Privacy Policy
1. WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL DATA? DATA PROTECTION OFFICER’S CONTACT DETAILS
Tuitive Health S.L. (“Madrid Cardiac Academy”)
NIF B-02995090.
Address: Calle Alfonso XII, numero 32 – 4º DCHA, 28014, Madrid
Contact email: madridcardiacacademy@gmail.com
Data Protection Officer’s (“DPO”) contact details: madridcardiacacademy@gmail.com (you can also send postal mail to the treatment officer’s address).
2. WHAT REQUIREMENTS MUST YOU MEET TO PROVIDE YOUR PERSONAL DATA?
2.1. Be 18 years or older, and possess a degree in Medicine. To provide us with your personal data, use the Website, and enroll in our Programs, you must be of legal age (18+), have sufficient legal capacity, and/or, if applicable, have prior and express authorization from your legal representatives (both parents, both guardians if you have two, etc., as explained in the Terms and Conditions – https://cardiac.academy/terminos-y-condiciones_eng/). Likewise, if you enter into contracts on behalf of a legal entity, you must be over 18, have full legal capacity, have sufficient authority to bind the entity, and be able to prove it with documentation.
2.2. Provide accurate information. When you give us your data to use our services, you guarantee that the information provided is real, truthful, updated, and belongs to you, not to third parties. Additionally, you must inform us of any changes to the data provided, and you are responsible for the accuracy and precision of the data at any time.
- Important: Tuitive Health S.L. reserves the right to verify your age and identity information at any time, including requesting an official identification document or an equivalent procedure. In cases of fraud detection or suspicion that the User is under 18, lacks authorization from both parents or guardians, or has provided incorrect or false data, Tuitive Health S.L. reserves the right to temporarily deactivate and/or cancel your account. Additionally, if you select a username or identifier similar to another for your account, Tuitive Health S.L. reserves the right to delete it, suggest another, or claim it.
3. WHEN AND WHY CAN WE PROCESS OR COLLECT YOUR DATA?
A. When you browse or use our Website, we may collect various data
When you access the Website, even if you are not registered, information is collected through Tuitive Health S.L.’s own cookies, which you must accept before beginning your browsing. These tools are small files that are downloaded and installed on your device and collect data about your use of the Website. Through these tools, we may collect the following data.
A.1 What data can we process when you use the Website? While using this Website, depending on the cookies you accept, we may process your IP address (Internet Protocol), know the city from where you’re connecting, and track your usage of the Website (how often you connect, which functionalities you use most, etc.).
A.2 For what purposes do we process the data collected while using the Website?
- To conduct statistical analyses to improve the Website: All the information collected through the cookies you accept helps us analyze, maintain, and improve the Website to offer you better service. This analysis allows us to detect Website errors, areas for improvement in design, or the need to add new features and services. For more information, you can visit our Cookie Policy.
- Prevention, detection, measures, and reporting of illicit activities or those contrary to the Terms and Conditions, or those that endanger the security of the information or the Website, or its Users. Tuitive Health S.L. can process data to monitor and prevent any form of abuse of our services, such as fraudulent activities, denial-of-service attacks, the use of the Website for spam or unwanted email, unauthorized access to User accounts, and any other practice contrary to the Terms and Conditions or that endangers the security of the Website or its Users.
- Display advertising on the Website, potentially from social networks: On the Website, you may encounter advertisements in the form of banners with text, images, animations, and/or videos, integrated into the Website’s framework. These advertising banners link to third-party websites or platforms for advertising and/or informational purposes and are not the responsibility of Tuitive Health S.L., as they are external to Tuitive Health S.L. If you click on one of these banners, you leave the Website and enter a third-party site, meaning Tuitive Health S.L. is not liable for what happens there. If you’ve explicitly accepted the installation of advertising cookies in your browser, these ads may be personalized to you, showing content related to your interests and recent searches. Similarly, we use third-party advertising services to offer advertising for our Services on other websites.
- Additionally, based on social network tracking devices configured on the Website (see the Cookie Policy), we can create an audience for the matching process on relevant social networks. The data sent is encrypted in our systems before being uploaded and provided to the social network, creating a hidden and anonymous version of User data. This is used to display Tuitive Health S.L. advertisements on your social networks. To learn more, visit: https://es-es.facebook.com/legal/terms/customaudience.
A.3 What gives us the right or legitimizes us to process your data?
