BASIC INFORMATION
Responsible for the treatment	Ditto Education, S.L. B72848948
	Avenida Madariaga 1, 3º. Bilbao 48014 TI@ditto.education
Purposes of the processing of personal data	– Manage and maintain the business relationship and allow access to the application. – Respond to requests for information. – To send commercial communications of our own or of third parties, always through Ditto.
	Retention periods: The data will be kept as long as the contractual relationship is maintained, as long as the deletion is not requested by the interested party, or they should not be deleted because they are necessary for the fulfillment of a legal obligation or for the formulation, exercise and defense of claims.
Origin	– Facilitated by the user himself. – Obtained from the minor’s legal guardian or custodian.
Basis Legitimacy	– The execution of the contract with the user. – Ditto’s legal obligations – Ditto’s legitimate interest. – The user’s consent.
Assignment recipients	All are necessary for the fulfillment of the aforementioned purposes, or are carried out in compliance with a legal obligation. Public administrations, suppliers for the provision of the requested services, companies and collaborating entities.
Rights of Participants	They may be exercised by e-mail: TI@ditto.education, or at Ditto’s registered office: Avenida Madariaga 1, 3º. 48014, Bilbao.
	We inform you that you may exercise, where appropriate, the rights of access, rectification or deletion, limitation of processing, opposition, to data portability or not to be subject to a decision based solely on automated processing, as well as to withdraw the consent given.
	You may file complaints with the Spanish Data Protection Agency: www.aepd.es, the Spanish Data Protection Supervisory Authority.
	More information can be found in the full Privacy Policy in this document.

1. Who is the data controller?

Ditto Educación, S.L. is responsible for the processing of your personal data for the purpose of providing you with the services identified in this privacy policy.

Ditto Educación, S.L. is a company located at Avenida Madariaga 1, 3º. 48014, Bilbao, and its Tax ID number is B72848948 (hereinafter, «Ditto«).

At Ditto we are committed to the fundamental right to the protection of your personal data and this privacy policy is intended to inform you of your rights under the General Data Protection Regulation («GDPR«).

What information do we process?

a) The data you provide directly to us:

We collect information about you when you contact us through the channels provided for this purpose, or register you in our application.

All fields marked with an asterisk (*) in the forms provided to you in the channels must be completed, so that the omission of any of them could result in the impossibility to provide you with the requested services. You must provide truthful information, being prohibited the impersonation or use of aliases or anonymous names.

It is essential that you safeguard at all times your reference data, passwords and access codes that you generate. You are solely responsible for the use of your personal account, and in this regard you agree to make diligent use of such information, not to make it available to third parties, and to notify us without delay of its loss or theft.

To ensure that the information provided is always up to date and contains no errors, you must inform Ditto as soon as possible of any changes to your personal data.

Likewise, by clicking on the «I accept» button (or equivalent) incorporated in the aforementioned forms, you declare that the information and data you have provided in them are accurate and truthful.

b) Data obtained indirectly:

When you browse, various cookies and other tracking devices may be installed on your device, as explained in our Cookie Policy.

3. What is the origin of the data?

We consider that all data processed by Ditto is freely provided by you.

In the event that the personal data provided is that of a third party, you warrant that you have informed them of this Privacy Policy and have obtained their authorization to provide the data to Ditto for the purposes outlined above. Likewise, you guarantee that the data provided are accurate and up to date, and you are responsible for any damage or loss, direct or indirect, that may be caused as a result of the breach of this obligation.

4. For what purpose and on what legitimate basis do we process the data?

Ditto is responsible for the processing of personal data for the following purposes and in accordance with the following legitimate bases:

• Based on the management of the contractual or pre-contractual relationship:
  
  a) To manage your registration as a registered user on our website, as well as to allow your access to the application and manage your profiles and contents.
  b) To provide you with the services you have requested from us and to attend to your requests for information, as well as to facilitate the exercise of your rights.
  c) To facilitate the management of the payments for the contracted services and to provide the same to you.

• Based on Ditto’s compliance with its legal obligations:
  
  a) Allow users to exercise their rights.
  b) Comply with the regulations applicable to Ditto.

• Based on the explicit, free and unequivocal consent that, if applicable, you give us at the time of collecting your data.:

  a)

  Where appropriate, to keep you informed about our own or third party products and services, always sent through Ditto by electronic means.

