Privacy policy ADAO

I.  PRIVACY POLICY AND DATA PROTECTION

Adhering to the current legislation, Autrán Online (hereinafter, also the Website) commits to implementing the necessary technical and organizational measures, in line with the security level appropriate to the risk of the collected data.

Laws incorporated into this privacy policy

This privacy policy aligns with the current Spanish and European regulations regarding the protection of personal data on the Internet. Specifically, it complies with the following rules:

  • The General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 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 December 5, on the Protection of Personal Data and guarantee of digital rights (LOPD-GDD).
    • Royal Decree 1720/2007, of December 21, approving the Regulation for the implementation of Organic Law 15/1999, of December 13, on the Protection of Personal Data (RDLOPD).
    • Law 34/2002, dated July 11, on Information Society Services and Electronic Commerce (LSSI-CE).

Identity of the entity responsible for processing personal data

The entity responsible for processing the personal data collected on Autrán Online is: Autrán Dental Academy Online, S.L., with tax identification number: B13951694, registered in: Commercial Registry of Madrid with the following registration details: Volume 37054, folio 104, entry 4, sheet M-661783, represented by: Fernando Autrán Mateu (hereinafter, Data Controller). Contact details:

Address: Rambla de Catalunya, 53-55, SA 1 Contact phone: +34 609 635 534

Contact email: protecciondatos@autran.es

Record of Personal Data

In compliance with the GDPR and LOPD-GDD, we inform you that the personal data collected by Autrán Online, through the forms on its pages, will be incorporated and processed in our file to facilitate, expedite, and fulfill the commitments established between Autrán Online and the User or the maintenance of the relationship established in the forms filled out by the User, or to respond to a request or inquiry from the User. Moreover, in accordance with

the provisions of the GDPR and LOPD-GDD, unless the exception provided for in Article 30.5 of the GDPR applies, a record of processing activities is maintained that specifies, according to its purposes, the processing activities carried out and the other circumstances established in the GDPR.

Principles governing the processing of personal data

The processing of the User’s personal data will align with the principles outlined in Article 5 of the GDPR and in Article 4 and subsequent articles of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights.

  • Principle of lawfulness, faithfulness, and transparency: User consent will be mandatory, accompanied by clear and transparent information in advance about the purposes for which personal data is collected.
    • Principle of purpose limitation: Personal data will be collected for specific, explicit, and legitimate purposes.
    • Principle of data minimization: The collected personal data will be strictly necessary in relation to the purposes for which they are processed.
    • Principle of accuracy: Personal data must be accurate and consistently updated.
    • Principle of limited storage period: Personal data will only be retained to identify the User for the time necessary for the purposes of processing.
    • Principle of integrity and confidentiality: Personal data will be processed to ensure security and confidentiality.
    • Principle of proactive responsibility: The Data Controller will be accountable for ensuring adherence to the above principles.

Categories of personal data

Autrán Online processes solely identifying data. Under no circumstances are special categories of personal data processed within the meaning of Article 9 of the GDPR.

Legal basis for the processing of personal data

The legal basis for processing personal data is consent. Autrán Online is committed to obtaining the express and verifiable consent of the User for processing their personal data for specific purposes.

The User retains the right to withdraw consent at any time, with the process being as straightforward as giving it. As a general rule, withdrawing consent will not impact the use of the Website.

In instances where the User is required to provide data through forms for inquiries, information requests, or reasons related to the Website’s content, they will be informed if

completion is mandatory for the proper execution of the operation.

Purposes of processing personal data

Autrán Online collects and manages personal data to facilitate, expedite, and fulfill commitments established between the Website and the User. This includes maintaining relationships established through filled-out forms or addressing requests and inquiries.

Similarly, the data may be utilized for commercial purposes, including personalization, operational and statistical objectives, and activities inherent to Autrán Online’s corporate mission. Moreover, it can be employed for data extraction, storage, and marketing studies to customize the content provided to the User and improve the quality, functionality, and navigation of the Website.

Users will be informed, at the time of data collection, about the specific purpose(s) of data processing, i.e., how the collected information will be used.

Retention periods for personal data

Personal data will only be retained for the minimum time necessary for its processing purposes and, in any case, only for the following period: Until a deletion request is made by the data subject or until the User requests its deletion.

Users will be informed, at the time of data collection, about the retention period for personal data or, when not possible, the criteria used to determine this period.

Recipients of personal data

The User’s personal data will be shared with the following recipients or categories of recipients:

  • Autrán Dental Academy Madrid, SL
  • Autrán Dental Academy Online, SL
  • Google Analytics

If the Data Controller intends to transfer personal data to a third country or international organization, Users will be informed at the time of data collection about the third country or international organization to which the data is intended to be transferred, as well as the existence or absence of an adequacy decision by the Commission.

Personal data of minors

In compliance with the provisions of Article 8 of the GDPR and Article 7 of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights, only individuals aged 14 or older can legally consent to the processing of their personal data by Autrán Online. If the individual is under 14 years old, parental or guardian consent is required for the processing, and it will only be considered lawful to the extent that they have granted such authorization.

