Last updated: May 29, 2020

1.- Responsible Entity and Description

1.1.- Responsible Entity

The entity responsible for processing data on this site is Scoolinary SL (hereinafter referred to as Scoolinary), with its address at Calle Batle Carbonell 3 casa 17, Bendinat, CP 07181, Illes Balears, Spain.

NIF: B-16671653

Email: support@scoolinary.com

1.2.- Description

Acceptance of Scoolinary’s privacy policy (hereinafter referred to as the “Privacy Policy”) is a necessary condition for using our website and providing the service (hereinafter referred to as the “Service”).

This Privacy Policy governs the collection, processing, and use of your personal and non-personal information as a user of Scoolinary, from the effective date mentioned in the header.

To process your personal data, Scoolinary complies with current local and European legislation, as well as its implementing regulations.

2.- Information Collected

The Service can be used without providing any data; however, to obtain more information, contract our services, courses, packs, and subscriptions, you will need to provide some personal data. The information (personal or non-personal) collected by the Service may vary depending on this.

The personal and non-personal information collected by the Service will be received in three ways: 1) collected automatically, 2) voluntarily provided by you, and 3) provided by third parties.

2.1.- Automatically Collected

This information will consist of:

• The information collected through cookies or similar mechanisms stored on your device, always with your consent or in accordance with other legal bases. Refer to our Cookie Policy for more information.

• The IP address from which the connection is made, the type of device used and its characteristics, the operating system version, the type of browser, the language, the date, the country, the time of the request, the URL from which you came, the URL to which you are going, or the mobile network used, among others.

• Service usage data and any errors detected during its use.

• Additionally, Scoolinary uses third-party services such as:

• Google Analytics, an analytical service provided by Google, LLC, based in the United States with its headquarters at 1600 Amphitheatre Parkway, Mountain View, California 94043. To provide these services, they use cookies that collect information, including the user’s IP address, which will be transmitted, processed, and stored by Google under the terms established on www.google.com, including the possible transmission of such information to third parties for legal reasons or when these third parties process the information on Google’s behalf.

In any case, you can disable Google Analytics cookies from here.

• MixPanel, an analytical tool owned by MixPanel Inc., based at One Front Street, 28th Floor, San Francisco, CA 94111. To provide these services, they use cookies that collect information, including the user’s IP address, which will be transmitted, processed, and stored by MixPanel under the terms established on the website https://mixpanel.com/

2.2.- Voluntarily Provided Information

This information will consist of:

• The information required by Scoolinary to create a new user account and subscribe to the platform: name, surname, email, and password.

All data are mandatory.

As additional information, the user may provide the following data to complete their profile: country, DNI or NIF number, full name or company name, address, and profile picture.

If you register on behalf of another person through the Service, you guarantee that you have legitimately obtained the personal information and consent of those other persons before providing their data to us.

Regarding the password, as a user of the Service, you will be responsible for its protection. In this sense, you will assume any damages that may arise from its misuse or disclosure to third parties.

• The information, personal or not, that may be contained in messages sent through the contact channels established in the Service, such as name, email, and message.

• The information, personal or not, that you may provide to register for free face-to-face or online workshops and activities that the platform may organize, such as name and surname, email.

• The information, personal or not, that you may provide to register for paid face-to-face or online workshops and activities that the platform may organize, such as name and surname, email, applicable coupon, and payment details.

Payment data refers to the credit card data used when contracting a service. In any case, payment will be made through the Stripe or Paypal platform, so Scoolinary does not store any of this data.

• The information, personal or not, that may be contained in comments on any of the website’s content, such as your name, email, and message.

• The information, personal or not, that may be contained in reviews and ratings of any of the courses on the website, such as your name, email, message, title, and rating.

• The information, personal or not, provided when contracting any of our packs. For example, name, surname, email, applicable coupon, and payment details.

• The information, personal or not, provided to complete a subscription. For example, name, surname, email, applicable coupon, and payment details.

• The additional personal information you must provide to receive the corresponding certification for the course completed.

• The information required by Scoolinary to register you as an affiliate: name, surname, NIF, email, address, website details, and payment information, among others.

Mandatory data will be marked with an asterisk.

