Privacy Policy

Your privacy is important for thespanishiceberg.com. This privacy statement explains what personal information is collected from users and how it is used. I encourage you to read these terms carefully before providing your personal information on this website. Those over 14 years may register at thespanishiceberg.com as users without the prior consent of their parents or guardians.

In the case of children under 14 years, the consent of the parents or guardians is required for the processing of their personal data.

In no case will data be collected from the minor related to the professional and economic situation or the privacy of other family members without the consent of the latter.

If you are under 14 years old and have accessed to this website without notifying your parents, you must not register as a user.

On this website users’ personal data are respected and treated carefully. As a user you must know your rights are guaranteed.

I have strived to create a safe and reliable website, and for that reason, I want to share with you some principles regarding your privacy:

• I never request personal information unless it is really necessary to provide you with the services required.

• I never share users’ personal information with anyone, except to comply with the law or in case I have your specific authorization.

• I will never use your personal data for any purpose other than the ones expressed in this Privacy Policy.

It should be noted that this Privacy Policy may vary depending on legislative requirements or self-regulation, so users are advised to visit it periodically. It will be applicable in case users decide to fill in any form where personal data is collected.

Ownership of this Website

IDENTITY: Laura Sanz
TIN: 02895162Z
ADDRESS: 11 Sangenjo Street 5ºD | Postcode 28034 | Madrid (Spain)
E-MAIL: laura@thespanishiceberg.com

ACTIVITY: Spreading of “Spanish” language as a second language for foreigners on the Internet, online training and thespanishiceberg.com mailing list (“Iceberg Club”) for informational, educational and commercial purposes

Legal Framework

The activity of thespanishiceberg.com is subject to the Spanish and European legal framework, specifically to the following standards:

• The General Data Protection Regulation (EU) 2016/679 (“GDPR”) approved by the European Parliament and the European Council of 27 April 2016 relating to the protection of individuals (RGPD). Rules of the European Union (EU) that unify the regulation of personal data processing in the different countries of the EU;

• Organic Law 3/2018, of 5 December 2018, of Personal Data Protection and guarantee of digital rights. Spanish regulations relating to personal data processing and the obligations to be assumed by those responsible for any website in the management of that information;

• Law 34/2002, of 11 Julio 2002, of Information Society Services and Electronic Commerce. This rule affects those websites that, in some way, carry out economic activity through electronic means.

For the purposes of the General Data Protection Regulation aforesaid, the personal data that you send through the web forms will receive the treatment “Web users and subscribers” data.

All technical and organizational security measures established in the current legislation are implemented for the data processing of the users.

Personal data processing principles

In processing your personal data, the following principles that comply with the requirements of the new General Data Protection Regulation (EU) 2016/679 (“GDPR”) apply:

• Principle of legality, fairness and transparency: I will always require your permission to process your personal data for one or more specific purposes that I will inform you in advance with absolute transparency.

• Data minimization principle: I will only request strictly necessary data in relation to the purposes for which they are required. The minimum possible.

• Data storage limitation principle: Your data will be stored and not held for longer than necessary for processing purposes. Depending on the purpose, you will be informed of the time limits. In the case of subscriptions, I will periodically review the lists and I will delete those inactive records for a considerable time to come.

• Integrity and confidentiality principle: Your data will be treated with the appropriate security measures and confidentiality. You must know that I take all necessary precautions to prevent unauthorized access or misuse of user’s data by third parties.

How do I get your data?

Your personal data treated by thespanishiceberg.com come from:

• Contact Form.
• Subscription form (“Iceberg Club”).
• Comments on blog.
• Service request form (online private lessons).

What are your rights when you provide me with your data?

Interested persons have the right to:

• Request access to personal data related to the interested party.
• Request rectification or deletion.
• Request the limitation of data processing.
• Be opposed to the data processing.
• Request data portability.

Interested persons are entitled to access their personal data and request the rectification of inaccurate data, or, if they wish, request deletion when, among other reasons, the data are no longer required for the purposes for which they were collected. In certain circumstances, interested parties may request a limitation concerning the processing of their data, in which case I shall only store the data required to make or defend myself against claims.

In certain circumstances and for reasons related to their particular situation, interested parties may object to the processing of their data. Thespanishiceberg.com shall cease to process the data, except for legitimate mandatory reasons, or in order to make or defend itself against possible claims.

As interested party, you have the right to receive your personal data that concerns you in an organized format, for common use and mechanical reading, and to transfer them to another person in charge of the processing when:

• The data processing is based on consent.
• The data has been provided by the interested person.
• The data processing is carried out by automated means.

By exercising your right to data portability, you will have the right to have personal data transferred directly from responsible to responsible when technically possible.

Those interested will also have the right to effective judicial protection and to file a claim with the supervisory authority, in this case, the Spanish Agency for Data Protection, if they consider that the personal data processing breaks regulations.

