Privacy Policy

Last updated: May 2025

Below we provide the privacy policy (hereinafter referred to as the “Privacy Policy” or “Policy”) that governs the website platform https://www.escuelasuperiordemusicareinasofia.es (hereinafter, the “Platform”), owned by Fundación Albéniz (hereinafter, “Fundación Albéniz” or “we”), an entity with tax identification number G-39067806, with registered office at Plaza de Oriente, s/n, 28013 Madrid, and registered in the Unified Register of State Jurisdiction Foundations under number 104CUL.

PLEASE TAKE A FEW MINUTES TO READ OUR PRIVACY POLICY. THROUGH IT, WE AIM TO EXPLAIN IN A SIMPLE, CLEAR, AND TRANSPARENT WAY HOW WE PROCESS AND PROTECT YOUR PERSONAL INFORMATION AND YOUR RIGHTS. YOUR PRIVACY AND THE SECURITY OF YOUR PERSONAL DATA ARE FUNDAMENTAL TO US, AND WE TAKE THEIR PROTECTION VERY SERIOUSLY.

1. WHO IS THIS POLICY ADDRESSED TO AND WHO DOES IT APPLY TO?

This Policy applies to all users of the Platform (hereinafter, indistinctly, the “User” or the “Users”) who are natural persons. By personal data, we refer to any information relating to an identified or identifiable natural person.

This Platform is intended for users over 18 years of age. Any person under 18 who wishes to register or create an account must ask their legal guardian to do so on their behalf.

2. WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR PERSONAL DATA?

Fundación Albéniz is the data controller of your personal data:

Full name: FUNDACIÓN ALBÉNIZ

Address: Plaza de Oriente, s/n, 28013, Madrid

Contact phone number: 91 523 04 19

General contact email: fundacion@albeniz.com

For any questions regarding the protection of your personal data, you may contact our Data Protection Officer at the following email address: dpd@albeniz.com

3. WHAT TYPE OF DATA DO WE PROCESS?

When you browse our Platform and, in particular, when you interact with or register on it, you provide us with data directly, for example, by filling out any form or request available on the Platform according to the data processing purposes indicated in each case (e.g., via the newsletter subscription form).

The data you provide through such forms or requests may vary depending on the type of request, but we will always ask only for data that is adequate, relevant, and limited to what is necessary in relation to the purposes of the processing:

• Identifying personal data (first and last name, gender, date of birth).
• Contact personal data (mobile phone number, email address, postal code, country).

4. FOR WHAT PURPOSES DO WE PROCESS YOUR DATA?

The personal data you provide will be processed for the purposes specifically set out in this Privacy Policy and, where applicable, in the different data forms provided on the Platform.

In this sense, your personal data may be processed for the following purposes:

• To enable you to browse and use our Platform, allowing you access to the information and content available on it.
• To manage the online purchase of tickets.
• To respond to and manage the requests or enquiries you send us through our contact form or via the various channels available for that purpose (email, telephone, etc.).
• If the user fills in our registration form, to process the student's admission to the School and carry out the different administrative procedures required for the academic activity, payment management, and scholarship procedures.
• If the user fills in our “Auditions Information” form, to send them information about the auditions, including electronically, that may be of interest.
• If the user provides us with their data to pre-register or reserve a place for the Music & Culture Summer Camp or any of our other workshops or events, to process their application and admission.
• If the user fills in our “Subscribe to our newsletter” form, to send them all the latest news from our School, our event and concert calendar (our own and third-party), as well as any other information that may be of interest.
• Where applicable, to manage their personal account in our private area if they are entitled to it as a member of the School.
• To allow the use of cookies on the Platform as described in our Cookie Policy.

If you have accepted the use of different types of cookies, and in particular, analytical cookies (user navigation/profile), we will carry out the corresponding analysis and statistics related to web browsing in order to improve our services and their quality. At any time, if you wish, you may configure your cookie preferences and have the right to withdraw your consent for the purposes associated with such cookies. You can find more information in our Cookie Policy.

