Privacy Policy

 

Principles on which the privacy policy is based in a very descriptive and visual way

 
OUR PRINCIPLES
 
Your privacy and the security of your data are our priority. It has always been and is part of our DNA. Therefore, we respect your privacy and your right to control your personal data. Here we show you the principles that we apply when using your data that govern our entire privacy policy.
 
  • Transparency:
We are 100% transparent with you regarding the data collected about you and we explain why we use them and for what purposes. We will not manage your data in an unexpected, obscure or abusive way. 
 
  •  Control:
You are the only one who can control the use with which your data is treated. We put at your disposal tools to decide at all times how you want us to treat your data, including when and how you can access and update your personal information 
 
  • Security:
We care about guaranteeing the security, secrecy and confidentiality of your data, communications and personal information. the most demanding and robust security measures have been applied to avoid their loss, alteration, misuse or access without your authorization.
 
 
Remember that you can always contact us by email at legal@siele.org. We will be happy to assist you and resolve any questions you may have. 
 

Basic information on the Privacy Policy of SIELE

  1. Who is responsible for managing your data as a user of SIELE?
    Telefónica Educación Digital S.L.U.
     
  2. What data do we manage about you?
    Data about who you are and how you use the services of SIELE.
     
  3. How do we obtain and where does the data come from? 
    Directly from you or the various public or private institutions with whom we have legal agreements.
     
  4. For what and why do we use your data? 
    So that you can enjoy the SIELE service and to inform you of the possibilities this service offers.
     
  5. How long do we keep your data?
    Five years after you stop using the service, as this is the validity of the SIELE certificate.
     
  6. Who has access to your data (besides Telefónica Educación Digital, S.L.U.)?
    Should you decide to take an exam, we will need to provide your data to the examination centres so you can be properly identified, and to the proprietary institutions for the issuing of the SIELE certificate.
     
  7. What are your rights and how can you control your data?
    Access, rectify and delete your data, as well as other rights and management options available.
     
  8. How do we use cookies and how can you manage them?
    We use our own and also third party cookies to give you a more personalized service and show you advertising related to your preferences and browsing habits. By using SIELE we understand that you accept them. 
     
  9. How do we protect your data?
    By using SIELE your data and personal information are limited and protected so that they have no impact on your private life. 
     
  10. What do you have to keep in mind especially when using SIELE?
    You can only use SIELE if you are over 16 years old. Get information on SIELE in our Terms and Conditions of Use.

Detailed information of the Privacy Policy and Cookies of SIELE

 
 1. Who is responsible for managing your data as a user of SIELE?
 
Summary:
 
Telefónica Educación Digital S.L.U is the Telefónica Group company responsible for managing your personal data as a user of SIELE.
 
Detail: 
 
The company responsible for managing your data as a user of SIELE: 
 
  • Name: Telefónica Educación Digital
  • CIF: B82857053
  • Address: Ronda de la Comunicación SN, Oeste 1, Planta 4, 28050 - Madrid
  • Email: legal@siele.org
  • Data Protection Officer: A/A D. Manuel Crespo -  DPO - Telefónica S.A. - Ronda de la Comunicación SN - 28050 Madrid 
 
2. What data do we handle about you?
 
Summary:
 
We have information about who you are and how you use the services of SIELE.
 
Detail: 
 
The information we have about you includes information about who you are and how you use the services of SIELE.
 
Who you are:
 
We ask you to provide information that allows us to address you properly, namely:
 
Name, surname(s) and title. City of residence, to know if you have a nearby SIELE Centre, as well as your email address and date of birth.
 
Should you decide to reserve an exam place, we need data that will allow you to identify yourself when taking the SIELE exam, and issue the resulting certificate.
 
In addition to the previous data, you will be asked for the type of document you bring to the exam, the number of said document, your nationality, level of studies and native language. In addition, as an exam control measure, we may take a photograph from the computer's webcam in order to prevent illicit practices in obtaining the certificate.
 
Finally, given that we issue an invoice for the SIELE services, we must complete it with the tax identification number, the billing address with town or city, postal code and country.
 
