This is the Privacy Policy for notesfromben.com. It contains references to “Notes from Spain SL” – this is the company that my wife and I set up to handle our Spanish teaching website Notes in Spanish, and legal things for all our other websites, like this one. There are also links to the contact form at our other website Notesinspanish.com, as that’s the best way to reach me for legal things. For all other contact, use the ‘contact’ link on this site.
Your privacy is important to us. We therefore want to be transparent about what we intend to do with the information you entrust to us, i.e., about your personal data (hereinafter “Data”), not only because data protection laws require us to do so but also because we believe in honesty towards our users and customers. Please read this Privacy Policy carefully.
We will notify you in advance of any changes to this Privacy Policy and we will not make retroactive changes that reduce your rights to privacy unless legally required to do so and, under such circumstances, your consent will always be required. Moreover, you may opt out of the services offered on this site if you are not satisfied with the changes made.
Pursuant to the provisions of (EU) Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR) Notes from Ben informs you that by accepting this Privacy Policy you grant your express, free and unequivocal informed consent for the Data you provide to be treated by Notes From Spain SL (our parent company) and WordPress.com (the website provider), as data controllers, subject to the security, technical and organisational measures specified under current regulations.
Warning for minors
If you are under 16 and have accessed this website without notifying your parents you must not register as a user.
Users under 16 are required to obtain consent from parents or guardians for their personal data to be processed.
On this website we respect and care for our users’ personal data. As a user, you should know that your rights are guaranteed.
The controller of your personal data
- Controller ID: Notes From Spain S.L. (parent company of this site)
- Trade name: Notes from Spain
- NIF/CIF: B85103026
- Address: General Alvarez de Castro, 41 1ºizq oficina10
- Email: info@notesfromspain.com (please contact us via our contact form)
- Activity: Sale of Spanish teaching materials for foreigners. Writing about happiness.
- Registered in the Madrid Commercial Register, volume 24,309, folio 43, section 8), sheet M-437092, and entry 1
How do we get your information?
Notes From Spain S.L. manages the notesfromben.com site, where we provide information about services and products offered.
The personal data we process comes from our own users, which we collect through:
- Contact form
- Subscription form
- Blog comments
Legal basis for handling your data
Accepting this privacy policy is required in order to contact, sign up or make comments on this website.
Data category
Data handled for e-mail subscribers:
Categories of specially protected data are not handled.
For what purpose do we handle your personal data?
When a user connects to this website (for example, to comment on a post, send an email to the owner, sign up) he or she is providing information of a personal nature for which Notes From Spain, S.L. is the controller. Such information may include personal data such as your IP address, name, e-mail address and other information. By providing this information, you consent to your information being collected, used, managed and stored by Notes From Spain, S.L., as described in the Legal Disclaimer and this Privacy Policy.
In Notes From Spain, S.L. there are different personal data gathering systems and we treat the information provided by interested persons for the following purposes depending on each capture system (forms):
- Contact form: We request the following personal information: Name and e-mail, to meet the requirements of users that contact us through this channel. We may use this information, for example, to respond to your request and answer the questions, complaints, comments or concerns you may have regarding the information on the site, the services provided through the site, treatment of your personal data, issues relating to legal texts on the site as well as any other questions you may have which may not be subject to contracting terms.
- Content enrollment form: In this case, we request the following personal information: E-mail, to manage the subscription list, send newsletters, promotions and special offers, provided by the user upon enrollment. There are several enrollment forms on the site. Newsletters are managed by mailchimp.com.
- Registration form for blog comments: For users to comment on the blog they must register through this form. In this case, we request the following personal information: Name and e-mail. Once enrolled, users can make as many comments as they like and reply to earlier comments.
There are other purposes for which we handle your personal data:
To fulfil our legal obligations: We will handle your data to fulfil a legal obligation that requires us to do so, for example, to respond to a legal proceeding or under requirement from a competent supervisory authority, such as:
- To protect the rights and security of our users and third parties, as well as ours.
- To meet legal requirements, including compliance with court orders, requests and other appropriate legal mechanisms.
- To provide information to representatives and advisers, including lawyers and tax advisers, to help meet legal, tax and security requirements.
- To support and improve the services offered by this site.
- Other anonymous data are obtained by some cookies that are downloaded on the user’s computer when browsing the site, as detailed in the cookies policy.
- To manage social networks. The various domains associated with Notes From Spain, S.L. are present in social networks. The processing of data for people who become social media fans for notesfromben.com official pages shall be governed by this section, as well as the conditions of use, privacy policies and access regulations applicable to the social network as appropriate in each case and previously accepted by the user. Notes From Spain S.L. will treat your information with the purpose of properly managing your presence on the social network, reporting on activities, products or services and for any other purpose granted by the social network regulations. Under no circumstance will we use the profiles of social media fans to send advertising individually.
Notes From Spain, S.L. does not sell, rent or lease personal data that can identify the user to third parties without prior consent, nor will they do so in the future. However, in some cases collaborations may take place with other professionals. In such cases, users’ consent will be required upon identification of the partner and the purpose of collaboration. Collaborations will always take place under the strictest security standards.
What are your rights when you provide us with your data?
Anyone has the right to obtain confirmation on whether Notes from Ben is processing personal data concerning them or not.
Interested persons are entitled to:
- Request access to personal data relating to the person in question
- Request rectification or deletion
- Request cancellation
- Request limited treatment
- Oppose treatment
- Request data portability
Interested parties may access their personal data and request the correction of inaccurate data or, where appropriate, request withdrawal when, among other reasons, the data are no longer needed for the purposes for which they were collected. Under certain circumstances, interested parties may request the limited processing of data, in which case I will only keep them for implementing or defending claims.
