Privacy Policy

In accordance with the provisions of Articles 13 and 14 of REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of April 27, 2016, regarding the protection of natural persons with regard to the processing of personal data and the free movement of such data (hereinafter referred to as “GDPR”), and Articles 6 and 11 of Organic Law 3/2018, of December 5, on Personal Data Protection and Guarantee of Digital Rights (hereinafter referred to as “LOPDGDD”), which regulate the right to information when collecting data, we hereby inform you of the following points.

Who is responsible for processing your personal data?
The personal data you have provided through our website and in any other communications with us will be included in the Record of Processing Activities owned by THOMAS DEBIONNE, with registered office at c/ Cires nº44, holding CIF X0943688K.

What presence do we have on social media?
THOMAS DEBIONNE has the following profiles on major internet social networks (Facebook, LinkedIn, YouTube, Blog, and Newsletter).

We acknowledge ourselves as the data controller of the data of our users, followers, or individuals who comment via these platforms. Likewise, under the Law on Information Society Services and Electronic Commerce, THOMAS DEBIONNE is not liable for any type of responsibility arising from user and follower comments posted on our social networks.

THOMAS DEBIONNE may use the aforementioned profiles to inform users about topics that we consider of interest.

What personal data do we collect?
Personal data that users may provide includes:

• Identifying data: name, surname(s), position, role, email address, and/or phone number.
• Financial data: bank account number, credit card details, etc.

Why and for what purpose do we process your data?
Depending on the purposes, we may need to process different types of data, generally falling into the following categories:

• The website provides informative content about the educational platform services offered by THOMAS DEBIONNE. Your data may be processed to respond to requests for information about these services.
• Data collection and automated processing carried out through the website’s contact form aims to evaluate the possibility of contacting you.
• The website informs visitors through identification videos.
• The website features a blog where stories of interest to users can be uploaded and shared.
• To manage and maintain your application for employment with THOMAS DEBIONNE when you submit it to us. This processing is based on your consent and on the legitimate and mutual interest of both THOMAS DEBIONNE and the User, as indicated in the privacy notice that must be accepted before submitting the application.

Any personal data collected through any of the website’s channels will become part of the Record of Processing Activities (RPA) owned by THOMAS DEBIONNE. This record will be updated periodically in compliance with GDPR and LOPDGDD regulations. Therefore, THOMAS DEBIONNE has implemented all necessary security measures accordingly.

Users are informed of their right to withdraw consent previously granted for specific purposes without affecting the lawfulness of the prior processing based on said consent.

On what legal basis do we process your data?
The processing of your data may be based on the following legal grounds:

• Express consent: Users explicitly agree to receive commercial communications from THOMAS DEBIONNE by completing forms.
• Legitimate interest: Our legitimate interest lies in ensuring the security of our website, understanding user needs, expectations, and satisfaction levels, thus improving our services. All actions are performed with the aim of enhancing user satisfaction and providing a unique browsing and potential contracting experience.
• Compliance with legal obligations: For fraud prevention, cooperation with public authorities, and/or handling claims from third parties.

How long do we keep your data?
Data processing for the stated purposes will continue for as long as necessary to fulfill the initial purpose of collection, as well as to meet any legal obligations derived from the data processing. This does not preclude that retention might also be necessary for the formulation, exercise, or defense of potential claims, provided this is allowed by applicable legislation.

THOMAS DEBIONNE commits to ceasing data processing once the retention period has ended and properly blocking them in our databases.

To whom are your data disclosed?
Generally, THOMAS DEBIONNE will not disclose personal data to third parties, except in cases where they may be transferred to collaborators who provide services to THOMAS DEBIONNE for managing service delivery, contractual or pre-contractual relationships with interested parties, or for processing requests made by them.

In such cases, we ensure that recipients respect confidentiality and have appropriate measures in place to protect personal data. THOMAS DEBIONNE strives to guarantee the security of personal data when sent outside the company. Third parties contracted by THOMAS DEBIONNE are required to handle the information in compliance with current data protection laws.

In situations where the law requires disclosure of personal data to public bodies or other entities, only strictly necessary information will be revealed to comply with those legal obligations.

THOMAS DEBIONNE shares data with external providers, acting as data processors, to carry out certain services.

What rights do you have and how can you exercise them?
You may send communications and exercise your rights by sending a written request to the following email address: thomas@podamallorca.com

Under the applicable data protection regulations, you may request:

• Right of access: You may ask for information regarding the personal data we hold about you.
• Right to rectification: You may notify us of any changes to your personal data.
• Right to erasure (“right to be forgotten”): You may request the deletion of your personal data after they have been blocked.
• Right to restriction of processing: This involves limiting the processing of your personal data.
• Right to object: You may withdraw your consent to the processing of your data and object to further processing.
• Right to data portability: In some cases, you may request a copy of your personal data in a structured, commonly used, and machine-readable format for transmission to another data controller.
• Right not to be subject to automated decision-making: You may request not to be subject to decisions based solely on automated processing, including profiling, which produce legal effects or significantly affect you.

In some cases, a request may be denied if you request deletion of data necessary for fulfilling legal obligations. Additionally, if you have any complaints about the processing of your data, you may file a complaint with the relevant data protection authority.

Who is responsible for the accuracy and truthfulness of the data provided?
The user is solely responsible for the accuracy and correctness of the data provided through any of the forms on the website, thereby releasing THOMAS DEBIONNE from any liability in this regard. Users guarantee and assume responsibility for the accuracy, validity, and authenticity of the personal data provided and commit themselves to keeping the data updated. The user agrees to provide complete and correct information in the forms they fill out.

THOMAS DEBIONNE does not take responsibility for the veracity of information that is not of its own creation and for which another source is indicated; therefore, it assumes no liability for any damages that may arise from the use of such information.

THOMAS DEBIONNE is exempt from liability for any damage or harm the user may suffer as a result of errors, defects, or omissions in the information provided by THOMAS DEBIONNE, provided that this information originates from sources outside THOMAS DEBIONNE.

What security measures do we apply to protect your personal data?
THOMAS DEBIONNE has adopted the legally required levels of security for protecting personal data and strives to install additional technical and organizational measures within its capabilities to prevent loss, misuse, alteration, unauthorized access, and theft of personal data provided to THOMAS DEBIONNE. However, users should be aware that internet security measures are not entirely foolproof.

Therefore, THOMAS DEBIONNE is not responsible for hypothetical damages or losses that could result from interferences, omissions, interruptions, computer viruses, telephone malfunctions, or disconnections in the operational functioning of this electronic system caused by factors beyond THOMAS DEBIONNE’s control; delays or blockages in the use of this electronic system caused by deficiencies or overloads in telephone lines or in the Data Processing Center, the Internet system, or other electronic systems, as well as damages that may be caused by third parties through unlawful intrusions beyond THOMAS DEBIONNE’s control.

How do we handle data of minors?
As a general rule, THOMAS DEBIONNE processes data of minors for storage and maintenance on the educational platform for which it is the Data Controller. Contracts as data processors will be signed with educational institutions to guarantee the protection and security of this data.

How do we use cookies?
The THOMAS DEBIONNE website and social media pages use cookies to optimize and personalize your navigation. Cookies are physical information files stored on the user’s device. The information collected through cookies facilitates navigation on the portal and enhances the browsing experience. The data collected through cookies may be shared with their creators, but under no circumstances will this information be linked to personal data or identify the user. However, if the user does not wish cookies to be installed on their hard drive, they may configure their browser to prevent installation of these files. For more information, please refer to our Cookie Policy.

Internal Security Policy
Security breaches can be caused by employees, third parties, or technical errors. Therefore, we are legally obligated to notify affected individuals if their personal data has been seriously compromised within a maximum of 72 hours. Furthermore, users will be notified as soon as the breach has been resolved.

Modification of the Privacy Policy
This privacy policy may be modified. We recommend that you review the privacy policy periodically.