Serveis Lingüístics de Barcelona, SCCL run the websites www.slb.coop and the online learning platform learn.slb.coop. In this policy, “we”, “us” and “our” refer to Serveis Lingüístics de Barcelona, SCCL.
We are committed to safeguarding the privacy of our website visitors and service users. We respect that your privacy is important to you and we are committed to only use your data with your permission and for purposes consistent with the services we offer you.
This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
Credit: This document was created using a template from SEQ Legal (https://seqlegal.com)
1. What data do we collect?
Some data will be collected automatically by our sites, while other data will be collected only if you voluntarily submit it and consent to us using it for the purposes set out in section 5, for example, when signing up for our mailing list, applying to join the cooperative or buying a product from learn.slb. Depending upon your use of our sites, we may collect some or all of the following data:
- Email address;
- Email preferences;
- Statements of interest in joining SLB;
- Your CV;
- Payment information;
- IP address (automatically collected);
- Geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics.
2. How we use your data
We use your data to provide you with information that you have stated is relevant and of interest to you. This includes:
- Links to new blog posts
- Information about upcoming events
- Information about products and services we offer, including courses and membership
- Responses to comments on the blog
- Displaying your avatar on the blog
- Reducing spam comments on the blog
- Analysing your use of our sites to enable us to continually improve our sites and your user experience
Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. The legal basis for this processing is consent; our legitimate interests, namely the proper administration of our website and business; and/or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.1 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
2.2 We may process your account data (“account data“). The account data may include your name and email address. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you.
2.3 We may process your information included in your personal profile on our website (“profile data“). The profile data may include your name, email address, profile pictures, date of birth and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services.
2.4 We may process your personal data that are provided in the course of the use of our services (“service data“). The service data may include your name, address, telephone number, email address, profile pictures, date of birth and employment details. The source of the service data is you or your employer. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you.
2.5 We may process information that you post for publication on our website or through our services (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering our website and services.
2.6 We may process “enquiry data“. The enquiry data may be processed for the purposes of offering relevant goods and/or services to you, including membership of our cooperative.
2.7 We may process information relating to our customer relationships, including customer contact information (“customer relationship data“). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers.
2.8 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our websites (“transaction data“). The transaction data may include your contact details, your card details and the transaction details. We use Stripe for processing payments. Transaction data is sent directly to Stripe and is not stored by us (see section 3 below).
2.9 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters.
2.10 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our websites will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping.
3. Providing your personal data to others
3.1 We do not share any of your data with third party organisations other than in private accounts that we manage, e.g. MailChimp, used to send emails and messages to subscribers, and Stripe, used for payments.
3.2 Financial transactions relating to our websites and services are handled by our payment services providers, Stripe. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at https://stripe.com/es/privacy.
3.3 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4. Retaining and deleting personal data
4.1 This Section 4 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
4.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
4.3 We will conduct regular reviews and delete your data if we ascertain that we no longer need it.
4.4 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
5.1 We may update this policy from time to time by publishing a new version on our website.
5.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
5.3 We will notify you of significant changes to this policy by email or by asking for your consent when you visit our sites again.
6. How can you control your data?
6.1 We aim to give you strong controls on our use of your data, including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails.
8. Your rights
8.1 In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
8.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
8.8 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means;
you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
8.9 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
8.10 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
8.11 You may exercise any of your rights in relation to your personal data by written notice to us.
10. Our details
10.1 This website is owned and operated by Serveis Lingüistics de Barcelona, SCCL
10.2 We are registered in Spain with the CIF F6620785, and our registered office and principal place of business is at C/ Bruc 168, MG Coworking, Barcelona 08013, Spain
10.3 You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form at https://www.slb.coop/contact-us/
(c) by email, using firstname.lastname@example.org