Privacy Policy

Welcome to the American Women’s Club of Seville and our website at www.awcseville.com (our “website”). This Privacy Policy sets out the basis on which we will process any Personal Data that we may collect about you as a visitor to our website or our members or potential members. This policy further sets out how we protect your privacy and your rights in respect of our use of your Personal Data.

WHO IS THE DATA CONTROLLER?

A “data controller” is a person or organization who alone or jointly determines the purposes for which, and the manner in which, any Personal Data is, or is likely to be, processed. In this sense, American Women’s Club of Seville (Club de Mujeres Americanas (A. W. C.) de Sevilla) of Calle Harinas, 18 Sevilla, 41001 Spain ​(“AWC”, “we”, “us”, or “our”) is the data controller. If you have any questions about data protection at AWC in general, you can reach us using our Contact Form.

WHAT IS PERSONAL DATA?

Personal data is any information that relates to an identified or identifiable living individual. Different pieces of information, which collected together can lead to the identification of a particular person, also constitute Personal Data.

WHY DO WE HAVE A PRIVACY POLICY?

The Spanish Data Protection and Digital Rights Act 3/2018 (“DPA”) and the EU’s General Data Protection Regulation (“GDPR”) control how your Personal Data is used by us. We are also required to explain which Personal Data we collect from you via our website, what we use it for, when we delete it and how your data is protected.

WHAT ARE THE LEGAL BASES FOR PROCESSING PERSONAL DATA

All Personal Data that we obtain from you via our website will only be processed for the purposes described in more detail below. This is done within the framework of the DPA and the GDPR and only if at least one of the following applies: a) you have given your consent, b) the data is necessary for the fulfillment of a contract / pre-contractual measures, c) the data is necessary for the fulfillment of a legal obligation, or d) the data is necessary to protect the legitimate interests of our company, provided that your interests are not overridden.

WHAT PERSONAL DATA DO WE COLLECT FROM YOU?

a) Collection of access data and log files

When you visit our website, we collect the Personal Data that your browser automatically transmits to our server. This is technically necessary for us to display our website and to ensure its stability and security. In this sense, we collect the following data: i) IP address of the requesting computer, ii) Date and time of access, iii) name and URL of the file accessed, iv) website from which the access was made (referrer URL), v) browser used and, if applicable, the operating system of your device as well as the name of your access provider. The legal basis is our legitimate interest.

b) Hosting

The hosting service used by us for the purpose of operating our website is Name Hero, LLC. In doing so Name Hero, processes inventory data, contact data, content data, contract data, usage data, meta data and communication data of users, interested parties and visitors of our website, on the basis of our legitimate interests in an efficient and secure provision of the website and services in conjunction with the provision of contractual services.

c) Content Management System

We also use the open-source Content Management System (CMS) of WordPress.Org to publish and maintain the created and edited content and texts on our website. This means that all content and texts submitted to us by our users is transferred to our Name Hero server. In addition to texts, this also includes, for example your data in our forms. The legal basis for this processing is our legitimate interest.

d) Cookies

For the processing of personal data using cookies and similar technologies on our website, please refer to our Cookie Policy. The legal basis for the use of cookies is our legitimate interest or your consent when you agree to the use of technically non-essential cookies as further explained in our Cookie Policy.

e) Contact options

We process and store the Personal Data provided in the contact enquiry solely for the purpose of processing and responding to your enquiry and contacting you. If you contact us, we will process the data you provide to respond to you and answer your questions and requests. In doing so, the principle of data economy and data avoidance is observed in that you only have to provide the data that we absolutely need from you in order to contact you. These are usually your first and last name, your email address, the topic selection and the message itself. The legal basis for processing is our legitimate interest, the provision or initiation of a contractual service and your consent.

f) Using our membership services

We process the Personal Data involved in your use of our membership services in order to be able to join our club and participate in our activities. This includes in particular our support, correspondence with you, invoicing, fulfillment of our contractual, accounting and tax obligations. Accordingly, the data is processed on the basis of fulfilling our contractual obligations and our legal obligations.

g) Members Only Area

It is also possible for you to register for an account. For this purpose, you are required to provide your name, email and password. Your phone number, address, d.o.b., citizenship details, spoken languages and partner’s name, avatar are optional. Your password and email address will enable you to log in more easily without having to enter your data again when you wish to access your AWC profile and our members only area. The purpose of processing your other registration details is the issuance and maintenance of your membership following an eligibility assessment. The purpose of processing your profile information also extends to showing your details in our directory and to be able to develop it further. The legal basis for the processing of your Personal Data is the establishment and implementation of the membership contract and your consent.

