1. Identification

  • Owner/Controller: Fundación Centro de Estudios Monetarios y Financieros (CEMFI) (hereinafter, "CEMFI").
  • TAX ID (NIF): G79812806
  • Address: Calle Casado del Alisal 5, 28014, Madrid
  • Phone: +34 914 290 551
  • E-mail: dpo@CEMFI.es

CEMFI will act as joint controller for the processing of the data together with Universidad Internacional Menéndez Pelayo with NIF Q2818022B, address Calle Isaac Peral, 23 -28040 Madrid and e-mail dpd@uimp.es in relation to the processing of the application for the Master in Economics and Finance and the PhD in Economics.

2. Information

By accepting this Privacy Policy, the user (hereinafter, the "User" or, where appropriate, "Users") is informed that the personal data provided through the website located at the URL www.CEMFI.es (hereinafter, the "Website"), as well as the data derived from its navigation and those other data that the User may provide in the future, will be processed by CEMFI as controller for the processing with the purposes indicated in this Privacy Policy.

The User should carefully read this Privacy Policy, which has been written in a clear and simple way, to facilitate its understanding, and the User may freely and voluntarily determine whether he/she wishes to provide his/her personal data to CEMFI.

3. Obligation to provide the data

The data requested in the forms on the Website are, in general, mandatory (unless otherwise specified in the field) to fulfill the purposes for which they are being collected.

Therefore, if the User does not provide them or does not provide them correctly, the User's requests cannot be fulfilled, notwithstanding the fact that he/she may freely view certain contents of the Web Site.

4. Origin of the data

The data processed by CEMFI for the purposes listed in the following section come from:

  • The User himself/herself through the different forms of the Website, the data obtained from the use of the Website by the User and his/her navigation through it (through cookies or data storage and retrieval devices).
  • Third party sources: in those cases in which it is necessary to contrast and validate the information provided by the user, using publicly available sources, for example: to verify the validation of foreign diplomas.

5. For what purposes will CEMFI process the user's data?

CEMFI will process the User's data for the following specific purposes:

  • Manage the registration and deregistration of the User registered on the Website: in order to facilitate the User's access to the services offered by CEMFI through the Website. As well as, to contact the User to remind him/her and/or help him/her to finalize the activation of his/her account.
  • Verify the User's account: process and manage User's identity verifications via email.
  • To manage the User's registration request, enrollment and management in relation to the different courses, activities and seminars offered through the Website and to allow the display of their profile to the rest of the participants.
  • Manage the User's application for enrollment in the Master in Economics and Finance PhD in Economics, in order to review the assessment of the necessary requirements and their admission.
  • Give answer to the issues raised by the User through the contact channels provided: manage, process and support requests, applications, incidents, complaints or queries made by the User through the various communication channels made available to the User.
  • Preparation of reports, statistics and internal analysis to improve the services of the Website: analyze, manage and prepare internal reports and statistics on the behavior of Users to implement improvements to the Website, in any case, using aggregate information.
  • Send communications to the User by CEMFI about courses, masters, doctorates, internships and seminars or own or third party events in which CEMFI collaborates: if the User consents to it by checking the appropriate box.
  • Conduct quality and satisfaction surveys to Users: regarding the quality and satisfaction with the courses, masters, internships and seminars provided by CEMFI, as well as to carry out analysis of the reports and statistics obtained from Users' responses.
  • To comply with legally established obligations: when the processing is necessary to comply with a legal obligation derived from Spanish or European Union law that may be applicable to CEMFI.

6. What user data will CEMFI process?

When using the Website, the following personal data may be processed:

a) To manage the registration and deregistration of the User registered on the Website:

  • Contact information: e-mail.
  • Connection data: encrypted password.

b) To verify the User's account:

  • Contact information: e-mail.

c) To manage the User's registration request, enrollment and management in relation to the different courses, internships and seminars offered through the Website and to allow the display of their profile to the rest of the participants.

