1. WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL DATA? CONTACT DETAILS OF THE DATA PROTECTION OFFICER

Priscilla Medina Fernandez (BePM)

NIF B-87867297.

Address: Rue Muzy 16, Geneva, Switzerland

Contact email: info@bepm.academy

 

2. WHAT REQUIREMENTS MUST YOU MEET TO PROVIDE US WITH YOUR PERSONAL DATA?

2.1. Be 18 years of age or older, or have authorization from your parents or guardians. To provide us with your personal data, use the Website, and contract our Programs, you must be of legal age (18 years or older), have sufficient legal capacity, and/or, where applicable, have the prior and express authorization of your legal representatives (parents, both guardians if you have two, etc., as explained in the Terms and Conditions – https://bepm.academy/terminos-y-condiciones). Similarly, to contract our services on behalf of a legal entity, you must be of legal age (18 years or older), have full legal capacity to act, have sufficient capacity and standing to bind said legal entity, and be able to provide documentary proof thereof.

 

2.2. Providing accurate information. When you provide us with your information to use our services, you guarantee that the information provided is real, truthful, up-to-date, and belongs to you and not to third parties. Furthermore, you must notify us of any changes to the information provided, and you are responsible for the truthfulness and accuracy of the information supplied at all times.

 

Important: BePM reserves the right to verify your age and identifying information at any time, including requiring official documentation or an equivalent procedure. In the event of fraud detection, if it is confirmed or suspected that the User is a minor (under 18 years of age) or lacks authorization from both parents or guardians, etc., or has provided us with erroneous or false information, we reserve the right to temporarily deactivate and/or cancel your account. Furthermore, if you select a username or identifier similar to another for your account, BePM reserves the right to delete it, suggest an alternative, or reclaim it.

 

3. WHEN AND FOR WHAT PURPOSE CAN WE PROCESS OR COLLECT YOUR DATA?

 

1. When you browse or use our Website we may collect different data

 

When you access the Website, even if you haven’t registered, information is collected through BePM’s own cookies, which you accepted before starting to browse. These tools are small files that are downloaded and installed on your device and collect data about your use of the Website. Through these tools, we can collect the data described below.

 

A.1 What data can we process when you use the Website? While you use this Website, depending on the cookies you accept, we can process your IP (or Internet Protocol) address, we can know which city you connect from, your use of the Website (how often you connect, which features you use most, etc.).

 

A.2 For what purposes do we process the data we collect when you use the Website?

 

1. Conducting statistical analysis to improve the Website: All the information collected through the cookies you accept helps us analyze, maintain, and improve the Website to provide you with better service. This analysis allows us to detect website errors, identify areas for design improvement, and determine the need to add new features and services. For more information, please visit our Cookie Policy.

 

2. Prevention, detection, enforcement, and reporting of illegal activities or activities contrary to the Terms and Conditions or that endanger the security of information, the Website, or its Users. BePM may process data to monitor and prevent any form of abuse of our services, such as fraudulent activities, denial-of-service attacks, use of the Website for sending spam or unsolicited email, unauthorized access to User accounts, as well as any other practice that is contrary to the Terms and Conditions or endangers the security of information on the Website or of Users, or the integrity of the Website or the Programs themselves.

 

3. Including advertising on the Website, which may originate from social media: You may see advertising on the Website in the form of banner ads containing text, images, animations, and/or videos, integrated within the Website’s framework. These banner ads link to third-party websites or platforms for advertising and/or informational purposes and are in no way the responsibility of BePM, as these are environments external to BePM over which it has no control. In other words, if you click on one of these banners, you will leave the Website and enter a third-party website, so you cannot hold BePM liable for what happens there. The advertising that appears in these banners may be personalized for you if you have expressly accepted the installation of advertising cookies in your browser before you start browsing the Website, which allows us to show you ads related to your interests and recent searches. Similarly, we use third-party advertising services to advertise our Services on other websites.

