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Privacy Policy of Espanjan Nurkka
Privacy Policy of Espanjan Nurkka
Last updated: August 2026
1. Data Controller
1. Data Controller
In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (General Data Protection Regulation or GDPR), as well as the applicable Finnish data protection legislation, please be informed that the controller of personal data is:
LM Digital Projects Oy
Trading name: Espanjan Nurkka
Contact details
Email:maria@espanjannurkka.fi
Telephone / WhatsApp: +358413114591
Address: Kauppakatu 32 lh 5
Business ID (Y-tunnus): 3505390-3
For any questions regarding the processing of personal data, users may contact the Data Controller through any of the contact methods listed above.
2. Scope of Application
2. Scope of Application
The purpose of this Privacy Policy is to provide clear and transparent information about how Espanjan Nurkka collects, uses, stores, protects and, where applicable, discloses the personal data of individuals who use its services.
This policy applies to:
individuals who visit the Espanjan Nurkka website;
individuals who request information about courses or activities;
students enrolled in any course;
participants in events organised by Espanjan Nurkka;
any other person who maintains a relationship with the Data Controller.
Personal data will always be processed in accordance with the principles set out in Article 5 of the GDPR: lawfulness, fairness, transparency, purpose limitation, data minimisation, accuracy, storage limitation, integrity, confidentiality and accountability.
3. Categories of Personal Data Processed
Espanjan Nurkka only collects personal data that is necessary to provide its educational services, comply with legal obligations and improve the learning experience of its students.
3.1 Identification and Contact Data
The following data may be processed, among others:
first name and surname;
email address;
telephone number;
preferred language of communication.
Purpose
Managing enrolments.
Maintaining communication with students.
Providing information related to the courses purchased.
Responding to enquiries.
Legal Basis
Performance of a contract.
Legitimate interest.
Consent, where applicable.
3.2 Billing Data
3.2 Billing Data
Where necessary for administrative management and compliance with legal obligations, the following data may be processed:
billing address;
information required to issue invoices;
payment history;
tax information when required by applicable legislation.
Purpose
Issuing invoices.
Administrative management.
Compliance with tax and accounting obligations.
Legal Basis
Compliance with legal obligations.
Performance of a contract.
3.3 Academic Data
In order to organise teaching activities appropriately, the following data may be processed:
Spanish language level;
placement test results;
assigned group;
attendance records;
academic progress;
pedagogical observations related to the learning process.
Purpose
Organising groups.
Adapting teaching to students’ levels.
Monitoring learning progress.
Providing personalised support.
Legal Basis
Performance of a contract.
3.4 Information Voluntarily Provided for Learning Personalisation
As part of Espanjan Nurkka's educational methodology, students may voluntarily provide information such as:
personal interests;
hobbies;
learning goals;
motivation for studying Spanish;
specific learning-related needs;
availability;
any other information that the student considers useful for personalising their learning experience.
Providing this information is entirely voluntary.
Refusing to provide it will not prevent access to the courses.
Purpose
Personalising materials and activities.
Adapting the learning pace.
Designing activities related to students’ interests.
Providing a more individualised learning experience.
Legal Basis
Consent of the data subject.
4. Purpose and Legal Basis of Processing
4. Purpose and Legal Basis of Processing
Personal data will only be processed for legitimate and specific purposes, including:
managing requests for information;
processing enrolments;
organising groups and schedules;
delivering courses;
monitoring students’ learning progress;
personalising the learning process;
managing billing and payments;
complying with legal and tax obligations;
maintaining communication with students;
organising activities and events;
continuously improving the quality of the services provided.
Each processing activity will rely on an appropriate legal basis, which may include:
performance of a contract for educational services;
compliance with legal obligations;
consent of the data subject;
the legitimate interest of the Data Controller, provided that the rights and freedoms of the data subject do not override such interest.
Where processing is based on consent, consent may be withdrawn at any time without affecting the lawfulness of processing carried out prior to its withdrawal.
5. Retention of Personal Data
Personal data will only be retained for as long as necessary to fulfil the purposes for which it was collected and, where applicable, for the periods required by applicable legislation.
Once these periods have expired, the data will be securely deleted or anonymised, unless a legal obligation requires its retention for a longer period.
* Unless applicable legislation establishes a longer retention period.
6. Disclosure and Transfer of Personal Data to Third Parties
Personal data will be processed by the Data Controller, as well as by persons expressly authorised by the Data Controller to perform their duties and by data processors appointed in accordance with Regulation (EU) 2016/679 (GDPR).
All processing activities will be carried out using appropriate technical and organisational measures to ensure the security, confidentiality and integrity of personal data.
As a general rule, personal data will not be disclosed to third parties, except in the following circumstances:
a) Where there is a legal obligation to do so or where a request has been made by a competent public authority.
b) Where this is necessary to comply with accounting, tax, legal, administrative or financial obligations.
c) Where this is essential for the provision of the contracted services through service providers acting as data processors.
Espanjan Nurkka may currently use the following data processors:
7. International Transfers of Personal Data
Some of the technology providers used by Espanjan Nurkka may process personal data outside the European Economic Area.
Where this occurs, such transfers will only take place where the provider offers appropriate safeguards in accordance with the General Data Protection Regulation, including, where applicable, European Commission adequacy decisions, Standard Contractual Clauses or other legally recognised mechanisms.
Espanjan Nurkka will endeavour to use providers that offer a high level of protection for personal data.
8. Communication Channels
In order to properly provide its educational services, Espanjan Nurkka may communicate with students through the following channels:
Email.
Telephone.
SMS messages.
WhatsApp.
Electronic invoicing (e-lasku), where applicable.
The learning platform used during the course.
The video conferencing platform used for online classes.
These communications will be used exclusively for the proper management of the educational and administrative relationship between the student and Espanjan Nurkka.
Participation in Padlet group boards is entirely voluntary. Students understand that when participating by commenting on Padlet group boards, the username they have chosen will be visible to other members of the board who are students of Espanjan Nurkka.
Students may leave these digital boards voluntarily at any time without this affecting their student status or the provision of any other contracted services.
9. Exercises Involving Audio and Video Recordings
9. Exercises Involving Audio and Video Recordings
As part of Espanjan Nurkka's teaching methodology, some exercises may involve the voluntary submission of audio or video recordings to the teacher for educational purposes only, for example, to practise speaking, pronunciation, comprehension or communication in real-life situations.
These recordings will only be used for educational purposes and to provide individual feedback to the student.
The recordings will not be shared with other students or third parties without the explicit consent of the data subject, unless there is a legal obligation permitting or requiring such disclosure.
The recordings will only be retained for as long as necessary to fulfil the educational purpose for which they were created and will subsequently be securely deleted.
10. Photographs and Videos During Activities and Events
10. Photographs and Videos During Activities and Events
Photographs or video recordings may be taken during certain activities or events organised by Espanjan Nurkka.
The taking and use of photographs or videos in which an individual can be identified will be subject to the applicable legal basis and, where necessary, the individual's prior consent.
Authorised photographs and videos may be used, depending on the scope of the consent given, to document Espanjan Nurkka activities and, where applicable, to communicate and promote its activities through its website, social media or other official channels.
Consent to the use of images may be withdrawn at any time. Withdrawal of consent will not affect the lawfulness of any use carried out prior to the withdrawal.
11. Data Minimisation Principle
11. Data Minimisation Principle
Espanjan Nurkka is committed to collecting only personal data that is adequate, relevant and necessary for the purposes for which it is processed.
No personal information will be requested where it is not necessary for the management of courses, provision of educational services, voluntary personalisation of learning, organisation of activities or fulfilment of the legal obligations of the Data Controller.
Where additional information is voluntarily provided in order to personalise the learning experience, such information will only be used for the purposes specified in this Privacy Policy.
12. Security of Processing
12. Security of Processing
The processing of personal data will be based on the principles of lawfulness, fairness, transparency, data minimisation, relevance and accountability.
Data may be processed using electronic and digital systems and, where necessary, in physical form, using appropriate technical and organisational procedures and measures to ensure its security and confidentiality.
Espanjan Nurkka will take reasonable measures to reduce the risks of loss, accidental destruction, theft, unauthorised access, unlawful use, unwanted modification or improper disclosure of personal data.
These measures may include, among others:
authentication systems and passwords;
devices protected by appropriate security measures;
restricted access to personal data;
services and platforms provided by providers offering appropriate security guarantees;
backups where necessary;
procedures designed to prevent access by unauthorised persons.
Access to personal data will be limited to persons who need access to perform their duties.
Espanjan Nurkka also undertakes to maintain the confidentiality of personal data and to process it in accordance with applicable data protection legislation.
13. Rights of Data Subjects
13. Rights of Data Subjects
Individuals whose personal data is processed by Espanjan Nurkka may exercise the rights recognised under Regulation (EU) 2016/679 (GDPR) at any time by submitting a request to the Data Controller using the contact details provided in this Privacy Policy.
In particular, the data subject has the right to:
a) Right of access
Request confirmation as to whether Espanjan Nurkka is processing their personal data and, where this is the case, obtain access to such data and to the information provided for in Article 15 of the GDPR.
b) Right to rectification
Request the correction of inaccurate personal data and the completion of incomplete personal data.
c) Right to erasure
Request the deletion of their personal data where any of the circumstances set out in Article 17 of the GDPR apply, including where the data is no longer necessary for the purposes for which it was collected or where the processing is unlawful.
This right is subject to the exceptions and retention obligations established by applicable legislation.
d) Right to restriction of processing
Request the restriction of the processing of their personal data in the cases established in Article 18 of the GDPR.
e) Right to data portability
Request to receive the personal data they have provided to Espanjan Nurkka in a structured, commonly used and machine-readable format, and to request that such data be transmitted to another controller where the requirements of Article 20 of the GDPR are met.
f) Right to object
Object to the processing of their personal data where such processing is based on the legitimate interests of the Data Controller, provided that there are grounds relating to their particular situation which override those interests, in accordance with Article 21 of the GDPR.
The data subject may object at any time to the processing of their personal data for direct marketing purposes.
g) Right not to be subject to certain automated decisions
The data subject has the right not to be subject to a decision based solely on automated processing, including profiling, where such decision produces legal effects or similarly significantly affects them, under the terms established in Article 22 of the GDPR.
Espanjan Nurkka does not currently use systems for solely automated decision-making that produce legal effects or similarly significant effects on its students.
Exercising Rights
Exercising Rights
Requests may be submitted by email or in writing using the contact details of the Data Controller provided in this Privacy Policy.
In order to protect users' personal information, Espanjan Nurkka may request additional information where reasonably necessary to verify the identity of the person making the request.
The exercise of rights recognised under the GDPR will generally be free of charge. In the exceptional cases provided for in Article 12 of the GDPR, the measures established in that Article may apply.
Espanjan Nurkka will respond to requests without undue delay and, in principle, within one month of receiving the request. Where a request is particularly complex or where a large number of requests are received, this period may be extended in accordance with the conditions established by the GDPR.
Where the processing of certain data is based on consent, the data subject may withdraw their consent at any time. Withdrawal of consent will not affect the lawfulness of processing carried out before the withdrawal.
14. Complaints
14. Complaints
Espanjan Nurkka encourages anyone who has questions, concerns or objections regarding the processing of their personal data to first contact the Data Controller in order to resolve the matter as quickly and appropriately as possible.
Questions or complaints may be addressed to:
LM Digital Projects Oy
Trading name: Espanjan Nurkka*
Email: maria@espanjannurkka.fi
*Espanjan Nurkka is a trading name used by LM Digital Projects Oy. Registration of the auxiliary company name is pending.
Without prejudice to any other administrative or judicial remedy, every data subject has the right to lodge a complaint with the competent supervisory authority if they consider that the processing of their personal data infringes the GDPR. In Finland, the competent authority is the Office of the Data Protection Ombudsman (Tietosuojavaltuutetun toimisto).
Office of the Data Protection Ombudsman
Lintulahdenkuja 4
00530 Helsinki
Finland
Postal address:
P.O. Box 800
00531 Helsinki
Finland
Telephone: +358 29 566 6700
Email: tietosuoja@om.fi
The data subject may also lodge a complaint with the supervisory authority of the Member State concerned in the cases provided for in Article 77 of the GDPR.
15. Changes to the Privacy Policy
15. Changes to the Privacy Policy
Espanjan Nurkka may amend or update this Privacy Policy where necessary, for example, due to changes in the services provided, the tools and platforms used, applicable legislation or personal data processing practices.
The updated version will be available on the Espanjan Nurkka website and will include the date of its latest update.
Where a change significantly affects users' rights or the way their personal data is processed, Espanjan Nurkka will take the necessary measures to inform the persons concerned where required by applicable legislation.
Users are advised to review this Privacy Policy periodically to stay informed about any updates.
16. Contacto
16. Contacto
For any questions regarding this Privacy Policy, the processing of personal data or the exercise of rights recognised under the GDPR, you may contact the Data Controller:
LM Digital Projects Oy
Trading name: Espanjan Nurkka
Email: maria@espanjannurkka.fi
Telephone / WhatsApp: +358 413114591
Address: Kauppakatu 32 lh 5
Business ID (Y-tunnus): 3505390-3
*Espanjan Nurkka is a trading name used by LM Digital Projects Oy. Registration of the auxiliary company name is pending.
Contact person for data protection matters:
María del Mar Tur Martí
Last updated: August 2026
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