Privacy Policy
1. Data controller
- Owner: Elena Glintchevskaia Glintchevskaia
- Tax ID (NIF): 02301550D
- Trading name: HTL Escuela de Empresa Online
- Address: Carrer Diputación 282, 08009 Barcelona, Spain
- Email: practicas@htlescueladeempresaonline.com
- Phone: +34 93 14 15 199 · +34 654 893 748
- Data Protection Officer (DPO): none appointed — the activity does not fall within the cases of GDPR Art. 37. For any data-protection matter, please use the contact details above.
2. Data we process
- Identification: first name, last name, date of birth, nationality, ID document (DNI/NIE/passport).
- Contact: email, postal address, phone.
- Academic: enrolled course, chosen language, Moodle progress, grades, certifications.
- Billing: company name, tax ID and fiscal address (for company customers).
- Payment: we do not store card data. Payments are processed directly by Stripe or PayPal.
- We do not process special categories of data (health, racial origin, political opinions, etc. — GDPR Art. 9).
3. Source of data
Data is collected directly from you when you fill in our forms. For enrollment via a corporate pack, some identification data may initially be provided by your employing company, which acts as the entity handling your registration.
4. Minimum age
This service is intended for users aged 18 or over. Stripe and PayPal require full legal age to use their payment methods, and signing the internship agreement requires full contractual capacity. Users aged 14 to 17 may only enrol in person, with written authorisation from the holders of parental authority.
5. Purposes of processing
- Manage your enrollment and internship agreement (convenio).
- Create and maintain your Moodle account.
- Issue invoices and meet tax and accounting obligations.
- Issue enrollment and completion certificates.
- Academic communications (reminders, deadlines, course completion).
- Live chat support (only if you opt in).
6. Legal basis
- Contract performance (GDPR art. 6(1)(b)): your enrollment is a contract for educational services.
- Legal obligation (art. 6(1)(c)): invoice retention under Spanish General Tax Law 58/2003 art. 66.
- Consent (art. 6(1)(a)): for non-essential cookies and, where applicable, marketing communications.
- Legitimate interest (art. 6(1)(f)): platform security and fraud prevention.
7. Consequences of not providing the data
The data requested is necessary to formalise your enrollment, issue invoices and manage the internship agreement. If you do not provide it, we cannot deliver the service.
8. Processors
We have data processing agreements (GDPR Art. 28) in place with the following providers:
- Stripe Payments Europe Ltd. (Ireland, with processing in the USA) — card payments.
- PayPal (Europe) S.à r.l. (Luxembourg, with processing in the USA) — PayPal payments.
- SignaturIt Solutions S.L. (Spain) — electronic signature of internship agreements.
- tawk.to inc. (USA) — live chat, only if you accept optional cookies.
- Raiola Networks S.L. (Spain) — web and Moodle hosting.
9. Disclosures to third parties
- Bank — to process wire transfers.
- Public authorities — Spanish Tax Agency and other bodies when required by a statutory rule.
10. Joint controllership (enrollment via company)
When a company enrols students through a corporate pack and views their progress from its company area, the company and the controller act as joint controllers for the academic data visible to the company, in accordance with GDPR Art. 26. The relationship is governed by the agreement signed with the contracting company.
11. International transfers
Transfers to the United States (Stripe, PayPal, tawk.to) rely on Commission Implementing Decision (EU) 2023/1795 of 10 July 2023 on the adequate level of protection under the EU-US Data Privacy Framework and, additionally, on Standard Contractual Clauses approved by the European Commission.
12. Retention period
- Active account: while the contractual relationship lasts.
- Invoices and tax data: 6 years from issuance (Spanish General Tax Law 58/2003 art. 66).
- Academic data and certificates: 5 years from course completion. After that period we keep only what is strictly necessary to issue duplicates on request.
- Cookie consent log: 3 years from the last user action.
- Browser cookies: see Cookie Policy.
13. Your rights
You can exercise the following rights by emailing practicas@htlescueladeempresaonline.com or by postal mail to our address, including a copy of your ID document:
- Access: know what data we hold about you.
- Rectification: correct inaccurate data.
- Erasure ("right to be forgotten"): delete your data when no longer necessary.
- Restriction: limit processing in certain cases.
- Objection: object to legitimate-interest-based processing.
- Portability: receive your data in a structured, commonly used format.
- Withdraw consent at any time (without retroactive effect).
You have the right to lodge a complaint with the Spanish Data Protection Agency (AEPD):
- Website: www.aepd.es
- Address: C/ Jorge Juan 6, 28001 Madrid, Spain
- Phone: 901 100 099 · 912 663 517
14. Automated decisions
We do not perform automated decision-making with legal effects concerning you or individual profiling. Internal progress statistics are aggregated and used solely to improve the service.
15. Marketing communications
We do not send marketing communications by email except with your express consent (Art. 21 of Spanish Law 34/2002 LSSI-CE). You may withdraw it at any time using the unsubscribe link in each message or by writing to the contact address.
16. Changes to this policy
If we modify this policy, we will notify you by email and ask for fresh consent where required. A version history is available on request.