Privacy Policy

LEGAL NOTICE AND GENERAL CONDITIONS OF USE OF THE WEBSITE
www.kingrichardcollege.com
I. GENERAL INFORMATION

In compliance with the availability of information required in Article 34/2002 of the Law of Information Society Services and Electronic Commerce (LSSI-CE, the following general information about this website is provided below:
The ownership of this website, www.kingrichardcollege.com, (hereinafter, Website) is held by: KING RICHARD III COLLEGE SL, provided with NIF: A07162506 and registered in:
Palma Company Register: TOMO: 549, FOLIO 173, HOJA PM7860, and whose representative and contact information is:
The Legal Representative,
King Richard III College SL,
Calle Oratorio, nº4 – 07181, Portals Nous, Calvià – Mallorca – Spain
Contact telephone number: 971 675850
Contact email: dpo@kingrichardcollege.com

II. TERMS AND GENERAL CONDITIONS OF USE

The purpose of the terms: The Website

The purpose of the General Terms of Use (hereinafter, Terms) is to regulate access to and use of the Website. For the purposes of these Terms, the following shall be understood as the Website: the external appearance of screen interfaces, in either fixed or dynamic form, which would constitute the navigation menu; and all the integrated elements in both screen interfaces and the navigation menu (hereinafter, Contents) and all those online services or resources that may be offered to Users (hereinafter, Services).
King Richard III College reserves the right to modify, at any time and without prior notice, the presentation and configuration of the Website and the Contents and Services that may be included in it. The User acknowledges and accepts that at any time King Richard III College may interrupt, deactivate and / or cancel any of these elements that are integrated in the Website, or access to them.
Access to the Website by the User is free and, as a general rule, is free without the User having to provide anything in return to be able to enjoy it, except in relation to the cost of connection through the telecommunications network provided by the access provider that the User has contracted.
The use of any of the Content or Services of the Website may be done through the subscription or prior registration of the User.
The User
Access, navigation and use of the Website confers the status of User, which is why, from the moment the Website navigation starts, all the Conditions established herein, as well as their subsequent modifications, notwithstanding the application of the corresponding mandatory legal regulations as may be appropriate. Given the relevance of the above, the User is recommended to read them each time they visit the Website.
The King Richard III College Website provides a wide variety of information, services and data. The User assumes responsibility to make correct use of the Website. This responsibility will extend to:
• Use of the information, content and / or services and data offered by King Richard III College without being contrary to the provisions of these Conditions, the Law, morality or public order, or that may otherwise be assumed injury to the rights of third parties or the operation of the Website.
• The accuracy and legality of the information provided by the User in the forms provided by King Richard III College for access to certain Content or Services offered by the Website. The User will immediately notify King Richard III College about any fact that allows the improper use of the information registered in such forms, such as, but not limited to, the theft, loss, or unauthorized access to identifiers and / or passwords, in order to proceed with their immediate cancellation.
The mere access to this Website does not imply any kind of commercial relationship between King Richard III College and the User.
Always in compliance with current legislation, the King Richard III College Website is addressed to all people, regardless of their age, who can access and / or browse the pages of the Website.
The Website is aimed primarily at Users resident in Spain. King Richard III College does not ensure that the Website complies with the laws of other countries, either in whole or in part. If the User resides or has their domicile in another place and decides to access and / or navigate the Website, they do so at their own responsibility. They must ensure that such access and navigation comply with the local legislation that is applicable. King Richard III College does not take any responsibility that may derive from such access.

III. ACCESS AND NAVIGATION ON THE WEBSITE:
EXCLUSION OF GUARANTEES AND LIABILITY

King Richard III College does not guarantee the continuity, availability and utility of the Website, nor of the Contents or Services. King Richard III College will do everything possible to uphold the proper functioning of the Website. However, King Richard III College does not take responsibility or guarantee that access to this Website will not be uninterrupted or error-free.

Furthermore, King Richard III College does not take responsibility or guarantee that the content or software that can be accessed through this Website is free of error or for damage caused to the computer system (software and hardware) of the User. In no case will King Richard III College be liable for losses, damages or harm of any kind arising from access, navigation and use of the Website, including, but not limited to, those caused to computer systems or those caused by the introduction of viruses.
King Richard III College is not responsible for any damages that may be caused to users due to improper use of this Website. In particular, it is not responsible in any way for the disconnection, interruptions, lack or defect of telecommunications that may occur.

