Privacy Policy

1. Who is the Controller of your data?

POLARIS MINOR, S.L.U. (hereinafter, “POLARIS MINOR”), with Tax Identification Number B-65923690, will be the controller of the personal data that you provide us by completing any of our forms in paper or electronic format, as well as those obtained as a result of the formalisation of enrolment in any of our courses and the relationship arising from said enrolment. This company is located at Avda. Diagonal 662-664, 08034 Barcelona, and can be contacted via the e-mail address info@iberonex.com.

You may contact our Data Protection Officer by writing to dpo@planeta.es or to Grupo Planeta, Attn.: Data Protection Officer, Avda. Diagonal 662-664, 08034 Barcelona.

2. What sources does your data come from?

The enrolment of a student in a Programme.
Contact requests, including requests for information on Programmes and services provided.
The creation of a Business Profile.
Through the various forms available on the websites.
Your subscription to the newsletter.
The communication of information provided by telephone, post, email or via one of our paper forms;
During forums, master classes, trade fairs, through computerised or paper forms filled in by a potential customer or a student.
The performance of our relationship with you.
Those provided by the companies in which you can do curricular or extracurricular internships.
In the event that the company you work for is the company that has contracted the Programme in which you are enrolled, that company may have provided us with certain personal data relating to you, such as contact and identification details.
If you are a minor, your father, mother or legal guardian may have provided us with certain personal data relating to you, such as identification or contact details.
With regard to obtaining scholarships, grants or funding and in relation to the legal guardian and/or parents, it is possible that the student has provided us with certain personal data, for the purpose of assessing the allocation of such scholarships, grants or funding. The categories of such data are: contact data, identification data and financial data.
Use of our website.

POLARIS MINOR may collect your Data directly or indirectly, through other Grupo Planeta entities.

Your communication of the data marked with an asterisk in the enrolment form is necessary for the contracting of educational services and compliance with legal obligations. Consequently, if you do not provide this information, you will not be able to enrol in the Programme you have selected and, therefore, you will not be able to access our educational services.

3. What categories of personal data do we process?

Identity data: surnames, first names, nationality, telephone number, email address, postal address, date of birth, country of residence, identity document, visa application if applicable;
Professional data: level of education and initial field of training, diplomas obtained, professional experience and addresses of the different employers where this professional experience was acquired, data concerning your skills and interests;
Financial data, including bank details, relating to the payment of tuition fees and scholarship applications, or funding arrangements for continuing education;
Data relating to comments/questions collected during the pre-contractual or contractual relationship;
Connection data: IP address, technical and location information generated in connection with the use of our websites and applications;
Cookies: for more information, please see our Cookie Policy.

3.1. Special categories of personal data

Special categories of personal data (hereinafter, “sensitive data”) are personal data which may reveal racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, genetic data, biometric data intended to uniquely identify a natural person, data concerning health or data concerning the sex life or sexual orientation of a natural person.

POLARIS MINOR will only process sensitive data in accordance with data protection law and if it has a valid legal basis to do so and in very limited circumstances, for example, to identify particular needs to adapt the learning environment to those needs.

4. For what purpose do we process your personal data? What gives us the right to process it and how long will we store your data?

POLARIS MINOR, S.L.U may process your personal data for the following purposes:

