Privacy Policy

1. Introduction

In compliance with the provisions of 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 on the free movement of such data (hereinafter, the GDPR), and Organic Law 3/2018, of 5 December, on Personal Data Protection and the Guarantee of Digital Rights (hereinafter, the LOPDGDD), the educational institution HIGHLANDS SCHOOL LOS FRESNOS of the CONGREGATION OF THE LEGIONARIES OF CHRIST (hereinafter, “HIGHLANDS SCHOOL LOS FRESNOS”) wishes to inform users of this website of its policy regarding the processing and protection of the personal data of those individuals who voluntarily provide their contact details, use email to contact HIGHLANDS SCHOOL LOS FRESNOS, complete information request forms for the admissions/enrolment process, dining services, transport, extracurricular activities, camps, or general enquiries, complete the work with us form, use the services made available to members of the school community or parents/guardians, or use any other service available on the website that involves communicating their personal data to HIGHLANDS SCHOOL LOS FRESNOS.
This Privacy Policy contains a general description of the aspects relating to the processing of personal data carried out by HIGHLANDS SCHOOL LOS FRESNOS as the controller of such processing arising from the operation of this Website. It is the responsibility of the user to read, prior to communicating their personal data to HIGHLANDS SCHOOL LOS FRESNOS, the information notices provided by HIGHLANDS SCHOOL LOS FRESNOS. This policy is expressly and fully accepted by the user from the moment that, for the use of this site or any of its services, they communicate their personal data to HIGHLANDS SCHOOL LOS FRESNOS, as such communication is voluntary. Should the user disagree with this policy, they must not use any service on this Website that requires the communication of their personal data to HIGHLANDS SCHOOL LOS FRESNOS.

2. Data Controller

Identification: HIGHLANDS SCHOOL LOS FRESNOS of the Congregation of the Legionaries of Christ
Tax Identification Number (NIF): R2800595G
Address: C. de la Comunidad Canaria, 8, 28660 Boadilla del Monte, Madrid, Spain

3. Data Protection Officer (DPO)

To contact the Data Protection Officer, you may send an email to the following email address: dpo@serviciosrc.es

4. Purposes of Personal Data Processing

Users accessing the HIGHLANDS SCHOOL LOS FRESNOS website are not required to provide personal information in order to use the website; therefore, any communication of data for such purposes shall occur because the user has voluntarily chosen personalised browsing or use of the services, accepting this Privacy Policy by ticking the corresponding box.

In view of the above, if the user wishes to access particular services that require prior registration, they must complete the personal data request forms. In this regard, depending on the form completed in each case and the means by which the data is collected, HIGHLANDS SCHOOL LOS FRESNOS may process personal data for the following purposes:

  • To attend to and respond to any enquiries, questions, comments or concerns relating to the information contained on the website, as well as to provide the information requested by the user.
  • To manage admission applications and process new enrolments at HIGHLANDS SCHOOL LOS FRESNOS.
  • To send commercial and promotional communications by email, WhatsApp, SMS, social media communities or any other electronic or physical means, whether current or future, that make it possible to carry out commercial communications. Such information may continue to be sent even after the commercial relationship between HIGHLANDS SCHOOL LOS FRESNOS and the user (if any) has ended, or until the user objects.
  • To assess and, where appropriate, allow participation as a candidate in current or future recruitment processes to work with us, retaining personal data for a period of 2 years from the completion of the recruitment process or, if the individual does not participate in a recruitment process, from the date on which their CV was provided, in order to fulfil the purposes for which the data is being processed and to comply with the relevant legal obligations. After this period, the data shall remain blocked for an additional period of 3 years in order to address any liabilities that may arise from the processing. In all cases, the user shall be responsible for ensuring that such data remains up to date at all times.
  • If the data is provided for the use of an online service (Educamos), the data will be processed in order to manage the use of that service, which may include authenticating the user’s identity and/or sending access credentials to enable access to and use of the service, as well as any purposes directly or indirectly arising from the use of such services through this website.

