Privacy Policy

1. What is the purpose of this End User Privacy Policy?

This End User Privacy Policy describes how we, Banco Santander S.A. (“Banco Santander”, the “Bank” or “us“), with registered office at Paseo de Pereda, 9-12, Santander, Spain; process the personal data of users who use the entrepreneurship platform available through https://www.santanderx.com/ (“Santander X” or the “Platform”) on their own behalf (the “End User(s)“ or “you“), in order to view and register for the Calls for entrepreneurship training programs, events, challenges and awards (the “Calls“) published by Banco Santander or the affiliated universities and entities (the “Institutions”) on the Platform, or to collaborate with other End Users in the entrepreneurial projects of which they are the owners (“Entrepreneurial Projects”) or the companies they represent (“Companies”).

Santander X is a space created by Banco Santander that brings together End Users like you and Institutions from different countries, with the aim of completing and enhancing entrepreneurship projects and creating an entrepreneurship ecosystem. Through Santander X, End Users can enroll in Calls for training programs, events, awards, and entrepreneurship challenges and/or any other content related to entrepreneurship that has been published by both Banco Santander and the Institutions. Specifically, the service provided by Banco Santander includes access to Calls for training programs, entrepreneurship promotion events, growth support awards, entrepreneurship challenges, and business internationalization of entrepreneurship or any other functionality that may be added in the future and which we will inform you of expressly. Additionally, Banco Santander offers End Users a free catalog of training courses with unlimited access seats (“Courses with Unlimited Seats”) aimed at providing tools for the growth and transformation of their business to End Users and completing their training. The Courses with Unlimited Seats are intended to equip End Users to achieve greater opportunities for development and business growth. All the above functionalities collectively compose the "Service". You can find more details about our Service in the Terms of Service for End Users.

In addition to Institutions, the Service offered may have been financed by third parties (the "Promoters"), with whom the Institution may jointly manage the Calls or allow access to details about it, as they have financed these Calls.

Under certain conditions, certain End Users may have access to additional digital communities offered by Banco Santander (“Santander Communities”). These are digital communities in the form of a social network aimed at connecting highly skilled entrepreneurs and facilitating their relationships with other members of the entrepreneurial ecosystem. Santander Communities are accessible through a specific section of the Platform, which is only available to certain users. Within the Santander Communities section, there may be different communities (“Communities”), each with a specific audience and specific terms and conditions. Access to each specific community within the Santander Communities section will be granted as a prize to those users who have been selected by the Institutions as winners and/or finalists of specific calls for proposals indicating this.

Likewise, End Users can access benefits and discounts offered by third parties unrelated to Banco Santander ("Strategic Allies") simply by registering on the Platform ("Benefits"). These Benefits consist of access to valuable services for entrepreneurs under advantageous conditions. Banco Santander will not transfer any personal data of End Users to Strategic Allies.

This Privacy Policy for End Users describes the purposes for which we process your personal data, the reasons why the processing is lawful, the periods for which we keep your data, the entities with which it is shared, the rights you can exercise and other points we consider relevant so that you are aware of what we do with your data when you use our Service.

By “personal data”, we refer to any information related to you that has either been provided to us directly by yourself, generated while using our Service, inferred through analysis of your profile (when you agree to let us) or shared with us by third parties (“Data”). Specially protected data or information that is considered “sensitive” will not be processed.

Furthermore, we would like to inform you that due to your use of the Platform, we may process information that does not relate to you but instead pertains to the Entrepreneurial Projects and Companies which you register on the Platform (“Entrepreneurship Information”). This information is not considered to be of a personal nature and, therefore, is not subject to data protection regulations or to the provisions of this Privacy Policy. However, you may contact Banco Santander at any time with any concerns, queries or requests related to the Entrepreneurship Information.

The Data marked with an asterisk is necessary for you to use the Service. If you do not provide this information, you will not be able to use the Service. In this context, we may ask you for additional data for some features, e.g. to sign up for an entrepreneurship  training program, you may be asked for academic and/or professional data.

Additionally, for those Users who are clients of Banco Santander (Spain), registration on the Platform can be done directly through a registration form via their app (hereinafter, "App Santander"). This is a space provided by the app to facilitate Users' access to our services. Both the App Santander and the Santander X space are the responsibility of Banco Santander.

Please note that the processing of your data in the context of programmes, events and awards published by Banco Santander or the Institutions on the Platform is subject to their own privacy policies, so we recommend that you consult them beforehand.

