Privacy Policy

This privacy policy (“Privacy Policy”) has been amended on 12 December 2020.

In this Privacy Policy you will find all the information regarding the processing of your personal data and the rights you can exercise to maintain control over your personal data. You should therefore read it carefully before using this website. Please do not hesitate to contact PEIBOLEARN if you have any questions.

PRINCIPLE ISSUES REGARDING THE PROCESSING OF YOUR PERSONAL DATA

PEIBOLEARN needs to process the personal data that is requested from you during your navigation and use of the website: www.peibolearn.com (hereinafter, the “Website”), in order to:

To offer you different channels to contact us and request information.

To enter into a contract with you or take necessary steps to enter into a contract to offer you the courses and other training activities and for you to be able to manage PEIBOLEARN’s services.

To offer you, where appropriate, products and services that may be of interest to you through electronic means.

PEIBOLEARN may also use your data to help improve the development, maintenance and usability of the Website.

In any event, PEIBOLEARN will strive to keep this information secure and confidential with appropriate controls and in accordance with current regulations on personal data protection.

At any time, you can exercise your rights under the data protection regulations or ask any questions you may have about the processing of your data by contacting PEIBOLEARN by e-mail hello@peibolearn.com.

ENTIRE PRIVACY POLICY

1.WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL DATA?

Your personal data will be processed by PEIBOLEARN, Madrid, España and email: hello@peibolearn.com.

2.WHICH REQUIREMENTS MUST BE MET IN ORDER TO PROVIDE PEIBOLEARN WITH YOUR PERSONAL DATA?

2.1. Legal age. In order to provide PEIBOLEARN with your personal data, use this Website and purchase PEIBOLEARN services and programs, you must be of legal age, have sufficient legal capacity and/or, if applicable, the authorization of your legal representatives. Furthermore, in order to contract the services on behalf of a company, you must be of legal age, with full legal capacity to act and with due legal capacity to bind the company.

2.2. Accuracy. When you provide PEIBOLEARN with your data to use PEIBOLEARN services and programs, you guarantee that the data and information provided is accurate, truthful, updated and also that it belongs to you and not to third parties.

In addition, you must notify PEIBOLEARN of any change in the data provided, and you are responsible for the truthfulness and accuracy of the data provided at any time.

2.3. Verification capabilities. PEIBOLEARN is entitled to verify your age and personal information at any time, even requiring you to provide an official document or equivalent procedure of proof. If fraud is detected and/or it is proved or suspected that the User (as defined in the Terms and Conditions) is a minor, PEIBOLEARN may delete, temporarily disable and/or cancel the User’s account.

Moreover, in case you select a username or similar identifier for your account, PEIBOLEARN is entitled to delete or claim it if PEIBOLEARN considers it reasonably necessary, such as if it is obscene or offensive to the ordinary person.

3.WHICH DATA PROCESSINGS DOES PEIBOLEARN CARRY OUT THROUGH THE WEBSITE AND WHAT ARE ITS MAIN FEATURES?

Below, PEIBOLEARN explains how it processes your personal information and provides you with all relevant information regarding your privacy:

3.1 Use of the Website

a) What data does PEIBOLEARN collect?

Website usage information: When you access the Website, even if you have not registered, information is collected through cookies and/or other tracking tools. These tools are small files that are downloaded to your device and collect data about your use of the Website. Through these tools, PEIBOLEARN may collect:

Device Information: While using the Website, PEIBOLEARN collects information about the mobile device from which you access the Website. The information PEIBOLEARN collects is the device model, operating system and version, unique device identifier and network.
Location information: PEIBOLEARN also collects the IP address, time zone and mobile service provider, if any, which allows PEIBOLEARN to obtain a general location.
User navigation information: PEIBOLEARN collects information about your use of the Website. Specifically, the frequency of use, the sections you visit, use of specific functions.

b) What are the purposes of the processing of your personal data?

1. Perform statistical analysis and improvement of the Website: All the information collected through cookies and other tracking tools helps PEIBOLEARN to analyze, maintain and improve the Website, since from the analysis of the navigation that the Users make, PEIBOLEARN is able to detect errors in the Website, aspects to be improved in the design or the need to add new functions and services.

For more information, you can visit PEIBOLEARN’s Cookie Policy.

2. Prevention, detection and prosecution of activities that are illegal or contrary to the terms and conditions of the service or that endanger the security of the information or the Website. PEIBOLEARN may process the data in order to control and prevent any form of abuse of PEIBOLEARN services, such as fraudulent activities, denial of service attacks, spam, unauthorized access, as well as any other practice that is contrary to the Terms and Conditions of the Website or the business general conditions or that endangers the security of the information or the integrity of the Website itself.

