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FORVO S.L. PRIVACY POLICY

Privacy Policy is updated as of December 16, 2022.

This Privacy Statement informs that the personal data of the users of the FORVO website and the other applications and services that include FORVO brand (hereinafter, "the Services" or "the Service"), will be treated in accordance with the principles of transparency, purpose limitation, data minimization, accuracy, integrity and confidentiality, as well as respecting the other obligations and guarantees established in Regulation (EU) 2016/677 of the European Parliament and of the Council of April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

FORVO provides its services in accordance with its Terms and Conditions and this Privacy Policy. FORVO reserves the right to modify and update this Privacy Policy at any time. All changes will be posted on our website, and any interested party can consult the latest version of this Privacy Policy at any time at https://forvo.com/privacy/. The fact of continuing to use the service or the website after such changes have been made will be considered as an acceptance by you of the new Privacy Policy.

This policy contains the following information:

  • Information and identification of our company and its legal consideration as responsible.
  • The personal data we process;
  • How and why, we process your personal data;
  • When and why, we might disclose your personal data to other companies or organizations;
  • International data transfers;
  • The rights that protect you and your options regarding your personal data;
  • The measures we take to ensure that your information is kept secure and confidential;
  • How long we will retain your personal data;

Controler: FORVO MEDIA S.L., (FORVO). NIF: B20987541. Address: Txirrita Maleo 3G, 20100 - Renteria, Gipuzkoa, Spain. Gipuzkoa Commercial Registry: Volume: 2, 408 - Page: 153 Vto - Inscription: 2nd - Section: 8th - Page: SS-31.114, is the controller that determines the purposes and means of the processing of personal data according whit this Privacy Policy.

Personal Data: Personal data is any information relating to an identified or identifiable natural person. In this sense, an identifiable natural person is considered to be any person whose identity can be determined, directly or indirectly, by an identifier such as a name, an identification number, location data, an online identifier or one or more physical, physiological, genetic, psychological, economic, cultural or social elements of that person.

Usually, we process the personal information that the user provides for commercial contracting or subscription of a service, the information generated through the provision of the same, as well as the data generated or estimated by us. Based on the principle of minimization, the data that we can process will be adequate, relevant and limited to those necessary for the purposes for which they are processed, always respecting the user's will.

The data subject to processing will be different depending on the service that FORVO is going to provide or the user profile that accesses the services. Therefore, this Privacy Policy is applicable to both the users of the website www.forvo.com and the students and/or teachers of the FORVO online learning platform. The data and information that we may process as a result of the use or subscription of the services are as follows:

  • When a user account is created, FORVO collects personal information such as your username, email address, date of birth, gender, spoken or studied language, phone number, academic or professional data, economic data such as payment and/or billing information, as well as any other personal information such as photographs and/or presentation videos or any other preferences that may be voluntarily added.
  • FORVO also collects and automatically generates information from other areas of use, such as service metadata, login information, device information, IP addresses, third-party data and information obtained from cookies. We may also collect, use and share aggregated data, such as statistical or demographic data, for any purpose. Aggregated data may be derived from your personal data, but, under the law, is not considered personal data as it does not reveal your identity either directly or indirectly. In no case will we collect any special category of personal data concerning you (which includes information about your race or ethnic origin, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership and your health or genetic or biometric data).

By using or subscribing to the Services, you can set up your personal profile, establish relationships, send and receive messages through the Services, perform searches and queries, enroll in or book classes and courses, and transmit information through various channels.

There is no legal or contractual obligation to provide this data, but in the event that it is not provided, we will be unable to provide the service.

Purposes processing of your data:

The personal data provided by users of the services will be processed by FORVO for the following purposes:

  • To provide, update, maintain and protect the Services, websites, applications and activities;
  • To manage and track the contractual and pre-contractual relationship that FORVO maintains with users;
  • To comply with applicable legislation, legal procedure or regulation;
  • To respond to your questions, comments and requests;
  • To send you commercial and/or advertising communications, including, among others, emails, push notifications, SMS and messages within the application about the services;
  • For statistical purposes, internal reporting, in a dissociated manner,
  • For billing, economic management of accounts/services and administrative matters related to the Services;
  • In the case of the internal communications service between teachers and students, to send notifications informing about the reception of said message, as well as the person who has sent the mentioned message;
  • To investigate and help prevent security problems, third-party claims and/or abuse;
  • For other purposes, to the extent that these are described at the time of collection.

The user should be aware that if they enter payment data from or related to any credit or debit card when purchasing or contracting any of the Services (including any subscription), FORVO does not receive or store this information, as it is received, stored and used by our payment service providers in order to complete the purchase (stripe.com, maybe an example). FORVO will only store the necessary banking data (a bank account number) to pay teachers for their classes.

