Data protection policy

In compliance with the Personal Data Protection Regulations and the Law on Information Society Services and Electronic Commerce, we inform you that the personal data you provide to us through the www.air-institute.com website will be considered confidential and will become part of the FUNDACIÓN INSTITUTO INTERNACIONAL DE INVESTIGACIÓN EN INTELIGENCIA ARTIFICIAL Y CIENCIAS DE LA COMPUTACIÓN (hereinafter AIR INSTITUTE) data controller.

Who is responsible for the processing of your personal data?

We inform you that your personal data will be processed by FUNDACIÓN INSTITUTO INTERNACIONAL DE INVESTIGACIÓN EN INTELIGENCIA ARTIFICIAL Y CIENCIAS DE LA COMPUTACIÓN (hereinafter AIR INSTITUTE), with the Spanish Tax Identification Number (TIN): G37571627 and registered office at Av. Santiago Madrigal, 37003 Salamanca (Spain), registered on 01/08/2018, with protocol 2609.

To guarantee proper compliance in data protection matters, the entity has a Data Protection Delegate who will be entrusted with answering any queries that may arise regarding the protection of your personal data and ensuring compliance with data protection legislation. You can contact him at the following e-mail address: contacto@delegado-lopd.es.

Where do we collect your personal data?

AIR INSTITUTE may process the personal data you provide to us from one of the following sources:

  • Data provided by the interested party, or an authorised third party, through the completion of the forms made available, by sending e-mails or by any other means by which the user establishes communication with AIR INSTITUTE.
  • Data generated as a consequence of the user browsing and using the AIR INSTITUTE website.
  • Data generated as a consequence of the formalisation, development, processing and maintenance of the contractual relationship.
  • Data owned by any of the entities with which AIR INSTITUTE collaborates either for research programmes or for the execution of projects in which AIR INSTITUTE participates.

For what purpose and on what legitimate basis are your personal data processed?

Please be informed that all the requested personal data are necessary for the purposes described in this Privacy Policy and failure to provide them would imply the impossibility of contacting you, providing you with adequate service or managing the submitted request.

In the event that you provide data of third parties, you declare that you have their consent and undertake to provide said third parties with the information contained in this policy.

In the case of data processing based on consent, each consent obtained for the indicated purposes is independent, so that the interested party may revoke, at any time, any of the consents without affecting the others.

The different purposes for which your personal data are processed are described in more detail below:

Visitor data

1.- The legal basis for the processing of your personal data involves the following lawful purposes:

  • Control of access to AIR INSTITUTE facilities. To guarantee and uphold the security of persons, information, goods, and facilities and to exercise control over persons external to the foundation who access the facilities and work centre, AIR INSTITUTE will process your identification, contact and professional data.

Collaborators' data

1.- The legal basis for the processing of your personal data involves the following lawful purposes:

  • Processing of registration as a collaborator. This data processing activity consists in managing the registration and deregistration of collaborators, which will imply carrying out the verifications required to process the collaborator's application, as well as the validation of their documentation. For this activity AIR INSTITUTE will process the collaborator's identification data, contact data and financial data if necessary.
  • Management of the relationship with collaborators. The main purpose of this data processing activity is to manage your status as an AIR INSTITUTE collaborator in order to enable you to benefit from the associated advantages. For this activity, AIR INSTITUTE will process your identification data, purchase history, contact data and financial data.
  • Management of meetings and governance of the cooperative. This data processing activity consists of organising events, facilitating the exercise of political rights and your participation in the governance of the foundation through the relevant bodies. This data processing activity includes sending institutional communications, organising events and electoral processes, as well as sending the necessary notifications. AIR INSTITUTE will process the data you provide for this purpose. In particular, AIR INSTITUTE will process the following categories of data: identity, contact and professional data.

