Privacy policy

This website and all its contents, including the texts, images, sound and any other material, are the property of Barcelona Activa.

BARCELONA ACTIVA SAU SPM (henceforth, “BARCELONA ACTIVA” or “The Entity”) having tax identification code (C.I.F.) A-58295296 and registered company address in Carrer de la Llacuna, nº. 162-164, 08018 Barcelona, duly registered with the Barcelona Company Register, hereby declares that it is the owner of the https://www.barcelonactiva.cat/ website as a municipal company of Barcelona City Council (henceforth, the “Website”) in accordance with the obligations provided for under Act 34/2002, of 11 July, on information society services and e-commerce (henceforth, the “LSSICE”).

Barcelona City Council is the Data Controller, as owner responsible for the service provided by BARCELONA ACTIVA, which acts as Barcelona City Council’s Data Processor. For further information, you may consult Barcelona City Council’s Privacy Policy, which is available from the city’s various Citizen Help and Information Offices and from the (https://seuelectronica.ajuntament.barcelona.cat/ca/proteccio-de-dades) website. Nevertheless, Section 4.2.2. of this Policy provides for certain types of processing regarding which BARCELONA ACTIVA is the Data Controller. This Privacy Policy applies to the data processed by BARCELONA ACTIVA in its capacity as Barcelona City Council’s Data Processor.

You will find information below on the data that BARCELONA ACTIVA processes as Data Controller and as Data Processor respectively.

All requested data must be incorporated through the Website for the purposes of achieving an optimal provision of the services put at the disposal of users. Unless users supply all the data required by BARCELONA ACTIVA, there will be no guarantee that the information and services requested can be provided, correctly provided or adjusted to the needs of the users.

The term “user(s)” is used here for referring to anyone of legal age who accesses the Website.

1. Identity and contact details of the Data Controller

Under the applicable data-protection regulations and, in particular, Regulation (EU) 2016/679 of the European Parliament and of The Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (henceforth, the “GDPR”), and Spain’s Framework Act 3/2018, of 5 December, on Personal Data Protection and Guarantee of Digital Rights (henceforth, the “LOPDGDD”), the Data Controller is:

2. Compliance with the applicable regulations

BARCELONA ACTIVA has adapted the Website to the GDPR and to the LOPDGDD. It has also implemented all the technical and organisational policies, measures and procedures for guaranteeing and protecting the confidentiality, integrity and availability of its personal data.

The User of BARCELONA ACTIVA’s services (henceforth, “the User”) voluntarily transfers their data through the Website, having been informed, in advance, of the use and purposes of the processing.

3. Principles wich we apply to your personal information

Data supplied to BARCELONA ACTIVA through various media, online or off-line contact forms, or any other procedure used for gathering your data will be processed in accordance with the current data protection regulations in force and for the sole purpose, as you have been informed, of providing the service.

We apply the following principles adjusted to GDPR requirements when we process your personal data:

• Principle of lawfulness, loyalty and transparency.

• Principle of data minimisation.

• Principle of storage limitation.

• Principle of integrity.

• Principle of confidentiality.

• Principle of data accuracy.

BARCELONA ACTIVA reserves the right to exclude from its services any User who has provided false data, without prejudice to any other legal actions that may go ahead.

4. Personal data processing

4.1. Personal data gathering and processing

Data supplied to BARCELONA ACTIVA through various media, contact forms, or any other procedure used for gathering your data will be processed in accordance with the current data protection regulations in force and for the sole purpose, as you have been informed, of providing the service.

The User of BARCELONA ACTIVA’s services voluntarily transfers their data through the Website, having been informed, in advance, of the use and purposes of the processing.

BARCELONA ACTIVA hereby informs the User that only the information necessary for achieving the purpose of the processing is gathered and only the data which the User has supplied for the purpose(s) that they gave their informed consent to will be processed.

4.2. Purposes of the processing

4.2.1. Barcelona City Council as the Data Controller

Barcelona City Council, as the Data Controller, has tasked BARCELONA ACTIVA, as the Data Processor, with achieving the purposes described below:

4.2.2 Barcelona Activa as the Data Controller

BARCELONA ACTIVA processes the following information as the Data Controller:

4.3. Personal data categories

Having regard to the above-mentioned purposes, BARCELONA ACTIVA gathers and processes the following categories of the User's data on behalf of Barcelona City Council:

• Identification data: name, surname(s), email address, telephone number, postal address, sex, date of birth, level of studies and employment.

• Sensitive data: disability, criminal record, data indicating social vulnerability. This information will be anonymised if used for statistical reports.

• Browsing data: BARCELONA ACTIVA also uses cookies to gather certain information on the User's browsing. Their processing and purposes are explained in our Cookies Policies https://www.barcelonactiva.cat/cookies.