Your express consent, which you give when accessing the Website and selecting the cookies to be installed on your device through the pop-up or pop-in window. However, you can withdraw your consent at any time by following the steps indicated in our Cookie Policy.
A.4 How long do we keep the data collected while using the Website?
The data retention periods for information collected through cookies depend on the specific cookie (which could be first-party or third-party). All retention periods are specified for each cookie type in our Cookie Policy.
A.5 Does Tuitive Health S.L. transfer to third parties the data collected during your use of the Website?
No, we do not transfer your data. However, as we use third-party cookies (cookies installed and managed by third parties) for some of the purposes outlined in section A.2, third parties external to Tuitive Health S.L. can access the information you provide when using the Website if you accept the installation of those cookies (you have more information in the Cookie Policy).
B. We may also collect various data when you contact us through the channels indicated on the Website, through instant messaging systems (such as WhatsApp or Telegram), or by email
B.1 What data can we process when you contact us through these means?
Identifiable personal information you provide through the available channels on the Website or instant messaging systems (such as WhatsApp or Telegram), usually consisting of your identifying information (name and, if applicable, surname), your email address, and/or phone number (depending on the medium used), as well as any other personal information you voluntarily include in the communications you send us.
Curricular, academic, and professional information. If you send us your résumé, we may process information about your studies, training, academic experience, and any other information you choose to include.
B.2 For what purposes do we process the data you send through these means?
- Respond to your requests. The main purpose of processing these data is to respond to your requests, resolve your doubts, and/or provide the information you ask for, as well as, if necessary, to follow up.
- Improve customer service. All the information derived from doubts, inquiries, and advice offered to interested parties, as well as how requests are resolved, allows us to understand how we deliver our customer service and know what needs to be improved. All the collected information is anonymized once the indicated conservation period ends, so it ceases to be personal and therefore cannot be attributed to the interested parties.
B.3 What gives us the right or legitimizes us to process these data that you provide through the Website, instant messaging systems, and email?
Your express consent, which you provide when you voluntarily contact us through any of these means to request information, send us other communications, or send us your résumé to participate in our employee selection processes.
Our legitimate interest. All the information you voluntarily provide to our customer service department helps us analyze how this department operates and improve the quality of the service we offer, which we do based on our legitimate business interest in providing better service to our Users.
B.4 How long do we keep the information you send through the Website and instant messaging systems?
Your identifying personal information, as well as your résumé and professional data, which you provide through the Website or instant messaging systems, will be processed while your requests are being handled. After this period, Tuitive Health S.L. will keep the information in compliance with the law for a period that may be up to six years from the last communication we exchange.
C. We may also process your data to send our newsletter or publications of interest to you or if you want to receive commercial communications
C.1 What data can we process?
Normally, your email address or mobile phone number, which we will have because you provided it through the Website or other communication means, whether or not you have enrolled in one of our Programs.
C.2 What are the purposes of processing your personal data?
Sending publications of interest and commercial communications: If you have a contractual relationship with us or have subscribed to receive commercial information, we can send you, through electronic means (emails, SMS, WhatsApp, or others), communications about products and services related to Tuitive Health S.L..
C.3 What gives us the right or legitimizes us to process these data?
Your express consent. If you do not wish to continue receiving this type of communication, you can withdraw it at any time by following the instructions indicated in the communication, or by writing to madridcardiacacademy@gmail.com to unsubscribe from these communications.
C.4 How long do we keep the data you provide to send our newsletter, publications of interest to you, or commercial communications?
Until you decide to unsubscribe from our mailing list or inform us that you no longer want to receive commercial communications. After that, we will retain this data under the conditions set by the law, for a period that may be up to six years from the last communication.
If you have provided these data for other purposes, we will continue processing them for those purposes as long as you do not object, unless processing is necessary to execute a contract that we have in force. Once this is completed, Tuitive Health S.L. will keep your information under the conditions established by the law for a period that may be up to six years from the last communication we exchange.
C.5 Does Tuitive Health S.L. transfer to third parties the data you provide to receive our newsletter/publications or commercial communications?
Sometimes, we will transfer your data to entities that mediate the contracting of financial services. The transfer’s purpose is to offer you the possibility of arranging the financing of our services through loan contracts with financial entities, which may include the following purposes:
- Responding to information requests and contacting you by phone and/or email. Legitimate basis: consent of the interested party.
- Registering you and managing your registration in their files/system/platform. Legitimate basis: consent granted by the interested party.
