Privacy policy

If you have registered on the Website using your email address, the data you provide includes:

• Personal identification and personal characteristics data: first name, surname(s), telephone number, email address, date of birth, postal code, third-party account identifiers (Google ID or Apple ID), and supplementary information for applications to join the employment pool or other corporate requests addressed to the RCDE. If you subscribe to RCDE's digital calendar, we may process the data necessary to manage that subscription, including preferences relating to selected calendars, matches, competitions or events, as well as technical and usage data necessary for the synchronisation, updating and proper functioning of the service.

The data provided through forms marked as mandatory must be supplied in order for the basic functionalities of the Website to operate. If you do not provide them, the application will not be able to perform its basic functionalities for your user account.

Additionally, for certain interactive functionalities of the Website or other tools within RCDE's digital ecosystem, we may process data arising from such interactions, including messages, queries, comments, content entered by the user in chats or virtual assistants, username or alias, avatar, date and time of publication or interaction, associated audiovisual content and technical information necessary to ensure the provision of the service.

We may also collect data through the use of cookies on the Website (and/or similar technologies) so that, depending on your settings, RCDE may collect and process personal data. The information we gather includes:

• Limited personal information and anonymous overall statistics for all users visiting our websites, the Internet Protocol (IP) address of the device you are using, the browser you use, your operating system, the date and time of access, the Internet address of the website from which you accessed our websites, and also information on how you use our websites, the battery level of the device used, available storage space, device language, etc.

For further information on the use and configuration of cookies (and/or similar technologies), please see our Cookie Policy.

Your personal data will be processed for the following purposes:

1. Provision of Services and Sale of Products
   Your data will be processed in order to provide you with the service consisting of the purchase and sale of products and the contracting of services offered through the Website. By way of example but not limitation, this processing includes managing the contracted services, processing your orders, delivering them to the indicated shipping address, managing any returns and informing you of the status/issues with your order/delivery.
   Legal basis: Performance of a contract to which you are a party, or, where applicable, to take steps at your request prior to entering into a contract (Article 6(1)(b) GDPR).

2. Management of Membership as a Club Member ("Socio")
   If you are interested in creating a Club member account, we will process your data to properly manage your subscription request to the members' area, as well as your access to the content and benefits made available to you as a Club member. This will involve managing your member account as part of the Club's digital services (unified login).
   Legal basis: Performance of a contract to which the user is a party, or, where applicable, to take steps at the user's request prior to entering into a contract (Article 6(1)(b) GDPR).

3. Management of Registered User Accounts
   If you are interested in creating a registered user account, we will process your data to properly manage your registration request, as well as your access to the content and benefits made available to you as a registered user. This will involve managing your account as part of the Club's digital services (unified login).
   Legal basis: Performance of a contract to which the user is a party, or, where applicable, to take steps at the user's request prior to entering into a contract (Article 6(1)(b) GDPR).

4. Complaints and Incident Management
   Managing and handling your complaints, requests, suggestions and assistance regarding possible incidents, sending, where applicable, non-commercial information related to the contract.
   Legal basis: Performance of a contract to which the user is a party, or, where applicable, to take steps at the user's request prior to entering into a contract (Article 6(1)(b) GDPR).

5. Marketing Communications Based on Consent
   Provided that you have consented to this processing, we will send, by any electronic means (email, SMS, push notifications), commercial communications about RCDE's products and services, including, by way of example but not limitation, discounts, news, upcoming launches, invitations to events or competitions, surveys, as well as products and services of RCDE's partner collaborators, related to exclusive promotions for its users, none of which will involve the creation of profiles or the disclosure of data to third parties.
   Legal basis: Processing will be carried out exclusively where you have given your consent to do so (Article 6(1)(a) GDPR).

6. Digital Calendar Subscription
   Managing your subscription to the Club's digital calendar, so that you can receive information related to the matches, competitions or events you have subscribed to and in which the Club participates, including the synchronisation, addition and updating of such events in your calendar, as well as the possibility of inviting you to register in RCDE's digital ecosystem (hereinafter, "Perico ID"), without this involving the sending of commercial communications, the disclosure of your data to third parties or the creation of profiles.
   Legal basis: Performance of a contract to which the user is a party, or, where applicable, to take steps at the user's request prior to entering into a contract (Article 6(1)(b) GDPR).