With regard to enquiries or requests made through the forms available from the “CONTACT” and “INSTITUTIONAL VISITS” pages, Users are allowed to briefly explain the respective reasons for their enquiry and the institutional visit. Bear in mind that BARCELONA ACTIVA will not reply to any personal enquiries, except for those strictly established under the current legislation in force. Under no circumstances may the User communicate special category data (for example: data on health or religion) through the forms provided on the Website. Should they do so, the User shall exempt BARCELONA ACTIVA from all responsibility and liability. Any inappropriate enquiries or contents that are sent will be deleted by BARCELONA ACTIVA. 

For further information on the other types of data processing carried out by BARCELONA ACTIVA, please see our Register of Processing Activities at this link: https://www.barcelonactiva.cat/documents/20124/0/RAT_GENERAL_BA_tcm101-52112.pdf/02cdcac6-0879-8252-02ac-13428fc8df4a?t=1603117532896

5. Minors

Minors must not use the services available from the Website without the prior authorisation of their father, mother, guardian or legal representative, who shall be solely responsible and liable for all the actions carried out through the Website by the minors in their care, including the filling in of its forms with the minors’ personal data and the ticking, where appropriate, of their accompanying boxes.

6. Data processing by third parties and data transfers

Depending on the purposes for which the personal data were gathered, such data may be processed by:

• BARCELONA ACTIVA’s authorised staff or representatives acting in its name, subject to the current applicable data protection regulations in force.

• Public Administrations, Authorities and Bodies, including Courts, where required by the applicable regulations.

• Third-party external service providers hired by BARCELONA ACTIVA that have the status of data processor, IT services providers that process information, accommodation services, database, software and application maintenance support, training services, advice and any other service provider needed for achieving the purposes described in point 4.2. of this Policy. All that only after implementing the necessary measures to ensure we are able to share this information in accordance with the data protection regulations.

• We hereby inform you that your data may be transferred by BARCELONA ACTIVA on behalf of Barcelona City Council with your prior express consent – or as permitted on any other legal grounds – to the public administration, public sector entities and other companies with which valid contracts or collaboration agreements are in place for the purposes of fulfilling the aims directly related to BARCELONA ACTIVA's functions; as well as, where applicable, for managing active employment policies, intermediation in the labour market and carrying out internships.

• If an appointment is requested through the “WhatsApp” instant messaging application, the data of the person concerned will be processed by WhatsApp Ireland Limited. To find out about the data processing carried out by WhatsApp, you can access its privacy policy from the following link: https://www.whatsapp.com/legal/privacy-policy-eea.

Should BARCELONA ACTIVA undergo any sale, merger, consolidation, change in corporate control, substantial transfer of assets, reorganisation or liquidation, we may then transfer, sell or assign, at our discretion, the information gathered in the Website to one or more relevant parties.

7. Security measures

BARCELONA ACTIVA adopts the levels of security required by the GDPR appropriate to the nature of the data subject to processing at any time for its activity. Here it uses encryption techniques that prevent third parties from being able to trace the identity of the User interacting with our services. Likewise, it may also carry out secure anonymisation techniques on the personal data that it processes for the purposes of performing its activity. Nevertheless, technical security in a medium such as the Internet is not impregnable and malicious third-party actions may occur, although BARCELONA ACTIVA puts all its means at your disposal to prevent such types of actions.

8. International transfer of data

We do not transfer the User's personal data to third parties outside the European Economic Area. If international transfers of data are made, every appropriate technical and organisational measure will be taken to guarantee the data’s security.

9. Rights of the persons concerned an their exercise

In accordance with the GDPR and the LOPDGDD, Users may exercise the following rights:

• Right of access to data.

• Right to rectification of data.

• Right to request the erasure of data.

• Right to request the restriction of data processing.

• Right to object to data processing.

• Right to data portability.

• Right not to be subject to a decision based solely on automated personal-data processing.

• Right to revoke consent.

• Right to submit a complaint to the Catalan Data Protection Authority. You may submit your complaint before the Catalan Data Protection Authority (APDCAT) (https://apdcat.gencat.cat/ca/).

You can use the templates and forms on the rights referred to above by entering the official website of the Catalan Data Protection Authority (https://apdcat.gencat.cat/ca/documentacio/models_exercici_drets/), or emailing the Data Protection Officer at dpo@barcelonactiva.cat, with the REF: “Data Protection”

BARCELONA ACTIVA may request any additional information it deems necessary in order to properly address requests concerning the exercising of rights. 

In the event of the organisation having reasonable doubts about the identity of the interested party, it may request a copy of a document proving their identity (e.g. ID / DNI or passport). 

