1. Data controller
Innovaforma Canarias, S.L., tax number B16462582, with its registered address at Calle Tomás Miller, 76, 6.º F, 35007 Las Palmas de Gran Canaria, Las Palmas, Spain, is the controller of the data used to handle your requests, your account and the commercial relationship. For privacy questions or to exercise your rights, write to info@edugenia.com.
The processing of your data is governed by the General Data Protection Regulation (GDPR), Spain’s Organic Law 3/2018 on the Protection of Personal Data and the Guarantee of Digital Rights, and any other data protection rules that apply.
If you access Edugenia through an academy or organisation, that organisation manages your access and permissions. When we process personal data on its behalf, we follow its instructions. Edugenia is the controller of the processing it carries out to manage your account, answer your queries and meet its own legal obligations.
2. What data we use and why
We process your identification and contact details, your link to an organisation and any personal data you include in your courses, files or messages to support. We also use technical information about access to and use of the platform, such as your IP address, your browser and activity logs.
This data comes from you, from the organisation that manages your access and from your use of the service.
When an academy uses courses connected to Edugenia, we process on its behalf the identifiers, names and roles of learners passed on by its learning platform, together with their access, progress and assessment results. We use this data to manage access to the course and to let the academy follow its learners’ progress.
We use this information to provide the service, manage your account and your content, answer your requests and keep the platform secure. What is stored in your browser is explained in the cookie policy.
The data we ask for as mandatory is needed to handle your request or provide the corresponding service. If you do not provide it, we will not be able to handle that request or provide that service.
Edugenia’s AI features are used to create and adapt teaching content. We never add your email address or your account profile details to AI generation requests.
When you use them, your instructions, texts and documents are processed by technology providers of AI to generate the results you ask for. If you include personal data in those materials, it will also form part of the content that is processed. Only provide the data needed for the feature you are using. Our approach to supporting teachers and reviewing content is set out in the AI use policy.
Neither Edugenia nor our AI providers use your data, documents, instructions or generated content to train or improve artificial intelligence models.
3. Purchases and invoicing
To manage payments and invoices, we send a specialised payment provider the identification and contact details of the user and of the academy, the purchase information and the language selected. We send this data before opening the provider’s payment page. Billing and payment method details are collected on that page.
To manage the credit balance and purchase history, Edugenia keeps the reference, amount and date of each purchase, as well as the credits acquired. These records are linked to the corresponding user and academy. Invoices are managed through the payment provider.
The processing needed to manage a purchase you make as part of the contract is based on its performance. The information required to meet tax and accounting obligations is processed on the basis of those legal obligations.
4. Legal basis
For the services you contract directly with Edugenia, we process the data needed to perform the contract. We also use the data needed to handle what you ask us to do before contracting. Compliance with legal obligations and our legitimate interest in protecting the platform against fraud and misuse are further bases for processing, depending on its purpose.
5. Retention and deletion of data
We keep personal data for as long as needed for the purposes described in this policy, with the periods and exceptions set out below.
When you delete your account, we erase the personal data that is no longer needed and delete or anonymise the data that identifies you in activity and change histories, support conversations and diagnostics. If there are pending queries, incidents or complaints, including those about purchases and credits, we keep only the data needed until they are resolved, without prejudice to the retention and blocking obligations set out in this section.
Records of purchases, payments and invoicing subject to tax and accounting obligations are kept after the account is closed. For accounting records and their supporting documents, the general period is six years from the last entry in the books, without prejudice to other applicable legal periods.
We also keep the data needed to deal with liabilities and claims for the applicable legal periods. Where the law requires it to be blocked, it will be withdrawn from ordinary use and consultation, kept only for the competent authorities to establish liabilities arising from its processing, and destroyed once the limitation periods end.
AI services may keep copies of the instructions, documents and results they process in order to prevent misuse and deal with security incidents. The maximum ordinary period for these copies is 60 days from receipt of the instructions and documents or from generation of the results. It may only be extended by a legal obligation or to deal with security incidents or possible misuse, limited to the data and time needed.
This period refers to the copies processed by the AI services. The courses, files and other data saved in Edugenia follow the retention criteria explained in this section. The commitment not to train models also applies while copies are kept by the AI services.
Deleting your account does not delete the academy. Its courses, files and change history may remain available to its members. When we process personal data in those materials on behalf of the academy, we follow its instructions and the applicable rules. If they contain your data, you can ask for it to be erased and we will work with the academy to deal with your request.
The procedure for closing an account is described in the terms of use.
6. Who we share your data with
To provide and maintain the service we rely on providers of cloud infrastructure and authentication, email, payments and invoicing, and artificial intelligence. Our information about service providers describes these categories, what they do and the data they process.
Where a legal obligation requires it, we will provide the necessary data to the competent body.
7. Your rights
You can access your data, correct it or ask for it to be erased. You can also ask for processing to be restricted, object to it and request portability in the cases provided for by the GDPR. To exercise these rights, write to info@edugenia.com. If processing is based on your consent, you can withdraw it at any time, without affecting earlier processing.
Your right of access includes asking for the identity of the recipients to whom your personal data has been or will be disclosed, on the terms provided for by the GDPR.
Requests to exercise your rights must be answered without undue delay and within one month of receipt at the latest. If the complexity or number of requests makes it necessary, we may extend that period by up to two further months, telling you why within the first month.
8. Security and updates
We apply security measures proportionate to the processing. Data from forms is not used to take decisions based solely on automated processing that produce legal or similarly significant effects.
We may update this policy to reflect changes in the services, in the providers involved in processing data or in the applicable rules. We will publish the updated version on this page with the date of its revision.
Changes will be subject to the information requirements and, where relevant, the consent requirements laid down in the applicable rules.
9. Questions and complaints
If you have questions about this policy or about how your data is processed, you can write to us at info@edugenia.com.
You can also lodge a complaint with the competent data protection authority, such as the Spanish Data Protection Agency (AEPD) in Spain.