Learnlight platform privacy policy

We provide you with this Privacy Policy in order to inform you in detail about how Learnlight processes your personal data and to protect your privacy and the information you provide to us.

If we make changes to this Privacy Policy in the future, we will inform you through this platform or by other means, so that you can be aware of any new privacy conditions that have been adopted.

Below, in the form of questions and answers, we inform you of the conditions under which our company processes your personal data:

Who is responsible for the processing of your data?

The data controller may be any of the subsidiaries of the LEARNLIGHT GROUP, depending on which subsidiary the service is contracted with. The Group includes the following subsidiaries:

Name and address of company Country where (or from which) the data is processed
Learnlight Spain, SLU

Plaza de Euskadi, 5 – 48009 Bilbao

Spain
Learnlight Services, SLU

Calle de las huertas 11, 28012 Madrid

Spain
Learnlight Administration, SLU

Calle de las huertas 11, 28012 Madrid

Spain
Learnlight SARL

52 Boulevard Sébastopol, 6th Floor, 75003 Paris

France
Learnlight Holland BV

Koetsierbaan 51, 1315SJ Almere

Netherlands
Intensive Business English SRL

via Lazzaro Palazzi n. 2/A, 20124 Milan

Italy
Business English, SRL

via Lazzaro Palazzi n. 2/A, 20124 Milan

Italy
Arenalingua GmbH

Mergenthalerallee,77 65760, Eschborn, Frankfurt

Germany
Learnlight UK, Ltd

9 Appold St, London, EC2A 2AP, UK

United Kingdom
Learnlight Americas, Inc USA
Learnlight Beograd d.o.o.

Dvadesetsedmog Marta, Num. 5, Belgrade

Serbia
Georgal S.A. de C.V.

Barranca del Muerto 493 Col. Merced Gómez, Alcaldía Álvaro Obregón 01600 Mexico City

Mexico

Our contact details are as follows:

Notwithstanding the above, on most occasions LEARNLIGHT accesses student data in its capacity as data processor, the data controller being the company of which the student is an employee, since the language training services are provided in the name and on behalf of the client company. In this case, LEARNLIGHT will process the data in accordance with the instructions given by your company in order to provide you with the contracted services.

For what purpose do we process your personal data?

We process your personal data in order to register you as a user and to offer you the language training services you have requested. For this purpose, we will collect the following personal data: username, first name, last name, email address, contact details, telephone number, native language, city, country and, in certain cases, when the student so indicates (the student will be asked during the training), voice recordings of the training. The provision of data for this purpose is mandatory, otherwise the service cannot be provided.

In any case, we will not process or collect any specially protected data.

We will not collect additional personal data unless the user provides this information voluntarily. If third party-data is provided, the user responsible for providing this information must have previously informed the person concerned in accordance with Article 14 of the General Data Protection Regulation (GDPR).

For how long will we process your data?

Your data will be stored for the duration of your contract with Learnlight. After the end of this relationship, your data may be kept for the time required by the applicable legislation and until the expiry of any liabilities arising from the contract.

However, if a user has not used the service for more than one year, any user-specific data will be completely anonymized.

What is the legitimacy for the processing of your data?

Your data provided will be processed on the basis of the contractual relationship existing between the parties, as a result of the provision of services offered.

To which recipients will your data be communicated?

Your data will be treated confidentially and will not be disclosed to third parties, except to the competent Public Administrations, including judges and courts, in the cases provided for and for the purposes defined in the law. However, your data may be communicated to the subsidiaries of our Group, which are listed in the section entitled “Who is responsible for the processing of your data?”

The purpose of this transfer is the centralized management of our activities and the fulfillment of internal administrative purposes, including the processing of students’ personal data.

Although this does not involve a transfer of data, third-party companies acting as our suppliers may access your information to carry out the service. These third parties access your data according to our instructions and may not use it for any other purpose, while maintaining the strictest confidentiality, on the basis of a contract in which they undertake to comply with the requirements of the current regulations on the protection of personal data.

Where does Learnlight store its data?

The following highly secure data centers host Learnlight’s data:

– Amazon Web Services Germany GmbH, Domagkstrasse 28, 80807, Munich, Germany

Please note that these external service providers do not process any data, they only provide hosting services and are located in the European Economic Area.

