Privacy Policy

The present Privacy Policy has been developed taking into account the provisions established in the current regulations regarding data protection: Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter GDPR); and Spanish Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights (hereinafter LOPDGDD).

This Privacy Policy aims to inform the holders of personal data, regarding which information is being collected, about the specific aspects related to the processing of their data, including, among other things, the purposes of the processing, the contact details to exercise their rights, the retention periods of the information, and the security measures, among other things.

Data Controller

First name and surname: Elisa Winkelmann (EW Lingua)

Address: Avda. del Mediterráneo Bloque 15 - 11406 Jerez de la Frontera (Cádiz)

NIF: Y7622178S

Telephone: +34 695 62 32 84

email: info@ewlingua.com

Data processing

The personal data that may be requested will consist solely of those strictly necessary to identify and address the request made by the data subject, hereinafter referred to as the interested party. This information will be processed fairly, lawfully, and transparently in relation to the interested party. Furthermore, the personal data will be collected for specified, explicit, and legitimate purposes, and will not be processed further in a manner incompatible with those purposes.

The data collected from each interested party will be adequate, relevant, and not excessive in relation to the corresponding purposes for each case, and will be updated whenever necessary.

The data subject will be informed, prior to the collection of their data, of the general aspects regulated in this policy so that they can provide explicit, precise, and unequivocal consent for the processing of their data, if necessary and in accordance with the following aspects.

Processing of data of minors under 14 years old

When the activities relate to minors under 14 years of age, both the details of the minor and those of the individuals exercising parental authority must be collected.

In these cases, those individuals are the ones who must consent to the processing of the data of the minor, which they have voluntarily provided. To this end, various details will be requested, such as the date of birth of the minor (to verify their age) and their identifying information, as providers of consent on their behalf.

By completing the details of the minor and those of the individuals exercising parental authority in the designated forms, they expressly declare that they exercise parental authority over the minor, that the information is true, and that they consent to the processing for the purposes established in the corresponding clause.

Purposes of the processing

The explicit purposes for which each of the processing is carried out are included in the information clauses incorporated in each of the data collection methods (web forms, paper forms, contracts, posters, etc.).

However, in general, the collection and processing of data aims to:

The maintenance of the contractual relationship established between the data subject and EW Lingua.
The execution, maintenance and management of any relationships that may be maintained between EW Lingua and the Data Subject: commercial, administrative, accounting, employment, marketing, and any other service provision that may be requested from EW Lingua by the Data Subject.
Obtain the consent of the holders of parental responsibility for the child under 14 years old for the processing of their data.
Respond to requests for information and/or contact.
Facilitate registration on the website and the creation of a personal account.
Provide access to the account where the user can modify their details and view/download the invoices corresponding to the services received.
Facilitate access to E-learning (Live sessions are carried out through Microsoft Teams) and to the value-added content (videos, documents, …), through the teaching platform as well as shared/collaborative tools (One Drive, SharePoint and Whiteboard).
Carry out assessments, through Forms and One Note.
The sending of advertising and promotional information related to EW Lingua's own products, provided that the recipient has given their consent for this or there is a prior commercial/contractual relationship and it refers to the sending of commercial communications regarding products or services similar to those that were initially the subject of the contract with the client (Article 21.2 of Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce).

Under no circumstances will they be used for purposes other than those for which they were collected.

Legitimation

As a general rule, prior to the processing of personal data, EW Lingua obtains unequivocal consent from the data subject by incorporating informed consent clauses into the various information collection systems.

However, in the event that the consent of the data subject is not required, the legal basis for the processing on which EW Lingua relies is the execution of the established contractual relationship, our legitimate interest in business development, in the case of commercial promotion and prospecting, or compliance with a law that authorises or requires the processing of the data subject's data.

If you have given your consent for any of the processes we are going to carry out (such as sending information about products and services), we inform you that you can withdraw it at any time.

Addressees

As a general rule, EW Lingua will not disclose your personal data to any third party, unless the Data Subject has given his or her consent to this effect, where the disclosure is authorised by law or in the cases of entities with which we have a relationship and by virtue of processor contracts concluded with them.

International data transfers

There are no plans for international data transfers.

Conservation periods

The information collected from the data subject will be kept for as long as it is necessary to fulfil the purpose for which the personal data were collected, so that, once the purpose has been fulfilled, the data will be cancelled. Said cancellation will give rise to the blocking of the data, which will only be kept at the disposal of the Public Administrations, Judges and Courts, in order to attend to any possible liabilities arising from the processing, during the period of limitation of these, after which time the information will be destroyed.

For information purposes, the legal deadlines for the conservation of information in relation to different matters are set out below:

DOCUMENT	LIMIT	LEGAL REFERENCE
Accounting and tax documentation for commercial purposes	6 years	Art. 30 Commercial Code
Accounting and tax documentation for tax purposes	4 years	Articles 66 to 70 General Tax Law
Data for sending information on products and services	As long as the interested party does not request its deletion	Not applicable
Details of people who have contacted us	As long as the interested party does not request its deletion	Not applicable
Details of holders of parental authority over the child represented	For as long as the processing of the child's data is maintained	Organic Law 1/1982, of 5 May 1982, on the Civil Protection of the Right to Honour, Personal and Family Privacy and Personal Image. Law 1/1996 of 15 January 1996 on the Legal Protection of Minors.

Browsing Data

With regard to the navigation/ browsing data that may be processed through the website, in the event that data subject to the regulations are collected, it is recommended that you consult the Privacy Policy published on our website.

Rights of the interested parties

Any person has the right to obtain confirmation as to whether or not EW Lingua is processing personal data concerning them.

Interested parties have the right to access their personal data, as well as to request the rectification of inaccurate data or, where appropriate, to request its deletion when, among other reasons, the data is no longer necessary for the purposes for which it was collected.

In certain circumstances, data subjects may request that we restrict the processing of their data, in which case we will only retain the data for the purpose of exercising or defending claims.

In certain circumstances and for reasons related to their particular situation, data subjects may object to the processing of their data. In this case, EW Lingua will stop processing the data, except for compelling legitimate reasons, or the exercise or defence of possible claims.

Interested parties may exercise the aforementioned rights by writing to EW Lingua at the following address: Avda. del Mediterráneo Bloque 15 - 11406 Jerez de la Frontera (Cádiz), or to the e-mail address info@ewlingua.com, enclosing in all cases a photocopy of their National Identity Card or equivalent document valid in law that allows their identity to be accredited.

You also have the possibility of filing a complaint with the Spanish Data Protection Agency (aepd.es) in the event that you consider that your data is not being processed appropriately.