3. Advertising on the Website and social networks: This Website may display advertising in the form of banners containing text, images, animations and/or videos, integrated within the content of the Website itself. Such banners would link to third party websites for advertising and / or information purposes and in no case shall be the responsibility of PEIBOLEARN. The advertising that appears in such banners may include personalized advertising, derived from the information obtained from the reading of Cookies or other tracking devices in your browser that allow the display of ads related to your recent searches and show you the most relevant ads. In addition, PEIBOLEARN uses third-party advertising services to serve ads for PEIBOLEARN services and program on other websites.

Even if you choose not to receive personalized ads based on your browser’s settings, ads may still appear based on other factors such as your general location or generics.

In addition, based on the social network tracking devices that are set up on the Website (see Cookie Policy), PEIBOLEARN may create an audience for the matching process in the relevant social networks. The data sent is encrypted in PEIBOLEARN systems before being uploaded and provided to the social network (i.e. a hidden, anonymous version of the User’s data is sent) for subsequent use and to display PEIBOLEARN advertising on your social networks. To learn more, visit: https://es.facebook.com/legal/terms/customaudience.

c) What is the basis of legitimacy that allows PEIBOLEARN to process your data? If so, is the provision of this data mandatory?

The information PEIBOLEARN collects through cookies and other tracking devices is based on your consent, which is requested when you access the Website through an informational pop-up. You may withdraw your consent at any time by following the steps outlined in its Cookie Policy.

PEIBOLEARN may use this information, based on its legitimate interest, to analyze and evaluate the use of its Website and to make improvements to it.

d) How long does PEIBOLEARN keep your information?

The period of time for which the information collected through cookies is held depends on the specific cookie. All the information retention periods are specified, for each cookie type, in its Cookie Policy.

e) With whom does PEIBOLEARN share your personal information?

The transfers of personal data that are made through cookies from third parties (cookies collected and managed by a third party) for this purpose are specified in the Cookie Policy. In addition, PEIBOLEARN may use the services of service providers, who will have limited access to the data and will be bound by a duty of confidentiality (for more information on how PEIBOLEARN’s service providers operate, see Section 4, “To whom does PEIBOLEARN transfer your personal information?” > “Service Providers”).

If at any time PEIBOLEARN decides to display advertising to you on this Website, PEIBOLEARN may share certain information with third-party advertisers and networks and use that information to provide the user with targeted, personalized advertising as well as statistical analysis. In addition, advertisers may share with PEIBOLEARN data they collect about you to display its advertising on other sites. For more information, please visit its Cookie Policy.

3.2 Contact with PEIBOLEARN through its channels (contact form, e-mail, WhatsApp, chat, scheduled appointment, etc.)

a) What data does PEIBOLEARN collect?

Identification and contact information. PEIBOLEARN collects the information that you provide to PEIBOLEARN through the means that are made available on this Website. PEIBOLEARN will process your identification data (name and, if applicable, surname) and the e-mail address and/or telephone number (depending on the means used), as well as any other data you include in the communications you send to PEIBOLEARN.

Curricular, academic and professional information. In the event that you send to PEIBOLEARN your Curriculum Vitae (CV), PEIBOLEARN will be able to process the information relating to your studies, training, academic experience and any other information you may have included.

b) What are the purposes of the processing of your personal data?

To answer your requests. The main purpose of the processing of these data will be to answer your questions, provide requested information, and, if necessary, to follow up with you.

Advise you about its courses and activities: If available, an advice service will be made available to you by PEIBOLEARN customer service, through which you will be able to explain your interests and PEIBOLEARN will be able to recommend the courses and activities that best suit your needs. This service will only be available by appointment, therefore you must select the date and time (according to availability) and leave your contact details, and the department will contact you on the date indicated

Participate in its recruitment processes. In the event that you send to PEIBOLEARN your CV, PEIBOLEARN will process your personal information to initiate, if applicable, a recruitment process for an eventual hiring and to keep track of it.

Improve its customer service. All the information deriving from the queries, consultations and advice offered to the interested parties, as well as the way in which the requests are resolved, allows PEIBOLEARN to know exactly how the customer service is provided, allowing PEIBOLEARN to improve its quality. Once the conservation time indicated in point d) has expired, all the information gathered will be made anonymous, only kept for statistical purposes, and the interested parties cannot be identified.

c) What is the basis of legitimacy that allows PEIBOLEARN to process your data? If so, is the provision of this data mandatory?

