Privacy Policy

This Privacy Policy describes the processing of your personal data carried out by Re[Framed] – owned by Marta Alegre Vicente (hereinafter, “RE[FRAMED]”), through the Internet portal: www.reframedmusicproject.com (hereinafter, the «Site»).

You must be of legal age to use the services offered through this Site. If we detect that you are under 18, we may block and/or delete the personal data that you may have provided to us. However, there may be a specific case, especially during a promotional action, where the personal data of minors is processed, in which case the consent and authorization of the parents or guardians will be requested if the minor is not yet 14 years old.

If you are a minor and are not sure you understand something we explain, ask your parents or guardians for help. Regarding the use of social networks, we recommend that parents or guardians regularly check and supervise their children’s internet activity. Please make sure that your children do not provide us with personal data without asking for your authorization and consent. In any case, the parents or guardians of the minor may contact marta@reframed.com to block and/or delete the minor’s personal data, through the means indicated in the section “YOUR RIGHTS” of this Privacy Policy.

WHO IS THE DATA CONTROLLER?

Identity: RE[FRAMED] Marta Alegre Vicente
ID: 72313511Q
Address: Diagonal 100 1-5, 08019 BARCELONA.
Email: marta@reframed.com

WHAT PERSONAL DATA DO WE PROCESS?

Personal data that you provide to us. Generally, the personal information that you provide to us (through the Site forms or, where applicable, if you contact our customer service), is: full name, address, DNI, date of birth, email, and contact phone number. In very specific cases, and depending on the purpose and intended use of your data, personal characteristics, academic and professional data, employment details, commercial information, social, economic, and insurance circumstances, transfers of goods and services may be collected. In this same sense, the personal data indicated above are mandatory to attend to your requests, such that the refusal to supply them will make it impossible to attend to them and, where applicable, carry out the provision of the requested services. In the event that you provide third-party data, you state that you have their consent and you agree to transfer the information contained in this clause to them, exempting RE[FRAMED] from any responsibility. In any case, RE[FRAMED] may carry out periodic checks to verify this fact, adopting the corresponding due diligence measures in accordance with the applicable regulations.

Personal data that we collect: The Site uses cookies (and/or similar technologies) so that, depending on their configuration, RE[FRAMED] may collect and process personal data. Generally, we collect and store limited personal information and anonymous global statistics from all users who visit our websites, either because you actively provide us with said information or you are simply browsing our websites. The information we collect includes the Internet Protocol (IP) address of the device you are using, the browsing program you use, its operating system, the date and time of access, the Internet address of the website from which you accessed our websites, and also information on how you use our websites. For more information on the use and configuration of cookies (and/or similar technologies), please consult our Cookies Policy.

FOR WHAT PURPOSES?

RE[FRAMED] will process your personal data for the following purposes:

  • In the event that you request information through the forms provided for this purpose or contact us, to process and attend to your request, as well as to provide you with the best possible service.
  • Management of personnel selection processes, including requesting work references or companies where you have provided your services and, where applicable, to carry out your employment contract.
  • To send newsletters and commercial communications, as well as any type of notification by any means (postal, email, or telephone) to inform you of our offers, promotions, products, and services related to the music industry.
  • To report job vacancies in our organization.
  • Depending on your cookie usage settings, to perform statistical analysis and create profiles based on your browsing habits, conduct surveys, statistics, and market trend analysis.

LEGAL BASIS (LEGITIMATION)

The legal bases for processing your personal data according to the purposes described above are the following:

  • In the event that you request information through the “Contact Form”: the execution of the contractual relationship with you, or the adoption of pre-contractual measures if you are not yet a client or user.
  • For the management of personnel selection processes, the adoption of pre-contractual measures with you.
  • Where applicable, your consent to send you newsletters and commercial communications, as well as any type of notification by any means (postal, email or telephone) to inform you of our offers, promotions, products and services related to.
  • Where applicable, your consent to perform statistical analysis and create profiles based on your browsing habits.

Consent will be the free, specific, informed, and unequivocal expression of will. You have the right to revoke the consent given, without retroactive effect, at any time. RE[FRAMED] will adopt the necessary actions to ensure that the personal data it collects, stores, and processes from interested parties are treated in a lawful, fair, and transparent manner, complying with the obligations resulting from the applicable legal system due to its activity.

WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

In general, RE[FRAMED] will not communicate your personal data to third parties, except in the following cases:

  • Competent authorities and bodies, courts, tribunals, or any other third parties legitimized in accordance with applicable regulations.

However, RE[FRAMED] has contracted the provision of certain services (e.g., virtual infrastructure services, cloud computing, customer relationship management, organization of games and contests, management of loyalty programs, sen3ding emails for marketing purposes, etc.) to suppliers, who may have access to and/or process personal data as data processors. Some of these suppliers may process and store personal information on servers located outside your country of residence. Therefore, depending on the user’s location, data transfers to other countries may occur.

In such a case, your personal data may be transferred internationally to third parties located outside the European Economic Area («EEA»), provided that RE[FRAMED] has the authority to do so and subject to compliance with the adequate safeguards established in Articles 44 to 50 of the GDPR. Said third parties will only access the data to carry out their services on behalf of and for the account of RE[FRAMED], under an obligation of confidentiality and always following its instructions and without being able to use said data for their own purposes and/or unauthorized purposes at any time.

