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Privacy Policy

This Privacy Policy describes how Estudia Español (collectively “us,” or “we”) process personal data and other information through the Learn English Fluently Academy website, applications and other online platforms (our “Services”). This Privacy Policy explains what types of information we collect, how we use it, our sharing practices and the choices of the User (collectively “the User(s)”, or “you”).

You can contact Learn English Fluently Academy directly by using the mechanisms identified in the “Contact” section.

This Website collects some personal data from users.

Data Controller

Estudia Español by Rocco Dabellonio – VAT Number 04395380712

Via Monte Rosa 12 – 71042 Cerignola (FG)

E-mail Address: info@estudiaespanol.com

Types of Data Collected

The personal data we collect, either independently or by third-parties, include the following: Cookies, data usage, unique identifiers of advertising devices (for example Google Advertiser ID or IDFA identifier), name, surname, e-mail, VAT number, business name, address, tax code, geographical location, language, date of birth, image and city.

Details about every type of data collected are provided in the relevant sections of this privacy policy or through specific informational texts displayed before the collection of said data. 

Personal Data collected may be freely provided by the User or, in the case of Data Usage, automatically collected during the use of this Website.

Unless otherwise specified, all of the Data requested by the Website is mandatory. If the User refuses to provide them, it may be impossible for the Website to provide its Service. In the case that this Website deems certain Data as optional, the Users are free to refuse communicating such Data, without this having any consequence on the availability of the Service or its operation.

If the Users have doubts about which data is mandatory, they are encouraged to contact us. 

Any use of Cookies – or other means of tracking – on behalf of this Website or the owners of third-party services used by this Website, unless otherwise specified, is for the purpose of providing the requested service by the User, along with additional purposes described in the present document and in the Cookie Policy.

The User takes responsibility for Personal Data provided to third-parties, published or shared through this Website, and guarantees the right to provide or release them, freeing us from any responsibility to third-parties. 

How and Where the Collected Data is Processed

Methods of Processing

We take necessary security measures to prevent unauthorized access, disclosure, tampering or destruction of Personal Data.

The data processing is carried out by means of computer and/or telematic instruments, with organizational methods and logics strictly related to the defined purposes. Besides the Data Controller, other subjects involved in the organization of this Website may have access to the Data of the Users (administrative personnel, commercial, marketing, legal, system administrators) or external subjects (such as third-party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) also appointed, if necessary, as Data Processors. You can always request the updated list of Data Processors from us.

Legal Basis of Data Processing

We process Personal Data relevant to the User if one of the following conditions occurs: 

  • The User has given consent for one or more specific purposes; Note: in some jurisdictions, the Controller may be authorized to process Personal Data without the User’s consent or any of the other legal basis specified below, until the User objects (“opts-out”) to such processing. However, this does not apply where the processing of Personal Data is governed by European legislation on the protection of Personal Data;
  • The data processing is necessary for the execution of a contract with the User and/or the execution of pre-contractual measures;
  • The data processing is necessary to comply with a legal obligation to which we are subject;
  • The data processing is necessary for the performance of a task carried out in the public interest or in the exercise of public authority vested in us;
  • The data processing is necessary for the execution of a contract with the User and/or the execution of pre-contractual measures;
  • The data processing is necessary to comply with a legal obligation to which we are subject;
  • The processing is necessary for the performance of a task carried out in the public interest or in the exercise of public authority vested in us;
  • The processing is necessary for the pursuit our legitimate interest or of third-parties.

However, it is always possible to ask us to clarify the concrete legal basis of each case of processing and in particular to specify whether the instance of processing is based on law, required for by a contract or necessary to conclude a contract.

Location

The Data is processed at our operational headquarters and in any other place where the parties involved in the processing are located. For further information, please contact us.

Your Personal Data may be transferred to a country other than the country in which you are located. For further information on the processing location, please refer to the section on Personal Data processing.

The User has the right to obtain information on legal basis for the transfer of Data outside the European Union, or to an international organization under public international law, or formed by two or more countries, such as the UN, as well as the security measures adopted by us to protect the Data.

In the event that one of the transfers just described takes place, the User may refer to the respective sections of this document or request information by contacting using the contact details given at the beginning.

Duration of Storage

Data is processed and stored for the amount of time required for its purposes.

However:

  • Personal Data collected for purposes related to the performance of a contract between the Controller and the User will be retained until the performance of such contract is completed.
  • Personal Data collected for purposes relevant to the legitimate interest of the Controller will be stored until such interest is satisfied. You may obtain further information regarding our legitimate interest in the relevant sections of this document or by contacting us.

When processing is based on User consent, we may store Personal Data for longer time periods until such consent is revoked. In addition, we may be obliged to retain Personal Data for a longer time period in compliance with a legal obligation or by order of the authorities.

At the end of the storage period, the Personal Data will be deleted. Therefore, at the end of this period the access rights, cancellation, rectification and the right to data portability can no longer be exercised.

Reasons for Data Collection

User Data is collected to enable us to provide Services and for the following purposes: Hosting and backend infrastructure, Traffic optimization and distribution, Advertising, Content commenting, Interaction with social networks and external platforms, Statistics, Registration and authentication, RSS feed management, Contacting the User, Displaying content from external platforms, Payment management, Contact management and messaging and Social features, as well as interaction with social networks and external platforms.

To find more information on the reasons for data processing and the Personal Data concretely relevant for each purpose, the User may refer to the relevant sections of this document.

Details on Processing Personal Data

Personal Data is collected for the following purposes using the following services:

Content Commenting 

The comment services allow Users to formulate and publish their own comments regarding the content of this Website.

The Users, depending on the settings determined by us, can also leave the comment anonymously. If the Personal Data provided by the User includes an e-mail, this may be used to send notifications of comments from the same content. Users are responsible for the content of their comments.

If a comment service provided by a third-party is installed, it is possible that, even if you do not use the comment service, it collects traffic data relating to the pages where the comment service is installed.

Jetpack (Automattic Inc.)

The comment section is created through the Jetpack plugin provided by Automattic Inc.

Personal Data collected: name, e-mail, website.

Location of Data Processing: USA – Privacy Policy

Contacting the User

Mailing List or Newsletter

By registering to be on a mailing list or newsletter, the User’s e-mail address is automatically added to a list of contacts to whom e-mail messages containing information, including commercial and promotional information, relating to this Website may be sent. The User’s e-mail address may also be added to this list as a result of registering with this Website or making a purchase.

Jetpack (Automattic Inc.)

Mailing List and Newsletter section is created through the Jetpack plugin provided by Automattic Inc.

Personal Data collected: e-mail, name and surname.

Location of Data Processing: USA – Privacy Policy

MailChimp (The Rocket Science Group)

The Mailing List and Newsletter section is created through MailChimp provided by The Rocket Science Group.

Personal Data collected: e-mail.

Location of Data Processing: USA – Privacy Policy

Contact Form (This Website)

The User, by filling out the contact form with his or her data, consents to their use to respond to requests for information, quotes, or of any other nature indicated in the header of the form.

Personal Data collected: name, surname and e-mail.

Interaction with Social Networks and External Platforms

This type of service allows the User to interact with social networks, or other external platforms, directly from the pages of this Website.

Interactions and information captured by this Website are in every case subject to the User’s privacy settings for each social network.

If a service for interaction with social networks is installed, it is possible that, even if the User does not use the service, traffic data will be collected relating to the pages where it is installed.

Facebook Like Button and Social Widgets (Meta Platforms, Inc.)

The Facebook “Like” button and social widgets are interactive services from the Facebook social network, provided by Meta Platforms, Inc.

Personal Data collected: Cookies and Data Usage.

Location of Data Processing: USA – Privacy Policy

Twitter Tweet button and Social Widgets (Twitter, Inc.)

The Tweet button and Twitter social widgets are interactive services from the Twitter social network, provided by Twitter, Inc.

Personal Data collected: Cookies and Data Usage.

Location of Data Processing: USA – Privacy Policy

Statistics 

The services contained in this section allow us to monitor and analyze traffic data in order to use it to track User behavior.

WordPress Stat (Automattic Inc.)

WordPress Stats is a statistical service provided by Automattic Inc.

Personal Data collected: Cookies and Data usage.

Location of Data Processing: USA – Privacy Policy

RSS Feed Management

This type of service allows for the management of RSS feeds and the distribution of their contents. Depending on the characteristics of the service used, these services can also be used to insert advertisements within the contents and to collect statistical data about them. 

PowerPress (Blubrry) 

PowerPress is an RSS feed management service provided by Blubrry that allows to collect statistical data on the consultation of content and to integrate advertisements within them.