IV. PRIVACY AND DATA PROTECTION POLICY

With respect to the establishment of the current legislation, King Richard III College is committed to adopting the necessary technical and organizational measures, according to the level of security appropriate to the risk relative to the data collected.

Laws that implement a privacy policy
This privacy policy is adapted to current Spanish and European regulations regarding the protection of personal data on the Internet. In particular, it respects the following rules:
• 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).
• The Organic Law 15/1999, of December 13, on the Protection of Personal Data (LOPD).
• Royal Decree 1720/2007, of December 21, which approves the Regulations for the development of Organic Law 15/1999, of December 13, on the Protection of Personal Data (RDLOPD).
• Law 34/2002, of July 11, on Services of the Information Society and Electronic Commerce (LSSI-CE).

Identity of the person responsible for the processing of personal data
The person responsible for the processing of personal data collected by King Richard III College is: KING RICHARD III COLLEGE SL, provided with NIF: A07162506 and registered in: Palma de Mallorca. The company is registered with the following registration data: TOMO: 549, FOLIO 173, SHEET PM7860, whose representative is: The Legal Representative (hereinafter, also referred to as the Responsible Party). The contact information is as follows:
Address: Calle Oratorio, nº4 – 07181, Portals Nous, Calvia – Mallorca – Spain
Contact telephone number: 971 675850
Contact email: dpo@kingrichardcollege.com

Delegate of Data Protection (DPO)
The Delegate of Data Protection (DPO) is responsible for ensuring compliance with the data protection regulations to which King Richard III College is subject. The User can contact the DPO using the following contact information: dpo@kingrichardcollege.com

Registration of Personal Data
The personal data collected by King Richard III College, using the forms available on the Website, are automatically filed under the responsibility of the Responsible Party – duly declared and registered in the General Register of the Data Protection Agency:
You can consult the website of the Spanish Agency for Data Protection (http://www.agpd.es) regarding the commitments established between King Richard III College and the User, or maintenance of the relationship established from the forms that one has completed, or to attend a request or consultation regarding said forms.

Principles applicable to the processing of personal data
The processing of User personal data will be subject to the following principles set forth in article 5 of the GDPR:
• Principle of legality, loyalty and transparency: at all times the purpose for which personal data will be used must be made clear to the User.
• Principle of limitation of purpose: personal data will be collected for specific, explicit and legitimate purposes.
• Principle of minimization of data: the personal data collected will only be that which is strictly necessary in relation to the purposes for which it is gathered and used.
• Principle of accuracy: personal data must be accurate and always updated.
• Principle of limitation of the period of retention: personal data will only be retained in such a way that the identification of the User is allowed for the time necessary for the purpose of its processing.
• Principle of integrity and confidentiality: personal data will be treated in a way that guarantees its security and confidentiality.
• Principle of proactive responsibility: the Responsible Party will be responsible for ensuring that the above principles are met.

Categories of personal data
The categories of data dealt with at King Richard III College are as much identification data as special categories of personal data within the concept of Article 9 of the GDPR.
Special categories of personal data are understood as those that reveal ethnic or racial origin, political opinions, religious or philosophical convictions, or union affiliation, and the processing of genetic data, biometric data aimed at specifically identifying a particular person, data related to health or data related to sexual life or sexual orientation of a particular person.
For the processing of special categories of personal data, the explicit consent of the User for one or more specific purposes will be necessary.

Legal basis for the processing of personal data
The legal basis for the processing of personal data is consent. King Richard III College undertakes to obtain the express and verifiable consent of the User for the processing of their personal data for one or several specific purposes.
The User shall have the right to withdraw his/her consent at any time. As a rule, the withdrawal of consent will not restrict the use of the Website.
On occasions when the User must or may provide their information through forms to make inquiries, request information or for reasons related to the content of the Website, you will be informed that the completion of any of them is mandatory because they are essential for processing the operation concerned.