• To adopt any protective measures deemed necessary, in accordance with current legislation, for the better protection of your personal data, including the potential anonymisation or pseudonymisation of your personal data using the appropriate available techniques.

5. ON WHAT BASIS DO WE LEGITIMATELY PROCESS YOUR DATA?

Purpose of processing: To enable you to browse our Platform, thereby granting you access to the information and content available on it.

Legal basis for processing: Your consent and, where applicable, the satisfaction of our legitimate interest or that of third parties, linked to the proper management, maintenance, development, and evolution of the Platform, tools, network, and associated information systems, allowing their correct operation, functionalities, content and service access, as well as overall security.

Purpose of processing: To manage the online sale of tickets for concerts organised by Fundación Albéniz, both at the Reina Sofía School of Music Auditorium and at other venues, theatres, or institutions.

Legal basis for processing: Your consent given by completing and submitting the corresponding form.

Purpose of processing: To handle and manage requests or inquiries you send us.

Legal basis for processing: Your consent given by submitting such requests or inquiries.

Purpose of processing: To process the student's admission to the School and carry out the necessary administrative procedures.

Legal basis for processing: Your consent and, where applicable, the implementation of pre-contractual measures at the user's request.

Purpose of processing: To send you information about upcoming auditions.

Legal basis for processing: Your consent given by completing and submitting the corresponding form.

Purpose of processing: To process your application for admission to the Summer Camp or other workshops and events.

Legal basis for processing: Your consent given by completing and submitting the corresponding form.

Purpose of processing: To send you our newsletter.

Legal basis for processing: Your consent given by completing and submitting the corresponding form.

Purpose of processing: To manage your personal account in our private area.

Legal basis for processing: Performance of the contract, where applicable, concluded with the user.

Purpose of processing: If you have accepted the use of cookies, to carry out the corresponding analysis derived from your web browsing for analytical, statistical, and/or advertising purposes.

Legal basis for processing: Your consent.

To adopt all applicable protective measures in accordance with current legislation, including possible pseudonymisation and anonymisation of your personal data using the appropriate techniques available.

Compliance with a legal obligation (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, repealing Directive 95/46/EC — hereinafter the “General Data Protection Regulation” or “GDPR”) https://www.boe.es/doue/2016/119/L00001-00088.pdf. Where processing is carried out to guarantee the security of the Platform, network and information system, our legitimate interest or that of a third party may be invoked, as appropriate.

Where the lawful basis for processing your personal data is your consent, please note that you have the right to withdraw such consent at any time, easily and free of charge, by writing to dpd@albeniz.com, without this affecting the lawfulness of processing based on consent prior to its withdrawal.

6. HOW LONG DO WE RETAIN YOUR DATA?

Data related to user browsing on our Platform

- In general, data collected for this purpose will be retained for the time strictly necessary to enable correct navigation and use of our Platform and the content available through it.

- Regarding data linked to your browsing profile and analytical cookies you have accepted (as described in our Cookie Policy), please refer to the section on their duration in the Cookie Policy.

Data related to the purchase of tickets

Until the user requests to unsubscribe from the service.

Data related to handling your requests or enquiries

- For the time necessary to properly handle your specific requests or enquiries, depending on the case.

- If such requests involve the implementation of pre-contractual measures at your request or the signing of a contract, the data will be retained as long as needed to fulfil such obligations.

Data related to processing the student’s admission and administrative procedures

For as long as necessary to carry out the admission process.

If the user is accepted, the data retention periods described in the Privacy Policy applicable to student data processing will apply.

Data related to sending you information about upcoming auditions

Until the user requests to unsubscribe from the service.

Data related to processing your application for the Summer Camp or other events or workshops

For as long as necessary to carry out the admission process and, if applicable, your participation in them.

Data related to sending you our newsletter

Until the user requests to unsubscribe from the service.

Data related to the management of your personal account in our private area

For the duration required to fulfil the contract signed between the parties.

