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Identification of the data controllers
In compliance with Article 13 of Regulation (EU) 2016/679 (hereinafter, ‘GDPR’) and Organic Law 3/2018 on the Protection of Personal Data and the Guarantee of Digital Rights (hereinafter, ‘LOPDGDD’), we inform you that your personal data will be processed by the Europa Education Group entity with which you are associated as a former student, with each entity acting as a data controller individually in respect of its own students and users:
- UNIVERSIDAD EUROPEA DE MADRID, S.A.U., with Tax Identification Number (N.I.F.) A-79122305 and registered office at C/ Tajo s/n 28670 Villaviciosa de Odón, Madrid.
- UNIVERSIDAD EUROPEA DE VALENCIA, S.L.U., with Tax Identification Number B-97934467 and registered office at Paseo de la Alameda 7, 46010 Valencia.
- UNIVERSIDAD EUROPEA DE CANARIAS, S.L.U., with Tax Identification Number B-57257263 and registered office at C/ Inocencio García Feo 1 Casa Salazar, 38300 La Orotava, Santa Cruz de Tenerife.
- INSTITUCIÓN ARTÍSTICA DE ENSEÑANZA IADE, S.L., with tax identification number B-06988380 and registered office at Calle María de Molina 39, Madrid, 28006.
- INICIATIVA EDUCATIVA UDDI, S.L., with Andorran tax registration number L-718330-G and registered office at Carrer Prat de la Creu no. 59-65, Escala B, Planta baixa B2, AD500 - Andorra la Vella, Principality of Andorra
- INICIATIVA EDUCATIVA UEA, S.L., with tax identification number B-86130044 and registered office at C/ Eolo 10, 29010, Málaga.
- PROYECTOS EDUCATIVOS ASTUR, S.L.U., with Tax Identification Number B-70938899 and registered office at C/ Tajo s/n, 28670, Villaviciosa de Odón, Madrid.
Hereinafter, jointly or individually, ‘the Entity’ or ‘the University’. Each entity acts as an independent data controller with regard to the personal data of individuals associated with it.
The University has formally appointed a Data Protection Officer and has also set up the following communication channels: dpo@universidadeuropea.es, dpo@iade.es, dpo@universidaduddi.com, to which you may, at your discretion, address any queries regarding the processing of your personal data.
Universidad Europea de Madrid, S.A.U. provides technological, administrative and data protection support services to the other entities of the Europa Education Group in its capacity as a data processor, under an intra-group agreement in accordance with Article 28 of the GDPR.
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Source and categories of personal data
2.1. Source of the data
The personal data we process comes from the following sources:
- Data provided directly by you in the Alumni Portal registration form and in subsequent updates and communications.
- Data generated or already existing in our systems as a result of your previous academic relationship with the Organisation (first name, surname, student number and qualifications obtained).
- Data derived from your interaction with the Alumni Portal and with the community’s activities and communications.
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2.2. Categories of data processed
Depending on the specific processing activity, we may process the following categories of data:
- Identification and contact details: first name, surname, student number, email address and, where applicable, telephone number.
- Personal data: nationality, country and city of residence.
- Academic and professional data: qualifications obtained, professional status, company, position and years of experience.
- Social circumstances data: professional interests and social media profiles (LinkedIn, Instagram or others) provided by you.
- Special categories of data (Art. 9 GDPR) are not processed unless strictly necessary and always on a specific legal basis and with enhanced safeguards.
- No biometric data will be processed.
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Processing relating to the Portal and the Alumni community
3.1. Management of the Alumni Portal
- Purpose: registration on the Alumni Portal, verification of your status as an alumnus, and management of your membership and participation in the Alumni community, making the associated content and services available to you.
- Data categories: identification and contact details, personal, academic and professional data.
- Legal basis: Article 6(1)(a) of the GDPR (consent given upon registration on the Portal) and Article 6(1)(f) of the GDPR (the University’s legitimate interest in managing its relationship with alumni).
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3.2. Access to discounts and benefits offered by Europa Education Group organisations
- Purpose: to manage access to and the use of the discounts, benefits and privileges offered by Europa Education Group entities to members of the Alumni community.
- Data categories: identification and contact details.
- Legal basis: Article 6(1)(f) of the GDPR (the University’s legitimate interest in improving and strengthening its relationship and ties with alumni by providing them with the best possible benefits and discounts).
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3.3. Management of activities, events and networking within the Alumni community
- Purpose: to manage participation in events, professional meetings, networking initiatives, mentoring and other activities aimed at revitalising the Alumni community, as well as to manage registrations and communications relating to such activities.
