Privacy policy

Version in force from [DATE].

This Privacy Policy (hereinafter, the ‘PRIVACY POLICY‘) regulates, in general, the collection and processing by AGENCIA VASCA DE INTERNACIONALIZACIÓN-BASQUE TRADE AND INVESTMENT, S.A. (hereinafter, ‘BASQUE TRADE’) of (i) the personal data that you provide us as a user of the website accessible through the domain name www.basquetrade.spri.eus/en/ (hereinafter, the ‘WEBSITE‘), including the services that are available through the WEBSITE at any given moment; and (ii) other data gathered using other collection systems duly identified below. All notwithstanding the specific provisions established in certain sections, forms or services available on the WEBSITE in order to provide you with the relevant information and, where applicable, obtain your consent.

BASQUE TRADE reserves the right to amend the PRIVACY POLICY to adapt to administrative, jurisprudential and legislative developments, along with the practices developed at any given moment through the WEBSITE, while always taking your rights and interests into account.

In any event, BASQUE TRADE will provide you with the appropriate technical resources so you can access the PRIVACY POLICY in order to duly comply with our information obligations pursuant to the applicable data protection legislation.

1. Who is the Data Controller of your data?

The Data Controller of your data is AGENCIA VASCA DE INTERNACIONALIZACIÓN-BASQUE TRADE AND INVESTMENT, S.A., a company whose registered office is in Bilbao (Bizkaia) at C/ Alameda Urquijo, nº 36, 4º, registered in Bizkaia Trade Registry in Volume 5735, Folio 188, Page BI-70809 and with tax number A-95903027.

For any question related to the PRIVACY POLICY and/or the processing of your personal data, you can contact us at the above postal address and/or by email to lopd@basquetrade.eus.

2. How have we obtained your data?

The data that we process at BASQUE TRADE has been obtained from yourself, by means of (i) the different forms that you complete when browsing through the WEBSITE and/or through other channels (e.g. registering as a user of the WEBSITE – when required –, contact forms, forms referring to job offers and/or recruitment processes, etc.); (ii) when sending a consultation email; or (ii) by means of duly identified collection systems.

When so indicated, providing the data collected in the forms available in the WEBSITE is mandatory; failure to do so will make it impossible to process your request, whether it refers to your registering as user, obtaining information, signing up for the Newsletter or for any other service available on the WEBSITE

If the personal data provided belongs to a third party, you guarantee that you have informed the third party of the PRIVACY POLICY and have obtained their authorisation to facilitate their data to BASQUE TRADE for the purposes indicated below.

We likewise inform you of the possible processing of your social media data through the corporate profiles that BASQUE TRADE has on each social medium on which it is present, all of which in the terms and conditions established by each social medium.

3. What type of data do we process?

The data that we process at BASQUE TRADE is what we have provided while browsing the WEBSITE, by means of the different forms that we use for formalise our contact with you and/or by email, as well as any other data, as applicable, we obtain through the BASQUE TRADE corporate profiles on the social media where we are present.

In particular, BASQUE TRADE processes the following data categories:

  • Contact and identification data (e.g. name, surname(s), ID, email and postal address, telephone number, etc.)
  • Professional data (company where you work, post and duties; email and postal address for work purposes, and professional telephone number) to the extent that (i) you provide the data through the respective forms; and (ii) the data is necessary for your business location and/or for the purpose of maintaining our commercial relationship with you or your company
  • Image
  • Identification codes and passwords as a registered user of the WEBSITE and/or of the applications accessible through the site
  • Internet browsing data (e.g. IP address, visits to websites, connections to WIFI networks, etc.)
  • Data on personal characteristics, training, employment, etc. (in the case of BASQUE TRADE job offers/applications and/or recruitment processes in which you take part voluntarily

4. For what purposes and on what legal grounds do we process your data?

Your personal data is processed for the following purposes:

