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Privacy Policy

The following sets out the information obligations established in Article 13 of the General Data Protection Regulation in relation to the processing activities carried out by Pamplona City Council.

Through this privacy notice, we inform users — as data subjects — of the specific aspects relating to the processing of their data: the purposes of processing, contact details for exercising their rights, data retention periods, the legal basis that authorises us to process data, and any data disclosures made, among other matters.

 

GENERAL INFORMATION

DATA HANDLER

  • Identity: Pamplona City Council (Ayuntamiento de Pamplona)
  • Postal address: Plaza Consistorial 1, 31001 Pamplona (Navarre), Spain
  • Phone: 948 420 177
  • Data Protection Officer: protecciondedatos@pamplona.es

 
MINORS

Pamplona City Council does not authorise persons under the age of 14 to provide their personal data, whether by completing web forms for requesting services, contact forms, or by sending emails.

Accordingly, those who provide personal data through these means formally declare that they are over 14 years of age or, failing that, that they have the relevant authorisation from their parent(s) and/or legal guardian(s).

 
IMAGES ON THE WEBSITE

Pamplona City Council, through its website, provides information about events and activities involving public participation. On some occasions, the information provided is accompanied by photographs or videos in which identified or identifiable persons appear.

If a user recognises themselves in any of these photographs and does not wish to appear in them, we ask that they notify us at protecciondedatos@pamplona.es, attaching a copy of a document proving their identity and referencing the section of the website where the image or video appears. In the case of children under 14, the request must be made by the parent or legal guardian.

 

RIGHTS OF DATA SUBJECTS

Data protection legislation grants a number of rights to the persons whose data are processed. These rights are as follows:

  • Right of access: the right to obtain information about whether their own data are being processed, the purpose of that processing, the categories of data being processed, the recipients or categories of recipients, the retention period, and the origin of the data.
  • Right to rectification: the right to have inaccurate or incomplete personal data corrected.
  • Right to erasure: the right to have data erased in the following circumstances:
    • When the data are no longer necessary for the purpose for which they were collected.
    • When the data subject withdraws their consent.
    • When the data subject objects to the processing.
    • When the data must be erased in compliance with a legal obligation.
    • When the data have been obtained in connection with an information society service pursuant to Article 8(1) of the European Data Protection Regulation.
  • Right to object: the right to object to a particular processing activity based on the data subject’s consent.
  • Right to restriction of processing: the right to obtain restriction of processing when any of the following conditions applies:
    • When the data subject contests the accuracy of the personal data, for a period enabling the organisation to verify the accuracy of the data.
    • When the processing is unlawful and the data subject opposes erasure of the data.
    • When the organisation no longer needs the data for the purposes for which they were collected, but the data subject needs them for the establishment, exercise or defence of legal claims.
    • When the data subject has objected to processing while verification is pending as to whether the legitimate grounds of the organisation override those of the data subject.
  • Right to lodge a complaint with the competent supervisory authority.

Data subjects may exercise the rights listed above by writing to the General Registry of Pamplona City Council (C/Mayor 2, Pamplona) or through the electronic office.

Data subjects may also lodge a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos) by writing to C/ Jorge Juan, 6, 28001 Madrid, or through its electronic office at www.agpd.es.

 

PURPOSE, LEGAL BASIS AND RECIPIENTS

Pamplona City Council wishes to inform users of the purposes for which it will use the personal data collected, the legal basis on which it relies to process personal data, and whether data will be communicated to third-party organisations.

 
CONTACT FORM AND EVENT BOOKINGS

Purpose: To manage requests for information, contact and bookings for visits and activities offered through the website, as well as related communications, incidents, payments or procedures. A satisfaction survey linked to the visit or activity carried out may also be sent, in order to evaluate and improve the service provided.

Data retention period: Data will be retained for as long as necessary to fulfil the stated purpose and will be stored for as long as the organisation may be liable in connection with their processing. Pamplona City Council must also comply with the obligations set out in Foral Law 12/2007 of 4 April on Archives and Documents.

Legal basis: Performance of a contract to which the data subject is party, or in order to take steps at the request of the data subject prior to entering into a contract (Art. 6.1.b); task carried out in the public interest (Art. 6.1.e GDPR).

Recipients: Data will not be disclosed to third parties except where required by law or where disclosure is necessary for the fulfilment of the stated purpose. Provider organisations that supply services necessary for the management of the platform, bookings, communications, payments, technical support or surveys may access the data as processors or sub-processors, subject to the guarantees required by data protection legislation. In particular, The Torre Platform, S.L.U. may access the data as a data processor in order to provide the booking technology platform, following documented instructions from Pamplona City Council and without being able to use the data for its own purposes.

 

INTERNATIONAL DATA TRANSFERS

As a general rule, Pamplona City Council does not transfer personal data outside the European Economic Area. Should it be necessary to carry out such transfers in connection with the provision of a specific service, this will be communicated in the specific privacy notice for that processing activity, and appropriate safeguards will be adopted in accordance with Chapter V of the GDPR.

 

Last updated: May 2026