Privacy Policy
Last Updated: January 15, 2025
At Xalvente Myrthon, we understand that choosing an educational program means trusting us with your personal information. This policy explains how we handle your data when you interact with our mobile game development courses and services. We're based in Barcelona and operate under Spanish and European Union data protection laws, which means you get some of the strongest privacy protections available anywhere.
Who We Are
Xalvente Myrthon operates as an educational platform focused on mobile game development training. Our main office sits at Rambla de Catalunya, 37, 08007 Barcelona, Spain. When we talk about "we," "us," or "our" in this document, we're referring to Xalvente Myrthon as the data controller responsible for your personal information.
You can reach our data protection team at help@xalventemyrthon.com or call us at +34944255260 during business hours.
What Information We Collect
Information You Give Us Directly
When you sign up for our programs or reach out to us, we collect what you share:
- Contact details: Your name, email address, phone number, and mailing address
- Account information: Username, password (encrypted), and profile preferences
- Educational background: Previous experience, skill level, and learning goals
- Payment data: Billing address and transaction details (though payment processors handle the sensitive bits)
- Communication records: Messages you send us through contact forms, emails, or support tickets
Information We Gather Automatically
Like most websites, ours collects some technical data when you visit:
- Device information: IP address, browser type, operating system, and device identifiers
- Usage patterns: Pages you visit, time spent on sections, links you click
- Learning progress: Course completions, quiz scores, and engagement metrics
- Technical logs: Access times, error reports, and system diagnostics
We don't collect sensitive personal data like health information, religious beliefs, or political opinions. If you accidentally share such information with us, let us know and we'll remove it promptly.
How We Use Your Information
We process your data for specific reasons, each grounded in legal bases required by Spanish and EU law:
Purpose | Legal Basis |
---|---|
Delivering educational services you've enrolled in | Contract performance |
Processing payments and managing your account | Contract performance |
Sending program updates and administrative notices | Contract performance |
Improving our courses based on user feedback | Legitimate interest |
Marketing communications (only with consent) | Consent |
Complying with legal obligations | Legal requirement |
We analyze learning patterns to understand which teaching methods work best. This helps us adjust course difficulty and identify where students typically need extra support. But we look at this data in aggregate form most of the time, not focusing on individual students unless you specifically reach out for help.
Sharing Your Data
We're selective about who gets access to your information. Here's the complete picture:
Service Providers We Work With
- Payment processors: Handle transactions securely without us seeing your full card details
- Email service providers: Help us send course materials and updates
- Cloud hosting services: Store our platform data with encryption
- Analytics tools: Process usage statistics to improve our services
All these partners sign agreements requiring them to protect your data and use it only for specified purposes. They can't use your information for their own marketing or other unrelated activities.
Legal Disclosures
Sometimes we're legally required to share information with authorities. This happens rarely but could include responses to valid court orders, law enforcement requests in criminal investigations, or regulatory inquiries. We'll notify you about such requests unless prohibited by law.
We never sell your personal data to third parties. That's not part of our business model and never will be. Your trust matters more than any potential revenue from data sales.
International Data Transfers
Our servers are primarily located within the European Union, but some service providers we use operate globally. When your data moves outside the EU/EEA, we ensure protection through:
- Standard Contractual Clauses approved by the European Commission
- Adequacy decisions recognizing equivalent protection levels
- Additional security measures like encryption and access controls
You can request details about specific safeguards for any particular transfer by contacting our data protection team.
How Long We Keep Your Data
We don't hold onto your information longer than necessary. Here's our retention approach:
- Active student data: Maintained throughout your enrollment plus one year after completion
- Financial records: Kept for seven years to comply with Spanish tax law
- Marketing consent records: Retained until you withdraw consent, then archived for proof of compliance
- Support communications: Usually deleted after three years unless related to ongoing issues
- Technical logs: Automatically purged after 90 days in most cases
After these periods, we either delete your data or anonymize it so completely that it can't be linked back to you. Some aggregated statistics might be kept indefinitely for historical analysis, but these contain no personal identifiers.