Data related to the adoption of protection measures in compliance with applicable regulations

For as long as your personal data is processed, according to the applicable retention periods.

In any case, and without prejudice to the above, the user is informed of the following:

• With regard to cookie retention periods, users are advised to consult our Cookie Policy.
• As a general rule, when personal data is no longer necessary for the purposes for which it was collected, it will be blocked and made available only to competent authorities to address any legal responsibilities arising during the data’s processing, in accordance with applicable legislation. After the relevant legal periods have elapsed, the data will be deleted or, where appropriate, securely anonymised (anonymised/non-personal data).

In this regard, and to address possible liabilities in data protection matters, and in accordance with Article 72 of Organic Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights, Fundación Albéniz may securely retain personal information for three years (limitation period for very serious infringements in this area).

7. WHAT ARE THE CONSEQUENCES OF NOT PROVIDING YOUR DATA?

We strive to request only the minimum and essential data needed to carry out personal data processing related to our purposes and mission. This is in line with the principles of applicable legislation.

However, if you do not provide your personal data, this could result in the following: 1) You may be unable to properly browse our Platform (if technical or session cookies are not accepted); 2) You may be unable to access certain content or services (for example, if you do not provide your data for the newsletter, you will not receive it or the related content); 3) We may be unable to process your specific request (for example, due to incomplete or insufficiently filled-out forms).

In any case, the personal data and information you provide must always be:

• Sufficient, yet appropriate, limited, and proportionate to the legitimate purposes of processing as informed in each case, respecting the principles of purpose limitation and data minimisation.
• Accurate, up to date, and truthful, in order to properly verify identity, capacity, and representation, where applicable, and to tailor data processing to your specific needs and actual situation, in line with the principle of data accuracy.

Users shall be fully responsible for the data and personal information they provide to Fundación Albéniz.

8. DO WE SHARE YOUR PERSONAL DATA WITH THIRD PARTIES?

Your personal data will not be transferred or disclosed to third parties, except in cases necessary for the development, control, and fulfilment of the stated purpose(s), in the cases provided for by law, or in specific situations that will be expressly communicated to the User.

Likewise, it is possible that certain third parties may access your personal information in the context of a service they provide to Fundación Albéniz, always complying with the requirements established by current legislation.

9. ARE INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA MADE?

We inform you that, in general, no international transfers of your personal data are planned. Fundación Albéniz adopts the necessary measures and safeguards in this regard in accordance with applicable data protection regulations.

10. WHAT ARE YOUR RIGHTS, WHAT DO THEY MEAN, AND HOW CAN YOU EXERCISE THEM?

Right to information

What does it mean? The right to be provided by Fundación Albéniz with the appropriate information, both at the time your personal data is collected and at any time thereafter, regarding how we process your personal data.

How can you exercise it? Fundación Albéniz aims to provide you with all necessary information regarding the processing of your personal data in accordance with Articles 12 to 14 of the GDPR. However, if you have any questions about our Privacy and Cookie Policy, please do not hesitate to contact our Data Protection Officer at dpd@albeniz.com and we will respond to your request for additional information.

Right of access

What does it mean? The right to obtain confirmation from Fundación Albéniz as to whether or not your personal data is being processed, and access to such data, including a copy of the personal data being processed (Article 15 of the GDPR).

How can you exercise it? By sending a written communication to dpd@albeniz.com with the subject line "Exercise of Rights", including, if necessary to verify your identity, a copy of your national identity document or equivalent identification (passport, foreigner ID, etc.).

Right to rectification

What does it mean? The right to obtain without undue delay the rectification of your personal data by Fundación Albéniz under the terms of Article 16 of the GDPR.

How can you exercise it? By sending a written communication to dpd@albeniz.com with the subject line "Exercise of Rights", including, if necessary to verify your identity, a copy of your national identity document or equivalent identification (passport, foreigner ID, etc.).

Right to erasure

What does it mean? The right to obtain the erasure of your personal data by Fundación Albéniz without undue delay, under the terms of Article 17 of the GDPR.