7. Video Surveillance
   Preserving the safety of people, property and the Club's facilities through the use of video surveillance systems.
   Legal basis: Processing will be carried out on the basis of the performance of a task in the prevailing public interest (Article 6(1)(e) GDPR), in accordance with Law 5/2014, of 4 April, on Private Security.

8. Compliance with Legal Obligations
   In certain cases, your personal data will be disclosed to third parties in order to comply with certain legal obligations or possible judicial decisions, specifically: to competent authorities and bodies, courts, tribunals or any other third parties authorised under applicable regulations.
   Legal basis: The legal basis for the processing is compliance with our legal obligations (Article 6(1)(c) GDPR).

9. Marketing Communications Based on Legitimate Interest
   To the extent permitted by law, and provided you have not objected, we will use your data to send you commercial and/or promotional communications by email or SMS about products and services similar to those you have previously contracted with the Club during the last year, without this involving the disclosure of your data to third parties or the creation of profiles.
   Legal basis: Processing is carried out to satisfy our legitimate interest (Article 6(1)(f) GDPR), always taking into account that our interest does not override your interests, rights and fundamental freedoms. When we contact you by email, SMS or equivalent electronic means, we rely on the exception provided for in Article 21.2 of Law 34/2002 (LSSI).

10. Personalised Commercial Offers
    Provided you have given your consent, your personal data will be processed in order to study products or services that may be tailored to your profile and commercial situation, in order to offer you commercial offers tailored to your needs and preferences, without this involving the sending of commercial communications or the disclosure of your personal data to third parties. In particular, transactional data obtained through the Club's various digital channels will be analysed, from which historical and temporal behaviour patterns are identified, with a level of detail aimed at better understanding your interests and consumption habits.
    Legal basis: Processing will be carried out exclusively where you have given your consent to do so (Article 6(1)(a) GDPR).

11. Statistical Analysis and Service Improvement
    Depending on your cookie settings, we will process your information to carry out anonymous, collective statistical analyses for the purpose of understanding how our Website operates, with a view to improving the development and personalisation of our services.
    Legal basis: Processing will be carried out exclusively where you have given your consent to do so (Article 6(1)(a) GDPR).

12. Website Security
    Your information will be processed to ensure the security of our Website, preventing and detecting possible security incidents and fraud.
    Legal basis: Processing is carried out to satisfy our legitimate interest, which consists of ensuring and improving the security of our products and services (Article 6(1)(f) GDPR), always taking into account that our interest does not override your interests, rights and fundamental freedoms.

13. Artificial Intelligence Virtual Assistants
    Managing the automated handling of queries made through artificial-intelligence-based virtual assistants in order to provide guidance on RCDE's content, services or official channels, without this involving automated decision-making or the creation of profiles.
    Legal basis: Performance of a contract to which the user is a party, or, where applicable, to take steps at the user's request prior to entering into a contract (Article 6(1)(b) GDPR).

14. Live Chat and Comment Functions
    Managing participation in live chat functionalities and comments associated with audiovisual content, subject to moderation to prevent unlawful or abusive uses or uses contrary to applicable legislation, without this involving automated decision-making or the creation of profiles.
    Legal basis: Performance of a contract to which the user is a party, or, where applicable, to take steps at the user's request prior to entering into a contract (Article 6(1)(b) GDPR). In this case, at the time of accepting the use of the live-chat functionality.

Provided that you have given your consent, your personal data and information may be subject to profiling, in accordance with what is indicated in section: "3.- For what purpose and on what legal basis do we process your data?". 

In this regard, your data and personal information are analysed for the purpose of creating a profile of your interests and preferences in order to personalise the commercial and/or promotional communications you have consented to receive. 

This profile is created by combining the information you provided when registering as a user and, additionally, where you have given express consent for each of the purposes described in section “3.- For what purpose and on what legal basis do we process your data?”, this profile will be created by combining the above information with information obtained from "cookies" whose installation you have consented to (for more information, see the Cookie Policy). Transactional data collected through the Club's various digital channels are also taken into account, from which historical and temporal behaviour patterns are analysed.

The creation of these profiles will not result in legal effects for the user or significantly affect them in a similar way. They will only influence the type of commercial and/or promotional communications sent. Please remember that you may withdraw the consent given in relation to this processing at any time. 

