PRIVACY POLICY, DATA PROCESSING AND USE OF COOKIES

Effective May 25, 2018

Privacy Policy

Thank you for taking a few minutes to review the privacy conditions we apply to the data we collect on this website. The relationship with our clients and potential clients is based on honesty and transparency in order to build solid relationships and mutual trust.

Initiatives in Languages, S.L. and V.Iniciativas, S.L. (hereinafter, “Diverbo Group”) have adapted this website to the requirements of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 concerning the protection of natural persons (RGPD) in order to offer the highest legal guarantees in relation to your privacy.

1. IDENTIFICATION OF THE WEB SITE HOLDER

Those responsible for processing the data collected through this Website are:

Iniciativas en Idiomas, S.L., with C.I.F. number B-84813674 registered in the Mercantile Registry of Madrid on the sheet, M- 415199, volume 23168, page 10, section 8, 1st inscription, and V.Iniciativas, S.L. with C.I.F. number B-83318311 registered in the Mercantile Registry of Madrid on the form, M-303350, volume 17659, page 33, section 8, 1st inscription.

You can contact our Data Protection Delegate by writing to the address in Madrid, Calle Orense, 4, 7ª Planta, 28020 or by e-mail diverbo@diverbo.com.

Warning to minors

Children under the age of 16 who access this Website without the consent of their parents or legal guardians mustn’t register as a user. The present Web respects and takes care of the personal data of the users, guaranteeing their rights. For the processing of personal data in the case of children under 16, the consent of their parents or legal guardians is required.

2. FOR WHAT PURPOSE DO WE PROCESS YOUR PERSONAL DATA?

The personal data provided to Diverbo Group will be used to:

1. Enable the maintenance, development and management of the business relationship formalized by the contracting of products and / or services through this Website. The data processed for this purpose will be kept as long as this business relationship is maintained and, once it is finalized, during the preservation periods and the statute of limitations for legally stipulated liabilities.

2. To respond to requests for information and / or consultations made by the User. The data processed for this purpose will be kept during the conservation and limitation periods of legally established responsibilities.

3. Keep the User informed, including by electronic means, about the products, services and innovations of Diverbo Group. The data processed for this purpose will be kept until such time as the User withdraws his consent given through this Website.

4. In the case of sending a CV through this Website, the data provided by the User will be used to process your job application and, where appropriate, allow you to apply for a job at Diverbo Group. The data processed for this purpose will be retained until the User revokes their consent or until 24 months after receipt.

5. Communicate the User’s data to third organizations belonging to the digital and education sectors, in order that they may keep you informed, including by electronic means, about their products, services and news. The data processed for this purpose will be kept until the User revokes his or her consent.

2.1. What is the legitimization for the processing of your data?

The legal basis of the processing is the execution of the business relationship of which the User is a party. For the rest of the purposes described in this Privacy Policy, the legal basis is the User’s consent.

2.2. To which recipients will your data be communicated?

The data may be communicated to the following third-party recipients: Public Administrations for compliance with legal obligations.

They can also communicate with the following categories of managers: Providers of electronic communications and online office automation, hosting, SaaS services such as CRM / ERP, management, accounting, auditing and lawyers.
Diverbo Group may transfer the personal data to managers located in the United States of America who are members of the Privacy Shield, which has a decision to adapt from the European Commission (Execution Decision (EU) 2016/1250 of the Commission).

3. WHAT ARE YOUR RIGHTS WHEN YOU PROVIDE US WITH YOUR DATA?

In accordance with current regulations on data protection, the interested party may at any time exercise the rights of access, rectification, deletion, limitation, opposition or portability by email to diverbo@diverbo.com or by writing to Diverbo Group, in Calle Orense, 4, 7ª Planta, 28020 Madrid. In dealings where legitimization is based on consent, the User has the right to withdraw such consent at any time. The interested party shall have the right to submit a request to the supervisory authority.

We inform you that not providing the information requested may imply the impossibility of formalizing or fulfilling the purpose of the contract.

4. SOCIAL PLUGINS

On our Website there are links and services related to our different social networks. If you are a member of any of these social networks and click on the corresponding link, the provider of the social network may link your profile data with the information of your visit to said Website. Therefore, we recommend that you inform yourself about the functions and policies of the personal data processing of the respective social network in case you access one of our Websites with any of their profiles on social networks or share information through them.

In addition to familiarizing yourself with the privacy policies of the different social networks located on our Website, we recommend you learn how to set up your profile and guarantee your privacy. Below we provide the conditions of use of these social networks so you can consult them if you consider it necessary:

Facebook: Facebook: https://www.facebook.com/help/323540651073243/
Twitter: https://twitter.com/privacy
Instagram: https://help.instagram.com/155833707900388
Linked in: https://www.linkedin.com/legal/privacy-policy?_l=es_ES
Youtube: https://www.youtube.com/static?template=terms&hl=es&gl=ES

5. SECURITY MEASURES

In accordance with the provisions of the RGPD, the Diverbo Group informs you that it has implemented the necessary technical and organizational security measures to guarantee the security of your personal data and to prevent the alteration, loss and unauthorized processing and / or access of said data, taking into account the state of the technology, the nature of the stored data and the risks to which they are exposed, whether they come from human action or from the physical or natural medium.