Purposes of processing for which personal data is used
Personal data is collected and managed by King Richard III College in order to facilitate, hasten and comply with the commitments established between the Website and the User or the maintenance of the relationship established in the forms that the latter completes or to answer a request or inquiry.
Likewise, the data may be used for commercial purposes for tailoring the Website, for operational and statistical purposes, for corporate purposes, as well as for the retrieval and storage of data and marketing studies to adapt the Content offered to the User. Equally for improving the quality, operation and navigation of the Website.
When personal data is obtained, the User will be informed about the purpose or specific purposes of the processing to which the personal data will be assigned; that is, the use or uses that will be given to the information collected.

Period of retention of personal data
Personal data will only be retained for the minimum time necessary for the purposes of its processing and, or until the User requests its deletion.
When the personal data is obtained, the User will be informed about the period during which the personal data will be kept or, when that is not possible, the criteria used to determine this term.

Recipients of personal data
The personal data of the User could be shared with the following recipients or categories of recipients:
– Google Analytics – cookies and usage data
– Mailchimp – for handling email addresses for bulk school information
– Cambridge – Name, date of birth and passport or identity card number
– UNED – Name, date of birth and passport or identity card number
– La Alta Inspección de Educación de las Islas Baleares – Name, date of birth, passport or identity card number, and school grades
– Google Classroom – Name, year group and google generated email address to use with Google classroom
– Abacus – Name and year group
– Software and Technology applications – Name and year group
– Companies offering sporting activities, residential and other excursions – Name, date of birth and necessary medical information if allergies and behavioural issues need to be catered for.
In the event that the Responsible Party is transferring personal data to another country or international organization, at the time that personal data is obtained the User will be informed about the other country or international organization that will hold the data.

Personal information of minors
In accordance to articles 8 of the GDPR and 13 of the RDLOPD, only those Users over 14 years of age may grant their consent for the processing of their personal data by King Richard III College. Users under the age of 14 require the consent of their parents or guardians for the processing of their personal data, and as such will only be considered lawful where parents have authorized it.

Confidentiality and security of personal data
King Richard III College is committed to adopting the necessary technical and organizational measures, relative to the level of security appropriate for the risk of the data collected, so as to ensure the confidentiality of personal data and avoid destruction, loss or accidental alteration or unlawful transfer of personal data (original or processed in an alternative form), or unauthorized communication or access to said data.
However, because King Richard III College cannot guarantee the impregnability of the Internet or the total absence of hackers or others who fraudulently access personal data, the Responsible Party undertakes to notify the User without undue delay when a violation of the security of personal data occurs that is likely to entail a high risk regarding the rights and freedoms of the individual. In line with that agreed in Article 4 of the GDPR, violation of the security of personal data means any breach of security that causes the destruction, loss or accidental or unlawful alteration of personal data transmitted, preserved or otherwise processed, or the unauthorized communication or access to said data.
Personal data will be treated as confidential by the Responsible Party, who undertakes to inform and guarantee through a legal or contractual obligation that such confidentiality is respected by King Richard III College’s employees, associates, and any person to whom that information is accessible.

Rights resulting from the processing of personal data
As recognized under the GDPR, the User has and can exercise the following rights regarding the processing of their personal data:

• Right of access: it is the right of the User to obtain confirmation from King Richard III College regarding whether they are processing the Users personal data and, if so, obtain information about what processing of personal data has been done by King Richard III College, as well as, information available on the origin of the personal data and the recipients of said data.

• Right of rectification: It is the right of the User to modify personal data that prove to be inaccurate or (depending on the final use of the data) incomplete.

• The right of withdrawal and the right to be forgotten – it is the right of the User, providing current legislation does not indicate 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;
• to withdraw consent to process their data and this does not have any other legal basis;
• to oppose the processing of their data when there is no other legitimate reason to continue with it, personal data has been processed illegally, personal data needs to be deleted in compliance with a legal obligation, or personal data obtained via services of the information society for a child under 14 years of age. Aside from deleting the data, the Responsible Party (technology and reasonable cost permitting) should adopt reasonable measures to inform recipients who are dealing with said personal data of the request of the interested party.

• Right to limitation of processing: it is the User’s right to limit the processing of their personal data. The User has the right to obtain limitation of processing when it challenges the accuracy of their personal data, the processing is illegal, the Responsible Party no longer needs the personal data, but the user needs it to make a claim, and when the User does not wish processing to continue.

