This Privacy Policy was last updated on January 1, 2020.

Your privacy is important to us! This Privacy Policy explains how we respect the personal data of our users and we confirm that this website complies with the General Data Protection Regulation (EU) 2016/679 of the European Parliament and the Council of 27 April 2016 (GDPR), the Spanish Act 15/1999 of 13 December (LOPD), the Royal Decree 1720 /2007 of 21 December on the protection of personal data, the Act 34/2002 of 11 July 2002 on Information Society and E-commerce Services (LSSICE) and any other data protection legislation in force.

LEAP Global Educational Consultants, S.L. (hereinafter “LEAP”, respects the protection of personal data as stated above, the privacy of users and the confidentiality and security of personal data, and adopts for this purpose technical and organizational measures to avoid the loss, misuse, alteration, unauthorized access and theft of provided personal data, taking into account the current state-of-the-art, nature of the data and the risks to which they are exposed.

This Privacy Policy can be subject to periodical revisions with the aim to reflect any changes in accordance with the legislation in force in order to maintain our practices regarding collection, use and disclosure of the information in compliance to the relevant legislation.

CONTROLLER OF THE TREATMENT

Your data will be incorporated into a file which LEAP provided with C.I.F. B67491233, telephone number 677 72 34 56  and domiciled for Data Protection purposes at Carrer del Bruc 35, 5a planta, 08010 Barcelona, (Spain) with the purpose of managing and processing any application you make using any forms and/or contact forms available on our website.

Regarding the GDPR the personal data you provide through one of the web-based forms will be treated as “Web users”.

PRINCIPLES APPLICABLE TO YOUR DATA

During the treatment of your personal data, we will apply the following principles according to the GDPR:

• Lawfulness, fairness and transparency: we will always require your consent for the treatment of your data for a specific purpose that we will inform you about;
• Minimization, purpose limitation: We will collect data for specified, explicit and legitimate purposes and not further process them in a manner that is incompatible with those purposes and those data will be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
• Time limitation of conservation: personal data may be stored for longer periods insofar as the personal data will be processed according to each purpose; 
• Integrity and confidentiality: Your data will be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.

PURPOSES

Data collected through this website will not be categorized as special, but general personal data, according to the GDPR.

The main purpose for which we collect data through this website is the rendering of services in order to comply with the purposes of LEAP. The services rendered are the following:

• Provide information and advice about the choice of University and major;
• Provide information and advice for Admissions;
• Offering publicity and advertisement about educational and professional programs;
• Offering the possibility to apply for an internship or job;
• Offering the possibility to subscribe to and receive a newsletter.

We never ask for personal data unless it is necessary to render our services.

HOW DO WE OBTAIN YOUR DATA

The personal data treated by LEAP obtained from this website come from:

• Through the general contact form
• Through the application form
• Through specific contact forms, e.g. accommodation form

Apart from the website: LEAP will process any personal data you gave us (previous authorization) but in any case we will treat your personal data highly confidential obtained from third parties.

TRANSFERRING PERSONAL DATA TO THIRD PARTIES

LEAP and any of our trusted entities and partners share information of their clients and users:

• Among entities of the LEAP Group, which are also subject to this privacy policy or follow Data Protection policies under the Commission Decision of 26 July 2000 pursuant to Directive 95/46/EC of the European Parliament and of the Council on the adequate protection of personal data provided in Switzerland;
• With services renderers: LEAP and the LEAP Group entities hire other companies in order to develop certain functions on their behalf. Some of those functions are: managing payrolls and offering legal, economic and consulting services, cleaning services, collection and destruction of documents, IT services, security services. Consequently, those third parties will have access to personal data, but they will not use it for other purposes or objectives. Moreover, they will treat this information in accordance with this Privacy Policy and the applicable legislation in Data Protection matters;
• The LEAP Group entities are the following:
  1. LEAP Global Educational Consultants, S.L., CIF B67491233, domiciled at Carrer del Bruc 35, 5a planta, 08010 Barcelona, Spain.

Nonetheless, we inform you that LEAP and the LEAP Group entities will be allowed to transfer information about the used data whenever the Law provides so and when Administrative and/or Judicial Authorities require it.

Furthermore LEAP and the LEAP Group entities also reserve the right to disclose and/or transfer personal data to a third party in the event of a proposed or actual purchase, sale of all or part of its/their  business or assets. If such sales or transfers are carried out, LEAP and the LEAP Group entities will make all reasonable efforts in order to make the buyer or transferee to use such information in a compatible way with our Privacy Policy. Upon completion of the purchase or transfer, the user will be able to liaise with the acquiring entity to raise any doubts regarding the treatment of personal data. 

SOCIAL MEDIA

LEAP has a presence on different social media. The usage of personal data following the official profiles of LEAP will not only be treated by this privacy policy, but also by the terms of use, privacy policies and regulations to access belonging to that specific social network. The main purpose is to correctly manage the presence in the social network, informing about activities, products or services rendered at https://studies-in-spain.com or any other purpose allowed by the legislation of the social networks.