How do you use the services of SIELE:
In order to customize the services we offer you from SIELE, certain data from your use of the platform is recorded - for example: Includes when and where you use SIELE, how and how long you browse with it (e.g. what your device and your operating system are, the network where you connect, if you go for a long time without logging onto SIELE, etc.)]  
 
 
3. How do we obtain and where does the data come from? 
 
Summary:
 
It is mainly you who directly provides us with your data. If your data have been incorporated into SIELE from a collaborator, it is irrefutably assumed to be their responsibility to have obtained your permission to provide SIELE these data solely for the purposes of accessing SIELE services.
 
 
Detail: 
 
Mainly we obtain your data directly from you: 
 
  • You have provided them us directly, as we have mentioned, so these data are strictly necessary for the provision of the service.
  • Name, surname(s) and title. City of residence, to know if you have a nearby SIELE Centre, as well as your email address and date of birth.
  • Should you decide to reserve an exam place, we need data that will allow you to identify yourself when taking the SIELE exam, issue the resulting certificate and carry out the controls using the photographs from the webcam of the computer where you take the exam.
  • In addition to the previous data, you will be asked for the type of document you bring to the exam, the number of said document, your nationality, level of studies and native language.
  • Remember that the personal information you provide us directly must always be real, truthful and up-to-date. We put at your disposal the necessary tools so that you can update or modify these data. 
 
 
4. For what and why do we use your data? 
 
Summary:
 
We use your data to provide you with the service of  SIELE. we also use them for other legitimate purposes with the goal of communicating with you, knowing the use you give to SIELE or even complying with some legal obligations that are applicable to us. 
 
Detail: 
 
We manage your data to: 
 
  • That you can enjoy SIELE and all its functionalities (rendering the service).
  • Communicate and be in contact with you with the goal of informing you about the products and services that are relevant to you through various channels such as, for example, the email, SMS or the SIELE app. To be honest with you, our goal is that you download and register in SIELE (if you have not already done so), as well as that you are happy with the services SIELE, know them and use them actively.
  • Know how you use the products and services SIELE to:
    • Detect trends and correlations in order to understand and predict in an aggregate way the use of these services and the needs you may have as a user.
    • Make better business decisions, such as how to improve the products and services SIELE, as well as your experience, or how to make the communication actions that we indicated in the previous point more effective.
    • Prepare reports with added data on the evolution in the number of active users or how certain functionalities are used.
    • Check if you have performed a specific action through SIELE.
    • Monitor compliance with quality of service levels (eg to debug and detect errors).
    • Prevent and detect fraudulent, malicious or illegal activities (especially when this may affect other users). 
  • Conduct surveys in order to ask you and know your opinion about the SIELE or its services and functionalities.
  • Collaborate and respond to orders or requirements of the authorities.
  • Report or make known to the authorities fraudulent, malicious or presumably illegal actions.
  • Defend against lawsuits, complaints and / or claims of any kind.
  • Guarantee the physical security of the networks and the information technologies that we use to provide you with our services and products.
 
Lastly, it is possible that in the future we need to manage your data for additional purposes with the aim of continuing to innovate and offer you added value services.
 
Do not worry, in that case we will always analyze if these purposes are compatible with your expectations and with the principles that govern our privacy policy and cookies. 
 
In any case, we will previously take all necessary actions to ensure compatibility such as, for example, additional transparency, control or security measures. 
 
We use your data for the above purposes because:
 
  • We need them so that you can enjoy [name P & S] and its functionalities in accordance with its conditions of use.
  • We need them to comply with certain legal and regulatory obligations (eg, obligation to collaborate and respond to the requirements of the authorities).
  • Some of the purposes are necessary for the legitimate business interests of Telefónica Educación Digital S.L.U., although you can always oppose them (eg, communicate and be in contact with you to inform you about products and services SIELE).
  • Because you have given us your permission for us to process your data for certain purposes (eg, those permissions you grant us during registration so that we can access information about your device). 

