Privacy Policy
PRIVACY POLICY FOR THE WEBSITE
1. DATA CONTROLLER
This Privacy Policy regulates the processing of personal data carried out by:
Cristina Ramos Suárez
NIF: 30233595A
Address: Avenida Kansas City 84, 10D, 41007 Seville, Spain
Email: [email protected]
Telephone: +34 611 17 15 27
Hereinafter, SEVILLAELE.
SEVILLAELE is the data controller responsible for the personal data collected directly from users, students, customers, interested parties and participants in its services and activities, in accordance with applicable legislation.
This Privacy Policy applies to personal data processed through:
- the SEVILLAELE website;
- contact and pre-registration forms;
- enrolment and contracting processes;
- student management;
- classes and activities;
- SevillaELE Club;
- communications with students and users;
- digital platforms used to provide the services;
- other communication channels used by SEVILLAELE.
2. APPLICABLE LEGISLATION
The processing of personal data carried out by SEVILLAELE is governed, among other applicable regulations, by:
- Regulation (EU) 2016/679, General Data Protection Regulation (GDPR);
- Organic Law 3/2018 on the Protection of Personal Data and guarantee of digital rights;
- Law 34/2002 on Information Society Services and Electronic Commerce, where applicable;
- and any other Spanish and European legislation applicable to data protection and privacy.
Organic Law 3/2018 is currently consolidated, with its latest published update dated 27 December 2025.
3. WHAT PERSONAL DATA MAY WE PROCESS?
Depending on the relationship with SEVILLAELE and the service used, we may process different categories of data.
3.1. Identification and contact data
For example:
- first and last name;
- telephone number;
- email address;
- address, where necessary;
- country of residence or other information provided by the user.
3.2. Contract-related data
We may process information relating to:
- enrolment;
- contracted service;
- service modality;
- group;
- level;
- schedule;
- duration;
- payments;
- renewals;
- cancellations;
- incidents;
- contracting history.
3.3. Academic activity data
Where necessary to provide the service, we may process information relating to:
- Spanish language level;
- assigned group;
- attendance;
- academic progress;
- class organisation;
- preferences relating to activities;
- communications between student and teacher relating to the service.
3.4. Communication data
We may retain communications that are necessary to manage the relationship with the student or respond to requests, including communications made through:
- email;
- WhatsApp;
- ViDay;
- other channels enabled by SEVILLAELE.
3.5. Payment-related data
We may process information relating to:
- amount;
- payment date;
- payment status;
- contracted service;
- invoicing;
- refunds;
- payment incidents.
SEVILLAELE does not directly store complete bank card details. Payments made through external platforms are processed by the relevant payment service provider.
For example, Stripe states that it may act as a data processor for its business customers in certain payment-processing services.
3.6. Image data
Where there is valid authorisation to do so, we may process photographs and videos in which an individual can be identified.
This processing is specifically regulated in the relevant section of this Privacy Policy.
3.7. Technical and browsing data
When using our website, we may process certain technical data, such as:
- IP address;
- device information;
- browser;
- browsing information;
- data relating to cookies and similar technologies.
The use of cookies is also governed by the information provided in the corresponding cookie notice or cookie settings on the website.
4. WE DO NOT GENERALLY REQUEST SPECIAL CATEGORIES OF PERSONAL DATA
As a general rule, SEVILLAELE does not need to collect special categories of personal data in order to provide its services.
We ask users not to provide particularly sensitive information through forms, email, WhatsApp or other channels when such information is not necessary for the provision of the service.
If, exceptionally, it becomes necessary to process a special category of personal data, this will only be done where there is a valid legal basis and the requirements established by applicable legislation are met.
5. HOW WE USE PERSONAL DATA
SEVILLAELE may use personal data for the following purposes:
5.1. Managing requests and enquiries
To:
- answer questions;
- respond to requests for information;
- manage pre-registration;
- contact interested individuals.
5.2. Managing enrolments and contracts
To:
- formalise enrolment;
- register the student;
- open and maintain the student’s file;
- manage payments;
- manage groups and schedules;
- manage cancellations and renewals;
- manage the contractual relationship.