  • Managing and processing your registration as a user of the WEBSITE, when possible, and based on your request for pre-contractual measures or the contractual relationship established with you in that regard.
  • Managing your access and use of the content and services that BASQUE TRADE makes available to you through the WEBSITE, including the blog services, social media or any other features that are accessible from the WEBSITE, and based on your request for pre-contractual measures or the contractual relationship established with you in that regard.
  • Processing and managing the request for information, suggestions, complaints and claims made through the WEBSITE or email, and based on your consent.
  • Addressing and managing the information facilitated through the whistleblowing channel accessible through the WEBSITE; as applicable, investigating the reported facts, all on the basis on compliance with the legal obligations for BASQUE TRADE (Act 2/2023, of 20 February, regulating the protection of whistleblowers reporting legislative infringements and fighting against corruption).
  • Managing your subscription to our newsletter services and sending out the respective electronic communications, provided that you have given your consent and on the basis on that consent.
  • Sending you by different means, including electronically, BASQUE TRADE advertising and commercial communications on products, services, offers, promotions and any other relevant information referring to those entities, provided you have agreed and on the basis of that consent.
  • If you have so consented, managing and disseminating activities and events organised by BASQUE TRADE, using your image and your identification details to do so, all based on the consent give.
  • Managing your subscription to our newsleter services and sending out the respective electronic communications, provided that you have given your consent and on the basis on the consent.
  • Managing your job application or your registering for a job offer and your participation in the respective recruitment process, all of which is based on your requesting pre-contractual measures.
  • Keeping accessible, through our Transparency Portal available on the WEBSITE, the data that we are legally required to make available to the general public, all based on compliance of our legal obligations (applicable transparency legislation).
  • Keeping accessible, through our Contractor Portal available on the WEBSITE, the data that we are legally required to make available to the general public, all based on compliance of our legal obligations (applicable transparency legislation).

Please note that when consent is the legal grounds for the processing, you can freely revoke it at any moment and at no charge, as per the terms indicated in Article 7 below.

5. To whom do we disclose your data?

Apart from those cases where BASQUE TRADE is required by law (e.g. Tax Authorities, the justice system or other Public Administrations), your data will not be disclosed to third parties.

No international transfers of your data are envisaged.

6. For how long do we keep your data?

In general, the personal data will be kept for as long as you do not withdraw your consent to the processing or request the data be deleted, as well as for the necessary time to meet the legal obligations that BASQUE TRADE must observe.

In any event, we hereby inform you that BASQUE TRADE has internal data cleansing policies aimed at controlling the storage periods for the data in its procession, which may be deleted when no longer necessary and/or appropriate for the purpose for which the data was gathered.

In particular, your data will be kept for a maximum 5-year period to manage job applications.

7. What are your rights?

The applicable data protection legislation grants you a series of rights concerning your personal data that you can exercise during its processing. Those rights are those indicated below:

  • Access your data: you are entitled to access your data in order to know which of your personal data we are processing.
  • Requesting the rectification or deletion of your data: in certain circumstances, you are entitled to rectify any inaccurate personal data referring to you that we process, even to request its deletion when the data is no longer necessary for the purposes for which it was collected, inter alia.
  • Requesting limitation on the processing of your data: in certain circumstances, you are entitled to request the processing of your data be limited, in which case we hereby inform you that we will only keep the data to exercise or defend claims as envisaged in the General Data Protection Regulation.
  • The portability of your data: in certain circumstances, you are entitled to receive the personal data concerning you, and which you have provided, in a common use and structured format, and which can be read mechanically, and to have the data transferred to another data controller.
  • Objecting to the processing of your data: in certain circumstances and for reasons related to your personal situation, you are entitled to object to the processing of your data in any case, and we would cease to process it except for when it must be kept for imperative legitimate reasons or to exercise or defend possible claims.

Furthermore, you are entitled to withdraw consent at any moment, which will not affect the lawfulness of the processing based on the consent prior to the withdrawal.

You may exercise those rights by writing to BASQUE TRADE at the postal address in Section 1 or by sending an email to lopd@basquetrade.eus.

Finally, we must inform you that you may lodge a claim with the complement Supervisory Authority, (in the case of BASQUE TRADE, the Basque Data Protection Agency), particularly when the exercising of your rights has not been satisfactory. You can contact that authority through its website: www.avpd.euskadi.eus).

8. Security Measures

BASQUE TRADE will always process your data in totally confidentially and comply with the required duty of secrecy regarding the data, pursuant to what is envisaged in data protection legislation; it will adopt the necessary organisational and technical measures to guarantee the security of your data and avoid its alteration, loss, unauthorised access or processing, taking into account the state of the art, the nature of the stored data and the risks to which it is exposed.

9. Cookie Policy

In addition, please note that BASQUE TRADE has a Cookies Policy that is accessible through the following link