Privacy Policy
Tutore Vaughan S.L. (hereinafter "¿Cómo Estás?", "we", "us") is committed to protecting your personal data and complying with Regulation (EU) 2016/679 (GDPR) and the UK GDPR as retained in UK law.
Data Controller
Tutore Vaughan S.L. — CIF B78489820 — C/ General Yagüe 7, 28020 Madrid, Spain — privacy@comoestas.co.uk
Purposes and Legal Basis
We process your personal data to (a) manage your account and deliver the service you subscribed to (Art. 6.1.b GDPR — performance of a contract); (b) manage live video classes and sessions (Art. 6.1.b); (c) send service communications (Art. 6.1.b); (d) comply with legal obligations (Art. 6.1.c).
Video Sessions
Live video classes are conducted via a third-party videoconferencing provider. Audio and video are processed in real time to deliver the class. Sessions are not recorded unless explicitly communicated. Your teacher can see and hear you during the session only.
Data Retention
Account data is retained for the duration of the contractual relationship and up to 5 years thereafter as required by law. Session metadata (date, topic, teacher) is retained for 3 years.
Your Rights
You have the right to access, rectify, erase, restrict processing, and data portability. You may also object to processing and lodge a complaint with the UK Information Commissioner's Office (ICO — www.ico.org.uk) or the Spanish Data Protection Authority (AEPD — www.aepd.es). To exercise your rights, contact: privacy@comoestas.co.uk.
Third-Party Services
We use the following sub-processors: (1) Pusher Ltd — real-time notifications; (2) Amazon Web Services — file storage; (3) Postmark — transactional email. Each has been assessed for GDPR and UK GDPR compliance. No data is transferred outside the EEA or UK without adequate safeguards.
Contact
Data Protection queries: privacy@comoestas.co.uk