PRIVACY POLICY
In accordance with the provisions of Regulation (EU) 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, the GDPR), and Organic Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights (hereinafter, LOPDGD), I hereby inform you about the processing of personal data that you provide through this website:
Who is responsible for the processing of your personal data?
Data controller: Andrea Polverini
Postal address: Calle Bañeres, 5 - 2 D, 03203 Elche (Alicante - Spain)
Telephone: 627 313 653
E-mail: andreapolverini@youritalianlanguagecoach.com
For what purpose will I process your personal data?
I will process your data for different purposes depending on the reason for which you have provided it to me:
As a user of the website (contact form/email sent to the email addresses that appear on the page): your data will be used to respond to requests for information or queries that you send me via the WRITE me section or the email addresses that appear on the website, to maintain relations and communication with you.
Blog: in order to comment on the articles in my blog, the user must provide the data requested as it is necessary for the management of the blog. Your e-mail address will not be published. The name and comment provided will be used to publish them on the blog and interact with the user.
I may also publish articles on the blog about customers who have authorised it, including pictures of them and links to my YouTube channel if I have published videos of such customers.
Testimonials: I will publish on the website the name and opinion about my services of people who have authorised it.
Booking Neurolanguage Coaching and Life Coaching sessions: the data you provide me during the booking process will be used to manage the session/lesson, including billing, payment and operations relating to its execution.
Recording of videos: in some cases and provided that the student has authorised it, I will record the coaching sessions and language lessons that I have given by video conference and subsequently publish them on YouTube, including a link to this publication on my blog. Likewise, I can publish videos of clients who have given me their permission on my YouTube channel.
As a follower on RRSS: the data you have provided to the social network will be used to interact with you and keep track of our accounts. Communication will always take place within the chosen social network, in accordance with its terms and conditions and for as long as you remain my follower.
How long will I keep your personal data?
I will keep the data you have provided me to book my services for the duration of the contractual relationship and thereafter for the applicable periods of law and for as long as necessary to fulfil the purpose for which it was collected and to determine any liabilities that may arise from that purpose and from the processing of the data.
Contact details you provide to communicate with me will be retained for as long as necessary to maintain such communication within the established relationship.
When you comment on the blog or authorise me to publish articles about you on the blog, as well as when you authorise the publication of testimonials on the website, the recording of coaching sessions or language lessons and their publication on YouTube or the publication on YouTube of videos in which you participate, the data will be processed indefinitely until you revoke your consent or request deletion of the data.
In the case of social media, your data will be retained for as long as you are my follower.
What is the legitimacy of the processing of your personal data?
When you have provided me with your data in order to book my services, the legal basis for the processing is the performance of the contractual or pre-contractual relationship (GDPR, Art. 6.1.b), as well as compliance with the legal obligations applicable to the data controller in tax matters (GDPR, Art. 6.1.c). The disclosure of your data in this case is necessary in order to formalise the contract and fulfil legal obligations.
Contact data provided by you when you contact me to establish relationships of any kind will be processed on the basis of the legitimate interest in maintaining such relationships and communications (GDPR, Art. 6.1.f).
In the case of data that you voluntarily provide for the purpose of commenting on the blog or publishing articles about you, publishing testimonials about my services, recording lectures and publishing them on my YouTube channel, the publication on YouTube of videos in which you participate or as a follower of social networks, the processing is based on your consent (GDPR, Art. 6.1.a).
To which recipients will I disclose your data?
As a general rule, I will not disclose your personal data to third parties, unless I am legally obliged to do so. This is the case, for instance, with the disclosure to the tax authorities of customer data resulting from the invoicing of my services.
On the other hand, the data of people who comment on the blog, or who authorise the publication on the blog of articles about them, or the publication on the site of testimonials about my services, or the recording of language lessons and their publication on my YouTube channel, or the publication on YouTube of videos in which you participate, will be accessible to Internet users.
Your data may also be accessed by various service providers used by me, provided that they need it for the proper provision of the services and solely for that purpose, such as the website hosting provider, the provider of lesson planning/booking software, the platform for conducting video conferencing lessons, the provider of email, cloud storage and office applications, the provider of an invoicing and accounting/tax advice application.
Finally, when I publish videos or record language lessons on YouTube, I will communicate the data of the persons participating in the lessons to the Internet platform provider for uploading and viewing the videos.
INTERNATIONAL DATA TRANSFERS
Some of the services mentioned in the previous section are provided by providers whose data processing facilities are located in third countries outside the European Union, and therefore their use involves the international transfer of personal data being processed. These are the following services:
Email provider, cloud storage service and suite of office applications included in Google Suite: Google LLC (USA)/Google Ireland Limited.
Provider of the video conferencing platform: Google Meet (USA), Wix.com (Israel).
Provider of the billing application: Wix.com (Israel).
All the companies listed above have adopted standard data protection contractual clauses, approved by the European Commission, as an adequate safeguard under the GDPR to allow international data transfers.
When using a video conferencing platform other than Jitsi Meet at your request, we will endeavour to use a platform from another provider that has adopted one of the legal instruments or mechanisms under the GDPR to ensure the lawfulness of the international transfer of derived data when using facilities located in third countries.
The publication of lessons and video recordings on YouTube involves the international transfer of the personal data in question to Google LLC (United States), based on the explicit consent of the data subjects.
What rights do you have when providing me with your personal data?
In the cases and under the conditions provided for by the applicable data protection legislation, you may exercise the following rights in relation to your personal data:
Right of access: to obtain confirmation as to whether or not I am processing your personal data and to receive this information in writing.
Right of rectification: to request rectification of your personal data if it is inaccurate or incomplete.
Right to erasure: to request the erasure of your personal data when, among other reasons, the data are no longer necessary for the purposes for which they were collected.
Right to restriction of processing: to request, under certain circumstances, the restriction of the processing of your personal data, in which case they will only be retained for the purposes of making, exercising or defending claims, protecting the rights of third parties or for reasons of public interest of the European Union or an EU Member State.
Right to object: to request, under certain circumstances and for reasons related to your particular situation, to object to the processing of your data. In this case, I will stop processing your data, except for compelling legitimate reasons or for the exercise or defence of any rights.
Right to data portability: where the processing of your data is automated and based on consent or where it is necessary for the performance of a contract or pre-contract, you have the right to receive the data you have provided to me in a structured, commonly used and machine-readable format and to request its transmission to another data controller.
Right to revoke consent: where the processing of your data is based on consent, you have the right to revoke that consent at any time, without prejudice to the lawfulness of the processing based on consent prior to its revocation.
Similarly, you have the right to lodge a complaint with the Spanish Data Protection Agency, particularly if you have not obtained satisfaction in the exercise of your rights, by writing to the following postal address: C/ Jorge Juan, 6, 28001 - Madrid, or through its electronic office (www.aepd.es).