Privacy Policy

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Personal Data Protection
Privacy policy for the corporate website
  • Created on: 2018/05/25
  • Reviewed on: 2024/01/15
  • Ref.: WEB-002
  • Version: 4.0

Basic Data Protection information

Data controller

Mondragon Lingua-Alecop, S.Coop. (ES-F72523962).

Purposes

  • Offer and manage our products and services.
  • Provide tools for contacting, consulting and communicating with data subjects
  • Respond to requests for information, queries, enquiries and quotes.
  • Manage and analyse our corporate presence on the internet.

Legal basis

  • The need to process data for the management of our products and services (“contractual relationship”).
  • With the express consent of the user. Legitimate interest.

Recipients

  • No transfer of data to third parties is foreseen, except for those legally established.

Retention

  • The deadlines established in the applicable regulations (tax, commercial, etc.).

Rights

  • Access, rectification, restriction, erasure, objection and portability at Loramendi kalea, 11, 20500 Arrasate Mondragón (Gipuzkoa) / (+34) 943712055 / mlarrasate@mondragonlingua.com

Full privacy policy and information on personal data protection on the MLAKOOP website and social media

Data controller

The cooperative “Mondragon Lingua-Alecop, S.Coop.” (hereinafter “MLAKOOP” or “the company”) acts, under the terms established in the data protection regulations, as the Data Controller in relation to the processing of personal data (users, information requesters, etc.) carried out through its official websites, mobile applications (“APPs”) and official presence on the company’s social and professional media.

Data Controller: Mondragon Lingua-Alecop, S.Coop. “MLAKOOP”

Tax ID number: ES-F72523962

Address: Loramendi kalea, 11

Town/City: 20500 Arrasate Mondragón (Gipuzkoa)

Telephone: (+34) 943712055

Email: mlarrasate@mondragonlingua.com

Applicable legislation

The basic regulations on personal data protection applicable to the data processing carried out by MLAKOOP are:

  • 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 (“GDPR”).
  • Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights (‘LOPDGDD’).
  • Their respective complementary and implementing regulations.

Websites, APPs and social and professional media channels

The main MLAKOOP website is located at www.mlakoop.com. For the purposes of this Privacy Policy, the official MLAKOOP websites, its “APPs” and the official channels on the company’s social and professional media will all be referred to as “the website”, unless otherwise specified.

Purposes of data processing and legitimate legal bases.

In compliance with current regulations on Personal Data Protection, users are informed that the personal data they provide through any means located on the website or through its APPs or the official social or professional media channels of MLAKOOP (via email, forms, private areas, messages, newsletter subscriptions, etc.), or as a result of their use, may be included in the data processing systems of MLAKOOP.

The purposes of data processing that may occur through the MLAKOOP website are:

CUSTOMERS AND USERS OF THE WEBSITE

 

Purpose: Offer and manage MLAKOOP products and services and, where appropriate, contract and manage them online.

Legal basis: The need to process the data for the management of products and services (a “contractual” or “pre-contractual” relationship according to Article 6.1.b of the GDPR).

Possible recipients: No data transfers to third parties are foreseen, except in specific cases to MLAKOOP’s providers who are involved in any stage of managing the requested products or services, and as required by law.

Rights: See the section “Rights of Data Subjects””.

CUSTOMERS AND USERS OF THE WEBSITE

 

Purpose: Offer and manage MLAKOOP products and services and, where appropriate, contract and manage them online.

Legal basis: The need to process the data for the management of products and services (a “contractual” or “pre-contractual” relationship according to Article 6.1.b of the GDPR).

Possible recipients: No data transfers to third parties are foreseen, except in specific cases to MLAKOOP’s providers who are involved in any stage of managing the requested products or services, and as required by law.

Rights: See the section “Rights of Data Subjects””.

INFORMATION REQUESTERS

 

Purpose: Provide tools for contacting, consulting and communicating with data subjects and similar purposes. Respond to requests for information, queries, enquiries and quotes.

Legal basis: Consent of the data subject (GDPR Article 6.1.a), when they provide their data for these purposes, by filling in “Contact”, “Request quote” or similar forms, and checking the boxes for acceptance of conditions and privacy policy.

Possible recipients: No data transfers to third parties are foreseen.

Rights: See the section “Rights of Data Subjects””.

NEWSLETTER SUBSCRIBERS AND RECIPIENTS OF INFORMATIONAL EMAILS

 

Purpose: Send information and commercial communications related to our products, services and activities.

Legal basis: Consent of the data subject (GDPR Article 6.1.a), when they provide their data for these purposes, subscribing to the “newsletter” or checking boxes to accept receiving such communications.

Possible recipients: No data transfers to third parties are foreseen.

Right not to receive further communications: In the case of subscribing to newsletters or similar services, users may unsubscribe from these services at any time by sending a request to the email address mlarrasate@mondragonlingua.com or using any other method provided by MLAKOOP for this purpose, such as the “Unsubscribe” mechanism located at the end of the newsletters themselves.

Other rights: See the section “Rights of Data Subjects””.

WEBSITE USERS AND SOCIAL MEDIA CHANNEL USERS

 

Purpose: Inform about, organise and publicise the activities and initiatives of MLAKOOP or those in which it participates, as well as the opinions and evaluations made by third parties and entities.

Legal basis: The legitimate interest of MLAKOOP (GDPR Article 6.1.f) in publicising its products, services and activities.

Possible recipients: No data transfers to third parties are foreseen, except for the publication or dissemination of opinions and evaluations made.

Rights: See the section “Rights of Data Subjects””.

WEBSITE USERS AND SOCIAL MEDIA CHANNEL USERS

 

Purpose: Inform about, organise and publicise the activities and initiatives of MLAKOOP or those in which it participates, as well as the opinions and evaluations made by third parties and entities.

Legal basis: The legitimate interest of MLAKOOP (GDPR Article 6.1.f) in publicising its products, services and activities.

Possible recipients: No data transfers to third parties are foreseen, except for the publication or dissemination of opinions and evaluations made.

Rights: See the section “Rights of Data Subjects””.

Data retention period

The personal data provided will be kept for as long as necessary to fulfil the purpose for which it was collected, determine any potential liabilities that may arise from the purpose, or for the period required by applicable regulations in each case (accounting, tax, commercial, consumer, etc.), after which they will be deleted, taking the necessary security measures to ensure their confidentiality.

Rights of data subjects

You  may exercise your rights regarding the protection of your personal data (access, rectification, erasure, restriction of processing, portability and objection), as well as withdraw any consents granted, or make any other request in this regard by writing to MLAKOOP, at Loramendi kalea, 11, 20500 Arrasate Mondragón (Gipuzkoa), telephone (+34) 943712055, or at the email address mlarrasate@mondragonlingua.com.

The request must be accompanied by a copy of a document verifying the identity of the requesting person. If the request is made in your capacity as a legal representative, in addition to the copy of the document verifying the identity of the requesting individual, a document confirming such representation must also be attached.

The supervisory authority which you can contact if you do not agree with the resolution of the requests or to lodge a complaint is the Spanish Data Protection Agency: www.aepd.es

Collection of personal data

MLAKOOP does not require you to provide personal data in order to access the website.  However, the website may have forms (e.g., “Contact”), private areas, newsletter subscriptions, etc., whose use requires the user to provide personal data, mostly identification or contact details. The user provides their personal data freely and voluntarily. MLAKOOP does not request more personal information than is necessary to carry out the requested service.

The user who sends/includes any type of content (data, documents, texts, videos, sound, photographs, graphics, messages or other material) declares and guarantees to do so in a way that complies with the conditions expressed herein and with current legislation. The user who includes personal data of third parties declares that they have obtained the express and verifiable consent of the third party in question for the processing of said data. The inclusion of third-party data without the express consent of the third party is prohibited.

