PRIVACY POLICY

This policy describes the processing of a user’s personal data by Mirzo Music Foundation through the website, https://www.mirzomusicfoundation.com (hereinafter, the “Website”).

All references in this privacy policy to “Mirzo Music” or the “Foundation” refer to MIRZO MUSIC FOUNDATION, foundation with its registered address Erbil Sharawani  N10 Kurdistan, Iraq. You can contact us by phone at (+34)626786387  or at the e-mail address  hello@mirzomusicfoundation.com

This policy was last updated on March 1st 2021.

DATA CONTROLLER

MIRZO MUSIC FOUNDATION

Identity: MIRZO MUSIC FOUNDATION (hereinafter, “Mirzo Music” or the “Foundation”)

Address: Erbil Sharawani  N10 Kurdistan, Iraq
E-mail address: hello@mirzomusicfoundation.com
Data Protection Officer (DPD): hello@mirzomusicfoundation.com
DPD Contact: hello@mirzomusicfoundation.com

Mirzo Music, as the data controller of the Website, in accordance with the provisions set forth in Regulation (EU) 2016/679 (GDPR) on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and the provisions set forth in all other legislation in force on personal data protection, as well as the provisions set forth in Spanish Act 34/2002 of 11 July, on Information Society Services and Electronic Commerce (LSSICE), hereby informs you that it has implemented the necessary security measures of a technical and organizational nature to guarantee and protect the confidentiality, integrity and availability of the input data.

PURPOSE

  • Carrying out the necessary administrative actions with users of the website.
  • Forwarding commercial advertising communications via e-mail, SMS, social networks or via any other electronic or physical means (if previously accepted).
  • Responding to queries and/or providing the information required by the user.
  • Providing the services for which the User has signed up.
  • Management of Curriculum Vitae.
  1. PURPOSE OF THE PROCESSING

The data subject gives their express consent for the data controller to perform the following activities and/or actions:

Contact: we request your data so that we can contact you, because you have shown an interest in us, so that we can send you information, news via any of the Foundation’s own social initiatives, and to manage any incidents, queries or complaints about which you might have knowledge.

Provision of services:  Mirzo Music Foundation processes your data for the provision of services that are part of its founding purpose: to support victims of war, sexual slavery and Islamic fundamentalism who currently live in refugee camps or have returned to their homes and are trying to rebuild their lives.

Managing work or volunteers, if applicable.

Assessing an application by a user by receiving and/or evaluating their curriculum vitae by any means.

Sending communications by electronic means to inform interested parties of the activities, services, promotions, advertising, news, and other information about the services of the Foundation that are the same as, or similar to, those that originally attracted the interest of the Customer, in accordance with Spanish Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce.

Special category data: please note that Mirzo Music processes special category data to carry out its intended purposes within the scope of activity of the Foundation, and aimed at the following groups: victims of war, sexual slavery and Islamic fundamentalism.

Suppliers with data access: Please note that your data will be processed by third party companies that help us provide IT services, for example by providing platforms, database support, or support with our software and applications that may contain data about you.

Furthermore, your personal data will be used for the following purposes:

  • Carrying out the necessary administrative actions with users of the website.
  • Sending communications via e-mail, social networks or any other electronic or physical means, if the user has expressly consented to the electronic transmission of commercial communications by signing up for the NEWSLETTER.
  • Responding to queries and/or providing the information required by the user.
  • Providing the services for which the User has signed up.
  • Using your data to contact you, by both electronic and non-electronic means, to obtain our opinion about the service provided and,
  • For notifying you of changes or important developments in the privacy policy, the legal notice or the cookies policy.
  • Analyses will be conducted of profiles and of usability.
  • Users’ data will be processed, within the contractual relationship that binds them to the controller, in compliance with the administrative, tax, accounting and labour obligations that may be necessary in accordance with legislation in force.

You may revoke your consent at any time by sending a letter to hello@mirzomusicfoundation.org, including “de-registration” in the subject.

In accordance with the LSSICE, Mirzo Music Foundation does not carry out SPAM practices. Therefore, it does not send commercial e-mails that have not been previously requested or authorized by the User. Consequently, in all communications that users receive from the provider, they will have the possibility of cancelling their express consent for receiving communications from us.

We will not process your personal data for any purposes other than those that are described, barring any legal obligation or court requirement to do so.

 

2.1. MANAGEMENT OF CURRICULUM VITAE (CV)

In the event that a user sends their CV through our website, we hereby inform you that the data provided will be processed to include them as a participant in any selection processes that may exist, thus carrying out an analysis of the applicant’s profile for the purpose of selecting the best candidate for the vacant post. We hereby inform you that this is the only official process for accepting your CV. Therefore, curricula vitae sent by any other different procedure will not be accepted. In the event of any modification of your data, please inform us in writing as soon as possible so that your data can be kept properly updated.

The data will be kept for a maximum period of one year, after which the data will be erased, while guaranteeing complete respect for confidentiality in both the processing and the subsequent destruction thereof. In this regard, once said period has elapsed, and if you would like to continue participating in the Data Controller selection, please send us your curriculum again.

The data may be processed and/or communicated to entities with which the Foundation maintains a relationship during the time when your CV is stored and for the same purposes mentioned above.

LEGITIMATE BASIS

Legitimate basis

a) Performance of the contract.
b) Consent of the data subject.
c) Compliance with legal obligations.
d) Legitimate interest

  1. LEGITIMATE BASIS OF THE PROCESSING

The legal basis for processing the data is the consent you have given for carrying out the purposes mentioned above, which will be requested when the corresponding box is ticked at the time of collecting your data.

Failure to provide the requested personal data or accept this data protection policy means that it will be impossible to sign up, register or receive information about the Provider’s products and services.

In cases in which there is a prior contractual relationship between the parties, the legitimate basis for developing any administrative, tax, accounting and labour obligations that may be necessary in accordance with the current legislation shall be the prior existence of the commercial relationship established between the parties. In cases in which there is a prior contractual relationship between the parties, the legitimate basis for developing any administrative, tax, accounting and labour obligations that may be necessary in accordance with the current legislation shall be the prior existence of the commercial relationship established between the parties.

 

3.1. COMMUNICATIONS

Any communication sent will be included in the Mirzo Music Foundation information systems. Upon accepting these conditions, terms and policies, the User expressly consents to the following activities and/or actions being carried out by Mirzo Music, unless the User indicates otherwise:

Sending communications by any enabled means to inform Users about the activities, services, news and other information about the services and products related to the activity.

In the event that the User may have expressly consented to the electronic transmission of communications by signing up for the newsletter, the transmission of said communications by electronic means to inform Users about the activities, services, news and other information about the Foundation’s services that are the same as or similar to those that were the object of interest by the User.

The storage of data during the periods provided for in applicable provisions.

 

3.2. OFFICIAL MEANS OF COMMUNICATION

The user is hereby informed that the means enabled by the company for communicating with users and other affected parties are the corporate phone number, the company’s mobile phone numbers and the corporate e-mail address.

If you send personal information through a means of communication other than those indicated in this section, the Foundation will be relieved of any liability regarding the security measures of the means concerned.

 

RECIPIENTS

Your data will not be transferred to third parties, barring any legal obligation to do so. No international transfers will take place without your prior consent.

  1. RECIPIENTS OF ASSIGNMENTS OR TRANSFERS

Mirzo Music does not transfer or communicate data unless there is a reasonable need to comply with a court proceeding or a legal obligation, or subject to obtaining the user’s consent.

However, it is possible that, for certain projects, data will be transferred on a one-off basis to private non-profit entities engaged in social work or pursuing social objectives.

Moreover, no international transfers of the user’s personal data will take place without their prior consent, without prejudice to them being able to block or cancel their account if there are signs of the user having committed any crime. The information provided will only be that which the provider has available at the time.

Mirzo Music will not transfer the collected data to third parties unless there is a reasonable need to comply with a court proceeding or a legal obligation, or subject to obtaining the user’s consent.