Purpose of processing your personal data

When a user connects to this website for example to comment on a post, send an email to the owner, subscribe or contract a service, they are providing personal data information with for which, Laura Sanz is responsible. This information may include personal data such as your name, email address and other information. By providing this information, the user gives consent their information to be collected, used, managed and stored by thespanishiceberg.com, only as described in the Legal & Terms of Use and in this Privacy Policy.

In thespanishiceberg.com there are different systems for collecting personal data and data processing provided by interested persons with the following purpose for each collection system (forms):

• Contact form: The following personal data (Name and Email) are requested to respond to the requirements of the users of thespanishiceberg.com. For example, I can use this information to respond to your request and respond to any doubts, complaints, comments or concerns you may have regarding the information included on the website, the services provided, the personal data processing, questions regarding the legal texts included on the web, as well as any other queries you may have which are not subject to Terms & Conditions. I inform you that the data you provide me with will be located in Web Empresa servers within the EU.

• Subscription form: In this case, the following personal data (Name and Email) are requested to manage the “Iceberg Club” email list provided by the user when filling out the subscription form. Within the web there is only one form to activate the subscription. The newsletter is managed by MailChimp (email marketing provider) through its company The Rocket Science Group LLC, located in the USA. MailChimp is covered by the EU-US Privacy Shield agreement, whose information is available here, approved by the European Data Protection Committee.

• Registration form for blog comments: To comment on blog posts and resources, the user is required to register through this form. In this case, the following personal data (Name and Email) are requested. Once registered, the users can publish as many comments as they want and give an answer on the previous ones. I inform you that the data you provide me with will be located in the Web Empresa servers within the EU.

• Service request form: The following personal data are requested: (Name and Email) to request any of the services (private online Spanish classes) that thespanishiceberg.com makes available to its users. The information collected will allow to request the corresponding service via offline contracting. Requests will be answered by email. The website does not allow online payments (only bank transfer). I inform you that the data you provide me with will be located in the Web Empresa servers within the EU.

In addition to the previous ones, there are other purposes for which your personal data is processed:

• To ensure compliance with the conditions of use and applicable law.

• To support and improve the services offered by this website.

• Other non-identifying data are also collected. This data is collected through some cookies which are downloaded to the user’s computer when browsing this website. I detail these cookies in Cookies Policy.

• To manage social networks since thespanishiceberg.com has presence in social networks. The data processing concerning people who become followers in social networks of the official website of thespanishiceberg.com, will be governed by this section. As well as for those conditions of use, privacy policies and access regulations that belong to the social network where appropriate, and previously accepted by the user. Your data will be treated for the purpose of correctly managing your presence in the social network, reporting on the activities, products or services of thespanishiceberg.com. As well as for any other purpose that the regulations of social networks allow. In no case will I use followers’ profiles in social networks to send advertising individually.

In accordance with Regulation (EU) 2016/679 relating to the protection of individuals (RGPD). Laura Sanz established in 11 Sangenjo Street 5ºD | 28034 Madrid (Spain) will be responsible for data processing corresponding to web users and subscribers.

Thespanishiceberg.com does not sell, rent or transfer any personal data that can identify the user, nor will it in the future, to third parties without prior consent.

Remarketing

Remarketing purpose is to target people who have visited thespanishiceberg.com before and to associate a specific audience with a particular message. Remarketing is a method to get users who have visited the site to do it again.

As a user of thespanishiceberg.com, I inform you that I am collecting information for this remarketing purpose.

The information is collected by Facebook cookies. You can know the data collected by these cookies in the following privacy policy:

Facebook

If you do not want your information to be collected by these cookies, you can disable Google cookies through Google Ads Settings. You can also disable them from a third-party provider through the disabling page of Network Advertising Initiative.

This type of services allows you to interact with social networks or other external platforms directly from the pages of this website. The interactions and collected information through this website will always be subject to the user’s privacy settings in each social network. If a service which allows to interact with social networks is installed, it is possible that, although users do not use the service, it collects web traffic data related to the pages on which it is installed.

Facebook Ads

Thespanishiceberg.com uses Facebook Ads, the Facebook advertising platform, which allows you to create campaigns and ads. When creating an ad, you can segment the audience by:

• Location.
• Demographic data (age, sex, etc.).
• Interests (activities, hobbies, etc.).
• What they buy online and through other channels.

The data collected through Facebook Ads are subject to this privacy policy as soon as the user fill out the subscription form of this website to join the “Iceberg Club”. In no case will the information from Facebook be used for a different purpose.

I can select and publish testimonials and / or customer reviews on the Services, which may contain personal information, such as your name and / or the city, state or country in which you live. I will obtain your consent before publishing any testimony with your name. If such content is published, it will be available to other users of the Services. If you want your name or testimony to be deleted from this website, you can send an email at laura@thespanishiceberg.com.

Legal grounds for personal data processing

The legal basis for data processing is: consent.