Notwithstanding the above, certain functionalities of the Website or of RCDE's digital ecosystem, such as virtual assistants or chat and comment moderation systems, may incorporate automated mechanisms to generate responses, filter content, prevent abuse or ensure the security of the service. These mechanisms are not intended to create commercial profiles of the user or to adopt decisions based solely on automated processing that produce legal effects on the user or significantly affect them in a similar way.

Likewise, subscribing to the Club's digital calendar and, where applicable, being invited to register in the Perico ID ecosystem will not, in themselves, involve the creation of commercial profiles or the adoption of decisions based solely on automated processing that produce legal effects on the user or significantly affect them in a similar way.

RCDE will process your personal data for the period necessary to fulfil the purposes set out in this Privacy Policy, as well as to retain your personal information in compliance with applicable laws and regulations. 

The criterion we follow for this is determined by: (a) the purpose of the data collected and the fulfilment of that purpose (e.g. for as long as our relationship continues); (b) the reasons why the data is collected (e.g. in the case of consent, you may withdraw it at any time); and (c) mandatory retention periods according to contractual and regulatory requirements.

As a general rule, the Club will process your personal data for as long as the commercial and/or contractual relationship remains in force. However, for each of the purposes, in the information we provide to you when collecting your personal data, we will inform you specifically and promptly of the applicable retention period in each case, including any periods set by statutory limitation, such as those relating to video surveillance activities or internal complaints.

However, in relation to chat functionalities, messages and comments published may remain visible for as long as the audiovisual content with which they are associated remains available on the Platform, unless removed by RCDE, at the user's request, or for any other reason provided for in the applicable Terms or current legislation.

Please note that, in some cases, we may retain your data beyond the period established above, for the period necessary for the formulation, exercise or defence of claims, requirements, liabilities and legal, contractual or ethical obligations, always duly blocked. Once the statutory limitation periods have elapsed, your personal data will be destroyed.

Your personal data will not be disclosed to third parties, except where there is sufficient legal basis authorising it under applicable legislation. However, depending on the purposes for which the personal information is collected, the following recipients may, where applicable, have access to that information:

Competent bodies and/or authorities, courts and tribunals, as well as the relevant law-enforcement forces, where there is a legal requirement and/or obligation to do so.

Third-party service providers may access personal data as data processors in order to provide services to the Club related to the purposes described in this Privacy Policy, including (without limitation) companies operating in the following sectors: technology, legal advice, marketing, multidisciplinary professional services, IT services, etc. These providers will only access personal data to carry out their services on behalf of and for the Club, under an obligation of confidentiality and always following its instructions, without ever being able to use such data for their own purposes and/or unauthorised purposes.

In particular, for the provision of the digital calendar service, the Club may engage ECAL Marketing Ltd. as technical service provider and data processor, which will process personal data on behalf of the Club and following its instructions.

Likewise, to the extent that ECAL Marketing Ltd. processes certain data for its own strictly technical, security, platform-protection, calendar-permission-management purposes or for the use of aggregated data, ECAL Marketing Ltd. may act as an independent controller. In such cases, the provision or disclosure of data to ECAL Marketing Ltd. will be carried out exclusively for those purposes, which must be described in its corresponding Privacy Policy.

Some of these providers may process and store personal information on servers located outside your country of residence; you can request details of these providers, which involves an international data transfer, by emailing: dpd@rcdespanyol.com

Therefore, depending on the user's location, data transfers to other countries may occur. In such cases, your personal data may be transferred internationally to third parties located outside the European Economic Area ("EEA"), provided that RCDE has the authority to do so and subject to compliance with the appropriate safeguards established in Articles 44 to 50 of the GDPR. Such third parties will only access the data in order to carry out their services on behalf of and for RCDE, under an obligation of confidentiality and always following its instructions.

In any event, appropriate safeguards include, among others:

• i. Adequacy Decision: A declaration by the European Commission that a non-EU State offers an adequate level of data protection equivalent to that provided by European data protection legislation.
• ii. Binding Corporate Rules (BCRs): These apply to business groups or unions of companies engaged in a joint economic activity, enabling the flow of personal data on the basis of self-regulation.
• iii. Standard Contractual Clauses: A contractual mechanism signed between the exporter and importer of Personal Data, whose model has been approved and published by the European Commission.
• iv. Code of Conduct or Certification Mechanism: Together with binding and enforceable commitments assumed by the recipient for the protection of the data transferred.