- Data categories: identification and contact details, academic and professional details, and details of social circumstances.
- Legal basis: Article 6(1)(a) of the GDPR (express consent given by registering for the events and activities offered)
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Marketing communications and profiling
4.1. Sending commercial communications
- Purpose: to send you advertising or promotional information, or information that may be of interest to you regarding opportunities, events, services, academic programmes and exclusive benefits for alumni, via post, email, SMS, instant messaging apps (WhatsApp, Telegram, Line) and other electronic communication channels used by the University.
- Data categories: identification and contact details.
- Legal basis: Article 6(1)(a) of the GDPR (explicit consent) and Article 21 of Law 34/2002 on Information Society Services (LSSI) for electronic communications. You may withdraw your consent at any time via the unsubscribe link included in each communication or by writing to the DPO.
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4.2. Profiling and segmentation for marketing purposes
- Purpose: to create profiles using statistical and segmentation techniques based on internal sources, with the aim of personalising our academic and service offerings and selecting the proposals best suited to your characteristics and interests.
- Data categories: identification and contact details; preferences, professional interests and interaction history.
- Legal basis: Article 6(1)(f) GDPR (legitimate interest of the controller in providing the information most suited to each data subject’s profile).
- Profiling: the processing includes profiling based exclusively on internal information that you have provided to us or generated from your interaction with us. The result of the profiling is limited to determining which academic content, products or services may be of interest to you, without producing legal effects on you or significantly affecting you in other areas.
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Compliance with legal obligations
- Purpose: to comply with the legal obligations incumbent upon the University in any respect, including, where applicable, responding to judicial and administrative requests.
- Data categories: identification and contact details.
- Legal basis: Article 6(1)(c) GDPR (compliance with a legal obligation).
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Recipients and international transfers
6.1. Categories of recipients
Your personal data will not be disclosed to companies outside the Europa Education Group, except to the following recipients where necessary for the specific purpose:
- Other entities within the Europa Education Group.
- Partner companies and organisations necessary for specific purposes.
- Technology providers acting as data processors with whom the relevant data processing agreements have been signed.
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6.2. International transfers
Transfers to Andorra: as the Europa Education Group includes Iniciativa Educativa UDDI, S.L., which is based in the Principality of Andorra, certain processing operations may involve the transfer of data to that jurisdiction. These transfers are covered by the European Commission’s Adequacy Decision 2010/625/EU of 19 October 2010, which recognises an adequate level of protection.
Other transfers: for transfers to other countries, the safeguards set out in Articles 45 to 49 of the GDPR shall apply.
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General criteria for retention periods
Personal data will be retained provided that you have not exercised your right to erasure, and will be retained taking into account the applicable legal time limits in each specific case, the type of data and the purpose of the processing. Once the above time limits have expired, the data will be blocked and retained exclusively for the use of public authorities, judges and courts to address any potential liabilities arising from the processing, for the duration of the limitation period for legal actions. Once this period has expired, the data will be permanently deleted.
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Your data protection rights
Data protection legislation grants you the following rights, which you may exercise free of charge and at any time:
- To know what personal data we process about you and for what purpose.
- To request the correction of inaccurate or incomplete data.
- Erasure (‘right to be forgotten’). To request the deletion of your data when, amongst other reasons, it is no longer necessary for the purposes for which it was collected or when you withdraw your consent.
- To object to the processing of your data on grounds relating to your particular situation.
- Request that your data be retained without being actively processed in the circumstances set out in Article 18 of the GDPR.
- Data portability. To receive, in a structured, commonly used and machine-readable format, the data you have provided to us and which is processed on the basis of consent or for the performance of a contract, or to request that it be transmitted directly to another controller where technically feasible.
- Not to be subject to automated decision-making. Not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or significantly affects you (Article 22 of the GDPR).
- Withdrawal of consent. Where processing is based on your consent, you may withdraw it at any time without this affecting the lawfulness of processing carried out prior to such withdrawal.
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How to exercise your rights?
You may exercise any of these rights, without distinction, through the following channels, and your request may be answered within the statutory period of one month, which may be extended by a further two months:
- Email to the Data Protection Officer: dpo@universidadeuropea.es · dpo@iade.es · dpo@universidaduddi.com
- Post: Data Protection Officer — Universidad Europea de Madrid, S.A.U., C/ Tajo s/n, 28670 Villaviciosa de Odón (Madrid).
You may lodge a complaint with the Spanish Data Protection Agency (www.aepd.es). As a preliminary and voluntary step, we recommend that you contact the Data Protection Officer.
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