For more details about how we process your Data, please see the following sections of this End User Privacy Policy.

2. Who is the data controller for your Data?

Identity of the data controller

Banco Santander, S.A., with corporate tax no. (NIF) A-39000013 and registered with the Bank of Spain under record no. 0049 and in the Santander Mercantile Registry, Sheet 286, Folio 64, Companies Book 5, Entry 1.

Contact details for the data controller

Postal address: Ciudad Grupo Santander, Avenida de Cantabria s/n, Santander Universidades, 28660 Boadilla del Monte, Madrid.

‒ Contact Form in relation to privacy: Contact Form

‒ Contact details for the data protection officer: [email protected]

3. What personal data do we process? How do we get your personal data?

At Banco Santander we process Data that you have provided to us both at registration and directly thereafter, Data that you have generated when using our Service, when you register for Calls as well as connection or browsing data on the Platform.

In some cases, we may obtain the User's registration process Data from other sources or services provided by Banco Santander, such as the App Santander.

In particular, we receive the following personal data: first name, last name, gender, address, personal email, professional email, date of birth, professional position, connection with Entrepreneurial Projects or Companies, telephone number, identification number (e.g. ID card, passport) as well as data related to browsing and use of the Platform (IP address, registrations in Calls, and Courses with Unlimited Seats or Benefits inquiry and profile data). In addition, we inform you that we may process the following Entrepreneurship Information about the Entrepreneurial Projects or Companies you have registered: company name and identification of the project or company concerned, address or registered office, profile of the company according to its size (micro-enterprise, start-up, scale-up, SME or other), dates of establishment of the company concerned, identification of the founders of the project or company and their current role in relation to the same, identification of the management positions of the company, web address of the company, description of the company's project or activity and its products or services, number of employees, location, internationalisation status of the company's activity, economic-financial information about the company (turnover, annual growth, customer volume, share capital, results of financing rounds), description of the company's investor profiles and participation in incubation or acceleration programmes.

In other cases, to enjoy the Service, the Platform may require minimal necessary information about your Company or Entrepreneurial Project in the form of questions, for example, to access the Courses with Unlimited Seats or to the Benefits (the “Minimum Information”). This information will be as follows: company name, company position, company CIF, and corporate email.

Finally, we inform End Users that we obtain information about browsing habits through cookies. For more information on this subject, we recommend that End Users consult our Cookie Policy.

4. What do we use your Data for? What is the legal justification for doing so?

Within the framework of Santander X, we will process your Data for the purposes described below. We always use your Data in a lawful way, so next to each purpose we state the basis on which we demonstrate that the purpose complies with data protection law.

General operations of Santander X

a) Creating your account on Santander X and enabling you to use that account to identify yourself, access and use the Service.

The main purpose of processing your Data and, as applicable, the Entrepreneurship Information about Companies, is to manage your registration as an End User on the Platform, so that you can identify yourself and we know who you are, as well as so that you can enjoy the Service that the End User uses, such as enrollment in Calls and Courses with Unlimited Seats offered on the Portal.

Once you have registered, we will use your Data and Entrepreneurship Information for all processing necessary to enable you to use the features of the Platform, such as managing your access to the various Calls for entrepreneurship training programs, challenges, events and awards published on Santander X and sharing your Data.

In order to register and access the Services, we require certain data from you. This may include: first name, last name, address, personal email, professional email, date of birth, job title, connection with Entrepreneurial Projects or Companies, telephone number and gender/identification number, for users registering an Entrepreneurial Project (e.g. ID card, passport). Additionally, you may furnish specific Entrepreneurship Information depending on your utilisation of the Platform.

What is the legitimate basis that allows us to do this?

The legitimate basis for the processing of data is the execution of a contract concluded through the acceptance of the End User Terms and Conditions of Service.

b) Autocompletion of information in the User registration process. 

When requested, Banco Santander may process Users' Data to pre-fill some of the information requested during the registration process, that is, creating your account in Santander X and registering as a User. The purpose of the processing is to facilitate the User's registration in the services offered by Banco Santander, in those cases where they already have the relevant information. The User may modify any data that is pre-filled in the registration forms before it is submitted to Banco Santander for the creation of the user account. The data processed will only be those indicated in the registration form of the Platform. Depending on the context in which the User registration process takes place, Banco Santander may obtain the data from a different source:

- Registration from the Santander App of Banco Santander (Spain)

When the User is a client of Banco Santander (Spain) and registers on the Platform through their Santander App, Banco Santander will obtain the data from the account that the User has previously created when registering in the Santander App. This Santander App is also the responsibility of Banco Santander, just like this Platform (see the specific privacy policy of the Santander App).

There is no transfer or communication of personal data in the registration from the Santander App because the processing of personal data of the involved service is the responsibility of Banco Santander. Nevertheless, Users' consent will always be requested for the autocompletion of their Data.

What is the legal basis that legitimizes this processing?

The legal basis for carrying out this data processing is the express consent of the User.

In the event that the User does not initially provide their consent or, having provided it, revokes it in the future, it will not result in the loss of their status as a User nor will this affect their enjoyment of the service.

c) Transfer of Data to Institutions organising entrepreneurship training programmes, events, challenges and awards and/or to Institutions promoting or sponsoring entrepreneurship training programs, challenges, events and awards.

Upon registering in a Call for an entrepreneurship training program, event or award, we will transfer your Data and relevant Entrepreneurship Information regarding Companies to the responsible Institution that organises it, as well any other Institution responsible for promoting, granting or sponsoring it, so you can take part in it. This also includes the Collaborators, Assessors and Mentors designated by those Institutions. Additionally, sometimes the training programs require that the training be completed at an institution different from the one that granted it, to which Banco Santander will also transfer the data in order to manage the necessary procedures to take the training program. In summary, the following cases may occur:

Case I: There is a Promoter that finances a training program, challenge, event, or award and an Institution that grants the training program, challenge, event, or award and simultaneously where the End User takes the training, so Banco Santander will transfer the data to the Promoter and the Institution in question.

Case II: There is a Promoter that finances the training program, event, challenge, or award and, on the other hand, an Institution that grants them, and finally a third Institution where the End User takes it. In this case, Banco Santander will transfer the data to the Promoter, the Institution that grants the training program, event, challenge, or award, and the Institution where the End User takes it.

The transmission of Data to the organising and/or sponsoring Institutions is required for participation in the selected entrepreneurship training program, event , challenge or award. In some cases, the organising and/or promoting entities are located in unsafe countries or outside the European Union. Section 2 “International data transfers to third countries” outlines the name and details of Institutions affiliated with Santander X located outside of the European Union.

The following data are assigned: first name, last name, gender, address, personal email, professional email, date of birth, professional position, connection with Entrepreneurial Projects or Companies, telephone number, identification number (e.g. ID card, passport). Furthermore, Entrepreneurship Information will be supplied regarding Entrepreneurial Projects or Companies that submit to the Calls and Courses with Unlimited Seats.

What is the legitimate basis that allows us to do this?

The legitimate basis that allows us to carry out this processing is the execution of a contract that comes into existence with the acceptance of the End User Terms and Conditions, as well as the Legal Terms and Conditions of the Call for the training program, challenge, award or event in question. In addition, we consider that the transfers to the organising and/or sponsoring Institutions in whose Calls you register are one-off transfers, as we only do this when you register for them. The transfer of your data to Institutions located outside of the country in which you are located, to countries that have not been formally recognised as safe by data protection authorities, may be warranted due to both considerations.

d) Contact mailbox.

Banco Santander processes the data in order to respond to your requests for information, such as incidents, privacy rights, requests for Calls for entrepreneurship training programs, challenges, events and awards that are published, or other aspects of Santander X sent by the End User (whether registered or not) through the contact form provided, as well as to the actions and operations that may result from them.

What is the legitimate basis that allows us to do this?

This processing is carried out on the basis of our legitimate interest in adequately addressing concerns raised by End Users and increasing satisfaction with the Service and, where applicable, in compliance with legal obligations relating to customer service.

We have carried out a weighting analysis to assess whether we can actually carry out this processing based on our legitimate interest. End Users can contact us to ask us to send it to them using the contact details indicated in Section 2). However, we list some of the main conclusions of this analysis as follows: the resolution of doubts and questions represents a genuine interest for us that is entirely legitimate, it is proportionate as there are no less intrusive measures that allow us to develop our interest without processing End Users' data in a lawful manner, it does not represent any harm to you (on the contrary, it allows for fluid communication with Banco Santander), the processing of the data is not unbalanced, and, furthermore, it is a common practice in the industry.

e) Transmission of its own communications relating to the content and improvement of the Santander X Service by any means, including electronic means. Banco Santander will use the personal data supplied upon signing up to the Platform to send communications that can help facilitate Service utilisation. This includes providing automatic notifications if you begin and do not complete registration on a Call  and Courses with Unlimited Seats available through Santander X, with the intention of offering the necessary assistance mechanisms for completion. We will also send you communications to find out how satisfied you are with the Service and identify possible improvements we could make and communications related to Calls currently active on Santander X for entrepreneurship training programs, challenges, Courses with Unlimited Seats, events and awards that may be of interest to you.

