Privacy policy.

1. Data controller

The controller of the personal data processed through this website is:

Controller

Elcano Films, S.L.

Tax ID

B22936934

Postal address

C/ Ordorika Auzua 6A, 48392 Muxika (Bizkaia), España

Privacy contact

dpo@elcanofilms.com

2. Data Protection Officer

Elcano Films, S.L. has not appointed a Data Protection Officer because the processing it carries out does not fall under the cases set out in article 37 of the GDPR (large-scale processing of special-category data, large-scale systematic monitoring or core public-authority activities). For any matter related to the protection of personal data you may write to us at dpo@elcanofilms.com.

3. Personal data we process

We only process the strictly necessary data:

Identification and contact data: name, email address and the content of your message, when you write to us using one of the email addresses published on this website.

Browsing data: when you give your prior consent through the cookie banner, we collect anonymous statistical data through Google Analytics 4 (truncated IP, device, browser, pages visited, time on page, geographical region at city level). We do not use advertising or behavioural-tracking cookies.

We do not process special categories of data (article 9 GDPR) and we do not collect data from minors under 14 years of age (article 7 LOPDGDD).

4. Purposes

Reply to your enquiry and manage the resulting business relationship (commercial, press, brand, festivals, financing).

Comply with legal obligations (accounting, tax, administrative).

Generate aggregated statistics on the use of this website to improve its content and performance — only when you consent to it.

5. Legal basis

Email enquiries: pre-contractual or contractual measures (article 6.1.b GDPR) or legitimate interest in answering the message you have sent us (article 6.1.f GDPR).

Statistical analysis through Google Analytics 4: your express consent given through the cookie banner (article 6.1.a GDPR and article 22 of Spanish Law 34/2002, LSSI-CE).

Compliance with legal obligations: legal obligation imposed on the controller (article 6.1.c GDPR).

6. Retention period

Email correspondence: for the time necessary to attend to your request and, where applicable, to manage the resulting relationship; thereafter, for the periods set out in commercial law (general 6-year period, article 30 of the Spanish Commercial Code) and in tax law (4 years, article 66 of the Spanish General Tax Act). Once those periods elapse, the data are securely deleted.

Statistical data through Google Analytics 4: a maximum of 14 months from the date of collection.

Cookie consent record: 6 months from the date you record your preference, after which the banner is shown again.

7. Recipients and processors

We do not transfer your data to third parties except where there is a legal obligation to do so. Personal data may be processed on our behalf by the following processors:

Google Ireland Limited — provider of Google Analytics 4 (anonymous statistical data) and Google Search Console (does not access personal data of website visitors). Headquarters: Gordon House, Barrow Street, Dublin 4, Ireland.

The hosting provider where this website is served — strictly to keep the website available.

Google Workspace — provider of the email accounts at @elcanofilms.com used to receive your messages.

8. International data transfers

Some of the processors above (notably Google) may host data in the United States. Such transfers are covered by the EU–US Data Privacy Framework (Adequacy Decision of the European Commission of 10 July 2023), to which Google LLC is certified, and by the standard contractual clauses approved by the European Commission. You may consult Google's data transfer policies at https://policies.google.com/privacy.

9. Your rights

You may exercise the following rights free of charge at any time:

Access — confirm whether we are processing data about you and obtain a copy.

Rectification — correct inaccurate or incomplete data.

Erasure ("right to be forgotten") — request deletion of data when, among other reasons, it is no longer necessary for the purpose for which it was collected.

Objection — object to the processing of your data on grounds relating to your particular situation.

Restriction — request that we limit the processing of your data while a request is reviewed.

Portability — receive your data in a structured, commonly used, machine-readable format.

Withdrawal of consent — withdraw, at any time, the consent you have given (without affecting the lawfulness of processing carried out before the withdrawal).

To exercise these rights, please write to dpo@elcanofilms.com indicating the right you wish to exercise. We may ask you to confirm your identity. We will reply within one month, extendable by two further months if the request is complex (we will tell you if so).

10. Right to lodge a complaint

If you consider that the processing of your personal data infringes the law, you have the right to lodge a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos, AEPD): C/ Jorge Juan 6, 28001 Madrid · https://www.aepd.es. We would, however, ask you to contact us first so we can try to resolve the matter directly.

11. Automated decisions and profiling

We do not take decisions based solely on automated processing, nor do we carry out profiling that produces legal effects on you.

12. Security

We have technical and organisational measures in place to protect your data against unauthorised access, alteration, loss or disclosure, in line with article 32 GDPR.

13. Changes to this policy

We may update this policy. The applicable version is the one published at the time you access the website; we will keep the previous version's date in the change log. We recommend that you review this page periodically.