In situations where one of the following circumstances occurs, BARCELONA ACTIVA may also require a copy of the person's ID document or equivalent:

• Applications made by third parties on behalf of the interested party: Under these circumstances, BARCELONA ACTIVA may require a copy of the ID document or equivalent for the person authorised by the interested party, of the interested party themselves, as well as an authorisation from the interested party stating that the third party may exercise their rights on their behalf.  
• Unusual requests: If the application differs from what is typically expected, or is submitted in an unusual way, this may create a need for additional verification, in order to ensure that the application is legitimate and originates from the correct person.
• Access to sensitive or confidential information: If the application is related to information that is especially sensitive or confidential, additional identity verification may be requested, in order to ensure that only the authorised person has access to that information.
• Recent changes to personal information: If the applicant's personal information has recently changed, such as a change of name, address or telephone number, this may create doubts about that person's identity and justify an additional verification.
• Suspected fraud or identity theft: If there are reasonable grounds for suspecting that an attempted fraud or identity theft is occurring, it shall be necessary to carry out an exhaustive identity verification before providing access to personal data, in order to prove that the applicant is effectively the data subject or representative of the data subject in regard to the request for exercising rights.
• Multiple or repetitive applications: If someone submits multiple requests for exercising rights using different identities, or does so repeatedly, this may create suspicion and doubts about their real identity.

In any event, BARCELONA ACTIVA shall apply reasonable technical and organisational measures, taking into account the concurrent circumstances and always using the least invasive means possible in terms of the privacy of the applicants. 
 

10. Commercial and promotional information

If the User has authorised BARCELONA ACTIVA to send them commercial and/or promotional communications, the personal data that they provide through the corresponding form will be subject to processing by BARCELONA ACTIVA on behalf of Barcelona City Council, for the purposes of notifying them of any advertising content and commercial communications relating to the services provided by BARCELONA ACTIVA.

The User may revoke their consent at any time by accessing the link established in the newsletter and sending an email to dpo@barcelonactiva.cat, with the REF: “Cancel Newsletter”.

Newsletters may also contain links to third-party websites. We will store your data for the period of time you have signed up to the newsletters. If you cancel your subscription, we will block your data in that context so you will stop receiving BARCELONA ACTIVA’s newsletters.

11. Consent of the user concerned

The User declares they have read and expressly accepted this Privacy Policy.

The User undertakes to hold harmless and indemnify BARCELONA ACTIVA for any possible claim, fine or penalty that it may incur as a result of the User's breach of duty described in this paragraph.

12. Objection to or revocation of consent for data processing

If you have given your consent to the processing of your personal data, you can revoke that consent at any time. You can communicate your revocation to dpo@barcelonactiva.com.

Notwithstanding the above, despite any objection or revocation made, we may be legally obliged to keep the data.

In addition, you may also object and revoke your consent at any time to the processing of your personal data for advertising purposes. You can find the contact details in Point 1.

13. Links to other websites

This Website contains links or connections to other websites not managed by Barcelona City Council, which neither Barcelona City Council nor BARCELONA ACTIVA exercise any control over, nor is it responsible for the information they have access to. We suggest you visit these websites directly to obtain information on their Privacy Policies where information is provided on data protection, security, data collection and the arrangements for data transfers. BARCELONA ACTIVA shall not be responsible or liable for any action that may be taken through or from the contents of these websites.

Unless, therefore, the Data Controller or BARCELONA ACTIVA has authorised this in advance and in writing, no "link", "hyperlink", "framing" or the like may be inserted in the Website.

If you follow us on social media such as Twitter, Instagram, Facebook, YouTube, SlideShare and LinkedIn, please review their privacy policies for gathering information on how they process and share your personal data, as neither Barcelona City Council nor BARCELONA ACTIVA exercise any control them or is responsible or liable in any way for the information that the social media have access to.

14. Changes to Privacy Policy

We will only use personal data according to the provisions established in the Privacy Policy in force at the time when these data are gathered.

Barcelona City Council and BARCELONA ACTIVA reserve the right to amend this Privacy Policy at any time, with effect from the date of these amendments’ publication on the Website, which is why we recommend you visit it every time you access it. If we decide at any time to use personal data differently from the way(s) stated when they are gathered, the User will be informed of this by email, provided we have their email address. The User will be given an option at that time for authorising other uses or disclosures of the personal data provided to us before the amendment to our Privacy Policy.

Should any clause in this Privacy Policy be set aside or considered null and void, none of the other terms and conditions shall be affected, remaining fully valid and enforceable, under the current regulations applicable at any time.

15. Applicable legislation

The privacy of all the information provided, both by the User through the various personal data request forms and by what is accessible through the Website, is governed by the current data protection regulations in force, above all, the GDPR and the LOPDGDD. 

16. Cookies

Access to the Website may involve the use of cookies. Cookies are small quantities of information which are stored in the browser used by each User so that the server can remember certain information. That information may subsequently identify them as a specific user and enable their personal preferences to be stored, as well as technical information on the Website’s use and operability.

Users who do not wish to activate the cookies or wish to be informed before they are stored on their devices may arrange the settings for their own device for that purpose. For further information, you can see our Cookies Policy https://www.barcelonactiva.cat/cookies.