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Madrid for Refugees Privacy Policy

Effective date: February 23rd 2022.
Last revision: May 16th 2022.

Madrid For Refugees, and its IT formation subsidiary, Refugees Code (hereafter referred to as “us”, “we”, or “our”) operates the www.madridforrefugees.org website (hereafter referred to as the “Website”). Within the wording of this policy, we utilize “you” or “your” to refer to you as an user of our free services, or as a donor or volunteer.

We are committed to ensuring the privacy of your personal information, such as your full name, address, e-mail address, telephone number or other identifying information, according to the General Data Protection Regulation (EU) 2016/679 and the Organic Law 3/2018 of December 5 on Protection of Personal Data and Guarantee of Digital Rights.  Madrid For Refugees only uses your personal information for purposes as disclosed in this Privacy Policy or as disclosed by us at the time information is requested from you.

The controller for your Personal Data, when the data is processed in ways outlined herein:

Entity: Madrid For Refugees (Association)

Registered Address: C/Victoria 9, 28012 Madrid

Tax Registration Number: G87483087
National Registry of Associations in Spain nº 610122

E-mail address: info@madridforrefugees.org

Types of Data Collected

Contact details: While using our Website, we may ask you to provide us with certain Personal Data that can be used to contact you. The Personal Data we ask may include your name, email address, telephone number and other contact details.

Course eligibility data: At the time of enrolling to our courses, we may ask you to provide us with certain Personal Data to assess your eligibility to take part in our courses. The Personal Data we ask may include your country of origin, asylum status, right to work in Spain and other information. Requesting this kind of data allows us to maintain the mission of our organization, which is to provide assistance, formation, and other services or initiatives directed at people in asylum status, whether in process or already granted, in the city of Madrid. This data will only be used to assess eligibility and will not be subject to any kind or level of discrimination. 

Personal Data Usage

Our website provides a variety of opportunities for your involvement with the Refugees Code services and features. These opportunities and the ways in which your Personal Data is used are described below.

Enrollment in our formation courses

To take part in Refugees Code formation courses, you must submit Personal Data for us to be able to evaluate your eligibility for such courses. This is because the Refugees Code courses and other initiatives are directed at people of any age, gender, nationality, that are located within the territory of the Kingdom of Spain and are currently in asylum status, whether already granted or in progress. Additionally, we will request contact information from you to get in touch with you before, during and after the completion of the course. All data referred to course and workshop registration will be processed and stored in our official Madrid For Refugees AirTable account with restricted access and only essential data for the execution of the course or workshop will be communicated to the instructors via closed communication tools. To review AirTable’s privacy policy, you can access it through this link: https://www.airtable.com/privacy 

The legal basis for the processing of Personal Data in this case is our legitimate interest to ensure the adequacy of our initiatives and performance of a contract with you as you wish to enroll to our courses. In any case, to the extent the data processing activity is based on our legitimate interest, you can also exercise your right to object to such processing on grounds relating to your situation, at any time. Your Personal Data shall be retained for the time required to fulfill the purposes. We will not trade, share, transfer or sell this information to third parties, either online or offline. Additionally, we may request you to add further information about you in an anonymized form for statistical purposes.

Donation and Donor Information

To make a donation to Madrid for Refugees or Refugees Code, you must submit Personal Data such as contact information and residence area so that we may use it for the purpose of processing donations. The legal basis for the processing of Personal Data is the performance of a contract to which you, as a data subject, are a party, or the performance of a legal obligation, or our legitimate interest in having an overview of our donors. We will not trade, share, transfer or sell this information to third parties, either online or offline. At any case, to the extent the data processing activity is based on our legitimate interest, you can also exercise your right to object to such processing on grounds relating to your situation, at any time.