Treatment	Purpose	Legitimization Basis	Retention Period
Information Request	Manage your request for information about the selected training program.	Consent	Your data will be deleted once the information is provided and/or after two calls.
Information Request	Create a profile based on the information provided both during registration and while browsing the website to tailor advertising and improve the quality of the enrollment management process.	Legitimate Interest For more information on legitimate interest, please refer to the corresponding section of this privacy policy.	Your data will be deleted once the information is provided and/or after two calls.
Enrollment and Completion of the Program	– Manage the enrollment and enable you to complete the Program. – Provide access to the Virtual Campus, as well as materials, databases, and other training resources available to students. – Send you relevant information, notifications, and communications for the development of the Program. – Conduct continuous evaluation of the knowledge you acquire in relation to the Program. – Facilitate, if applicable, your participation in the internship program linked to the training activity in question, as well as evaluate the aforementioned program. – Manage, if applicable, the delivery of the certificate of completion or final degree corresponding to the training activity in which you have enrolled.	Contractual Relationship	We will process your data until the end of the contractual relationship.
Enrollment and Completion of the Program	– Send you, by any means, commercial communications about the rest of our courses that are similar to the one you have contracted.	Exception of Article 21 of the Law on Information Society Services and Electronic Commerce.	We will process your data until you object to the processing.
Recording of Asynchronous Classes	To the extent that the classes taught online as part of the Program in which you are enrolled may be recorded for the purpose of being viewed later, we may process your image or voice if you participate and/or intervene in any of these classes.	Legitimate Interest For more information on legitimate interest, please refer to the corresponding section of this privacy policy.	We will process your data until the end of the contractual relationship.
Online Knowledge Evaluation	In cases where the evaluation of your knowledge requires an anti-fraud accreditation system, these systems will be used solely and exclusively for this control function and never for any other purpose. Depending on the Program in which you enroll, these anti-fraud accreditation systems may consist of one or more of the following: front camera with or without facial recognition (biometric accreditation), screen activity monitoring, and environment verification using a second camera.	Contractual Relationship and Legitimate Interest in the Prevention of Academic Fraud. For more information on legitimate interest, please refer to the corresponding section of this privacy policy.	We will process your data until the evaluation records of each test are final.
Request for Scholarships, Aid, or Financing	If you request a scholarship, aid, or financing to cover the payment of the Program in which you enroll, we will process your personal data to manage your request and the corresponding scholarship, aid, or financing.	Contractual Relationship	We will process your data until the end of the contractual relationship.
Alumni Club	For the Alumni Club, we will process your personal data to manage your registration and subsequent participation in it, in accordance with the corresponding participation conditions. Within the framework of this club, we may send you information about the activities and benefits that you can enjoy as a member, as well as information related to the educational sector.	Contractual Relationship	We will process your data as long as you maintain the status of a member of the aforementioned club.
Events	Process your personal data, including your image and voice, which may be captured as a result of your participation in a specific event.	Consent	Until you revoke that consent or exercise your rights of deletion and opposition to the processing of your data.
Commercial Surveys	Send and manage your participation in commercial surveys to learn about your opinion and training preferences and, based on them, recommend that you take another of our training programs and/or those of other training centers unrelated to us.	Consent	Until you revoke that consent or exercise your rights of deletion and opposition to the processing of your data.
Quality or Satisfaction Surveys	In attention to our legitimate interest in knowing the satisfaction of our customers or users regarding our products and/or services and the attention provided in relation to our teaching services, we may process your personal data to conduct or send you satisfaction or quality surveys. This also benefits you as it allows us to know your opinion and evaluate the quality of our products, services, and/or attention provided, identify areas for improvement, strengths, and understand the needs and expectations of our customers.	Legitimate Interest For more information on legitimate interest, please refer to the corresponding section of this privacy policy.	We will process your data for the time necessary to conduct the quality or satisfaction survey or until you object to the processing or we anonymize your data.
Draws and Contests	If you participate in a draw or contest organized by POLARIS MINOR, your data will be processed to manage your participation and, if you are a winner, to deliver the prize and, if applicable, manage the publication of your identifying data through various media such as the POLARIS MINOR, S.L.U. website. In each draw or contest you participate in, the legal bases will be available where we will provide you with more detailed information about the processing of your data.	Contractual relationship arising from the execution of the legal bases of the draw or contest.	We will keep your data until the end of the draw, once the corresponding prize has been delivered, as well as, subsequently, the time during which any type of liability may arise.
