1. IDENTIFICATION
· Data Controller: CLUB ATLÉTICO DE MADRID, S.A.D. (hereinafter, the “Club”)
· Tax ID: A-80373764
· Registered office: Av.de Luis Aragonés, 4 – 28022 Madrid
· Email: datos@atleticodemadrid.com
· Data Protection Officer: dpo@atleticodemadrid.com
2. INFORMATION
By accepting this PrivacyPolicy, the user (hereinafter, the “User” or, where applicable, the “Users”)is hereby informed that the personal data provided to the Club, as well as any data that may be generated during access to and use of the website located at theURL https://theforum.es/ (hereinafter, “Web The Forum”), will be processed by the Club in accordance with the provisions herein.
The User must carefully read this Privacy Policy, which has been drafted in clear and simple language to facilitate understanding, and the User may freely and voluntarily determine whether to provide their personal data to the Club.
3. MANDATORY PROVISION OF DATA
The data requested in the forms on The Forum Website are, in general, mandatory (unless otherwise specified in the required field) to fulfill the purposes for which they are being collected.
Therefore, if the User does not provide this data or does not provide it correctly, the User’s requests cannot be processed, although the User may freely view certain content on The Forum website.
4. SOURCE OF THE DATA
The data processed by the Club for the purposes listed in the following section comes from:
· From the User: data provided by the User through the various forms on The Forum website,data obtained from the User’s use of The Forum website and their browsingactivity on it (via cookies or data storage and retrieval devices), subject to anyconsent the User may provide to the Club.
· From third-party sources: only in cases where the User has given their consent, because the User has agreed to allow the Club to create a profile using their personal data in order to send them commercial communications tailored to their tastes and preferences. Specifically, the Club may collect information about the User’s browsing activity.
5. HOW WILL THE CLUB PROCESS THE USER’S DATA?
Personal data provided through The Forum website or other means made available to users will be processed by the Club as follows:
a) Responding to questions raised by theUser through the designated contact channels:
· Purpose: to manage, process, and provide support for the User’s requests, inquiries, incidents, complaints, or questions submitted through the contact channels made available by the Club.
· Legal basis: The processing of data for this purpose is based on the User’s consent, which may be withdrawn at any time. If the User withdraws consent, the inquiry or question raised cannot be processed.
· Types of data processed:
- Identification data: first name, last name.
- Contact data: email address.o Professional data: company and position or role held.
- Other data: any data the User may provide in connection with the inquiry or request submitted.
· Retention period: the data will be retained for the period necessary to process and respond to your request and, once this process is complete, for the statute of limitations period for any legal actions arising from said request.
b) Management of invitations to The Forum:
· Purpose: to manage and respond to requests submitted via the contact form in order to contact interested parties and manage their invitation to The Forum.
· Legal basis: The legal basis for data processing related to this purpose is the fulfillment of the contractual relationship.
· Typesof data processed:
- Identification data: first and last names.
- Professional data: company and position or role held.
- Contact data: email address.
· Retention period: The data will be retained until the conclusion of The Forum and, once concluded, for the statute of limitations period for any legal actions that may arise from such invitations.
c) Sending of commercial communications by the Club regarding products and services similar to those contracted
· Purpose: The Club may send commercial and promotional communications by electronic means (including SMS, email, and similar channels) concerning products or services similar to those already contracted or requested, provided that the User has not objected to such communications.
· Legal basis: the processing carried out for this purpose is based on the Club’s legitimate interest, in accordance with the exception provided under Article 21.2 of the Spanish Information SocietyServices Act (LSSI) and Recital 47 of the General Data Protection Regulation(GDPR). This legitimate interest is grounded in the provision of direct marketing aimed at offering the User products and services that may be of interest and fostering customer loyalty.
However, the User has the right to object to this processing both at the moment of providing their data and at any time thereafter.
· Categories of data processed:
- Identification data: first and last names.
- Contact data: email address.
· Retention period: The data will be processed for this purpose until the User objects to receiving such commercial communications.
If the User provides data regarding third parties, they represent that they have obtained their consent and/or sufficient authorization and agree to convey the information contained in the Privacy Policy to them, thereby releasing the Club from any liability in this regard. However, the Club may carry out the necessary verifications to confirm this fact, adopting the appropriate due diligence measures in accordance with data protection regulations.
6. WITH WHOM WILL THE USER’S DATA BE SHARED?
All personal data provided by the User through The Forum website may be disclosed to:
a) Kiwi Comunicación, S.L., with Tax ID No. B-85438737 and registered address at CalleJose Antonio Fernández Ordoñez, 40, portal 5, Office 15, 28055 Madrid, Spain, to the extent necessary for the provision of invitation management services, based on the fulfillment of the contractual relationship with the Club.
b) Public authorities, in the cases provided for by law , based on compliance with a legal obligation.
c) Courts and Tribunals, in the cases provided for by law, based on compliance with a legal obligation. In addition, the Club will engage third-party service providers who may have access to your personal data, which they will process on behalf of and for the account of the Club for the purpose of providing services. The Club follows rigorous supplier selection procedures to ensure compliance with its data protection obligations, including the execution of the corresponding data processing agreement in accordance with Article 28 of the GDPR. Specifically, the Club will rely on services provided by third-party suppliers operating, by way of example and not limited to, in the following sectors: legal advice, and technology and IT services.
