policy

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1. Who is responsible for processing your data?

Data Controller:

Sofbrain S.L. (Hereinafter, the Company)

Address: Paseo de la Castellana, No. 40, 8th Floor, Door A, 28046 Madrid

Email: dpd@sofbrain.com

Telephone Contact: +34697686568


You can contact our Data Protection Officer at the above address or via email at dpd@sofbrain.com.

2. Applicable Legislation

This privacy policy has been prepared in accordance with current regulations on the protection of personal data, and in particular with:

  • Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR).
  • Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD).

3. For what purpose do we process your personal data?

Your personal data is processed for the following purposes:

  1. Managing requests through the website (contact forms, registrations, subscriptions, etc.).
  2. Providing training services through our e-learning platform (Moodle), including:
    • User registration.
    • Access to content.
    • Progress evaluation.
    • Interaction with tutors.
  3. Recording of virtual sessions conducted using the BigBlueButton tool, for educational, review, and quality control purposes.
  4. Recording of voice calls between students and tutors, for formative monitoring and service improvement.
  5. Storage of WhatsApp messages between students and tutors made with different tools, for formative monitoring and service improvement.
  6. Sharing of information between the companies that make up the Doce Blar Group for internal administrative purposes, coordinated service management, and student support.

4. What is the legal basis for processing your data?

The legal bases that justify the processing are:

  • Performance of a contract: provision of training services in accordance with the relationship between the user and the companies of the Doce Blar Group.
  • Consent of the data subject for certain actions, such as offers of training courses.
  • Consent of the data subject for the recording of virtual sessions and follow-up calls when required.
  • Legitimate interest of the data controller: in improving the service, traceability of care, and internal coordination between companies within the group.
  • Compliance with legal obligations, especially in educational, tax, or data protection matters.

5. Who will your data be shared with?

Your data may be shared with:

  • The entities of the Doce Blar Group, when necessary for the coordination of services.
  • Service providers acting as data processors: technology companies that provide support for Moodle, BigBlueButton, calling tools, hosting, secure storage, etc.
  • Where applicable, competent authorities, as required by law.
    No international data transfers are foreseen, unless a provider is located outside the European Economic Area, in which case appropriate safeguards will be adopted in accordance with the GDPR.

6. How long do we keep your data?

Data will be kept for:

  • The time necessary to fulfill the purpose for which it was collected.
  • For the duration of the contractual or training relationship.
  • Regarding recordings:
    • Virtual sessions: during the course period and for the access authorized by users.
    • Recorded calls: for the time strictly necessary for training follow-up, unless there is a request for deletion.
    • Stored WhatsApp messages: for the time strictly necessary for training follow-up, unless there is a request for deletion.


Subsequently, they will be kept blocked for the applicable legal periods to address potential liabilities.

7. What are your rights?

You have the right to:

  • Access your personal data.
  • Request the rectification of inaccurate data.
  • Request the erasure of your data when it is no longer necessary.
  • Object to the processing of your data or request its restriction.
  • Request the portability of your data, when the basis is contractual or based on consent.

You can exercise these rights by sending a request to dpd@indiplu.com Attach a copy of your identity document to verify your identity. If you believe your rights have not been respected, you can file a complaint with the Spanish Data Protection Agency (AEPD): www.aepd.es

8. How do we protect your data?

The Doce Blar Group has adopted appropriate technical and organizational measures to guarantee the confidentiality, integrity, and availability of data, including:

  • Encryption of communications.
  • Access control to the platform.
  • Access logging and traceability.
  • Privacy policies and training for internal staff.

9. Additional Information

This policy may be updated to reflect legal or technical changes. The updated version will always be available on our website and platform.

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