Last updated: (January 2021)

We are committed to protecting and respecting your privacy. This policy sets out the basis on which any personal data we collect will be processed by us. Please read this privacy policy carefully to understand our views and practices and your rights regarding your personal data. By visiting any of our websites (www.lightonspanish.com, www.learn.lightonspanish.com) you are accepting and consenting to the practices described in this policy.

For the purpose of data protection legislation, the data controller is Jorge Sivit and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

Contact Details

Our full details are:

Full name of legal entity: Jorge Sivit

Email address: jorge@lightonspanish.com

Postal address: Dolores Romero 20, 28028 Madrid, Spain

It is very important that the information we hold about you is accurate and up to date. If at any time your personal information changes, please let us know by emailing us at jorge@lightonspanish.com

What Information Do We Collect From You?

We collect and process the following data about you:

-Information you give us: This is information about you that you give us by filling in forms on our site or by corresponding with us by email or otherwise. It includes any communication that you send to us whether that be through contact or opt-in forms on our website, through email, text, social media messaging, social media posting or any other communication that you send us. The information you give us may include your name, address, email address, age, location and financial information in the event of a purchase. Please let us know if any of this information changes so we can keep our records up to date.

-Information we collect from your use of our site: With regard to each of your visits to our site we will automatically collect the following information:

1. Technical information, such as the Internet protocol (IP) address used to connect your device to the Internet.
2. The location where you connected to our service
3. Your internet service provider (ISP).
4. What type of device you are using to access our service
5. Other online services information such as your login activity data, details about your browser and length of visit to pages on our website, page views and website navigation paths, details about the number of times you have used our website, your time zone settings and other information about the devices you use to access our website. The source of this data is our analytics tracking system.

-Information we collect throughout our relationship with you: This is information relating to products (free or paid) that you download or purchase from us.

-Marketing Information: This includes data about your preferences in receiving marketing from us and our third parties and your communication preferences.

Note: We may use information you give us, information we collect from your use of our site, information we collect throughout our relationship with you, and marketing information to:

Deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements)

Measure or understand the effectiveness of the advertising we serve you.

Our lawful ground for processing this information is our legitimate interests which are to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).

Why Do We Collect This Information?

We use this information in the following ways:

Information you give to us or which we receive from other sources: We process this data for the purposes of communication with you, for record keeping and administration, and for the establishment, pursuance or defense of legal claims. Our lawful ground for processing this information is our legitimate interests, which in this case are to reply to communications sent to us by you, to keep accurate records and to establish, pursue or defend legal claims.

We use this information:

-In order to take steps necessary to assess whether we can enter into a contract with you and in order to perform our contract with you. This includes carrying out our obligations to you and providing you with our, or a third party’s products and services;

-For the purpose of improving our service to you, to ensure that content from our site is presented in the most effective manner for you and for your device;

-To deal with any legal queries relating to your use of our service;

-To provide you with service communications so that we can perform our obligations to you. These may be sent by email. These will include notifications about changes to our service, event details and information about products that you have signed up to;

-To provide you with marketing communications including, with your permission, information about other goods and services we offer that are similar to those that you have already purchased or enquired about; or

-In our or a third party’s legitimate interests of keeping customers up to date with goods and services, increasing awareness of ourselves and third parties within the market, making promotional offers and generating new business, building and maintaining loyalty or market share.

Information we collect from your use of the site: We process this data to analyze your use of our website and other online services, to administer and protect our business and website and to deliver relevant and interesting website content and advertisements to you, as well as to understand the effectiveness of our advertising and marketing strategies. Our lawful ground for processing this information is our legitimate interests which in this case are to properly administer our website and our business, to grow our business and to make decisions about our marketing strategies. We use this information for the following purposes:

-To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

-To improve our site to ensure that content is presented in the most effective manner for you and for your device;

-As part of our efforts to keep our site safe and secure;

-To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you

Information we collect throughout our relationship. We process this data to supply the goods and/or services you have purchased from us or our affiliates and to keep records of such transactions. Our lawful ground for processing this data is the fulfillment of a contract between you and us and/or taking steps to enter into such a contract, at your request.

Marketing Information: We process this data to enable you to participate in our promotions, competitions, prize draws and free give-aways, as well as to deliver relevant website content and advertisements to you and measure or understand the effectiveness of these advertising and marketing strategies. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services and website, to develop them, to grow our business and to make decisions about our marketing strategies.

How Do We Use Your Data For Marketing Communications?

Our lawful ground for processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).

Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if:

-You purchased or asked for information from us about our goods or services

-You agreed to receive marketing communications and you have not opted out of receiving these communications since.

We will not share your personal data with any third party for their own marketing purposes without first obtaining your express consent.

-You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any of our marketing messages or emails, or by emailing us at jorge@lightonspanish.com at any time.

If you opt out of receiving marketing communications this opt-out does not apply to personal data you have provided to us as a result of other transactions, such as purchases, event registrations etc.

How Long Do We Keep Hold Of Your Information?

