“General Policy for the Protection of Personal Data”

The present document establishes the Privacy policy and WiFi Terms & Conditions which  REAL SOCIEDAD DE FUTBOL, S.A.D puts at the users’ disposal. The use of the Portal WiFi is conditioned by the user’s prior reading and acceptance of the terms, conditions, communications, warnings and any other legal notices contained in this clause.

In compliance with the provisions of current legislation on data protection, and in the context of the new regulatory framework established by virtue of the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council, of 27 April 2016, relating to the protection of natural persons with regard to the processing of personal data and the free circulation of said data and the national regulations on the protection of personal data, we hereby inform you about the processing of your personal data.  

Who is responsible for the processing of your data?

Identity: REAL SOCIEDAD DE FÚTBOL, S.A.D

Postal address: Anoeta Pasalekua, 1, 20014 Donostia/San Sebastián, (Gipuzkoa).

Contact Data: mailto:[email protected]

With what purpose and legitimacy do we process your personal data?

In general, your data will be processed by REAL SOCIEDAD DE FUTBOL, S.A.D for the fulfillment of the following purposes:

-To manage service requests and allow the use and access of the “Please wifi” service.

-To respond to any correspondence and service-related enquiries you send to us in respect of our products or services.

-To analyze your use of the “Please WiFi” service and the data it collects in order to, in aggregated and dissociated form, create statistics and information about the use of the service and the potential customers of REAL SOCIEDAD DE FÚTBOL, S.A.D.

-To elaborate a commercial profile based on the information provided by the user in the “Please WiFi” service. Automated decisions based on this profile will not be taken.

-We will use this information to market products and services to you where you have consented to this, on the basis of the interests determined by the “Commercial profile”.

-To store basic information about you, your device and your location, complying with the provisions set forth and to extend the WiFi service that the owner of the property provides and to whom we provide with customer analytics.

We also inform you that the information collected about you is used for the following purposes.

-To provide you with information relating to the establishment you are in, including information related to its products and services.

REAL SOCIEDAD DE FUTBOL, S.A.D will send offers or publicity and promotional communications to your email account by any electronically means where you have consented to this.

Therefore, the legal basis to the processing of your personal data is the consent you provide by using the service.

What personal data do we collect from you?

These are the categories of personal data we collect and use about you:

1-Registration Data: This is the personal data that is provided by you or collected by us from the social network you used to register in our system, but only when you have consented to share your personal data with us. This information is subject to the security settings of your social network account. We could request additional information in order to plan a campaign or promotion. If you report a problem with our service and having first obtained your prior consent, we will inform you about how we will use this information.

2-Additional information

- If you contact us, we will correspond on that matter.

- You may also be required to complete surveys which are used for analysis. However, you are not obliged to respond.

- Details of transactions you carry out through our site.

- Details of the navigation through our site.

3-Device data: We can also collect additional data about mobile devices, Smartphone, handheld devices, laptops, desktops computers or any other device used to access and use the services (device) including, when available, unique mobile device identifiers, operating system, search engine and information about the telephony operator as well as the device’s phone number (if any) in order to manage the system and where applicable, provide our advertisers with the information stored. We may also associate the devices information with any information provided. According to the privacy policy, both would be processed as personal data during the period they are combined.

4- Data localization: We could collect information about your current location. In some cases, we would collect data about the devices (WiFi enabled) which are in that location. This data is calculated on the basis of the WiFi signal strength. This data will be linked to the user by using the MAC device and will be shared both with the owner of the establishment and the Internet operator to contribute with the customer traffic analysis.

5-Registration data: Whenever you use the service, we would collect and store some information on our server logs, including but not limiting, the Internet protocol addresing system, the Internet Service Provider, site-visitation data, type and language of the search engine and date, time and pages visited.

How will we process your data?

All the information provided is stored in our secure services. The services are in Amazon Web Services, Inc (EEUU), company adhered to PRIVACY SHIELD. In consequence, we guarantee a high level of safety. The PRIVACY SHIELD system was designed by the European Commission on July 12, 2016 (UE) 2016/1250. The full text is available for consultation on the following site: http://eur-lex.europa.eu/legal-content/ES/TXT/PDF/?uri=CELEX:32016D1250&from=EN.

