Privacy Policy
Document reviewed on 26/05/2023
At LEADING CREW, S.L. we understand that maintaining a transparent relationship with you is essential. Therefore, we present our Privacy Policy so that you are always properly informed about how we collect and securely process any data you provide to us.
Your data will be processed in accordance with current legislation and, specifically, in accordance with Regulation (EU) 2016/679 of 27 April 2016 (GDPR) on the protection of natural persons with regard to the processing of personal data and the free movement of such data. Also in relation to Organic Law 3/2018, of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights.
A careful reading of our Privacy Policy will provide you with the necessary information to understand what we will do with the data you provide.
1 - Who is the data controller?
If you, or an authorized person, have provided us with your data, we inform you that LEADING CREW, S.L., with CIF: ESB38608642, is the data controller. This data will be processed in accordance with current regulations on the protection of personal data.
There may be other data controllers in the processing we carry out. In that case, we will always inform you of who the data controller is, as well as their identification details.
The Website may include hyperlinks or links that allow access to third-party web pages other than www.proflyacademy.com, which are therefore not operated by LEADING CREW, S.L.. The owners of such websites will have their own data protection policies, being themselves, in each case, responsible for their own processing and their own privacy practices.
At LEADING CREW, S.L. we are committed to complying with the obligation of secrecy regarding personal data and the duty to safeguard it. To this end, we adopt the necessary measures to prevent its alteration, loss, unauthorized processing or access in accordance with the provisions of the Regulation.
2 - Where do we inform?
At LEADING CREW, S.L. we inform through the website www.proflyacademy.com in the section corresponding to the privacy policy. More information in "Legal Notice".
3 - What personal data do we process?
The personal data we process includes:
- Data that you voluntarily choose to provide us
- Data derived from communications you maintain with us
- Information corresponding to your own browsing in the case of Online Services (IP address or information derived from cookies or similar devices)
- Information that is available from publicly accessible sources, which we may legitimately access
- Data derived from the contractual or pre-contractual relationship you maintain with us, including your image, always informing you in this case of the possibility of capturing your image
- Data that third parties provide about you, where there is a legitimate basis or having obtained your consent
- Third-party data that you provide to us, with the prior consent of the third party in question
You can find more information in the activities register section of this privacy policy.
4 - How do we process data?
At LEADING CREW, S.L. we always process your personal data in strict compliance with current legislation. Furthermore, we inform you that we have the appropriate technical and organizational measures in place to guarantee an optimal level of security, thereby ensuring that only authorized persons will have access, that we will keep them intact, avoiding any intentional or accidental loss, and that we have strengthened our data processing systems and services.
However, since LEADING CREW, S.L. cannot guarantee the impregnability of the internet or the total absence of hackers or others who fraudulently access personal data, we commit to notifying you without undue delay when a personal data security breach occurs that is likely to entail a high risk to the rights and freedoms of natural persons. In accordance with Article 4 of the GDPR, a personal data breach means any breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed.
The operations, management and technical procedures that we carry out in an automated or non-automated manner and that enable the collection, storage, modification, transfer and other actions on personal data, are considered personal data processing.
5 - What is the legal basis for processing?
The legal basis for the processing of Personal Data will be that which results from the contractual or pre-contractual relationship, the employment relationship or any other that is required for the processing of data, such as express consent.
6 - How do we manage electronic communications?
In accordance with Law 34/2002 of 11 July, on Information Society Services and Electronic Commerce, and Directive 2002/58/EC, we inform you that you may receive commercial communications and information through this electronic communication system (emails, automated form response messages and other communication systems) when you have given us your consent or when it involves commercial communications relating to products or services similar to those previously provided by the data controller.
If you do not wish to receive communications and information of this nature, you may notify us through this same channel by indicating in the subject line "UNSUBSCRIBE COMMERCIAL COMMUNICATIONS" so that your personal data is removed from our database. Your request will be processed within 1 month of submission. If we do not receive an express response from you, we will understand that you accept and authorize our entity to continue making such communications.
If you receive such communications through these means, we inform you that the messages are addressed exclusively to their recipient and may contain privileged or confidential information. If you are not the intended recipient, we notify you that the use, disclosure and/or copying without authorization is prohibited under current legislation.
7 - How long do we keep your data?
Personal data relating to natural persons that LEADING CREW, S.L. collects by any means will be retained as long as the data subject does not request its deletion. Likewise, they will be retained while the relationship that originated the data processing is maintained, respecting in any case the legal retention periods. Once this period has ended, personal data will be deleted from all LEADING CREW, S.L. systems.
8 - Will your data be disclosed to third parties?
There will be no transfer, transmission or disclosure of personal data, except those already informed, that are not as a result of a legal obligation. If your data is requested by the Public Administration or Autonomous Institutions within the scope of the functions expressly attributed to them by law, it will be transmitted.
If there is a transfer, transmission or disclosure of personal data outside the cases previously foreseen, you will be previously informed so that, if applicable, you may give us your consent.
However, in order to organize ourselves correctly, have good operations and procedures that guarantee good management, LEADING CREW, S.L. may need to contract the services of advisors, professionals, or other service companies to process data under our instructions.
This processing on behalf of third parties is regulated in a written contract or in some other legally admissible form that allows its execution and content to be accredited, expressly specifying that the data processor will process the data in accordance with our instructions and will not apply or use it for a purpose other than that stated in said contract, nor will they communicate it, not even for its preservation, to other persons.
9 - What are your rights?