The user is solely liable for the truthfulness, accuracy, and lawful processing of the data provided, exempting MLAKOOP from any liability in this regard. Users guarantee and are, in any case, liable for the accuracy, validity, and authenticity of the personal data provided, and undertake to maintain them duly updated.

Failure to complete or incorrect completion of fields indicated as mandatory in the forms or private areas of the website may result in MLAKOOP being unable to respond to the user’s request.

MLAKOOP will collect personal data in an appropriate manner, relevant to the purposes, uses, services or features included on the website, in a specific, explicit and legitimate way, and under no circumstances will fraudulent, unfair or illicit means be used, or means that in any way endanger the rights of users.

The submission of information through this website, the registration or subscription to its different services or the use of the private areas necessarily entails the express authorisation for the data processing described in this privacy policy and in the general conditions of the website.

Registration

The personal data provided during registration for our courses, whether in-person or online, will be incorporated into our data processing systems. The purpose of this is to manage the activities related to language training and teaching and those derived or related to it, maintain the commercial relationship with our students and their representatives (e.g., by sending commercial communications), promote and disseminate our services and activities, carry out the legitimate functions inherent to our activity, and comply with the legal obligations arising from it.

The data related to attendance, progress, grades obtained, behaviour, incidents, sanctions, participation in activities and any other data necessary for the proper fulfilment of the course objectives  may be communicated to the parents or legal guardians of the student, or to the person, company or institution on behalf of whom the individual is registered as a student at MLAKOOP.

In the case of students sitting official exams, the student and, where applicable, their parents or legal guardians expressly authorise that the data necessary to carry out this procedure be communicated to the organisers and coordinators of the exams, and that, in the event that the student passes,{t 3} MLAKOOP may publish their name in the media and on its websites, web channels and publications.

In the case of students who wish to take courses and study abroad, the student and, where applicable, their parents or legal guardians expressly authorise that the data necessary to take these courses be communicated to the organising entities and third parties collaborating in the courses.

In the event of requesting financial aid, the student and, where applicable, their parents or legal guardians expressly authorise the Data Controller to communicate their data to the competent institutions.

Durante el desarrollo de las actividades el Responsable del Tratamiento puede realizar fotografías, grabaciones audiovisuales, etc. en las que se incluyan la imagen y voz de los participantes. La persona alumna y, en su caso, sus padres o representantes legales autorizan expresamente al Responsable del Tratamiento que su imagen y voz puedan ser incluidas en las instalaciones, sitios web y redes sociales del centro.

La persona alumna y, en su caso, sus padres o representantes legales son informados que, en base al interés legítimo del Responsable del Tratamiento, les puede hacer llegar informaciones relacionadas con los servicios solicitados y las actividades que desarrolle, por correo postal, teléfono y por medios electrónicos, incluyendo correo electrónico (boletín electrónico, etc.), redes y canales sociales (Facebook, Twitter, Instagram, etc.), mensajería electrónica (WhatsApp, mensajes SMS, etc.) y herramientas similares.

El tratamiento de los datos personales se podrá realizar tanto en papel como por medios informáticos. Una vez terminada la prestación de servicios, MLAKOOP conservará los datos durante un periodo de diez años, tras el cual procederá a suprimirlos con las medidas de seguridad necesarias para garantizar su confidencialidad.

During the course of the activities, the Data Controller may take photographs, make audiovisual recordings, etc. that include the image and voice of the participants. The student and, where applicable, their parents or legal guardians expressly authorise the Data Controller to include their image and voice in the centre’s facilities, websites and social media.

 

The student and, where applicable, their parents or legal guardians are informed that, based on the legitimate interest of the Data Controller, they may be sent information related to the services requested and the activities carried out, by post, telephone and electronic means, including email (electronic newsletter, etc.), social media and channels (Facebook, Twitter, Instagram, etc.), electronic messaging (WhatsApp, SMS messages, etc.) and similar tools.

 

The processing of personal data may be carried out both on paper and by electronic means. Once the provision of services has been completed, MLAKOOP will retain the data for a period of ten years, after which it will proceed to delete it with the necessary security measures to guarantee its confidentiality.

 

This section constitutes the Data Protection Policy of MLAKOOP in relation to students, and therefore it will not be necessary to inform you about it in future actions, except in the case of changes to the policy or legislative modifications. The provision of the requested data, the request for our services and the acceptance of this Data Protection Policy necessarily implies your express consent for the collection and for each of the data processing operations and possible communications described, including data that is legally considered as specially protected, when necessary. If you do not give your consent for the processing of your data or you subsequently withdraw your consent, Mondragon Lingua will not be able to provide the requested services.

Processing of specific data: Children’s data

The products, services and activities on this website are not specifically aimed at children. If any of our products or services were to be specifically aimed at children, MLAKOOP would request the consent of parents or legal guardians for the collection of personal data or, where applicable, for the processing of data.

 

MLAKOOP recommends that users consult the various materials developed by the supervisory authorities in relation to the protection of personal data of children and young people. This information (recommendations, user manuals for new technologies, educational videos, etc.) is available on the websites of the Basque and Spanish Data Protection Agencies.

Processing of specific data: Job applicants:

Persons submitting their CV and applying for work at MLAKOOP by means of forms, email, the company’s social or professional media channels, or similar mechanisms, are informed, as established in the Personal Data Protection regulations, that the data provided through their job application will be incorporated into our data processing called “CVs and Personnel Recruitment””.

 

Your data may be used for the purpose of involving you in future MLAKOOP personnel recruitment processes, which may be carried out internally or by external companies that MLAKOOP contracts for the purpose of personnel recruitment processes.

 

MLAKOOP will retain your CV for a period of approximately one year. After this period, the data will be destroyed using the necessary security measures to guarantee its confidentiality.

 

If you do not agree with any of the purposes described, please inform us in writing as soon as possible. Likewise, if there is any change in your data, please keep us informed.

 

You may exercise your rights regarding the protection of your personal data (erasure, access, rectification, restriction of processing, portability, objection, etc.), as well as make any requests in this regard as indicated in the section “Rights of Data Subjects” of this Privacy Policy.

 

Processing of specific data: Registrations and subscriptions

In the case of subscribing to newsletters or similar services that involve the processing of personal data, may unsubscribe from these services at any time by sending a request to the email address mlarrasate@mondragonlingua.com or by using any other method provided by MLAKOOP  for this purpose, such as the Unsubscribe” mechanism located at the end of the newsletters themselves.

Processing of specific data: Traffic data

In order to provide a better service through this website, the IP address and other device characteristics of the user may be recorded, allowing for the subsequent processing of the data to statistically analyse the number of visits, their geographical origin, the types of devices used, and other data to improve the features and use of the website.

Links to social media and web channels

This website may offer links to social media, professional networks and external websites and web channels. MLAKOOP assumes no responsibility for these linked sites. Users who access social or professional networks and external websites and web channels related to MLAKOOP, from the links on this website or by any other means, are hereby informed in advance and expressly that the conditions of use, privacy policies, cookies policies and any other conditions or regulations depend on the entities responsible for these social or professional media and websites and web channels, and never MLAKOOP.

Presence of MLAKOOP on social media

MLAKOOP may have profiles on social and professional media, with the main purpose of promoting its products, services, and activities. The publications offered through these channels will be for informational purposes only.

 

By registering on MLAKOOP’s profiles with their social or professional media profile, the user gives their express consent to MLAKOOP for the processing of their personal data in accordance with this Privacy Policy

 

The information and personal data voluntarily provided by the user through MLAKOOP’s social or professional media may be processed for the purpose of contacting the user and addressing the enquiries and requests made, sending informational and commercial communications, managing events, invitations, contests, and similar activities, gathering the user’s opinion or evaluation of MLAKOOP and its publications, and generally managing the company’s presence on social and professional media.

 

Users are informed that the information and content (data, texts, videos, audio, photographs, plans, graphics, comments, messages, or other material) they post through MLAKOOP’s social media (including, where applicable, personal data) may be made publicly available to other users of these social and professional media. This content may be visible, commented on, and freely shared by visitors, in accordance with the terms set by each social or professional media channel.