Unfortunately, the data transmission through Internet is not completely safe. Event though we will do everything possible to protect your personal data, we cannot ensure the security of your transferred data through our service. The risk of any transmission depends on you. Once we have received your information, we will apply strict procedures and security items to avoid unauthorized accesses. The access to our service is granted through the social network you choose. Therefore, you must ensure that you not send any personal data which you do not want to be seen, stored or used by other users.

How long will we keep your data?

The personal data will be processed and stored unless relationship with you is duly blocked.  We also retain your data to meet the requirements of the applicable law. Once it is not necessary, your data will be deleted and blocked according to our retention and destruction policy and limitation and prescription periods in accordance with the legislation in force.

How we are legally permitted to process your data?

The legal basis to process your data is the execution of the WiFi service subscription and the service conditions consent provided by the user besides the additional services explicit consent.

In any case,  refusal to consent or withdrawal of consent with regard to specific purposes will cause the automatic termination of services, notwithstanding the continuity of services inherent subject to subscription.

Data origin

Data processed is provided by the user once he/she subscribes to the club’s WiFi.

Recipients of your data

The recipients of personal data collected will be the club’s service providers. They will use this data for the performance of the subscription under a service agreement, a processor contract and a confidentiality agreement, as well as under the official entities which in the exercise of their functions require the club to do so.

What are your rights when making your data available to us?

You have the right to obtain confirmation on wether or not REAL SOCIEDAD DE FÚTBOL, S.A.D. is using your personal data.

You may exercise, if you wish, the rights of access, rectification and deletion of data sending a written communication or contacting the CLUB through the following email address: mailto:[email protected]

You can also contact REAL SOCIEDAD DE FÚTBOL, S.A.D. by postal mail at the address:  Anoeta Pasalekua, 1, 20014 Donostia/San Sebastián, (Gipuzkoa).

If we consider this necessary to be able to identify you, we may request you to provide a copy of a document evidencing your identity.

If you want an electronic copy of the personal data you provided, REAL SOCIEDAD DE FÚTBOL, S.A.D could send you en e-mail attachment with your data in a standardized format.

REAL SOCIEDAD DE FÚTBOL, S.A.D. will do everything possible to keep your information updated. However, the responsibility for the accuracy of the data supplied depends on the user. Therefore, if there is any modification in the user’s data, please contact us in order to implement them.

Equally, you have the right to object to the processing of your personal data to be shared with third parties and their use for marketing or commercial purposes or automated decision systems by simply informing us of the reason for your request and the right that you wish to exercise.

In the case of electronic communications, the necessary means will be put in the message body so that you will be able to oppose the sending of information and publicity.

Finally, we inform you that you have the right to file a claim before the responsible data protection regulatory authority, in particular, before the Spanish Data Protection Agency (https://www.agpd.es/portalwebAGPD/index-ides-idphp.php).

Personal data protection security

REAL SOCIEDAD DE FÚTBOL, S.A.D. maintains the necessary technical and organizational character measures in accordance with the level of risk of data processing and its impact on the rights of individuals to ensure the security of processing the personal data and in accordance with applicable data protection legislation at all times.

Nevertheless, users must be aware that currently, in the Internet environment, invulnerable security does not exist and therefore are not safe from possible illegal and undue interference, which REAL SOCIEDAD DE FUTBOL, SAD would not take any responsibility, since it has acted diligently to protect the data as determined by the Law.

COOKIES

Our service uses cookies to distinguish you from other users using our service. This helps us to offer you a good experience when you use the service and also helps us improve it. For more information about the cookies we use and why we use them, please see our cookies policy through the link on the access page.

CONNECTION TO THE WIRELESS NETWORK

Welcome to REAL SOCIEDAD DE FÚTBOL, S.A.D WiFi hot spot. The following Terms & Conditions are intended to regulate REAL SOCIEDAD DE FÚTBOL, S.A.D’s WiFi access and determine the conditions of access to the contents and services that we put at the user’s disposal through Internet.

1. DEFINITIONS

“User” is the natural person using REAL SOCIEDAD DE FÚTBOL, S.A.D’s free hot spot. This hot spot incorporates communication technologies with the purpose of promoting Internet connectivity.

You must accept the Terms & Conditions in order to access REAL SOCIEDAD DE FÚTBOL, S.A.D.’s WiFi.

By using and/or activating Service with us and/or clicking the accept button on the login/registration page you agree to be bound by this agreement.

This agreement applies from when we accept your request for Service.

This is a free Hotspot wireless internet Service provided by REAL SOCIEDAD DE FÚTBOL, S.A.D.