We will keep information about you for a maximum of 6 years after the end of our relationship with you unless obligations to our regulators require otherwise or we are required to remove such data from our records.

In some circumstances we may anonymise your personal data for our research or statistical purposes, and in such cases we may use this information indefinitely without further notice to you.

Who Might We Share Your Information With?

We may have to share your personal data with the parties listed below:

-Service providers who provide IT and system administration services to us

-Professional advisers including lawyers, bankers, auditors and insurers

-Government bodies that require us to report on our processing activities

-Third parties to whom we sell, transfer, or merge parts of our business or our assets

-We require that all third parties to whom we transfer your data respect the security of your personal information and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

You agree that for the purposes set out in the ‘Why do we collect this information?’ section above, that we have the right to share your personal information with the aforementioned parties.

How Is Your Data Stored And Kept Secure?

At Light On Spanish we take your safety and security very seriously and we are committed to protecting your personal and financial information.

Where we have given you (or where you have chosen) a password that enables you to access certain parts of our services or products, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access to your data.We have in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to employees and partners who have a business need to access that data. They will only process your personal data on our instructions and they must keep it confidential.

We have procedures in place to deal with any suspected personal data breach and will notify you and any relevant regulator of any breaches if we are legally required to.

Transferring Your Data Outside Of The European Economic Area (EEA)

European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria due to the fact that countries outside of the EEA do not always offer the same levels of protection to your personal data.

Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

In such cases where it necessary for us to transfer your personal data out of the European Economic Area, we will do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:

-We will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data

-In cases where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give your personal data the same protection it has in Europe

-If we use US-based providers, we will use providers that are part of EU-US Privacy Shield, as they have equivalent safeguards in place.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

What Are Your Rights?

Where processing of your personal data is based on consent, you can withdraw that consent at any time.

You have the following rights. You can exercise these rights at any time by contacting us at the address above or by emailing jorge@lightonspanish.com. You have the right:

-To ask us not to process your personal data for marketing purposes. We will inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes;

-To ask us not to process your personal data where it is processed on the basis of legitimate interests provided that there are no compelling reasons for that processing;

-To request from us a copy of personal information held about you;

-To ask for the information we hold about you to be rectified if it is inaccurate or incomplete;

-To ask for data to be erased provided that the personal data is no longer necessary for the purposes for which it was collected, you withdraw consent (if the legal basis for processing is consent), you exercise your right to object, set out below, and there are no overriding legitimate grounds for processing, the data is unlawfully processed or the data needs to be erased to comply with a legal obligation

-To ask for the processing of that information to be restricted if the accuracy of that data is contested, the processing is unlawful, the personal data is no longer necessary for the purposes for which it was collected or you exercise your right to object (pending verification of whether there are legitimate grounds for processing);

You can read more about these rights at: http://www.agpd.es/portalwebAGPD/CanalDelCiudadano/derechos/index-iden-idphp.php.

Should you have any issues, concerns or problems in relation to your data, or wish to notify us of data which is inaccurate, please let us know by contacting us using the contact details above.

You will not have to pay a fee to us to access your personal data (or to exercise any of the other rights). However, if your request is clearly unfounded, repetitive or excessive, we may charge a reasonable fee or refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is only disclosed to the person who has the right to receive it. We may also contact you to ask you for further information in relation to your request in order to assist us in providing you with a fast response.

We aim to respond to all legitimate requests within one month, however, occasionally it may take us longer than a month to fulfil your request if it is particularly complex or you have made a number of requests. In such a case, we will notify you.

In the event that you are not satisfied with our processing of your personal data, you have the right to lodge a complaint with the relevant supervisory authority, which is the AEPD (Spanish Agency of Data Protection) in Spain, at any time.

Third-Party Links

Our website may include links to third-party websites, plug-ins and applications. Clicking on such links or enabling such plug-ins and applications may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies. When you leave our website, we encourage you to read the privacy policy of every third-party website you visit to understand their respective privacy policies.

Cookies

We use cookies to track how you use our website.

This enables us to understand your use of the site and track any patterns with regards how you are using the site. We use this information to help us to develop and improve our website as well as products and / or services in response to what you might need or want.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. However, please note that if you choose to disable or refuse cookies, some parts of our website may become inaccessible or not function properly for you.

A cookie is a small text file that we store on your device. Our website uses cookies to distinguish from other users of you website. Cookies also provide us with information about how this website is used so we can keep it as up to date, relevant and error-free as possible. Our site uses the following kinds of cookies:

-Strictly necessary cookies – These are cookies that are essential to the operation of our website.

-Analytical/performance cookie – These cookies allow us to recognise and count the number of visitors to our website.

-Functionality cookies – These cookies are used to recognise you when you return to our website.

-Targeting Cookies – These cookies record your visit to our website, the pages you have visited and the links you have followed.

Cookies are used by nearly all websites and do not harm your system in any way.

Your consent applies to the domain: www.lightonspanish.com.

