Privacy policy

Privacy policy and information on personal data protection of Basque Country Cycling website and social networks

  1. Data Controller

The company BASQUE COUNTRY EXPERIENCES S.L. (hereinafter “BCE” or “Data Controller”) acts, under the terms established in the data protection regulations, as Data Controller in relation to the processing of personal data (e.g. customers, website users, information requesters) that are made through BCE’s websites, smartphone applications (“APP”s) and social media presence.

Data controller: BASQUE COUNTRY EXPERIENCES S.L.

NIF: B55386684

Address: C/ Jose Miguel Barandiaran 24. Bajo. 20013 Donostia San Sebastián (Spain)

Telephone: +34 617702185

Email: info@basquecountrycycling.com

Registration information: Commercial Registry of Gipuzkoa, number of entrance 1/2024/4348,0, diario 2024, asiento 348 on the 4th of June 2024, folio eléctrónico, IRUS :1000422261147, inscripción/anotación 1 con hoja SS-46938.

  1. Applicable Legislation

The basic regulations regarding the protection of personal data applicable to the data processing carried out by BCE are:

  • EU Regulation 2016/679 of the European Parliament and of the Council of April 27, 2016, regarding the protection of natural persons regarding the processing of personal data and the free circulation of these data (“GDPR”).
  • Organic Law 3/2018, of December 5, regarding the Protection of Personal Data and digital rights guarantee (“LOPDGDD”).
  • Their respective complementary and development regulations.
  1. Website identification and social network presence

BCE’s official website is www.basquecountrycycling.com.

BCE’s main official channels in social and professional networks are the following:

For the purposes of this Privacy Policy, the official BCE website, APPs and official channels on social or professional networks will all be referred to hereinafter as “the website”, except when otherwise specified.

  1. Purposes of data processing and legitimate legal basis

In compliance with current regulations on the Protection of Personal Data, users are informed that the personal data they provide through any means located on the website or official channels on BCE’s or professional networks (by email, forms, e. g.), or as a result of their use, may be incorporated into BCE’s data processing systems.

The purposes of the data processing that BCE’s can carry out through the website are:

  1. CUSTOMERS AND WEBSITE USERS:

Purpose: offering cycling experience tours and bike rentals, and related activities.

Legal Basis: We need to process the data to manage our products and services (“contractual” or “pre-contractual” relationship according to article 6.1.b of the GDPR).

Possible recipients: No communication of data to third parties is foreseen, except to BCE’s suppliers that intervene in any phase of the marketing or delivery of the products or services requested and for legal obligations or specific cases.

Rights: Please read the “Rights of Interested Parties” section.

  1. INFORMATION REQUESTS:

Purpose: Providing contact, consultation, and communication tools with interested and related people, responding to applications and requests.

Legal basis: Consent from the interested party (GDPR art. 6.1.a), when they provide their data for these purposes, by filling in “Contact” forms or similar, and checking the required boxes to accept the conditions and the privacy policy.

Possible recipients: We do not foresee the communication of data to third parties.

Rights: Please read the “Rights of Interested Parties” section.

  1. USERS OF THE WEBSITE AND THE SOCIAL OR PROFFESIONAL NETWORK CHANNELS:

Purpose: Managing and analyzing the use of the website and its corporate presence in social and professional networks.

Legal Basis: BCE’s legitimate interest (GDPR art. 6.1.f) in publicizing its products, services and activities.

Possible Recipients: We do not foresee the communication of data to third parties, except for the publication or dissemination of the opinions and evaluations made.

Rights: Please read the “Rights of Interested Parties” section.

  1. USERS OF THE WEBSITE AND THE SOCIAL OR PROFFESIONAL NETWORK CHANNELS:

Purpose: Managing and analyzing the use of the website and its corporate presence in social and professional networks.

Main Legal Basis: BCE’s legitimate interest (GDPR art. 6.1.f) in knowing and managing the operation of its website and its channels on social and professional networks.

Specific Legal Basis: Consent from the interested party (GDPR art. 6.1.a), when the data analysis is based on the use of analytical cookies, advertising cookies, or similar technologies, granted by accepting the use of cookies.

Possible Recipients: We do not foresee the communication of data to third parties.

Right to Modify or Revoke the Consent Granted for the Use of Cookies: The user has the “Cookie Settings” tool available at all times on the website for this purpose.

Other Rights: Please read the “Rights of Interested Parties” section.

  1. PEOPLE APPLYING FOR JOBS THROUGH THE WEBSITE AND CHANNELS ON SOCIAL OR PROFESSIONAL NETWORKS

Purpose: Provide a tool for contact, consultation and communication with people interested in working at BCE and, where appropriate, to invite them to participate in the company’s personnel selection processes.