- Sending commercial communications about services and promotions offered by these intermediary entities for contracting financial services. Legitimate basis: consent granted by the interested party and, when a contractual relationship exists, the exception of Article 21 of the Information Society Services Act.
D. When you register on the Website as a Registered User and subsequently enroll in one of our educational services or Programs
D.1 What data can we process?
At the time of registration:
Identifying and contact information. We collect the information you provide through the registration form on our Website. The data that you must give mandatorily will be marked with an asterisk [*].
- Important: Registration through social networks. If you decide to register or log in through a third-party social network, we will have access to part of the information in your public profile, such as your name and other public profile information. If you don’t want us to access this information, do not register on the Website through a social network. In any case, we are not responsible for the processing of the information you provide to the social network because it’s outside the Website’s scope, so you should consult and comply with the privacy policy related to the treatment of personal data in the respective social network.
During the subscription and/or use of Services:
Browsing Data referred to in Section A, depending on the cookies you have accepted (if cookies exist).
Profile Data: Apart from the mandatory information for setting up a registered User profile on the Website (fields with an asterisk [*]), you can, at your exclusive responsibility, provide additional information in your profile, like a photo, a link to an external website, link(s) to your professional social network profile(s), and any other information (including, but not limited to, personal address, identification numbers, and/or professional trajectory) that you communicate to Tuitive Health S.L. while using our Website or within the context of any application or social network used by Tuitive Health S.L. on its Website.
Information about Program Participation: Information about tasks and activities completed; interactions with other students, level of Program progress and performance, handling, and registration of grades, information about your performance level to provide to the employer who contracts our services within your employee training plan, number of hours spent on your training, analysis of your efficiency as a student, certificate issuance, etc. Within the training activities we offer, there are channels to communicate with instructors or other students, through which you can post content related to the training activity you are enrolled in, and Tuitive Health S.L. processes all that information through the Website. Image and Voice: Some training activities require interaction with other students or instructors through video conferencing, and in those cases, your image or voice (or both) might be recorded as part of the training activity.
Information about transactions conducted: If you have subscribed to a paid service or made other transactions, we collect data about those purchases or transactions, including payment information and payment method, along with billing and shipping details and contact information. For security reasons, we do not collect or store information about the cardholder, credit/debit card numbers used, or other related data.
D.2 For what purposes do we process these data?
- Register you as a Registered User on our Website and provide our service(s). Based on the information you provide — which must be accurate — we will verify if you are of legal age (18 or older), and that information will allow us to identify you as a Registered User on the Website and maintain, fulfill, manage, control, and execute the services we offer. Note that if you register through a social network, we may access more information than you provide through the registration form.
- Management of the student profile and their record in relation to the educational activity and Programs. The data in your student profile will be visible to other students in the Program, and the information about their level of program progress will be accessible to the student (and, if applicable, to the employer who contracts the program as part of their training).
- Management and organization of videoconferences and educational activities that require interaction between students and instructors through telematic means, which may be recorded for later reference, for educational or instructional purposes (this might involve recording your image or voice, or both).
- Management and organization of your access to and use of our digital platform, where all materials necessary for the Programs are provided.
- Management and tracking of your progress as a student: participation in activities related to the Program or derived educational activities, handling, and registration of grades, information about your progress to the company that contracts our services for you as their employee, hours you’ve spent in your training, analysis of your efficiency as a student, certificate issuance, etc.
- Invitation to events and other activities related to the Program and networking or professional sector meetings related to the Program you are attending.
- In general, fulfilling our obligations according to the Terms and Conditions and specific conditions of each Program, as well as resolving issues or problems that might arise during your relationship with us.
- Perform ordinary management and delivery of our services to ensure smooth communication with you. As part of the ordinary management of services, we must process your identifying and contact data and, if you subscribe to a paid service controlled by us and not a third-party service provider, information related to your chosen card/account/payment method, which we request to manage your account and any purchases you might make. Additionally, it will be used to send you administrative communications about updates, changes to our Terms and Conditions or this Privacy Policy, security alerts, and respond to any request or requirement you send us.
- Prevention, detection, taking measures, and reporting of illicit activities or those contrary to the service’s Terms and Conditions or that endanger the security of the Website, the App, or other Users. Tuitive Health S.L., at its discretion, can process data to monitor and avoid any form of abuse of our services, such as fraudulent activities, denial-of-service attacks, spam sending from the Website, unauthorized access to Registered User accounts, and any other practice contrary to the Terms and Conditions or specific conditions of each Program, or that endanger information security or the Website’s integrity.