To contact or comment on this website, consent is required with this Privacy Policy.

The prospective or commercial offer of products and services is based on consent requested. Under no circumstances will the withdrawal of this consent determine the execution of the subscription contract.

Products and services contracting is governed by the terms and conditions contained in Terms & Conditions.

How long will I retain your data?

The personal data provided will be kept:

• While maintaining the commercial relationship.
• Until deletion is requested by the interested party.
• Period from the last confirmation of interest: 1 year.

Who do I communicate your data to?

Some tools that I use to manage your data are hired by third parties.

To provide services strictly necessary for the development of the activity, thespanishiceberg.com shares data with the following providers under their corresponding privacy conditions:

• Google Analytics: An analytical web service provided by Google, Inc., a Delaware company whose main office is at 1600 Amphitheater Parkway, Mountain View (California), CA 94043, United States (“Google”). Google Analytics uses “cookies”, which are text files located in your computer, to help thespanishiceberg.com analyze the use made by users of the website. The information generated by the cookie about your use of thespanishiceberg.com (including your IP address) will be directly transferred and stored by Google in its servers in the United States.

• Hosting: Webempresa Europa S.L. established in Spain. More information at: https://www.webempresa.com . Webempresa Europa S.L treats the data in order to perform its hosting services to thespanishiceberg.com.

• Web Platform: The WordPress Foundation established in USA. More information at: https://wordpress.org (The WordPress Foundation). The WordPress Foundation treats the data in order to perform its web platform services to thespanishiceberg.com.

• Email marketing: Rocket Science Group LLC (MailChimp) established in USA. More information at: https://mailchimp.com/. Rocket Science Group LLC (MailChimp) treats the data in order to perform its email marketing services to thespanishiceberg.com.

Automation

There are two types of automated processing on this website:

• The subscriber registration process in the MailChimp Tool.
• Segmentations in the mailing list, according to topics of interest based on statistics related to openings and clicks in the emails received.

Navigation

When surfing thespanishiceberg.com I can collect non-identifying data, which may include; IP addresses, geographical location (approximately), a record of how services and sites are used, and other data that cannot be used to identify the user. Among the non-identifying data are also those related to your surfing habits through third-party services. This website uses the following third-party analysis services:

• Google Analytics.
• Facebook Pixel.

I use this information to analyze trends, manage the site, track user movements around the site and to gather demographic information based on the users as a whole.

Data confidentiality and security

Thespanishiceberg.com undertakes to use your personal data respecting your confidentiality and to use them in accordance with its purpose, as well as to comply with my obligation to store them and take all measures necessary to avoid change, loss, processing or unauthorized access in compliance with the current regulations on data protection.

This website includes an SSL certificate. It is a security protocol that has your data travel in a complete and secure way, that is, the data transfer between a server and web user, and in feedback, it is fully encrypted.

Thespanishiceberg.com cannot however guarantee the absolute impregnability of the Internet and thus the infringement of data by fraudulent access to this by third parties.

With regard to processing confidentiality, thespanishiceberg.com will ensure that any authorized person to process user’s data (including its staff, collaborators and providers) will be under the appropriate obligation of confidentiality (either a contractual duty or legal).

When a security incident occurs, once thespanishiceberg.com is aware of it, it will notify the Client without undue delay and will provide with appropriate information related to the Security Incident as it is known or when requested by the Client.

Accuracy and veracity of data

As a user, you are only responsible for the veracity and correctness of data you submit to thespanishiceberg.com exonerating Laura Sanz from any responsibility in this regard.

Users guarantee and respond, in any case, to the accuracy, validity and authenticity of the personal data provided, and undertake to keep them duly updated. The user agrees to provide complete and correct information on the contact or subscription form.

Acceptance and consent

The user states that he/she has been informed of the conditions on personal data protection by accepting and consenting to their processing by thespanishiceberg.com in the form and for the purposes indicated in this Privacy Policy.

Revocability

The consent given, both for data processing and data transfer of interested parties, is revocable at any time by informing thespanishiceberg.com in the terms established in this Policy for the exercise of ARCO rights. In no case will this revocation be retroactive.

Changes to the Privacy Policy

Thespanishiceberg.com reserves the right to modify this Policy to adapt it to legislative or jurisprudential updates, as well as to industry practice guidelines. In these cases, thespanishiceberg.com will publish any changes on this page with sufficient advanced notice before implementation.

Commercial Emails

In accordance with LSSICE, thespanishiceberg.com does not engage in “spamming” practices, and therefore does not send commercial emails which have not been previously requested or authorized by the user. Consequently, in each of the forms on the web, the user has the possibility to expressly consent to receive the newsletter, regardless of the commercial information requested.

According to the Law 34/2002, of July 11, on Information Society Services and Electronic Commerce, thespanishiceberg.com undertakes not to send commercial communications without properly identifying them as such.

The Privacy Policy was last updated on June 30, 2020.