2. CONNECTIVITY

The following steps run through the general steps that you need to take to get connected to our WiFi:

Have a compatible device with WiFi access.

Turn the WiFi device on and wait until the device finds the net. Select REAL SOCIEDAD DE FÚTBOL, S.A.D from WiFi connections and fill the fields of the registration form.

However, REAL SOCIEDAD DE FÚTBOL, S.A.D is entitled to take the corrective measures necessary to guarantee the fulfillment of the Terms & Conditions designed in order to protect the integrity and security of the network.

3. WiFi USER TERMS & CONDITIONS

By connecting to our WiFi network you agree to the present Terms & Conditions.

By signing into the REAL SOCIEDAD DE FÚTBOL, S.A.D network, you acquire the condition of User. The condition of User implies the express, complete acceptance, without any reservations, of these General Conditions as well as of the specific conditions applicable to the content or service selected. In any case, any use of the REAL SOCIEDAD DE FÚTBOL, S.A.D network is subject to the fulfillment of the conditions and other applicable acts.

This service will not be used by Users under 16 years of age and will not collect personal information from them. If the User is under 16 years of age, he/she must not provide us with any personal information. REAL SOCIEDAD DE FÚTBOL, S.A.D reserves the right to ask the User at any moment to prove his/her identity.

REAL SOCIEDAD DE FÚTBOL, S.A.D will always try to make the Service available and guarantees an adequate bandwith speed. REAL SOCIEDAD DE FÚTBOL, S.A.D guarantee the availability and accessibility of the service. However, the service may be interrupted, limited or curtailed due to maintenance and repair work, transmission or equipment limitations/failures, collocation failures or due to an emergency.

When, in any circumstance,  REAL SOCIEDAD DE FÚTBOL, S.A.D cannot provide the WiFi service, under no circumstances, the User will require the mentioned Service to REAL SOCIEDAD DE FÚTBOL, S.A.D.

We reserve the right to immediately and without notice, suspend your access to the Service if we suspect that you violating the network security policies. Wireless devices must comply with all the laws, regulations and rules concerning wireless networks.

The interference or alteration of the wireless service due to a wrong use, both accidentally or intentionally, shall be prohibited.

Without prior notice, REAL SOCIEDAD DE FÚTBOL, S.A.D may modify the agreement at any time and introduce new conditions. The User accepts that REAL SOCIEDAD DE FÚTBOL, S.A.D may suspend, deactivate or disable this service.

The User commits her/himself to:

1. Not use the Service for unlawful purposes.
2. To comply with the WiFi access legislation in force.
3. Not use the Service to make offensive or nuisance communications in whatever form. Such usage includes posting, transmitting, uploading, downloading or otherwise facilitating any content that is unlawful, defamatory, threatening, a nuisance, obscene, hateful, abusive or harmful or which contravene the intellectual property or other rights of REAL SOCIEDAD DE FÚTBOL, S.A.D’s or third parties’.

REAL SOCIEDAD DE FÚTBOL, S.A.D does not guarantee:

1. The availability and/or continuity in the functioning of the Service.
2. The appropriate standards of quality, speed and reliability of the services.
3. The legality, reliability, utility, veracity, accuracy and actuality of the Internet services the User wants to access from REAL SOCIEDAD DE FÚTBOL, S.A.D’s WiFi network.
4. The absence of viruses or other harmful elements in the content or services provided or rendered by REAL SOCIEDAD DE FÚTBOL, S.A.D’s WiFi network.

REAL SOCIEDAD DE FÚTBOL, S.A.D does not control, nor is it in any way liable for, data or content that you access or receive via the Service. The exemption from liability for REAL SOCIEDAD DE FÚTBOL, S.A.D include any liabilities that are derived from:

1. The absence of availability and continuity of the functioning of REAL SOCIEDAD DE FÚTBOL, S.A.D’s WiFi network.
2. The interruption, suspension or cancellation of access to the Service.
3. The lack of veracity, exactness, reliability and usefulness of contents placed by the Service nor of any Internet site accesible from the network.
4. The unauthorised access and alteration of data stored and transmitted through the hotspot or the Services offered in this connection.
5. The infringement of intellectual and industrial property rights, the rights relating to the personality or any other rights related to transmission, distribution, storage, receipt, access, obtaining access to content, services and/or products through REAL SOCIEDAD DE FÚTBOL, S.A.D’s WiFi network.