 

From the user profile settings of each social or professional media channel, the user can configure which information they want to make public in each case, view the permissions they have granted, delete or deactivate them, and manage their posts according to their preferences and the usage rules of each social or professional media.

 

The user will be solely responsible for ensuring that their posts comply with current legislation, the terms of use, and privacy policies established by the respective social or professional media channel, as well as those of MLAKOOP, which assumes no responsibility for the posts made by each user. MLAKOOP will unilaterally remove, without prior notice, any content it deems to violate current legislation, the established terms of use and privacy policies, or content it considers inappropriate.

 

MLAKOOP may follow other profiles on Facebook, Instagram, LinkedIn, YouTube, and other social or professional media channels, without this implying any kind of affiliation with them. 

 

At the same time, MLAKOOP’s channels on Facebook, Instagram, LinkedIn, YouTube, and other social or professional networks may be followed by other users of those networks, without this implying any kind of affiliation with them. 

 

MLAKOOP reserves the right not to respond to messages or comments received through these channels. MLAKOOP may modify or remove posts on its social media at any time and without prior notice. 

 

By following or clicking “Like” (or similar features) on social or professional media, you consent to the processing of your personal data within the respective social or professional media environment, in accordance with their privacy policies, MLAKOOP’s access to the data contained in your contact list, and the appearance of its posts, including those of a commercial nature, in your notifications and alerts.

 

If the user wishes to stop following MLAKOOP’s official social or professional media channels, they must do so using the tools provided by each media channel for that purpose.

Security measures

MLAKOOP will process the personal data contained in its data processing activities by adopting the necessary technical and organisational measures to ensure their security and prevent their alteration, loss, unauthorised processing, or access, taking into account the state of technology, the nature of the stored data, and the risks they are exposed to, whether arising from human action or the physical or natural environment, in accordance with the applicable current legislation on security measures for personal data processing. However, users are informed that computer security measures are not impregnable and are not safe from possible illegal and undue interference, which would not be the responsibility of MLAKOOP.

 

 

 

In order to guarantee the security and privacy of the user, this website uses encryption technology based on secure connection layer protocols (https), so that browsing is as secure as possible.

Security breaches

The user must immediately notify MLAKOOP of any incidents, security breaches, unauthorised or improper access detected in relation to the website, private areas, access credentials, social media presence, or any other circumstance that jeopardises the security and confidentiality of the information or the proper functioning of the website.

 

The preferred notification mechanisms are by telephone (+34) 943712055 and by email at the address mlarrasate@mondragonlingua.com.

Duty of confidentiality

MLAKOOP is committed to the privacy and protection of data of website users. Your personal data will be processed confidentially and in compliance with this regulation. MLAKOOP employees have been expressly informed of their duty of professional secrecy or confidentiality.

Validity and modifications

MLAKOOP reserves the right to modify its privacy policy at its discretion, or in accordance with any changes in legislation or case law. If MLAKOOP introduces any modification, the new text will be published on this same website, where the user may read it. In any case, the relationship with the users will be governed by the rules in place at the time they access the website. That is why MLAKOOP recommends that you visit this privacy policy every time you connect to the website.

Jurisdiction

The relationship established between MLAKOOP and the user will be governed by the provisions of current regulations regarding the applicable law and competent jurisdiction. However, in cases where the regulations provide for the possibility of the parties submitting to a jurisdiction, MLAKOOP and the user, expressly waiving any other jurisdiction that may correspond to them, submit to the Courts and Tribunals of Bergara (Gipuzkoa, Spain).

 

MLAKOOP will pursue the breach of this Privacy Policy, as well as any improper use of the content displayed on this website, exercising all civil and criminal actions that may correspond to it by law, including those of a financial nature.

Legal notice: Legal notice

Information on the use of cookies: Cookie policy

Information on the Data Protection Officer: Data Protection Officer

Access to the Ethical Channel: Ethical Channel