Privacy Policy

Introduction

Harbour.Space ensures that online visitors can be confident their information is processed according to applicable privacy legislation. The policy describes how Harbour.Space handles and protects personal data as a data controller, and outlines your rights regarding this information.

The organization is committed to respecting privacy and protecting personal data — any information identifying an individual, such as name, address, pictures, or IP address collected through digital channels.

Personal Data Processing

1. Application to Programs or Courses

Type of processing

• Identification
• Correspondence regarding application procedure
• Program entry requirement control
• Internal record keeping and audits

Categories of personal data

• Name
• Surname
• Photo
• Date of birth
• Gender
• Place of birth
• Address
• E-mail
• Phone number
• Skype
• CV
• Diploma/Transcripts
• English proficiency test
• Recommendation letters
• Visa requirements (including copy of passport)
• Available information from social media and other online sources

Legal ground: Performance of the agreement to examine applications. Data collection is required to fulfill rights and obligations.

Retention period: Until acceptance/decline of entry to the course or program, and as necessary to comply with legal obligations.

2. Application for Teaching Engagement

Type of processing

• Identification
• Correspondence regarding application procedure
• Verification of entry qualifications
• Internal record keeping and audits

Categories of personal data

• Name
• Surname
• Photo
• Date of birth
• Gender
• Place of birth
• Address
• E-mail
• Phone number
• Skype
• CV
• Current position
• Personal web
• Previous positions
• Education
• Publications
• Conferences
• Available information from social media and other online sources

Legal ground: Performance of agreement to examine compliance with qualifications.

Retention period: Until acceptance/decline of position, and as legally required.

3. Compliance with Legal Obligations

Type of processing: Administration necessary for fulfilling legal obligations related to bookkeeping, tax payments, and educational activity regulations.

Categories of personal data

• Name
• E-mail
• Personal identification number
• Address
• Phone number

Legal ground: Compliance with legal obligations to which Harbour.Space is subject.

Retention period: As legally required (e.g., 2 years following graduation from course/program).

4. Customer and Student Service

Type of processing

• Questions regarding grades, courses, programs via phone or digital channels
• Identification
• Claims and support including technical support

Categories of personal data

• Name
• Phone number
• E-mail
• Skype
• Correspondence
• Information about purchases and potential errors or complaints

Legal ground: Legitimate interest in administering customer and student service matters.

Retention period: 36 months following data collection or consent revocation.

5. Administration of Invitations to Events and Newsletters

Type of processing

• Identification
• Correspondence, surveys, and evaluation regarding events such as registration confirmation and feedback

Categories of personal data

• Name
• Phone number
• E-mail

Legal ground: Legitimate interest in evaluating, developing, and improving Harbour.Space services.

Retention period: 36 months following data collection or consent revocation.

6. Direct Marketing

Type of processing: Direct marketing by Harbour.Space or through external partners.

Categories of personal data

• Name
• E-mail
• Phone number
• Address
• Navigational information including details about your computer, website visits, IP address, geographical location, browser type, referral source, length of visit, and pages viewed

Legal ground: Legitimate interest in evaluating, developing, and improving services and systems.

Retention period: 36 months following course/program end or consent revocation.

7. Evaluate, Develop and Improve Services and Systems

Type of processing

• Personalizing the website to improve browsing experience
• Administration of website and relationship with visitors
• Conducting optional online surveys
• Establishing material for service improvement
• Providing customers opportunity to improve services
• Developing IT security materials

Data analysis may sort you into customer segments based on purchase history, age, and gender, though analysis is never carried out at an individual level.

Categories of personal data

• Age
• Residence
• Correspondence/feedback
• Purchase and user-generated data including click and visit history
• Technical data such as browser type and domain names
• Interaction information with Harbour.Space
• Navigational information

Legal ground: Legitimate interest in evaluating, developing, and improving services.

Retention period: 36 months following data collection.

8. Prevent Misuse and Criminal Offences

Type of processing

• Preventing spam, phishing, harassment, incorrect logins, and similar activities
• Developing and improving IT systems for security

Categories of personal data

• Age
• Residence
• Correspondence/feedback
• Purchase and user-generated data including click and visit history
• Technical data
• Interaction information
• Navigational information

Legal ground: Legal obligation or legitimate interest in preventing misuse or investigating criminal offences.

Retention period: 36 months following data collection.

Sensitive Personal Data and Personal Identification Numbers

Sensitive personal data includes information revealing race or ethnicity, political views, religious or philosophical beliefs, trade union membership, health, or private life information.

Harbour.Space may process sensitive data when delivering services, such as information about special learning needs or dietary requirements. Personal identification numbers are only processed when needed to ensure identification or when strictly necessary, with limited use.

Additional protective measures are in place for sensitive data and personal identification numbers. The organization uses encryption such as SSL protocol to protect personal data and credit card numbers.

Sensitive personal data is only disclosed to third parties as referenced in this policy or when absolutely necessary for security or confidentiality purposes.

Sources of Information

Harbour.Space processes data you provide or that is registered based on your purchases and service use. The organization may supplement data with information from third parties to evaluate and improve digital channels and services.

Information collected from third parties includes:

• Address information from public registries
• Information from social media for marketing or anti-fraud purposes

Information to Other Parties

Data Processors

Harbour.Space may retain external suppliers (processors) for services connected to digital channels or services. These suppliers may process personal data and sometimes require limited access to collected information.

