PRIVACY POLICY
 

1. DATA CONTROLLER
The controller of personal data is Pronunciation with Emma, owned by Emma Walker, domiciled in Barcelona, Spain, acting in accordance with Regulation (EU) 2016/679 (GDPR) and other applicable data protection laws.

 

2. PERSONAL DATA SUBJECT TO PROCESSING
The following categories of personal data may be processed:

  • Identification data: name, email, country of residence

  • Academic data: English level, learning history, progress

  • Technical data: IP address, browser, device type, platform activity

  • Financial data: transactions processed via secure external platforms such as Stripe or Kajabi

 

3. PURPOSES OF PROCESSING
Personal data shall be processed for the following lawful purposes:

  • To establish, maintain, and execute the contractual relationship with the User

  • To manage access to and use of the contracted services

  • To send informational and commercial communications, where applicable, with prior consent

  • To comply with legal obligations or requests from competent authorities

 

4. LEGAL BASIS FOR PROCESSING
Processing operations are based on the following legal grounds:

  • The performance of a contract to which the data subject is a party

  • The User’s free, informed, specific, and unambiguous consent

  • Compliance with legal obligations applicable to the Company

  • The legitimate interest of the controller, properly balanced with the User’s rights

 

5. DATA RETENTION
Personal data shall be retained for as long as necessary to fulfil the purpose for which it was collected and, subsequently, for the periods required under applicable regulations, including tax, commercial, and data protection laws.
After such periods, data will be securely deleted.

 

6. DATA RECIPIENTS AND PROCESSORS
Data may be disclosed to third parties solely when necessary for the correct provision of services, such as:

  • Technology and communication providers

  • Payment management entities

  • Web hosting and support service providers

These third parties act as data processors under contracts compliant with Article 28 of the GDPR.

 

7. INTERNATIONAL DATA TRANSFERS
If data is transferred to third countries outside the European Economic Area, such transfers will comply with GDPR requirements through:

  • Standard contractual clauses approved by the European Commission

  • Adequacy decisions issued by the Commission

  • Additional safeguards where required

 

8. DATA SUBJECT RIGHTS
In accordance with Articles 15 to 22 of the GDPR, the User may exercise the following rights:

  • Right of access to personal data

  • Right to rectification of inaccurate data

  • Right to erasure (right to be forgotten)

  • Right to restriction of processing

  • Right to data portability

  • Right to object

  • Right not to be subject to automated decision-making

 

9. EXERCISING RIGHTS AND COMPLAINTS
Users may exercise their rights by sending a written request to emma@pronunciationwithemma.com, attaching a copy of their identification document.
Users may also lodge a complaint with the competent supervisory authority: Spanish Data Protection Agency (www.aepd.es).

 

10. SECURITY MEASURES
The Company implements appropriate technical and organisational measures to ensure a level of security appropriate to the risk, in accordance with Article 32 of the GDPR. Such measures include, among others, access protocols, encryption, audits, and staff training.

 

11. USE OF COOKIES AND SIMILAR TECHNOLOGIES
This website may use first-party and third-party cookies to personalise the User’s experience and analyse traffic. For more information, please refer to the Cookies Policy.

 

12. CHANGES TO THE PRIVACY POLICY
The Company reserves the right to amend this Policy to reflect legislative or case law developments. Any changes will be duly communicated through the usual channels.

 

13. APPLICABLE LAW AND JURISDICTION
This Policy shall be governed by and interpreted in accordance with Spanish law and the General Data Protection Regulation (EU Regulation 2016/679).
 

Any dispute shall be submitted to the competent Courts of the city of Barcelona.

 

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