I. PRIVACY POLICY AND DATA PROTECTION
Respecting the provisions of current legislation, Spanish for ADHD (hereinafter, also Website) undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected.
Laws incorporated into this privacy policy
This privacy policy is adapted to current Spanish and European regulations regarding the protection of personal data on the internet. Specifically, it complies with the following rules:
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 treatment 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, which approves the Regulations for the development of Organic Law 15/1999, of December 13, on the Protection of Personal Data (RDLOPD).
Law 34/2002, of July 11, on Services of the Information Society and Electronic Commerce (LSSI-CE).
Identity of the data controller
The controller responsible for the processing of personal data collected on Spanish for ADHD is: VERONICA JIMENEZ DAVILA, with NIF: 51983923J (hereinafter, Data Controller). Her contact details are as follows:
Address: 28002 Madrid. Spain
Contact Email: vero@thespanishontheroad.com
Registration of Personal Data
In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by Spanish for ADHD through the forms on its pages will be incorporated into our files in order to facilitate, streamline, and fulfill the commitments established between Spanish for ADHD and the User, or to maintain the relationship established in the forms filled out, or to address a request or inquiry.
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 that 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 will be subject to the following principles gathered in Article 5 of the GDPR and in Article 4 and following 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 be required at all times after completely transparent information on the purposes for which the personal data are collected.
Principle of purpose limitation: personal data will be collected for specified, 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 only be kept in a way that allows the identification of the User for the time necessary for the purposes of their processing.
Principle of integrity and confidentiality: personal data will be processed in a manner that ensures their security and confidentiality.
Principle of proactive accountability: the Data Controller will be responsible for ensuring that the above principles are met.
Categories of personal data
The categories of data processed by Spanish for ADHD 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. Spanish for ADHD undertakes to obtain the express and verifiable consent of the User 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. It will be as easy to withdraw consent as it is to give it. As a general rule, the withdrawal of consent will not condition the use of the Website.
On occasions when the User must or can 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 them is mandatory because they are essential for the correct development of the operation carried out.
Purposes of the processing of personal data
Personal data are collected and managed by Spanish for ADHD with the purpose of facilitating, streamlining, and fulfilling the commitments established between the Website and the User, or maintaining the relationship established in the forms filled out by the latter, or addressing a request or inquiry.
Likewise, the data may be used for a commercial purpose of personalization, operational and statistical analysis, and activities inherent to the corporate purpose of Spanish for ADHD, as well as for data extraction, storage, and marketing studies to tailor the Content offered to the User and improve the quality, operation, and navigation of the Website.
At the time the personal data are obtained, the User will be informed about the specific purpose or purposes of the processing for which the personal data will be used.
Retention periods for 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: 18 months, 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 kept or, when that 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 without explicit consent, except under legal obligation or with essential technological providers required for the proper delivery of services (such as email marketing tools or platform hosting), always ensuring they comply with privacy regulations equivalent to European standards.
In the event that the Data Controller intends to transfer personal data to a third country or international organization, the User will be informed at the time the personal data are obtained.
Personal data of minors
Respecting the provisions of Articles 8 of the GDPR and 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 grant their consent for the processing of their personal data by Spanish for ADHD. If the user is under 14 years of age, the consent of the parents or guardians will be necessary for the processing, and it will only be considered lawful to the extent that they have authorized it.
Secrecy and security of personal data
Spanish for ADHD undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, in such a way as to guarantee the security of personal data and avoid accidental or unlawful destruction, loss, or alteration of personal data transmitted, stored, or otherwise processed, or unauthorized communication 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 is fully encrypted.
However, because Spanish for ADHD cannot guarantee the absolute impregnability of the internet or the total absence of hackers or others who fraudulently access personal data, the Data Controller undertakes to notify the User without undue delay when a breach of personal data security occurs that is likely to entail a high risk to the rights and freedoms of natural persons. Following the provisions of Article 4 of the GDPR, a personal data security breach means any breach of security resulting in the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored, or otherwise processed.
Personal data will be treated as confidential by the Data Controller, who undertakes to inform and ensure by means of a legal or contractual obligation that such confidentiality is respected by employees, associates, and anyone to whom they make the information accessible.
Rights derived from the processing of personal data
The User has over Spanish for ADHD and may, therefore, exercise the following rights recognized in the GDPR and Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights against the Data Controller:
Right of access: It is the User's right to obtain confirmation as to whether or not Spanish for ADHD is processing their personal data and, if so, to obtain information about their specific personal data and the processing carried out.
Right to rectification: It is the User's right to have their personal data modified if they turn out to be inaccurate or incomplete.
Right to erasure ("the right to be forgotten"): It 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.
Right to restriction of processing: It is the User's right to limit the processing of their personal data in the cases provided by law.
Right to data portability: In the event that the processing is carried out by automated means, the User shall have the right to receive their personal data from the Data Controller in a structured, commonly used, and machine-readable format, and to transmit them to another controller.
Right to object: It is the User's right to object to the processing of their personal data or to demand that Spanish for ADHD cease processing them.
Right not to be subject to a decision based solely on automated processing, including profiling: It is the User's right not to be subject to an individualized decision based solely on the automated processing of their personal data.
Thus, the User may exercise their rights by means of a written communication addressed to the Data Controller with the reference "GDPR-https://www.spanishforadhd.com", specifying:
First name, last name of the User, and a copy of their ID/Passport (or any other legally valid document that proves their identity).
Request with the specific reasons for the application or the information they wish to access.
Address for notification purposes.
Date and signature of the applicant.
Any document supporting the request made.
This application and any other attached documents may be sent to the following address and/or email:
Postal Address: 28002 Madrid. Spain
Email: vero@thespanishontheroad.com
Links to third-party websites
The Website may include hyperlinks or links that allow access to web pages of third parties other than Spanish for ADHD, which are therefore not operated by Spanish for ADHD. 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
In the event that the User considers that there is a problem or infringement of 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 of 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 IN THIS PRIVACY POLICY
It is necessary that the User has read and agrees with the conditions on the protection of personal data contained in this Privacy Policy, as well as accepts the processing of their personal data so that the Data Controller can proceed with it in the manner, during the periods, and for the purposes indicated. The use of the Website implies acceptance of its Privacy Policy.
Spanish for ADHD reserves the right to modify its Privacy Policy, according to its own criteria, or motivated by a legislative, jurisprudential, or doctrinal change by the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. The User is recommended to check this page periodically to be aware of the latest changes or updates.
This Privacy Policy was updated to adapt to 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 to Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights.