EL CAMI DE LA SOLIDARITAT – General Privacy Notice
Last update: January 2024
1.What is this General Privacy Notice?
The General Terms established below are intended to help you better understand how we process your personal data and what rights you have to protect yourself.
2.What concepts should you know?
These are some of the Concepts you should know about:
- Personal Data: It refers to any information that allows us to identify, in any way, a Natural Person. This information could be the name, identification number, location data, etc.
- Data Controller: The organization or entity that process your personal data and determines the purposes and means of the processing of your personal data.
- Data Subject: It’s the owner of the personal Data. In this case, that would be YOU.
- Donor: the person who makes donations to help us reach our goals.
- Ambassador: any person who decides to participate with the NGO in any way.
- Volunteer: any person who decides to help us in the organization of any of our Activities.
- Affiliate: any person who decides to help us through a monthly contribution.
- Participant: any person who participates in a specific Public activities, such as Charity events sponsored by us, Crowdfundings, etc.
- Beneficiaries: any person or group of people in need of social assistance, aid or who are part of vulnerable groups for which El Camí de la Solidaritat has active social actions or aid projects.
- Data Protection legislation: refers to the applicable data protection regulations. In the specific case, the General Data Protection Regulation and the Organic Law on Data Protection and Guarantee of Digital Rights.
- Data Protection Authority: is an independent public authority that supervises, through investigative and corrective powers, the application of the data protection legislation.
- Social media channels: includes all those platforms that El Camí de la Solidaritat uses or may use; such as: Instagram, Youtube, WhatsApp, etc. These platforms are third parties outside El Camí de la Solidaritat that have their own privacy and cookie notices, so we suggest you check them before using them.
- Collaborators: Third-parties who contributes with their personal work to achieve our goals. This includes legal or natural persons such as other NGOs, activists, etc.
3.Who are we?
“El Camí de la Solidaritat” (hereby “EL CAMI”) is a non-profit, non-governmental organization, whose primary goal is to promote and defend social transformation.
For the purpose of this Privacy Notice, we are Data Controllers. This means that we determine the purposes and means of the processing of your Personal Data.
However we undertake to use only your Personal Data given to us under the terms and conditions established here.
If you have any doubt, you can contact us here:
Name: El Camí de la Solidaritat
Address: C/Pau Vila 58, 43850, Cambrils (Tarragona).
E-mail: dataprotection@elcami.eu
4.To Whom is this Privacy Notice Address?
This General Privacy Notice is addressed to any Data Subject whose Personal Data is processed directly or indirectly by us to achieve our goals as an NGO. This will include:
- Beneficiaries.
- Ambassadors.
- Affiliate.
- Newsletter subscribers.
- Donors.
- Participants in our Public activities.
- Collaborators.
- Any individual who wishes to know a little more about our mission and contact us through the different channels.
5.What Personal Data would be processed by El Camí?
As an NGO, we only process the strictly necessary personal data, in accordance with the Principle of “Data Minimization”. This Personal Data could include:
- Name and Surname.
- ID-related data(in case you request an invoice from us).
- Home address.
- Your Phone Number.
- E-mail address.
- Birthday.
- Photographs and videos.
- Bank information, such as Amount, source account/Wallet, and Subject Owner.
- Social Media’s Name Account.
- Signature.
6.What is the Purpose of Processing Your Personal Information?
The personal information we process is provided to us by you, or in certain cases by Third Parties, for one of the following reasons:
- Manage social assistance and the provision of aid to people in need, as well as vulnerable groups.
- Manage and control your collaboration as Donor, Ambassador and/or Affiliate.
- Manage your subscription to our newsletter to keep you informed of our activities.
- Manage and process any type of information request made by different means (website, email, phone call, etc.), including those aimed at becoming a Donor, Ambassador or Affiliate, as well as any doubts and queries you may have.
- Manage and control the donations you make to us through the different platforms and means enabled for this purpose.
- Contact you via WhatsApp to keep you informed about El Camí’s mission and projects when you have given us your consent to do so.
- Include you in our Whatsapp channel groups as long as we have your consent to do so.
- Post photos and/or videos on our social media channels.
- Contact you through social media channels when we believe you may be interested in collaborating with our initiatives and projects. As we value your privacy, we will only contact you once. If you are not interested, we will not bother you again and we will not store your data for any other purpose.
- Issuance of invoices at your request.
