LEGAL NOTICE

You are in a space committed to the rights of its users and for this reason, you will have maximum transparency and rigor about everything you need to know about this website.

This website strictly complies with Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights (LOPDGDD). It also complies with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 regarding the protection of natural persons (RGPD), as well as with Law 34/2002, of July 11, of Information Society Services and Electronic Commerce (LSSICE or LSSI).

The services and / or products are available only to legal entities and persons who are 18 years old.

Identifier of the person in charge of the web

  • Name:  Laxe Gorostiza Cerviño
  • NIF: 44346888J
  • Address::  San Sebastián – España.
  • Email:  hablacomama@gmail..com
  • Sitio Web:  https://hablacomama.com
  • Activity: Private Spanish classes online

Are you worried about your personal data?

Read the “Privacy policy”

Commitments and obligations of the users

The user is informed, and accepts, that access to this website does not imply, in any way, the beginning of a commercial relationship with Habla Comama.In this way, the user agrees to use the website, its services and contents. without violating current legislation, good faith and public order.

The use of the website, for illegal or harmful purposes, or that, in any way, may cause damage or impede the normal functioning of the website is prohibited. Regarding the contents of this website, it is prohibited:

  • Its reproduction, distribution or modification, in whole or in part, unless you have my authorization as the legitimate owner.
  • Any violation of the rights of the provider or of me as the legitimate owner.
  • Its use for commercial or advertising purposes.

When using the www.hablacomama.com website, the user agrees not to carry out any conduct that could damage the image, interests and rights of Habla Comama or third parties, or that could damage, disable or overload the www.hablacomama.com, or that would prevent, in any way, the normal use of the web.

However, the user must be aware that the security measures of computer systems on the Internet are not entirely reliable and that, therefore, www.hablacomama.com cannot guarantee the absence of malware or other elements that may cause alterations in the systems computer (software and hardware) of the user, or in their electronic documents and files contained therein, although I put all the necessary means and the appropriate security measures to avoid the presence of these harmful elements.

Security measures

The personal data communicated by the user to Habla Comama may or may not be stored in automated databases, whose ownership corresponds exclusively to Laxe Gorostiza, who assumes all technical, organizational and security measures that guarantee confidentiality, integrity and quality of the information contained therein in accordance with the provisions of current data protection regulations.

Communication between users and www.hablacomama.com uses a secure channel, and the transmitted data is encrypted thanks to https protocols, therefore, I guarantee the best security conditions so that the confidentiality of the users is guaranteed.

External links

The web pages www.hablacomama.com provide links to other own websites and content that are owned by third parties such as

  • spotify.com
  • youtube.com
  • calendly.com
  • stripe.com
  • gmail.com
  • instagram.com
  • facebook.com
  • pinterest.com

The sole purpose of the links is to provide the user with the possibility of accessing said links.

Habla Comama is not responsible in any case for the results that may derive to the user by accessing said links.

Likewise, the user will find within this site, pages, promotions, affiliate programs that access the browsing habits of users to establish profiles. This information is always anonymous and not identifiable to the user.

Information provided on these sponsored sites or affiliate links is subject to the privacy policies used on those sites and will not be subject to this privacy policy. So I highly recommend users to carefully review the privacy policies of affiliate links.

Exclusion of guarantees and responsibility

Habla Comama does not grant any guarantee, nor is it responsible, in any case, for damages of any kind due to:

  • The lack of availability, maintenance and effective operation of the web, or of its services and contents.
  • The existence of malware, malicious or harmful programs in the contents.
  • The illicit, negligent, fraudulent use or contrary to this Legal Notice.
  • The lack of legality, quality, reliability, usefulness and availability of the services provided by third parties and made available to users on the website.
  • Illegal or improper use of this website.

Habla Comama, holds all rights over the content, design and source code of this website and in particular the information. Not with standing the foregoing, the business names, trademarks or distinctive logos referred to in this website belong to their respective owners and are protected by current legislation regarding intellectual property and industrial property. The owner of the website reserves the right to update the content when they deem it appropriate, as well as to remove, limit or prevent access to the content, on a temporary or permanent basis. Any act of transmission, distribution, replication, storage or public disclosure, in whole or in part, must have the explicit permission of Habla Comama. The use of hyperlinks to the website, both the home page and the other pages, is allowed. Any use, alteration or exploitation of the contents included in the website for purposes contrary to law, morality or public order is prohibited. It is guaranteed that most of the images used to illustrate the pages of the website have been taken from , https://www.canva.com/ and https://sp.depositphotos.com after acquiring the appropriate licensing of their use. The rest of the images are owned by Habla Comama, its partners, professionals and / or other staff shall not be liable for any damage or loss suffered, direct or indirect, by any user, or third party, for any decision that may be taken based on the content of this website. Nor does  Habla Comama accept responsibility for the contents of pages to which the user can access from links included in their website.

PRIVACY POLICY

ADDITIONAL INFORMATION ON DATA PROTECTION

What is done and not done with your personal data on this website you will find here.

This policy expresses how the personal information of all the people who interact with Habla Comama through this website will be treated and protected. Please, you must read all the sections of the Legal Notice, the cookie policy and this privacy policy before using this website.

In accordance with the provisions of EU Regulation 2016/679, of the European Parliament and of the Council of April 27, 2016 (RGPD) and Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of rights digital,Laxe Gorostiza, informs you that, by accepting this Privacy Policy, you give your express, informed, free and unequivocal consent so that the Data you provide, and on which the security, technical measures are applied and organizational provisions provided for in current regulations, are treated by Laxe Gorostiza, as the data controller.

WHO IS THE RESPONSIBLE FOR THIS WEBSITE?

Responsible Identity: Laxe Gorostiza

Commercial name: Habla Comama

NIF: 44346888J

Address: San Sebastián-España

Email: hablacomama@gmail.com

Activity: Private Spanish Classes online

Contact details of the person in charge or representative, and of the data protection officer, if applicable: email: ihablacomama@gmail.com 

WHAT PERSONAL DATA IS COLLECTED ON THIS WEBSITE?

For the purposes established in this Privacy Policy, Habla Comama collects and processes the Personal Data detailed below, which will depend on the different products or services that you request on this website:

Identification data: name, surname.

Contact information: email.

Contractual data: data of contractual operations, ID, products and services acquired, financial operations, payment data.

Navigation data: IP address, type and identification of the device, type of browser, domain through which you access the Website, browsing data, activity on the Website.

ON WHAT LEGAL BASIS IS THIS DATA TREATED?

We treat your personal data with the following legal bases:

  • The execution of a contract with Habla Comama, to contract services, publish advertisements and manage the requested services.
  • The consent of the user in relation to contact, subscription to content and the sending of commercial communications, via mail, cookies or messaging systems.
  • The legitimate interest of the data controller to protect users of the Habla Comama website from abuse and fraud in the use of our services.

FOR WHAT PURPOSES WILL WE TREAT YOUR DATA?

On this website, there are different forms, in each of them, the information you collect will be used as follows:

(Select those that apply or add those that apply)

  • Content subscription forms: there are several forms to activate the subscription. The data provided will be used exclusively to send the Newsletter and keep you updated on news and specific offers, exclusively for subscribers of www.hablacomama.com
  • Comments form: The personal data entered in the form to insert these comments will be used exclusively to moderate and publish them.
  • Contact form: There is also a contact form for questions, suggestions or professional contact. In this case, the email address will be used to respond to them and send the information that the user requires through the web.
  • Registration Form: In this case, we request the following personal information: Name, Email, so that you can create an account in our system and give access to its functionalities.
  • Sales form: I also process data to manage the purchase of Private Spanish Lessons online, including order management, payment and all operations related to the contracting of the chosen service or product. This includes sending follow-up emails, responses, invoices, receipts, etc.

CONSERVATION TIME OF PERSONAL DATA

Customer Data: The period of conservation of personal data will vary depending on the service that the Customer hires. In any case, it will be the minimum necessary.

Subscriber data: From the moment the user subscribes until they unsubscribe.

Data of potential clients: the data will be kept in any case during the validity of the established commercial relationship and, once concluded, two years, unless the user requests its deletion beforehand.

WHAT ARE YOUR RIGHTS REGARDING THE USE OF YOUR DATA?