7. INTERNATIONALDATA TRANSFERS
To carry out the processing purposes described, we may additionally use authorized subcontractors acting on behalf of and in the name of the Club as data processors (e.g., internet service providers, data hosting and technical support providers, email providers, general service providers, and physical security service providers, etc.) and who are contractually bound by our instructions, solely for the lawful purposes described and for the period of time strictly necessary to do so.
When authorized subcontractors acting on behalf of and in the name of the Club or the aforementioned recipients are located outside the European Economic Area or process your data there, we will be carrying out an international transfer of your data in accordance with data protection regulations. As a general rule, we will avoid international transfers, and your data will be processed within theEuropean Economic Area. However, should such transfers be necessary, we will adopt the organizational, technical, and contractual measures necessary to ensure the protection and security of your data, such as, for example, signing the European Commission’s Standard Contractual Clauses (“SCCs”) with the authorized subcontractor or third-party assignee, conducting impact assessment son the international transfer in question to evaluate the risk and adopt measures for its mitigation, encrypting data in transit or at rest, pseudonymizing the data subject to the international transfer, ensuring the data subject can claim damages directly against the authorized subcontractor or third-party assignee, etc.
8. COMMERCIAL AND PROMOTIONAL COMMUNICATIONS
Law 34/2002 of July 11 on Information Society Services and Electronic Commerce permits the sending of commercial communications via the internet and other electronic means, provided they can be identified as such, as well as the entity from which they are sent.
One of the purposes for which the Club processes the personal data provided by Users (whether they have authorized it or have not objected to the processing) is to send them commercial communications containing information regarding products, services, promotions, offers, events, or news relevant to the Users.
If the User wishes to stop receiving commercial or promotional communications from the Club, they may request to unsubscribe from the service by sending an email to the following email address: datos@atleticodemadrid.com, or by clicking on the link that will appear at the bottom of the commercial communications sent.
9. USER RESPONSIBILITY
The User warrants that they are over fourteen (14) years of age and that the data provided to the Club is true, accurate, complete, and up-to-date. For these purposes, the User is responsible for the accuracy of all data provided and will keep the information provided suitably updated so that it reflects their actual situation.
Like wise, the User guarantees that they have informed any third parties whose data they provide, if applicable, of the terms contained in this document. Furthermore, the User guarantees that they have obtained such third parties’ authorization to provide their data to the Club for the purposes indicated.
In any case, the User shall be liable for any false or inaccurate information provided through The Forum website and for any direct or indirect damages that this may cause to the Club or to third parties.
10. EXERCISE OF RIGHTS
As the data subject, the User may send a written request to the Club at the address indicated in the header of this Privacy Policy, or via email to the address: datos@atleticodemadrid.com, providing proof of identity, at any time and free of charge, to exercise the following rights:
a) Right of access: You have the right to be informed by the Club whether or not your personal data is being processed and, if so, to access such data and receive information regarding the purposes for which it is processed, the categories of data affected by the processing, the recipients to whom your personal data has been disclosed, and the anticipated retention period for the data, among other information.
b) Right to rectification: You have the right to request the rectification of inaccurate data concerning you when, among other reasons, such data is no longer necessary for the purposes for which it was collected.
c) Right to erasure: You have the right to request the erasure of personal data provided that the legal requirements are met.
d) Restriction of processing, withdrawal of consent, and full or partial objection to processing: Under certain circumstances (for example, if the data subject disputes the accuracy of their data, while the accuracy is being verified), you may request that the processing of your personal data be restricted, with such data being processed solely for the purpose of asserting or defending legal claims. You also have the right to withdraw your consent and to object to processing at anytime, for reasons related to your particular situation, if the processing is based on our legitimate interest or the legitimate interest of a third party (including processing for the purposes of direct marketing and the creation of corresponding profiles). In this case, the Club will cease processing, unless it can demonstrate legitimate grounds.
e) Data Portability: You have the right to receive the personal data you have provided to the Club in a structured, commonly used, and machine-readable format, and to transmit that data to another data controller without hindrance from the controller to whom you provided it, in the cases provided for by law for this purpose.
f) Automated individual decision-making: Furthermore, in addition to the aforementioned rights, in the event that automated decisions are made, including profiling, you have the right to request human intervention by the Club, to express your point of view, and to challenge the decision.
g) Other: Likewise, when personal data is transferred to a third country or to an international organization, you have the right to be informed about how to access or obtain a copy of the appropriate safeguards regarding the transfer. You may also file a complaint regarding the protection of your personal data with the Spanish Data Protection Agency at C/ Jorge Juan, 6, 28001 - Madrid, if you believe the Club has violated the rights granted to you under applicable data protection regulations.
11. SECURITY MEASURES
The Club will process the User’s data at all times in a strictly confidential manner and will maintain the required duty of confidentiality regarding such data, in accordance with the provisions of applicable regulations, adopting for this purpose the technical and organizational measures necessary to ensure the security of the data and prevent its alteration, loss, unauthorized processing, or access, taking into account the state of technology, the nature of the stored data, and the risks to which they are exposed.
12. CHANGES
The Club reserves the right to revise its Privacy Policy at any time it deems appropriate, in which case Users will be notified. For this reason, we ask Users to regularly review this privacy statement to read the most recent version of the Club’s Privacy Policy.
13. ACCEPTANCE ANDCONSENT
The User declares that they have been informed of the conditions regarding personal data protection and accepts the content of this Privacy Policy.
Last updated: 03/17/2026
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