Company Name: Winning English (referred to in this text as The Provider)
Winning English, as the Data Processor for the website, in accordance with the provisions of Regulation (EU) 2016/679 of April 27, 2016 (RGPD), the Spanish Organic Law 3/2018 of December 5 (LOPDGDD) and other legal regulations in force on the protection of personal data, and by Spanish Law 34/2002, of July 11, on Services of the Information Society and Electronic Commerce (LSSICE), informs you that we have implemented the measures of necessary security, technical and organizational nature, to guarantee and protect the confidentiality, integrity and availability of all processed data.
Purpose of Personal Data Processing
Your personal data will only be used for the following purposes:
- To carry out the necessary commercial and administrative procedures with web Users
- To send valuable website related information and occasionally commercial advertising by email, social networks, or any other electronic or physical means, prior express consent by the user to receiving this form of communications electronically by subscribing to the mailing list
- To respond to queries and/or provide information requested by the User
- To carry out the provision of services and/or products contracted or subscribed to by the User
- To use your data to contact you, both electronically and non-electronically, to obtain your opinion about the service provided
Analysis of profiles and usability can be carried out.
Clients and/or suppliers’ data will be processed, within the contractual relationship that links them with The Provider, in compliance with the administrative, fiscal, accounting, and working liabilities that are necessary under the current legislation.
You can revoke your consent at any time by sending a letter with the subject “UNSUBSCRIBE” to firstname.lastname@example.org.
In accordance with LSSICE, The Provider does not send SPAM, therefore, the Provider does not send commercial emails that have not been previously requested or authorized by the User. Consequently, the User has the possibility of cancelling his or her express consent to receive our communications at any time.
We will not use your personal data for any purpose other than those described except by legal obligation or injunction.
Lawfulness of Personal Data Processing
The legal basis for data processing is your consent granted to carry out the purposes described above, which will be requested at the time by marking the corresponding box when collecting your data.
In cases where there is a prior contractual relationship between the parties, the legitimacy to carry out administrative, tax, accounting, and labour liabilities that are necessary under current legislation will be the prior existence of the business relationship established between the parties.
Assignments or Transfers Recipients
The Provider does not carry out any data transfer or communication to third parties unless there is a reasonable need to comply with a legal procedure, legal obligation, or the previous User’s consent has been obtained.
International transfers of your personal data will not be made without your prior consent, without prejudice to be able to block or cancel any account if there were indications of the commission of some crime by the User.
The information that you provide us through this website and through the application will be hosted on the servers of The Provider, contracted to the company SiteGround Spain S.L. with CIF B87194171 and fiscal address located on Calle de Prim 19, 28004 Madrid, España. The data processing by this company is regulated by a contract regarding the processing signed between the Provider and this company. Under no circumstances will this data processor outsource services that assume a data processing by third parties without our prior consent.
Any communication sent will be incorporated into the information systems of The Provider. By accepting these conditions, terms and policies, the User expressly consents to The Provider carrying out the following activities and/or actions, unless the User indicates otherwise:
- The sending of commercial and/or promotional communications by any means enabled, informing Users of the activities, services, promotions, advertising, news, offers, and other information about the services and products related to the activity.
- In the event that the User has expressly consented to the sending of commercial communications electronically by subscribing the mailing list, The Provider may then send the User electronic communications in which will inform the User of the activities, promotions, advertising, news, offers, and about services and products of The Provider equal or similar to those that were initially the aim of the contract or interest by the User.
- The preservation of personal data during the time limits provided for in the applicable provisions
Data Subject Rights
As a User, you can request The Provider for exercising the following rights by submitting a letter to the postal address located in the letterhead or by sending an email to email@example.com with the subject: “Data Protection – DATA SUBJECT RIGHTS”.
- Right of access: The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data.
- Right to rectification: The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
- Right to erasure: The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay if the data are inadequate or excessive.