Is data transferred internationally?

Student data may be processed in Spain, France, the United Kingdom and other countries outside the European Economic Area, as our employees and trainers are located all over the world. In all cases, Learnlight takes the necessary technical and organizational measures to ensure that your data is protected in the event of possible international transfers.

In addition, the following companies may have access to your data (depending on the services we provide to you), thereby creating an international transfer of data:

  • Vonage America Inc (formerly TOK BOX) (used for online training provided through the WebChat feature): first name, last name and IP.
  • The Rocket Science Group, LLC (formerly MAILCHIMP) (used for sending magazine newsletters only if your company has selected this option): name, email address, subscription list and user ID.
  • Argonaut Training Facilities (provides Learnlight with a platform for our clients to conduct cross-cultural assessments and to build their own personal cultural profile to assist their learning. This is only relevant if this option is included in the training package): first name, last name and email address.

Learnlight complies with the necessary measures to make international data transfers secure, in addition to having the standard contractual clauses approved by the European Commission to regulate such transfers. These clauses are available for consultation by our customers.

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

Any person has the right to obtain confirmation as to whether or not we are processing their personal data. Data subjects have the right to access their personal data, as well as to request the rectification of inaccurate data and, where appropriate, to request the erasure of their personal data when, for example, the data is no longer needed for the purposes for which it was collected.

Under the conditions provided for in the General Data Protection Regulation, data subjects may request the restriction of the processing of their data or the portability of their data, in which case, we will only keep their personal data for the assertion or defense of claims.

In certain circumstances and for reasons related to their particular situation, data subjects may object to the processing of their personal data. If you have given consent for a specific purpose, you have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on your consent prior to the withdrawal of your consent. In these cases, we will stop processing your data or, where appropriate, we will stop processing it for that specific purpose, except for compelling legitimate reasons, or for the assertion or defense of possible claims.

All the aforementioned rights can be exercised through the contact information provided at the beginning of this Privacy Policy.

If you believe that your rights have been violated, especially if you have not been able to exercise your rights to your satisfaction, you can lodge a complaint with the Spanish Data Protection Agency (contact details accessible at www.aepd.es), or another competent supervisory authority. You can also obtain more information about your rights by contacting these agencies.

What responsibility do you have over your personal data?

The User is solely responsible for the truthfulness of the data provided, so that, if the User has provided false or inaccurate data, LEARNLIGHT reserves the right to prohibit access to the platform, without prejudice to the legal actions it deems appropriate in order to defend its interests. LEARNLIGHT is also under no obligation to verify, and does not verify, the identity of Users, nor the truthfulness, validity, completeness and/or authenticity of the data that Users provide about themselves, or about other Users. The User is therefore responsible for informing LEARNLIGHT of any change in the data previously provided, and guarantees and is exclusively responsible for the truthfulness of such data.

What measures are taken in the processing of personal data?

LEARNLIGHT guarantees the security and confidentiality of the personal data that you provide to us. For this purpose, LEARNLIGHT has implemented the necessary technical and organizational security measures to prevent the alteration, loss and unauthorized processing of or access to your data, in accordance with the provisions of the applicable regulations.

LEARNLIGHT shall not be liable for any damages that may arise from interferences, omissions, interruptions, computer viruses, telephone line malfunctions or disconnections in the operation of this electronic system which are due to causes beyond LEARNLIGHT’s control, or for delays or blockages in the use of this electronic system caused by deficiencies or overloads of telephone lines or overloads in the Data Processing Center, in the Internet system or in other electronic systems, as well as damages that may be caused by third parties through illegitimate intrusions beyond LEARNLIGHT’s control.

How did we obtain your personal data and what responsibility do you have for the processing of third-party data?

The personal data that we process at LEARNLIGHT is provided by the data subject and, where appropriate, from the company of which the data subject is an employee, that has contracted the language training service, so that LEARNLIGHT can register the student, who provides us with the data indicated in this Privacy Policy.

Who should I contact if I have any questions about data privacy at Learnlight?

If you have any questions, please contact us at: privacy@learnlight.com.