2.- The legal basis for the processing of your personal data involves the following lawful purposes:

  • Management of customer communications. The present data processing activity consists mainly of sending communications addressed to your category of customer, initiatives and newsletters. In particular, AIR INSTITUTE will process the following categories of data: identification, contact and professional data.
  • Statistical studies and quality surveys on the services offered. To verify and improve the quality of AIR INSTITUTE’s communications, procedures, processing and services, your personal data may be processed in order to carry out satisfaction and quality surveys. We inform you that the predominant interest of AIR INSTITUTE in conducting data processing is to improve customer service procedures and update services, allowing it to continue its economic activity and grow within the sector. For this purpose, AIR INSTITUTE will process your identification and contact data.

3.- The legal basis for the processing of your personal data involves the following lawful purposes:

  • Sending commercial communications. Only when you have consented to the sending of commercial communications by checking the appropriate box, or through the various channels provided for this purpose, we will offer you information about our services, events, and news that may be of interest to you, which will enable AIR INSTITUTE to continue its business activity and the customer to benefit from it and stay updated. These communications may be made on the basis of a commercial profile, as well as data relating to interests that you have provided to us as a user. However, you have the possibility to object to the processing of your personal data at any time by following the indications that appear in each communication. Here, the processing will regard  your identification data, interests, location, professional data, and contact data. For this purpose, AIR INSTITUTE will process the data you provide and those provided by other collaborating entities.
  • Sending commercial communications from third parties. AIR INSTITUTE may send you, by both ordinary and electronic means, commercial or promotional communications of services of third-party companies, partners, or collaborators, provided that your consent has been obtained through the channels that AIR INSTITUTE has enabled for this purpose. You will always have the possibility to object to this processing of personal data at any time by following the indications that appear in each communication. Here, the processing will regard  your identification data, interests, products, and services contracted and contact information.
  • Event management. When you have agreed to attend and/or participate in an event, your data will be used to perform the necessary actions to enable the event to be held, such as inclusion in lists of attendees or access to venues. In particular, AIR INSTITUTE will process the following categories of data: identification, contact and professional data.

At events it is possible to take pictures and/or make videos presenting wide shots and ambient sound. The purpose of this is to publicize and promote the image and brand of AIR INSITITUTE on its own and third party media, both internally and externally, in order to provide greater visibility to the entity and to shape a public image of AIR INSTITUTE and the people who relate to it in accordance with the ideals and values that govern its activity, through the dissemination of the activities and events it organizes.

4.- The legal basis for the processing of your personal data involves the following lawful purposes:

  • Management of the exercise of the rights of interested parties. When you wish to exercise your data protection rights, AIR INSTITUTE will receive, study, and respond to your requests to exercise your rights. For this purpose, AIR INSTITUTE will process the data you provide and those provided by the other AIR INSTITUTE's collaborating entities accordingly. In particular, AIR INSTITUTE will process the following categories of data: identification data, contact data and data necessary to resolve a given request.

Potential customers

1.- The legal basis for the processing of your personal data involves the following lawful purposes:

  • Management of potential customers. This data processing activity consists of generating a candidate in order to be registered as a customer. For this purpose, AIR INSTITUTE will process the data obtained from the applications. In particular, it will process your identification data and professional data.
  • Customer service. This data processing activity consists primarily of answering queries or requests for information made by you through our customer service telephone number, contact forms, social networks or by any other means provided for this purpose. For this purpose, AIR INSTITUTE will process the data you provide and those provided by the rest of AIR INSTITUTE's collaborating entities accordingly. In particular, it will process your identification and contact data, as well as those that are necessary to resolve the query raised.

2.- The legal basis for the processing of your personal data involves the following lawful purposes:

  • Statistical studies and surveys on the services offered. To verify and improve the quality of communications, procedures, client attention, as well as AIR INSTITUTE services, your personal data may be processed in order to conduct satisfaction and quality surveys. We inform you that the predominant interest of AIR INSTITUTE in conducting this data processing is to improve customer service procedures and services, allowing it to continue its economic activity and grow within the sector. For this purpose, AIR INSITUTE will process your identification and contact data.
  • Sending commercial communications. AIR INSITUTE will offer information about services, events, and news that may be of interest to the provider, allowing AIR INSITUTE to continue its business activity. You have the possibility to object to this processing of personal data at any time by following the indications that appear in each communication. Here, the processing will regard  your identification data, interests, location, professional data and contact details. For this purpose, AIR INSITUTE will process the data you provide and those provided by the rest of the companies of the AIR Institute Group in each case.

3.- The legal basis for the processing of your personal data involves the following lawful purposes:

  • Invitations to events and event management.  Only when you have expressly consented to the sending of communications, AIR INSTITUTE will send you information, including by electronic means, of the events promoted for all interest groups. For this purpose, AIR INSTITUTE will process the data you provide. In particular, AIR INSTITUTE will process the following categories of data: identification, contact and professional data.

4.- The legal basis for the processing of your personal data involves the following lawful purposes:

  • Management of the exercise of the rights of the interested parties. When you wish to exercise your data protection rights, AIR INSTITUTE will receive, study and respond to your requests to exercise your rights. For this purpose, AIR INSTITUTE will process the data you provide and those provided by the other collaborating entities. In particular, AIR INSTITUTE will process the following categories of data: identification data, contact data and data necessary to resolve the corresponding request.

Customers

1.- The legal basis for the processing of your personal data involves the following lawful purposes:

  • Processing of customer registration. This data processing activity consists mainly of managing the registration and deregistration of customers, which necessarily involves carrying out the necessary checks to process your application, as well as performing validations of the documentation of the same. For this activity AIR INSTITUTE will process your identification data, purchase history, contact data and financial data.
  • Customer service. This data processing activity consists primarily of answering queries or requests for information made by you through our customer service telephone number, contact forms, social networks, or by any other means provided for this purpose. For this purpose, AIR INSTITUTE will process the data you provide and those provided by the rest of the collaborating entities. In particular, it will process your identification and contact data, as well as those that are necessary to resolve the query raised.
  • Customer relationship management. For the present processing activity, AIR INSTITUTE will be in charge of registering and deregistering you as a customer and will manage your contractual relationship. For this purpose, AIR INSTITUTE will process the data you provide and those provided by the rest of the collaborating entities. In particular, AIR INSTITUTE will process the following categories of data: identification data, contact data, address, and financial data.
  • Management of attention and resolution of incidents. In the event that you have an incident, AIR INSTITUTE will attend to and resolve your incidents. For this purpose, AIR INSITUTE will process the data you provide and those provided by other collaborating entities. AIR INSTITUTE will process the following categories of data: identification data, contact data, purchase history, as well as those that are necessary to resolve the incident raised.

2.- The legal basis for the processing of your personal data involves the following lawful purposes:

  • Statistical studies and quality surveys on the services offered. To be able to verify and improve the quality of communications, procedures, customer attention, as well as AIR INSTITUTE products and/or services, your personal data may be processed in order to conduct satisfaction and quality surveys. We inform you that the predominant interest of AIR INSTITUTE in conducting this data processing is to improve customer service procedures and services, allowing it to continue its economic activity and grow within the sector. For this purpose, AIR INSTITUTE will process your identification and contact data.

3.- The legal basis for the processing of your personal data involves the following lawful purposes:

  • Sending commercial communications. Only when you have consented to the sending of commercial communications by checking the appropriate box, or through the various channels provided for this purpose, we will offer you information about our services, events, and news that may be of interest to you, allowing AIR INSTITUTE to continue its business and the customer to benefit and be updated. These communications may be made on the basis of a commercial profile, as well as data relating to interests that you have provided to us as a user. However, you have the possibility to object to this processing of personal data at any time by following the indications that appear in each communication. Here, the processing will regard  your identification data, interests, location, professional data and contact data. For this purpose, AIR INSTITUTE will process the data you provide and those provided by other collaborating entities.
  • Sending commercial communications from third parties. AIR INSTITUTE may send you, both by ordinary and electronic means, commercial or promotional communications of services of third-party collaborating entities, partners or collaborators, provided that your consent has been obtained through the channels that AIR INSTITUTE has enabled for this purpose. You will always have the possibility to object to this processing of personal data at any time by following the indications that appear in each communication. Here, the processing will regard  your identification data, interests, products and services contracted and contact information.

