Privacy Policy

Introduction

Torvannis S.A. ("we," "our," or "us") is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website, use our services, or interact with us.

By using our services, you agree to the collection and use of information in accordance with this policy. If you do not agree with our policies and practices, please do not use our services.

Data Controller Information

The data controller responsible for your personal information is:

Data Collection

We collect several types of information from and about users of our services. The data we collect includes:

Personal Information

• Name and contact information (email address, phone number, mailing address)
• Educational background and language learning goals
• Payment information and billing details
• Course enrollment and academic progress information
• Communications you send to us

Technical Information

• IP address and browser type
• Device information and operating system
• Website usage data and navigation patterns
• Cookies and similar tracking technologies

How We Use Your Information

We use the information we collect to provide, maintain, and improve our services. Specifically, how we use your information includes:

• Providing language education services and course materials
• Processing enrollments and managing your student account
• Communicating with you about courses, schedules, and important updates
• Processing payments and managing billing
• Improving our website and services based on user feedback
• Complying with legal obligations and protecting our rights
• Marketing our services to you (with your consent where required)

Legal Basis for Processing

Under GDPR, we process your personal data based on the following legal grounds:

• Contract Performance: Processing necessary for the performance of our educational services
• Legitimate Interest: Processing for our legitimate business interests, such as improving services
• Consent: Where you have given explicit consent for specific processing activities
• Legal Obligation: Processing required to comply with legal requirements

Cookies and Tracking Technologies

We may use cookies and tracking technologies for analytics, advertising, and remarketing purposes, including Google Ads. These technologies help us measure campaign effectiveness, deliver relevant advertisements, and improve our services. You can manage your cookie preferences at any time through our cookie consent banner.

For detailed information about the cookies we use, please review our Cookie Policy.

Information Sharing and Disclosure

We do not sell, trade, or otherwise transfer your personal information to third parties except in the following circumstances:

• With your explicit consent
• To service providers who assist us in operating our business
• When required by law or to protect our rights
• In connection with a business transfer or merger

All third parties we work with are required to maintain appropriate security measures and use your information only for the specified purposes.

Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this privacy policy, unless a longer retention period is required or permitted by law. Generally:

• Student records are retained for 7 years after course completion for educational purposes
• Marketing communications data until you unsubscribe or object
• Website analytics data for 26 months
• Financial records as required by Spanish tax law

Your Rights

Under GDPR and applicable privacy laws, you have the following rights regarding your personal data:

• Right of Access: Request copies of your personal data
• Right to Rectification: Request correction of inaccurate or incomplete data
• Right to Erasure: Request deletion of your personal data in certain circumstances
• Right to Restrict Processing: Request limitation of processing in certain situations
• Right to Data Portability: Request transfer of your data to another organization
• Right to Object: Object to processing based on legitimate interests or for marketing purposes
• Right to Withdraw Consent: Withdraw consent where processing is based on consent

To exercise these rights, please contact us using the contact information provided below.

Data Security

We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of sensitive data in transit and at rest
• Regular security assessments and updates
• Access controls and authentication procedures
• Staff training on data protection and security

However, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.

International Data Transfers

Your personal information may be transferred to and processed in countries other than your country of residence. When we transfer personal data outside the European Economic Area (EEA), we ensure appropriate safeguards are in place, such as:

• Adequacy decisions by the European Commission
• Standard contractual clauses approved by the European Commission
• Binding corporate rules or certification schemes

Children's Privacy

Our services are not intended for children under 16 years of age. We do not knowingly collect personal information from children under 16. If we learn that we have collected personal information from a child under 16, we will delete that information promptly.

If you believe we have collected information from a child under 16, please contact us immediately at privacy@torvannis.shop.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Last Updated" date.

We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.

Contact Information

If you have any questions about this Privacy Policy or our data practices, or if you wish to exercise your rights, please contact us:

You also have the right to lodge a complaint with the Spanish Data Protection Authority (Agencia Española de Protección de Datos) if you believe your data protection rights have been violated.