5.3. Providing contracted classes and services
To:
- organise classes;
- assign groups;
- manage schedules;
- monitor attendance;
- send reminders;
- carry out necessary communications;
- manage changes;
- provide online services;
- provide the necessary resources.
5.4. Managing SevillaELE Club
To:
- manage membership;
- verify membership status;
- organise activities;
- manage the Telegram group;
- apply member benefits and conditions;
- manage activities and experiences.
5.5. Managing digital platforms
We may use the data necessary to provide services through platforms such as:
- ViDay, for administrative and academic management;
- Google Meet, for certain online classes;
- Stripe or other payment providers, to process payments;
- platforms used for Total Spanish;
- other technological tools necessary to provide the services.
5.6. Complying with legal obligations
We may process data in order to comply with:
- tax obligations;
- accounting obligations;
- administrative obligations;
- legal obligations;
- consumer-related obligations;
- obligations relating to service security.
5.7. Managing complaints and incidents
To handle:
- complaints;
- requests;
- incidents;
- disputes;
- exercise of data protection rights;
- potential legal liabilities.
5.8. Improving our services
We may use certain data to analyse the operation of our services and improve their organisation, quality and user experience, always respecting the applicable legal bases and limitations.
5.9. Marketing communications
Where there is a valid legal basis, we may use contact details to send commercial information about:
- courses;
- activities;
- events;
- SevillaELE Club;
- promotions;
- news;
- new services.
Where necessary, we will request prior consent.
Users may withdraw their consent or exercise their right to object to marketing communications at any time.
6. LEGAL BASES FOR PROCESSING
SEVILLAELE does not rely on consent as the legal basis for all processing activities.
Depending on the purpose, different legal bases may apply.
6.1. Performance of a contract
Where processing is necessary to:
- manage an enrolment;
- provide a class;
- manage a group;
- process a payment;
- manage a cancellation;
- provide Total Spanish;
- manage a SevillaELE Club membership;
- fulfil obligations arising from a contracted service.
6.2. Compliance with legal obligations
Where processing is necessary to comply with obligations established by applicable legislation.
6.3. Consent
Where processing requires consent, this will be requested through a clear and specific action.
For example:
- certain marketing communications;
- promotional use of photographs or videos;
- other processing activities for which consent is legally required.
Consent may be withdrawn at any time.
Withdrawal of consent will not affect the lawfulness of processing carried out before the withdrawal.
6.4. Legitimate interests
Where applicable, SEVILLAELE may process certain data on the basis of its legitimate interests, provided that such interests are compatible with the individual’s rights and freedoms and the requirements established by applicable legislation are met.
7. WHICH DATA IS MANDATORY?
Where certain data is necessary to provide a service, formalise an enrolment or comply with a legal obligation, this will be indicated.
If the user does not provide the necessary data, SEVILLAELE may be unable to:
- formalise a contract;
- manage an enrolment;
- provide certain classes;
- process a payment;
- comply with a legal obligation;
- provide certain services.
Data requested through contact or pre-registration forms that is not necessary for entering into a contract may be voluntary.
8. VIDAY MANAGEMENT PLATFORM
SEVILLAELE uses ViDay as an administrative and academic management tool.
ViDay may be used to:
- register students;
- manage their contact details;
- organise groups;
- manage schedules;
- send reminders;
- manage attendance;
- communicate changes;
- manage academic information;
- provide certain functions relating to contracted services.
Data entered into ViDay will be processed in accordance with the terms and safeguards applicable to the service.
SEVILLAELE will seek to ensure that providers processing personal data on behalf of SEVILLAELE provide appropriate safeguards and that the relevant relationships are formalised in accordance with applicable legislation.
9. PAYMENT PLATFORMS
SEVILLAELE may use external providers to process payments.
Where Stripe or another payment provider is used, certain data necessary to complete the transaction may be processed directly by that provider.
SEVILLAELE does not directly store complete bank card details.
Payment providers may process transaction-related information, including data necessary to process payments, issue refunds, prevent fraud and comply with legal obligations. Stripe explains in its policy that, depending on the service, it may act as either a data controller or a data processor.
10. TOTAL SPANISH AND TECHNOLOGICAL PLATFORMS
Total Spanish is an online service independent from SEVILLAELE’s in-person and private classes.
