PRIVACY POLICY
https://kaleidoschoolofspanish.com/
I. PRIVACY AND DATA PROTECTION POLICY
In compliance with current legislation, Kaleido School of Spanish (hereinafter also referred to as the Website) undertakes to adopt the necessary technical and organizational measures, in accordance with the appropriate level of security for the risk of the data collected.
Laws incorporated into this privacy policy
This privacy policy is adapted to the current Spanish and European regulations regarding the protection of personal data on the internet. Specifically, it complies with the following regulations:
- Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR).
- Organic Law 3/2018 of December 5, on the Protection of Personal Data and guarantee of digital rights (LOPD-GDD).
- Royal Decree 1720/2007 of December 21, approving the Regulation implementing Organic Law 15/1999 of December 13, on the Protection of Personal Data (RDLOPD).
- Law 34/2002 of July 11, on Information Society Services and Electronic Commerce (LSSI-CE).
Identity of the data controller responsible for processing personal data
The data controller responsible for processing the personal data collected on Kaleido School of Spanish is: Emilio Ceruti, with Tax Identification Number (NIF): Y3886456E (hereinafter, Data Controller). His contact details are as follows:
Address: 28012 – Madrid
Contact telephone: 644 88 00 07
Contact email: info@kaleidoschoolofspanish.com
Record of Personal Data
In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by Kaleido School of Spanish through the forms provided on its pages will be incorporated into and processed in our file in order to facilitate, expedite, and fulfill the commitments established between Kaleido School of Spanish and the User, or to maintain the relationship established in the forms filled out by the User, or to respond to a request or inquiry made by the User. Likewise, in accordance with the provisions of the GDPR and the LOPD-GDD, unless the exception provided for in Article 30.5 of the GDPR applies, a record of processing activities is maintained which specifies, according to its purposes, the processing activities carried out and the other circumstances established in the GDPR.
Principles applicable to the processing of personal data
The processing of the User’s personal data shall be subject to the following principles set out in Article 5 of the GDPR and in Article 4 and subsequent articles of Organic Law 3/2018 of December 5, on the Protection of Personal Data and guarantee of digital rights:
- Principle of lawfulness, fairness, and transparency: the User’s consent will always be required after being provided with completely transparent information regarding the purposes for which personal data are collected.
- Principle of purpose limitation: personal data will be collected for specific, explicit, and legitimate purposes.
- Principle of data minimization: the personal data collected will be only those strictly necessary in relation to the purposes for which they are processed.
- Principle of accuracy: personal data must be accurate and always kept up to date.
- Principle of storage limitation: personal data will be kept only in a form that permits the identification of the User for as long as is necessary for the purposes of their processing.
- Principle of integrity and confidentiality: personal data will be processed in a way that ensures their security and confidentiality.
- Principle of proactive responsibility: the Data Controller shall be responsible for ensuring compliance with the aforementioned principles.
Categories of personal data
The categories of data processed at Kaleido School of Spanish are solely identifying data. Under no circumstances are special categories of personal data processed within the meaning of Article 9 of the GDPR.
Legal basis for the processing of personal data
The legal basis for the processing of personal data is consent. Kaleido School of Spanish undertakes to obtain the User’s express and verifiable consent for the processing of their personal data for one or more specific purposes.
The User shall have the right to withdraw their consent at any time. Withdrawing consent shall be as easy as giving it. As a general rule, the withdrawal of consent will not condition the use of the Website.
On occasions when the User must or may provide their data through forms to make inquiries, request information, or for reasons related to the content of the Website, they will be informed if the completion of any of these is mandatory, as such data are essential for the proper execution of the operation carried out.
Purposes of the processing for which personal data are intended
Personal data are collected and managed by Kaleido School of Spanish for the purpose of facilitating, expediting, and fulfilling the commitments established between the Website and the User, or for maintaining the relationship established in the forms completed by the latter, or to respond to a request or inquiry.
Likewise, the data may be used for commercial purposes of personalization, operations, and statistics, as well as activities related to the corporate purpose of Kaleido School of Spanish, including data extraction, storage, and marketing studies to adapt the Content offered to the User, as well as to improve the quality, functionality, and browsing of the Website.
At the time the personal data are obtained, the User will be informed about the specific purpose(s) for which the personal data will be processed; that is, the use(s) that will be made of the information collected.
Retention periods of personal data
Personal data will only be retained for the minimum time necessary for the purposes of their processing and, in any case, only for the following period: for as long as necessary to fulfill the purpose for which they were collected and to determine possible legal liabilities, or until the User requests their deletion.
At the time the personal data are obtained, the User will be informed about the period during which the personal data will be retained or, when this is not possible, the criteria used to determine this period.
Recipients of personal data
The User’s personal data will not be shared with third parties.
In any case, at the time the personal data are obtained, the User will be informed about the recipients or the categories of recipients of the personal data.
Personal data of minors
In accordance with the provisions of Article 8 of the GDPR and Article 7 of Organic Law 3/2018 of December 5, on the Protection of Personal Data and guarantee of digital rights, only those over 14 years of age may lawfully give their consent for the processing of their personal data by Kaleido School of Spanish. In the case of a minor under 14 years of age, parental or guardian consent will be required for the processing, and it will only be considered lawful to the extent that they have authorized it.