4.- The legal basis for the processing of your personal data involves the following lawful purposes:

  • Management of the exercise of the rights of interested parties. When you wish to exercise your data protection rights, AIR INSTITUTE will receive, study, and respond to your requests to exercise your rights. For this purpose, AIR Institute will process the data you provide and those provided by the other collaborating entities. In particular, AIR INSTITUTE will process the following categories of data: identification data, contact data and data necessary to resolve the corresponding request.
  • Registration and transfer of data in case of adverse effects. In the event of adverse effects, the legally required personal data will be recorded and communicated to the relevant authorities in accordance with the regulations in force. Here, the processing will regard identification data, name, surname, e-mail, and the health data of the person concerned.

Website users

1.- The legal basis for the processing of your personal data involves the following lawful purposes:

  • Use of the Website and browsing experience. AIR INSTITUTE informs its users that it uses cookies on its Website. Cookies are small text files that are stored by your browser on your computer's hard drive. When you browse through our website, our server will be able to recognize the cookie and provide us with information about your last visit. Most browsers accept the use of cookies automatically, but you can configure your browser to be warned on your computer screen of the reception of cookies and to prevent their installation on your hard drive. In no case the files -cookies- can read information from your hard disk or files created by other sites. To read our Cookies Policy, click on the following link: COOKIE POLICY. Therefore, this data processing activity consists mainly of the use of this personal data for the management, maintenance, and support of the Website, as well as to improve the browsing experience. The legal basis for this processing is AIR INSTITUTE's legitimate interest in improving its processes in order to be able to offer you a browsing experience suited to your needs and to keep you protected at all times from an information security point of view. For this purpose, AIR INSTITUTE will process your identification and navigation data.
  • Logical security. This data processing activity consists primarily of analysing suspicious events on the website in order to prevent and block logical attacks by ensuring the security of our network and information. For this purpose, AIR INSTITUTE will process IP addresses and the browser's user agent string.

2.- The legal basis for the processing of your personal data involves the following lawful purposes:

  • Installation of cookies. If you give us your express consent through the banner enabled for this purpose, by installing cookies AIR INSTITUTE will conduct a series of processing of personal data. To gather additional information in this regard, please refer to our COOKIE POLICY which you can consult at the following link.

 

Reports Channel

The sending of personal information through the Reports Channel or any of the means envisaged in the Code of Conduct may require, in certain cases, depending on the subject of the report, the processing of personal data of the person who has made the report, as well as of the person that is being reported.

In this regard, the personal data collected through the Internal Information System shall be processed for the purposes of managing, processing, and investigating the communications sent, as well as for adopting disciplinary measures or processing the administrative or judicial proceedings that, where appropriate, may be required.

1. The legitimate basis for processing the personal data collected through the Internal Information System is:

  • Compliance with AIR INSTITTUTE's legal obligations to have an Internal Reporting System.
  • Legitimate interest when the communication reports a breach of AIR INSTITUTE's internal procedures, policies and regulations regarding conduct that does not fall within the scope of the Informant Protection Act. In such cases, the legitimate interest of the data controller is to minimise the negative impact resulting from such conduct and to reinforce the culture of compliance with AIR INSTITUTE's internal policies and procedures.

In addition, the Informant must provide consent in the event that a recording of their voice is made in accordance with the provisions of Article 7 of the Informant Protection Act.

Persons making a report through the Reports Channel or any of the means provided for in the Code of Conduct must ensure that the personal data provided is true, accurate, complete, and up to date.

 

Recipients:

The personal data you provide may be communicated to those third parties to whom the data controller is obliged to transmit information, such as public administrations, Courts and Tribunals, in order to comply with the requirements of such authorities and the applicable regulations, where applicable. Your data may also be transmitted to third party service providers if necessary to fulfil the purpose of data processing.

