At Learnlife, we receive and process a significant amount of personal data about our Learners and their families, and we pay special attention to safeguarding their privacy and complying with applicable data protection laws. This document sets out how we process this data and Learners’ and Representatives’ rights in relation to it. This policy is incorporated by reference into our Terms and Conditions (“T&Cs”) for the provision of our programmes.
1. Details of the data controller: “Learnlife” is LEARN SPACE, S.L.U. with registered office at Calle Enrique Granados no 7, 08007 Barcelona, with NIF B67163352. Contact for privacy issues: firstname.lastname@example.org.
2. Data processed. Learnlife processes the following personal data types:
a. All data included in the Enrolment Documents completed for a Learner’s application and admission to a Learnlife programme (collectively, “Admissions Data”):
- Enrolment Document data including, without limitation, the Learner’s identification, contact data (“Learner’s Registration Data”); the Legal Representative(s) identification data, contact data (“Legal Representative’s Data”); the Client(s) identification data,
contact data and bank account data (“Client’s Data”);
- Data about family, educational, medical and psychological conditions of the Learner collected during the Admissions Process (“Learner’s Medical Data”);
- Other data that the Client, or the Learner, or his/her Legal Representative(s) provide Learnlife about the Learner through other forms or documents required for acceptance into a programme (“Learner’s Other Data”);
b. All personal data of the Client(s), the Learner and his/her Legal Representative(s) that Learnlife may collect and process during the provision of its programme services (image and voice, behavioural and academic data, medical and health data, dietary needs, etc.)
(“Learner’s Programme Data”).
The provision of some data is mandatory, as indicated in the Intake Forms. If the Client or the Learner or his/her Legal Representative(s) does not provide us with the Client’s Data, the Learner’s Registration Data and Learner’s Medical Data and, when applicable, the Legal Representative’s Data, Learnlife may not be able to review the application, enrol the Learner on a programme, nor provide its services.
The Client(s), the Learner and, if applicable, his/her Legal Representative(s), confirm that the Admissions Data are complete, accurate and up-to-date. They must inform Learnlife as soon as possible of any change in this data.
3. Purpose of processing.
We process this data for several purposes:
Admissions Data is processed for analysing the suitability of potential learners and entering into and performing the contract for the provision of the Programme; for the proper compliance and management of the relationship Learnlife maintains with the Client(s), the Learner and, where appropriate, with his/her Legal Representative(s).
Learner’s Programme Data and other data related to a Learner’s life and activities at the centre is processed for the provision of our services and the realisation of the Programme, for supporting and looking after the Learner and in emergencies, contacting the appropriate health and safety services.
We also carry out academic and pedagogical profiling of all learner related data to understand the Learners and provide the best and most appropriate service possible for them, as well as to communicate progress with their Legal Representatives.
The Learner’s image and voice, if the Learner or his/her Legal Representative(s) give his/her consent, and other data relating to Learner’s activities of the centre (photographs of works, or videos of presentations and performances, etc.) will be also be processed for publishing them in the Learnlife’s website and social network accounts.
If the Learner or his/her Legal Representative(s) give his/her consent, Learnlife also processes the Learner’s, and his/her Legal Representative’s, personal data to keep them informed about any new programmes and services that can be relevant to the Learner’s profile through any means of communication including electronic means and, where appropriate, newsletters.
Finally, Learnlife processes the data on an individual and aggregated/statistical basis to improve its services and programmes, including the selection of available programmes.
4. Legal basis of the processing. We process the abovementioned data for the following purposes:
(a) Admission Data: for the preparation and execution of the contract and the Client(s)', Learner’s or his/her Legal Representative(s)’ express consent to receive the newsletter;
(b) Learner’s Programme Data: for the performance of the Learnlife programme contract, and in the legitimate interest of Learnlife to know the Learner in order to better serve him/her and respond to his/her educational, personal and, if necessary, medical needs;
(c) Learner’s Medical Data: with the express consent of the Learner or, when applicable, of his/her Legal Representative(s), being necessary to protect the vital interests of the Learner and for medical treatment in emergencies;
(d) Learner’s image and voice: with the express consent of the Learner or, when applicable, of his/her Legal Representative(s).