Confidentiality and security of personal data
Kaleido School of Spanish undertakes to adopt the necessary technical and organizational measures, in accordance with the level of security appropriate to the risk of the data collected, in order to guarantee the security of personal data and to prevent the accidental or unlawful destruction, loss, or alteration of personal data transmitted, stored, or otherwise processed, as well as the unauthorized communication of or access to such data.
The Website has an SSL (Secure Socket Layer) certificate, which ensures that personal data are transmitted securely and confidentially, as the transmission of data between the server and the User, and vice versa, is fully encrypted.
However, since Kaleido School of Spanish cannot guarantee the absolute invulnerability of the internet nor the total absence of hackers or others who may fraudulently access personal data, the Data Controller undertakes to inform the User without undue delay when a personal data security breach occurs that is likely to result in a high risk to the rights and freedoms of natural persons. In accordance with Article 4 of the GDPR, a personal data security breach is understood to mean any breach of security that results in the accidental or unlawful destruction, loss, or alteration of personal data transmitted, stored, or otherwise processed, or the unauthorized communication of or access to such data.
Personal data will be treated as confidential by the Data Controller, who undertakes to inform and guarantee, through a legal or contractual obligation, that such confidentiality is respected by its employees, partners, and any person to whom the information is made accessible.
Rights arising from the processing of personal data
The User has the following rights over Kaleido School of Spanish and may therefore exercise them against the Data Controller, as recognized in the GDPR and in Organic Law 3/2018 of December 5, on the Protection of Personal Data and guarantee of digital rights:
- Right of access: This is the User’s right to obtain confirmation as to whether or not Kaleido School of Spanish is processing their personal data and, if so, to obtain information about their specific personal data and the processing carried out or being carried out by Kaleido School of Spanish, as well as, among other things, the available information about the origin of such data and the recipients of any communications made or planned with them.
- Right to rectification: This is the User’s right to have their personal data modified if it proves to be inaccurate or, taking into account the purposes of the processing, incomplete.
- Right to erasure (“the right to be forgotten”): This is the User’s right, provided that current legislation does not establish otherwise, to obtain the erasure of their personal data when they are no longer necessary for the purposes for which they were collected or processed; when the User has withdrawn their consent to the processing and there is no other legal basis; when the User objects to the processing and there is no other legitimate reason to continue; when the personal data have been processed unlawfully; when the personal data must be erased in compliance with a legal obligation; or when the personal data have been obtained as a result of a direct offer of information society services to a minor under 14 years of age. In addition to erasing the data, the Data Controller, taking into account the available technology and the cost of its application, must take reasonable steps to inform controllers who are processing the personal data of the data subject’s request for the erasure of any links to such personal data.
- Right to restriction of processing: This is the User’s right to restrict the processing of their personal data. The User has the right to obtain the restriction of processing when they contest the accuracy of their personal data; when the processing is unlawful; when the Data Controller no longer needs the personal data, but the User needs them for claims; and when the User has objected to the processing.
- Right to data portability: Where processing is carried out by automated means, the User has the right to receive from the Data Controller their personal data in a structured, commonly used, and machine-readable format, and to transmit them to another data controller. Whenever technically possible, the Data Controller shall directly transmit the data to such other controller.
- Right to object: This is the User’s right to prevent the processing of their personal data or to stop the processing thereof by Kaleido School of Spanish.
- Right not to be subject to a decision based solely on automated processing, including profiling: This is the User’s right not to be subject to an individualized decision based solely on the automated processing of their personal data, including profiling, except where otherwise provided for by current legislation.
Thus, the User may exercise their rights by sending a written communication to the Data Controller with the reference “GDPR-https://kaleidoschoolofspanish.com/”, specifying:
- User’s first name, last name, and a copy of their ID. In cases where representation is admitted, identification of the representative by the same means will also be required, as well as the document accrediting such representation. The photocopy of the ID may be replaced by any other legally valid means that proves identity.
- A request stating the specific reasons for the application or the information to which access is sought.
- Address for notification purposes.
- Date and signature of the applicant.
- Any document that substantiates the request being made.
This request and any other attached document may be sent to the following address and/or email address:
Postal address: 28012 – Madrid
Email: info@kaleidoschoolofspanish.com
Links to third-party websites
The Website may include hyperlinks or links that provide access to third-party web pages other than Kaleido School of Spanish, and which are therefore not operated by Kaleido School of Spanish. The owners of such websites will have their own data protection policies, being themselves, in each case, responsible for their own files and their own privacy practices.
Complaints before the supervisory authority
If the User considers that there is a problem or a breach of the current regulations in the way their personal data are being processed, they shall have the right to effective judicial protection and to lodge a complaint with a supervisory authority, in particular in the State where they have their habitual residence, place of work, or place of the alleged infringement. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (https://www.aepd.es/).
II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY
It is necessary that the User has read and agrees with the conditions regarding the protection of personal data contained in this Privacy Policy, as well as that they accept the processing of their personal data so that the Data Controller can proceed with it in the manner, for the periods, and for the purposes indicated. The use of the Website will imply acceptance of this Privacy Policy.
Kaleido School of Spanish reserves the right to modify its Privacy Policy, at its own discretion, or due to a legislative, jurisprudential, or doctrinal change of the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. The User is advised to consult this page periodically to stay informed of the latest changes or updates.
This Privacy Policy was updated to comply with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR), and with Organic Law 3/2018 of December 5, on the Protection of Personal Data and guarantee of digital rights.