Anyone has the right to obtain confirmation as to whether or not Habla Comama is treating personal data that concerns them.

Interested persons have the right to:

  • Request access to personal data relating to the interested party.
  • Request its rectification or deletion.
  • Request its cancellation.
  • Request the limitation of your treatment.
  • Oppose the treatment.
  • Request the portability of the data.

If you have given your consent for a specific purpose, you have the right to withdraw the consent granted at any time, without affecting the legality of the treatment based on the consent prior to its withdrawal.

To exercise these rights, you can write to hablacomama@gmail.com

There is a form to exercise your rights, you can request it by email.

These forms must be electronically signed or accompanied by a photocopy of the DNI.

If someone represents you, you must attach a copy of your ID, or it must be signed with your electronic signature.

The forms can be presented in person, sent by letter or by mail to the address of the person in charge that appears at the beginning of this text.

REMARKETING ACTIONS: GOOGLE ADS

Ads is a Google platform for ADVERTISERS who want to advertise on GOOGLE. In www.hablacomama.com, Google Ads is used, Google’s advertising platform that allows you to create campaigns and advertisements to show them on other web pages. When generating an ad, you can segment your audience by:

  • Place
  • Demographic data (age, sex, etc.)
  • Interests (activities, hobbies, etc.)
  • What they buy on the internet and through other channels
  • Etc.

The data obtained through Google Ads are subject to this privacy policy from the moment the user leaves their data in the form on this website to join the subscription newsletter. In no case will the information from Google be used for a different purpose.

FACEBOOK ADS

This website uses Facebook Ads:

Facebook Ads allows you to segment the audience to target an ad.

Thanks to Facebook’s custom audiences feature, an audience can be created from user and subscriber data on this website, such as email addresses and phone numbers. To do this, it is necessary to share the databases with Facebook in order to later create personalized audiences by directing the ads to people with similar profiles.

Confidential personal information is not used for targeting ads in accordance with Facebook Policies and is not shared with third parties or other advertisers, and will be removed by Facebook as soon as said process is complete. In addition, Facebook will ensure confidentiality.

The ad system designed by Facebook allows you to show relevant and useful ads without revealing your identity to advertisers, being able to reach groups of people with specific profiles.

At any time as a user, you can revoke your consent through https://www.facebook.com/settings?tab=ads, where you can configure the reception of ads. You can also indicate that you do not want interest-based ads from Facebook, or from other companies, through the European Interactive Digital Advertising Alliance (EDAA) of Your On Line Choices ( http:// www.youronlinechoices.com/es/ ) or in the settings of your computer or your mobile device.

To use the custom audiences function, this website uses Facebook’s Website Custom Audience tool, which makes use of the Facebook pixel that marks the visitor to this website anonymously. If you wish to object to the use of Facebook’s Website Custom Audiences, you have the possibility to do so at: https://www.facebook.com/ads/website_custom_audiences/.

For more information on the scope and purpose of the collection of data by Facebook and its subsequent treatment, as well as, to configure your privacy you must go to the following links:

https://www.facebook.com/privacy/explanation.

Facebook conversion tracking pixel

For the optimization of the advertising campaigns of the ads that are published on Facebook, and for statistical purposes, the conversion tracking pixel of Facebook Inc., 1601 s is used. California Ave, Palo Alto, CA 94304, which tracks user actions after clicking on an ad.

The data obtained through said pixel is anonymous and does not refer to identified natural persons, nor is it stored, nor are profiles created with their personal data.

This data can be stored and processed by Facebook, and it can link this data with your Facebook account and also use it for its own advertising purposes in accordance with the Facebook data use policy that you will find at https://www.facebook.com/about/privacy/, recently updated at https://www.facebook.com/about/privacy/update.

You can enable Facebook and its partners to insert advertisements on and off Facebook, and for these purposes a cookie may be stored on your computer.

NOTIFICATION AND DECLARATION OF GAPS

Security notification and breach declaration

At Habla Comama we assume security measures appropriate to the level of risk to protect personal information against loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in processing and the nature of personal information ; However, if Laxe Gorostiza, determines that your service data has been misappropriated (even by a Laxe Gorostiza employee they have been exposed by a security breach or incorrectly acquired by a third party, Laxe Gorostiza will inform you immediately of said security breach, appropriation or improper acquisition.