What is the legitimate basis that allows us to do this?

Banco Santander's legitimate interest is the basis for this data processing. In particular, Banco Santander has an interest in ensuring that its End Users are aware of the various functions or possibilities of the Platform so that they can make full use of the Service and, furthermore, know how to improve it.

At Banco Santander, we have carried out a weighting analysis to assess whether we can indeed carry out this processing based on our legitimate interest. End Users can contact us to ask us to send it to them at the addresses indicated in Section 2). However, some of the main conclusions from this analysis are set out below: sending our own communications relating to the content and improvement of the Service is a genuine interest for us which is entirely legitimate; it is proportionate as there are no less intrusive measures which would allow us to develop our interest in alerting you to the opportunities we offer; it does not place you at a disadvantage, but rather results in us sending you offers and announcements for calls that we believe will help you in your training; you can object to it at any time and from the outset; and furthermore, it is a common practice in the industry.

f) Profiling for marketing purposes and sending our own commercial communications and third party products or services by any means, including electronically. It is our intention to send you content of interest at all times. Banco Santander may send you its own commercial communications and/or those of third party products or services, which may relate, for example, to banking products, insurance products, telecommunications, education, leisure, research, automotive, mass consumption, employment, culture, careers, textiles, transport, insurance, gastronomy, technology, food, television, radio, portals and Internet comparisons.

Commercial communications are personalised based on your profile, as we are not interested in sending you generic communications. This profile is created on the basis of factors such as (i) your Data (including your basic identification data and your browsing habits on our Platform, such as the type of Calls you sign up to, Courses with Unlimited Seats, the type of Benefits you consult, etc. ) (ii) other data about you that we may have because you have previously provided it to us outside of the Platform, (iii) data about you that comes from third party platforms that belong to the same advertising network as us (in the latter case, only if you have accepted the installation of cookies or other tracking devices when accessing the Platform), (iv) Entrepreneurship Information relating to the Companies to which you are linked.

What is the legitimate basis that allows us to do this?

The legitimate basis for enabling this data processing is your explicit consent. If you do not give your consent initially or, having given your consent, subsequently withdraw it, this will not result in the loss of your status as an End User, nor will it affect your participation in Santander X.

g) Transfer of data by Banco Santander to companies of the Santander Group located in your country of residence* so that they can send you personalised commercial communications from themselves or from third parties by any means, including by electronically. If you consent, we will transfer your data and, where applicable, Entrepreneurship Information about Companies, to the Santander Group companies located in your country of residence so that they can send you separate commercial communications about their own products and about third party products or services which may relate, for example, to banking products, insurance products, telecommunications, education, leisure, research, automotive, mass consumption, employment, culture, careers, textiles, transport, insurance, catering, technology, food, television, radio, portals and Internet comparisons. Commercial communications are personalised, as it is not in their interest to send general communications, based on the profile that each of them has about you. This profile consists of (i) the Data we provide them (see below) and (ii) the data they already have about you and that you have provided them outside the Platform, if they have any.

*You can see the list of Santander Group companies to which we may share your Data, depending on your country of residence, at this link.

The following Data are assigned: (i) first name, last name, gender, address, personal email, professional email, date of birth, professional position, connection with Entrepreneurial Projects or Companies, telephone number, identification number (e.g. ID card, passport) and (ii) data relating to browsing and use of the Platform (e.g. IP address and type of Calls registrations and Courses with Unlimited Seats or Benefits inquiry), together with certain Entrepreneurship Information where applicable.

What is the legitimate basis that allows us to do this?

The legitimate basis for enabling this Data processing is your explicit consent. If you do not give your consent initially or, after you have given your consent, subsequently withdraw it, this will not result in the loss of your End User status nor affect your participation in Santander X. This consent also applies to data transfers that would be made by the Data Controller if the End User is located in an “unsafe” country. Further details on international transfers can be found in Section 6) of this Privacy Policy.

h) Running prize draws, promotions and competitions. From time to time, Banco Santander may organise promotions to promote our Service, our other products or services, or third party products or services through the Platform or social media.