• Your photograph, name, and nickname if you decide to participate in any of our social media activities or complete your profile.

• The personal information required to subscribe to the newsletter, such as your email.

2.3.- Information Provided by Third Parties

This information will consist of:

• Information provided by payment systems or credit card processors, such as the time of purchase or its amount.

3.- Rights and Purposes

We inform you that filling out the forms is voluntary. However, if you do not fill in the mandatory fields (usually marked with an asterisk), the use of some features of the Service may not be possible or may be limited.

The personal data you provide will be incorporated and processed in Scoolinary’s Treatment Activity Register to meet your requests, provide the requested service, and keep you informed about matters related to the company’s activities and services.

You can exercise your rights of access, rectification, deletion, limitation of processing, opposition, and data portability of your personal data at any time by sending an email to: support@scoolinary.com or to the postal address: Calle Batle Carbonell 3 casa 17, Bendinat, CP 07181, Illes Balears, Spain.

In both cases, you must identify yourself with your name and surname, and provide a copy of your DNI or national ID, if necessary.

If you have given consent for a specific purpose, you have the right to withdraw it at any time, without affecting the lawfulness of the processing based on the consent prior to its withdrawal.

In addition, if you believe there is a problem with how Scoolinary is handling your data, you can file a complaint with the relevant data protection authority, with the Spanish Data Protection Agency being the appropriate authority in the case of Spain.

4.- Age

Regarding the use of the online service, you declare that you are of legal age and have the necessary legal capacity to be bound by this agreement and use the site in accordance with its terms and conditions, which you fully understand and acknowledge.

You declare that all the information you provide to access the Service, before and during its use, is true, complete, and accurate.

5.- Use of Data

Scoolinary will use the data collected for the following purposes:

• To manage and update the Service (the legal basis being our legitimate interest in keeping the Service up-to-date and in good condition).

• To address your questions and comments (the legal basis being our legitimate interest in addressing our users’ requests and concerns).

• To manage your registration on the platform (the legal basis being your consent).

• To process the payments you make and issue the corresponding invoices (the legal basis being the contract).

• To manage and provide you with the free face-to-face or online workshops and activities organized by the platform (the legal basis being your consent).

• To manage and provide you with the paid face-to-face or online workshops and activities that the platform may organize (the legal basis being the contract).

• To manage and provide you with the course packs you contract (the legal basis being the contract).

• To manage and provide you with the services related to your subscription (the legal basis being the contract).

• To publish a comment on the articles in the “Blog” section or completed lessons and manage them (the legal basis being your consent).

• To publish your reviews and ratings of the courses you have completed and manage them (the legal basis being your consent).

• To verify, prepare, and issue the certification that may correspond to the completed course (the legal basis being the contract).

• If you participate in our Affiliate services, to provide the contracted service (the legal basis being the contract).

• To send you our newsletter and promotional offers related to the contracted service by email (the legal basis, depending on the case, being the contractual relationship or our legitimate interest in direct marketing actions based on the prior contractual relationship, in accordance with art. 21.2 LSSICE).

You can unsubscribe from them directly from the received email or by contacting us at support@scoolinary.com. However, you will not be able to unsubscribe from certain correspondence from us, such as messages related to the security of your data or the Service’s terms and conditions.

• To maintain the security of the Service, investigate illegal activities, enforce our terms and conditions, and assist law enforcement authorities in their investigations (the legal basis being our legitimate interest in ensuring and maintaining the security of the Service and its users).

Scoolinary does not use automated decisions, although it may generate basic user profiles, with the legal basis being our legitimate interest for commercial purposes and providing personalized offers.

Additionally, Scoolinary may use user information in the form of aggregated and anonymous data to display to third parties. It may also share statistics and demographic information about users and their use of the Service with third parties. However, none of this will allow those third parties to personally identify you.

5.1.- In Emails and Contact Forms

The Service’s website has TLS encryption that allows the user to securely send their personal data through standard contact forms.

The personal data collected will be subject to automated processing and incorporated into the corresponding files of the Treatment Activity Register owned by Scoolinary.