The user can opt out of receiving promotional communications from FORVO when registering or subscribing to the Services. They can also opt out of receiving any communication, email, push notification or SMS in the same message.

Registration for the Services can be done by synchronizing with third-party services (Log-in with Facebook, Apple or Google account). If you follow a link to these websites, please note that you are sharing your profile information with us. The personal data shared depends on the settings of your Facebook, Apple or Google Platform. Visit the Platform related and review its privacy policy to understand how your personal data is shared and used in this context. The data we collect from your profile are email address, phone number and photograph (if they are configured in the profile), name and surname, gender, date of birth and city of residence.

Lawfulness of processing your personal data. -

Managing your registration as a user of the Services: The processing of your data is necessary for the execution of the terms that regulate the use and access to the Services. You are giving us your consent by accepting this privacy policy through the established consent mechanisms (links and verification check). Similarly, we consider that we have a legitimate interest to carry out the necessary checks to detect and prevent possible frauds when registering.

Managing the subscription, impartation, payment and collection of classes by teachers and students: The legitimating basis is the contractual and pre-contractual relationship maintained with the users at the time of acceptance of the Terms and Conditions of the services.

Manage booking requests for classes: Processing of data is necessary for the provision of the service requested, in accordance with the contractual relationship maintained with the user.

Posting advertisements or language teaching offers through the Services: processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;

Sending of commercial communications: The lawfulness of processing is the express consent that you grant us (for example: when you authorize the sending of advertising or our newsletter).

Management of incidents related to the use of the Services: The processing is necessary for the execution of the contractual relationship maintained with you. When the query is related to the exercise of the rights that we inform you about below, or with claims related to our services, what legitimizes us to treat the data is the fulfillment of legal obligations on our part.

Data storage periods.

In compliance with the principle of limitation of the storage period, the data will be processed exclusively by the time necessary and for the purposes for which they have been collected at each moment. They will therefore be maintained in such a way as to allow the identification of the interested parties for no longer than necessary for the purposes of the processing of personal data. In accordance with the above, we have established the following retention periods that will be applicable, unless a different period has been specified in this Privacy Policy or in the conditions of provision of each of the products and services that include the FORVO brand.

  • To carry out the processing related to the execution of the contract, the data will be kept for as long as is strictly necessary to fulfill the purposes required by each Service. For example, data obtained from the user will be kept while they are active; and information about traffic, navigation and location will be treated for a period that can range from 3 to 12 months to comply with the obligations of maintaining network security or preventing fraud.
  • In accordance with civil, commercial and tax legislation, data related to the contracting and invoicing of contracted services will be stored for a period of 8 years from the user's deactivation. In the case of receiving your CV or academic information, they will be kept for a period of three years, unless you register as a user, in which case that information will be kept until you unsubscribe from FORVO.

After the above indicated deadlines, the data may be destroyed, blocked or anonymized, as appropriate, and in accordance with the legislation.

Your rights concerning the processing of your data.

In accordance with the terms of the applicable legislation, the user is informed that he/she has the following rights:

  • Access: allows the data subject to obtain information about whether or not we are processing personal data concerning him/her and, if so, the right to obtain information about your personal data undergoing processing.
  • Rectification: allows you to correct errors and modify data that proves to be inaccurate or incomplete.
  • Erasure (‘right to be forgotten’): The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her.
  • Restriction of processing: under the legally established conditions, allows data processing to be stopped, in such a way as to prevent its processing in the future, which will only keep it for the exercise or defense of claims.
  • Right to object: in certain circumstances and for reasons related to their particular situation, data subjects may oppose the processing of their data. In this case, the data will no longer be processed, except for compelling legitimate reasons, or the exercise or defense of possible claims.
  • Data portability: allows the data subject to receive their personal data concerning them, which they have provided to us, and to be able to transmit them directly to another data controller in a structured, commonly used and machine-readable format. In order to exercise this right, it will be necessary for the customer to provide a valid e-mail address. Please note that this right only applies to automated information in respect of which the user initially consented to its processing or in the event that the information has been used to enter into a contract with you.

FORVO guarantees the adoption of necessary measures to ensure the exercise of these rights free of charge, being necessary for such exercise to attach a copy of your official identification document in general. However, depending on the complexity of the request, the complete attention/response of certain rights could take a longer period of time, which in any case will not exceed two additional months.

To exercise any of the previously mentioned rights, FORVO users who are interested may contact, easily and free of charge, through the e-mail address info@forvo.com. As established by law, the exercise of these rights will be dealt with by us within a maximum period of one month.

Finally, the data subject shall have the right to lodge a complaint with the national supervisory authority that may be applicable. For this purpose, please contact https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

Information we share.