What is the legitimate basis that allows us to do this?

If you choose to participate, the legitimate basis for processing your data is consent to the legal bases of the relevant promotion.

i) Carrying out statistical analysis on the operation of the technology supporting the Service in order to make technical, security, operational, user-friendly and commercial improvements.

We obtain statistical data about the technical operation of our technology in order to improve it commercially, correct errors and make it more secure and user-friendly. Therefore, we may use information that you generate by interacting with the Platform and the Service in aggregate form with that of other Users for the purpose described above.

What is the legitimate basis that allows us to do this?

Banco Santander's legitimate interest serves as the legal basis for this Data processing. Our interest is in collecting and analysing the data regarding use of our Service, in an aggregate form, in order to analyse the efficacy and practicality of the Call and Courses with Unlimited Seats or Benefits. Moreover, this would enable us to make further technical improvements such as increased security or improved usability that caters to our End Users’ needs.

We have carried out a weighting analysis to assess whether we can actually carry out this processing based on our legitimate interest. End Users can contact us to ask us to send it to them using the contact details indicated in Section 2). However, we list some of the main conclusions of this analysis as follows: the carrying out of statistical analyses represents a genuine interest for us that is entirely legitimate, it is proportionate as there are no less intrusive measures that allow us to develop our interest, it does not represent any harm to you, and, furthermore, it is a common practice in the industry.

j) Anonymisation of personal data. We will anonymise End User Data and utilize aggregation with Entrepreneurship Information and other anonymous data to understand patterns, extract insights, gain intelligence on entrepreneurship trends, enhance the security of our technology, and fulfil any additional objectives. The anonymised data may be used to produce aggregated reports or reports for internal Santander Group purposes.

The Data processed are: (i) first name, last name, gender, address, personal email, professional email, date of birth, professional position, connection with Entrepreneurial Projects or Companies, telephone number, identification number (e.g. ID card, passport) and (ii) data relating to browsing and use of the Platform (e.g. IP address and type of Calls registrations and Courses with Unlimited Seats or type of Benefits you inquiry), together with certain Entrepreneurship Information where applicable.

What is the legitimate basis that allows us to do this?

We believe that pursuing this purpose is lawful due to our legitimate interest in strengthening the security of our Service and gathering intelligence to gain insights regarding entrepreneurship trends. We also aim to use said insights for other applications. It is important to emphasise that the results of our analysis of aggregated, anonymous data will not have a direct impact on you.

We have carried out a weighting analysis to assess whether we can actually carry out this processing based on our legitimate interest. End Users can contact us to ask us to send it to them using the contact details indicated in Section 2). However, we list some of the main conclusions of this analysis as follows: anonymisation represents a genuine interest for us that is entirely legitimate, it is proportionate as there are no less intrusive measures that allow us to develop our interest, it does not represent any harm to you, and, furthermore, it is a common practice in the industry.

k) Compliance with legal obligations. Finally, Banco Santander may process Data to comply with applicable legal obligations. For example, obligations of a fiscal nature, compliance with judicial requirements, etc.

What is the legitimate basis that allows us to do this?

This purpose is lawful because we need to process your Data to comply with our legal obligations.

Specific operations of Santander Communities

l)  To enable you to identify yourself, access and use the Santander Communities Service and its various functionalities.

The main purpose of processing your Data and, where applicable, Entrepreneurship Information about Companies, is to manage your access, use and enjoyment of Santander Communities, so that you can identify yourself and we know who you are, as well as to enable you to use the features of the Community of which you are a member.

You do not need to go through an additional registration process to do this. We use the information you provided when you created your Santander X account to give you access and allow you to use the Santander Communities section. This way, you can access the Santander Communities section using the same access data that you would use to access the main Santander X service.

We use your Data and the Entrepreneurship Information for all processing necessary to enable you to use the features of Santander Communities or the Community you are participating in, such as managing your access, posting content, registering for events posted by other users or contacting other Santander Communities users.