If you provide an image for your avatar, we may process that image and the relevant facial-related information as part of your profile and within our directory. Images and facial-related information are used and processed solely for the purpose explicitly consented to and we do not collect, use, or store any images and facial-related information for the purpose of recognizing faces outside of this purpose. The legal basis is your consent.

For membership management, we are processing the data related to your membership using the services of Ultimate Membership Pro – WordPress Membership Plugin provided by WpIndeed. Membership records help by us are backed up digitally using the services of Dropbox and our AWC Payment Form requires Cognito Forms provided by Cognito. This data processing is based on our legitimate interest in providing our member services, the fulfillment of the membership contract and your consent.

We process the Personal Data that arises when you use our WhatsApp Groups. When you join one of our WhatsApp groups, We and WhatsApp process the Personal Data you provide in accordance with your consent, the performance of a contract and our legitimate interest for the purpose of providing the services (joining the WhatsApp Group) requested by you. Of course, we also process your chats with us and other users and the content you publish as part of the operation of our WhatsApp Groups including your provided text and voice messages, image and video recordings, etc. Some of the information you provide to us may be considered “special” or “sensitive”, for example in relation to your racial or ethnic origin, sexual orientation and religious beliefs. By choosing to provide this information, you consent to the processing of this information.

If you take out a membership, your payment data will be processed via our payment service provider Stripe or in case of offline payments Bank Transfer and Wise. Payment data will solely be processed through Stripe or your chosen payment service provider for offline payments, and we have no access to any Payment Data you may submit. The legal basis for the provision of a payment system is the establishment and implementation of the contract.

If you register for our newsletter, we use your email address to send you our email newsletter on a regular basis on the basis of your consent using the services of Mailchimp by Intuit Inc. Unsubscribing from the newsletter is possible at any time and can be done via the unsubscribe link provided in each newsletter. After unsubscribing, we will delete your email address unless you have expressly consented to further use of your data or we reserve the right to use data beyond this, which is permitted by law.

h) Administration, financial accounting, office organization

We process data in the context of administrative tasks as well as organization of our club, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest.

i) Promotional use of your data

We use your data (name and email) within the legally permissible scope for marketing purposes, e.g., to draw your attention to club internal communications and information via email. This serves to protect our legitimate interests.

j) Testimonials

Within our website, we may display certain Personal Data, share certain details, knowledge and insights in the form of testimonials. When you approve and submit your testimonial to us your consent is obtained, and you have choices about the information in your testimonial. The storage of testimonials is based on your consent.

k) Photographs of our members on our website

We process and publish photographs of our members on our website. Said photographs may include a) photos where no one can be identified; b) photos of crowds; c) photos of individuals and posed groups. While we do not require a legal basis for photographs where no one can be identified, the legal basis for processing photos of crowds is our legitimate interest and the processing of photos of individuals and posed groups is based on consent. In case of the latter, when you approve the publication, your consent is obtained.

l) Blogs by AWC Members

If you are interested in the blogs by our AWC members and want to look at a certain article you will be redirected to the relevant source, and as such your IP address and other data may be transferred to the relevant source. We have no influence or control over the data collected and processed by the relevant operator when you are being redirected and you can learn more about data processing at the relevant operator’s privacy policy. We use the Blogs by AWC Members feature, on the basis of our legitimate interests in conjunction with the initiation of a (pre)contractual relationship with you.

