Date: August 2020
We shall use the personal data gathered via this Website solely in accordance with the provisions of the Policy. Below is information regarding how we use your personal data, for what purposes, whom we share your data with and your rights in relation to your data.
1. Summary of our data processing activities
The following is a summary of the data processing activities carried out on our Website. You will find more detailed information in the sections indicated below.
- When you visit our Website to seek information without opening an account, your personal data will only be processed to enable your access to the Website (section 3).
- If you register for one of our services (e.g. the education website), more personal data will be processed to enable the provision of said services (sections 4 and 5).
- Your personal data will also be used for statistical analysis to help improve our Website (section 6). We also use third party content to improve your experience of the Website (section 8).
- Your personal data may be shared with third parties (section 9).
- We have implemented appropriate security measures to protect your personal data (section 10) and we will only hold your personal data for as long as is necessary (section 11).
- In accordance with the applicable legislation, you may exercise certain rights with respect to your personal data (section 12).
- Personal data: Any information related to a natural person that may directly or indirectly identify them, in particular their name, an ID number, an address or an online identifier.
- User: The owner of the data.
- Processing: Any operation carried out using personal data, such as obtaining, registering, organising, structuring, storing, adapting, disseminating it in any way or any other use.
- Controller: The person who determines the purposes and methods of processing the user’s data prior to obtaining their consent and is responsible for ensuring compliance with the General Data Protection Regulation (GDPR).
- Consent: Any free, unequivocal, specific and informed declaration of will by which the user consents to the processing of their data.
- Processor: The legal person, public authority, service or other body which provides a service to the Controller involving the processing of personal data by them.
- Third parties: Any natural or legal person who is not part of MacMillan or BQ Educación and who is not the user.
3. Use of the Website for information
When you visit our Website for information purposes, i.e. without registering for any of our services set out in section 4 and without providing any other form of personal data, we may automatically collect additional information about you which contains personal data in limited cases which our server automatically recognises. This includes the following:
– your type of device (PC or mobile),
– device model
– date and time of your requests
– content of your requests
– information about your browser version
– information about your operating system, including the language configuration
– location of your connection
We use this information solely for providing an effective service (e.g. to adapt our Website to the needs of your device or to enable you to log in to our Website) and for gathering anonymous and aggregated broad demographic information.
The use of your personal data for this purpose is based on our legitimate interest as owner of the Website, in accordance with article 6.1. f) of the GDPR.
4. Registering for our services
Our Website provides an education platform. You must create an account to use the service. We will process the following personal data with respect to your registration and subsequent use of the Website:
- Pupils over 14 years old : Identifying details including name and surname, email address and date of birth.
- Pupils under 14 years old : Identifying details including name and surname, email address of parent/legal guardian and the pupil’s date of birth.
- Teachers: Identifying details for the contact form including name and surname, email and position in the school.
The information required for the provision of the service is highlighted as such. All additional information is provided voluntarily.
We will process the personal data that you provide to:
- identify you whenever you log in;
- provide you with the services and information available through the Website or requested by you;
- administer your account;
- communicate with you.
The legal basis for these processing activities is article 6.1. b) of the GDPR.
We use the personal data and contact details that you provide during registration to inform you directly about our additional products and services. The use of your personal data for direct publicity on related products and services is based on our legitimate interest as owner of the Website, in accordance with article 6.1. f) of the GDPR.
You can object to the use of your personal data for direct marketing at any time. Once you have stated your objection, we will abstain from any processing which is related to these purposes. You can notify us of your objection by emailing us at email@example.com.
5. Automated decision-making
We will not use your personal data for automated decision-making which produces legal effects concerning you or similarly significantly affects you.
For statistical analysis, we use Google Analytics, an online analysis service provided by Google, to gather information about the use of this Website.
We use the information we obtain from Google solely to determine the most useful information relative to what you are searching for, and to improve and optimise this Website. We do not combine the information gathered using Google Analytics with personal data.
The information generated about your use of the Website will be sent to and stored by Google on its European servers. Google Analytics only records the IP address assigned on the date on which you visit this Website, rather than your name or any other identifying information. The provider will use this information to assess your use of the Website, to compile reports about the activities on the Website and to provide us with other services related to the use of the Website and the Internet.