Please remember that you have the following rights:

Right to request access to personal data: You can ask us whether we are processing your data, and if so, access it.

Right to request rectification: If the data is inaccurate or incomplete.

Right to request the erasure of your data: Right to request that the Controller erase all or part of the data subject's Personal data. Please remember that for as long as our commercial and/or contractual relationship with you remains in force, there is a series of Personal data that we are required to process in order to fulfil the contract.

Right to request restriction of processing: In this case we will only retain it for the exercise or defence of claims.

Right to object to processing: Right to object to processing based on consent or on the existence of a legitimate interest (e.g. the sending of commercial communications). You may also freely register with an advertising opt-out mechanism (e.g. www.listarobinson.es). Upon exercising this right, we will stop processing your personal data, except where it must continue for legitimate reasons or for the exercise or defence of possible claims.

Right to data portability: If you wish your data to be processed by another controller, provided it is technically feasible, in a structured, commonly used and machine-readable format.

Right not to be subject to a decision based solely on automated processing: The Controller informs the data subject that, notwithstanding decisions based on automated systems, these decisions either do not produce legal or significant effects on the data subject, or are not adopted exclusively in an automated manner.

Please remember that any consent you have given us is always voluntary and may be freely withdrawn at any time, without such withdrawal having retroactive effect.

In particular, you may withdraw your consent at any time, without such withdrawal affecting the provision of the service that was the subject of your request.

Complaints: You may also, if you consider it appropriate, file a complaint with the Spanish Data Protection Agency (www.aepd.es). 

Exercising your rights: To exercise your rights, you may contact us by sending an email to dpd@rcdespanyol.com or in writing to the postal address given in section 1 of this Privacy Policy.

 We will only use your personal data in accordance with the Privacy Policy in force at the time we collect your personal data. RCDE reserves the right to amend this Privacy Policy at any time by publishing such amendments on our Website. 

If any clause of this Privacy Policy is annulled or declared invalid, the remaining provisions shall remain unaffected, retaining their full force and effect, in light of the regulations in force at any given time.

Policy on use by children. Our services are aimed exclusively at people over 14 years of age. In this regard, we do not deliberately collect information from minors under 14, except where provided by their parents or legal guardians. If we detect that the user is under 14, we may block and/or delete any personal data they may have provided. However, there may be specific cases, particularly in connection with promotional campaigns, in which personal data of minors is processed, in which case the consent and authorisation of the parents or guardians will be requested if the minor has not yet turned 14. If you are a minor and are unsure of anything explained here, please ask your parents or guardians for help. Certain specific functionalities of RCDE's digital ecosystem may be subject to additional age requirements, which will be communicated, where applicable, in the relevant contracting, registration or subscription process.

Specially protected data. RCDE does not request or intend to process personal data revealing ethnic or racial origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data intended to uniquely identify a natural person, health data, sex life or orientation. Users must not provide this type of data through forms, chats, comments, virtual assistants or other interactive channels. If, despite this, a user voluntarily provides such data, RCDE may process it only to the extent strictly necessary to manage its deletion, moderation, the handling of requests, compliance with legal obligations or, where applicable, the defence of rights.

In certain cases, when you decide to create your RCDE member account, you may do so without having to complete all the fields of the registration form through the so-called "Social Login", simply by clicking on the corresponding logo, which means that you will allow the social network to provide your personal data linked to your profile (your name, surname and email address) to the Club in order to create your member account. In other words, during the registration process you will be redirected to a federated authentication service that verifies the credentials and, if correct, returns the information to the requested service, in this case, your member account area.

This personal data will be processed together with the data generated from the use of your member account for the purposes communicated by RCDE during registration for the online services. In any case, the aforementioned systems allow you to select your privacy preferences in order to prevent certain exchanges of personal data. We recommend that, for further information, you consult the privacy policy of each social network via the links above.

The Website may contain links to third-party websites that we consider potentially useful and informative for you. However, please note that we do not endorse or recommend the content or services of such websites, nor are we responsible for their privacy policies. We recommend that you review and read the privacy policies of all the sites you visit. Please remember that this Privacy Policy applies only to the data that RCDE collects and/or processes through the Website.