Privacy policy
Whenever we need information from you, we always ask you to provide it voluntarily. Data collected through the forms on this website is treated confidentially and used solely to provide the service you have requested, with the safeguards required by Regulation (EU) 2016/679 on data protection and Spanish Organic Act 3/2018 of 5 December.
Who the data controller is
- Controller: Giampaolo Sponza
- Tax number: ES-X2284747L
- Address: Calle Montejurra, 25-5A – 28017 Madrid (Spain)
- Email: info@giampaolosponza.com
No data protection officer has been appointed, as none of the circumstances set out in Article 37 of the Regulation applies. For any question about your data, you can write directly to the address above.
Why we process your data
We process information fairly, lawfully and transparently. Depending on your relationship with us, the data and purposes are as follows.
If you are a client or user, we process identification data (name and surname), contact data (email, telephone) and whatever you yourself provide in the form, in order to:
- Reply to your enquiry and handle the services or information you ask for.
- Handle course purchases and deliver the material to you.
- Comply with legal obligations, in particular tax and accounting ones.
If you are a supplier, we process identification, contact and invoicing data in order to manage the commercial relationship and meet administrative, accounting and tax obligations.
No automated decisions are taken and no profiling is carried out with your data. No commercial communications are sent unless you have expressly authorised them.
What happens with payments
Card payments for the courses are made entirely through the Stripe Payments Europe, Ltd. gateway. This website never receives, sees or stores your card details. If you choose to pay by bank transfer, the payment details are known only to your bank and to the account holder.
Do you have to provide your data?
Only the data strictly necessary for the purpose for which it is collected is requested. If you do not provide it, the requested service cannot be provided.
How long we keep your data
Data is kept for a maximum of five years from the last confirmation of interest, or for as long as a legal obligation requires. After that period it is duly blocked and deleted once it is no longer needed. Purchase records are kept for the period required by tax legislation.
The legal basis for processing
In accordance with Article 6.1 of Regulation (EU) 2016/679, the legal basis is as follows:
- Your consent, when you write to us through the contact form.
- Performance of a contract, when you buy a course.
- Compliance with a legal obligation applicable to the controller, in tax and accounting matters.
- The legitimate interest of the controller, provided your fundamental rights and freedoms do not override it.
Who your data is shared with
Your data is not passed on to third parties except where a legal obligation requires it. In order to operate, the controller relies on providers who access the data as processors, under a contract complying with Article 28 of the Regulation: the website hosting company, the Stripe payment gateway and, where applicable, the accountancy and tax firm. None of them uses the data for their own purposes.
Your rights
You may exercise your rights of access, rectification, erasure, restriction of processing, objection and portability at any time and free of charge, and withdraw any consent you have given. Simply write to info@giampaolosponza.com or to the address above, enclosing a copy of your identity document.
If you believe that your data is not being processed in accordance with the law, you may lodge a complaint with the Spanish Data Protection Agency (www.aepd.es).
Security
The controller applies the technical and organisational measures needed to protect your data against loss, misuse or unauthorised access. The website runs entirely over an encrypted connection.