  • Identification data: name, surname, DNI or NIE, passport, image.
  • Contact information: e-mail, phone number and postal mail.
  • Connection data: encrypted password and login.
  • Data on personal characteristics: date of birth and nationality.
  • Data on social circumstances: language, personal website address and interests.
  • Location data: country.
  • Data on the services or products contracted: course, seminar, master or internship.
  • Academic data: degree, certificate of analytical knowledge, English level, academic record, letter of recommendation, CV.
  • Professional or employment data: employer.

d) To manage the User's application for enrollment in the Master in Economics and Finance and PhD in Economics

  • Identification data: name, surname, DNI or NIE, passport, image.
  • Contact information: e-mail, telephone and postal mail.
  • Connection data: encrypted password and login.
  • Data on personal characteristics: date of birth and nationality.
  • Data on social circumstances: language.
  • Location data: country.
  • Academic data: degree, certificate of analytical knowledge, English level, academic record, letter of recommendation, CV.

e) To give answer to questions raised by the User through the contact channels provided

  • Identification data: first name, last name.
  • Contact information: e-mail, telephone and postal mail.
  • Data on social circumstances: language.
  • Other data: any data that the User may provide in connection with the query or request raised.

f) Preparation of reports, statistics and internal analysis to improve the services of the Web Site

  • Aggregate User Information.
  • Data on social circumstances: language.
  • Location data: country.
  • Website navigation data: IP, advertising ID, behavior on the Website.

g) To send commercial communications to the User, by CEMFI about courses, masters, doctorate, internships and seminars or own or third party events in which CEMFI collaborates

  • Identification data: name, surname, DNI or NIE, passport, image.
  • Contact information: e-mail, telephone and postal mail.
  • Data on personal circumstances: interests.

h) To conduct quality and user satisfaction surveys:

  • Identification data: first name, last name.
  • Contact information: e-mail address, telephone, mailing address.
  • Data on the services or products contracted: course, seminar, master or internship.
  • Other data: any data that the User may provide in the survey, such as opinions.

i) To comply with the legally established obligations:

  • Any data that may be legally required, in particular:

In the event that the User provides data of third parties, he/she declares to have the consent of these and/or sufficient legitimacy and undertakes to transfer them the information contained in the Privacy Policy, exempting CEMFI from any liability in this regard.

However, CEMFI may carry out the appropriate verifications to check this fact, adopting the corresponding due diligence measures, in accordance with data protection regulations.

In addition, the Registry of the Processing Activities of this entity is available in the Transparency Portal in the following link.

7. What is the legal basis of the processing of user data by CEMFI?

CEMFI processes the User's data according to the following legal bases:

  • Manage the registration and deregistration of the User registered on the Website: the processing of data derived from this purpose will be based on the fulfillment of the commercial relationship legal basis.
  • Verify the User's account: the processing derived from this purpose is the legitimate interest of CEMFI, recognized to the data controller by the regulations.
    This legitimate interest is based on ensuring that the goods and services are not used fraudulently, offering the User an additional layer of security protection, non-compliance with this Privacy Policy.
  • To manage the request for registration, enrollment and management of the User in relation to the various courses, internships and seminars offered through the Website, the processing of data derived from this purpose will be based on the fulfillment of the contractual relationship, while the processing of data derived from the purpose of allowing the display of your profile to other participants is based on the consent, which the User provides by checking the appropriate box and which may be withdrawn at any time.
  • Manage the User's application for enrollment in the Master in Economics and Finance and PhD in Economics: the processing of data derived from this purpose will be based on the legitimacy of compliance with pre-contractual measures.
  • To give answer to questions raised by the User through the contact channels provided: the processing of data derived from this purpose is the consent that the User may withdraw at any time. In the event that the User withdraws consent, the query or question raised may not be processed.
  • Preparation of reports, statistics and internal analysis to improve the services of the Website: all processing derived from this purpose will be based on legitimate interest recognized to the data controller by the data protection regulations.
    This legitimate interest is based on being able to know the state of operation of the Website and to detect errors or issues to be improved by adapting the Website to its final recipients, the Users, improving their experience. However, the User has the right to object to this processing at any time.
  • Send commercial communications to the User by CEMFI about courses, masters, doctorates, internships and seminars or own or third party events in which CEMFI collaborates: the processing derived from this purpose will have as a legal basis the consent, which the User provides by ticking the corresponding box and that may be withdrawn at any time.
  • To carry out quality and satisfaction surveys to Users: the processing derived from this purpose will be based on the legitimate interest, recognized to the data controller by the data protection regulations.
    This legitimate interest is based on being able to implement operational and product improvements adapted to its final recipients, the Users. The information obtained will be deleted once the corresponding statistical report has been drawn up, which in no case will contain personal data. However, the User has the right to object to this processing at any time.
  • To comply with legally established obligations: All processing derived from this purpose will be based on compliance with a legal obligation.