In any case, the adequate safeguards include, among others:

  • Adequacy Decision: declaration by the European Commission that a non-EU State offers an adequate level of data protection equivalent to that provided by European data protection legislation, making international data transfer possible to a third party established in that State outside the EU.
  • Binding Corporate Rules (BCR): apply to business groups or the union of companies dedicated to a joint economic activity, which allows the flow of personal data based on self-regulation accepted and assumed by each of the signing entities.
  • Standard Contractual Clauses (SCC): this is a mechanism signed between the exporter of the Personal Data from any of the EEA countries and a third country. It is a contractual agreement whose model has been approved and published by the European Commission and aligned with the precepts of the GDPR.
  • Code of conduct or a certification mechanism, together with binding and enforceable commitments assumed by the recipient in relation to the application of adequate guarantees for the protection of the transferred data.

In the absence of the above, your personal data may be exceptionally transferred to a third country or international organization, in application of the mechanisms that the data protection legislation may recognize in this regard.

RE[FRAMED], in order of preference, will carry out international transfers under the following guarantees:

Guarantee

Criterion used by RE[FRAMED]

Adequacy Decision issued by the EC

Measure included as preferential by RE[FRAMED]. You can find the list of countries subject to an adequacy decision at: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en

Binding Corporate Rules

In the absence of an Adequacy Decision, it will be the preferred guarantee measure that RE[FRAMED] will request from the importer of personal data. The list of entities that have BCR can be found here: https://edpb.europa.eu/our-work-tools/accountability-tools/bcr_en?page=1

Standard Contractual Clauses

As a secondary guarantee mechanism in the absence of the above, we will proceed to subscribe to and/or request a copy as appropriate from the importer of the personal data of the signed version of the Standard Contractual Clauses aligned with the models of the European Commission, available here: https://eur-lex.europa.eu/legal-content/ES/ALL/?uri=CELEX%3A32021D0914

HOW LONG DO WE RETAIN YOUR DATA?

RE[FRAMED] will retain your personal data to attend to and/or carry out the requested services (provided that its deletion or opposition is not requested through the means indicated in the section “YOUR RIGHTS”) and will maintain it during the necessary statutory limitation periods depending on the legislation that, in each case, is applicable to address future liabilities. After the legal limitation periods have expired, your personal data will be destroyed. However, for each of the processing activities, in the information that we will provide you at the time of collecting your personal data, we will inform you of the processing period of your respective personal data for said processing. Likewise, we inform you that we will take all reasonable measures to ensure that your data is rectified or deleted when it is inaccurate.

YOUR RIGHTS

At any time, you can exercise a series of rights regarding the processing of your Personal Data. These rights are inherent to each Interested Party and, therefore, are non-waivable and are the following:

  • Right of Access: Right to access the personal data that is processed by the Data Controller in accordance with article 15 GDPR.
  • Right of Rectification: Right to request the Data Controller to rectify certain personal data of the Interested Party in accordance with article 16 GDPR.
  • Right of Opposition: Right to object to those processing activities that are based on consent or the existence of a legitimate interest (including, but not limited to, the sending of commercial communications) in accordance with article 21.2 GDPR. In those cases where the processing is based on the existence of a legitimate interest, the Interested Party will have the right to request the balancing report carried out by the Data Controller. Furthermore, in cases where the purpose of the processing is the sending of commercial information from the controller or third parties, the Interested Party may freely and voluntarily adhere to an advertising exclusion mechanism (you can find more information here https://www.listarobinson.es/).
  • Right of Deletion (Suppression): Right to request the Data Controller that all or part of the Interested Party’s Personal Data be deleted in accordance with article 17 GDPR. Remember that while the commercial and/or contractual relationship we maintain with you remains in force, there is a series of Personal Data that we need to process to comply with the contract, so as long as it lasts we will not be able to delete, block, or cancel them, because otherwise it would prevent us from complying with the contract.
  • Right to Restriction of Processing: Right to obtain from the Data Controller the limitation of the Processing of your Personal Data as long as one of the conditions indicated in article 18 GDPR is met.
  • Right to Data Portability: Right to receive the data that you have provided to the Data Controller in a structured, commonly used, and machine-readable format, and to transmit them to another data controller (or to have them transmitted directly to the new data controller, when technically possible), in accordance with article 20 GDPR.
  • Right to Withdraw Consent: given for the performance of the processing activities identified in the section Processing based on the Interested Party’s consent, without said revocation having retroactive effects, in accordance with article 7.3 GDPR.
  • Right not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects or significantly affects you. The Data Controller informs the Interested Party that, without prejudice to the fact that it carries out decisions based on automated systems, these decisions (i) either do not produce legal effects or significant effects on the Interested Party; (ii) or are not adopted exclusively in an automated manner.

We will attend to your request as soon as possible and, in any case, within the established legal terms. Likewise, you can withdraw your consent at any time through the email address: marta@reframed.com, without, in any case, the withdrawal conditioning ensuring correct management of the commercial relationship. In the possible event that we breach our data protection obligations; you have the right to present a complaint to the Spanish Data Protection Agency (www.aepd.es). Finally, we remind you that in the event that you provide us with data relating to another natural person, you must, prior to its inclusion, inform them of the points contained in this Policy.

LINKS

This Site may include, display, or deploy links to other websites for your greater convenience and information. These websites may operate independently of us. It is possible that these linked pages have their own privacy policies, which we strongly recommend you read when you visit them. To the extent that any linked website you visit is not owned by us or is not under our control, we are not responsible for the content of such websites, their use, or their privacy practices.

UPDATE

This Policy may be updated periodically to reflect changes in our personal data processing. We will post a prominent notice on the Site to notify you of any significant changes to our Policy and will indicate at the bottom of the Policy when it was last updated.

Last update: November, 2025.
© 2025- RE[FRAMED] – Total or partial reproduction prohibited. All rights reserved.