Sending Commercial Communications, Own and Third-Party	If you provide us with your consent, we may send you personalized commercial communications about our products and/or services, or those of third-party collaborating companies, which may include the following sectors: publishing, training, culture, leisure, collecting, textiles, private insurance, consumer goods, jewelry, telecommunications, banking and financial sector, travel, technology, and legal activities. There are certain social networks, applications, or third-party websites that allow the sending of commercial communications or advertising impacts to specific or determined users. With this information, the social network or application verifies if the user has an account on its platform, allowing POLARIS MINOR, S.L.U. to carry out what is known as “Custom audience or personalized audience” with those users who have accepted the receipt of commercial communications in accordance with what is indicated above in this policy, and who in turn have an account on said social network or application, thus being able to show you advertising directly on them. This type of activity can be carried out in different media, highlighting social networks such as Facebook (Custom audience), Twitter (Tailored audiences), or Google (Customer Match).	Consent	We will process your data until you unsubscribe or revoke your consent.
Communication to Grupo Planeta Companies for Sending Commercial Communications	Additionally, you may provide us with your consent through the enabled checkbox for us to communicate your personal data to Grupo Planeta companies so that they can send you personalized commercial communications about their own products and/or services. The sectors of Grupo Planeta companies are the following: publishing, training, culture, leisure, collecting, textiles, private insurance, consumer goods, jewelry, telecommunications, banking and financial sector, travel, technology, and legal activities.	Consent	We will process your data until you unsubscribe or revoke your consent.
Contact	We may process your data if you contact us through the different established channels for managing doubts, queries, and/or complaints.	Consent
Fraud Prevention and Management	When making the payment, we may process your data to conduct a check on possible fraudulent operations, which may involve communicating data to expert providers in fraud prevention and management, in accordance with what is indicated in the section “To which recipients will your data be communicated?”. This processing will be carried out based on legitimate interest. The interest of POLARIS MINOR is to be able to manage and control any potentially fraudulent operation. The benefit this generates for POLARIS MINOR is to control financial losses and increase the trust that customers place in us and the reputational value of the company, which in turn benefits you by providing greater transparency and trust in POLARIS MINOR, preventing, as far as possible, fraudulent operations in which you may participate and improving your experience as a customer. For more information on legitimate interest, please refer to the section “Do we carry out processing based on legitimate interest?” of this privacy policy.	Legitimate Interest For more information on legitimate interest, please refer to the corresponding section of this privacy policy.	Your data will be processed as long as necessary to prevent and manage possible fraudulent operations, or until you object to the processing.
Cookies	We may obtain information about you through cookies. This information will be used to improve the functioning and performance of the website, analyze traffic, website usage, evaluate navigation, understand and determine areas of greatest interest, and manage the advertising spaces on our website and the advertising to be displayed on other websites, based on aspects that we consider may be of interest to you. For more information on cookies, consult the Cookie Policy.	Consent (except for strictly necessary Cookies)	They may last up to 2 years (in any case, review the information provided in our Cookie Manager).
Advertising on Social Networks or Third-Party Services	There are certain social networks, applications, or third-party websites that allow the sending of commercial communications or advertising impacts to specific or determined users. This type of activity can be carried out in different media, highlighting social networks such as Facebook (Custom audience), Twitter (Tailored audiences), or Google (Customer Match). These social networks or applications allow sharing user data to find or identify what is known as “similar audiences,” i.e., users who have a profile similar to yours on said social network or application but are not users of POLARIS MINOR, S.L.U. This type of activity is usually carried out especially through social networks such as Facebook (Lookalike audience), Twitter (Tailored audiences), or Google (Similar Audiences). In this case, as it does not directly impact users with advertising, the basic data of all users are used, even those who have not accepted the receipt of commercial communications. Regarding the data provided to these third parties, we consider it relevant for our users to know that only your email or phone number will be communicated, which will be communicated in an encrypted manner, guaranteeing the confidentiality and security of your data. The entire process is secured through the tool provided by the platform itself, which will allow it to identify you in its database. Remember that if you do not wish to receive advertising through the third-party social network or platform, you must restrict it through your user profile, all according to the privacy policies of each of the platforms. These social networks and/or applications will only provide us with your data in an anonymized and statistical manner, without us being able to re-identify you or know other new interests, unless you interact with us through one of our advertisements on the social network and/or application. We also inform you that we carry out the processing based on legitimate interest. The interest of POLARIS MINOR, S.L.U. is to target advertising messages based on user segments that may be interested in our products and services. The benefit this generates for POLARIS MINOR, S.L.U. is the savings in advertising costs. The benefit for users is that they do not receive indiscriminate advertising about products and services that are not of interest to them. For more information on legitimate interest, please refer to the corresponding section of this privacy policy.	For more information on legitimate interest, please refer to the corresponding section of this privacy policy.	The data will be processed as long as you have accepted commercial communications or until you object to the processing.
Video Surveillance	Video surveillance to ensure the safety of users and premises. Personal data processing activities whose main purpose is the capture and/or processing of images for surveillance purposes.	Legitimate Interest For more information on legitimate interest, please refer to the corresponding section of this privacy policy.	1 month