Diverbo Group continuously maintains the supervision, control and evaluation of data processing to ensure the privacy of the information you provide us, thus establishing additional measures to strengthen the integrity and confidentiality of our system.

6. ANNOUNCEMENTS AND REMARKETING

With the information you provide, we try to improve our advertising and measurement systems in order to show you advertisements for our services that may be of interest to you. We create campaigns and ads using advertising platforms. When generating an ad, the audience can be segmented by:

• Location
• Demographic data (age, sex, etc.)
• Interests (activities, hobbies, etc.)
• What they buy online and through other channels
• etc.

From the moment in which the user registers to our subscription bulletin and supplies his or her data in the form of this Website, said data is subject to this privacy policy. The information coming from these platforms will not be used for a different purpose.

We inform you that we collect information to conduct remarketing campaigns through the use of social networks. The cookies from the pages of each platform are responsible for collecting this information, storing data of our ads for potential customers in our servers. You have at your disposal the information about the data that these cookies collect in the privacy policies of each service: Facebook, Google Adwords …

If you do not want your information to be collected, you can disable the use of such cookies. Here is a link to our Cookies Policy. In addition, through the disabling page of the Network Advertising Initiative, you can disable the use of cookies from a third party provider.

Cookie policy

This Website uses its own and third-party cookies in order to improve the services provided by analyzing browsing habits, advertising to manage advertising on this Website and to offer behavioral advertising. If you go on surfing, we will consider you accepting its use.

For the purposes of this policy, “continue browsing” means clicking on any button, check box or website link, downloading any content from it or scrolling up or down.

1. WHAT IS A COOKIE?

A cookie is a file that is downloaded to the User’s computer when it accesses certain websites, such as, for example, this one. Cookies allow such websites, among other things, to store and retrieve information about the user or the user’s browsing habits and, depending on the information they contain and the way in which the user uses his or her equipment, they can be used to recognize the user.

2. WHAT DO THE COOKIES DO?

Cookies do not identify you personally and do not pose any risk to your computer or mobile device. They are not viruses or spyware. They are simply tools used by the websites you visit to improve your browsing, so that your data travels through a secure network, to help us understand what information on our website is most useful to our users or to know what offers may be of interest to each user. And all in a totally anonymous way: we will never know your name, address or phone number unless you give them to us.

You decide if you allow cookies or not, but if you decide not to allow them, you must block them in your browser. Before blocking them, we want to help you better understand how cookies are used.

For example, at diverbo.es we use cookies:

• When you access your personal area, so that you do not have to type your username constantly.
• To know your interests for your next visit to our website so that we can adapt our content to you (all the content will be available equally but this way we will make it easier for you to get to what really interests you the fastest).
• Additionally, to offer you personalized content. You should also bear in mind that, if you decide not to allow the use of cookies by diverbo.es, some features of the website may not work correctly and, in addition, we will not be able to adapt the information we offer to your interests.

3. FOR HOW LONG ARE THE COOKIES ACTIVE?

Basically there are two types of cookies:

• For a session, which expire when you leave the page or close the browser; that is, they are active for the duration of your visit to our website. They are erased when you turn off the device.

• The permanent ones, which expire when the purpose for which they serve are met or when they are manually deleted. All have an automatic deletion date and are normally used in online purchasing processes, customization or in the registry, so as not to have to enter the password constantly.

4. WHY DO WE USE COOKIES ON THIS WEBSITE?

We use cookies for different purposes that are summarized in:

Analysis Cookies: They are those that, correctly handled by Iniciativas en Idiomas or by third parties, allow to quantify the number of users and thus perform measurement and statistical analysis of the use users make of the Website. For this purpose, navigation on the Website is analyzed in order to improve the offer of contents, products or services shown therein.

Advertising cookies: are those that allow the management, in the most efficient way possible, of the advertising space that, if applicable, the editor has included in a web page, application or platform from which the requested service is provided, based on criteria like the edited content or the frequency in which the ads are displayed.

Behavioral advertising cookies: These are those that allow the management, in the most efficient way possible, of the advertising spaces that, if applicable, the editor has included in a web page, application or platform from which the requested service is provided. These cookies store information on the behavior of users obtained through the continuous observation of their browsing habits, which allows the development of a specific profile from which display advertising can be based.

Specifically, this Website uses:

1. Google Analytics, analytical tool offered by the third party Google Inc., located in the United States of America. Google Analytics uses its own cookies to notify user interactions on the Website and for storing non-personal identification information.
2. Hotjar, analytical tool.
3. LinkedInAds, advertising tool.
4. Facebook Impressions, advertising tool.

5. HOW CAN I BLOCK OR ELIMINATE THE COOKIES USED BY THIS WEBSITE?

The User can allow, block or eliminate the cookies installed on his or her computer by configuring the browser options installed on his computer.

If the User does not want their data to be collected with Google Analytics, he or she can install an opt-out plugin for browsers.

Más información
https://support.google.com/analytics/answer/181881?hl=en&ref_topic=2919631.

The act of blocking the installation of the analysis cookies described in this policy does not impede the effective use of the Website by the User.

If the user decides they want to navigate with or without cookies, they can modify their preferences at any time.