The consents obtained for the aforementioned purposes are independent, so the User may revoke only one of them without affecting the others.

8. Storage of data

The User's personal data will be stored by CEMFI for the following periods:

  • Data provided for the management of the registration and cancellation of the User registered on the Website: the data provided will be stored until the User requests the deregistration and, once the deregistration is completed, during the prescription period of the legal actions that may arise from it.
  • Data provided to verify the User's account: the data provided will be stored for the time necessary to verify the User's identity and, even afterwards, during the prescription period of any legal actions that may arise from it.
  • Data provided to manage the request for registration, enrollment and management of the User in relation to the various courses, internships and seminars offered through the Website and allow the display of your profile to other participants: the data provided to manage, process, formalize and fulfill the contractual relationship will be stored during the business relationship and, once it is terminated, during the prescription period of legal actions that may arise from it.
  • To manage the User's application for enrollment in the Master in Economics and Finance and PhD in Economics: the data provided will be stored during the period of time in which the selection process is active and, once it is completed, if the User has been admitted, for the duration of the Master or PhD and, if the User has not been admitted, during the prescription period of legal actions that may arise from it.
  • Data used to respond to questions raised by the User through the contact channels provided: the data will be stored for the period necessary to process and respond to your request and, once completed, during the prescription period of legal actions arising from the request.
  • Data used for the preparation of reports, statistics and internal analysis to improve the services of the Web Site: the data provided for this purpose will be stored for the duration of the surveys and, once the survey is completed, for the prescription period of legal actions that may arise from it.
  • Data used to send commercial communications to the User by CEMFI about courses, masters, doctorates, internships and seminars or own or third party events in which CEMFI collaborates: the data will be processed in accordance with this purpose until the User revokes his consent.
  • Data provided to carry out quality and satisfaction surveys to Users: the data provided for this purpose will be stored for the duration of the surveys and, once the survey is completed, for the prescription period of legal actions that may arise from it.
  • Data used to comply with the legally established obligations: the data provided to comply with the obligations arising from the services offered by CEMFI will be stored for the legally established periods.

 

9. With which recipients will the user's data be shared?

All personal data provided by the User through the Website may be disclosed to:

  • Public Administrations, in the cases provided for by law, based on the fulfillment of a legal obligation.
  • Courts and Tribunals, in the cases provided by law, based on the fulfillment of a legal obligation.
  • Persons who issue a recommendation of the User, with the purpose of forwarding such recommendation, based on the fulfillment of the contractual relationship.
  • National Agency for Quality Assessment and Accreditation (ANECA), in order to pass the audits, based on CEMFI's legitimate interest in obtaining a certificate attesting to its compliance with applicable regulations.

In addition, CEMFI will collaborate with third party service providers who may have access to your personal data and who will process your data on behalf of CEMFI in order to provide services to you. CEMFI follows rigorous supplier selection procedures in order to comply with its data protection obligations, including the subscription of the corresponding data processing contract in accordance with art. 28 of the GDPR.