• Based on the existence of a legitimate interest on the part of Ditto:

  a)

  Keep you informed about Ditto’s products and services, related to those previously contracted and that may be of interest to you.
  b) Conduct periodic reviews of our services and carry out satisfaction surveys to evaluate and improve the quality of the service we provide.

5. To whom is the data communicated?

All transfers of personal data that we make are necessary for the fulfillment of the stated purposes, or are made to comply with a legal obligation:

a) To the public administrations and the administration of justice, and to the security forces in compliance with the legal obligations applicable to us.

b) Payment service providers (banks, payment gateways, etc.), in the event that the customer makes a payment through the service offered by one of these companies.

c) Companies providing IT services, tools or IT infrastructure on which the services provided by Ditto are based, such as hosting providers, CRMs, emailing service companies, etc.

In this regard, we inform you that any transfer that occurs will be made taking into account all the necessary legal safeguards. We also ensure that we sign specific contracts with all our service providers in accordance with the regulations.

Likewise, Ditto guarantees that in the case of suppliers located in countries outside the European Union or other countries not considered adequate in accordance with data protection regulations, the necessary precautions are taken to ensure that the data can be transferred securely, either because the supplier offers adequate guarantees, through, among others, the signing of Standard Contractual Clauses of the European Commission, or because any of the exceptions included in the regulations are complied with.

6. Exercise of your rights.

We inform you that you may exercise the following rights:

1. Right of access to your personal data to know which are being processed and the processing operations carried out with them.

2. Right to rectify any inaccurate personal data.

3. The right to have your personal data deleted, when possible.

4. The right to request the limitation of the processing of your personal data when the accuracy, lawfulness or necessity of the data processing is in doubt, in which case, we may retain the data for the exercise or defense of claims.

5. Right to object to automated decision making, including profiling.

6. Right to object to the processing of your personal data when the legal basis that enables us to process it, in accordance with paragraph 4 above, is legitimate interest.

7. Right to the portability of your data, when the legal basis that enables us to process it of those indicated in paragraph 4 above is the existence of a contractual relationship or your consent.

8. Right to revoke consent given to Ditto.

You may exercise your rights at any time and free of charge in the following ways:

1. By sending an email to TI@ditto.education using the email address you used to register for our services and indicating the right you wish to exercise.
2. By sending a written request to the address Avenida Madariaga 1, 3º. 48014, Bilbao, indicating the right you wish to exercise.
3. In addition, when you receive any communication from us, by clicking on the unsubscribe section that will contain that communication, you will be able to unsubscribe from all previously accepted commercial communications.

When you exercise your rights, and only if we have doubts about your identity, we may ask you for additional information to verify your identity.

We also inform you that you have the right to file a complaint with the Spanish Data Protection Agency if you consider that we have committed a breach of data protection legislation with respect to the processing of your personal data.

In addition, we inform you that you can join the Robinson List at www.listarobinson.esThe system of advertising exclusion managed by the Spanish Association of Digital Economy (ADIGITAL), in which you can register in order to show your opposition to the use of your data for the purpose of sending you commercial communications.

7. Time of conservation of your data.

We will only keep your information for as long as it is necessary to provide you with these services. Any of the data you provide through the channels will be blocked as long as they are no longer necessary to manage the service and will only be available in case there is a legal obligation (derived from a request of the State Security Forces or Courts and Tribunals) as well as when you exercise your rights.

8. Security and confidentiality.

In order to prevent unauthorized access to or unauthorized disclosure of personal data, we have taken appropriate technical and physical measures and management processes to safeguard and secure the information we collect from you.

9. Minors

The application is designed for minors from 0 to 9 years of age, so all procedures are intended to be carried out by their legal guardians or those who have parental authority. While Ditto does not directly collect data from children and has no need for such data, it is possible that their legal guardians or custodians may enter some data on the platform (for example, the child’s name on a profile) and are responsible for the data they enter.

10. Update of the privacy policy.

We make our best efforts to keep our privacy policy fully updated. If we make changes, these will be clearly identifiable in a clear and specific manner, as possible in the relationship we have established with you (e.g., we may communicate changes to you by email).

This privacy policy has been revised and posted as of June 16, 2022.

Ditto Education, S.L.