- Invite you to participate in surveys and/or events or other activities exclusive to Tuitive Health S.L. Community members. We can invite you to participate in surveys via our own or third-party platforms to evaluate our Services, as well as invite you to events or other activities we organize for Program students. If you register for any of these activities through the respective form, we will collect and store the data you provide to manage and organize them. When using a third-party platform to manage a survey or activity, that third party’s privacy policy will apply.
D.3 What gives us the right or legitimizes us to process these data?
Your express consent, which you provide when, voluntarily, you register as a Registered User by filling in the required fields in the registration form, marked with an asterisk [*], or when you voluntarily provide your data to access activities, conduct surveys, attend networking events, etc.
The execution of the contract you sign with us when you enroll in one of our Programs. The processing of your personal data, in general, is necessary to execute the contractual relationship generated when you subscribe to one of our Programs.
Our legitimate interest. All the information you voluntarily provide during registration and afterward as a Registered User on the Website helps us analyze the quality of our services, Programs, and customer support, which we do based on our legitimate business interest in providing you with a better service.
D.4 How long do we keep the data you provide in the registration form as a Registered User and afterward?
The information you provide to register as a Registered User will remain in our systems as long as you don’t choose to close your account. The reason for this is our goal to keep the Website available to you at any time, and therefore we will delete your account when you decide (unless you breach the Terms and Conditions or any other described violations).
The information you provide when enrolling in a Program will be retained while our contractual relationship is in effect (duration of the course and while you have access to the study platform).
The information you provide to be included in any activity we organize or to attend any networking event will be kept while you receive the specific service.
Once you choose to close your Registered User account on the Website, end the contractual relationship with Tuitive Health S.L., or fulfill the purpose for which you provided the data, we will retain your information under the conditions set by the law, for a period that may be up to six years from the last communication we exchange.
D.5 Does Tuitive Health S.L. transfer to third parties the data you provide in the registration form or, afterward, when you subscribe to one of our Programs or register for activities related to them?
In addition to the transfers generally indicated in Section 4. Who do we share your personal information with?, we may share some basic identifying information with students in the courses you are enrolled in for informational purposes, for the proper development of joint activities. In this context, if you publish a comment, question, or doubt using the internal platform tools, the user information (including name) might be publicly visible to other users.
Finally, only in the case that you are enrolled in one of our Programs financed by a company that has contracted our services, we may share with that company your identifying information, grades, level of Program progress, among other aspects such as the number of hours you’ve spent on your training, analysis of your efficiency as a student, whether you’ve been granted a certificate or not, your grades, your level of Program participation, etc. By accepting this Privacy Policy, you expressly consent to share this data, which we also make available to your employer because they have a legitimate interest in knowing it, as it is your company that pays for the program and ensures you receive ongoing training.
E. When you post comments on our blog
E.1 What data can we process?
Basic identifying and contact data, indicated in the respective form. You can select an alias or pseudonym if you don’t want to publish your name.
E.2 For what purposes do we process these data?
Publication of comments on the blog. Through the respective form, you can post a comment with your opinion on the blog topics. The email request is necessary for security and fraud prevention.
Keep in mind that by posting a comment, it will be visible to all Users who visit the Website, and you are solely responsible for the content you post.
Remember that the publication of obscene, offensive, vulgar, criminally-inducing, denigrating, defamatory, infamous, violent, or generally contrary to law, morality, or good conduct is not allowed. Tuitive Health S.L. reserves the right to remove comments that violate these rules and take any appropriate measures.
E.3 What gives us the right or legitimizes us to process these data?
Your express consent, which you provide by giving the data through the respective form and freely and voluntarily posting your comments on the blog. Posting comments is entirely voluntary, so by including them on the blog, you give us your express consent to publish and process them.
Our legitimate interest. All the information you voluntarily provide to publish on the blog helps us maintain, manage, and analyze its quality and the support we provide, as well as prevent and take action against possible illegalities, based on our legitimate business interest in offering a good service.
E.4 How long do we keep the information you provide for the blog?
While the respective publication remains on the blog (while it’s relevant to the public) or until you request the removal of your post or the cancellation of your data. After that, we will retain the information under the conditions set by the law, for a period that may be up to six years from the last communication we exchange.