 

5. How long do we keep your data?
 
Summary:
 
There are certain reasons that legitimize us to conserve your data, although we will only conserve and manage them as long as they are necessary for the purposes indicated in point 4 of this policy. The specific conservation period will depend on the type of data and for what and why they are used. 
 
Detail: 
 
In general, we will no longer keep your data at the time it is not necessary to continue providing you with the service of SIELE. However, there are some exceptions to this general rule that we explain below.
 
In this matter, there are some purposes that persist and continue even after the removal of SIELE account. Specifically, we must continue to keep some information about you and how you used SIELE to: 
 
  • Have a history of how you used SIELE.
  • Comply with certain legal data conservation obligations applicable to Telefónica Educación Digital S.L.U.
  • Collaborate with the authorities and respond to their information requirements.
  • Defend against lawsuits, complaints and / or claims.
  • Prevent fraud, abuse or illicit actions.
  • Test and verify that you had a user account in SIELE.
 
However, during this additional period we will apply a series of additional measures and actions to ensure the protection of your information and your privacy. This type of measures may include, for example, the functional separation, pseudonymization, and / or encryption of your data and information.
 
Also, we will take all reasonable measures to ensure that your data is rectified or deleted when inaccurate.
 
6. Who has access to your data (besides Telefónica Educación Digital S.L.U.)?
 
Summary:
 
Besides Telefónica Educación Digital S.L.U, others who have access to your personal data are: our suppliers and collaborators, other companies of the Telefónica Group, as well as the authorities with whom we collaborate and interact. The access to your data that we provide to these third parties is always for lawful purposes and only during the period of time strictly necessary for it. 
 
Detail: 
 
We need to share your data with certain third parties that we indicate below, always in relation to the specific purposes for which we treat your data, described in point 4, and for a period strictly necessary for it.
 
Specifically, this involves giving access to your data to:
 
  • Our suppliers and collaborators, as well as the companies that they subcontract, which help us to provide the services of SIELE, to communicate and be in contact with you, as well as to conduct surveys and to know how you use SIELE. Some of these providers and collaborators may be able to process your data from the United States, and in such cases and to the extent that they involve a transfer of your data to that country, their services, infrastructure, systems, and/or tools will always be contracted by Telefónica Educación Digital S.L.U. after demanding the maximum and most appropriate guarantees applicable in each case in accordance with European regulations.
  • Other Telefónica Group companies, with an internal administrative and commercial management purpose, so that companies can communicate and contact you with information about products, promotions, offers and / or services.
  • In the event that in order to obtain a certification, you take the exam in a country outside of the European Economic Area, we must transfer your data to the manager of the exam center in that country to facilitate your access to the center and the corresponding identification, all based on the execution of the contract you have with us.
  • Authorities (eg, security forces and state security forces or judicial bodies), national and / or international, that require legal access to your information, as well as, those other Authorities with whom we need to share your information to defend ourselves against possible lawsuits, complaints and / or claims of any kind, as well as to bring to your knowledge fraudulent, malicious or allegedly illegal actions.  
 
In any case, Telefónica Educación Digital S.L.U. always guarantees the highest level of protection during the access that these third parties have to your data and information, for example, reaching data management agreements with them or through the establishment of measures of appropriate protection to ensure confidentiality and secure treatment of your data. 
 
 
7. What are your rights and how can you control your data?
 
Summary:
 
The regulations give you a series of rights regarding the data and information that we manage about you. Specifically, the rights of access, rectification, deletion, limitation, opposition, portability, as well as not being subject to automated decisions and to remove your consent at any time. 
 
Detail: 
 
You can perform the following data protection rights against Telefónica Educación Digital S.L.U.:
 