Specifically, CEMFI will count on the rendering of services by third party suppliers that carry out their activity, by way of example and without limitation, in the following sectors of activity: legal advice and technological and computer services.

10. User's responsibility

The User guarantees that he/she is at least eighteen (18) years old and that the information provided to CEMFI is true, accurate, complete and updated. To this effect, the User is responsible for the truthfulness of all the data he/she provides and shall keep the information provided properly updated, so that it corresponds to his/her real situation.

Likewise, you warrant that you have informed the third parties from whom you provide your data, if you do so, of the aspects contained in this document. Also, you guarantee that you have obtained their authorization to provide their data to CEMFI for the purposes indicated.

In any case, the User shall be liable for any false or inaccurate information provided through the Website and for any damages, direct or indirect, caused to CEMFI or third parties.

A claim can be submitted as well as arise a request to our Data Protection Officer dpo@cemfi.es.

11. Exercise of rights

As owner of the data, the User may send a letter to CEMFI, at the address indicated in the heading of this Privacy Policy, or by e-mail to the address: dpo@CEMFI.es , or to the Universidad Internacional Menéndez Pelayo at the postal and e-mail address of the Universidad Internacional Menéndez Pelayo, mentioned at the beginning of this Privacy Policy, proving his identity, at any time and free of charge, in order to exercise the following rights:

  • Right of Access:

You have the right to be informed by CEMFI whether or not it is processing your personal data and, if so, to have access to such data and to receive information on the purposes for which they are processed, the categories of data affected by the processing, the recipients to whom your personal data were disclosed and the expected period of data storage, among other information.

  • Right of Rectification and Erasure:

You will have the right to request the erasure of personal data provided that the legal requirements are met, and the rectification of inaccurate data concerning you when, among other reasons, they are no longer necessary for the purposes for which they were collected.

  • Limitation of processing, revocation of consent and total or partial objection to processing:

In certain circumstances (for example, in the event that the applicant disputes the accuracy of his or her data, while the accuracy of the data is being verified), he or she may request that the processing of his or her personal data be restricted and processed only for the purpose of asserting or defending claims.

You also have the right to withdraw your consent and to object to the processing at any time, for reasons related to your particular situation, if the processing is based on our legitimate interest or on the legitimate interest of a third party (including processing for direct marketing and profiling purposes). In this case, CEMFI will cease the processing, unless legitimate reasons are demonstrated.

  • Portability of your data:

You will have the right to receive the personal data you have provided to CEMFI in a structured, common and machine-readable format, and to be able to transmit it to another data controller without being prevented from doing so by the controller to whom you have provided it, in the cases legally provided for this purpose.

  • Automated individual decisions:

Also, in addition to the above rights, in case of automated decisions, including profiling, you have the right to obtain human intervention by CEMFI and to express your point of view and challenge the decision.

  • Others:

Likewise, when personal data is transferred to a third country or an international organization, you have the right to be informed about how you can access or obtain a copy of the appropriate safeguards concerning the transfer.

You may also file a complaint regarding the protection of your personal data before the Spanish Data Protection Agency (AEPD) at C/ Jorge Juan, 6, 28001 - Madrid, when the interested party considers that CEMFI has violated the rights that are recognized by the applicable regulations on data protection.

12. Security measures

CEMFI will process the User's data at all times with absolute confidentiality and keeping the mandatory duty of secrecy with respect to them, in accordance with the provisions of the applicable regulations, adopting for this purpose the necessary technical and organizational measures to ensure the security of your data and avoid its alteration, loss, processing or unauthorized access, given the state of technology, the nature of the data stored and the risks to which they are exposed.

13. Changes

CEMFI reserves the right to revise its Privacy Policy at any time it deems appropriate, in which case it will be communicated to Users. For this reason, please check this privacy statement regularly to read the most recent version of CEMFI's Privacy Policy.

14. Acceptance and consent

The User declares to have been informed of the conditions on personal data protection, accepting the content of this Privacy Policy.

 

Last update: February 9, 2023.

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