Privacy Policy
Last updated: 10 September 2025
This Policy explains how the Associação Cultural Públia Hortênsia de Castro de Elvas (ACPHCE) processes your personal data on acphcelvas.com and within the International Music Composition Competition of Elvas (CICME).
Data controller
Associação Cultural Públia Hortênsia de Castro de Elvas (ACPHCE), Elvas, Portugal.
Email: cicme@acphcelvas.com / aculturalphcelvas@gmail.com
Data we collect
- Form data (CF7): name, email, phone/mobile, nationality, place and date of birth, ID number, guardian details (if applicable), participant category, work titles and files (PDF/MIDI, authorisations, payment receipts).
- Technical data: IP address, user agent, pages visited (server logs).
- Anti-spam: reCAPTCHA may collect technical information. See Google Privacy Policy.
- Payments: if you use PayPal, some data are processed by PayPal. See PayPal Privacy Policy.
Purposes and legal bases
- Managing CICME applications (pre-contractual steps/contract performance).
- Competition communications (contract performance/legitimate interests).
- Legal compliance (tax/accounting archiving).
- Security and anti-fraud/spam (legitimate interests; reCAPTCHA).
Minors
Applications from 16–17 year-olds require a guardian’s authorisation. We do not process minors’ data without such authorisation.
Sharing and processors
We may share data with providers supporting the website and the competition (hosting, email, CF7, anti-spam, payments). They act as processors under contract and our instructions; PayPal and Google may act as independent controllers.
International transfers
reCAPTCHA (Google) and PayPal may involve transfers outside the EEA with appropriate safeguards (Standard Contractual Clauses).
Retention
- Application records: until the end of the edition and archived for up to 24 months.
- Accounting/payment records: for the legally required period (up to 10 years).
- Technical logs: short security periods (typically 90 days).
Your rights
Access, rectification, erasure, restriction, portability, objection, and withdrawal of consent where applicable. To exercise these rights, contact cicme@acphcelvas.com. You may also lodge a complaint with your local supervisory authority (in Portugal, the CNPD).
Cookies
We use technical and security cookies (e.g., reCAPTCHA). You can manage cookies in your browser. If we implement additional cookies (analytics, etc.), we will update this page.
Security
We apply appropriate technical and organisational measures to protect data.
Changes
We may update this Policy; please check the “Last updated” date.