We only share personal data with third-party recipients, for any of the purposes outlined in the Privacy Policy, in order to maintain the contractual relationship, as well as those that are legally required in compliance with any applicable regulations as set out below:

  • Necessary for the provision of service: To manage some of the necessary functions for the provision of the service, we have contracted trusted providers who may have access to personal data, who will act as data processors and who will be contractually obligated to comply with their legal obligations as data processors, to maintain the confidentiality and secrecy of the information.
  • Payment Service Providers: For the financial management of payments between teachers, students, and FORVO. Financial institutions third party payment services like Stripe or any other. This type of information will only be shared or communicated to the extent that it is strictly necessary to carry out the billing and payment of the courses that are provided.
  • Hosting services, video-call services, maintenance and support in our databases, as well as in our software and applications that may contain data about you.
  • Fulfillment of a legal obligation: Your personal information may also be communicated to third parties legally authorized when necessary to comply with the law. In this sense, the user's personal data may be communicated to the various public authorities under a legal obligation, such as tax and customs authorities, judicial authorities, judicial police and any other that according to current regulations may be applicable.

In any case, the user's personal data will be shared with third party companies without obtaining your prior consent, unless the communication of your data was necessary to ensure the maintenance of the contractual relationship with the user as well as in the cases provided for by the current regulations at all times.

International data transfer.

We only store your personal information on secure servers located in secure facilities in the European Economic Area, and we have an up-to-date firewall. Whenever we transfer your personal data outside the EEA, we can ensure a similar level of protection by ensuring that we only transfer your personal data to countries that the European Commission considers to provide an adequate level of protection for personal data.

In this context, we inform you that some of the functions necessary for the provision of the service are contracted with processors located outside the European Economic Area that, in any case, ensure an adequate level of protection of personal data. The data processors located outside the European Economic Area used for the provision of the services indicated below that, in any case, guarantees an adequate level of protection of personal data.

Cookies.

A cookie is a small text file, often with an anonymous unique identifier, that is sent to your browser from a website's computers and stored on your computer's hard drive. You can set your browser to accept all cookies, reject all cookies, or to notify you when cookies are downloaded. If you wish to delete cookies from your computer, please refer to your browser instructions to locate the file or directory where they are stored. If you reject all cookies, you may not be able to use some of the features of the Service. For more information about how we use cookies on FORVO, please visit https://forvo.com/cookie-policy/.

Social Networks

FORVO uses different social networks (Facebook, Twitter, etc.) to disseminate contents related to FORVO as well as to provide users with a way of contact. FORVO is responsible for the treatment of the data of its followers and contacts in social networks. Nevertheless, since the processing of personal data takes place within the framework of social networks whose suppliers impose operating rules, FORVO obligations will be limited to those aspects in which the company is free to act. Under no circumstances will FORVO extract data from social networks, make profiles of its users or collect additional personal data related to tastes, hobbies or mode of use of social networks, without the express consent of those affected.

Security and privacy in the processing of data/information.

FORVO is committed to ensuring the security, secrecy and confidentiality of your data, communications and personal information. That is why, as part of our commitment and in compliance with applicable law, we have adopted the most appropriate security measures and technical procedures to prevent loss, incorrect use or unauthorized access. When we receive your data, we use security procedures and functions to prevent any unauthorized access.

The personal data that we may collect through various communications that we maintain with you will be treated with absolute confidentiality, committing us to secrecy and ensuring the duty to protect them by adopting all necessary and reasonable measures to prevent their alteration, loss and unauthorized access or treatment, in accordance with the established in the applicable legislation.

For cases of security breach of personal data that involve risks to the rights of individuals, we will take the necessary measures to correct the situation and mitigate the possible negative effects that such a breach may have caused. We will also notify our customers or users and the competent National Authority when so required by the applicable data protection regulations.

Processing data of minors.

Is expressly prohibited that children under 14 years of age provide their data to FORVO without the previous consent of their parents, guardians or other legal representatives. In case that the User grants the use of the services to a user under 14 years of age, as responsible for the same will be responsible for authorizing and deciding on the processing of the data of the same in the terms set out in this Policy. FORVO will ensure the proper use of the data of minors ensuring respect for the laws applicable to them with the measures that are reasonably appropriate.

When parents, guardians or legal representatives of such minors detect unauthorized data processing, they may submit their queries or complaints by writing to info@forvo.com.

Other information

These terms and conditions are FORVO's Privacy Policy with respect to its customers/users in connection with the use of its products and services, and replace any prior agreements that may exist between FORVO and its customers/users. In the event that any provision of these terms and conditions, or any part thereof, is declared unlawful, invalid or unenforceable by a competent administrative or judicial body, it shall be deemed not to have been enforced, without affecting the other provisions.

The delay or the failure of FORVO in exercising a legal action or any right described in these conditions does not constitute, in any case, a renouncement of the same. Likewise, failure to claim a failure to comply with the obligations set in these conditions, will not imply a renouncement of its subsequent claim.

This Privacy Statement is updated as of December 16, 2022.