 

4. In addition, using the social media tracking devices configured on the Website (see Cookie Policy), we can create an audience for matching purposes on the relevant social networks. The data sent is encrypted in our systems before being uploaded and shared with the social network (i.e., a hidden and anonymized version of the User’s data is sent) for subsequent use in displaying BePM advertising on your social networks. To learn more, visit: https://es-es.facebook.com/legal/terms/customaudience.

 

A.3 What gives us the right or legitimizes us to process your data?

 

Your explicit consent, which you give us when you access the Website and choose which cookies you want installed on your device, via the pop-up window that appears. However, you can withdraw your consent at any time by following the steps outlined in our Cookie Policy.

 

A.4 How long do we keep the data we collect while you use the Website?

 

The retention periods for information collected through cookies depend on the specific cookie (which may be first-party or third-party). All data retention periods are specified for each type of cookie in our Cookie Policy.

 

A.5 Does BePM share the data it collects during your use of the Website with third parties?

 

No. We do not share your data. However, as we use third-party cookies (cookies installed and managed by a third party) for some of the purposes in section A.2, third parties unrelated to BePM may access the information you provide when using the Website if you accept the installation of these cookies (you can find more information in the Cookie Policy).

 

1. We may also collect different data when you contact us through the channels indicated on the Website, through instant messaging systems (such as WhatsApp or Telegram) or by email

 

 

 

B.1 What data can we process when you contact us through these means?

 

Personally identifiable information that you provide to us through the means available to you on the Website or through instant messaging systems (such as, for example, WhatsApp or Telegram), which normally consists of your identifying data (name and, where applicable, surnames), your email address and/or telephone number (depending on the means used), as well as any other personal information that you voluntarily include in the communications that you send us.

 

Curriculum, academic and professional information. If you send us your curriculum vitae (CV), we may process information relating to your studies, training, academic experience and any other information you have chosen to include in it.

 

 

 

B.2 For what purposes do we process the data you send us through these means?

 

1. Responding to your requests. The main purpose of processing this data will be to respond to your requests, resolve your doubts and/or provide you with the information you request, as well as, where appropriate, follow up on them.

 

2. Advising you about our Programs and Activities: If available and if you request it, our customer service team can provide you with an advisory service. You can explain your interests, and we can recommend the Programs and activities that best suit your needs, based on the information you voluntarily provide. This service is available by appointment, so you will need to select a date and time (subject to availability) and provide your contact information (primarily your phone number, email address, or any other contact details you choose). The customer service department will then contact you on the scheduled date.

 

Important: Also, with prior notice and your express consent, your voice and statements may be recorded by our sales department for the purposes of analyzing your suitability as a candidate for our Programs (or lead) and accurately recording your statements or comments regarding the services we offer.

 

3. To include you in our selection processes. If you send us your resume to participate in a selection process, we will process your personal information for that purpose, and we will assess your profile and compare it with that of other candidates for possible employment.

 

4. Improve customer service. All information derived from questions, inquiries, and advice offered to interested parties, as well as how requests are resolved, allows us to understand how we provide our own customer service and identify areas for improvement. All collected information is anonymized after the retention period indicated in section B4, thus ceasing to be personal and therefore not attributable to the individuals concerned.

 

B.3 What gives us the right or legitimizes us to process this data that you provide to us through the Website, through instant messaging systems and through email?

 

Your express consent, which you give us when you voluntarily contact us through any of these means to either request information, send us other communications, or send us your resume in order to participate in our personnel selection processes.

 

Our legitimate interest. All the information you voluntarily provide to our customer service department helps us analyze how that department works and improve the quality of the service we provide you, which we do based on our legitimate business interest in providing increasingly better service to our Users.

 

B.4 How long do we keep the information you send us through the Website and instant messaging systems?

 

Your personally identifiable information, as well as your resume and professional details, which you provide to us through the Website or instant messaging systems, will be processed while your applications are being handled. Once this period has ended, BePM will retain the information in compliance with the law for a period of up to six years from our last communication.

 

1. We may also process your data to send you our newsletter or publications of interest to you, or if you wish to receive marketing communications.

 

C.1 What data can we process?

 

Normally, we will collect your email address or mobile phone number, which we will have because you have given it to us through the Website, or by other means of communication, whether or not you have contracted any of the Programs.

 

C.2 What are the purposes of processing your personal data?

 

Sending publications of interest and commercial communications: If you maintain a contractual relationship with us or have subscribed to receive commercial information, we may send you, through electronic means (email messages, SMS, WhatsApp or others), communications about products and services related to BePM.

 

 

 

C.3 What gives us the right or legitimizes us to process this data?

 

Your explicit consent. If you no longer wish to receive these types of communications, you can withdraw it at any time by following the instructions provided in the communication itself, or by writing to us at info@bepm.academy with a copy to info@bepm.academy, so that we can unsubscribe you from these communications.

 

C.4 How long do we keep the data you provide us for sending our newsletter or publications of interest to you, or commercial communications?

 

Until you decide to unsubscribe from our mailing list or inform us that you wish to stop receiving marketing communications. From then on, we will keep this data, under the conditions established by law, for a period of up to six years from the date of the last communication.

 

If you have provided us with this data for other purposes, we will continue to process it for those purposes unless you object, except when processing is necessary to perform a contract we have in force, for example. Once this contract has ended, BePM will retain your information under the conditions established by law for a period of up to six years from our last communication.

 

 

 

C.5 Does BePM share the data you give us to receive our newsletter/publications or commercial communications with third parties?

 

We may occasionally share your data with financial service providers. This sharing is for the purpose of offering you financing for our services through loan agreements with financial institutions, and may include the following purposes:

 

To respond to your information requests and contact you by phone and/or email. Legal basis: Your consent.

 

Proceed with your registration and manage your entry in our files/System/Platform. Legal basis: Consent given by the interested party.

 

Sending commercial communications regarding the services and promotions offered by these intermediary entities for contracting financial services. Legal basis: Consent given by the interested party and, where a contractual relationship exists, the exception in Article 21 of the Law on Information Society Services.

 

1. When you register on the Website as a Registered User and, subsequently, if you contract any of our educational services or Programs

 

 

 

D.1 What data can we process?

 

At the time of registration:

 

Identification and contact information. We collect the information you provide through the registration form on our website. Data fields that are mandatory will be marked with an asterisk [*].

 

Important. Registration via social media. If you choose to register or log in through a third-party social network, we will have access to some of the information included in your public social network profile, such as your name and other public profile information. If you do not want us to access this information, you should not register on the Website through a social network. In any case, we are not responsible for the processing of the information you provide to the social network because it is an environment external to the Website, and therefore you should consult and comply with its privacy policy regarding the processing of your personal data on the relevant social network.

 

 

 

During the subscription and/or use of the Services:

 

Browsing data referred to in Section A, depending on the cookies you have accepted.

 

Profile data: Apart from the data required to set up a registered User profile on the Website (whose boxes are marked with an asterisk [*]), you may provide, under your sole responsibility, additional information in your profile, such as a photo, a link to an external website, link(s) to your profile(s) on professional social networks, as well as any other information (including, but not limited to, personal address, identification numbers and/or professional background) that you communicate to BePM when you are using our Website or in the context of any application or social network used by BePM on its Website.

 

Information about your participation in the Program: information about tasks and activities completed; information about your interactions with other students, your progress and performance in the Program you are taking, processing and recording of grades, information about your performance level to provide to the company that contracts our services within your employee training plan, the number of hours you have spent on your training, analysis of your efficiency as a student, issuance of certificates, etc. Within the training activities we offer, there are channels for you to communicate with speakers or other students, through which you can publish content related to the training activity you have subscribed to, and BePM processes all this information through the Website. Image and Voice: Some training activities require interaction with other students or, where applicable, speakers via videoconference, and in these cases your image or your voice (or both) may be recorded as part of the training activity.