5. Data Sharing with Third Parties

We use the feature known as Google Ads Customer Match. This tool enables us to use certain contact details that you have provided to us (for example, your email address and/or telephone number) in order to attempt to identify you as a user within Google services (such as your Google Account, YouTube or other associated services) and, in this way, display personalised advertisements when you browse those platforms, tailored to your interests so that they are more relevant to you.
Before your data is sent to Google, it is transformed through a process known as hashing. This means that, instead of your email address or telephone number being sent directly, they are converted into a code consisting of letters and numbers that does not allow you to be directly identified.
In this way, your data travels more securely and cannot be easily read by third parties during transmission. This system acts as a protective measure to reduce the risk of unauthorised access.
However, this process does not completely eliminate the possibility of identifying you. When Google receives that code, it may compare it with codes generated from the data of its own users. If there is a match, Google may recognise that it relates to you within its services and use this information to display personalised advertising.
The legal basis that legitimises this processing is your consent, which you may provide by ticking the box provided for this purpose on the admissions form. You may withdraw this consent at any time, without affecting any processing carried out prior to its withdrawal nor, in any event, the admissions process, which is not conditional upon the provision of such consent.
For the provision of this service, your data will be disclosed to Google Ireland Limited and, where applicable, Google LLC. This may involve international transfers of data outside the European Economic Area, particularly to the United States. These transfers are carried out on the basis of appropriate safeguards in accordance with the applicable regulations, specifically the existence of an adequacy decision adopted by the European Commission, such as the Data Privacy Framework to which Google LLC adheres.
Additionally, you should be aware that Google may process the data it receives as part of this functionality for its own purposes, acting as an independent data controller. Such purposes may include, among others, improving its services, measuring advertising campaigns, preventing fraud, or developing new products.
wise, in the context of such processing activities carried out for its own purposes, Google may combine or link this information with other data it already holds about you (for example, data derived from your activity across other Google services, such as searches, browsing activity or app usage), in accordance with its own Privacy Policy. For more information about how Google processes your personal data, please consult its Privacy Policy: https://policies.google.com/privacy
Your data will be processed for this purpose until the end of each promotional campaign relating to the relevant academic year and, in any event, until you withdraw your consent before that time. You may withdraw your consent at any time, as well as exercise your data protection rights in accordance with the terms set out in this Privacy Policy.

6. Mandatory Information

Personal data will be processed by the technical service providers of HIGHLANDS SCHOOL LOS FRESNOS that manage the Website and the distribution of commercial communications, such as IT service providers, website administrators, and communications delivery companies. Such providers shall process personal data only to the extent necessary to provide their respective services to HIGHLANDS SCHOOL LOS FRESNOS and under its instructions, and in no event for their own purposes.
The data provided by the user to HIGHLANDS SCHOOL LOS FRESNOS may be disclosed to entities related to THE CONGREGATION OF THE LEGIONARIES OF CHRIST. Such entities include, by way of example and without limitation: Francisco de Vitoria University Foundation, Altius Francisco de Vitoria Foundation, Logos Foundation, DIF Foundation, Alter Christus Foundation and the Royal Monastery of Santa Isabel Foundation. The purpose for which the data is disclosed is to provide information relating to the aforementioned entities that may be of interest to the user.

7. Social Media

The data requested through the website is mandatory, as it is necessary for the provision of an optimal service to the user. Should all the required data not be provided, HIGHLANDS SCHOOL LOS FRESNOS does not guarantee that the information and services supplied will be fully tailored to the user’s needs.