  • Access right: right to request the details of the data we have about you and how we treat them, as well as obtaining a copy of them.
  • Right of rectification: right to obtain the rectification of your inaccurate or erroneous data, as well as to complete those that are incomplete.
  • Right of removal: right to request the elimination or deletion of your data and information under certain circumstances. However, keep in mind that there are certain occasions in which Telefónica Educación Digital S.L.U. is legally entitled to continue to keep and process your data (eg, for compliance with a legal obligation to conserve data).
  • Right of limitation: right to restrict or limit the management of your data in certain circumstances (eg, if data deletion applies but, instead of eliminating them, you prefer that we block them and handle them only for the purpose of their preservation since you will need them later to file a claim). Again, keep in mind that there may be times when Telefónica Educación Digital S.L.U. is legally entitled to reject your limitation request.
  • Right of opposition: right to oppose Telefónica Educación Digital S.L.U. to manage your data for a specific purpose, in certain circumstances provided in the regulations and related to your personal situation. 
  • Right to data portability: right to receive your data in a commonly used format that allows you to transport them to another company, as well as, if applicable, to request Telefónica Educación Digital S.L.U. direct transmission to another company if it is technically possible. Remember that the right to data portability is different from the right to portability of your phone number. 
  • Right to not be the subject of automated decisions: the right to oppose being the subject of a decision based solely on the automated processing of data (without human intervention), including the preparation of profiles, which produces legal effects on you or affects you from a meaningful way. 
  • Right to remove consent at any time: right to remove your consent at any time to the management of your data for a specific purpose, when based on legitimating basis. 
 
You can check the full scope and detail of these rights on the website of the Spanish Data Protection Agency (SDPA) here. 
 
In general, you will be able to execute all these rights (at any time and for free) by writing to the privacy team of Telefónica Educación Digital S.L.U.at legal@siele.org.
 
For this, it is important to bear in mind that: 
 
  • When you exercise a right, you must provide a copy of your official identity document (Example: DNI, NIE or Passport) and, if possible, send your request from the same email address that you used to register with SIELE.
  • In the event that you decide to exercise one of these rights through a representative, it will be necessary to provide in the application, the documentation proving this condition (Example: in the case of a voluntary representative, the power of representation in which shows the powers that allow the exercise of such rights in your name).
  • The requests for the exercise of rights must be as specific and detailed as possible, indicating in them the specific right that you wish to exercise. 
 
However, you can exercise your right to oppose the receipt of commercial communications, by any channel, from Telefónica Educación Digital S.L.U., just send us an email to legal@siele.org. 
 
Lastly, remember that you also have the right to file a complaint with a Data Protection Control Authority (eg, the Spanish Data Protection Agency, whose contact information you can consult it here), especially if you estimate or understand that Telefónica Educación Digital S.L.U. has not correctly fulfilled the exercise of your data protection rights. 
 
 
8. How do we use cookies and how can you manage them?
 
Summary:
 
Telefónica Educación Digital S.L.U. uses own and third-party cookies to give you a more personalized service, to know how you use the services and products of SIELE and, where appropriate, to show you advertising related to your preferences and browsing habits. If you use SIELE we understand that you accept its use. 
 
Details: 
 
A cookie is a file that is downloaded to your device when accessing certain web pages and / or applications. Cookies allow, among other things, store and retrieve information about your number of visits, browsing habits or the type of device and, depending on the information they contain and the way you use it, they can be used to recognize you as a user.
 
Please note that in order to use SIELE it is necessary that you have cookies enabled, especially those of a technical nature that are necessary for Telefónica Educación Digital S.L.U. to identify you as a registered user each time you access our website or application. Telefónica Educación Digital S.L.U. uses the following types of cookies, which are treated either by us directly or by collaborating third parties:
 