Please note that the use of Santander Communities has the following implications:

• Public profile. When you activate your account in Santander Communities, your user profile and any content posted by you become visible to other Santander Communities users. Therefore, certain data you provided when registering with Santander X will be visible to these users. This data includes: your first name, surname and country of residence, as well as the name and description of the Business Project or Company you are linked to, together with certain Entrepreneurship Information.
• Registering for an event. When you register for an event, your information will be shared with the company or institution that organises, runs or manages the event. This company or institution will process your personal data under its own responsibility and in accordance with its data protection practices. We recommend that you consult the relevant privacy notice of that company or institution for the specifics of how your data will be processed.
• Messaging. Please be mindful of the information you send through the messaging features and use it with care. It is not permitted to include personal data of third parties in messages exchanged via the Community.

What is the legitimate basis that allows us to do this?

The legitimate basis for the processing of data is the execution of a contract concluded through the acceptance of the End User Terms and Conditions of the Service.

m) Sharing of Data by Banco Santander with Investors and Third Party Users so that they can contact End Users.

Where provided for in the legal provisions governing your experience in connection with a particular Community, we may offer to provide information about you, your Entrepreneurial Project or your Companies to potential Investors or other Third Party Users who participate in your Community. This may include providing your Data and/or, where applicable, Entrepreneurship information.

In this situation, Banco Santander will carry out a thorough review of your profile and its associated Entrepreneurial Projects and Companies. Your Data and the noted characteristics will be shared with potential Investors who can fulfil their inclination to invest, or with Third-Party Users who may benefit you through the offering of related experiences or valuable opportunities. They may contact the Companies for investment, business development, networking, mentoring and other purposes.

Please note that once Banco Santander discloses the Data, investors or third party users will process the Data received at their own risk and in accordance with their privacy practises. We recommend that you consult the relevant privacy notice for the specifics of how your Data will be processed.

The data transferred would be: name, surname, address, email, together with certain Entrepreneurship Information relating to the Companies.

What is the legitimate basis that allows us to do this?

The legitimate basis for processing your Data or Entrepreneurship Information about Companies is the Legal Terms and Conditions that govern your experience with a particular Community. These Legal Terms and Conditions govern the Call with which you apply for membership of the Community. If you do not wish to share this information with potential investors, you can tell us at any time as described in the following sections of this Policy.

5. How long do we keep your Data for?

The Data will be retained for the duration of our contractual relationship with you, which is governed by the End User Terms and Conditions of the Service.

In the event that you withdraw your consent or object to further processing of your Data, we will cease our processing activities related to purposes which required your consent. If however, our legitimate interests remain applicable, we will continue such activities.

If the End User withdraws their consent, or exercises their right to erasure, their personal data will be blocked for the periods established by law in order to comply with any obligations arising from their processing, to formulate, assert and/or defend any claims, insofar as this is permitted by applicable law, or to make the Data available to judges and courts or the competent authorities. Banco Santander will retain your Data in blocked form during this additional period. This means that we will not use it for the original purposes, but only for the purposes described in this paragraph and during the limitation periods for any liability claims that may exist. After the expiry of this additional period, we undertake to stop processing all Data.

6. To whom do we disclose your data?

Data Recipients

Your Data is shared with the entities listed below:

General operations of Santander X

‒ Service providers. They provide us with different services related to Service management, such as technological infrastructure, storage, commercial communications, or End User support. All of Banco Santander’s service providers who may have access to your Data are bound by confidentiality agreements and are required to comply with applicable data protection regulations. We have signed agreements with these service providers that regulate the use of your Data, limiting this to the provision of the Service and the security measures they must adopt to protect your Data. These providers never use your Data for their own purposes. They only use it to help us provide the Service to you.

Users may consult which specific Data is transferred to the above Recipients in Section 4 of this Privacy Policy.

‒ Institution affiliated to Santander X that organises and/or sponsors Calls for entrepreneurship training programs, challenges, events or awards, as well as its Assessors, Collaborators, Mentors and Jurors. The Data and files provided by the End Users during their application process will be directly transferred to whichever Institution has organised the entrepreneurship training program, challenge, event or award in which they are registering. Furthermore, if there is a different Institution that is sponsoring this activity, those documents will also be sent to them. Finally, all of these Institutions’ required Collaborators, Assessors, Mentors and Jurors will also receive copies of these documents.

‒ Santander Group entities. Banco Santander will communicate the Data of End Users who give their consent to other Santander Group entities domiciled in your country of residence, based on the criteria established in Section “4. What do we use your data for? What is the legal justification for doing so?”. Under the following link, you will find the entities of the Santander Group to which we may disclose your data if you give your consent so that they can send you personalised commercial communications in accordance with purpose f).