TO WHICH RECIPIENTS WILL YOUR DATA BE COMMUNICATED?

Many tools used on this website to manage data are hired by third parties. To provide services strictly necessary for the development of the activity, Laxe Gorostiza shares data with the following providers under their corresponding privacy conditions:

Third-party service providers (for example, payment processing, order processing, analytics, marketing campaign management, website management, and email distribution services and other similar service providers) in order for them to perform functions commercials on behalf of Laxe Gorostiza.

The web development and maintenance company, or the hosting company, may have access to this website from time to time. They have signed a service provision contract that requires them to maintain the same level of privacy that applies to the treatments carried out on this website.

Any international transfer of data derived from the use of tools or service providers will adhere to the Privacy Shield agreement, which guarantees that American software companies comply with European data protection policies in terms of privacy, secrecy and data security. .

Specifically, this website uses the following tools:

  • Email marketing tool: Mailer Lite and Convert pro
  • Billing tool: Stripe
  • Analysis tools: Google Analytics and Facebook Pixel
  • Online chat tool: Facebook Messenger and Instagram Messenger
  • Others: Stripe, Calendly

AFFILIATE LINKS AND ADVERTISING

On this website, the User is offered sponsored content, advertisements and / or affiliate links.

Among the links that you can find, there is the possibility of informing and referring to products and / or services and / or info-products of third parties. The information that appears in these affiliate links or the inserted ads is provided by the advertisers themselves, so www.hablacomama.com is not responsible in any case for inaccuracies or errors that the ads may contain, nor can it offer guarantees about the experience , integrity or responsibility of advertisers, or the quality of their products and / or services, although those products or services that www.hablacomama.com and its team have tried will always be recommended.

In addition, the ads will remain published on the portal until they are eliminated or suspended by the advertiser or www.hablacomama.com, which logically is not responsible for the fact that, once they have been removed from their databases, the ads continue to be indexed in search engines outside this portal.

Every user must understand that any contractual or extra-contractual relationship between the User and the advertisers, affiliates or third parties contacted through this website, are understood to be made solely and exclusively between the user and the advertiser and / or third person. www.hablacomama.com only acts as a channel or advertising medium and, therefore, has no type of responsibility for damages or losses of any nature caused by its negotiations, conversations and / or contractual or extra-contractual relationships with advertisers or third parties physical or legal entities contacted through this website.

SECRET AND SECURITY OF DATA

www.hablacomama.com is committed to the use and treatment of the user’s personal data, respecting its confidentiality, in accordance with the purpose of those; as well as to comply with its obligation to save them and adapt all measures to avoid alteration, loss, treatment or unauthorized access, in accordance with the provisions of current data protection regulations.

This website includes an SSL certificate. It is a security protocol that makes your data travel in an integral and safe way; that is, the transmission of data between a server and the web user, and in feedback it is fully encrypted or encrypted.)

www.hablacomama.com  cannot guarantee the absolute impregnability of the Internet network, nor, therefore, the violation of data through fraudulent access to them by third parties.

Regarding the confidentiality of the processing, Laxe Gorostiza will ensure that any person who is authorized by Laxe Gorostiza to process the client’s data (including its personnel, collaborators and providers), will be under the appropriate obligation of confidentiality (whether it is a duty contractual or legal).

When a security incident occurs, when Laxe Gorostiza realizes it, it must notify the Client without undue delay and must provide timely information related to the Security Incident as it is known, or when the client reasonably requests it.

ACCURACY AND TRUTH OF THE DATA

As a user, you are solely responsible for the veracity and correctness of the data you send to www.hablacomama.com , exonerating Laxe Gorostiza (Habla Comama) from any responsibility in this regard. Users guarantee and are responsible, in any case, for the accuracy, validity and authenticity of the personal data provided, and undertake to keep them duly updated. The user agrees to provide complete and correct information in the contact or subscription form.