ACCURACY AND VERACITY OF DATA

The user entering information on the website and other gates is solely responsible for the accuracy, veracity and correction of their data, exonerating LEAP and the LEAP Group entities of any responsibility in this regard. The user will guarantee and answer, in any case, about the precision, validity and authenticity of the personal data provided and will undertake to keep them up to date as required.

ACCEPTANCE AND CONSENT OF THE USER

Entering personal data through the forms available on the Web or, if necessary, sending of messages by email requesting information or services implies the user’s consent for their personal data to be used in accordance with the aforementioned purposes and the acceptance of this Privacy Policy.

The user may revoke at any time their consent to send commercial and advertising communications by communicating by mail to dpo[at]studies-in-spain.com (Data Privacy Officer) or sending a letter to C. Valldonzella 52, 3-3, 08001 Barcelona (Spain).

FOR HOW LONG IS YOUR DATA PROCESSED

The controller shall process and store personal data only for the period necessary to achieve the purpose of the storage or as far as this is granted by the European legislator or by other legislators in laws or regulations, to which the controller is subject to.

If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.

Moreover, data will be erased when the requirement from the data subject is made.

RIGHTS OF THE DATA SUBJECT

1. Right of confirmation

Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed.

1. Right of access

Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European legislator grants the data subject access to the following information:

• the purposes of the processing;
• the categories of personal data concerned;
• the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
• where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
• the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
• the existence of the right to lodge a complaint with a supervisory authority;
• where the personal data are not collected from the data subject, any available information as to their source;
• the existence of automated decision-making, including profiling, referred to in Article 22 (1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

Furthermore, the data subject shall have a right to obtain information as to whether personal data is transferred to a third country or an international organization.

1. Right to rectification

Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

1. Right to erasure (Right to be forgotten)

Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies and as long as the processing is not is necessary:

• The personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed.
• The data subject withdraws the consent on which the processing is based according to point (a) of Article 6 (1) of the GDPR, or point (a) of Article 9 (2) of the GDPR, and where there is no other legal ground for the processing.
• The data subject objects to the processing pursuant to Article 21 (1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21 (2) of the GDPR.
• The personal data has been unlawfully processed.
• The personal data has to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
• The personal data has been collected in relation to the offer of information society services referred to in Article 8 (1) of the GDPR.

1. Right of restriction of processing

Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:

• The accuracy of the personal data is contested by the data subject, for a period enabling the Controller to verify the accuracy of the personal data.
• The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.
• The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims.
• The data subject has objected to processing pursuant to Article 21 (1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

1. Right to data portability

Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided as long as the processing is based on consent pursuant to point (a) of Article 6 (1) of the GDPR or point (a) of Article 9 (2) of the GDPR or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as  the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, in exercising his or her right to data portability pursuant to Article 20 (1) of the GDPR, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible and does not adversely affect the rights and freedoms of others.

1. Right to object

Each data subject shall have the right  granted by the European legislator to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6 (1) of the GDPR. This also applies to profiling based on these provisions.

HOW TO EXERCISE THESE RIGHTS:

The User may exercise their rights of access, rectification, erasure, object, restriction of processing and portability of their personal data, under the terms and conditions set forth in the GDPR and the LOPD, by sending a signed request and including a copy of their ID to dpo[at]studies-in-spain.com  or by sending a letter together with a copy of their ID to:

LEAP Global Educational Consultants, S.L. provided with C.I.F. B67491233, telephone number +34 677 72 34 56 and domiciled for Data Protection purposes at domiciled at Carrer del Bruc 35, 5a planta, 08010 Barcelona, Spain.

For the resolution of any doubt or question regarding our Privacy Policy you can send us an e-mail to dpo[at]studies-in-spain.com  or contact the Accounting Department available to you from Monday to Friday from 9-17h CEST at the telephone number +34 677 72 34 56.

Furthermore, interested subjects will also have the right to lodge an appeal before the supervisory authority if the treatment of the data is considered contrary to the GDPR. In this case the Authority will be the Agencia Española de Protección de Datos.

SECURITY MEASURES

LEAP guarantees to have adopted the appropriate technical, administrative and organizational measures in their facilities, systems and processes, necessary to guarantee the security of their personal data and to prevent their alteration, loss, theft, disclosure or unauthorized use; all in accordance with the provisions of the Data Protection Legislation in force.

CHILDREN’S PRIVACY

Our Services do not address anyone under the age of 13. We do not knowingly collect personal identifiable information from children under 13. In the case we discover that a child under 13 has provided us with personal data, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us so that we will be able to do the necessary actions.

COMMERCIAL MAIL

In accordance with the LSSICE, LEAP does not SPAM. We do not send commercial e-mails unless they have been required by the web used. Consequently, in each website form, the user can check the box to give his/her consent to receive advertising.

Privacy Policy, as of: 24.11.2020.