The information that you provide to us, through both this website and through the application, will be hosted on the servers of MIRZO MUSIC, which are contracted from the company CDMon, holder of CIF [Tax ID Code] B62844725 and with its registered address at Carrer de Girona, 81, 08380 Malgrat de Mar, Barcelona. The processing of data by said entity is regulated by a data processor agreement signed between the provider and said company. In no event will this data processor outsource services that involve any data processing by third parties without our prior consent.

 

RIGHTS

Accessing, rectifying and cancelling data, as well as other rights indicated in the additional information.

  1. RIGHTS OF DATA SUBJECTS

As a user/data subject, you may send your request to exercise the following rights to Mirzo Music Foundation by letter to the postal address stated in the header, or by sending an e-mail to hello@mirzomusicfoundation.com, while indicating: “MIRZO MUSIC FOUNDATION: EXERCISE OF RIGHTS – LOPD” as the subject and attaching a photocopy of your DNI [National Identity Document] or any analogous means allowed by law.

 

Rights:

Right of access: it allows the data subject to know and obtain information about their personal data that is subject to processing.

Right of rectification or erasure: it allows the correction of errors or the modification of data that may be inaccurate or incomplete.

Right of cancellation: it allows inappropriate or excessive data to be deleted.

Right to object: the right of a data subject to not have their personal data processed or to have the processing of it stopped.

Limitation of processing: it involves the marking of stored personal data so that in future it may only be processed for certain limited purposes.

Data portability: providing the data that is object of processing to the data subject so that the latter can transfer the data to another controller without impediments.

Right to not be the object of automated individual decisions (which includes profiling): the right to not be the object of a decision based on automated processing that might produce legal effects or have a significant effect on you.

As a user, you have the right to withdraw the consent given at any time. The withdrawal of consent will not affect the legality of the processing performed before the consent was withdrawn.

You also have the right to file a claim before the supervisory authority if you think that your rights could have been violated in relation to the protection of your data (agpd.es).

STORAGE

Your data will be kept in the processing records owned by us for as long as the storage thereof may be necessary in order to take care of the purpose for which they were collected, as well as during the period for handling potential legal obligations.

  1. STORAGE OF YOUR DATA

Your data will be stored for as long as your relationship with us lasts or until you exercise your right of cancellation or objection, or the limitation of processing. However, we will store certain identifying personal data and traffic data for the maximum period of 2 years if required to do so by Courts and Tribunals or to initiate actions derived from improper use of the website.

Your data will be stored for as long as the commercial relationship with us exists, or until you exercise your right of cancellation or objection, or the limitation of processing is reached. However, we will store certain identifying personal data and traffic data for the maximum period of 2 years if required to do so by Courts and Tribunals or to initiate internal actions arising from the improper use of the website.

Please also note that our data retention policies comply with the statutory periods that define the legal responsibilities for limitation periods:

  1. a)      Rule of thumb:Under Article 30 of the Spanish Commercial Code, and unless otherwise specified, all company documents and/or data will be retained for six (6) years.   This applies to all accounting, taxation, labour, and commercial documentation, including correspondence.
  2. b)      Specific periods: Our company must also define minimum periods of time, based on the type of data in question, and taking into account the various limitation periods, of which each department must be aware.

This table presents the statutory time limits that affect or may affect our organisation:

 

Subject Time limit Regulation
Occupational for the purposes of offences 3 years Art. 4.1 RD 5/2000
Social Security for the purposes of offences 4 years Art. 4.2 RD 5/2000
Prevention of Occupational Hazards for the purposes of offences 5 years Art. 4.3 RD 5/2000
Tax for the purposes of offences 4 years Art. 66 Law 58/2003
Tax for the purposes of checking offset fees or credits applied 10 years Art. 66 Law 58/2003
Accounting and commercial 6 years Art. 30 of the Code of Commerce
Crimes against the Public Treasury and Social Security 10 years Art. 131 LO 10/1995

 

 

You will not be the object of decisions based on automated processing that produces legal effects to your data.

ADDITIONAL INFORMATION

Puede consultar la información adicional y detallada sobre Protección de Datos en nuestra página web:

  • Política de privacidad: www.mirzomusicfoundation.com/politica-privacidad
  • Aviso Legal: www.mirzomusicfoundation.com /aviso-legal
  • Política de cookies: www.mirzomusicfoundation.com/politica-de-cookies
  1. ADDITIONAL INFORMATION

7.1. ABOUT THE COLLECTED INFORMATION

The data collected by the Website’s data controller are as follows:

  • Those that users provide through the various services offered on the website.
  • Those included in the various forms provided on the website.
  • Data collected through cookies for improving the browsing experience, as is stated in the cookies policy.

 

The refusal to provide mandatory data will make it impossible to specifically handle the request concerned. You state that the information and the data that you provide to us are exact, current and true. In the event of any modification, please notify us immediately so that the information being processed is updated at all times and does not contain errors.

By means of this Privacy Policy, we inform you that the photographs that might be uploaded to the website are the property of Mirzo Music Foundation, including those of minors which were obtained with the prior consent of the parents, guardians or legal representatives by the signing of the forms filled in for this purpose by the centres that the minors attend. However, the parents, guardians or representatives of minors, who hold authority over the exercise of the rights of minors, and always subject to a formal request in writing, can object to the use of an image of a minor. In this case, the image will be pixelated.

 

7.2. SOCIAL NETWORKS

You are hereby informed that Mirzo Music Foundation is present on social networks. The data processing carried out regarding the persons who become followers of the Foundation’s official pages on social networks (and/or who make any link or connection action via the social networks) will be governed by this section, as well as by any conditions of use, privacy policies and access regulations that may pertain to the applicable social network in each case and that are previously accepted by the user.

Mirzo Music Foundation will process your data for the purpose of correctly administering your presence on a social network, thereby informing you of the provider’s activities, products or services, as well for any other purpose that may be allowed by the regulations of the Social Networks.

Publication of the following content is prohibited:

That which is presumably illegal in accordance with national, community or international legislation or which is related to activities that are allegedly illegal or contrary to the principles of good faith.

That which is an attack against the fundamental rights of persons, which represents a lack of courtesy on the Internet, which is troublesome or could generate negative opinions in our users or third parties, and generally any content that Mirzo Music may consider inappropriate.

And, in general, content that could violate the principles of legality, honour, responsibility, the protection of human dignity, the protection of minors, the protection of public order, the protection of private life, the protection of consumers and the protection of intellectual and industrial property rights.

Likewise, MIRZO MUSIC FOUNDATION reserves the authority to remove from the website or from the corporate social network, and without prior notice, any content that may be deemed inappropriate.

Communications sent through social networks will be included in a file owned by MIRZO MUSIC FOUNDATION, to which you may send any information of interest.

 

In any event, if you send personal information through the social network, MIRZO MUSIC FOUNDATION will be exempt from liability with regards to the security measures that are applicable to this platform. If a user would like to know what these measures are, they must consult the corresponding specific conditions of the network concerned.

 

7.3. SECURITY MEASURES

The data that you provide to us will be treated confidentially. The Provider has adopted all the technical and organizational measures and all the protection levels that are necessary to guarantee security in data processing and to prevent the alteration, loss or theft thereof, and to prevent unauthorized processing or access, in accordance with the state of technology and the nature of the stored data. Likewise, it is also guaranteed that any processing and recording in files, programmes, systems or equipment (whether local or centralized) complies with the requirements and conditions of integrity and security set forth in the current legislation.

 

7.4. LANGUAGE

The language applicable to this Privacy Policy is Spanish. Therefore, if there were any contradiction in any of the versions provided in other languages, the Spanish version will prevail.

 

7.5. CHANGES TO THIS PRIVACY POLICY

MIRZO MUSIC FOUNDATION reserves the right to make changes to this policy in order to adapt it to new changes in legislation or case law.

 

7.6. LEGISLATION

For all purposes, the relations between MIRZO MUSIC FOUNDATION and the Users of its online services present on this Website are subject to Spanish legislation and jurisdiction, to which the parties expressly submit. The Courts and Tribunals of Barcelona will hold jurisdiction for resolving any disputes derived from or related to the use thereof.