Legal Basis: We need to process the data to manage the application (RGPD art. 6.1.b) and consent from the interested party (GDPR art. 6.1.a) for the use of the website.

BCE’s legitimate interest (GDPR art. 6.1.f) in publicizing its products, services and activities.

Possible Recipients: It may be carried out internally or by external companies that BCE hires to carry out personnel selection processes.

Rights: Please read the “Rights of Interested Parties” section.

  1. Data retention period

The personal data provided will be kept for the time necessary to fulfill the purpose for which they are collected, determine the possible responsibilities that may arise from the purpose, or for the period that the applicable regulations establish in each case (accounting, tax, commercial, e.g.), after which they will be deleted by adopting the necessary security measures to guarantee their confidentiality.

  1. Rights of the interested parties

You can exercise the rights related to the protection of your personal data (e.g. access, rectification, erasure, restriction of processing, objection, portability), as well as withdraw the consent granted or make any other request on this matter by writing to BASQUE COUNTRY EXPERIENCES S.L., at C/ Jose Miguel Barandiaran 24. Bajo. 20013 Donostia San Sebastián (Spain), telephone +34 617 70 21 85, or at the email address info@basquecountrycycling.com.

The application must include a copy of a document proving the applicant’s identity. If you make the request in your capacity as legal representative, you must attach, in addition to a copy of a document proving the identity of the applicant, a document proving such a representation.

The control authority to which you can go if you do not agree with the resolution of the requests or to file a claim is the Spanish Agency for Data Protection (www.aepd.es).

  1. Personal Data Collection

The Data Controller does not require you to provide personal data to access the website. However, the website contains utilities and forms (e.g. contact form) whose use requires the user to provide personal data, mostly identification or contact data. The user provides personal data freely and voluntarily. BCE does not request more personal information than necessary to carry out each requested service.

Any user who sends/includes any type of content (data, documents, texts, images, videos, sound, graphics, messages, or other material) declares and guarantees to do so in such a way that it complies with the conditions expressed herein and with the current legislation. Any user who includes third-party personal data declares that they have their prior and express consent for their processing. The inclusion of third-party data without their prior and express consent is prohibited.

The user is solely responsible for the veracity, correctness and legitimate processing of the data included, exonerating BCE from any responsibility in this regard. Users guarantee and are responsible, in any case, for the accuracy, validity, and authenticity of the personal data provided and undertake to keep them duly updated.

The non-completion or erroneous completion of fields indicated as mandatory in the forms on the website may result in the Data Controller not being able to attend to the user’s request.

The Data Controller will collect personal data appropriately, according to the purposes, utilities, services, or features included on its website, in a determined, explicit, and legitimate manner, so that in no case will fraudulent, unfair, illicit, or illegal means be used that in any way endanger the legitimate rights of users.

Sending information through this website implies acceptance of this privacy policy and general conditions of the website.

  1. Specific data processing: minors

The services of the Data Controller are not aimed at minors. If some of our products or services were specifically directed to minors, the Data Controller would request the consent of the parents or guardians for the collection of personal data or, where appropriate, for the treatment of the data.

BCE recommends that users consult the different materials that have been developed by the supervisory authorities in relation to the protection of personal data of children and young people. This information (recommendations, manuals on the use of new technologies, educational videos, etc.) is available on the websites of the Basque and Spanish Data Protection Agencies.

  1. Specific data processing: Job applicants

Any person who provides their curriculum vitae offering their candidacy to work at BCE through forms, email, social or professional network channels or similar mechanisms, is informed, in accordance with the provisions of the Personal Data Protection regulations, that the data provided through their job application will be incorporated into our data processing systems (“CV and personnel selection” processing”).

Their data may be used for the purpose of making them participate in future personnel selection processes inside our company, which may be carried out internally or by external companies that BCE hires to carry out personnel selection processes.

BCE will keep their resume for approximately one year. After this, the data will be destroyed, applying the necessary security measures to guarantee its confidentiality.

If you do not agree with any of the purposes described, please notify us in writing as soon as possible. Likewise, if there is any change in your data, please keep us informed.

You can exercise the rights related to the protection of your personal data (access, rectification, erasure, restriction of processing, objection, portability, e.g.), as well as any request on this matter as indicated in the section “Rights of Interested Parties” of this Privacy Policy.

  1. Specific data processing: registrations and subscription

In the case of subscription to newsletters or similar services, which involve the processing of personal data, users may request cancellation of said services at any time by sending a request to the e-mail address info@basquecountrycycling.com or using any other means that BCE provides for this purpose, such as the mechanism called “Unsubscribe”, located at the end of the newsletters themselves.