  • Technical cookies: These are those used by Telefónica Educación Digital S.L.U. that allow the user to navigate and use the different options or services offered, such as controlling traffic and data communication, identifying the session, access restricted parts, remember the items that are in an order, perform the purchase process of an order, make the registration request, use security elements during navigation or store, disseminate and / or share content.
  • Personalization Cookies: Those used by Telefónica Educación Digital S.L.U. that allow the user to access SIELE with some predefined general characteristics based on a series of criteria in their device, such as language, the type of browser, the regional configuration from where you access, etc.
  • Analysis Cookies: These are those used by Telefónica Educación Digital S.L.U. and by third parties (GOOGLE ANALYTICS, GOOGLE TAG MANAGER, GOOGLE FIREBASE, AKAMAI, COMSCORE, MIXPANEL, HOTJAR, HOCKEY APPS and HUBSPOT) that allow quantifying the number of users and thus perform the measurement and statistical analysis of the use and activity that users do, as well as develop navigation profiles to be able to introduce improvements in products and services of SIELE.
  • Advertising and behavioral advertising cookies: These are those used by Telefónica Educación Digital S.L.U. and by our collaborators who manage the spaces that serve advertising of Telefónica Educación Digital S.L.U.  (APPSFLYER, PUBMATIC, ADSRVR, RUBICON PROJECT, SMAATO, CONNEXITY , TURN, SIMPLIFI, AFFILINET, BING ADS, BLUEKAI, DOUBLECLICK, YOUTUBE, CRITEO, MOVISTAR, GOOGLE, YAHOO, FACEBOOK, TWITTER, ROCKETFUEL, MEDIAMATH, SMART, APPNEXUS, OPENX, ADGRAVITY, SMARTCLIP, ADFORM, HUBSPOT, CRAZY EGG, PLATFORM161 , ROCKET FUEL and / or THE TRADE DESK) that allow us to disseminate adequate and relevant advertising, measure the effectiveness of our online campaigns, as well as adapt the content of the ads to the navigation profile of each user on the Internet.
 
Remember that you can allow, block or delete these cookies at any time through the configuration options of your device or terminal, as well as your internet browser. To do this, you can find the most up-to-date support information on these devices or browsers to know how you can eliminate cookies, since the way to do it can be different between different versions and operating systems. As an example:
 
  • For Internet Explorer, click here
  • For Mozilla Firefox, click here
  • For Google Chrome, click here
  • For Safari, click here
 
In case you use any other Internet browser, we recommend that you look for the different cookie management options that may be available, as well as, in general, any other tools available in the market for the blocking and / or administration of cookies (eg, Ghostery or Disconnect)
 
For more information, you can write to us at legal@siele.org
 
 
9. How do we protect your data?
 
Summary:
 
Telefónica Educación Digital S.L.U. guarantees the security, secrecy and confidentiality of your data, communications and personal information adapted to the most demanding and robust security measures, and putting at your disposal tools and functionalities that allow you to control access to your SIELE account. 
 
Detail: 
 
Telefónica Educación Digital S.L.U. is responsible for ensuring the security, secrecy and confidentiality of your data, communications and personal information. Therefore, as part of our commitment and in compliance with current legislation, we have adopted the most demanding and robust security measures and technical means to prevent their loss, misuse or access without your authorization.
 
Also, we promise to act quickly and responsibly in the event that the security of your data may be in danger, and to inform you if necessary.
 
 
10. What do you have to keep in mind especially when using SIELE?
 
Summary:
 
You Have to keep in mind certain aspects related to the minimum age of use of SIELE, the quality of the data you provide us, as well as the removal of your user account.
 
Detail: 
 
We recommend that you pay special attention to the following when registering and using SIELE:
 
  • Minimum age of use: in order to register and use SIELE you must be over 13 years old or have the authorization of your parents and / or legal guardians. Therefore, by signing up for SIELE, you guarantee to Telefónica Educación Digital S.L.U. that you are older than that age or, otherwise, that you have the proper authorization. We can contact you at any time to verify if you meet this condition. 
  • Quality of the data you provide: your personal data, mobile phone number and other information that you provide us with in the registration and / or use of the services of SIELE must always be real, accurate and up-to-date. We provide you with the necessary tools and options to control and update your personal information (eg, through the "Personal information" section of your profile in the app or by contacting us at legal@siele.org).
  • Removal of your user account: in general, there may be two situations in which the technical deactivation of your user account is carried out: 1) that you voluntarily request us to proceed to unsubscribe your user account in SIELE as explained in point 7 of this policy, and 2) that from  Telefónica Educación Digital S.L.U. proceed to the technical deactivation of your user account (eg, in cases in which we detect that you have breached the conditions of use of the service). In case of removal, you will lose the information and data that you may have in [name P & S], as well as the right to use any benefits or services that you may have had at the time of removal and / or have previously contracted as a user of SIELE.  
 
 
Date version 16/09/2020