5. Processing based on compliance with legal obligations

In addition to the processing specified in the table above, POLARIS MINOR, S.L.U. will need to process the user’s personal data in order to comply with the different legal obligations of an accounting, legal, fiscal and administrative nature that may be required of it at any given time. We refer, principally and among others, to those provided for in the following rules:

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 and repealing Directive 95/46/EC (“GDPR”).
Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights, which obliges POLARIS MINOR, S.L.U., as the entity legally responsible for the processing of your personal data to attend to requests, exercises of rights and claims that are submitted in matters of data protection.
If we are requested to do so by any Court or Tribunal, the State Security Forces or any other competent Public Authority or Administration, we may also have to provide it with your personal data, as we are legally obliged to do so.
Royal Legislative Decree 1/2007, of 16 November, approving the revised text of the General Law for the Defence of Consumers and Users and other complementary laws, to deal with requests, exercise of rights and claims presented by you when you are a consumer.

These obligations of a legal nature will be fulfilled by POLARIS MINOR, S.L.U. during the periods imposed on us in each case by the legislation in force.

6. To which recipients will your data be disclosed?

Your personal data may be disclosed to:

The companies in which, if applicable, the corresponding curricular internships will be carried out, with this disclosure being necessary in order to be able to carry out the said internships.
To the educational centres outside the centre itself to which it is necessary to transfer your record as a consequence of you choosing to do part of the Programme there, participating in an international training programme, or when you decide to do any other training programme there and request the aforementioned record transfer.
To the bodies or entities that manage the scholarships, grants or funding that, if applicable, may be requested to pay for the Programme in which you are enrolled, with this notification being necessary in order to manage and process the scholarship, grant or funding requested.
To the Department of Education and relevant authorities when we are legally obliged to do so.
To third parties if you have given your consent.
If you are a minor, or if you are of legal age on the basis of your consent, your academic record may be disclosed to your guardians and/or parents.

In the event that you give us your consent, your personal data and, as the case may be, your commercial profile will be disclosed to other Grupo Planeta companies for the purposes indicated in the section “For what purpose do we process your personal data?” of this privacy policy. You can consult the list of Grupo Planeta companies at the following link www.planeta.es. These companies operate in the publishing, education, culture, leisure, collecting, textile, private insurance, consumer goods and jewellery sectors.

We also inform you that, in the event of a legal obligation that requires us to do so, your data will be transferred to the administrations, authorities, public bodies or courts and tribunals indicated by the corresponding legislation.

We also inform you that POLARIS MINOR, S.L.U. contracts various services from third-party providers, who may have access to your personal data for the provision of such services in which case such providers will always process the data on our behalf, under a processor agreement, and never for their own interests. Specifically, POLARIS MINOR, S.L.U. may contract the provision of services by third-party suppliers that carry out their activity, by way of example, in the following sectors: logistics services, legal consultancy, supplier approval, multidisciplinary professional services companies, maintenance-related companies, technology service providers, IT service providers, instant messaging service providers, infrastructure management and maintenance companies.

7. Do we carry out international data transfers?

In the event that you choose to do part of the Programme in an educational centre located outside the European Economic Area or participate in an international educational programme, your data will be transferred internationally. In such cases, POLARIS MINOR shall adopt appropriate safeguards for the regularisation of such international transfers.

In addition, as noted in the previous point, POLARIS MINOR contracts various services from third-party providers, some of which are located outside the European Union or the European Economic Area. Accordingly, POLARIS MINOR has signed the corresponding standard contractual clauses approved by the European Commission with these providers, along with any additional safeguards required in each case.

8. Do we carry out processing based on legitimate interest?

As indicated in this Privacy Policy, some processing may be based on legitimate interest. In order to assess the legitimate interest, a weighting has been carried out in which we have analysed our own benefits as data controller, as well as the benefits of third parties, and in which we conclude that our legitimate interest in the processing prevails over the interests, rights and freedoms of users and/or third parties.

You may at any time request further information about the weighting of legitimate interest by contacting our Data Protection Officer.

We would also like to take this opportunity to remind you that you have the right to object to processing on the grounds of legitimate interest.

9. How long will we store your data?

All data provided will be processed for the period of time set out in section four of this Privacy Policy (“For what purposes do we process your personal data? What gives us the right to process it and how long will we store your data?). However, once the aforementioned time periods have expired, the data will be kept blocked, thus preventing their processing. The exception will be the availability of the data to judges and courts, the Public Prosecutor’s Office or the competent Public Administrations, for the claim of possible liabilities derived from the processing and only for the corresponding statute of limitations period. Once the aforementioned period of time has elapsed, the data will be deleted.

Without prejudice to these time periods, where possible, your data may be kept in an anonymised form for statistical or market research purposes.

10. What security measures do we apply to protect your data?

We take the necessary measures to ensure that your personal data collected through the website is not lost, consulted, modified or disclosed by unauthorised third parties.

To this end, we have put in place technical measures (such as firewalls) to protect your data against unlawful or accidental destruction, alteration or loss, misuse and unauthorised access, alteration or disclosure.

In addition, organisational measures (such as data access authorisation management systems, etc.) help to preserve the confidentiality of your data. For example, access to your personal data is strictly limited to the expressly authorised personnel of POLARIS MINOR, S.L.U. and to our partners and subcontractors, who act according to our instructions and in accordance with our contractual provisions and applicable legislation.

11. What are the rights granted by the regulations in force?

Any person has the right to obtain confirmation as to whether or not POLARIS MINOR, S.L.U. is processing personal data concerning them.

Furthermore, data subjects have the right to access their personal data, as well as the right to request the rectification of inaccurate data or, where appropriate, to request their erasure when, among other reasons, the data are no longer necessary for the purposes for which they were collected.

Under certain circumstances, data subjects may request the restriction of the processing of their data, in which case we will only store such data for the exercise or defence of legal claims.

At any time, the persons concerned have the right to withdraw any consent they may have given us. This will not prejudice the contractual relationship with POLARIS MINOR, S.L.U. or the legality of what we have carried out up to that moment: that is to say, the withdrawal of their consent does not have retroactive effects, but only applies from that moment onwards.

In certain circumstances, on grounds relating to their particular situation, data subjects may object to the processing of their data. POLARIS MINOR, S.L.U. will cease to process the data, except on compelling legitimate grounds for the exercise or defence of legal claims.

Data subjects shall also have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and to transmit those data to another controller.

In the event that we carry out an automated process, you have the right to challenge the decision that has been taken, to request the personal intervention of one of our analysts and to express your point of view, so that your request is re-evaluated. You may do so by sending an e-mail to rgpd@iberonex.com.

You may revoke your consent, where applicable, as well as exercise your rights of access, rectification, erasure and portability of your data, of limitation and objection to its processing before POLARIS MINOR, S.L.U. by letter addressed to Apartado de Correos 221 de Barcelona or by sending an e-mail to rgpd@iberonex.com.

You may also lodge a complaint with the Spanish Data Protection Agency whenever you consider it appropriate, especially if you believe that we have not properly addressed the exercise of your rights.

12. Changes to the Privacy Policy

This policy was last updated on 20/01/2025.

POLARIS MINOR, S.L.U. recommends that you review this document whenever you access the website so that you are properly informed about the processing of your personal data and aware of any changes that may occur.