The legal basis for this processing is art. 6.1. f) of the GDPR as well as our legitimate interest in analysing traffic to our Website to improve the experience of the user and to optimise the Website in general. Google will store the personal data gathered for statistical analysis for 6 months.
7. Links to third party websites
8. Sharing of information
Your data may be shared with companies in the Springer Nature group, of which Macmillan is a member. For more information, see http://group.springernature.com/gp/group. The legal basis for the sharing of your data is the legitimate interest of Macmillan in meeting administrative purposes.
We may share statistics containing aggregated and anonymous information about users of the Website to describe our services to potential members, advertisers and other respected third parties, and for other legal purposes. Said statistics will not contain personal data.
We may share personal data with service providers and
authorised third parties for activities and purposes which are legitimised by BQ Educación
We may share personal data with service providers and authorised third parties for legitimate activities and purposes (e.g. those necessary for providing the contracted education services, for the correct operation of the Website, for commercial activities, for marketing and for other publicity campaigns, etc.) contracted by Us via a ‘Data Controller’ contract.
The processing of personal data will be carried out based on specific written instructions provided by us in a contract and always in accordance with the GDPR.
If the processing of the personal data takes place in a country not on the list of countries which comprise the European Economic Area, it will be carried out based on standard contractual clauses approved by the European Commission.
We may share your data with third parties where this is necessary for compliance with our legal obligations (fiscal, commercial, etc.) or when requested by legal authorities.
We have reasonable latest-generation security measures in place to protect personal data from loss, unlawful use and alteration. For example, our security and privacy policies are periodically reviewed and improved when necessary, and personal data may only be accessed by authorised personnel. While we cannot provide a total guarantee against the loss, unlawful use or alteration of information, we make all reasonable effort to prevent this from taking place.
The user must bear in mind that the sending of information over the Internet is never completely secure. We cannot guarantee the security of the information that they send via our Website while it is in transit across the Internet. All information is sent at their own risk.
10. Data storage
We go to all reasonable lengths to limit our processing activities with respect to your personal data as much as possible. Where no specific data storage periods are defined herein, your personal data will be held solely during the period necessary for complying with the purpose for which they were gathered and, where applicable, provided it is required under the data storage obligations established in the applicable regulations.
11. Your rights
In accordance with the applicable legislation, you may have the right to exercise one or all of the following rights:
- to request (i) access to and/or copies of your personal data, (ii) to receive the personal data concerning you in a structured, commonly used and machine-readable format, and (iii) to transmit those data to another controller without hindrance from Us. Where technically possible, you will have the right to request that we transmit your personal data directly to another controller.
- to request the rectification, erasure or limitation of processing of your personal data, e.g. because (i) they are incomplete or inaccurate, (ii) they are no longer necessary for the purposes for which they were gathered, (iii) the consent upon which the processing is based has been withdrawn, (iv) you have exercised your right to the restriction of processing. Where the personal data are processed by third parties, your request for rectification, erasure or limitation of processing will be sent to said third parties unless this is impossible or requires a disproportionate effort.
- to refuse to grant, and to withdraw your consent to the processing of your personal data at any time. Withdrawal of consent shall have no impact on processing activities which may have taken place prior to the consent being withdrawn or on any other existing legal justification for the processing activity in question.
- to object at any time to your personal data being used for direct marketing or to your personal data being processed for other purposes, for reasons related to your particular situation.
- to take legal action in relation to any possible violation of your rights with respect to the processing of your personal data and to submit a complaint to the competent data protection authorities.
- not to be subject to a decision based solely on automated processing, including profiling (automated decision-making based on automated data processing to assess various personal characteristics), which produces legal effects concerning you or similarly significantly affects you.
- You may (i) exercise the aforementioned rights, (ii) ask a question or (iii) lodge a complaint with respect to the processing of your data by contacting us using the details provided below.
12. Contact us
Please email all questions, concerns or comments regarding this Policy, or any requests related to your personal data, to firstname.lastname@example.org.
You can contact the Data Protection Officer at Grupo Springer, of which Macmillan is a member, by emailing email@example.com.
You can contact the Data Protection Officer at BQ Educación by emailing PrivacyTeam@bq.com
The information you provide when you contact us (e.g. name, email address) will be processed for the purposes of managing your request and will be deleted when requested. Alternatively, we will restrict the processing of said information in accordance with the data storage requirements established by law.
13. Modifications to this Policy