Personal Data collected: Cookies and Data Usage 

Location of Data Processing: USA – Privacy Policy

Displaying Content from External Platforms

This type of service allows the User to display contents hosted on external platforms directly from the pages of this Website and to interact with them. If a service of this type is installed, it is possible that, even if you do not use the service, it collects traffic data relating to the pages where it is installed. 

YouTube Video Widget (Google Inc.) 

YouTube is a video content display service, operated by Google Inc., which allows this Website to incorporate such content into its pages.

Personal Data collected: Cookies and Data Usage 

Location of Data Processing: USA – Privacy Policy

Advertisements

These types of services allow the use of User Data for purposes of commercial communication in various forms of advertising, such as banners, also in relation to the User’s interests. This does not mean that all Personal Data is used for this purpose. Some of the services mentioned below may use cookies to identify the User or use the technique of behavioral retargeting, i.e., displaying advertisements tailored to the User’s interests and behavior, also detected outside this Website. For further information on this subject, we suggest that you check the privacy policies of the respective services. In addition to the opt-out possibilities offered by the services below, you may opt-out of receiving cookies from a third-party service by visiting the Network Advertising Initiative opt-out page.

AdSense (Google)

AdSense is a banner advertising service offered by Google. With AdSense you can place advertisements on your website, earning money based on the number of ad exposures or ad clicks.

Third-party vendors, including Google, use cookies to serve ads based on a user’s previous visits to your or other websites.

The use of cookies for advertising allows Google and its partners to serve ads based on their visits to this Website and/or other sites on the Internet.

You may choose to disable personalized advertising by visiting the Ads Settings page. Alternatively, you may offer users the ability to disable the use of cookies by third-party vendors for personalized advertising by visiting the www.aboutads.info page.

For more information on how Google uses data, please see Google’s Privacy Policy.

Anti-Spam and Bot Protection

reCAPTCHA (Google)

This website uses “Google reCAPTCHA” (hereinafter “reCAPTCHA”), a service offered by Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA (“Google”). The reCAPTCHA service is used to check whether data entered on this website (i.e., via a contact form) has been entered by a human being or by an automated program (bot). To do this, reCAPTCHA analyzes the visitor’s behavior on the website. This analysis is automatic and starts as soon as the visitor enters this website. For the analysis, reCAPTCHA evaluates various information (for example: IP address, how long the visitor spent on this website, mouse movements, etc.). The data collected during the analysis is sent to Google. The analysis conducted by reCAPTCHA takes place completely in the background: the visitor will not notice anything and will not be notified of the analysis. The data analysis is based on Art. 6 (1) (f) DSGVO. The owner of this site has a legitimate interest in protecting its website from spam and automated programs. For more information about Google reCAPTCHA and Google’s privacy policy, please see the following pages:

https://www.google.com/intl/de/policies/privacy/

https://www.google.com/recaptcha/intro/android.html

Methods of Payment

Payment methods allow the User to make and process payments made by credit card and PayPal. The User can request access at any time to all his/her collected data, know what data has been collected, know where the data is processed, request a copy of all the data collected and possibly request the total and permanent cancellation.

Donorbox (Rebel Idealist LLC)

Personal Data collected: name, surname, e-mail, address, data usage

Location of Data Processing: USA – Privacy Policy

Commercial Affiliations

This type of service allows this Website to display ads for products or services offered by third-parties. The ads may be displayed either in the form of advertising links or in the form of banners in various graphic forms. Clicks on the icon or banner posted on this Website are tracked by the third-party services listed below and are shared with this Website. To find out what data is collected, please refer to the privacy policy of each service.

Amazon Affiliation (Amazon)

Amazon Affiliation is a commercial affiliate service provided by Amazon.com Inc.

Personal Data collected: Cookies; Data usage.

Location of Data Processing: USA – Privacy Policy

User Rights

Users may exercise certain rights with respect to the Data processed by us.