Consent. The data provided for the above purposes will be processed on the basis of your consent, given when, voluntarily, you contact PEIBOLEARN through the means made available to you to either request information or you send other communications or to submit your CV to participate in PEIBOLEARN recruitment processes.

Legitimate interest. All the information gathered by the customer service department will be used to improve the quality of the customer service provided, based on PEIBOLEARN’s legitimate interest.

d) How long does PEIBOLEARN keep your information?

All your personal information will be kept for as long as your requests are being processed and for 6 months to keep track of them. Once this period has expired, PEIBOLEARN will hold, blocked, such information during the periods provided for in the legislation to attend to possible responsibilities and to demonstrate compliance with its obligations. All this, unless you start a new processing. From this moment on, PEIBOLEARN will only process the information in an anonymous manner, so that it will not be possible to link the statistical information with the specific users to whom it refers.

In the case of your CV, PEIBOLEARN will process your personal information during the recruitment process, if applicable, and/or, when there is no open recruitment process, for a maximum of 1 year for possible future recruitment processes that may fit your professional profile or the interests you have indicated.

e) With whom does PEIBOLEARN share your personal information?

PEIBOLEARN does not make any additional transfers to carry out this processing other than those indicated generally in Section 4, “To whom does PEIBOLEARN transfer your personal information?” In this sense, some channels through which you can contact PEIBOLEARN are managed by service providers, who act as Data Processors. You will find more information about how these service providers act in Section 4 below.

3.3 Subscription to the newsletter and reception of other commercial information by electronic means

a) What data does PEIBOLEARN collect?

Contact information. To send commercial information by electronic means, PEIBOLEARN uses the contact data you include in the corresponding form for registration in the newsletter or those contact data (e-mail or mobile phone) that PEIBOLEARN has under its contractual relationship with you, if any.

b) What are the purposes of the processing of your personal data?

Submission of commercial communications and publications of interest: If you have a contractual relationship with PEIBOLEARN or have subscribed to receive commercial information, PEIBOLEARN may send you, through electronic means (e-mails, SMS, WhatsApp or others), communications about products and services related to PEIBOLEARN.

Such communications will in no way infringe your data protection rights and will not be intrusive in terms of frequency as you may adjust the frequency of communications or unsubscribe entirely at any time by providing a notice to hello@peibolearn.com.

c) What is the basis of legitimacy that allows PEIBOLEARN to process your data? If so, is the provision of this data mandatory?

Commercial communications are sent:

On the basis of a previous contractual relationship with PEIBOLEARN; or

On the basis of your consent, requested at the time of your subscription on the mailing list or by ticking a corresponding box on other forms.

If you do not wish to receive this type of communication, you can withdraw your consent at any time by following the instructions provided in each e-mail or by sending PEIBOLEARN an e-mail to hello@peibolearn.com, specifying your wish to stop receiving such communications.

Even if you have unsubscribed from receiving commercial information, you may still receive other communications from the administrative management of the program purchased and/or other communications relevant to the execution of your program contract or security matters.

d) How long does PEIBOLEARN keep your information?

PEIBOLEARN will keep all your personal information for as long as the contractual relationship is in effect. Once it is finished, PEIBOLEARN will hold, blocked, such information for the periods foreseen in the current regulations in order to attend any possible liabilities and to prove the fulfillment of PEIBOLEARN obligations.

In the case that the submission of commercial communications is based on your consent, the information will be kept for as long as you are registered on the mailing list for this type of information and, once you have unsubscribed, it will be held blocked for the legal periods of time required to meet any liabilities.

e) With whom does PEIBOLEARN share your personal information?

PEIBOLEARN does not make any specific transfers of your personal data in order to comply with the purpose indicated in this section. However, PEIBOLEARN may use mail marketing service providers or other advertising and marketing service providers, who will have limited access to the data and will be bound by a duty of confidentiality (for more information about how PEIBOLEARN’s service providers act, see Section 4, “To whom does PEIBOLEARN transfer your personal information?” > “Service Providers”).

3.4 Registration and purchase of PEIBOLEARN Programs

a) What data does PEIBOLEARN collect?

At the time of registration:

Identification and contact information. PEIBOLEARN collects the data you provide through the registration form on the Website. In this regard, PEIBOLEARN will process your personal information (name and surname), the username you have chosen and the e-mail address.

Registration through social networks. In the event that you choose to register or log in through a third party social network, PEIBOLEARN will have access to some of your information contained in your public social network account, as well as name and other profile information.

While using the Website and the services:

Browsing Data. In the course of using the Website and the services and in connection with your registration data, PEIBOLEARN may collect the information set out in Section 3.1.

Profile Data. You may provide additional information in your profile, such as a photo, link to a website, your professional social network profiles as well as any other data (including, but not limited to, personal address, identification numbers and/or professional background) you include in the communications you send to PEIBOLEARN while using the Website or in the context of any application or social network used by PEIBOLEARN within its Website.

Program participation information. While you are doing the program, PEIBOLEARN collects information about your participation in the program: tasks and activities performed; user interactions with other students. Within the training activities PEIBOLEARN offers you, there are channels to communicate with speakers or other students, through which you can publish content related to the program you have subscribed to.

Image and Voice. Some program activities require interaction with other students or, where appropriate, speakers through video conferences.

Transaction information. If you have made a paid subscription or other transaction, PEIBOLEARN collects data about those purchases or transactions. Among the data, PEIBOLEARN may obtain: payment information and means of payment used, as well as billing, shipping and contact details. For security reasons, PEIBOLEARN does not collect or store information about the cardholder, credit/debit card number used and other data relating to the card.

b) What are the purposes of the processing of your personal data?

Register and provide you with PEIBOLEARN services. The main purpose of the processing of your personal data is to register you on the Website in order to, firstly, verify your identity and that you are of legal age and to be able to provide, carry out, develop, control and perform the services that PEIBOLEARN offers through it.

In the event that you register through a social network, PEIBOLEARN will have access to the data included in your social network profile for the same purposes indicated above. Therefore, PEIBOLEARN will not publish anything in your profile on your behalf without your consent.

Within this purpose, there are many processes that are related to it:

Management of the student’s profile and file in relation to the program and the services offered by PEIBOLEARN. The data included in the profile will be visible to the rest of the students of the program.
Management of the videoconferences and formative activities that require interaction of the students and speakers by telematic means.
Management of the platform, where all the necessary materials are provided to carry out the program.
Management and monitoring of the student.
Invitation to events and other activities related to the program and networking actions.
The fulfillment of PEIBOLEARN obligations included in the Terms and Conditions of its Website, as well as the resolution of disputes.

To carry out the management of PEIBOLEARN services and to contact you. Within the daily management of the services, it is necessary to process your identification and contact details and, if you contract any payment service, those relating to your card/account/means of payment chosen, which PEIBOLEARN asks you to provide in order to manage your account and any purchases you make. They will also be used to send you management communications, updates, changes in PEIBOLEARN terms and conditions, security alerts, as well as to reply to any request or requirement that you send us.

3. Improving the Website, the program and adjusting the contents: Any personal information that PEIBOLEARN requests or collects in the course of the contractual relationship enables PEIBOLEARN to create an anonymous profile that, in relation to the other profiles of the other users, allows PEIBOLEARN to create usage statistics that helps PEIBOLEARN to understand the use of the Website and the services in order to improve it, adjusting the content of PEIBOLEARN publications and services offered to the users. The profile created for this purpose is anonymous, so PEIBOLEARN cannot relate the information to a specific user.

In addition, all the information gathered through the cookies and other tracking tools helps PEIBOLEARN to analyze, maintain and improve the Website, since from the analysis of the navigation made by the users, PEIBOLEARN can detect errors in the Website, aspects to be improved in the design or the need to add new functions and services. For more information on how PEIBOLEARN collects and process information through cookies, please visit its Cookie Policy.

Forwarding of publications of interest and commercial communications: If you have a contractual relationship with PEIBOLEARN or have subscribed to the reception of commercial information, PEIBOLEARN may send you, by electronic means, communications about products and services related to its Services, as explained in point 3.3.

5. Prevention, detection and prosecution of activities that are illegal or contrary to the conditions of service or that jeopardize the security of the information or the App. PEIBOLEARN, at its discretion, may process the data to control and prevent any form of abuse of its services, such as fraudulent activities, denial of service attacks, sending spam, unauthorized access to the accounts of PEIBOLEARN’s users, as well as any other practice that is contrary to the General Conditions of Use of the Website or the business General Conditions or that threatens the security of the information or the integrity of the Website itself.

6. Participate in surveys and/or events or other activities organized by PEIBOLEARN. PEIBOLEARN may invite you to conduct a survey through their own or third party means to assess its Services, as well as invite you to events or other activities that PEIBOLEARN organizes for students. If you sign up for any of these activities, PEIBOLEARN will collect and store the information you provide to them to manage these activities. When we use a third-party platform to administer a survey or activity, that third party’s privacy policy will apply.

c) What is the legal basis that allows PEIBOLEARN to process your data? If so, is the provision of this data mandatory?

