For the purposes of the provisions of current legislation on the Protection of Personal Data 1 and in accordance with the provisions of the Legal Basis of the Santalucía Impulsa Programme for startups (“Programme”), as a Participant in the same, Santalucía offers you the following information on how we treat your personal data with regard to your involvement in the Programme.

1. Who is responsible for processing your personal data?

The person responsible for the processing of the personal data of the participants in the Program is SANTA LUCÍA, S.A., Insurance and Reinsurance Company, with address in Madrid, Plaza de España No. 15, C.P. 28008, and with N.I.F. No. A-28039790 (hereinafter, “Santalucía”) Santalucía has formally appointed a Personal Data Protection Delegate and also has enabled the following communication channel

Likewise, you are informed that when you register for the Program, as you were informed when you sent your data in the registration form, your personal data will also be part of the databases of INNSOMNIA ACCELERATOR, S.L. (from now on, “Innsomnia”), an entity collaborating with Santalucia in the management and development of the Programme. Innsomnia, on the other hand, will provide you with the corresponding information in compliance with the current regulations on Personal Data Protection.


1 That is, Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (RGPD) and Organic Law 3/2018 of 5 December on the protection of personal data and the guarantee of digital rights (LOPDGDD).

2. How do we obtain your personal data?

We must distinguish between the sources from which your data come and the type of personal data processed by Santalucia:

a) Sources from which the personal data originate.

Contributed by you when you registered through the form available on the Programme’s web platform, or the Innsomnia web platform, as the Programme’s manager, through the link, in which case your data were transferred to us by the latter.
Contributed by you later during the development of the Programme.

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b) Types of personal data.

Data of other participants that are part of your participation. In this respect, the Participant declares that he or she has obtained the consent of and informed the persons whose data were provided to Santalucia for their necessary participation in the Programme.
Identification data: name and surname, telephone and physical address and e-mail and image.

3. For what purpose do we process your personal data and what is the legitimation?

We will treat your personal data for the correct development, management and achievement of the Program in which you have voluntarily enrolled. Therefore, such treatment is legitimised in the necessary execution of the Programme of which you are a part.

This may mean that Santalucía needs to carry out the appropriate checks on the veracity of the data and information provided, based on your legitimate interest and/or compliance with legal obligations.

Finally, for the purpose of promoting the Programme, as well as the Participants, we may use your image as informed in the following Base.


4. To which recipients will your personal data be communicated?

No transfer of your data is foreseen, except when a legal obligation or requirement indispensable for the correct achievement of the Program requires its communication. Various suppliers, with whom Santalucía has signed the corresponding contracts for processing, will have access to the same data.

5. How long do we keep your data?

The personal data will be kept for the duration of the Programme and, subsequently, will be kept for the legal periods of time that apply in each specific case, taking into account the type of data, as well as the purpose of the processing, and will be subsequently deleted.

In relation to the processing of the image whose rights have been transferred to Santalucia, we would like to inform you that, although the transfer of the image obtained in these cases is not subject to any time limit, nor is it restricted to the national scope of any country, so that the media through which it has already been used during your relationship with Santalucia and the Programme may continue to be used, you are informed that you may exercise your rights at any time within the limits set out above. On the other hand, the image, understood as personal data, will be maintained for as long as your relationship with Santalucia is in force as a result of the Project, and will be kept for the legal periods of time that may apply, and will subsequently be deleted.

You can request more information about Santalucia’s data conservation periods at:

6. What are your rights in relation to the processing of your data by us?

Santalucia informs you that you have the right to access your personal data and obtain information about how it is being processed.

Likewise, you have the right to request the rectification of inaccurate data or, where appropriate, to request their deletion when, among other reasons, the data is no longer necessary for the purposes for which they were collected by Santalucía.

Under certain circumstances, you may request the limitation of the processing of your data, in which case Santalucia will only keep them for the exercise or defence of any possible claims.

Likewise, under certain circumstances, you may oppose the processing of your personal data for the purpose informed by Santalucia, without this affecting the lawfulness of the processing based on prior consent. In this case, Santalucia will cease to process the personal data, unless there are legitimate reasons, or to guarantee the exercise or defence of any possible claims.

Finally, you may request the right to portability and obtain for yourself or for another service provider certain information derived from the contractual relationship formalized with the Entity.

You may exercise such rights by writing to SANTA LUCÍA, S.A., Compañía de Seguros y Reaseguros at the postal address Plaza de España, 15, 28008 Madrid, or at the e-mail address

In both cases, it is required to prove the identity of the person exercising his rights, by sending a copy of his DNI, NIE, passport or equivalent document, on both sides.

Santalucia will provide you with the requested information within a maximum period of one month from the receipt of the request. This period may be extended by two months if necessary, taking into account the complexity and number of applications.

You may withdraw your consent at any time, in the event that consent has been granted for a specific purpose, without this affecting the lawfulness of the processing based on the consent prior to its withdrawal.

You may lodge a complaint with the competent data protection supervisory authority. However, in the first instance, you may lodge a complaint with the Data Protection Officer, who will resolve the complaint within a maximum period of two months.

Confidentiality obligations

The Participants and Santalucia agree to keep secret and confidential all personal data and information of a confidential nature that may arise during the development of the Project (know-how, finances, security of access to facilities, personal data or any other aspect related to the Project, Santalucia and/or the Participants), which may become known as a result of their relationship with it. This obligation will continue even after the end of their participation.

By registering, the Participant confirms that he or she has read and understood the information on data protection provided by Santalucia, as well as stating that he or she has obtained the consent of and informed the persons whose data were provided to Santalucia for their necessary participation in the Programme.

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