8. Minors and Incapacitated Individuals

Social media platforms are services provided by third-party providers that allow users to participate in a virtual community with other users through which they can create their own public profile, where they may create and share content, information and personal data with other users of the network. Within a social network, pages, accounts or profiles may be created and shared for personal and/or commercial purposes. The operation of a social network is governed, firstly, by the terms and conditions established by the owner and/or provider of the network and, secondly, where pages, accounts or profiles are created for commercial purposes, by the terms and conditions established by the controller of the commercial profile or account, who shall also be the controller of the personal data processed through it, where applicable.
HIGHLANDS SCHOOL LOS FRESNOS maintains profiles on various social media platforms including, without limitation, Instagram, Facebook, YouTube and LinkedIn. Users may follow us and become fans of the official HIGHLANDS SCHOOL LOS FRESNOS pages on the aforementioned social media platforms and other social networks.
Users are informed that any processing of data carried out through the pages, profiles or accounts of HIGHLANDS SCHOOL LOS FRESNOS on social media platforms shall be governed by the corresponding policies and terms and conditions of both the official page and, where applicable, the owner of each social network. Such owner and provider of the social network shall likewise be the controller of the personal data files relating to users whose data is processed through the official page.

9. User Rights

If the user is a minor or lacks legal capacity, HIGHLANDS SCHOOL LOS FRESNOS advises that they must have the permission and consent of their parents, guardians or legal representatives before providing their personal data. Accordingly, HIGHLANDS SCHOOL LOS FRESNOS requests that they refrain from supplying personal data unless they have obtained the consent of their parents, guardians or legal representatives. Failing this, HIGHLANDS SCHOOL LOS FRESNOS shall not be held responsible for the actions of the minor or person lacking legal capacity. Notwithstanding the foregoing, HIGHLANDS SCHOOL LOS FRESNOS may process the data of individuals over fourteen years of age on the basis of their own consent, except in those cases where the law requires the assistance of those holding parental authority or guardianship

10. Commercial Communications

HIGHLANDS SCHOOL LOS FRESNOS informs users of their right to exercise the rights of access, rectification, erasure, objection, data portability and restriction of the processing of their data, under the terms established by the applicable legislation. For this purpose, and in accordance with the provisions of the GDPR and the LOPDGDD, users may exercise their rights by means of a written request sent to the postal address or via the email address of the Data Protection Officer (DPO) mentioned above, duly proving their identity.
Users are also informed that they may contact the Spanish Data Protection Agency (Agencia Española de Protección de Datos) in order to notify any issue relating to the processing of their personal data, as well as to lodge a complaint where their rights have been infringed, through the website www.aepd.es, by writing to its registered office at Calle de Jorge Juan, 6, 28001 Madrid, or by calling the contact telephone number: +34 912 66 35 17.

11. User Obligations

Users who have expressly authorised HIGHLANDS SCHOOL LOS FRESNOS to send commercial communications by email are hereby informed that, pursuant to Articles 21 and 22 of Law 34/2002 of 11 July on Information Society Services and Electronic Commerce (hereinafter, the LSSICE), they have the right to object to the processing of their data for promotional purposes and the receipt of commercial communications, as well as the right to withdraw at any time the consent granted for such purpose by simply notifying HIGHLANDS SCHOOL LOS FRESNOS of their decision.
To do so, users may submit their objection by sending an email to: info@serviciosrc.es.

12. Third-Party Data

The user shall be obliged to:
  • Ensure compliance with the principle of data quality, whereby the personal data provided must be adequate, relevant and not excessive. Furthermore, the information must always be accurate, up to date and truthful. The user must provide their own personal data; if personal data relating to a third party is provided, there must be a legally established representation. For these purposes, the user shall be solely responsible for any direct and/or indirect damage caused to third parties or to HIGHLANDS SCHOOL LOS FRESNOS through the use of another person’s personal data, or through the use of their own personal data where such data is false, inaccurate, outdated, inadequate or irrelevant. Likewise, any user who communicates the personal data of a third party shall be liable to that third party in respect of the information obligation established in Article 13 of the GDPR and Article 11 of the LOPDGDD where personal data has not been obtained directly from the data subject, and/or for the consequences of having failed to provide such information.
  • Inform HIGHLANDS SCHOOL LOS FRESNOS of any modification to the information previously provided. This must be done either by post to C. de la Comunidad Canaria, 8, 28660 Boadilla del Monte, Madrid, or by email to info@serviciosrc.es, identifying themselves as a user of the website and specifying the information that must be amended.
  • Maintain the confidentiality and secrecy of their access passwords and identification codes, informing HIGHLANDS SCHOOL LOS FRESNOS as soon as possible in the event of theft, loss, unauthorised access, etc. Until such notification is made, HIGHLANDS SCHOOL LOS FRESNOS shall be exempt from any liability that may arise.

