Policy and will inform users accordingly.