- Manage requests to exercise your privacy rights.
Some of our purposes may involve the use of Bank/Wallet accounts used by you. In case you require us an invoice, we may need to process Additional Information. But don’t worry, this information will always be as minimum as possible, and limited to the specific purpose of the invoice.
7.What are the Legal Bases for the processing of Personal Data?
Under the Data Protection legislation , the lawful bases we rely on for processing this information are:
- Your consent, concerning the information provided to contact you. You are able to remove your consent at any time. You can do this by contacting dataprotection@elcami.eu.
- In some cases, we have a legal obligation to process the Personal Data provided by you or by Third Parties, in accordance with local and regional Law.
- When there’s a pre-contract or a contract between you and the NGO.
- Our legitimate interest in order to use your personal data to achieve the NGOs goals, for the purposes of data protection legislation. In these cases, we inform you that you can object to the processing of your personal data by contacting us through the channels provided in this privacy notice.
*We also inform you that we will not process your data on the basis of automated decisions, including profiling.
- How long will your data be kept?
Your personal data will be stored and kept for the period of time necessary to fulfil the purposes described in this General Privacy Notice, unless a longer retention period is required or permitted by law.
The criteria used to determine our retention periods may include:
- The duration of our relationship with you (e.g., if you choose to work with us as an Ambassador),
- Whether there is a legal obligation to which we are subject (e.g., if you choose to support us through a donation, we must retain information related to the donation); and
- If the retention is necessary in view of our legal position (e.g., in the event of claims, complaints or lawsuits).
However, once we no longer need your personal data, it will be securely deleted from our systems.
9.Who are the Data Recipients?
Your Data may be communicated to service providers that assist El Camí in carrying out its business, for example, IT tools, technical support services, etc., as well as those departments of El Camí that should have access to the data.
In some cases, we would share your Personal Data to third parties, like Social Media Platforms, as long as we have your consent. However, we recommend that you review their own privacy notices so that you are aware of how they process your data.
Some of the above may be located outside the European Economic Area (EEA).
When your Data may leave the EEA, they will maintain the same level of protection based on compliance with the provisions of European data protection law. In this regard, international data transfers will be made (i) to countries with an adequate level of protection declared by the European Commission (ii) on the basis of the provision of adequate safeguards (standard contractual clauses) or (iii) by virtue of authorization by the competent supervisory authority or under other conditions provided for in the regulations.
To receive more information about international data transfers or to obtain confirmation or a copy of the safeguards used, you may contact at dataprotection@elcami.eu
In cases where it is necessary to comply with El Camí‘s legal obligations, the personal data may be communicated to the Public Administration and the State Security Forces and Corps.
10.Which security measures do we apply?
El Camí is committed to keep your personal data secure, taking all reasonable measures to do so. El Camí will implement all necessary organizational and technical measures in accordance with the regulations in force against any unauthorized access and modification, disclosure, loss or destruction. We require and contractually oblige our service providers who may handle your personal data to do the same.
11.What are your data protection rights?
Under the data protection legislation, you may have different privacy rights in order to guarantee your privacy. This includes:
- a) Your right of access – You have the right to ask us for copies of your personal information.
- b) Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- c) Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
- d) Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
- e) Your right to object to processing – You have the right to object to the processing of your personal information in certain circumstances.
- f) Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
If you make a request, we have one month to respond to you, although on certain occasions, privacy regulations allow us to extend for an additional two months.
To exercise your rights, please contact us at the address dataprotection@elcami.eu. To help us process your request, please indicate “Data Protection” in the subject line and provide any information that will allow us to verify your identity (e.g., name, e-mail, etc.).
In certain situations where we cannot properly verify your identity with the information provided, we may ask you to provide us with a copy of your ID card, passport or similar documentation to assist us for this purpose. Please, note that we will only need access to the minimum information necessary to identify you on your documentation, so you can anonymize/hide the rest of the information.
Finally, exercising your rights will not, as a general principle, require any payment in addition. However, in the event that you exercise your rights in an excessive manner due to their repetitive nature or your request is manifestly unfounded, we inform you that we may charge you a reasonable fee.
12.How to complain?
If you have any concerns about our use of your personal information, you can make a complaint to us at dataprotection@elcami.eu
However, we inform you that you can also complain to the competent Data Protection Authority (in Spain, www.aepd.es) if you are unhappy with how we have processed your data.