• Right to data portability: In the event that the processing is carried out by automated means, the User shall be entitled to receive their personal data in a common format from the Responsible Party, and to be able to pass it on to another party for processing. Whenever technically possible, the Responsible Party will pass the data directly to the third party.

• Right of objection: It is the right of the User that King Richard III College does not process personal data or ceases to process it.

•The right not to be the subject of a decision based solely on automated processing, including the preparation of profiles: It is the User’s right not to be the subject of an individualized decision based solely on the automated processing of their current personal data, including the preparation of profiles, unless the current legislation indicates otherwise.
The User may exercise their rights in writing to the Responsible Party highlighting the reference “GDPR – www.kingrichardcollege.com” and specifying:

• Name and surname of the User and a copy of the passport. Where the User is represented by another party, the same identification is also required of the User’s representative as well as the User, as well as a signed document accrediting the representation. The photocopy of the passport may be substituted by any other official document valid in law, that proves a person’s identity.
• The petition with the specific reasons for the request or information that you wish to access.
• Address to send notifications.
• Date and signature of the applicant.
• All necessary documents that certify the request that you wish to make.

This application and any other attached document may be sent to the following address and / or email:
Postal address:
King Richard III College, Calle Oratorio, nº4 – 07181, Portals Nous, Calvià – Mallorca
Email: dpo@kingrichardcollege.com

Claims before the supervisory authority
In the event that the User considers that there is an issue or infringement of current regulations with regard to the way their personal data is being processed, they will have the right to effective judicial protection and to present a claim to the supervisory authority for the State in which they are habitually resident, the place of work or the place of the alleged infringement. In the case of Spain, the supervisory authority is the Spanish Agency for Data Protection (http://www.agpd.es).

Acceptance and changes in this privacy policy
It is necessary that the User has read and is satisfied with the conditions of the protection of personal data contained in this Privacy Policy, as well as to accept the processing of their personal data so that the Responsible Party can proceed appropriately, in good time and for the purposes indicated. The use of the Website implies the acceptance of the Privacy Policy.
King Richard III College reserves the right to modify its Privacy Policy, according to its own criteria, or motivated by a legislative, jurisprudential or doctrinal change from the Spanish Agency for Data Protection. When accessing the Website, the User will be notified of Changes or updates to the Privacy Policy.
This Privacy Policy was updated on June 25, 2018 to adapt to 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 circulation of data (GDPR).

V. COOKIES POLICY

Access to this Website may involve the use of cookies. Cookies are small amounts of information that are stored in the browser of the device being to navigate the web so that the server remembers certain information that only it will read at a later date. Cookies make browsing easier, make it more user-friendly, and do not damage the navigation device.

Cookies are automatic procedures for collecting information related to the preferences determined by the User during his/her visit to the Website in order to recognise him/her as a User, and to personalise the experience and use of the Website and may also help to identify and resolve errors.

The information collected through cookies may include the date and time of visits to the Website, the pages viewed, the time spent on the Website and the sites visited just before and after it. However, no cookie allows contact with the User’s phone number or any other means of personal contact. No cookie can extract information from the User’s hard drive or steal personal information. The only way that the User’s private information is part of the Cookie file is if the user personally gives that information to the server.

Cookies that enable identification of a person are considered personal data. Therefore, the Privacy Policy described above will apply to them. In that sense, the User’s consent will be necessary to use them. Consent will be communicated, based on a clear choice, offered through an affirmative and positive decision, before any initial, removable and documented processing.

Own cookies
Are those cookies that are sent to the computer or device of the User and managed exclusively by King Richard III College so that the Website functions well. The information that is collected is used to improve the quality of the Website, its Content, and the browsing experience as a User. These cookies allow the User to be recognised as a recurring visitor to the Website and adapt the content to suit the User’s preferences.