In general, the processing of your personal data is necessary to execute the contractual relationship created by your registration on PEIBOLEARN’s Website, to take steps at your request prior to entering into a contract, and to comply with its legal obligations (purposes b.1., b.2. and b.5).

The sending of commercial communications (purpose b.4) is carried out on the basis of the previous contractual relationship.

The carrying out of surveys or registration for events organised by PEIBOLEARN (purpose b.6) will always be based on your consent, and your participation in such activities is always voluntary.

The information PEIBOLEARN collects through cookies and other tracking devices is based on your consent, which is requested when you access the application. PEIBOLEARN may use all this information, based on its legitimate interest, to analyse and evaluate the use made of the Website and to be able to apply the necessary improvements to it (purpose b.3).

d) How long does PEIBOLEARN keep your information?

All your personal information will be kept for the duration of the contractual relationship (duration of the course and while the platform is active). Once this is finished, PEIBOLEARN will keep, blocked, this information during the periods foreseen in the legislation to attend eventual responsibilities and to demonstrate the fulfillment of their obligations.

The periods of conservation of the information collected through the cookies depend on the specific cookie. All the periods of conservation of information are specified, for each type of cookie, in its Cookie Policy.

e) With whom does PEIBOLEARN share your personal information?

In addition to the releases indicated, in general, in Section 4, “To whom does PEIBOLEARN transfer your personal information?” PEIBOLEARN may share some basic identifying information with the students of the courses you have enrolled in for information purposes, for the proper development of the joint activities. In this sense if you publish a comment, query or a question using the media within the platform, the user information (including your name) may be publicly visible to other users.

3.5 Purchase of PEIBOLEARN Products

a) What data does PEIBOLEARN collect?

Identification and contact information. PEIBOLEARN collects the information you provide through the purchase form on the Website. In this sense, PEIBOLEARN will process your identification data (name and surname), shipping and billing address, e-mail and other data needed to process the purchase and shipment.

Information on transactions made. PEIBOLEARN collects data on such purchases or transactions as necessary to process the order. Among the data, PEIBOLEARN may obtain: payment information and means of payment used, as well as billing, shipping and contact details. In general, all of the payment methods are secure, and PEIBOLEARN does not collect or store information about the cardholder, credit/debit card number used, or other data relating to the card.

b) What are the purposes of the processing of your personal data?

1. Process the purchase and shipment of the products. The main purpose is to process the purchase made through PEIBOLEARN online store and the shipment of the products.

To carry out the management of PEIBOLEARN services and to contact you. Within the daily management of the services, it is necessary to process your identification and contact details and, if you contract any payment service, those relating to your card/account/means of payment chosen, which PEIBOLEARN asks you to provide in order to manage your account and any purchases you make. They will also be used to send you management communications, updates, changes in PEIBOLEARN terms and conditions, security alerts, as well as to reply to any request or requirement that you send us.

Forwarding of publications of interest and commercial communications: If you have a contractual relationship with PEIBOLEARN or have subscribed to the reception of commercial information, PEIBOLEARN may send you, by electronic means, communications about products and services related to its Services, as explained in point 3.3.

c) What is the basis of legitimacy that allows PEIBOLEARN to process your data? If so, is the provision of this data mandatory?

The processing of your personal data, in general, is necessary to execute the contractual relationship created by your registration on PEIBOLEARN Website and to comply with its legal obligations (purposes b.1., b.2. and b.5).

The sending of commercial communications (purpose b.4) is carried out on the basis of the previous contractual relationship.

The information collected through cookies and other tracking devices is based on your consent, which is requested when you access the application. PEIBOLEARN may use all this information, based on PEIBOLEARN’s legitimate interest, to analyse and evaluate the use made of the Website and to be able to apply the necessary improvements to it (purpose b.3).

d) How long does PEIBOLEARN keep your information?

All your personal information will be kept for the duration of the contractual relationship. Once it is finished, PEIBOLEARN will keep, blocked, this information during the periods foreseen in the legislation to attend eventual responsibilities and to demonstrate the fulfillment of its obligations.

e) With whom does PEIBOLEARN share your personal information?

In addition to the transfers indicated, in general, in Section 4, “To whom does PEIBOLEARN transfer your personal information?”, PEIBOLEARN will use the services of transport companies for the shipment of products purchased through its online store. This transfer is, in any case, necessary in order to fulfill the contractual obligations (shipment and delivery of the purchased product).

3.6 Publication of Comments on the Blog

a) What data does PEIBOLEARN collect?

Basic identification and contact data. For the publication of the comments, PEIBOLEARN requests the basic contact data from the corresponding form. You can select an alias, in case you do not want to publish your name.

b) What are the purposes of the processing of your personal data?

Posting comments on the blog: Through the corresponding form you can publish a comment with your opinion about the topics that appear in the blog. The request for the email is necessary for security and fraud prevention purposes.

Please note that when you post a comment, it will be visible to users visiting the Website.

It should be reminded that it is not allowed to publish obscene, offensive, vulgar or inducing criminal, denigrating, defamatory, infamous, violent or, in general, contrary to the law, morality and generally accepted good customs or public order and / or content contrary to its Terms and Conditions. PEIBOLEARN reserves the right to withdraw the comments that violate these rules and take those measures it deems appropriate.

c) What is the basis of legitimacy that allows PEIBOLEARN to process your data? If so, is the provision of this data mandatory?

Consent. The publication of comments is completely voluntary, so their inclusion in the blog implies the granting of consent for their publication and processing by PEIBOLEARN.

d) How long does PEIBOLEARN keep your information?

Comments will be posted for as long as the corresponding post is published on the blog (for as long as it is relevant to the public).

e) With whom does PEIBOLEARN share your personal information?

There are no specific transfers of your personal data to fulfill the purpose indicated in this section. However, PEIBOLEARN may use the services of service providers, who will have limited access to the data and will be bound by a duty of confidentiality (for more information on how PEIBOLEARN’s service providers operate, see Section 4, “To whom does PEIBOLEARN transfer your personal information?” > “Service Providers”).

Please note that the comments are public, so they will be visible to other users who access the publication.

3.7 Presence of PEIBOLEARN in social media

PEIBOLEARN has a profile in the main social media networks, such as Facebook, Twitter, Instagram, LinkedIn or YouTube.

When you become a follower of any of PEIBOLEARN’s pages in social networks, the processing of data will be governed by the conditions of use, privacy policies and access regulations that belong to the corresponding social network and previously accepted by the user.

PEIBOLEARN, in this sense, will process your data with the purpose of correctly managing its presence in the social network, informing you of activities, products or services, as well as for any other purpose that the regulations of the social media networks allow.

Please note that PEIBOLEARN has no influence on the information that the social network collects or how it is processed, so it is recommended that you keep yourself informed of the purpose and scope of the information collection that takes place through such social networks.

TO WHOM DOES PEIBOLEARN TRANSFER YOUR PERSONAL INFORMATION?

Generally, PEIBOLEARN will not communicate your data to third parties. However, in addition to the transfers that are specifically indicated in the section in which the characteristics of the different operations are explained (Section 3), PEIBOLEARN informs you of the communications that PEIBOLEARN can perform, in general, and that affect all the previous processing and its basis of legitimacy.

Service providers essential to execute the service offered to you, (e.g. computer hosting companies or commercial communication delivery platforms). Notwithstanding the above, these entities have signed the corresponding confidentiality agreements and will only process your data according to PEIBOLEARN’s instructions, not being able to use them for their own purposes or apart from the service they provide.

International transfers. Some of the service providers are located in the United States or other countries outside the European Economic Area. The services of these providers imply the existence of an international transfer of your personal data, which could mean a lower degree of protection than that provided for in European regulations. Nevertheless, PEIBOLEARN has adopted appropriate safeguards within the framework of personal data transfers to third countries or international organizations under the terms of applicable data protection regulation, including, inter alia and among others, the signing of the corresponding standard contractual clauses approved by the European Commission. Therefore, the use of these suppliers does not give rise to a lower degree of protection of your personal data tan the use of suppliers located in the European Union.

Public bodies and other entities. PEIBOLEARN may disclose to appropriate public authorities or other private entities (e.g., auditors) data and other information in its possession or accessible through the systems when there is a legal obligation to do so, as well as when required to do so, for example, when the purpose is to prevent or prosecute abuse of the services or fraudulent activities through the Website or web page. In these cases, the personal data you provide would be kept and made available to the administrative or judicial authorities.

3. In the event of a corporate transaction: In the event that PEIBOLEARN is subject to a merger, acquisition, sale of all or part of its assets or any other corporate transaction involving a third party, it may share, disclose or transfer user data to the successor entity (including during the pre-transaction phase).

4. To third parties following aggregation or anonymization: PEIBOLEARN may disclose or use aggregated or anonymized data (i.e., data that is not linked to an identified or identifiable individual) for any purpose.

5. To third parties with the user’s consent or other legitimate basis: In the event that PEIBOLEARN wishes to share data with third parties outside the scope of this Privacy Policy, PEIBOLEARN will, in any case, ask for their consent or inform them about this Policy and its legitimate basis.

Likewise, PEIBOLEARN informs you that this Privacy Policy only refers to the collection, processing and use of information (relating to personal data) by PEIBOLEARN through the interaction you have with the Website. Access to third party websites that you may access through links from the Website have their own privacy policies over which PEIBOLEARN has no control. Therefore, before you provide any personal information to them, PEIBOLEARN recommends that you inform yourself about their Privacy Policies.

WHAT ARE THE RIGHTS YOU CAN EXERCISE AS AN INTERESTED PARTY?

You can exercise the rights guaranteed by law in relation to the processing of your personal data by contacting PEIBOLEARN by e-mail at hello@peibolearn.com.

Any request for rights that PEIBOLEARN receives will be resolved as soon as possible and, in any case, within a maximum period of 1 month from the date of receipt. In some cases, it will be necessary to request a copy of your identity card or other identification document if it is necessary to verify your identity.

We have listed the privacy rights for several jurisdictions below, but we understand you may have additional rights in your jurisdiction. You may contact us directly at any time about exercising your data protection rights. We will consider your request in accordance with applicable laws.

5.1 European Economic Area (EEA) and United Kingdom (UK) Individuals

I. Right to withdraw consent

You may revoke your consent in relation to all processings based on it at any time. However, withdrawal of consent shall not affect the lawfulness of processing based on consent prior to withdrawal.

II. Right to access

You have the right to know what data is being processed, if any, and, if so, to obtain a copy of it, as well as to obtain information concerning:

the origin and recipients of the data;
the purposes for which they are processed;
whether there is an automated decision-making process, including profiling;
the data retention period; and
the rights provided for by the regulations.

III. Right to rectification

You have the right to obtain the rectification of your personal data or to complete them when they are incomplete.

IV. Right to erasure

You have the right to request the deletion of your personal data if they are no longer necessary for the purpose for which they were collected or, where appropriate, if PEIBOLEARN is no longer authorised to process them.

V. Right to data portability

You have the right to request the portability of your data in the case of the processing of your data that is based on your consent or on the execution of a contract, provided that the processing has been carried out by automated means. If you exercise this right, you will receive your personal data in a structured format, commonly used and readable by any electronic device. However, you may also request, where possible, that your data be transmitted directly to another company.

VI. Rights to restrict the processing of your personal data

You have the right to restrict the processing of your data in the following cases:

When you have requested the correction of your personal data during the period in which PEIBOLEARN verifies the accuracy of the data.

When you consider that PEIBOLEARN is not authorized to process your data. In that case, you may ask to restrict their use instead of requesting their erasure.

When you consider that it is no longer necessary for PEIBOLEARN to process your data and you want to keep them for the purposes of exercising or defending claims.

In cases where there is processing based on PEIBOLEARN’s legitimate interest and you have exercised your right to oppose it, you may ask to restrict the use of your data during the verification of the prevalence of such interests with respect to your own

VII. Right to object

You have the right to object at any time to the processing of your personal data on the basis of PEIBOLEARN’s legitimate interest, including profiling.

Unsubscribing from commercial communications: Remember that at any time you can object to receiving this type of communication by sending an email to hello@peibolearn.com. You may also opt-out of this service by following the instructions at the bottom of each email sent to you.

PEIBOLEARN reminds you that, even if you proceed to unsubscribe from these commercial communications, you may still receive communications from PEIBOLEARN regarding the administrative management of the Services you have contracted, security alerts, changes in the conditions and policies and other communications necessary for the development of the contractual relationship PEIBOLEARN has with you or to resolve requests and applications that you send to PEIBOLEARN through the means that are made available to you.

VIII. Right to file a complaint with the Supervisory Authority

Remember that, at any time, and in the event that you consider that PEIBOLEARN has infringed your right to the protection of your data, you may address the corresponding Control Authority, in the case of Spain, the Spanish Data Protection Agency (www.agpd.es).

Closure of your account and withdrawal

Remember that you can exercise your right of withdrawal to the contracted Program, as specified in the Terms and Conditions. In the event that you proceed to withdraw and/or close your account by sending an email to hello@peibolearn.com with a copy to hello@peibolearn.com, you will lose the right to use any benefits or services that you may have had active at the time of cancellation and/or have contracted previously.

In case you exercise your right of withdrawal and/or cancellation, all your personal data may be kept for a period necessary to ensure the exercise of the processes, legal obligations and to resolve any disputes.

All your personal data will be processed and kept to the extent strictly necessary to comply with the law or with the purposes described. Once the data has been cancelled, PEIBOLEARN may keep it for a period necessary to guarantee the exercise of its processes and legal obligations and to resolve any disputes. When your data is no longer relevant to the purposes for which it was collected, it will be deleted or made anonymous, including any records or other supporting information.

5.2 California Privacy Rights

If you are a California consumer, you have the following rights:

The right to know what personal information is being collected about you.
The right to know whether your personal information is sold or disclosed and to whom.
The right to say no to the sale of personal information.
The right to access your personal information.
The right, in certain circumstances, to delete the information you have provided to us.
The right to equal service and price, even if you exercise your privacy rights.

Request for Information and Deletion. California consumers have the right to request, up to twice in a 12-month period, that a business that collects personal information about the consumer disclose to the consumer the information listed below for the preceding 12 months. We have the right to request verification of your identity for all requests for information.

(1) The categories of personal information it has collected about that consumer.

(2) The categories of sources from which the personal information is collected.

(3) The business or commercial purpose for collecting or selling personal information.

(4) The categories of third parties with whom the business shares personal information.

(5) The categories of personal information that the business sold about the consumer and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each third party to whom the personal information was sold.

(6) The categories of personal information that the business disclosed about the consumer for a business purpose.

(7) The specific pieces of personal information it has collected about that consumer.

To make such a request, please email us at legal@PEIBOLEARN.com, or contact us using the contact information below.

Do Not Sell My Personal Information. California consumers have the right to opt out of the sale of the consumer’s personal information.

We do not sell your personal information to third parties. However, under the California Consumer Privacy Act (CCPA), some sharing of personal information necessary to provide you with personalized ads may be considered a “sale,” even if no money is exchanged, such as our use of DoubleClick cookies, Facebook Pixel, and similar technologies. You may control your cookie settings through the cookie banner on our Website or learn more about how to opt out of such personalized ads through our Cookie Policy.

Third Party Marketing. California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information to third parties for the third parties’ direct marketing purposes. We do not share your personal information to third parties for this purpose.

HOW DOES PEIBOLEARN GUARANTEE THE CONFIDENTIALITY OF YOUR INFORMATION?

The security of your personal data is a priority for PEIBOLEARN. For this reason, PEIBOLEARN has implemented reasonable security measures for the efficient use and processing of the personal data provided by the user, safeguarding the privacy, confidentiality and integrity of the data and making use of appropriate technical means to avoid the alteration, loss, unauthorized access or processing of your data, according to the state of technology at all times.

Consequently, PEIBOLEARN complies with the recommended security standards to protect them. However, it is impossible to guarantee total security due to the nature of the Internet and because there may be malicious actions by third parties outside PEIBOLEARN’s control.

PEIBOLEARN undertakes to act quickly and diligently if data security is threatened or compromised.

WHAT REGULATIONS AFFECT THIS PRIVACY POLICY?

If you wish to obtain more information about the regulations that assist, protect and establish your rights, PEIBOLEARN makes available to you the laws that have inspired this policy and are relevant to you. Please note that you may have additional rights in your jurisdiction, and that different laws may apply to you.

General Data Protection Regulation EU 216/679

https://www.boe.es/buscar/doc.php?id=DOUE-L-2016-80807

Organic Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights

https://www.boe.es/eli/es/lo/2018/12/05/3

Law 34/2002, of 11 July, on information society services and electronic commerce

http://www.boe.es/buscar/act.php?id=BOE-A-2002-13758

California Consumer Privacy Act of 2018

http://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=CIV&division=3.&title=1.81.5.&part=4.&chapter=&article=

California “Shine the Light” Law

http://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=CIV&sectionNum=1798.83.

POLICY CHANGES

This privacy policy may change at any time and from time to time. The most recent version of the privacy policy is reflected by the date located at the top of this privacy policy. All updates and amendments are effective immediately upon notice, which we may give by any means, including, but not limited to, by posting a revised version of this privacy policy or other notice on the Websites. We encourage you to review this privacy policy often to stay informed of changes that may affect you. Our electronically or otherwise properly stored copies of this privacy policy are each deemed to be the true, complete, valid, authentic, and enforceable copy of the version of this privacy policy that was in effect on each respective date you visited the Websites.

CONTACT INFORMATION

If you have any questions or comments, or if you have a concern about the way in which we have handled any privacy matter, please contact us at: hello@peibolearn.com (or via our online webform).

Privacy Policy

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