F. Tuitive Health S.L.’s / cardiac.academy presence on social networks
Tuitive Health S.L. / cardiac.academy can use profiles on leading social networks, such as Facebook, Twitter, Instagram, LinkedIn, or YouTube.
When you follow one of our social network pages, the data processing is governed by the terms of use, privacy policies, and access regulations of the respective social network, which you must accept beforehand. These terms of use and privacy policies are beyond Tuitive Health S.L.’s control, so we are not responsible for the data processing that occurs in those environments.
Tuitive Health S.L., in this sense, as a user of the mentioned social networks, complies with their rules to process other users’ data (in this case, yours), with the purpose of properly managing its social network presence, informing you of activities, products, or services, and contacting you for any other purpose allowed by the network’s regulations, which you should have accepted beforehand.
By expressing interest in our services, Tuitive Health S.L. may check your professional profile on professional social networks, as well as in official bulletins, press media, electronic communications services directories, and other files where consultation is not restricted by a prohibitive rule. This personal data processing is based on Tuitive Health S.L.’s legitimate interest, and it will be limited to the information strictly necessary to locate you professionally.
Please remember that we do not have influence over the information collected by the social network or how it processes it, so we recommend you stay informed about the purpose and scope of information collection conducted through those social networks.
4. WHO MIGHT WE TRANSFER YOUR PERSONAL INFORMATION TO?
- To the entities of its Business Group (including Tuitive Health S.L.) for the purposes expressed in this Privacy Policy.
- Public organizations, judges, and courts, and, in general, the competent administration and authorities, when Tuitive Health S.L. has a legal obligation to provide them.
- To Tax Authorities, for compliance with fiscal obligations, as well as to financial entities for payment and collection management.
- To companies that might collaborate with Tuitive Health S.L. in detecting fraud in the use of the Website and its contents and services offered within it.
5. WHAT ARE YOUR DATA PROTECTION RIGHTS? HOW CAN YOU EXERCISE THEM?
- Right of access. Exercising this right, you can know the information related to the processing of your personal data.
- Right of rectification. You can correct or modify your data if they are incorrect or incomplete to ensure that the information we might have about you is correct.
- Right to erasure (or right to be forgotten). You can request the erasure of your personal data when any of the contemplated conditions are met. For example, illegal data processing, or when the purpose that motivated the processing or collection no longer exists. However, some exceptions apply where this right does not proceed. For example, when the right to freedom of expression and information must prevail.
- Right to object. Using this right, you can object to the processing of your personal data: (i) when, for reasons related to your situation, the data processing must cease unless a legitimate interest is demonstrated or if it’s necessary for the exercise or defense of claims, or (ii) when the processing has direct marketing as its objective.
- Right to restriction of processing. You can request that we limit the processing of your data (i) when the data accuracy is challenged, while we verify this challenge (ii) when processing is illegal, but you object to erasure and request restriction instead (iii) when you need them for a claim (iv) or even when you’ve objected to data processing to fulfill a public interest mission or to satisfy a legitimate interest, which must be verified. In these cases, we will only retain them to exercise or defend claims.
- Right to data portability. You can request your data in electronic format and the possibility to transfer them to another entity.
- Right to file a complaint with the Supervisory Authority. Remember that at any time, you can file a complaint with the Supervisory Authority; in Spain’s case, the Spanish Data Protection Agency (www.agpd.es).
You can exercise the rights that the data protection regulation guarantees you in relation to your personal data processing by contacting our Data Protection Officer by writing to madridcardiacacademy@gmail.com.
Any request for the exercise of rights that we receive will be resolved as quickly as possible and, in any case, within the legally established deadlines. In some cases, it might be necessary to request a copy of your identification document or another form of ID.
6. CLOSING YOUR ACCOUNT AND TERMINATING THE CONTRACTUAL RELATIONSHIP YOU ESTABLISHED WITH US FOR AN EDUCATIONAL SERVICE OR PROGRAM
To close your Registered User account or to withdraw from contracted Programs, you must follow the procedure indicated in our Terms and Conditions, in addition to what may be specified in the specific conditions of each Program.
- Important: If you withdraw and/or request cancellation (account closure) by sending an email to madridcardiacacademy@gmail.com, you will lose the right to use any active benefits or services that were active at the time of cancellation and/or previously contracted.
In these cases, we will keep your data locked, under the conditions set by the law, for a period that might be up to six years from when we exchange the last communication.
This Privacy Policy was modified on January 5, 2024.
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