Your personal data may be communicated to other collaborating entities of AIR INSTITUTE, which you can consult at the following link, to be processed in order to satisfy your request for information or your corresponding consultation according to the existing contractual relationship between the parties.

Likewise, if you give your express consent, in order to send you communications related to the sector, communications may be sent to AIR INSTITUTE's other collaborating entities to be processed by them, within the commercial and contractual relationship.

Are there any international data transfers?

The use of WhatsApp as a communication channel may involve access to personal data by WhatsApp Ireland Limited, which may involve the processing of personal data from outside the European Economic Area. Notwithstanding the foregoing, in the event that it is necessary to carry out international transfers of your personal data to countries whose level of data protection is not considered adequate by the European Commission, appropriate safeguards will be in place, in accordance with applicable law, to protect your personal data at all times.

Retention Time:

In compliance with the principles of limitation in the retention period, the data collected will be processed only and exclusively for the time necessary and for the purposes for which they were collected.

It will be understood that the conservation of the data is justified when:

  • There is a legal obligation to keep the data for a specific period of time.
  • It is necessary to respond to the contractual relationship.
  • They are used for historical and/or statistical purposes.
  • The interests of third parties or those of the legitimate owner of the data could be harmed.
  • Are necessary to guarantee the traceability and follow-up of a service.
  • The data and documentation serve as proof of an activity or service provided, during the statute of limitations of civil, criminal, administrative or any other type of actions that may arise from the activity or provision of the service. In such a case, the data will be blocked until the end of the retention obligation.
  • A longer retention period has been agreed upon by the interested parties.

In addition, the application of encryption technologies has been implemented, both in storage and transmission of information. Use of confidentiality preservation technologies, applying access control or identity management solutions, among others.

  • Integrity: the information systems have security policies and password policies that limit and protect the information available by assigning access profiles both on local servers and in the AIR INSTITUTE cloud used in the foundation.
  • Availability: through resource allocation policies and backup policies that reach all systems including projects and services provided to users. Systematic data recovery tests are conducted in the event of serious incidents that could limit data availability.
  • Implementation of resilience mechanisms, which allow for the monitoring and rapid detection of incidents and ensure the articulation of planned recovery mechanisms.
  • Implementation of incident response protocols, both physical and logical, to ensure rapid and effective resolution of incidents.
  • Implementation of auditing practices to periodically verify the implementation of the different security measures and their effectiveness.

Exercise of rights:

We inform you that you can exercise your rights of access, rectification, deletion, opposition and other rights in accordance with the provisions of Personal Data Protection Regulations, by sending an email to the above address indicating in the subject "LOPD" accompanied by a copy of your national identity card, passport or other valid document that identifies you. You can also make use of the models and forms for the exercise of these rights available to you on the portal of the Spanish Data Protection Agency. Your rights are as follows:

  • Any person has the right to obtain a confirmation as to whether we process their personal data in our company.
  • Interested parties have the right to access their personal data, as well as to request the rectification of inaccurate data or, where appropriate, request its deletion when, among other reasons, the data is no longer necessary for the purposes for which it was collected.
  • Data subjects may request the limitation of the processing of their data while the accuracy of the data is being challenged; when the processing is lawful but you object to the deletion of your data; if the controller does not need to process your data but you need them for the exercise or defence of claims or when you have objected to the processing of your data for the fulfilment of the legitimate interest of the controller, while verifying whether the legitimate grounds for the processing prevail over yours; in which case we will only keep them for the exercise or defence of claims.
  • In certain circumstances, and for reasons related to their particular situation, data subjects may object to the processing of their data. Our company will stop processing the data, except for compelling legitimate reasons, or the exercise for the defence of possible claims.
  • Likewise, you have the right to data portability, in cases where the law allows it.
  • We inform you that you may withdraw your consent for any or all purposes at any time, without affecting the lawfulness of the processing based on the consent prior to its withdrawal.
  • We inform you that you may file a complaint with the competent Data Protection Control Authority (AGPD - Spanish Data Protection Agency, for example).

