For the provision of services and management the website www.smartick.com (the “Web Site”), Sistemas Virtuales de Aprendizaje, S.L. (“Smartick”) collects and processes personal data in the various modes set out in this Privacy Policy.

In its position responsible for the processing of personal data collected on the Web Site, Smartick informs the User that their address is located at Avenida María de Orueta (Urb. El Olivar), 14, 29195, Málaga.

Smartick guarantees the exercise of rights of access, rectification, cancelation and opposition in the terms established by the Data Protection Act. Any interested party who wishes to exercise any of the aforementioned rights shall do so at the following email address: [email protected], making clear reference in the message subject to the exercise of the corresponding right.

In application of the provisions of the Data Protection Act the exercise of the rights shall be conducted using the following procedure:

The communication directed to Smartick must contain:

Smartick will answer the request addressed to it in any case, regardless of whether or not personal data in its files are affected. In the event that the application does not meet the requirements specified in the first paragraph, Smartick will request the rectification thereof.

Smartick collects personal data in the following instances:

The User has the right to request a copy of any personal information that we have about them in our registry, and correct or update any erroneous or outdated informtion. The User can also request that we don’t send any commercial communicaton, the suppression of their personal data when, amongst other reasons, the data are no longer necessary for the reasons they were collected or, in their case, request the portability of their data. In determined circumstances, the User may request the limitation of or oppose the treatment of their data. Smartick will stop processing the data, except for compelling legitimate reasons, or the exercise or defense of possible claims. Likewise, the user has the right to withdraw their consent at any time, when this is the legal basis for the processing of their personal data. Finally, the User is entitled to the protection of the Spanish Agency for Data Protection, en www.agpd.es.

Any interested party who wishes to exercise any of the aforementioned rights shall do so at the following email address: [email protected], making clear reference in the message subject to the exercise of the corresponding right.

Smartick will answer the request addressed to it in any case, regardless of whether or not personal data in its files are affected. In the event that the application does not meet the requirements specified in the first paragraph, Smartick will request the rectification thereof.

Smartick collects personal data in the following instances:

Use of cookies and IP addresses of users of the Website

The Web Site uses cookies, for two reasons:

• facilitate and customize user navigation through the Website, and
• obtain statistical information on the use of the Website (browsers and operating systems used by users, most visited sections, countries connected from, etc.).

Cookies are not viruses, do not generate pop-ups, or allow us to know any other information (personal or otherwise) that users keep on their computers.

Most browsers offer various options regarding cookies (for example, accept, reject, delete at the end of the session, etc.). If you choose not to accept cookies generated by this Web Site, your browser will consider each visit you make your first visit.

Smartick does not use cookies for navigation data associated with individuals who have not been previously identified.

The website collects the IP address of the users who access it. The IP address of each user accessing this website may not be the same every time. In addition, several users can share a single IP address.

Although Smartick does not, nor will not perform any work towards the IP address associated with specific individuals, the gathering of IP addresses can be considered processing of personal data under potentially identifiable character of the natural person who can be associated by IP, so in accordance with Data Protection Act, it shall be applicable as provided in this Privacy Policy.

Data on cookies and IP addresses are incorporated into a file called “WEB USERS” registered in the General Data Protection Registry. The purpose of this file is to obtain statistical information.

All information about cookies, their names and use can be found here

Smartick will store the information on use of cookies during the necessary time for the provision of the services and in the case of cookies used for statistical purposes while the User does not withdraw their consent.

If it is reasonably necessary or required and as long as it is in order to comply with legal or regulatory requirements, resolve disputes, prevent fraud and abuse, or to enforce Smarticks terms and conditions, Smartick may maintain certain information related to the User, even after having closed their account or withdrawn their consent.

Data Collection during the registration process of the Service Users

During the registration process for the provision of the Services, the different users, whether Tutors, Students or Secondary Tutors facilitate the collection of personal data by Smartick for the management and delivery of services.

The data provided during the registration process will be incorporated into the following personal data files:

The purpose of the management of both files is to render the service, monitor the progress of the student, the administrative and financial management of the relationship with their legal representatives and Secondary Tutors, and to send news, giveaways, discounts and promotions relevant to Smartick. Users may stop receiving communications at any time by sending an email to the address {0}. Within the service provided, Smartick also allows students to connect and interact with each other through the Social Club, for which it allows a student to consult, through an internal search engine, the user name and facilitated full name in the register of other students.

Smartick will not transfer personal data contained in those files to third parties. The only exceptions to this rule are the necessary communication of data on the progress of individual students to their relevant tutors, and the aforementioned search function.

The legal basis for the treatment of the above data is the execution of the corresponding contracts or, where appropriate, the legitimate interest of Smartick in offering its services and in reporting news, gifts, discounts and relevant promotions relating to Smartick to users that do not oppose the receipt of this information.

Smartick will keep the personal information of users while their corresponding account is valid. If it is reasonably necessary or required and as long as it is in order to comply with legal or regulatory requirements, resolve disputes, prevent fraud and abuse, or to enforce Smarticks terms and conditions, Smartick may maintain certain information related to the User, even after having closed their account or withdrawn their consent.

Recommendations to friends of tutors

Smartick allows Tutors to recommend that their friends visit the Smartick website.

Data collected on friends of tutors through this procedure is incorporated into the file “FRIENDS OF THE TUTORS.” The purpose of this file is to allow tutors to recommend the services to others.

The legal basis for the treatment of the above data is the consent of the friends granted by the Tutors.

Smartick will keep the information of the friends of the tutors during the time necessary to fulfill the purpose for which they were collected and during the periods necessary to comply with the legal obligations that may result from application.

Emails received to [email protected] and through the form available on the website as well as calls received at Smartick contact numbers

The data received by Smartick in the form of its website, as well as the email address [email protected] and any calls receieved to Smartick contact numbers is used solely to respond to inquiries, suggestions or complaints sent by customers and users of the Web Site.

This data is incorporated into the file “CLAIMS AND SUGGESTIONS”, registered in the Spanish Registry of Data Protection. The purpose of this file is to manage such inquiries, suggestions, or complaints, and follow them up.

After answering inquiries, suggestions, or complaints, Smartick proceeds to block all personal data collected through these methods. Notwithstanding the above, if you have subscribed to the Smartick newsletter, Smartick will continue with the processing of data required to send this newsletter.

The legal basis for the treatment of the above data is the request from the User, the fulfillment of a contract or, where appropriate, the legitimate interest of Smartick in the management of its services.

Smartick will keep the users information for as long as it is necessary to attend to their queries, suggestions or complaints and perform a follow-up. If the user has subscribed to the Smartick newsletter, Smartick will continue processing their data for the sending of that newsletter. Likewise, Smartick may keep personal data during the periods necessary to comply with the legal obligations that may be applicable.

Subscription and Comment on the Smartick Blog

Smartick has a blog available where you can read articles about a variety of topics (teaching resources, addition and subtraction, probability and statistics, world problems, psychology). Additionally, you are able to comment on the posts and interact with other readers.

The data received by Smartick for the subscription and intereaction on the blog are utilized for managing the blog subscription, as well as to receive, publish, and in some cases, moderate the comments that are published. From Smartick, a comment or a user request will be responded to, as applicable.

The legal basis for previous data processing is the user’s request, the contractual relationship for the provision of services that binds us (even if the requested service is free of charge) or, where appropriate, Smarticks legitimate interest in the management of its services.

Smartick will save the user’s information for as long as it is necessary to receive and post a comment. Smartick will also be able to keep personal information during the periods necessary to fulfill the legal obligations that could apply.