Consent (for consent-based processing) may be revoked at any time by the Learner or his/her Legal Representative(s).
5. Data Disclosure. The data mentioned in clause 2 is confidential and will not be communicated to third parties except as indicated below:
- To entities and collaborating suppliers of LEARN SPACE, SLU, for the provision of their services in favour of Learnlife (computer hosting, catering, learning guides, studio experts, mentors, etc.) for the correct performance of the contract with the Learner and as necessary
for the effective realisation of the Programme. Some of these suppliers may be outside the territory of the European Economic Area in countries that do not generally offer a level of protection comparable to that established in the Data Protection Legislation. However, we have signed contracts with these entities that offer the adequate guarantees according to the Data Protection Legislation;
- Certain data of the Learner will be shared with other Learners and their families or online (photos, voice recordings, images, etc.) within the framework of Learnlife’s activities and Programmes. You agree that we are not responsible for these persons’ use of the Learner’s shared data;
- We may share the data with the other companies that are part of our business group (namely Our Dream School, SL, with the same address and contact as above) for the purpose of supervising and participating in activities relating to the group as a whole (e.g. our website at https://learnlife.com/);
- We may share the data with entities interested in acquiring the business of our group, in any due diligence process;
- To public entities and authorities that regulate our activity, at their request subject to legal guarantees;
- To public entities and authorities for the purpose of investigating suspicions or allegations of fraud, harassment, bullying, crimes or other violations of any law, rule or regulation;
- To medical, educational and other health care professionals (e.g. psychologists, support staff), to support the Learner’s education, and in cases of emergency to protect the Learner's vital interests.
6. Retention. The personal data will be kept for the duration of the provision of our services, as well as subsequently for the legally established periods for legal liabilities derived from the execution of this contract and the provision of the Learnlife services (usually 10 years). From the moment the Learner finishes or abandons the Programme, said data will be stored in a blocked manner and only accessible by the Learner, his/her Legal Representative(s) or our security staff in the event of any judicial or other legal claim or procedure. Also, on such termination, we anonymise the data for aggregate statistical analysis of our activities. This data will be shared with the entities of our group on this anonymous basis (see above).
7. Disclosure and publication of the image and voice of the Learner. If the Learner or his/her Legal Representative(s) gives his/her consent for publishing certain data (according to clause 14 of the T&Cs), Learnlife may publish on the group website (currently, https://learnlife.com/) and social network accounts certain images and recordings of the Learner (in photograph, film or audio and video recording) created during the Programme for promotional purposes, always respecting the image and honour of the Learner.
8. Use of data by other users. If you (Client(s), Learner and/or Legal Representative(s)) have access to personal data of other Learners and persons at Learnlife, you agree to process and use said data in accordance with the provisions of the T&Cs and only for the explicit purposes of the Programme, unless you have the consent of the other person. You will not facilitate or publish any personal data related to any individual that has not been authorized by said person or the T&Cs. You will protect the confidentiality of any accessible personal data and will prevent access by any unauthorised third parties. It will inform Learnlife of any problem related to the management of this data within 24 hours after it occurs. You will be responsible for any illicit use made of personal data of other Learners, including any use contrary to applicable data protection laws and/or that violates the
9. Data Subjects rights. The Client(s), Learner or, where appropriate, his/her Legal Representative(s), may exercise, at any time, the rights of access, rectification, limitation, erasure and, where appropriate, objection or withdraw of consent to processing of their personal data by means of a written communication addressed to LEARN SPACE, SLU, with address at Calle Enrique Granados,
no 7, 08007 Barcelona, with NIF B67163352, or by sending an email to the following address email@example.com. This communication must include the name and surname, address for the purposes of notifications, date, and signature, and we may request a photocopy of the DNI or another valid document that identifies him/her to verify the identity of the applicant.
If you consider that the data subject rights of the Client(s), the Learner or the Legal Representative(s) have been violated, you can contact the Supervisory Authority, in our case, the Spanish Agency for Data Protection (la Agencia Española de Protección de Datos), www.agpd.es.