Your Privacy Rights
Under Spanish law and the GDPR, you have substantial control over your personal data. Here's what you can do:
Access Your Information
Request a copy of all personal data we hold about you. We'll provide this in a commonly used electronic format within one month. The first copy is free; we might charge a reasonable fee for additional copies.
Correct Inaccuracies
Update incorrect or incomplete information in your profile at any time. Most details can be changed directly through your account settings, but you can also contact us for assistance.
Delete Your Data
Request deletion of your personal information, sometimes called the "right to be forgotten." We'll comply unless we have legitimate grounds to retain specific data, such as legal obligations or defending against claims. We'll explain our reasoning if we can't delete everything you've requested.
Restrict Processing
Ask us to limit how we use your data in certain situations, like when you're challenging the accuracy of information or the lawfulness of processing. During restriction periods, we'll store the data but not actively use it.
Object to Processing
Object to processing based on legitimate interests or for direct marketing purposes. We'll stop unless we can demonstrate compelling grounds that override your interests or need the data for legal claims.
Data Portability
Receive your data in a structured, machine-readable format and transmit it to another service provider. This applies to information you provided under contract or consent.
Withdraw Consent
Revoke consent for processing activities that rely on it, like marketing emails. This doesn't affect the lawfulness of processing before withdrawal.
To exercise any of these rights, email us at help@xalventemyrthon.com with "Privacy Request" in the subject line. We'll verify your identity and respond within one month. Complex requests might take up to three months, but we'll keep you informed about progress.
Security Measures
Protecting your information is something we take seriously. Our security approach includes:
- Encryption: Data encrypted in transit using TLS protocols and at rest using AES-256
- Access controls: Role-based permissions ensuring staff only access data needed for their jobs
- Regular audits: Quarterly security assessments and annual penetration testing
- Staff training: Ongoing education about data protection and security best practices
- Incident response: Documented procedures for handling potential breaches
No system is completely invulnerable, but we maintain multiple layers of protection. If a breach affecting your data ever occurs, we'll notify you and relevant authorities within 72 hours as required by law.
Cookies and Tracking
Our website uses cookies and similar technologies. Most are essential for basic functionality, but others help us improve your experience:
- Essential cookies: Required for login, security, and basic navigation
- Functional cookies: Remember your preferences and settings
- Analytics cookies: Help us understand how people use the site
You can control cookie preferences through your browser settings. Blocking all cookies might affect some functionality. Our cookie banner gives you granular control over non-essential categories.
Children's Privacy
Our programs target adults and professionals. We don't knowingly collect data from anyone under 16 without parental consent. If you're under 16 and interested in our courses, please have a parent or guardian contact us. We'll work with them to ensure appropriate protections are in place.
If we discover we've inadvertently collected data from someone under 16 without proper consent, we'll delete it immediately.
Changes to This Policy
We update this policy occasionally to reflect new practices or legal requirements. When changes are significant, we'll notify you by email and prominently display a notice on our website for at least 30 days.
The date at the top shows when we last revised this document. Continuing to use our services after changes take effect means you accept the updated terms. If you disagree with modifications, you can close your account, though we'll retain some information as legally required.
Supervisory Authority
You have the right to lodge a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos) if you believe we've mishandled your personal data. While we hope you'll contact us first so we can address concerns directly, you can reach the agency at:
Agencia Española de Protección de Datos
C/ Jorge Juan, 6
28001 Madrid, Spain
www.aepd.es
Automated Decision-Making
We occasionally use automated systems to personalize learning paths or recommend courses based on your progress and stated interests. These recommendations don't produce legal effects or similarly significant impacts on you. You can always choose different courses regardless of automated suggestions.
We don't use automated decision-making for admissions, pricing, or other significant decisions that would require human oversight.
Questions or Concerns?
We're here to help with any privacy questions or concerns.
Email: help@xalventemyrthon.com
Phone: +34 944 255 260
Address: Rambla de Catalunya, 37, 08007 Barcelona, Spain