Under certain circumstances and for reasons relating to their particular situation, the interested parties may oppose the processing of their data by Notes From Spain, S.L. At that time, Notes from Ben will stop processing the data, except for compelling legitimate grounds, or for implementing or defending against any claims. As the interested party, you are entitled to receive your personal data which you have provided us, and in a structured, commonly used and machine readable format, and transmit them to another controller when:
- The treatment is based on consent
- The data has been provided by the person concerned.
- The treatment is carried out by automated means.
By exercising your right to data portability, you will be entitled to have personal data transmitted directly from controller to controller where technically possible.
Those concerned parties shall also be entitled to an effective legal protection and file a complaint with the supervisory authority, in this case, the Spanish Data Protection Agency, if they consider that the processing of their personal data infringes the Regulation.
We have enabled a contact form for you to execute these rights.
How long will we keep your data?
Personal data provided will be kept:
- While the business relationship is active.
- Until deletion is requested by the person concerned.
To whom will your data be communicated?
According to the uses for your personal information, we may disclose your personal information to recipients who help us promote or who support our services or our users’ services (“service providers”).
All service providers enter into a contract with Notes From Spain, S.L. protecting personal information and restricting the use of any personal information pursuant to this policy.
In order to provide services strictly necessary for developing this activity, Notes From Spain, S.L. shares data with the following providers under their corresponding privacy conditions:
Google Analytics: a web analytics service provided by Google, Inc., a Delaware company with headquarters in 1600 Amphitheatre Parkway, Mountain View (California), 94043, USA (“Google”). Google Analytics uses “cookies”, which are text files stored on your computer, to help notesfromben.com analyse how users use the site. The information generated by cookies about your use of notesfromben.com (including your IP address) will be directly sent to and stored by Google on servers in the United States.
E-mail marketing: Mailchimp. com, established in the United States of America. More information: http://www.mailchimp.com/, mailchimp.com, treats data in order to carry out e-mail marketing services for Notesfromben.com
Payment management: Stripe.com and PayPal.com
Askimet: A spam-filtering service that keeps our comments free of spam. Part of the WordPress group on companies. See https://akismet.com/privacy
Data confidentiality and security
Notes From Spain, S.L. undertakes to the use and processing of users’ personal data, respecting their confidentiality and using them in accordance with the purpose thereof, and to comply with its obligation to keep it and adopt all measures to prevent alteration, loss, or unauthorized access, in accordance with the provisions of the current legislation on data protection.
Regarding processing confidentiality, Notes From Spain, S.L. will ensure that anyone who is authorised to process customer data (including its staff, partners and providers), will be under the appropriate duty of confidentiality (either a contractual or legal obligation).
When Notes from Ben becomes aware of a security incident, it must notify the customer without undue delay and provide timely information regarding the Security Incident as the information becomes available or the Customer requests it within reason.
Security notification and gap reporting
In Notes From Spain, S.L. we adopt reasonable and appropriate measures to protect personal information from loss, misuse and unauthorised access, disclosure, alteration and destruction, taking into account the risks involved in processing and the nature of personal information. However, if Notes From Spain S.L. determines that your details have been misused (including by an employee of Notes from Spain S.L.), have been exposed to a security breach or improperly acquired by a third party, Notes from Spain S.L. will inform you immediately regarding such security breach, improper appropriation or acquisition.
Navigation
When browsing notesfromben.com non-identifiable data can be collected, which may include IP addresses, geographic location (approximately), a record of how services and sites are used, and other data that cannot be used to identify the user. Non-identifying data also includes your browsing habits through third party services. This website uses the following third-party analysis services:
- Google Analytics
We use this information to analyse trends, administer the site, track users’ movements around the site and gather demographic information about our user base as a whole.
Accuracy and veracity of data
As a user, you are solely responsible for the accuracy and correctness of the data that you send to notesfromben.com, releasing Notes From Spain S.L. from any responsibility.
Users at all times guarantee and are liable for the accuracy, validity and authenticity of the personal data provided and undertake to keep them updated. You agree to provide complete and correct information in the contact or subscription form.
Acceptance and Consent
Users acknowledge to have been informed of the personal data protection terms, duly accepting and consenting to the processing thereof by Notes From Spain S.L., in the manner and for the purposes stated in this privacy policy.
Reversal
The consent granted, both for treatment and for transfer of data from stakeholders, may be withdrawn at any time by notifying Notes From Spain S.L. in the terms of this Policy under Data Protection rights, in addition to the new rights under the European Data Protection Regulation (portability, suppression and limitation). This reversal will not have retroactive effects.
Changes to the Privacy Policy
Notes From Spain S.L. reserves the right to amend this policy to adapt it to new legislation or jurisprudence as well as industry practices. In such cases, Notes From Spain S.L. will announce on this page any changes made with reasonable advance notice prior to implementation.
Doubts and questions about this policy and your privacy. Questions
If you have questions about this policy or if you have privacy concerns regarding access or accuracy of personal information, you may contact us through our contact form (best method) or write to us at: info@notesfromspain.com
Although most access-related questions and problems can be handled quickly, complex requests may take more research and time. In such cases, problems are solved and you will be informed of the following steps, depending on the nature of the problem, within thirty days.
Document revised on 21 Jan, 2020.
Notes from Ben 