Third party cookies
These are cookies requested by King Richard III College which are used and managed by external entities to improve the Website and the user’s browsing experience. Third-party cookies are used to obtain access statistics and to analyse the navigation information, to see how the User interacts with the Website.
The information that is obtained refers, for example, to the number of pages visited, the language used, the location of the User’s IP address, the number of Users that access the site, the frequency and repetition of visits, the duration of the visit, the browser they use, the operator or type of device from which the visit is made. This information is used to improve the Website and detect new needs to offer Users a Content and / or service of optimum quality. The information is collected anonymously, and website-trend reports are produced without identifying individual users.
You can obtain more information about cookies, information about privacy, or consult the description of the type of cookies used, their main characteristics, expiration period, etc. in the following links:
– Google Analytics: https://developers.google.com/analytics/
– OPTIMIZELY: https://help.optimizely.com
The entity in charge of the supply of cookies may transfer this information to third parties, when the law requires it, or for a third party who processes this information for these entities.

Disable, reject and delete cookies
The User can disable, reject and delete the cookies -totally or partially- installed on their device through the configuration of their browser (among which are, for example, Chrome, Firefox, Safari, Explorer). In this regard, the procedures for rejecting and deleting cookies may differ from one Internet browser to another. Consequently, the User must go to the instructions provided by the Internet browser that he/she is using. If you reject the use of cookies -totally or partially- you may continue to use the Website, although you may find that you have limited use of some of the features.

Changes in the Cookies Policy
It is possible that the Cookies Policy of the Website changes or is updated, therefore it is recommended that the User reviews this policy each time he accesses the Website in order to be adequately informed about how and why we use cookies.

VI. LINKS POLICY

The User or third party that makes a hyperlink from a distinct website to the King Richard III College Website should know that:
The reproduction – totally or partially – of any of the Contents and / or Services of the King Richard III College Website is not permitted without the express authorisation of King Richard III College.
Equally, no false, inaccurate or incorrect information about King Richard III College, its Website, or the Contents and / or Services thereof, is allowed.
With the exception of the actual link to our Website, the website on which a hyperlink is established will not contain any element of our Website, which is protected by the Spanish legal system under the law of intellectual property, unless expressly authorised by King Richard III College.
The establishment of the hyperlink will not imply the existence of any relationship between King Richard III College and the owner of the website from which the link is made, nor the knowledge and acceptance of King Richard III College of the contents, services and / or activities offered on that site, and vice versa.

VII. INTELLECTUAL AND INDUSTRIAL PROPERTY

King Richard III College in its own right or as a transferee, is the owner of all the intellectual and industrial property rights of the Website, as well as the elements contained therein (for example but not limited to – images, sound, audio, video, software, texts, trademarks, logos, combinations of colours, structure and design, selection of material used, computer programmes necessary for its operation, access and use, etc.). They will therefore be works protected as intellectual property under the Spanish legal system, and hence applicable through Spanish and European Union regulations in this field, as well as international agreements signed with Spain relating to this subject.
All rights reserved. Under the provisions of the Law of Intellectual Property, the reproduction, distribution and public communication, including the act of making available, all or part of the contents of this Website for commercial or any other non-personal purpose (regardless of format or technical means) are expressly prohibited without the authorisation of King Richard III College.
The User agrees to respect the intellectual and industrial property rights of King Richard III College. You can view the elements of the Website or even print them, copy them and store them on your computer’s hard drive or any other physical support, provided that it is exclusively for your personal use. The User, however, may not delete, alter, or manipulate any protection device or security system that was installed on the Website.
In the event that the User or third party considers that any of the Website’s Contents constitutes a violation of the rights of intellectual property protection, he / she should immediately notify King Richard III College through the contact information in the GENERAL INFORMATION section of this Disclaimer and General Conditions of Use.

VIII. LEGAL ACTION, APPLICABLE LEGISLATION AND JURISDICTION

King Richard III College reserves the right to present civil or criminal action that it deems necessary for the improper use of the Website and Content, or for the breach of these Conditions.
The relationship between the User and King Richard III College will be governed by the current European Union regulations applicable in Spanish territory. Should any dispute arise in relation to the interpretation and / or application of these Conditions, the parties shall submit their disputes to the courts for the attention of the judges and tribunals that correspond to the law.

Last modified: June 25, 2018

Phone: 0034 971 675 850
Fax: 0034 971 676 820
Calvià, Mallorca, Spain
Calle Oratorio No. 4, Portals Nous, 07181