DISCLOSURES OF YOUR PERSONAL DATA

We will not disclose or otherwise distribute your Personal Data to third parties unless this is a) necessary for the performance of our services b) you have consented to the disclosure, c) or if we are legally obliged to do so e.g., by court order or if this is necessary to support criminal or legal investigations or other legal investigations or other legal proceedings; or proceedings at home or abroad or to fulfill our legitimate interests.

INTERNATIONAL TRANSFER

We may transfer your Personal Data to other companies as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organizational measures to protect the Personal Data we transfer.

SOCIAL MEDIA

We are present on social media on the basis of our legitimate interest (currently, Facebook). If you contact or connect with us via social media, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The Personal Information collected when contacting us is to handle your request and the bases are both your consent and our legitimate interest.

In addition, your data may be processed for market research and advertising purposes. For example, usage profiles can be created from your usage behavior and the resulting interests. This allows, for example, advertisements to be placed within and outside the platforms that presumably correspond to your interests. The legal basis is our legitimate interest.

When you visit our social media profiles, we, as the operator of the profile, process your actions and interactions with our profile (e.g., the content of your messages, enquiries, posts or comments that you send to us or leave on our profile or when you like or share our posts) as well as your publicly viewable profile data (e.g., your name and profile picture). Which Personal Information from your profile is publicly viewable depends on your profile settings, which you can adjust yourself in the settings of your social media account. The legal basis is our legitimate interest and your consent.

HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We will delete your Personal Data when we no longer need such Personal Data, for instance where:

  • it is no longer necessary for us to retain your Personal Data to fulfill the purposes for which we had collected it;
  • we believe that your Personal Data that we hold is inaccurate; or
  • in certain cases where you have informed us that you no longer consent to our processing of your Personal Data.

Sometimes, however there are legal or regulatory requirements which may require us to retain your Personal Data for a specified period, and in such cases we will retain your Personal Data for such specified period; and we may need to retain your Personal Data for certain longer periods in relation to legal disputes, and in such cases we will retain it for such longer periods to the extent required.

HOW WE SECURE YOUR PERSONAL DATA

We take appropriate organizational, technical, and physical measures to help safeguard against accidental or unlawful destruction, loss, alteration, and unauthorized disclosure of, or access to, the Personal Data we collect and process. However, no method of collection, storage, or transmission is 100% secure. You are solely responsible for protecting your password, limiting access to your devices, and signing out of websites after your sessions.

LINKED SITES

For your convenience, there may be hyperlinks on our website that link to other websites. We are not responsible for, and this Privacy Policy does not apply to the privacy practices of any linked websites or of any companies that we do not own or control. The website links may collect information in addition to the information we collect.

We do not endorse any of these linked websites, their products, services, or any of the content on their websites. We encourage you to seek and read the Privacy Policy of each linked website that you visit to understand how the information that is collected about you is used and protected.

YOUR RIGHTS AND PRIVILEGES

a) Privacy rights

You can exercise the following rights:

  • The right to access;
  • The right to rectification;
  • The right to erasure;
  • The right to restrict processing;
  • The right to object to processing;
  • The right to data portability;

b) Updating your information and withdrawing your consent

If you believe that the information we hold about you is inaccurate or request its rectification, deletion, or object to legitimate interest processing, please do so by contacting us.

c) Access Request

In the event you want to make a Data Subject Access Request, please contact us. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.

d) Complaint to a supervisory authority

You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The supervisory authority in Spain is: Agencia Española de Protección de Datos (“AEPD”) C/Jorge Juan, 6, www.aepd.es. We would, however, appreciate the chance to deal with your concerns before you approach the AEPD.

e) What we do not do

  • We do not request Personal Data from minors and children;
  • We do not process special category data without obtaining prior specific consent; and
  • We do not use Automated decision-making including profiling.

HELP AND COMPLAINTS

If you have any questions about this policy or the information we hold about you, you can reach us using our Contact Form.

CHANGES

The first version of this policy was issued on Saturday, August 3rd, 2024 and is the current version. Any prior versions are invalid and if we make changes to this policy, we will revise the effective date.