  1. Links to social and professional networks

This website offers links to social networks and external websites and channels. BCE assumes no responsibility in relation to these linked sites. Any user who accesses social and professional networks and external websites and channels related to BCE, from the links located on this website or in any other way, is previously and expressly informed that the conditions of use, privacy policies, cookie policies and any other conditions or regulations depend on the entities responsible for said social networks and websites and channels, and never on BCE.

  1. Presence of Basque Country Experiences SL in social and professional networks

BCE can have profiles on social and professional networks, with the main purposes of disseminating its products, services, and activities, and establishing channels of communication with companies and professionals. The publications offered through these channels are informative in nature.

By registering in the BCE profiles with their profile on a social or professional network, the user gives their express authorization to BCE for the processing of their personal data in accordance with this Privacy Policy.

Any information and personal data provided voluntarily by the user through BCE’s social or professional networks may be processed for the purpose of contacting the user and dealing with requests made, sending informative or commercial communications, managing events, invitations and similar activities, to know their opinion or assessment about BCE and its publications and to manage, in general, the presence of BCE in social and professional networks.

Users are informed that the information and content (data, texts, videos, sound, photographs, graphics, comments, messages or other material) that they publish through BCE’s social or professional networks (including, where appropriate, personal data) may be made publicly available to other users of these social or professional networks and may be freely visible, commented on and shared by their visitors, under the terms established by each social or professional network.

From the configuration of the user profile of each social or professional network, the user can configure what information they want to make public in each case, check the permissions they have granted, delete or deactivate them, and manage their publications according to their criteria and the rules of use of each social or professional network.

The user will be solely responsible for their publications respecting current legislation, the rules of use and privacy policies established by the corresponding social or professional network, and those of BCE, which does not assume any responsibility in relation to the publications that each user performs. BCE will unilaterally and without prior notice remove content that it considers to be in violation of current legislation, the rules of use and established privacy policies, or that it considers inappropriate.

BCE can follow other profiles on other social or professional networks, without this fact implying a link of any kind with them.

In turn, the BCE channels in different social or professional networks can be followed by other people or users of those networks, without this fact implying any kind of connection with them.

BCE reserves the right not to respond to messages or comments received through these channels. BCE may modify or delete at any time and without prior notice the publications issued on its social networks.

By becoming a follower, clicking “Like” or taking any other similar action on social or professional networks, you consent to the processing of your personal data in the environment of the corresponding social or professional network, in accordance with its privacy policies, BCE’s access to data contained in the contact list and that of their publications, expressly including those of a commercial nature, appear in your notices and notifications.

If the user wants to stop following the official channels on BCE’s social or professional networks, they must do so using the tools provided for this purpose by each network.

  1. Security Measures

BCE will process the personal data contained in its data processing system, adopting the technical and organizational measures that are necessary to guarantee its security and avoid its alteration, loss, processing or unauthorized access, taking into account the state of the technology, the nature of the stored data and the risks to which they are exposed, whether they come from human action or from the physical or natural environment, in accordance with current legislation that is applicable in terms of security measures for personal data processing. However, users are informed that computer security measures are not impregnable and are not safe from possible illegal and improper interference, which would not be the responsibility of the Data Controller.

To guarantee the security and privacy of the user, this website uses encryption technology based on secure connection layer protocols (https), so that browsing is as secure as possible.

  1. Security Breaches

The user must immediately notify BCE of any incident, security breach, improper or unauthorized access detected in relation to the website, private areas, access codes, presence in social or professional networks or any other circumstance that jeopardizes the security and confidentiality of the information or the proper functioning of the website.

The telephone number 617702185 and the email address info@basquecountrycycling.com  are established as preferential notification mechanisms.

  1. Duty of Secrecy

The Data Controller is committed to the privacy and protection of user data. The processing of their personal data will be carried out confidentially and in compliance with current legislation.

  1. Validity and modifications

The Data Controller reserves the right to modify its privacy policy according to its criteria, to introduce legislative or jurisprudential changes. If the Data Controller introduces any modification, the new text will be published on this same website, where the user may have knowledge of it. In any case, the relationship with the users will be governed by the rules established at the precise moment when the website is accessed. That is why the Data Controller recommends that you visit this privacy policy each time you connect to the website.

  1. Authority

Any relationship established between BCE and the user will be governed by the provisions of the current regulations regarding the applicable legislation and the competent authority. However, for cases in which the regulations provide for the possibility for the parties to submit to an authority, BCE and the user, expressly waiving any other jurisdiction that may correspond to them, submit to the Courts of Donostia / San Sebastián (Gipuzkoa, Spain).

BCE will pursue legal action against the breach of these Conditions, as well as against any improper use of the contents and utilities presented on its website, exercising all civil and criminal actions that may correspond by law, including those of an economic nature.