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Privacy Policy

PRIVACY POLICY

Last updated: [October 2026]

1. DATA CONTROLLER

In accordance with Regulation (EU) 2016/679 (General Data Protection Regulation, GDPR) and Spanish Organic Law 3/2018 on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD), we inform you that the controller of your personal data is:

Kaizen Global S.L., operating under the brand Vivid Spanish®
Tax ID (NIF): B-22854087
Registered address: [dirección del domicilio social], 08960 Sant Just Desvern (Barcelona), Spain
Email: info@vividspanish.com
Website: www.vividspanish.com

Vivid Spanish LLC, a company registered in Wyoming (United States), manages bookings and payments from the Americas on behalf of Vivid Spanish.

2. WHOSE DATA WE PROCESS

  • Parents and legal guardians who enquire about or book a Vivid Summer Program

  • Participants in our programs and trips, most of whom are minors

  • Teachers, school staff and school contacts who request a quote or book a Vivid School Trip

  • Anyone who contacts us through our website, email, phone or social media

3. WHY WE PROCESS YOUR DATA

3.1 Managing our programs and trips. To process enquiries, quotes and bookings; organise accommodation with host families or hotels; arrange flights, transport, classes, activities and excursions; and communicate with families and schools before, during and after the program or trip.

3.2 Participants' safety and wellbeing. To collect and use medical information, allergies, dietary needs and emergency contacts, solely to make sure participants are safe and properly cared for.

3.3 Photos and videos. With the express consent of parents, legal guardians or, for School Trips, the school, we may take photos and videos during activities for internal documentation, as a memory for participants, and, with specific authorisation, for promotional use on our website and social media.

3.4 Enquiries and communications. To answer enquiries sent through our contact forms, the quote form, email or phone, and, only with your express consent, to send you information about our programs and services.

3.5 Legal obligations. To issue invoices, keep accounting records and comply with tax obligations.

4. WHAT DATA WE COLLECT

4.1 Identification and contact data: name and surname, email, phone number, postal address, nationality and country of residence.

4.2 Participant data: date of birth, passport or ID details (needed for flights and accommodation), Spanish level, parental or school authorisation, and emergency contacts.

4.3 Health data: relevant medical information, medication, allergies and intolerances.

4.4 School data (School Trips): school name, contact person, group size, year group, travel dates, list of participants and accompanying teachers, and any information the school provides so that we can organise the trip.

4.5 Payment data: information needed to process payments. Card details are handled by our payment providers and are not stored by Vivid Spanish.

4.6 Browsing data: IP address, browser type, pages visited and time spent on the website, collected through cookies (see section 10).

5. LEGAL BASIS

  • Performance of a contract: to provide the programs and trips booked and to take the steps needed before booking, such as preparing a quote.

  • Explicit consent: to process health data (Article 9.2.a GDPR), to send commercial communications and to use images. Where necessary to protect a participant in an emergency, health data may also be processed to protect their vital interests (Article 9.2.c GDPR).

  • Consent of parents or legal guardians: for the processing of minors' data, in accordance with Article 7 of the LOPDGDD.

  • Legal obligation: for invoicing, accounting and tax purposes.

  • Legitimate interest: to answer enquiries, improve our services and prevent fraud.

6. WHO WE SHARE YOUR DATA WITH

We share only the data each recipient needs:

  • Host families: name, age, allergies, dietary needs and relevant medical information.

  • Teachers, team leaders and our program staff: the information needed to run classes and activities and to supervise participants.

  • Travel and program providers: airlines, hotels and accommodation providers, transport companies, activity providers and insurers.

  • Schools: for School Trips, the information needed to coordinate the trip with the school and its accompanying teachers.

  • Payment processors, to manage payments securely.

  • Technology providers: website hosting (Wix), email, calendar and booking tools (such as Google), and management software.

  • Public authorities, where there is a legal obligation.

  • Emergency and medical services, when necessary to protect a participant's health or safety.

7. INTERNATIONAL TRANSFERS

Some data may be transferred outside the European Economic Area, for example to Vivid Spanish LLC in the United States (to manage bookings and payments from the Americas) and to technology providers based in the United States. In all cases we make sure appropriate safeguards are in place, such as the EU–US Data Privacy Framework or Standard Contractual Clauses approved by the European Commission.

8. HOW LONG WE KEEP YOUR DATA

  • Contract and booking data: for the duration of the contract and up to 6 years after it ends, to meet legal obligations and to deal with any claims.

  • Health data: only for the duration of the program or trip, and deleted afterwards unless we are legally required to keep it.

  • Tax and accounting data: for the periods required by law (generally 6 years).

  • Enquiries that do not lead to a booking: up to 12 months.

  • Commercial communications: until you withdraw your consent.

  • Photos and videos: until consent is withdrawn or deletion is requested.

  • Browsing data: a maximum of 2 years.

9. YOUR RIGHTS

You can exercise the rights of access, rectification, erasure, restriction of processing, portability and objection, and withdraw your consent at any time, by writing to info@vividspanish.com. If we have reasonable doubts about your identity, we may ask you for additional information to confirm it.

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

If you believe that your data has not been processed correctly, you can file a complaint with the Spanish Data Protection Agency (AEPD) at www.aepd.es.

10. COOKIES

Our website uses technical cookies, necessary for it to work, and, with your consent, analytics cookies to understand how visitors use the site and improve it. You can accept, reject or configure non-essential cookies through the cookie banner, and change your preferences at any time. You can also set your browser to block cookies, although some features of the website may not work properly. 

11. SECURITY

We apply appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, misuse, alteration or disclosure. No online system is completely secure, but we work continuously to keep your data protected.

12. MINORS

Our Summer Programs are for participants aged 14 to 18, and our School Trips for students aged 11 to 18. We process minors' personal data, including health data and images, only with the consent of their parents or legal guardians or, for School Trips, through the school, which is responsible for obtaining the necessary authorisations from families.

13. CONTACT FORMS

Data sent through our forms is used only to answer your enquiry or prepare your quote. We will only send you commercial information if you have expressly agreed to it.

14. CHANGES TO THIS POLICY

We may update this Privacy Policy to reflect changes in the law or in our services. We will announce any significant change on our website and, where appropriate, by email.

15. CONTACT

For any questions about this Privacy Policy or the processing of your data:
Email: info@vividspanish.com
Address: Emilia Guardia 5,, 08960 Sant Just Desvern (Barcelona), Spain

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