Data Protection Policy

INICIATIVAS INNOVADORAS, S.A.L. (hereinafter INICIATIVAS INNOVADORAS) makes this data protection policy available to you through the website in order to inform you in detail about how we process your personal data and protect your privacy and the information you provide us with.

In the event of any future changes to this policy, we will notify you via the website or by other means so that you can be informed of the new privacy conditions introduced. In compliance with Regulation (EU) 2016/679, General Data Protection Regulation and Organic Law 3/2018, of 5 December, on Personal Data Protection and guarantee of digital rights, we inform you of the following:

1. Minors

In accordance with the provisions of data protection regulations, INICIATIVAS INNOVADORAS determines as an essential requirement for you to access this website that the user must be over 14 years of age. If you are under 14 years of age and have accessed this website, you must not provide us with any information about yourself. You are responsible for the accuracy of this information. INICIATIVAS INNOVADORAS, in the event that it finds that the aforementioned requirement is not met, has the authority to disregard the request for information sent. Under no circumstances will data relating to the professional or economic situation or the privacy of the other members of the family be collected from the minor without their consent.

2. Who is the data controller?

INICIATIVAS INNOVADORAS, S.A.L. with CIF A-31679806, with address at C/ Zabalgaina nº 3 -1º Oficinas 4/5 31.180 Zizur Mayor (Navarra), telephone: +34 948 281 270 and e-mail address: –

3. What information do we collect about you and for what purpose?

INICIATIVAS INNOVADORAS processes the personal information provided directly by the user.

In general, we will process identifying data (such as name, surname, telephone number, e-mail and IP address).

The user guarantees the authenticity, accuracy and truthfulness of all the information provided, undertaking to keep the personal data updated so that it corresponds, at all times, to their real situation. The user will be solely responsible for any false or inaccurate statements and for any damages that they may cause.

The personal data you provide us with in the course of providing our services are mandatory and are the minimum necessary for us to process your order.

The data you provide may be used for one or more of the purposes indicated below, which will be determined by factors such as your relationship with INICIATIVAS INNOVADORAS or with the partners of the SEA2LAND project or by the means used to send the data. Below, we set out the processing referred to in this policy, without prejudice to the fact that there may be others for which you will be informed or asked for the appropriate authorisation:

a) Compliance with legal obligations

It may be necessary to process personal data in order to comply with applicable legal requirements. In particular, in order to comply with data protection, tax, statistical, insurance, etc. legislation.

b) Communication-contact

The data you send us by email, instant messaging applications, we use them to respond to the request made.

c) Sending of commercial communications by any means in case of additional consent

If you give your explicit consent, your data may be transferred to our collaborating entities for the purpose of informing you by any means for promotional and advertising purposes of this project.

4. How do we obtain your personal data?

We collect your personal information by different means, but you will always be informed at the time of collection by means of informative clauses about the person responsible for the processing, the purpose © David Muñiz Aguirreurreta Legal text 21 and legal basis of the processing, the entities to which the data is sent and the period of conservation of your information, as well as the way in which you can exercise your rights regarding data protection. In general, the personal information we process is limited to identifying information (name, organisation and e-mail address).

Through our website we collect personal information related to your browsing through the use of cookies. To find out clearly and precisely what cookies we use, what their purposes are and how you can configure or disable them, please consult our Cookies Policy.

5. How long will we keep your data?

We only keep your information for the period of time necessary to fulfil the purpose for which it was collected, to comply with the legal obligations imposed on us and to meet the possible liabilities that may arise from the fulfilment of the purpose for which the data were collected. Your personal data will be kept for the duration of the legal relationship and, thereafter, provided that you have not exercised your right to deletion, will be kept taking into account the legal limitation periods for liabilities that may be applicable in each specific case, taking into account the type of data, as well as the purpose of the processing.

In the event that you exercise your right to erasure and it is appropriate, in compliance with art. 32 LOPDGDDD, the data will be blocked, being available only at the request of the Courts and Tribunals, the Ombudsman’s Office, the Public Prosecutor’s Office or the competent Public Administrations during the period of limitation of any actions that may arise and, once this period has elapsed, they will be completely erased.

We process your data in a lawful, fair, transparent, adequate, relevant, limited, accurate and up-to-date manner. That is why we undertake to take all reasonable steps to ensure that they are deleted or rectified without delay when they are inaccurate.

6. What is the legitimacy for the processing of your data?

Depending on the relationship we have and therefore the purpose of the processing, the legal basis may be different. Below, we set out the different applicable bases depending on the processing carried out:

Legitimate Interest

Among others, for profiling, quality or opinion surveys, maintenance of the website or telephone support.

Legal Obligation

For compliance with the obligations established in any other applicable regulations. 


When you provide us with your data through the contact forms on the website, or for the sending of commercial communications by electronic means. You should be aware that in those processing operations where you are asked for consent, failure to grant or eventual withdrawal of consent at a later date will have no negative consequences for you.

In the event that third party data is provided, you declare that you have the consent of the owners of said data for the aforementioned communication of data or, if applicable, that you are their legal representative, exempting INICIATIVAS INNOVADORAS and the rest of its partners from any liability.