 

Information about transactions. If you have made any paid subscriptions or other transactions, we collect data about those purchases or transactions. This data may include payment information, the payment method used, billing details, shipping information, and contact information. For security reasons, we do not collect or store information about the cardholder, the debit/credit card number used, or other card-related data.

 

D.2 For what purposes do we process this data?

 

1. To register you as a User of our Website and provide you with our service(s). Based on the information you provide—which must be accurate—we will verify that you are of legal age (18 years or older). This information will allow us to identify you as a registered User of the Website and to maintain, fulfill, develop, monitor, and execute the services we offer you. Please note that if you register through a social network, we may have access to more information than you provide through the registration form.

 

2. Management of the student profile and their record in relation to the training activity and the Programs. The data included in your student profile will be visible to the rest of the students in the Program, on the Website, and information about your level of performance in the program will be accessible to the student (and, where applicable, available to the student’s employer who contracts the program as part of their employee training).

 

3. Management and organization of videoconferences and training activities that require interaction between students and speakers by electronic means, which may be recorded for later consultation, for educational or teaching purposes (which would imply the recording of your image or your voice or both).

 

4. Management and organization of your access to and use of our digital platform, where all the necessary materials for carrying out the Programs are provided.

 

5. Management and monitoring of your progress as a student: attendance at activities organized in relation to the Program or with training activities derived from it, processing and registration of grades, information on your level of performance to the company that contracts our services for you because you are its employee, hours you have spent in your training, analysis of your efficiency as a student, issuance of certificates, etc.

 

6. Invitation to events and other activities related to the Program and to networking actions or meetings of the professional sector to which the Program refers.

 

7. In general, compliance with our obligations according to the Terms and Conditions and the specific conditions of each Program, as well as resolving incidents or problems that may arise during your relationship with us.

 

8. To manage and provide our services on a regular basis and to be available to you so that you can maintain smooth communication with us. As part of the regular management of our services, it is necessary to process your identification and contact information, and, if you contract any paid service that is controlled by us and not by a service provider, information related to your chosen card/account/payment method, which we request to manage your account and any purchases you may make. This information will also be used to send you administrative communications, updates, changes to our Terms and Conditions or this Privacy Policy, security alerts, and to respond to any requests or inquiries you send us.

 

9. Prevention, detection, enforcement, and reporting of illegal activities or activities contrary to the Terms and Conditions of the service or that endanger the security of information on the Website, the App, or other Users. BePM may, at its discretion, process data to monitor and prevent any form of abuse of our services, such as fraudulent activities, denial-of-service attacks, spamming from the Website, unauthorized access to registered User accounts, as well as any other practice that is contrary to the Terms and Conditions or the specific terms of each program or that endangers information security or the integrity of the Website itself.

 

10. Requesting your participation in surveys and/or events or other activities exclusive to BePM Community members. We may invite you to take a survey through our own or third-party channels to evaluate our Services, as well as invite you to events or other activities we organize for students in the Programs. If you register for any of these activities through the corresponding form, we will collect and store the data you provide to manage and organize them. When we use a third-party platform to administer a survey or activity, that third party’s privacy policy will apply.

 

 

 

D.3 What gives us the right or legitimizes us to process this data?

 

Your express consent, which you give us when you voluntarily register as a Registered User by filling in the mandatory fields of the registration form, marked with an asterisk [*], or when you voluntarily provide us with your data to access activities, conduct surveys, attend networking events, etc.

 

The execution of the contract you sign with us when you subscribe to one of our Programs. The processing of your personal data, in general, is necessary to execute the contractual relationship that is generated when you subscribe to one of our Programs.

 

Our legitimate interest. All the information you voluntarily provide to us during registration and subsequently as a registered User of the Website helps us analyze the quality of our services, our Programs, and the attention we give you, which we do based on our legitimate business interest in providing you with increasingly better service.

 

D.4 How long do we keep the data you provide us in the registration form as a registered user and subsequently?

 

The information you provide to register as a User will be kept on our systems until you decide to unsubscribe. This is because we want the Website to be available to you whenever you choose, and therefore we will delete your account when you decide to do so (unless you breach the Terms and Conditions or any other violation described therein).

 

The information you provide to us to enroll in a Program will be kept for the duration of our contractual relationship (course duration and while you have access to the study platform).

 

The information you provide to us so that we can include you in any activity organized by us or by a third party, or to attend any networking event, will be kept for the time necessary for you to receive the specific service.

 

Once you decide to unsubscribe as a registered User on the Website, after the contractual relationship with BePM has ended or the purpose for which you gave us the data has been fulfilled, we will keep your information as established by current legislation, for a period that can be up to six years from the last communication we exchanged.

 

D.5 Does BePM share with third parties the data you give us in the registration form or, subsequently, when you subscribe to one of our Programs or sign up for activities related to them?

 

In addition to the transfers indicated in general terms in point 4, “Who do we share your personal information with?”, we may share some basic identifying data with students enrolled in the courses you have registered for informational purposes and to facilitate the smooth running of joint activities. In this regard, if you post a comment, question, or doubt using the platform’s features, your user information (including your name) may be publicly visible to other users.

 

Finally, and only if you are enrolled in one of our programs funded by a company that has contracted our services, we may share your identifying information, grades, and progress in the program with that company (including aspects such as the number of hours you have dedicated to your training, an analysis of your efficiency as a student, whether or not you have been awarded a certificate, your grades, your level of participation in the program, etc.). By accepting this privacy policy, you expressly consent to us sharing this data, which we also make available to your company because it has a legitimate interest in knowing it, since your company is the one paying for the program and ensuring that you receive increasingly comprehensive and specific training.

 

1. When you post comments on our blog

 

 

 

E.1 What data can we process?

 

Basic identification and contact information, as indicated on the corresponding form. You can select an alias or pseudonym if you do not wish to publish your name.

 

E.2 For what purposes do we process this data?

 

Posting comments on the blog. You can use the form provided to post a comment with your opinion on the topics covered in the blog. Providing your email address is required for security and fraud prevention purposes.

 

Please note that when you post a comment, it will be visible to all Users who visit the Website, and you are solely responsible for the content you post.

 

Please note that posting obscene, offensive, vulgar, or otherwise objectionable content, or content that incites criminal, denigrating, defamatory, slanderous, violent, or otherwise unlawful acts, or that violates generally accepted morals, good customs, or public order, and/or content that contravenes our Terms and Conditions, is prohibited. BePM reserves the right to remove comments that violate these rules and to take any other measures it deems appropriate.

 

E.3 What gives us the right or legitimizes us to process this data?

 

Your explicit consent, which you give us by providing your data through the corresponding form and freely and voluntarily publishing your comments on the blog. Posting comments is entirely voluntary, so by including them on the blog you give us your explicit consent for their publication and processing.

 

Our legitimate interest. All the information you voluntarily provide to us for publication on the blog helps us to maintain, manage, and analyze its quality, as well as the attention we give you, and to prevent and take action against possible illegal activities, which we do based on our legitimate business interest in providing a good service.

 

 

 

E.4 How long do we keep the information you give us for the blog?

 

Your information will be kept for as long as the post remains published on the blog (for as long as it is relevant to the public) or until you request its removal or the deletion of your data. After that, we will retain your information in accordance with applicable law, for a period of up to six years from our last communication.

 

1. BePM’s presence on social media

 

BePM has a profile on the main social networks, such as Facebook, Twitter, Instagram, LinkedIn or YouTube.

 

When you become a follower of one of our pages on social media, the processing of your data will be governed by the terms of use, privacy policies, and access regulations of the corresponding social network, which you will have to accept beforehand. These terms of use and privacy policies are external to BePM and beyond our control; therefore, we are not responsible for the processing of your data that may occur in those environments.

 

BePM, in this sense, as a user of the aforementioned social networks, submits to their rules for processing data of other users (in this case, you), for the purposes of properly managing its presence on the social network, and we may inform you of activities, products or services, as well as contact you for any other purpose that the regulations of said social networks, which you should have previously appreciated, allow.