Secrecy and security of personal data

Autrán Online is committed to implementing the required technical and organizational measures, aligning with the appropriate security level based on the risk associated with the collected data. This commitment ensures the security of personal data and safeguards against the accidental or unlawful destruction, loss, alteration of transmitted, stored, or otherwise processed personal data, as well as unauthorized communication or access to such data.

The Website holds an SSL certificate (Secure Socket Layer), ensuring the secure and confidential transmission of personal data. Data transmission between the server and the User, as well as feedback, is fully encrypted and secure.

However, as Autrán Online cannot guarantee the invulnerability of the Internet or the complete absence of hackers or others who may fraudulently access personal data, the Data Controller pledges to promptly inform the User when a breach of the security of personal data occurs, likely to pose a high risk to the rights and freedoms of individuals. In line with Article 4 of the GDPR, a breach of the security of personal data is understood as any violation causing accidental or unlawful destruction, loss, alteration, unauthorized communication, or access to such data.

The Data Controller will treat personal data as confidential and is committed to informing and ensuring, through a legal or contractual obligation, that confidentiality is respected by its employees, associates, and anyone to whom the information is made accessible.

Rights arising from personal data processing

In accordance with the provisions of the GDPR and Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights, the User possesses the following rights over Autrán Online and can thus exercise them against the Data Controller:

  • Right of access: The User has the right to obtain confirmation from Autrán Online as to whether their personal data is being processed. If so, they are entitled to information about their specific personal data and the processing activities carried out or being conducted by Autrán Online. This includes details about the origin of the data and the recipients of communications made or planned regarding this data.
  • Right of rectification: The User has the right to request the modification of their personal data if inaccuracies or incompleteness are found considering the purposes of the processing.
    • Right to erasure (“right to be forgotten”): The User, unless contrary to current legislation, has the right to obtain the deletion of their personal data when such data is no longer necessary for the purposes for which it was collected or processed; the User has withdrawn their consent to the processing, and there is no other legal basis; the User objects to the processing, and there is no other legitimate reason to continue with it; the personal data has been processed unlawfully; the personal data must be deleted in compliance with a legal obligation; or the personal data has been obtained as a result of a direct offer of information society services to a child under 14 years of age. In addition to deleting the data, the Data Controller, considering the available technology and the cost of implementation, must take reasonable measures to inform those responsible for processing the personal data of the data subject’s request to delete any links to that personal data.
    • Right to limitation of processing: The User has the right to limit the processing of their personal data. This right applies when the accuracy of the User’s personal data is contested; the processing is unlawful; the data controller no longer requires the personal data, but the User needs it for claims; and when the User has objected to the processing.
    • Right to data portability: If processing is carried out by automated means, the User has the right to receive their personal data from the Data Controller in a structured, commonly used, and machine-readable format and to transmit it to another data controller. Where technically feasible, the Data Controller will transmit the data directly to the other controller.
    • Right of objection: The User has the right to object to the processing of their personal data or request the cessation of such processing by Autrán Online.
    • Right not to be subject to automated decision-making, including profiling: The User has the right not to be subject to an individualized decision based solely on automated processing of their personal data, including profiling, unless current legislation establishes otherwise.

Therefore, the User can exercise these rights through a written communication addressed to the Data Controller with the reference “GDPR- https://www.autrandentalacademy.com/en/online-courses/”, specifying:

  • Name and surname of the User, along with a copy of their ID. In cases where representation is admitted, identification of the person representing the User, along with documentary evidence of the representation, is also necessary. Photocopy of the ID may be replaced by any other legally valid means proving identity.
    • Request with specific reasons for the application or information to be accessed.
  • Address for notifications.
    • Date and signature of the applicant.
    • Any document supporting the request.

This request and any attached documents can be sent to the following address and/or email:

Postal address: Rambla de Catalunya, 53-55, SA 1 Email: protecciondatos@autran.es Links to third-party websites

The Website may contain hyperlinks or links providing access to third-party websites other than Autrán Online, and therefore, not operated by Autrán Online. The owners of such websites will have their own data protection policies, and they are responsible for their own files and privacy practices.

Complaints to the supervisory authority

If the User believes there is a problem or a violation of current regulations in the way their personal data is being processed, they have the right to effective judicial protection and can file a complaint with a supervisory authority. This is especially applicable in the state where they have their habitual residence, workplace, or the place of the alleged infringement. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (https://www.aepd.es/).

II.  ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

It is essential for the User to have read and agreed to the conditions outlined in this Privacy Policy concerning the protection of personal data. Additionally, the User must accept the processing of their personal data for the Data Controller to proceed in the specified manner, within the designated time frames, and for the indicated purposes. The use of the Website implies the acceptance of its Privacy Policy.

Autrán Online reserves the right to modify its Privacy Policy according to its own criteria or motivated by a legislative, jurisprudential, or doctrinal change by the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. It is recommended that the User periodically checks this page to stay informed about the latest changes or updates.

This Privacy Policy was updated to comply with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR), and Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights.