General Privacy Policy

• Data Controller: CUNEF S.L.U. Tax Identification Number: B86969235
• Address: Calle de Almansa, 101 – 28040 MADRID
• Telephone: 91 444 51 61
• email: lopd@cunef.edu

A Data Protection Officer (DPO) is a legally established figure whose role is to provide information and advice regarding the organisation’s duties in terms of personal data protection, as well as to supervise compliance. For any questions related to the processing of your personal data, please contact CUNEF’s DPO:

• Address: Picón y Asociados Derecho y Nuevas Tecnologías, S.L. C/ Hermanos Pinzón 3, Bajo – 28036 Madrid.
• email: dpd@piconyasociados.es

Any information you provide will be processed for one or more of the purposes listed below, depending on why you provided it:

1. To solve queries or doubts and process requests—for information or of any kind—made using any of the contact means available to users.
2. To send marketing communications aimed at informing users of the services we offer and the events we organise or participate in. Based on the data you provide, we can identify your interests to offer you relevant services and information. No automated decisions will be made using your personal data.
3. To process user applications for admission and registration for any of the academic, cultural or sports-related services offered by CUNEF, including events or activities that  CUNEF organises or participates in, as well as any related activities. 
   1. To this end, CUNEF may contact users and send them information via WhatsApp, provided that they have previously given their consent. It is up to the user to authorise CUNEF to process their data and establish WhatsApp as a means of communication. Should they not consent, CUNEF will contact them via traditional means.
4. To handle student requests for academic services, applications for scholarships and financial aid, and any procedures related to their studies at CUNEF (pursuing internships, participating in academic events, etc.). For these purposes, the organisation may take photographs and record videos, which may contain both images and voice recordings for educational purposes (e.g.: university assignments, projects, exams…). 
5. CUNEF will process graduates’ personal and professional data with the legitimate purpose of maintaining the institutional relationship and providing them with information suited to their profile and interests on academic activities, continuing education programs, institutional events, networking initiatives, and opportunities for professional or academic collaboration, including participation in surveys, mentoring or strategic alliances.
6. During the different activities and events carried out by CUNEF, the organisation may take photographs and record videos, which may contain both images and voice recordings of participants, to publicise and advertise CUNEF events in the organisation’s magazine or on its website or social media.
7. To manage customer relations, invoicing and payments. Customers are required to provide their data, as it is otherwise impossible to fulfil our contractual relationship.
8. To manage our relationship with our suppliers, including invoicing and payments. Suppliers are required to provide their data, as it is otherwise impossible to fulfil our contractual relationship.
9. CUNEF may also use students’ data to send them surveys on its academic services, in order to implement the necessary improvements. Completing the surveys is completely optional and anonymous, so the only consequence of not doing so is that CUNEF will not have the students’ opinions on the services received. CUNEF may also send surveys to alumni to find out their opinion regarding their employability, as set out in CUNEF’s Internal Quality Assurance System.

For the purposes described in points 1 and 2, personal data will be stored until we provide a final solution to the user’s request or query. After that, they will be kept as part of a communications record for a maximum of one year, unless the user requests their erasure via any of the contact means specified in this Policy. For marketing communications, the data will be stored indefinitely, or until users specify that they do not wish to continue receiving said communications.

For the purpose of processing applications for admission and registration in any of the academic, cultural or sports-related services offered by CUNEF, including events or activities that  CUNEF organises or participates in, as well as any related activities, your data will be stored for the duration of said services and, after that, until any related liabilities expire.

For the purpose of handling student requests for academic services, applications for scholarships and financial aid, and any procedures related to their studies at CUNEF (pursuing internships, participating in academic events, etc.), their data, including any images captured for academic purposes, will be stored for as long as they are students at CUNEF and, after that, until any liabilities related to their academic relationship with the institution expire, as per the current statute of limitations.

Graduate data will be kept as long as the graduate does not oppose their use or request their erasure and, after that, until any liabilities related to their academic relationship with CUNEF expire, as per the current statute of limitations.

Images and voice recordings of participants captured during different activities and events carried out by CUNEF for the purpose of publicity and advertising of said events will be stored indefinitely, unless the user requests their erasure via any of the contact means specified in this Policy.

The data processed for the purpose of managing customer and supplier relationships, including invoicing and payments, will be stored for the duration of the contract. After that, the data may continue to be stored as long as required by current legislation and until any liabilities related to your participation in the international mobility programme expire, as per the current statute of limitations. The data of potential customers finally choose not to hire our services or do not wish to receive commercial information will be deleted once it is confirmed that they will not hire our services. If the relationship between the parties, regardless of the fact that it has not yet materialised, could give rise to possible liabilities, the data will be kept until the statute of limitations expires.

Anonymous data collected in surveys may be stored indefinitely. Graduates will only receive surveys for three years after graduation.

For the purposes described in points 1 and 2, the legal basis is the consent the user gives by providing the information. Users may withdraw their consent at any time, although this will not affect the lawfulness of any previous use of the information. Providing personal data is optional, but, unless users provide the necessary information, it will not be possible to process their requests. Therefore, providing their personal data is necessary for CUNEF to handle their requests and send, where appropriate, marketing communications. Regardless of this, marketing communications to CUNEF clients/students are based on the legitimate business interest of being able to offer our clients/students the option of hiring other services, as well as information on our events and activities. This legitimate interest is recognised by current regulations, which expressly allow the processing of personal data on that basis for direct marketing purposes. However, we remind you that you have the right to oppose this use of your data, and can do so by any of the means specified in this Policy. The data that will be processed for these purposes will be the following: Identification and contact details.

For the purpose of processing applications for admission and registration for any of the academic, cultural or sports-related services offered by CUNEF, including events or activities that  CUNEF organises or participates in, as well as any related activities, the legal basis is the contractual relationship between both parties or the implementation of pre-contractual measures. Personal data must be processed for admission and registration in the different academic, cultural or sports-related services offered by CUNEF. This means it is mandatory to provide personal data, since it is otherwise impossible to process said applications.

For the purposes described above, the legal basis for processing users’ personal data, specifically their name and telephone number, to contact them via WhatsApp, is their consent. Users may withdraw their consent at any time, although this will not affect the lawfulness of any previous use of the information.

For the purpose of handling student requests for academic services, applications for scholarships and financial aid, and any procedures related to their studies at CUNEF (pursuing internships, participating in academic events, etc.), the legal basis is fulfilling a) a mission carried out in the public interest, by virtue of Organic Law 2/2023, of 22 March, on Universities, and b) the existing contractual relationship with the student resulting from their enrolment in this University, regarding any services requested by them that are not directly related to the public service of higher education. When students’ image is captured for an academic purpose (university assignments, projects, exams, etc.), the legal basis is also fulfilling a mission carried out in the public interest. It is mandatory to provide said data for the purposes described above, since it is otherwise impossible for students to enrol in and pursue their studies or participate in other academic services offered by CUNEF.

For the purpose of processing graduate data, the legal basis is the University’s legitimate interest in fostering an alumni community and promoting their personal and professional development, guaranteeing that their data is protected at all times. This legitimate interest is recognised by current legislation, which expressly permits the processing of personal data for marketing purposes on this legal basis. However, graduates have the right to oppose this use of their data and may do so by any of the means specified in this privacy policy.

With regard to processing images and voice recordings of participants in different activities and events carried out by CUNEF, when images are not captured for an educational purpose, but rather for publicity and advertising of CUNEF events in the organisation’s magazine, or on its website or social media, we will seek consent from the parties involved, thus acquiring a legal basis. Using images of participants for publicity and advertising is not mandatory, which means that they cannot be used for this purpose without participants’ consent. Consent can be withdrawn at any time, although this will not affect the lawfulness of any previous use of the data. In any case, CUNEF reserves the right to take photographs and shoot videos of all the activities and events that it organises, individually or with third parties. Therefore, any participants who wish for their image and voice to be captured and used for the above-mentioned purposes of publicity and advertisement must express their consent. Any participants who do not express their consent must refrain from voluntarily participating in the photographs and videos made by CUNEF. If their image is captured incidentally, it will not be considered an illegitimate invasion of privacy and personal image, and there is no need to obtain their express consent, in accordance with Organic Law 1/82, since the legal basis is the above-mentioned fulfilment of a mission carried out in the public interest.

For the purpose of managing customer and supplier relationships, the legal basis is the fulfilment of the contract between the parties. The prospective offer of products and services to our customers is based on the legitimate business interest consisting of offering them other services to build loyalty. This legitimate interest is recognised by applicable regulations (GDPR), which expressly permit personal data processing for direct marketing purposes on that legal basis. However, please note you that you have the right to object to this processing of your data, and you may do so by any of the means specified in this Policy. Prospectively offering our services to anyone who, having shown interest in them, has not become our customer, is based on their consent. This consent can be withdrawn at any time, with the sole effect of ceasing to receive any advertising and without affecting the lawfulness of any previous use of the data.

For the purpose of  conducting surveys, the legal basis is CUNEF’s legitimate interest in learning students’ opinions on the academic services received and alumni’s opinions regarding their employability. This legitimate interest is considered to prevail considering that:

1. Surveys are sent only to CUNEF students, graduates, and alumni.
2. They are anonymous.
3. The intrusion into their privacy is minimal.

However, please note you that you have the right to object to this processing of your data, and you may do so by any of the means specified in this Policy.

If you become a friend or follower of CUNEF on social media, we will process your data to keep you informed of our events and activities via said media. The legal basis for this is your consent, and your data will be stored for as long as you remain a friend or follower. You may withdraw your consent at any time, although this will not affect the lawfulness of any previous use of the information. Providing personal data is optional, but, unless you provide the necessary information, it will be impossible for you to become a friend or follower on social media.

When users register directly via social media, we will process the data provided on said platforms only for the purposes described in their privacy policies, collecting the data required to complete our registration form. If we require additional information to register you on our website, you will be required to add it using our registration form, subject to the conditions set out in in this Privacy Policy.