7. What types of data do we process?

The categories of data processed are:

  • Contact: identification data (name, surname, telephone, email and IP address).
  • Commercial communications-newsletter: identification data (email).
8. To which entities will your data be communicated?

Depending on the services we provide, your personal data may be communicated to third parties, such communication being necessary for the proper fulfilment of legal and/or contractual obligations. These providers will not process your data for their own purposes that have not been previously informed by INICIATIVAS INNOVADORAS.

In those cases in which, in order to improve the management and provision of services, access to data is granted to third parties, INICIATIVAS INNOVADORAS guarantees to maintain confidentiality in the processing of personal data. In any case, the user will be duly informed of these transfers, detailing the identity of the Transferee and the purpose of the transfer.

Your data may be passed on to our partners in this project which you can find out more about here.

9. ¿Cuáles son tus derechos cuando nos facilitas tus datos?
Law Content Channels of attention
Access You have the right to obtain confirmation as to whether INICIATIVAS INNOVADORAS is processing your personal data.
C/ Zabalgaina nº 3 -1º
Oficinas 4/5
31.180 Zizur Mayor (Navarra)
Correction You will be able to change your details if they are inaccurate.
Suppression You may request the deletion of your data.
Opposition You may request that your data no longer be processed.
Treatment limitation

You may request the limitation of the processing of your data when:

  • While your data is being checked for accuracy.
  • When the processing is unlawful and you object to the erasure of the data.
  • When INICIATIVAS INNOVADORAS does not need to process your data, but you need them for the exercise or defence of claims.
  • When you have objected to the processing of your data for the satisfaction of a legitimate interest of INICIATIVAS INNOVADORAS, while verifying whether this interest prevails over your rights and freedoms.
Portability You may receive, in electronic format, the personal data that you have provided us with and those obtained from your contractual relationship with INICIATIVAS INNOVADORAS, as well as the right to transfer them to another entity of your choice.
You have the right to withdraw consent at any time. Withdrawal of consent will not affect the lawfulness of processing operations based on consent prior to its withdrawal.
The maximum time limit for a decision is one month from the receipt of your application, which may be extended for a further two months depending on the number of applications received or the complexity of the applications.
If you feel that your request has not been properly dealt with, you can contact the Spanish Data Protection Agency ( and file a complaint.
To exercise your rights, please attach a copy of your DNI, NIE, Passport or other document proving your identity to your request.
The exercise of these rights is free of charge.

These rights are characterised by the following:

  • It is free of charge, except in the case of manifestly unfounded or excessive requests (e.g. repetitive nature), in which case INICIATIVAS INNOVADORAS may charge a fee proportional to the administrative costs incurred or refuse to act.
  • You can exercise your rights directly or through your legal representative or volunteer.
  • We must respond to your request within one month, although, taking into account the complexity and number of requests, the deadline can be extended by a further two months.
  • We are obliged to inform you about the means of exercising these rights, which must be accessible and without being able to refuse you the exercise of the right on the sole ground that you have chosen another means. If the request is made by electronic means, the information will be provided by electronic means where possible, unless you ask us to do otherwise.
  • If INICIATIVAS INNOVADORAS does not act on the request, it will inform you, within one month at the latest, of the reasons for its failure to act and the possibility of lodging a complaint with a supervisory authority.

In order to facilitate their exercise, we provide links to the application form for each of the rights:

10. How do we protect your information?

At INICIATIVAS INNOVADORAS we are committed to protecting your personal information. We use reasonably reliable and effective physical, organisational and technological measures, controls and procedures aimed at preserving the integrity and security of your data and guaranteeing your privacy. In addition, all staff with access to personal data have been trained and are aware of their obligations in relation to the processing of your personal data.

All these security measures are regularly reviewed to ensure their adequacy and effectiveness. However, absolute security cannot be guaranteed and no security system is impenetrable, so in the event that any information under our control and under our control is compromised as a result of a security breach, we will take appropriate steps to investigate the incident, notify the Supervisory Authority and, where appropriate, those users who may have been affected to take appropriate action.

11. Commercial communications by electronic means

INICIATIVAS INNOVADORAS informs you that it complies with Law 34/2002 of 11 July, on Information Society Services and Electronic Commerce and does not engage in SPAM practices, and will therefore request your consent to the processing of your e-mail address or mobile phone for commercial purposes at all times.

12. Privacy policy update

INICIATIVAS INNOVADORAS reserves the right to modify its privacy policy or conditions of use of its services for reasons of adaptation to current legislation, or other reasons. When this occurs, we will notify you of any changes and ask you to re-read the most recent version of our policy and, if applicable, to confirm your acceptance of it. The absolute confidentiality and privacy of the personal data collected is assured and therefore security measures have been adopted in order to prevent alteration, loss, processing or unauthorised access, and thus guarantee its integrity, availability and security. However, INICIATIVAS INNOVADORAS shall not be liable for any incidents that may arise in relation to personal data when these are the result of an attack or unauthorised access to the systems in such a way that it is impossible to detect or prevent it, even if measures are adopted in accordance with the current state of technology.

Last updated on 05 May 2021