To provide Total Spanish, we may use external technological platforms and tools.
The technological platform currently used for Total Spanish is developed through Lovable.
The data necessary to create and manage a customer’s access may be processed through the technological tools used to provide the service.
Where a provider processes personal data on behalf of SEVILLAELE, the corresponding contractual and organisational measures will be implemented.
Specific information regarding providers, data locations and any international data transfers will be updated when necessary to reflect the actual configuration of the service.
11. WHATSAPP, TELEGRAM AND OTHER COMMUNICATION CHANNELS
SEVILLAELE may use WhatsApp for operational communications and student support.
It may also use Telegram to manage the SevillaELE Club community.
The use of these services means that certain data may be processed by their respective providers.
SEVILLAELE will use these channels according to their intended purpose and will seek to limit the information shared to what is strictly necessary.
Where a communication contains particularly sensitive information, more appropriate channels will be used where necessary.
12. GOOGLE MEET
Online classes may be held through Google Meet.
In order to participate in an online session, the technical and identification data necessary to access the session may be processed.
SEVILLAELE will not use classes for purposes other than those necessary to provide the service, unless there is a specific legal basis and the student is adequately informed.
Classes will not generally be recorded by SEVILLAELE.
If a recording is necessary for a particular activity, participants will be informed in advance and the appropriate authorisation will be obtained where required.
13. PHOTOGRAPHS AND VIDEOS
SEVILLAELE may take photographs and videos during certain classes, activities, events and experiences.
Where an individual can be identified and processing requires consent, specific authorisation will be requested for the use of their image.
Authorisation to use an individual’s image for promotional purposes will be:
- independent from the contracting of services;
- voluntary;
- specific to the purposes stated;
- revocable.
Refusing to authorise promotional use of an individual’s image will not affect their ability to contract or participate in SEVILLAELE services.
Where valid authorisation exists, images may be used through SEVILLAELE’s own media, such as:
- website;
- social media;
- communication materials;
- newsletters;
- promotional campaigns;
- presentations;
- other SEVILLAELE communication channels previously indicated.
Withdrawal of consent will not affect uses lawfully made before the withdrawal. Where technically possible and appropriate, SEVILLAELE will stop using the images in new publications following withdrawal.
14. MINORS
Where a service involves minors, SEVILLAELE will process their data in accordance with applicable legislation.
Where consent is required for a particular processing activity and the minor cannot validly provide it themselves, consent will be obtained from the relevant parent or legal representative.
In relation to photographs, videos and promotional communications involving minors, SEVILLAELE will exercise particular caution and obtain the authorisations legally required.
The minimum age for providing consent for certain information society services will be governed by applicable legislation.
15. RECIPIENTS OF PERSONAL DATA
SEVILLAELE may provide certain personal data to:
- technology providers necessary to provide the services;
- management platform providers;
- payment service providers;
- hosting and maintenance providers;
- communication service providers;
- teachers or collaborators where necessary to provide the service;
- professional advisers where necessary;
- public authorities;
- courts, tribunals or public bodies where legally required.
Data will not be disclosed where such disclosure is not necessary for a legitimate purpose.
Where a provider acts on behalf of SEVILLAELE as a data processor, the corresponding contractual safeguards will be established.
16. COLLABORATORS AND ACTIVITIES
For certain activities, SEVILLAELE may work with teachers, collaborators, establishments or external providers.
Only the data necessary to manage the relevant activity will be shared.
Where a collaborator contracts directly with the participant and acts as an independent data controller, their own privacy policy will apply to the processing activities they carry out.
Where SEVILLAELE is the data controller and the collaborator acts on behalf of SEVILLAELE, the corresponding safeguards will be established.
17. INTERNATIONAL DATA TRANSFERS
Some technology providers used by SEVILLAELE may be established outside the European Economic Area or use infrastructure located internationally.
Where an international transfer of personal data takes place, SEVILLAELE will implement the measures and safeguards required by the GDPR, including, where applicable:
- adequacy decisions;
- Standard Contractual Clauses;
- other legally recognised safeguards.
Specific information regarding providers and international transfers will be kept up to date according to the actual configuration of the services used.
18. DATA RETENTION
SEVILLAELE will retain personal data for as long as necessary to fulfil the purposes for which it was collected.