If you submit your résumé, we will process your personal data to collect all the information required for the job/internship recruitment process. The data submitted for a specific ongoing recruitment process will be stored for the duration of said process and subsequently deleted, unless the candidate is selected, in which case the data will be included in their employee file. Any applicants who are not selected and want us to store their résumé for future recruitment processes must request this explicitly via email. In this case, as well as when users submit their résumé spontaneously, simply for future reference, the data will be stored for a year after the information is last updated. You must keep your data up to date, especially in terms of education and experience. 

The legal basis for processing résumés submitted for a specific ongoing recruitment process is the existence of a pre-contractual relationship. Any additional data collected during the interview or candidate selection process will be processed on the same legal basis.

The legal basis for processing the data in your résumé if you have asked us to store it after a recruitment process or you have submitted it spontaneously is your consent. You can withdraw this consent at any time, although this will not affect the lawfulness of any previous use of the information. 

Student data may be transferred to the following recipients:

1. Relevant government agencies, for the cases and purposes established by law.
2. Financial institutions that process billing and payments.
3. Insurance companies where CUNEF holds the corresponding insurance policies.
4. In the context of the academic service offered by this University, students’ data may be transferred to CUNEF’s training and employment partners, to facilitate access to jobs/internships.
5. Students’ parents or legal guardians will receive information regarding grades, enrolment or scholarships, provided that students have given their consent or are financially dependent on said parents/guardians. In these cases, a prevailing legitimate interest is assumed as a rule, enabling the transferring of the data without the need for students’ prior consent. Students can exercise their right to object within the limitations established by law.

Data provided by other website users will not be transferred to third parties, except government agencies for the cases and purposes established by law.

Additionally, CUNEF uses WhatsApp to stay in touch and send information to users. When a user consents to receiving notifications by WhatsApp, their data will be stored in WhatsApp LLC, located in the United States, which requires an international data transfer; nevertheless, this organisation offers adequate data protection guarantees by adhering to the Data Privacy Framework. For more information, go to https://www.whatsapp.com/legal/business-data-transfer-addendum.

Everybody has the right to know if we are processing their data or not. You have the right to access your data, to request that inaccurate data be rectified and also to request the erasure of data when, among other reasons, they are no longer necessary for the purpose for which you provided them.

Under the terms of the GDPR, you may request the restriction of the processing or transferring of your data, in which case we will only store them for the exercise or defence of legal claims.

Under certain circumstances, and for reasons related to their specific situation, users may object to the processing of their data. If you give consent for a specific purpose, you have the right to withdraw it at any time, although this will not affect the lawfulness of any previous use of the information. In such cases, we will stop processing your data or, where necessary, stop processing them for that specific purpose, except for compelling legitimate interests, or the exercise or defence of legal claims.

Additionally, data protection regulations allow you to object to being subject to decisions based solely on automated data processing, if applicable.

The following conditions apply to all the aforementioned rights:

• You can exercise them free of cost, unless your requests are manifestly unfounded or excessive (e.g., repetitive), in which case we may either charge a fee for the administrative costs incurred or refuse to act.
• You can exercise them directly or through a legal representative or volunteer.
• We must respond to you request within one month, although, depending on the complexity and number of requests, the period can be extended for another two months.
• It is our duty to inform you of how to exercise these rights and ensure that the necessary means are available. We cannot deny you the right to exercise your rights for the sole reason of choosing other means. If the request is submitted by electronic means, the information will be provided by these means whenever possible, unless you ask us to do otherwise.
• If, for any reason, your request is not granted, we will inform you, within a maximum period of one month, of the reasons and of the possibility of filing a claim with a competent Control Authority.

To make it easier for you to exercise your rights, the links to the corresponding forms are included below:

1. Right of Access Form
2. Right to Rectification Form
3. Right to Object Form
4. Right to Erasure Form
5. Right to Restrict Processing Form
6. Right to Data Portability Form
7. Rights in relation to automated decision making and profiling Form

All the aforementioned rights can be exercised using the contact details provided at the beginning of this Privacy Policy.

If you feel that your rights have been breached, especially if you tried to exercise them and did not receive a satisfactory response, you can file a claim with the Spanish Data Protection Agency (contact details at www.aepd.es) or another competent authority. You can also contact them for more information about your rights.

Users are responsible for ensuring that any information they provide via this website is accurate. They are accountable for the truthfulness of the data provided, and must keep them duly updated, to ensure that they reflect their actual status at all times. Users will be liable for any false or inaccurate information that they might provide, and any harm this might cause to the owner of this website or to third parties.

CUNEF undertakes to use the data provided for the purposes indicated in this Privacy Policy, guaranteeing the security and confidentiality of said data. To this end, the organisation has implemented technical and organisational security measures to prevent data alteration, loss and unauthorised use or access, in accordance with applicable laws.

All personal data processed by CUNEF have been provided by users.

If you provide third-party data, you are solely responsible for having previously obtained their consent authorising us to process their data, after duly informing them of all the provisions of Article 14 of the GDPR.