Data protection regulations grant you the following rights:
Right of access
This is the right of the User to obtain confirmation as to whether LEADING CREW, S.L. is processing their personal data or not and, if so, to obtain information about their specific personal data and the processing that LEADING CREW, S.L. has carried out or carries out, as well as, among other things, information available about the origin of such data and the recipients of communications made or planned.
Right of rectification
This is the right of the User to have their personal data modified when it proves to be inaccurate or, taking into account the purposes of the processing, incomplete.
Right of erasure (the right to be forgotten)
This is the right of the User, provided that current legislation does not establish otherwise, to obtain the deletion of their personal data when it is no longer necessary for the purposes for which it was collected or processed; the User has withdrawn consent and there is no other legal basis; the User objects to the processing and there is no other legitimate reason to continue; the personal data has been unlawfully processed; the personal data must be deleted in compliance with a legal obligation; or the personal data was obtained from a direct offer of information society services to a minor under 14 years of age.
Right to restriction of processing
This is the right of the User to limit the processing of their personal data. The User has the right to obtain restriction of processing when they contest the accuracy of their personal data; the processing is unlawful; the Controller no longer needs the personal data, but the User needs it to file claims; and when the User has objected to the processing.
Right to data portability
In the event that the processing is carried out by automated means, the User shall have the right to receive from the Controller their personal data in a structured, commonly used and machine-readable format, and to transmit it to another controller. Whenever technically feasible, the Controller shall transmit the data directly to that other controller.
Right to object
This is the right of the User that the processing of their personal data not be carried out or that the processing be ceased by LEADING CREW, S.L.
Right not to be subject to a decision based solely on automated processing
This is the right of the User not to be subject to an individualized decision based solely on the automated processing of their personal data, including profiling, except where current legislation establishes otherwise.
If you wish more information regarding the processing of your data, to rectify inaccurate data, to object and/or limit any processing you consider unnecessary, or to request the cancellation of the processing when the data is no longer necessary, you may write to LEADING CREW, S.L. at Rua de Amio, 114, 15707 - Santiago de Compostela (A Coruna) or by email to info@proflyacademy.com.
Such communication must reflect the following information: First and last name of the user, the request, the address and supporting documentation.
The exercise of rights must be carried out by the user themselves. However, they may be exercised by an authorized person as the legal representative of the authorized party. In such a case, documentation proving this representation of the data subject must be provided.
Likewise, we want to inform you that you may withdraw the consent given without affecting the lawfulness of the processing already carried out.
If you consider that there is a problem or infringement of current regulations in the way your personal data is being processed, you will have the right to effective judicial protection and to file a complaint with a supervisory authority, in particular, in the State in which you have your habitual residence, place of work or place of the alleged infringement. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (https://www.aepd.es/).
10 - What is the purpose and legal basis for data processing and how long will data be retained?
Below we detail the purposes of data processing carried out by some, or all, of the Data Controllers listed above.
| Processing Activity | Purpose of Processing | Legal Basis | Retention Period |
|---|---|---|---|
| Labor management | Personnel management for the formalization of an employment contract, file management, payroll management | Contractual relationship | 5 years from the end of the contract |
| Fiscal and accounting management | Processing necessary for compliance with fiscal and accounting obligations | Contractual relationship, Legal obligation, Legitimate interests | 5 years from the end of the contract. Time necessary to meet legal obligations |
| Contact management | Processing of data to maintain communications with data subjects | Contractual relationship, Legitimate interests, Express consent | 5 years from the end of the contract. Until cancellation or objection by the data subject |
| Occupational risk prevention | Compliance with current legislation on occupational risk prevention and health surveillance | Contractual relationship, Legal obligation | Until the end of the contractual relationship. Legally established period |
| Candidate management | Personnel selection and job placement through CV management, personal interviews and assessment tests | Vital interests of the data subject, Express consent | Upon completion of the period for which it was requested |
| Organization of events and activities | Management and coordination of activities and events related to the entity's activity. Attendance and participant control | Contractual relationship, Express consent | Until cancellation or objection by the data subject. Time necessary to meet legal obligations |
| Multimedia management | Processing of images and/or videos for dissemination in media and social networks and promotion of activities | Express consent | Until cancellation or objection by the data subject |
| Labor control | Monitoring of employee attendance at the workplace (vacations, absences, time tracking) | Contractual relationship, Legal obligation, Legitimate interests | Until the end of the contractual relationship |
| Supplier management | Analysis, evaluation, contracting, order management and supplier payment management | Contractual relationship | 5 years from the end of the contract. Legally established period |
| Training activities management | Organization of courses, and possible billing of expenses derived from them | Contractual relationship, Express consent | Until cancellation or objection by the data subject |
| Student management | Student data for contact, commercial management, service offers, class management, billing receipt management | Express consent | Until cancellation or objection by the data subject |
| Student records management | Student data to create the academic record according to current regulations | Express consent | Until cancellation or objection by the data subject |
11 - Acceptance and changes to this privacy policy
It is necessary that the User has read and agrees with the conditions on the protection of personal data contained in this Privacy Policy, as well as accepting the processing of their personal data so that the Controller may proceed with it in the manner, during the periods and for the purposes indicated. Use of the Website implies acceptance of its Privacy Policy.
LEADING CREW, S.L. reserves the right to modify its Privacy Policy, at its own discretion, or motivated by a legislative, jurisprudential or doctrinal change of the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. The User is recommended to consult this page periodically to stay informed of the latest changes or updates.
This Privacy Policy was updated to comply with Regulation (EU) 2016/679 of the European Parliament and of the Council, of 27 April 2016, on the protection of natural persons with regard to the processing of personal data and the free movement of such data (GDPR) and Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights.