PRIVACY POLICY (LAST UPDATED: 30/01/2023)

Anfrinit respects your right to privacy. This Privacy Notice explains who Anfrinit is, how we collect, share and use personal information about you, and how you can exercise your privacy rights.

This Privacy Notice applies to personal information we collect from you through our website and your account at www.anfrinit.com (“Website”).

If you have any questions or concerns about our use of your personal information, then please contact us:

Anfrinit
Adrienn Csongor Domotor

Calle Anis de la Sierrezuela 9.

29651 Mijas, Malaga, Spain

Info@anfrinit.com

What personal information does Anfrinit collect?

Personal information you provide

The personal information that we may collect from you directly broadly falls into the following categories:

• Contacting us. If you contact Anfrinit, we will usually collect your name, email address, phone number, country and any further information you choose to provide about your query.

• Registering an account. When you register for an account with us as a Student, we will ask you for your name, email address, password and phone number. You may also choose to provide other details such as your photo, address, preferred language, date of birth, gender and business information.

• Course booking. When you book a course through our Website we will record this information, as well as details of the payments made for the courses.

This personal information will generally be used to register your account, provide you with the courses you have booked and the products you have order, and provide you with communications relating to your account and respond to your queries. We may also use the information to improve our Website, marketing materials, products and training.

Occasionally we take photos or videos of Anfrinit events, and may publish these on our Website or other promotional materials. Whenever we do this, we will let you know if advance of taking photographs or recording and provide you with the opportunity to opt-out.

Personal information we collect automatically

When you visit our Website, we may collect certain information automatically from your device. Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information.

We may also collect information about how your device has interacted with our Website, including the pages accessed and links clicked. Collecting this information enables us to better understand the visitors who come to our Website, where they come from, and what content on our Website is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Website to our visitors. Some of this information may be collected using cookies and similar tracking.

Personal information we obtain from other third parties

From time to time, we may receive personal information about you from other third party sources, but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us.

Who does Anfrinit share personal information with?

We may disclose your personal information to the following categories of recipients:

• Third party services providers and partners. We use third parties to provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Website), or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information. We use:

o ServerSpace, Microsoft and Amazon Web Services to store our data.

o DNA Digital, Shopify and Volusion to host, develop and maintain our Website

o Mailchimp, Group Metrics and Insights for email marketing and analytics

o PayPal and Access Dimensions for payment processing and accounting

o Google Analytics and Site Visability for website analytics

o CookieBot for our cookie consent and transparency tools

o Vimeo to host videos

o Amazon and CD Baby to sell audio files

• Competent law enforcement bodies, regulatory or government agencies, courts or other third parties. We only share your personal information with these parties where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person.

• Actual or potential buyers. In connection with any actual or proposed purchase, merger or acquisition of any part of our business we may share your personal information with the actual or potential buyer (and its agents and advisers) provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice.

• Other persons with your consent.

We also aggregate information about how individuals interact with Anfrinit and may provide these anonymous statistics to third parties.

Legal basis for processing personal information

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. The legal basis will typically be:

• where it is necessary to perform a contract with you, for example to provide you with the training courses you have purchased at the Anfrinit.

• where the processing is in our legitimate interests and not overridden by your rights, for example to respond to your queries, improve our courses and to undertake marketing activities.

• where we have a legal obligation, for example for accounting, tax or audit purposes.

• to protect your vital interests or those of another personal, for example in relation to unforeseen medical issues that may arise when you attend a course.

• where you have provided your consent for us to do so, for example where using your photograph or a video recording you appear in for promotional reasons.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details above.

How does Anfrinit keep my personal information secure?

We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. For example we follow industry best practice including using firewalls, encrypting data, implementing patches to our software and using monitoring tools and antivirus software by leading manufacturers.

International data transfers

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country.

Specifically, our Website servers are located in Spain, and our group companies and third party service providers and partners operate around the world. This means that when we collect your personal information we may process it in any of these countries.

However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice. These include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information when sending personal information outside of the EEA or UK unless the other country has been deemed to have adequate data protection laws by the appropriate authority.

Your data protection rights

You have the following data protection rights:

• The right to access, correct, update or request deletion of your personal information. Note that you can amend some of your personal information from your online account.

• The right to object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.

• The right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us.

• If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

• The right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Updates to this Privacy Notice

We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.

You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.