 

By expressing your interest in our services, BePM may consult your professional profile on professional social networks, as well as in official bulletins and journals, press reports, electronic communications service directories, professional association membership records, and other databases whose consultation is not prohibited by a restrictive regulation. This processing of personal data is based on BePM’s legitimate interest and will be limited to the information strictly necessary for your professional contact.

 

Please note that we have no influence over the information that the social network collects or how it processes it, so we recommend that you stay informed about the purpose and scope of the information collection carried out through these social networks.

 

4. TO WHOM COULD WE GIVE YOUR PERSONAL INFORMATION?

 

1. Public bodies, judges and courts and, in general, the Administration and competent authorities, when BePM has a legal obligation to provide them.

 

2. To the Tax Authorities, for the fulfillment of tax obligations, as well as to financial entities for the management of collections and payments.

 

3. To companies that could collaborate with BePM in detecting fraud in the use of the Website and the content and services offered on it.

 

 

 

5. WHAT ARE YOUR DATA PROTECTION RIGHTS? HOW CAN YOU EXERCISE THEM?

 

1. Right of access. By exercising this right you can find out the information regarding the processing we carry out on your personal data.

 

2. Right of rectification. You can correct or modify your data if it is inaccurate or incomplete to ensure that the information we have about you is correct.

 

3. Right to erasure (or right to be forgotten). You may request the erasure of your personal data when any of the stipulated grounds apply. For example, unlawful processing of data, or when the purpose for which the data was collected or processed no longer exists. However, there are a number of exceptions in which this right does not apply. For example, when the right to freedom of expression and information must prevail.

 

4. Right to object. Through this right you can object to the processing of your personal data: (i) when, for reasons related to your personal situation, the processing of your data must cease unless a legitimate interest is demonstrated, or it is necessary for the exercise or defense of claims, or (ii) when the processing is for direct marketing purposes.

 

5. Right to restriction of processing. You may request that we restrict the processing of your data when we process it (i) when the accuracy of the data is contested, while we verify such contestation; (ii) when the processing is unlawful, but you oppose the erasure of your data and request the restriction of processing instead; (iii) when you need them for the establishment, exercise, or defense of legal claims; or (iv) when you have objected to the processing of your data for the performance of a task carried out in the public interest or for the purposes of our legitimate interests, which must be verified. In these cases, we will only retain them for the establishment, exercise, or defense of legal claims.

 

6. Right to data portability. You may request the portability of your data in electronic format, as well as the possibility of transmitting it to another entity.

 

7. Right to lodge a complaint with the Supervisory Authority. Remember that you can lodge a complaint with the Supervisory Authority at any time; in the case of Spain, the Spanish Data Protection Agency (www.agpd.es).

 

You can exercise the rights guaranteed to you by data protection regulations in relation to the processing of your personal data by contacting our Data Protection Officer by writing to info@bepm.academy, copying info@bepm.academy.

 

We will resolve any request to exercise your rights as soon as possible and, in any case, within the legally established timeframes. In some cases, we may need to request a copy of your identity document or other identification.

 

 

 

6. CLOSURE OF YOUR ACCOUNT AND WITHDRAWAL FROM THE CONTRACTUAL RELATIONSHIP YOU HAVE ESTABLISHED WITH US FOR ANY EDUCATIONAL SERVICE OR PROGRAM

 

To cancel your registered User account or to withdraw from the contracted Programs you must follow the procedure indicated in our Terms and Conditions, in addition to what may be provided in the particular conditions of each specific Program.

 

Important: If you withdraw and/or request cancellation (closure of your account) by sending an email to info@bepm.academy, you will lose the right to use any benefits or services that you may have active on the date of cancellation and/or have contracted previously.

 

In the above cases, we will keep your data blocked, under the conditions established by law, for a period that may be up to six years from the date of our last communication.

 

This Privacy Policy was modified on October 31, 2023.

 

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