- Right to object: The data subject shall have the right to obtain from the controller not carry out the processing of their personal data or to cease it in some circumstances.
- Right to restriction of processing: The data subject shall have the right to obtain from the controller restriction of processing. It involves the marking of personal data, with the purpose of limiting its future processing.
- Right to data portability: The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided,
- Right not to be subject to automated individual decision-making (including profiling): The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her
- As a User, you have the right to withdraw the consent given at any time. The withdrawal of consent will not affect the lawfulness of the process carried out before the withdrawal of consent.
You also have the right to submit a claim to the supervisory authority if you believe that your rights may have been violated in relation to the protection of your personal data (agpd.es).
Storing Your Personal Data
Your data will be retained for the duration of the business relationship with us or until you exercise your rights to erasure, object or restriction of processing. However, we will retain certain personal and traffic data for a maximum period of 2 years if it was required by the Courts or Tribunals or to initiate internal actions derived from the misuse of the website.
You will not be the subject of decisions based on automated processing that produce effects on your data.
Official Communication Systems
The User is informed that the systems enabled by the company to communicate with customers and others affected are the corporate phone, corporate mobile phones and corporate email.
If you send personal information through a communication system different from those indicated in this section, the Provider shall be exempt from liability in connection with the security measures available to the system in question.
Information we Collect:
The data collected by the Provider are the following:
- Those that Users provide through the different services offered on the website
- Those included in the different forms provided on the website
- Data collected through “cookies” for browsing experience improvement as reported in the Cookies Policy.
The refusal to supply the obligatory data will result in the impossibility to respond the particular request in question. You say that the information and data you provide us are accurate, current and truthful. We ask you to notify us in case of modification, so that the information is up to date and do not contain errors.
If you contract the service through our website winningenglish.net we may ask you to provide us some personal data.
We inform you that The Provider has a presence on social networks. The processing of data that is carried out concerning the people who become followers on social networks (and/or carry out any link or connection action through social networks) of the official pages of The Provider will be regulated by this section, as well as those conditions of use, privacy policies, and access regulations of the social network in each case and previously accepted by the User.
The Provider will process your data in order to properly manage its presence on social networks, informing you of the provider’s activities, products or services, as well as any other purpose that the regulations of the social networks allow.
The publication of the following content is prohibited:
- Content that are allegedly illicit according to national, community or international regulations or that carry out activities that are allegedly illicit or contravene the principles of good faith.
- Content that threaten the fundamental rights of people, lack of courtesy on the network, disturb or may generate negative opinions in our Users or third parties and in general, any content that The Provider deems inappropriate.
- Content that contravene the principles of legality, honesty, responsibility, protection of human dignity, protection of minors, protection of public order, protection of privacy, consumer protection, and intellectual and industrial property rights.
Likewise, The Provider reserves the right to remove without notice, from the website or the corporate social network, those contents deemed inappropriate.
Communications sent through social networks will be incorporated into a file owned by The Provider, and the Provider may send you information of interest.
In any case, if you send personal information through a social network, The Provider will be exempt from liability in relation to the security measures applicable to this platform. It is the responsibility of the User to know these security measures, by checking the user conditions of that network.
The information you provide will be processed confidentially. The Provider has adopted all the technical and organizational measures and all the levels of protection necessary to guarantee the security in the processing of the data and to avoid its alteration, loss, theft, processing or unauthorized access, according to the state of technology and nature of the processed data. Likewise, it is also guaranteed that the processing and registration in files, programs, systems or equipment, premises and centres comply with the requirements and conditions of integrity and security established in the current regulations.
The Provider reserves the right to modify this Policy to adapt it to new legislation or jurisprudence dispositions (case law).
For all purposes, the relationship between The Provider and the Users of this web or application is subject to the Spanish legislation and jurisdiction to which the parties expressly submit, being competent for the resolution of all conflicts arising or related the Courts and Tribunals of Barcelona.