‒ Public authorities and bodies for the fulfilment of their tasks. We may sometimes share information with public authorities or bodies as required by law in order to enable them to carry out their duties. For example, tax authorities or courts of law may use your Data for their own purposes.

Specific operations of Santander Communities

‒ Other Community users. Please note that depending on how you participate in the Communities and use their features, other Santander Communities users may access your data, including data resulting from your use of the Community, such as your posts, messages and the like.

‒ Companies or institutions organising events. If you register for an event organised by a third party, Banco Santander will transmit the Data you provide in the registration form to the company or institution that manages, organises or runs the event in order to process your participation.

‒ Potential investors. In accordance with the Legal Terms and Conditions outlined in the applicable Community, Banco Santander will communicate relevant End User information and Entrepreneurship Information about Entrepreneurial Projects or Companies they are associated with to potential investors whose investment requirements correlate with said Companies' characteristics pursuant to Section “4. What do we use your data for? What is the legal justification for doing so?”.

International data transfers to third countries

‒ Institution affiliated to Santander X that organises and/or sponsors Calls for entrepreneurship programmes, events or awards, as well as its Assessors, Collaborators, Mentors and Jurors. Santander X is international in nature, and End Users and Institutions located inside and outside the European Union may register with it. If the End User registers for a Call for any international programme, event or entrepreneurship award organised and/or sponsored by an Institution outside the European Union, your Data may be transferred to such Institutions as well as their associated Collaborators, Assessors, Mentors and Jurors. We wish to alert you to the potential risks associated with sending data outside the European Union. In such cases, the safeguards required by applicable European regulations would no longer apply due to the lack of an adequacy ruling from the Commission on that third party country. Banco Santander will not be held liable for nor can it guarantee the security of the assigned data. The international transfers associated with this agreement are legally permissible due to their supporting role in executing the End User Terms and Conditions of the Service and by way of their sporadic nature; these transfers will only be made upon request when you decide to register in Calls for applicable programmes, events or awards.

‒ Santander Group entities. We must make you aware that there are entities of the Santander Group located in regions outside of the European Union which have been declared “unsafe” by the European Commission. Unless otherwise stated, we will only transfer your personal data in accordance with Standard Contractual Clauses approved by the European Commission. End Users may obtain further information regarding international transfers of personal data and the aforementioned protective measures by sending an email to the address provided in Section “7.  What are your privacy rights?”.

‒ Service providers. Some of these service providers are located outside of or may access End Users' Data from outside of the European Economic Area. We have therefore put appropriate safeguards in place to ensure that the Data is processed with a level of protection equivalent to that in the European Economic Area. In these cases, there are what we call “international data transfers”. These transfers may be covered in particular by the adoption of Standard Contractual Clauses approved by the European Commission, which you can access at https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en or where our providers have binding corporate rules. You can request more information about international transfers and the appropriate safeguards we apply in each case by emailing us at [email protected].

7. What are your privacy rights?

Reference to the exercising of rights

End Users are entitled to access their Data, as well as to request the rectification of any inaccurate Data, the limitation of its processing or, where appropriate, request it be deleted when, among other reasons, the Data is no longer necessary for the purposes for which it was collected, as well as not be subject to automated individual decisions. In certain circumstances and for reasons related to their particular situation, data subjects may object to the processing of their Data; and Banco Santander will stop processing the data unless there are compelling legitimate reasons or the exercise or defence of possible claims. End Users will have the right to request the portability of their Data.

Data subjects may exercise their rights by contacting Banco Santander at Avda. de Cantabria s/n, Santander Group City, Santander Universities, 28660 Boadilla del Monte, (Madrid) and/or the following Contact form.

Right to withdraw consent granted

End Users have the right to revoke any consent given at any time by contacting the above addresses.

Right to complain to the Supervisory Authority

Data subjects have the right to contact the Spanish Data Protection Authority, Calle Jorge Juan 6, 28001, Madrid, through the website www.aepd.es, to submit a claim, especially if they have not obtained satisfaction in the exercise of their rights.

8. Amendment of the End User Privacy Policy

We reserve the right to amend this End User Privacy Policy in accordance with applicable law at any time. However, we will inform you of any significant changes that could have a material impact on your privacy well in advance. We will publish the amended End User Privacy Policy on our Platform, where you will be able to check the date of the last update. We may require new consents from you depending on the nature of the changes we make.

Last updated: 27/11/2024