In this regard:

• Your IP address will be collected, which will be used to verify the origin of the message to offer you appropriate recommendations (e.g., presenting information in the correct language) and to detect possible irregularities (e.g., possible attempts of cyber-attacks on the Service), as well as data related to your ISP.

• Additionally, you can provide us with your data via phone, email, and other communication channels indicated.

Regarding the payment methods used:

• Our payment service providers for paying for our services are VISA, Mastercard, and American Express, Paypal. In cases where the card is not accepted, or you prefer to use a bank transfer or direct debit, please contact us to find out if this method is possible at support@scoolinary.com

• At no time will the Service or its staff have access to the banking data (e.g., credit card number) that you as a customer will provide to those third parties.

On the other hand, certain services provided through the website (e.g., the possibility of participating in a contest or promotional code giveaway) may contain specific conditions regarding personal data protection. Acceptance of these conditions will be necessary before participating in these services.

5.2.- On Social Media

Scoolinary has profiles on some of the main social networks, being responsible for the processing of data published on them (e.g., photos uploaded by Scoolinary in which people’s faces appear).

The processing that Scoolinary will carry out with the data within each of these networks will be, at most, the one that the social network allows for corporate profiles.

Thus, Scoolinary may inform our followers by any means allowed by the social network about their activities or offers when the law does not prohibit it.

In no case will Scoolinary extract data from social networks unless the user’s consent is specifically obtained for this purpose.

Your participation in Scoolinary’s activities and courses may involve capturing your image, which may be shared on our social networks. If you prefer not to appear, contact us through the social network or at support@scoolinary.com and we will remove the image.

5.3.- In Contests

By participating in promotional actions exclusively organized by Scoolinary, the data you provide will be processed solely by us for the purpose stated in the action’s announcement and its corresponding legal conditions.

6.- Data Retention

The following indicates how long the data processed by the Service will be retained:

• Disaggregated data will be retained indefinitely.

• Customer data, whether subscriptions, individual courses, packs, or our affiliate program, will be retained for the minimum necessary, which may be up to:

• 5 years, according to art. 1964 of the Civil Code (personal actions without a special term).

• 6 years, according to art. 30 of the Commercial Code (e.g., accounting books or invoices).

• Newsletter subscriber data will be retained from the time the user subscribes until they unsubscribe.

• User data uploaded by Scoolinary to its social networks will be retained from the time the user gives their consent until it is withdrawn.

• Blog or course comment data will be retained from the time the user publishes them until they request their removal or it is deleted for violating these terms and conditions.

7.- Data Shared with Third Parties

There are third parties that manage part of the Service.

Scoolinary requires them to comply with this Privacy Policy to the extent applicable, in addition to having their own policy. However, Scoolinary will not be responsible for their compliance with that policy.

Under certain circumstances, Scoolinary may share, use, preserve, or disclose Personal Information with third parties in a non-aggregated form:

• To provide the Service:

Service providers that perform functions on our behalf, such as payment services, web hosting, business analytics, customer service, website marketing, professionals providing the courses, the mail manager, the platform or platforms where we host the videos and podcasts, the email and CRM tool, the support/ticketing tool, and the management company that handles billing data. These service providers may collect and access the information necessary to perform their functions, but they are not allowed to share or use the information for any other purpose.

• To cooperate with competent authorities:

If we believe it is reasonably necessary to comply with any law, legal process, or legitimate interest. In any case, we will only provide the strictly required information.

8.- Security Measures

Scoolinary takes all necessary technical and organizational measures to protect the security and integrity of the personal and non-personal information collected. This includes protection against unauthorized access, alteration, loss, or accidental destruction.

In any case, Scoolinary cannot guarantee the absolute security of the information collected, so you should cooperate and use common sense at all times regarding the information shared.

You understand and acknowledge that even after deletion, personal and non-personal information may remain visible in cache or if others have copied or stored it.

9.- Changes to the Privacy Policy

We may update this Privacy Policy in the future. We will inform you of any changes by sending a notice to the provided email address and/or placing a notice in a prominent place on our website.

10.- Contact

If you have any questions about this Privacy Policy, contact us at:

Email: support@scoolinary.com

Address: Calle Batle Carbonell 3 casa 17, Bendinat, CP 07181, Illes Balears, Spain.