You may exercise these rights by requesting us at the above address.

Accuracy of the data and updating of the same:

The User guarantees that the Personal Data provided to AIR INSTITUTE are truthful and is responsible for communicating any changes in them. The user will be solely responsible for any damage or harm, direct or indirect, that may be caused to AIR INSTITUTE or any third party as a result of the completion of the forms with false, inaccurate, incomplete or outdated data. The User shall not include personal data of third parties without their prior informed consent of the provisions of this data protection policy, being solely responsible for their inclusion. All data requested through the website are mandatory, as they are necessary for the provision of an optimal service. In the event that all the data is not provided, there is no guarantee that the information and services provided will be completely tailored to your needs. To provide us with your personal data, a minimum age of 14 years is required.

Social networks:

AIR INSTITUTE will use social networks as a means of communication and promotion of its services. In no case we will use the data for purposes not permitted. This company is not responsible for the content, comments, opinions, or information, own or third parties, that users post on our accounts created on Facebook, Twitter, LinkedIn, YouTube, etc. You may use our content for lawful purposes, as long as you mention its origin or author. The purpose of the data collected will be the database of users and contacts of the company's social network accounts. Please note that the use of social networks is subject to the privacy policies of each of them.

Processing of images of people:

AIR INSTITUTE informs that, in the case of processing related to the management and attendance to events, it is possible to take pictures and/or film videos of attendees, take wide shots and capture ambient sound. The purpose is to publicize and promote the image and brand of AIR INSTITUTE on its own and third party media, both internally and externally, in order to provide greater visibility to the entity and to shape a public image of AIR INSTITUTE and the people who relate to it in accordance with the ideals and values that govern its activity, through the dissemination of the activities and events it organizes.

The processing of the images of the interested parties, employees or collaborators respects the person, in accordance with the Organic Law 1/1982 of May 5, 1982, on the protection of the right to honour, to personal and family privacy and to one's own image, by eliminating any images of videos that could violate fundamental rights.

Confidentiality and security of your data:

AIR INSTITUTE has adopted the necessary measures to avoid the alteration, loss, unauthorised processing and access to personal data, taking into account at all times the state of technology, however, the User must be aware that security measures on the Internet are not impregnable.

The data obtained through the Website and/or any other means, will be processed by the CONTROLLER with absolute confidentiality, undertaking to keep them secret.

That in accordance with the provisions of the regulations in force on Personal Data Protection, the CONTROLLER complies with all the provisions of the GDPR and LOPDGDD regulations for the processing of personal data under their responsibility, and manifestly with the principles described in Article 5 of the GDPR and Title II of the LOPDGDD, by which they are processed in a lawful, fair and transparent manner in relation to the data subject and adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

The DATA CONTROLLER guarantees that it has implemented appropriate technical and organizational policies to apply the security measures established by the GDPR and the LOPDGDD in order to protect the rights and freedoms of the Users and has communicated adequate information to them so that they can exercise them.

Data protection legislation may be modified, so we strongly recommend that you regularly consult our Data Protection Policy.

We inform you that the AIR INSITUTE website does not support encryption and we inform you that information sent over the Internet without encryption can be viewed by others, by submitting our forms you agree to the sending of unencrypted information.

Modification of the Data Protection Policy:

AIR INSTITUTE reserves the right to modify its data protection policy according to its criteria, or because of a change in legislation, jurisprudence, or business practice. Should AIR INSTITUTE introduce any modification, the new text will be published on this website, where the User will be informed of AIR INSTITUTE's current data protection policy. In any case, the relationship with users will be governed by the rules provided at the precise moment when the website is accessed.

Additional information:

Should you require clarification or wish to share any comments, please do not hesitate to contact AIR INSTITUTE by sending an e-mail to the address above.

Last update: 13 February 2024.