The specific retention period will depend on the purpose.
For example:
- data necessary to provide a service will be retained while the contractual relationship exists;
- data necessary to comply with legal obligations will be retained for the periods required by the relevant legislation;
- data relating to potential complaints may be retained for the period necessary to determine or defend legal liabilities;
- data processed on the basis of consent for a specific purpose will be retained until consent is withdrawn, unless another legal basis allows its continued retention;
- data used for marketing communications will be retained while there is a valid legal basis for doing so or until the individual objects or withdraws consent where applicable.
Once the applicable retention periods have expired, the data will be deleted or, where appropriate, anonymised.
19. SECURITY
SEVILLAELE will implement appropriate technical and organisational measures to protect personal data against:
- loss;
- destruction;
- alteration;
- unauthorised access;
- unlawful processing;
- unauthorised disclosure.
The measures will be determined taking into account the type of data, the risks involved in the processing and the circumstances of each service.
No system connected to the internet can guarantee absolute security. However, SEVILLAELE will adopt reasonable measures to protect information under its responsibility.
If a personal data breach occurs that is legally required to be notified, SEVILLAELE will act in accordance with the obligations established by applicable legislation.
20. DATA SUBJECT RIGHTS
Users may exercise, where applicable, the following rights:
- Access: to know whether we process their data and obtain information about it.
- Rectification: to request the correction of inaccurate or incomplete data.
- Erasure: to request deletion of their data where applicable.
- Objection: to object to certain processing activities.
- Restriction: to request that processing be temporarily restricted.
- Data portability: to receive certain data in a structured format and transmit it to another controller where legally applicable.
- Withdrawal of consent: to withdraw consent where processing is based on consent.
- The right not to be subject to certain solely automated decisions, where applicable.
The Spanish Data Protection Agency (AEPD) provides information on these rights and recommends that individuals are also informed about how to exercise them and about their right to lodge a complaint with the supervisory authority.
21. HOW TO EXERCISE YOUR RIGHTS
To exercise your rights, you may send a request to:
The request must allow SEVILLAELE to reasonably verify the identity of the person making the request.
SEVILLAELE may request additional information where necessary to verify identity and prevent unauthorised access.
Where possible, the request should indicate:
- full name;
- the right you wish to exercise;
- the information or data concerned;
- any additional information that may help locate the relevant processing activity.
A copy of an identity document will not automatically be required. Additional information may only be requested where it is necessary and proportionate to verify identity.
22. RIGHT TO LODGE A COMPLAINT WITH THE AEPD
If an individual considers that the processing of their personal data does not comply with applicable legislation, they may lodge a complaint with the Spanish Data Protection Agency (AEPD).
Official information regarding the exercise of rights and complaints is available on the AEPD website.
23. MARKETING COMMUNICATIONS
Communications necessary to manage a contractual relationship will not be considered marketing communications.
Marketing communications will only be sent where there is a valid legal basis.
Where consent is required, it will be requested separately.
Users may object to or unsubscribe from marketing communications using the mechanism indicated in each communication or by contacting:
24. COOKIES
The SEVILLAELE website may use cookies and similar technologies.
Necessary cookies required for the operation of the website may be used where technically justified.
Analytics, advertising or third-party cookies will be used in accordance with the applicable consent settings and legislation.
The website currently uses a cookie management system that allows users to configure certain categories of cookies, including strictly necessary and analytics cookies.
Specific information regarding the cookies used, their purposes, providers and duration will be included in the corresponding Cookie Policy.
25. UPDATES TO THIS PRIVACY POLICY
SEVILLAELE may update this Privacy Policy in order to adapt it to:
- changes in legislation;
- new tools;
- changes to services;
- new providers;
- changes in processing purposes;
- organisational changes.
The updated version will be available on this page.
Where a change requires additional information or consent, SEVILLAELE will take the necessary measures to inform users.
26. CONTACT
For any questions regarding the processing of personal data:
Cristina Ramos Suárez – SEVILLAELE
NIF: 30233595A
Avenida Kansas City 84, 10D
41007 Seville, Spain
Email: [email protected]
Telephone: +34 611 17 15 27
Last updated: 7 September 2026.