WHO IS PROCESSING YOUR DATA?
The data processor may be any of the subsidiaries of the LEARNLIGHT GROUP, depending on which subsidiary the service is contracted with. In these cases, LEARNLIGHT will process the data in accordance with the instructions given by your company to provide you with the contracted services.
The Learnlight Group includes the following subsidiaries:
|Company Name and Address||Country in (or from) which Processing takes place|
|Learnlight Spain, SLU
Plaza de Euskadi, 5 – 48009 Bilbao
|Learnlight Services, SLU
Calle de las Huertas 11, 28012 Madrid.
|Learnlight Software, SLU
Calle de las Huertas 11, 28012 Madrid.
|Learnlight Administration, SLU
Calle de las Huerta’s 11, 28012 Madrid.
52 Boulevard Sébastopol, 6th Floor, 75003Paris
|Learnlight Holland BV
Koetsierbaan 51, 1315SJ Almere
|Intensive Business English SRL
via Lazzaro Palazzi n. 2/A, 20124 Milan
|Business English, SRL
via Lazzaro Palazzi n. 2/A, 20124 Milan
Mergenthalerallee,77 65760, Eschborn, Frankfurt
|Learnlight UK Ltd
9 Appold St, London, EC2A 2AP, UK
|Learnlight Americas, Inc
8th. The Green, Suite A, Dover, Kent 19901, Delaware, United States
|Learnlight Beograd d.o.o.
Dvadesetsedmog Marta, Num. 5, Beograd
|Georgal S.A. de C.V.
Barranca del Muerto 493 Col. Merced Gómez, Alcaldía Álvaro Obregón 01600 Ciudad de México, Mexico.
Our contact details, for Data Protection matters, are as follows:
Address: Calle de las Huertas, 11, 28012 Madrid
Telephone: +34 935 107 287.
Notwithstanding the above, on some occasions LEARNLIGHT accesses student data in its capacity as data controller. These occasions are private learners and when a company hands over their employee’s data.
For what purpose do we process your personal data?
Learnlight processes your personal data to provide the language training services the clients have requested, which includes the registration as a user on the platform. For this purpose, Learnlight collects the following personal data: username, first name, last name, address, contact details, telephone number, native language, city, country. The provision of data for this purpose is mandatory, otherwise the service cannot be provided. In any case, nonspecial categories of data will be collected.
Learnlight 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?
All data obtained for the provision of services will be stored according to Learnlight’s Data Retention Policy. The Data Retention Policy sets the required retention periods for specified categories of personal data and sets out the minimum standards to be applied when anonymizing certain information within Learnlight Group. However, the data subject can execute the erasure right at any time throughout this period.
What is the legitimacy for the processing of your data?
The data collected will be processed based on the contractual relationship existing between the companies, because of the Service Agreement signed between them.
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, data may be communicated to the subsidiaries of the Learnlight 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 the 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, based on 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 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 Learnlight 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 In (previously TokBox, Inc.), 23 Main Street Holmdel, NJ 07733 United States||
|Connection method for virtual training services. Name, surname, and IP address. Only relevant if the WebChat option is selected as a connection method.|
|The Rocket Science Group, LLC, (previously MailChimp) 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA, 30308, USA.||
|Sending of Magazine newsletters to learners. Name, email, subscription list, user ID. Learners can unsubscribe from this service at any time.|
|Argonaut Training Facilities Ltd, Lower Ground Floor, 28a York Street, London, W1U 6QA||EU (Ireland). Please be advised that they also have servers in the USA, but they are not used for our services.||CultureConnector provides Learnlight with a platform for our clients to do an Intercultural Assessment and build their own personal cultural profile to aid their learning. It is only relevant if this option is included in the training package.|
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 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, Learnlight will only keep their personal data for the assertion or defense of claims.
In certain circumstances and for reasons related to their 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 (please know in Learnlight case, the consent was given by the Company to which you belong). In these cases, Learnlight will stop processing your data or, where appropriate, stop processing it for that specific purpose, except for compelling legitimate reasons, or for the assertion or defense of claims.
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 for your personal data?
The Data Subject is solely responsible for the truthfulness of the data provided, so that, if the data that has provided is false or inaccurate, LEARNLIGHT reserves the right to prohibit access to the platform, without prejudice to the legal actions it deems appropriate 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 all personal data that is provided to us. For this purpose, LEARNLIGHT has implemented the necessary technical and organizational security measures to prevent any 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 Learnlight obtain your personal data and what responsibility do you have for the processing of third-party data?
The personal data that Learnlight processes is provided by the data subject’s employer and, where appropriate, from the data subject itself.
Who should I contact if I have any questions about data privacy at Learnlight?
If you have any questions, please contact us at: firstname.lastname@example.org.