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Last Updated: November 2025

1. CONTROLLER INFORMATION

In accordance 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 (GDPR), and Spanish Organic Law 3/2018 of December 5 on Personal Data Protection and guarantee of digital rights (LOPDGDD), we inform you of the following:

Data Controller:
Kaizen Global SL (operating under the trade name "Vivid Spanish")

Tax ID: B22854087
Address: Emilia Guardia 5, 08960, Barcelona, Spain
Email: info@kaizenglobal.es
Website: www.vividspanish.com

2. PURPOSE OF DATA PROCESSING

At Vivid Spanish, we process the information provided by interested parties for the following purposes:

2.1. Language Immersion Program Management

• Process applications and bookings for programs

• Manage participation in language immersion activities in Barcelona

• Coordinate accommodation with host families

• Organize Spanish classes and cultural activities

• Communications related to the contracted program

2.2. Minor's Data

For participants under 18 years of age, we collect additional information including medical data, allergies, and emergency contacts, solely to ensure their safety, wellbeing, and proper care during the program.

2.3. Audiovisual Material

With the express consent of parents or legal guardians, we may capture photographs and videos during program activities for:

• Internal program documentation

• Promotional use on social media and website (with specific authorization)

• Memories for participants

2.4. Communications and Marketing

• Sending information about our programs and services

• Newsletter and commercial communications (only with express consent)

• Response to inquiries made through contact forms

2.5. Legal Compliance

• Issuing invoices and accounting management

• Compliance with tax and fiscal obligations

3. PERSONAL DATA WE COLLECT

3.1. Identification and Contact Data

• First and last name

• Date of birth

• Email

• Phone number

• Mailing address

• Nationality

• Passport number

3.2. Minor's Data (14-18 years)

• Relevant medical information

• Allergies and intolerances

• Emergency contacts

• Parental authorization

3.3. Navigation Data

• IP address

• Browser type

• Pages visited

• Time spent

• Information collected through cookies (see section 8)

4. LEGAL BASIS FOR PROCESSING

The legal basis for processing your personal data is:

• Contract Performance: Processing necessary for the provision of contracted language immersion services

• Data Subject's Consent: For sending commercial communications, use of images, and non-essential data

• Parental Consent: For processing data of minors under 18 years

• Legal Compliance: For invoicing and tax obligations

• Legitimate Interest: For improving our services and fraud prevention

5. DATA RECIPIENTS

Your personal data may be communicated to:

5.1. Service Providers

• Host Families: We share necessary data for accommodation coordination (name, age, allergies, dietary preferences, relevant medical information)

• Monitors and Teachers: Access to information necessary for activity development and classes

• Payment Processors: To manage payments securely

• Technology Providers: Hosting, email marketing, management tools

5.2. Legal Obligations

• Public administrations when there is a legal obligation

5.3. International Transfers

For American participants, we have established an entity in the United States (LLC) that facilitates the payment process. Data necessary for these transactions may be transferred to the US under appropriate safeguards in accordance with GDPR.

Some technology providers may be located outside the European Economic Area. In these cases, we ensure adequate safeguards exist (Standard Contractual Clauses approved by the European Commission, certifications, etc.).

6. DATA RETENTION

We will retain your personal data for:

• Contractual Data: During the contract term and up to 6 years after its completion (statute of limitations for legal actions)

• Tax and Accounting Data: 4-6 years according to legal obligations

• Commercial Communications: Until you revoke your consent

• Images and Videos: Until you revoke your consent or request deletion

• Navigation Data: Maximum 2 years

7. DATA SUBJECT RIGHTS

You may exercise the following rights:

• Access: Know what personal data we have about you

• Rectification: Correct inaccurate or incomplete data

• Erasure: Request deletion of your data

• Restriction: Request limitation of processing

• Portability: Receive your data in a structured format

• Objection: Object to the processing of your data

• Consent Withdrawal: Withdraw consent at any time

7.1. Specific Rights for Minors

Parents or legal guardians may exercise these rights on behalf of minors.

7.2. How to Exercise Your Rights

You may exercise your rights by sending an email to info@kaizenglobal.es attaching a copy of your ID card, passport, or equivalent identification document.

7.3. Complaint to the Supervisory Authority

If you believe the processing of your data is not correct, you may file a complaint with the Spanish Data Protection Agency (AEPD) at www.aepd.es.

8. COOKIES AND TRACKING TECHNOLOGIES

Our website uses cookies and similar technologies to improve user experience and analyze web traffic.

8.1. Types of Cookies We Use

Technical Cookies (necessary):

• Enable navigation and use of basic website functionalities

Analytical Cookies:

• Google Analytics: We analyze user behavior to improve our website. Data is collected anonymously.

Chatbot Cookies:

• Enable the online chat service functionality

8.2. Cookie Management

You can configure your browser to reject cookies or be notified when they are sent. Disabling cookies may affect website functionality.

For more information, please see our Cookie Policy [link].

9. DATA SECURITY

We have implemented appropriate technical and organizational measures to protect your personal data against:

• Unauthorized access

• Accidental loss

• Misuse

• Alteration

• Unauthorized disclosure

However, no Internet transmission system is 100% secure. We do everything possible to protect your data, but we cannot guarantee absolute security.

10. MINORS

Our programs are designed for students aged 14 to 18 years.

For participation of minors under 18 years, we require express consent from parents or legal guardians for:

• Processing of the minor's personal data

• Processing of medical and health data

• Capture and use of images and videos

Parents or guardians may exercise the minor's rights and revoke consent at any time.

11. CONTACT FORMS AND COMMUNICATIONS

Data provided through contact forms will be processed solely to respond to your inquiry and will not be used for other purposes without your express consent.

If you wish to receive commercial information about our programs, you must expressly indicate this in the corresponding form.

12. PRIVACY POLICY MODIFICATIONS

We reserve the right to modify this Privacy Policy to adapt it to legislative changes or changes in our business practices.

We will notify you of any significant changes through:

• Prominent notice on our website

• Email to the address you have provided us

We recommend reviewing this policy periodically.

13. CONTACT

For any questions about this Privacy Policy or about the processing of your personal data, you may contact us at:

Email: info@kaizenglobal.es
Address: Emilia Guardia 5, 08960, Barcelona, Spain

Consent:

By using our services and providing your personal data, you declare that you have read and accepted this Privacy Policy.

For minors under 18 years, the parent or legal guardian declares having read and accepted this policy on behalf of the minor.