Legal · Privacy

Privacy Policy

Last updated: 27 February 2026 · Applies to: collachamp-aguxwg2y.manus.space

1. Identity of the Data Controller

In accordance with Regulation (EU) 2016/679 (GDPR) and Organic Law 3/2018 (LOPDGDD), the data controller responsible for processing your personal data through the COLLA Knowledge Arena platform is:

OrganisationSEBA — Social Education & Business Academia
PlatformCOLLA Knowledge Arena
Websitecollachamp-aguxwg2y.manus.space
Data Protection Contact[email protected]
Registered TerritoryCatalonia, Spain (EU)
Supervisory AuthorityAgència Espanyola de Protecció de Dades (AEPD) — aepd.es

2. What Personal Data We Collect

We collect only the minimum personal data necessary to provide the COLLA Knowledge Arena service. The categories of data we may collect are as follows:

Data CategoryExamplesSourceRequired?
Contact InformationName, email address, school/organisation nameProvided by user via contact or registration formsYes (for form submission)
Usage DataPages visited, time on site, navigation paths, browser type, IP address (anonymised)Automatically collected via analytics cookies (with consent)Optional
Preference DataLanguage selection, quiz results, theme preferenceStored locally in browser (localStorage)Optional
Communication DataContent of messages sent via the contact formProvided by userYes (for contact)
Device & Technical DataBrowser version, operating system, screen resolutionAutomatically collected for security and compatibilityEssential

We do not collect sensitive personal data (special categories under GDPR Art. 9) such as health data, biometric data, racial or ethnic origin, political opinions, or religious beliefs.

3. Purposes of Processing and Legal Basis

PurposeDescriptionLegal Basis (GDPR)
Service DeliveryProviding the COLLA Knowledge Arena platform, including the teacher dashboard, student quiz, and competition features.Art. 6(1)(b) — Contract performance
Contact Form ResponsesResponding to enquiries submitted via the Pilot page contact form.Art. 6(1)(b) — Pre-contractual steps / Art. 6(1)(a) — Consent
Analytics & ImprovementUnderstanding how visitors use the site to improve content and navigation (anonymised, aggregated data only).Art. 6(1)(a) — Consent
Legal ComplianceComplying with applicable laws, regulations, and court orders.Art. 6(1)(c) — Legal obligation
Security & Fraud PreventionProtecting the platform against unauthorised access, abuse, and technical attacks.Art. 6(1)(f) — Legitimate interest
Pilot Programme ManagementManaging school participation in the Tortosa pilot, including coordinating with school directors and the Consistori.Art. 6(1)(b) — Contract / Art. 6(1)(f) — Legitimate interest

4. Data Retention

We retain personal data only for as long as necessary to fulfil the purpose for which it was collected, or as required by applicable law. The following retention periods apply:

Data TypeRetention PeriodReason
Contact form submissions3 years from last contactLimitation period for contractual claims under Spanish law
Analytics data (Google Analytics)26 months (Google default)Statistical analysis and service improvement
Cookie consent records12 monthsProof of consent under GDPR Art. 7(1)
Browser localStorage dataUntil user clears browser dataUser preference persistence; no server-side storage
Pilot programme correspondence5 years from programme endInstitutional accountability and audit requirements

5. Data Sharing and Third Parties

We do not sell, rent, or trade your personal data to third parties for commercial purposes. We may share data with the following categories of recipients only where necessary and under appropriate safeguards:

RecipientPurposeSafeguard
Google LLC (Analytics)Anonymised site usage analyticsData Processing Agreement (DPA) + EU–US Data Privacy Framework
Pilot School DirectorsCoordinating participation in the Tortosa pilot programmeJoint controller agreement; data limited to programme coordination
Ajuntament de TortosaInstitutional reporting on pilot outcomes (aggregated, anonymised data only)Data sharing agreement; no individual-level data shared
Legal AuthoritiesCompliance with court orders or legal obligationsOnly where legally required; minimum data disclosed

6. Your Data Subject Rights

Under the GDPR, LOPDGDD, and other applicable regulations, you have the following rights with respect to your personal data. To exercise any of these rights, please contact us at [email protected]. We will respond within 30 calendar days.

RightGDPR ArticleWhat It Means
Right of AccessArt. 15Request a copy of the personal data we hold about you and information about how it is processed.
Right to RectificationArt. 16Request correction of inaccurate or incomplete personal data.
Right to ErasureArt. 17Request deletion of your personal data where there is no compelling reason for its continued processing.
Right to RestrictionArt. 18Request that we restrict processing of your data in certain circumstances.
Right to Data PortabilityArt. 20Receive your personal data in a structured, machine-readable format and transmit it to another controller.
Right to ObjectArt. 21Object to processing based on legitimate interest or for direct marketing purposes.
Right to Withdraw ConsentArt. 7(3)Withdraw consent at any time without affecting the lawfulness of prior processing.
Right to Lodge a ComplaintArt. 77Lodge a complaint with the AEPD (aepd.es) or your national supervisory authority.

7. Children's Privacy

COLLA Knowledge Arena is designed for secondary school students aged 12–18 in supervised educational settings. Under Article 8 GDPR and Article 7 LOPDGDD, the age of digital consent in Spain is 14 years. For students under 14, parental or guardian consent must be obtained by the participating school as part of the institutional onboarding process.

We do not knowingly collect personal data directly from children under 14 without verifiable parental consent. The platform does not require students to create accounts or submit personal data to use the core competition and quiz features. Any data collected in school deployments is governed by a joint controller agreement with the participating institution.

If you believe a child under 14 has submitted personal data without appropriate consent, please contact us immediately at [email protected] and we will delete the data promptly.

8. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

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HTTPS Encryption
All data transmitted between your browser and our servers is encrypted using TLS 1.2+.
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Minimal Data Storage
Preference data is stored locally in your browser; no personal data is stored on our servers beyond what is necessary.
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Access Controls
Access to any personal data is restricted to authorised personnel on a need-to-know basis.
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Processor Agreements
All third-party processors are bound by Data Processing Agreements compliant with GDPR Art. 28.

No method of transmission over the internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee absolute security. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours as required by GDPR Art. 33.

9. International Data Transfers

Our primary operations are based within the European Economic Area (EEA). Where personal data is transferred to third countries (e.g., the United States for Google Analytics), we ensure appropriate safeguards are in place:

Transfer DestinationRecipientSafeguard Mechanism
United StatesGoogle LLC (Analytics)EU–US Data Privacy Framework (adequacy decision, July 2023) + Standard Contractual Clauses

10. Cookies

We use cookies and similar technologies to enhance your experience on the Site. For detailed information about the cookies we use, their purposes, duration, and how to manage your preferences, please refer to our Cookie Policy.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our data practices, technology, or legal requirements. When we make material changes, we will update the "Last updated" date at the top of this page and, where appropriate, notify you via the cookie consent banner or email.

We encourage you to review this policy periodically. Continued use of the Site after changes are posted constitutes your acknowledgement of the revised policy.

12. Contact & Complaints

For any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact our Data Protection contact:

OrganisationSEBA — Social Education & Business Academia
Email[email protected]
Response TimeWithin 30 calendar days (GDPR Art. 12)

If you are not satisfied with our response, you have the right to lodge a complaint with the competent supervisory authority:

Spain / EU
Agència Espanyola de Protecció de Dades (AEPD) 🔗
United Kingdom
Information Commissioner's Office (ICO) 🔗
Other EU States
Your national Data Protection Authority 🔗
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