13. Personal Data on the Website

If the user provides data relating to third parties to HIGHLANDS SCHOOL LOS FRESNOS for any purpose, they guarantee that such data has been obtained lawfully, that they have informed the data subjects in advance, that they have obtained their consent to communicate such data, and that the information provided is accurate and truthful.

14. Security Measures

With regard to any personal data that may be published on the HIGHLANDS SCHOOL LOS FRESNOS website, users are informed that such data forms part of one or more data processing activities owned and controlled by the aforementioned school and has been incorporated with the prior informed consent of the data subjects. Such data may not be freely processed or reproduced by the user or by other third-party users, even where reference is made to its source, unless the prior authorisation and informed consent of the data subject concerned has been obtained.
The personal data that HIGHLANDS SCHOOL LOS FRESNOS may publish on its website may include, without limitation, any numerical, alphabetical, graphical, photographic, acoustic or other type of information relating to identified or identifiable natural persons, such as names, surnames, photographs, images of events held by HIGHLANDS SCHOOL LOS FRESNOS, data published by users of web services and other information.

15. Data Retention

HIGHLANDS SCHOOL LOS FRESNOS declares that it has implemented all the necessary technical and organisational measures to ensure the security of data and prevent its alteration, loss, unauthorised processing or access, taking into account the current state of technology, the nature of the data stored and the risks to which it is exposed, whether arising from human action or from the physical or natural environment.
Notwithstanding the foregoing, such security measures are not infallible, and users are fully aware of this fact.

16. Cookies

Your data will only be retained for as long as necessary to fulfil the purposes for which it is being processed and to comply with the applicable legal obligations.
Once the data is no longer required, we will proceed to securely destroy it.

17. User Recommendations

In compliance with the LSSICE, this website uses cookies, allowing HIGHLANDS SCHOOL LOS FRESNOS to collect data in order to monitor users, obtain information about browsing habits and improve the use of the website, among other purposes.
Users may block or delete the cookies installed by configuring the settings of the browser installed on their computer. However, disabling them may prevent the proper functioning of the website, for which HIGHLANDS SCHOOL LOS FRESNOS shall not be held responsible. For further information, please refer to the Cookie Policy.

18.- RECOMMENDATIONS TO USERS

HIGHLANDS SCHOOL LOS FRESNOS recommends that users use the latest versions of software applications for browsing the Internet, as these incorporate enhanced security measures.
Likewise, HIGHLANDS SCHOOL LOS FRESNOS recommends that users make use of any security mechanisms available to them (secure web servers, encryption, digital signatures, firewalls, etc.) in order to protect the confidentiality and integrity of their data to the extent necessary, given that there are risks of identity theft and interception of communications.
HIGHLANDS SCHOOL LOS FRESNOS reminds users that the Internet is not completely secure. However, various means exist and continue to be developed that can improve the protection of their data. Therefore, users should make use of any means available to protect their data and communications, such as legally available encryption for confidential email and access codes for their own computers.
HIGHLANDS SCHOOL LOS FRESNOS advises users that whenever they provide personal information over the Internet, by means of email, newsgroups, discussion forums, etc., they should bear in mind that such information may be collected and processed for purposes not intended by them. For this reason, HIGHLANDS SCHOOL LOS FRESNOS recommends that users familiarise themselves with the confidentiality and privacy policies of the websites they visit.
HIGHLANDS SCHOOL LOS FRESNOS advises users that, unless encryption mechanisms are used, email communications over the Internet are not secure. Email messages and discussion forums may be subject to forgery and identity impersonation, and this should always be taken into account when using them. If users do not wish to disclose their email address, they should configure their browser so that it does not leave their email address on the web servers they access.
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