In particular, the User has the right to:

  • Revoke consent at any time. The User may revoke the consent to the processing of their Personal Data previously expressed.
  • Oppose the processing of their Data. The User may object to the processing of his/her Data when it is done on a legal basis other than consent. Further details on the right to object are set out in the section below.
  • Access to their own Data. The User has the right to obtain information on the Data processed by the Data Controller on certain aspects of the processing and to receive a copy of the Data processed.
  • Verify and request correction. The User may verify the correctness of his or her own Data and request that it be updated or corrected.
  • Obtain the limitation of the treatment. When certain conditions are met, the User may request the restriction of the processing of their Data. In this case, the Data Controller will not process the Data for any purpose other than its preservation.
  • Obtain the cancellation or removal of their Personal Data. When certain conditions are met, the User may request the deletion of their Data by the Data Controller.
  • Receive their Data or have them transferred to another owner. The User has the right to receive his or her Data in a structured, commonly used and machine-readable format and, where technically feasible, to have it transferred without hindrance to another controller. This provision is applicable when the Data is processed by automated means and the processing is based on the User’s consent, a contract to which the User is a party or contractual measures related thereto.
  • Propose a complaint. The User may lodge a complaint with the competent data protection supervisory authority or take legal action.

Details on the Right to Object

When Personal Data is processed in the public interest, in the exercise of public powers vested in us or to pursue our legitimate interest, Users have the right to object to the processing for reasons related to their particular situation.

Users should note that if their Data is processed for direct marketing purposes, they may object to the processing without providing any reasons. To find out whether we process data for direct marketing purposes, you may refer to the respective sections of this document.

How to Exercise your Rights 

In order to exercise User rights, you may address a request to our contact details indicated in this document. Requests are filed free of charge and processed by us as soon as possible, in any case within one month.

Cookie Policy

This Website makes use of Cookies. To learn more and to view the detailed information, you can consult the Cookie Policy.

Other Information about Data Processing

Legal Defense

We may use the User’s Personal Data in legal proceedings or in the preparatory phases of such proceedings in order to defend against abuses in the use of this Website or related Services by the User.

The User declares to be aware that we may be obliged to disclose the Data by order of public authorities.

Specific Information

Upon the User’s request, in addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.

Maintenance and System Log 

For operational and maintenance purposes, this Website and any third-party services used by it may collect system logs, i.e., files that record interactions and may also contain Personal Data, such as the User’s IP address.

Information not Contained in this Policy

Further information in relation to the processing of Personal Data may be requested at any time by the User using our contact details.

Response to “Do Not Track” Requests

This Website does not support “Do Not Track” requests.

To find out whether any third-party services used support them, you’re invited to consult their respective privacy policies.

Modifications to this Privacy Policy

We reserve the right to make changes to this privacy policy at any time by informing Users on this page and, if possible, on this Website as well as, if technically and legally feasible, by sending a notification to Users through one of our contact details. Therefore, please consult this page regularly, referring to the last modification date indicated at the bottom.

If the changes affect processing whose legal basis is consent, the Data Controller will collect the User’s consent again, if necessary.

Personal Data (or Data)

Personal data is any information that, directly or indirectly, even in connection with any other information, including a personal identification number, makes a natural person identified or identifiable.

Data Usage 

This is information collected automatically through this Website (including by third-party applications integrated into this Website), including: IP addresses or domain names of computers used by the User who connects with this Website, URI (Uniform Resource Identifier) addresses, the time of the request, the method used to forward the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.), the country of origin, the characteristics of the browser and the operating system used by the User, the various temporal connotations of the visit (for example, the time spent on each page) and the details of the itinerary followed within the Application, with particular reference to the sequence of pages consulted, the parameters relating to the operating system and the User’s IT environment.

User

The individual using this Website who, unless otherwise specified, is the Data Subject.

Data Subject

The individual to whom the Personal Data relates.

Data Processor

The natural person, legal entity, public administration and any other entity that processes personal data on our behalf, as set forth in this privacy policy.

Data Controller (or Holder)

The natural or legal person, public authority, service or other body which, individually or jointly with others, determines the purposes and means of the processing of personal data and the instruments adopted, including the security measures relating to the operation and use of this Website. We, unless otherwise specified, are the owner of this Website.

This Website (or this Application)

The hardware or software tool used to collect and process Users’ Personal Data.

Services

The Services provided by this Website as defined in the relevant terms (if any) on this site/application.

European Union (or EU)

Unless otherwise specified, any reference in this document to the European Union shall be deemed to extend to all current member states of the European Union and the European Economic Area.

Cookies

A small portion of data stored within the User’s device.

Legal References 

This privacy policy is written on the basis of multiple legislative orders, including Articles 13 and 14 of Regulation (EU) 2016/679.

Unless otherwise specified, this privacy policy applies only to this Website.

Last modified: 13/05/2024