REVOCABILITY

The consent given, both for the treatment and for the transfer of the data of the interested parties, is revocable at any time by communicating it to Laxe Gorostiza (Habla Comama) in the terms established in this Policy for the exercise of ARCO rights. This revocation will in no case be retroactive.

CHANGES IN THE PRIVACY POLICY

Laxe Gorostiza reserves the right to modify this policy to adapt it to new legislation or jurisprudence, as well as to industry practices. In such cases, it will announce on this page the changes introduced with reasonable anticipation of their implementation.

COOKIE POLICY

This policy defines the conditions set for the following domains:

https://hablacomama.com

Why do I have to inform you about cookies?

Within the LSSI-CE regulation (Information Society and Electronic Commerce Law), there is a section dedicated to cookies that requires those of us who have a website that downloads third party cookies in your browser, we have the obligation to inform the user about the type of cookies, the duration and the purpose of each one of them. You will understand that it is not easy, but I have the obligation to try to get as close as possible to these requirements.

This website uses its own and third-party cookies to give you a better browsing experience, to share content on social networks and to obtain statistics and browsing habits of users of this blog.

As a user, you can refuse the processing of data or information by blocking these cookies using the appropriate settings on your browser. However, you should be aware that, if you do so, this site may not function properly.

According to article 22.2 of Law 34/2002 on Information Society Services and Electronic Commerce, if you continue browsing, you will be giving your consent to the use of these cookies.

As a user, you expressly accept, by using this website, the processing of the information collected in the manner and for the purposes detailed below. You also acknowledge that you are aware of the possibility of refusing the processing of such data or information by rejecting the use of Cookies by selecting the appropriate settings for this purpose in your browser. Although this option of blocking Cookies in your browser may not allow you to make full use of all the functionalities of this website.

What is a cookie?

A cookie is a file that is downloaded to your computer when you access certain websites. Cookies allow a website, among other things, to store and retrieve information about the browsing habits of a user or their computer and, depending on the information they contain and the way you use your computer, they can be used to recognise the user.

Considering the way the Internet and websites work, it is not always possible to have information from cookies placed by third parties through my website. This applies in particular to cases where my website contains so-called embedded elements: texts, documents, images or short films that are stored elsewhere, but are displayed on or via our website and those derived from analysis plug-ins used by this website. Therefore, in the event that you encounter such cookies on this website and they are not listed below, you should let me know so that I can review that cookie and add it to this list if necessary.

If you do not want cookies to be stored in your browser or if you wish to be informed each time a cookie is set, you can set your browser to do so. Most browsers allow cookies to be managed in 3 different ways:

  • Cookies are always rejected
  • The browser asks if the user wants to install each cookie.
  • Cookies are always accepted

The browser can also include the possibility to better specify which cookies should be accepted and which should not. Specifically, the user can normally accept one of the following options:

  • Reject cookies from certain domains.
  • Reject cookies from third parties.
  • Accept cookies as non-persistent (they are deleted when the browser is closed).
  • Allow the server to create cookies for a different domain.

If you encounter cookies on this website that are not listed below, please let me know. You can also contact the third party directly to request information about the cookies it sets, the purpose and duration of the cookie, and how it has ensured your privacy.

Cookies used by this website

This website uses its own and third-party cookies to provide you with a better browsing experience, to share content on social networks and to obtain user statistics.

As a user, you can refuse the processing of data or information by blocking these cookies using the appropriate settings on your browser. However, you should be aware that, if you do so, this site will not function properly.

According to the terms included in Article 22.2 of Law 34/2002 on Information Society Services and Electronic Commerce, if you continue browsing, you will be giving your consent to the use of the cookies detailed below. 

The cookies on this website help to:

  • Make this website work properly.
  • Save you having to log in every time you visit our website.
  • Remind you of your settings during and between visits.
  • Allow you to view videos.
  • Earn revenue through affiliate cookies, facebook ads and Adsense.
  • Improve the speed / security of the site.
  • Allow you to share pages with social networks.
  • Continuously improve this website through analytics.
  • Allow you to purchase and pay for the products I offer (Stripe cookies).
  • I will never use cookies to:
  • Collect personally identifiable information (without your express permission).
  • Collect sensitive information (without your express permission)
  • Share personally identifiable information with third parties 

Third party cookies that I use and that you should be aware of this website, like most websites and blogs, includes functionality provided by third parties. 