Changes to our privacy policy

This policy may be updated from time to time. Please check back frequently to see any updates or changes to our privacy policy.

Terms of Service

Introduction

These Website Standard Terms and Conditions written on this webpage shall manage your use of this website. These Terms will be applied fully and affect to your use of this Website. By using this Website, you agreed to accept all terms and conditions written in here. You must not use this Website if you disagree with any of these Website Standard Terms and Conditions.

Minors or people below 18 years old are not allowed to use this Website.

Intellectual Property Rights

Other than the content you own, under these Terms, Jorge Sivit and/or its licensors own all the intellectual property rights and materials contained in this Website.

You are granted limited license only for purposes of viewing the material contained on this Website.

Restrictions

You are specifically restricted from all of the following:

-publishing any Website material in any other media;

-selling, sublicensing and/or otherwise commercializing any Website material;

-publicly performing and/or showing any Website material;

-using this Website in any way that is or may be damaging to this Website;

-using this Website in any way that impacts user access to this Website;

-using this Website contrary to applicable laws and regulations, or in any way may cause harm to the Website, or to any person or business entity;

-engaging in any data mining, data harvesting, data extracting or any other similar activity in relation to this Website;

-using this Website to engage in any advertising or marketing.

Certain areas of this Website are restricted from being access by you and Jorge Sivit may further restrict access by you to any areas of this Website, at any time, in absolute discretion. Any user ID and password you may have for this Website are confidential and you must maintain confidentiality as well.

Your Content

In these Website Standard Terms and Conditions, “Your Content” shall mean any audio, video text, images or other material you choose to display on this Website. By displaying Your Content, you grant Jorge Sivit a non-exclusive, worldwide irrevocable, sub licensable license to use, reproduce, adapt, publish, translate and distribute it in any and all media.

Your Content must be your own and must not be invading any third-party’s rights. Jorge Sivit reserves the right to remove any of Your Content from this Website at any time without notice.

No warranties

This Website is provided “as is,” with all faults, and Jorge Sivit express no representations or warranties, of any kind related to this Website or the materials contained on this Website. Also, nothing contained on this Website shall be interpreted as advising you.

Limitation of liability

In no event shall Jorge Sivit, nor any of its officers, directors and employees, shall be held liable for anything arising out of or in any way connected with your use of this Website whether such liability is under contract. Jorge Sivit, including its officers, directors and employees shall not be held liable for any indirect, consequential or special liability arising out of or in any way related to your use of this Website.

Indemnification

You hereby indemnify to the fullest extent Jorge Sivit from and against any and/or all liabilities, costs, demands, causes of action, damages and expenses arising in any way related to your breach of any of the provisions of these Terms.

Severability

If any provision of these Terms is found to be invalid under any applicable law, such provisions shall be deleted without affecting the remaining provisions herein.

Variation of Terms

Jorge Sivit is permitted to revise these Terms at any time as it sees fit, and by using this Website you are expected to review these Terms on a regular basis.

Assignment

Jorge Sivit is allowed to assign, transfer, and subcontract its rights and/or obligations under these Terms without any notification. However, you are not allowed to assign, transfer, or subcontract any of your rights and/or obligations under these Terms.

Entire Agreement

These Terms constitute the entire agreement between Jorge Sivit and you in relation to your use of this Website, and supersede all prior agreements and understandings.

Governing Law & Jurisdiction

These Terms will be governed by and interpreted in accordance with the laws of Spain, and you submit to the non-exclusive jurisdiction of the courts located in Spain for the resolution of any disputes.

Identification

The website lightonspanish.com is a site operated by Jorge Sivit. We are registered in Spain with our registered office and main trading address at Dolores Romero 20, 28028 Madrid.

Right to cancel

You have the right to cancel the purchase of a good without having to give a reason at any time within the “cooling off period” of seven working days, beginning on the day after you receive the goods.

If you are in possession of the goods you are under the duty to retain them and take reasonable care of them. You must send the goods back to us to our contact address at your own cost (unles we delivered the item to you in error or the item is damaged or defective) as soon as possible once you have canceled the contract.

We reserve the right to make a charge not exceeding our direct costs of recovering the goods if you do not return the goods or return them at our expense.

Once you have notified us that you wish to cancel the contract, any sum debited to us will be refunded to you as soon as possible and in any event within 30 days of your cancellation.

You will not have any right to cancel a purchase for the supply of any of the following goods:

-for the supply of goods the price of which is dependent on fluctuations in the financial market which cannot be controlled by the retailer.

-for the supply of good made to your specifications or clearly personalised or which by reason of their nature cannot be returned or are liable to deteriorate or expire rapidly.

-for the supply of audio or video recordings or computer software if they are unsealed by you.for the supply of newspapers, periodicals or magazines.

-for gaming, betting or lottery services.

Conclusion

These terms are governed by Spanish law. Any contract for the purchase of goods from this site and any dispute or claim arising out of or in connection with any such contract will be governed by Spanish law. You and we both agree that the courts of Spain will have non-exclusive jurisdiction.