How can you exercise it? By sending a written communication to dpd@albeniz.com with the subject line "Exercise of Rights", including, if necessary to verify your identity, a copy of your national identity document or equivalent identification (passport, foreigner ID, etc.).

Right to restriction of processing

What does it mean? The right to obtain from Fundación Albéniz the restriction of processing of your data when:

- You contest the accuracy of your personal data, for a period enabling Fundación Albéniz to verify the accuracy of such data.
- The processing is unlawful and you oppose the erasure of your personal data and request the restriction of its use instead.
- We no longer need the personal data, but you require it for the establishment, exercise or defence of legal claims.

This right shall be exercised under the terms set out in Article 18 of the GDPR.

How can you exercise it? By sending a written communication to dpd@albeniz.com with the reference "Exercise of Rights", including, if necessary to verify your identity, a copy of your national identity document or equivalent (passport, foreigner ID, etc.).

Right to data portability

What does it mean? The right to receive the personal data that concerns you, which you have provided to us, in a structured, commonly used and machine-readable format, and to transmit those data to another data controller, where technically feasible, under the terms set out in Article 20 of the GDPR.

How can you exercise it? By sending a written communication to dpd@albeniz.com with the reference "Exercise of Rights", including, if necessary, a copy of your national identity document or equivalent (passport, foreigner ID, etc.).

Right to object

What does it mean? The right to object at any time to the processing of your personal data, as described in Article 21 of the GDPR.

Right not to be subject to automated decision-making (including profiling)

What does it mean? The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, as established in Article 22 of the GDPR.

How can you exercise it? By sending a written communication to DPD@albeniz.com with the reference "Exercise of Rights", including, if necessary, a copy of your national identity document or equivalent (passport, foreigner ID, etc.).

Right to withdraw consent

What does it mean? You have the right to withdraw the consent you previously granted at any time.

Withdrawal of consent does not affect the lawfulness of processing based on consent prior to its withdrawal.

How can you exercise it? Through the systems made available by Fundación Albéniz, depending on the case (e.g., by unsubscribing from the newsletter via the link provided). In any case, you may also send a written communication to DPD@albeniz.com, including, if necessary, a copy of your national identity document or equivalent (passport, foreigner ID, etc.).

Right to lodge a complaint with the competent supervisory authority

What does it mean? This implies the possibility of contacting the supervisory authority — in this case, the Spanish Data Protection Agency (www.agpd.es) — if you believe your rights have been violated or if you consider that your data is being processed contrary to current regulations.

How can you exercise it? We recommend that before filing any complaint or claim with the Spanish Data Protection Agency (AEPD), you contact our Data Protection Officer (DPD@albeniz.com) to assess your specific situation and try to find an effective and amicable solution.

11. ARE SECURITY MEASURES APPLIED TO PROTECT YOUR PERSONAL DATA?

Taking into account the nature, scope, context and stated purposes of the processing, as well as the varying likelihood and severity of risks to your rights and freedoms, Fundación Albéniz applies appropriate technical and organisational measures to ensure the proper security and protection of your personal data, following the principles of privacy by design and by default.

12. LINKS TO THIRD-PARTY WEBSITES

This Platform, owned by Fundación Albéniz, may contain links to third-party websites whose privacy policies are not related to Fundación Albéniz.

Therefore, upon accessing such websites, we recommend that you review their privacy and cookie policies, as Fundación Albéniz is not responsible, under any circumstances, for the processing of your data by such third parties.

13. VALIDITY AND MODIFICATION OF THIS PRIVACY POLICY

This policy is in force as of 13 May 2025.

Fundación Albéniz reserves the right to modify this policy in order to adapt it to legislative, doctrinal or jurisprudential changes that may apply, or for technical, operational or strategic reasons, informing you reasonably and in advance of any changes whenever possible. In any case, we recommend that each time you access this Platform, you read this policy carefully, as any modifications will be published through it.