Habla Comama may use third-party services that collect information for statistical purposes, the use of this website by the user and for the provision of other services related to the activity of this website and other Internet services.

In particular, this website uses Google Analytics, a web analytics service provided by Google, Inc. domiciled in the United States with headquarters at 1600 Amphitheatre Parkway, Mountain View, California 94043. In order to provide these services, they use cookies to collect information, including the user’s IP address, which will be transmitted to, processed and stored by Google on the terms set out on the Google.com website.

Including the possible transmission of such information to third parties for reasons of legal requirement or where such third parties process the information on Google’s behalf.

 Among the most stable third-party cookies are:

  • Technical Cookies: These are those that allow the user to navigate through a website, platform or application and the use of the different options or services that exist in it such as, for example, control traffic and data communication, identify the session, access parts of restricted access, remember the elements that make up an order, make the buying process of an order, make the application for registration or participation in an event, use security features while browsing, store content for broadcasting videos or sound or share content via social networks.
  • Personalisation cookies: These cookies allow the user to access the service with some predefined general characteristics depending on a series of criteria in the user’s terminal, such as the language, the type of browser used to access the service, the regional configuration from which the service is accessed, etc.
  • Analysis Cookies: These are those that are well treated by Habla Comama or by third parties, allow me to quantify the number of users and thus perform the measurement and statistical analysis of the use made by users of the service offered. To do this, your browsing on my website is analysed in order to improve the range of products or services that we offer.
  • Advertising cookies: These are cookies that, either processed by Habla Comama or by third parties, allow me to manage as effectively as possible the offer of advertising spaces on this website, adapting the content of the advertisement to the content of the service requested or to the use you make of my website. To do this, I can analyse your browsing habits on the Internet and I can show you advertising related to your browsing profile.
  • Remarketing Cookies: These are also cookies that track browsing habits in order to target advertising based on your interests and offer you differential advertising. These cookies are associated with the anonymous user and their computer, and do not in themselves provide the name and surname of the user.
  • Affiliate Cookies: This website collaborates with partners who promote this site and some specific launches, such as webinars. These cookies are necessary to allow us to reward these partners and these cookies are generally created by specialised companies (known as affiliate networks). Neither the owner of this website nor the partners can identify you personally.
  • Social media cookies: Social media cookies may be stored in your browser while you are browsing Habla Comama. For example, when you use the button to share Habla Comama content on a social network.

The companies that generate these cookies corresponding to the social networks used by this website have their own cookie policies:

Twitter cookie, according to the provisions of its privacy policy and use of cookies.

Pinterest cookie, as set out in its privacy policy and use of cookies. 

Linkedin cookie, as set out in its Cookie Policy.

Facebook cookie, as set out in its Cookie Policy.

Calendly cookie, as set out in its Cookie policy

Stripe cookie, as set out in its Cookie policy

The privacy implications will depend on each social network and will depend on the privacy settings you have chosen in these networks. In no case, neither the manager of this website nor the advertisers can obtain personally identifiable information from these cookies.

How to manage and disable these cookies

If you do not want websites to place any cookies on your computer, you can adjust your browser settings so that you are notified before any cookies are downloaded. Similarly, you can adjust your browser settings so that your browser rejects all cookies, or only third-party cookies. You can also delete any cookies that are already on your computer. Please note that you will have to adapt the settings separately for each browser and device you use.

 Habla Comama makes available to users who wish to prevent the installation of the aforementioned cookies, links provided for this purpose by browsers whose use is considered to be the most widespread:

 Google Chrome – Internet Explorer – Mozilla Firefox – Apple Safari.

 Notices regarding cookies

The Publisher accepts no responsibility for any technical faults that the user may encounter on the website or in his/her browser due to incorrect handling of the deactivation or deletion of cookies. At all times the user should check the information on their deactivation or deletion in the help section of his/her browser. The user assumes responsibility for deleting or disabling cookies in their browser and therefore assumes the consequences arising therefrom.

At any time, the user may contact the Publisher at hablacomama@gmail.com.