Volunteer registration

To become a volunteer for Madrid for Refugees and/or Refugees Code, you must submit your Contact Details and other Personal Data such as your name and professional background. The legal basis for the processing of this data is our legitimate interest to assess your eligibility as a volunteer to Madrid For Refugees or Refugees Code and to be able to get in touch with you. Once your volunteer application is successful, we will ask you to sign a Code of Conduct in which some additional details will be requested. Additionally, we may request you to add further information about you, such as country of origin and gender for statistical purposes. Unless explicitly specified otherwise by you, the e-mail address you register with will be used for intra-team communications and displayed to all volunteers on our internal communication channels. All data referred to course and workshop registration will be processed and stored in our official Madrid For Refugees AirTable account with restricted access. To review AirTable’s privacy policy, you can access it through this link: https://www.airtable.com/privacy 

In any case, to the extent the data processing activity is based on our legitimate interest, you can also exercise your right to object to such processing on grounds relating to your situation, at any time. We will not trade, share, transfer or sell this information to third parties, either online or offline.

Newsletter

To receive Refugees Code emails and communication regarding initiatives, upcoming courses, among other, you should submit your email address to us. You will then start receiving emails on a regular basis. The legal basis for the processing of Personal Data in this case is your consent. We will not trade, share, transfer or sell this information to third parties, either online or offline.

You can unsubscribe from emails by following the unsubscribe instructions in each email.

Other ways in which we may use your Personal Data

Madrid for Refugees may use your Personal Data also for the following purposes:

  • To provide and maintain the Website. The legal basis for the processing of Personal Data in this case is our legitimate interest. You can also exercise your right to object to such processing on grounds relating to your situation, at any time.
  • To provide customer care and support. The legal basis for the processing of personal data is our legitimate interest in taking care of our customers’ needs, or the performance of a contract to which you, as a data subject, are a party.
  • To carry out analysis or collect valuable information so that we can improve the Website. The legal basis for the processing of personal data in this case is our legitimate interest in learning how we can improve our Website and your consent when we rely on cookies or other tracking technologies. 
  • To monitor the usage of the Website. The legal basis for the processing of personal data in this case is our legitimate interest in ensuring the safety of our Website.
  • To provide our services to you. The legal basis for the processing of personal data is either the performance of a contract to which you, as a data subject, are a party or our legitimate interest, depending on the circumstances.

Recipients of Personal Data

  • Data processors within Madrid for Refugees, including data processors within Refugees Code.
  • Public authorities and bodies, including Courts and Tribunals, when required by the applicable regulations.

Madrid for Refugees will not otherwise use or disclose your Personal Data to third parties unless required to do so by law or in order to defend its lawful interest and comply with its legal obligations. 

Transfers of your Personal Data to third parties or external entities will never be carried unless necessary and provided there is an adequate mechanism for such international transfer in accordance with the applicable laws.

Legal Requirements

Storage of your Personal Data and Security

We store your Personal Data only as long as is necessary to fulfill the purposes for which the Personal Data were collected. Your Personal Data will be stored according to cybersecurity and security guidelines.

Your rights as a Data Subject

Subject to statutory restrictions, you have the right to:

  • request access to your personal data;
  • request rectification of your personal data;
  • request erasure of your personal data;
  • request a restriction on processing your personal data;
  • object to the processing of your personal data;
  • receive your personal data in a machine-readable format and to transmit the data to another controller (right to data portability);
  • withdraw your consent of data processing at any time, without this affecting the lawfulness of the processing prior to withdrawal.

You have the right to object to the processing of your personal data. However, we note that certain personal data is necessary for us to provide our services to you. Therefore, when you object to the processing of such data, we may not be able to provide our services to you.

Where necessary, you may correct or update any Personal Data that you have provided to us.

In order to exercise the above mentioned rights, please contact us on dataprotection@madridforrefugees.org  

If you are of the opinion that we have breached your privacy rights in any way, you have the right to lodge a complaint with a supervisory authority in the Member State of your habitual residence. The list of European Data Protection Authorities can be accessed at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

Changes to the Privacy Policy

We reserve the right to update or modify this Privacy Policy at any time. We will notify you of any changes by posting the new Privacy Policy on our website along with a changes log.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy become effective once they are posted.

Contact Us

If you have any questions about this Privacy Policy, please contact us on dataprotection@madridforrefugees.org

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