Types of suppliers used include:

• Payment solutions providers
• Marketing services including social media and advertising
• IT companies handling operations, technical support, and IT maintenance
• Events, statistics, and surveys companies

Harbour.Space endeavours to limit third-party access and only share information necessary for suppliers to perform their work. The organization verifies that suppliers meet high standards and provide sufficient safeguards.

Other Data Controllers

Harbour.Space may share personal data with independent data controllers:

• Government agencies of Spain or Thailand if required by law
• Companies offering payment solutions and student benefits

When data is shared with independent data controllers, this Privacy Policy no longer applies.

Transfers to Third Countries

Harbour.Space strives to keep personal data within the European Economic Area (EEA) but engages suppliers outside the EEA such as Google, Facebook, Mailchimp, and Bitrix24.

Data may be transferred outside the EEA during support and maintenance or when sharing with group companies. Harbour.Space always takes appropriate technical and organizational measures to ensure the same security level as in the EEA, such as using EU Commission Standard Clauses or Privacy Shield registration.

Amendments to the Privacy Policy

Harbour.Space reserves the right to change this Privacy Policy. Changes will be notified on the harbour.space webpage one month before implementation. You should not supply personal data if you do not accept changes to the policy.

Deletion of Data

Personal data is not stored longer than necessary for processing purposes. Harbour.Space will delete personal data in accordance with applicable legislation and our Retention Policy. Where information is unreliable, irrelevant, or excessive, it will be securely deleted or access removed as soon as reasonably possible.

Your Rights

You are entitled once each year and free of charge to request information regarding personal data Harbour.Space processes about you and to have erroneous information corrected.

You may request deletion of personal data held about you if it is no longer necessary for collection purposes, is processed illegally, or if you opt-out from direct marketing. Harbour.Space may decline requests if legally required to retain data for tax, bookkeeping, or legal defense purposes.

You have the right to request limitations of personal data processing. You always have a right to opt-out from direct marketing activities and request limitation based on legitimate interest, including profiling for direct marketing.

Where consent is provided or processing is based on agreement fulfillment, you may have the right to transfer your data to another data controller.

To request information about how Harbour.Space processes personal data, send a written and signed request to the organization using the contact information below.

Links

Digital channels may include links to websites from other group companies or external organizations. This Privacy Policy does not apply to such websites. Review the privacy policy of any such website before providing personal data.

Security

Harbour.Space takes all appropriate technical and organizational security measures which are necessary to safeguard personal data against unauthorized access, modification, or destruction. However, providing personal data over digital channels entails risks since complete protection from unauthorized access is not possible.

Information About Children

The Harbour.Space website is not intended for or targeted at children under 13 years old. The organization never knowingly or intentionally collects information about children under this age. If you believe Harbour.Space has collected information about a child, contact privacyofficer@harbour.space to request deletion.

Social Media and External Websites

The Harbour.Space website includes social media features such as Facebook 'Like' buttons and widgets like 'Share this' buttons. These features may collect your IP address, track pages you visit, and set cookies. This Privacy Policy does not apply to these features; your interactions are governed by the privacy policies of the companies providing them.

The website may provide hyperlinks to other websites. Harbour.Space does not control and is not responsible for the content or practices of other websites.

Contact Information

For questions regarding the Privacy Policy or processing:

Cookies & Technologies

Cookies are small text files consisting of letters and numbers sent from the web server and stored on your browser or device. They help websites work or work more efficiently and provide site owners with information.

Harbour.Space uses cookies to improve services, save functional settings such as language, and target relevant marketing. Cookies allow the organization to understand which pages users have seen and determine popular areas of the website.

Harbour.Space uses cookies or similar technologies to analyze trends, administer the website, track user movements, and gather demographic information.

Types of Cookies Used

• Session cookies: Temporary, ending when you close your browser
• Permanent cookies: Remain on your computer until deletion or expiration
• First-party cookies: Set by the site you visit
• Third-party cookies: Set by another site, primarily for analysis like Google Analytics
• Similar techniques: Store information in browser or device similar to cookies

Use of Google Analytics

Harbour.Space analyzes information about harbour.space website use and activity on Harbour.Space's social media pages using Google Analytics. Using Google Analytics, Harbour.Space will analyze behaviour for creating more relevant ads and offers, as well as for developing Harbour.Space's products and services.

How to Control Cookies

You have the ability to accept or decline cookies. Most browsers automatically accept cookies, but you can usually modify settings to decline them. If you decline cookies, you may not fully experience interactive features of the subscription service or websites.

Your browser or device enables you to change cookie usage settings. You can block all cookies, accept only first-party cookies, or delete cookies when closing your browser. Some services may not work if cookies are blocked.

Clear Gifs (Web Beacons / Web Bugs)

Harbour.Space uses clear gifs (web beacons or web bugs) to better manage the website and subscription service by informing what content is effective. Clear gifs are tiny graphics with unique identifiers, similar to cookies in function, used to track online user movements. Unlike cookies stored on computer hard drives, clear gifs are embedded invisibly on web pages or in emails.

The organization uses clear gifs in HTML-based emails to track which emails have been opened. This allows Harbour.Space to gauge effectiveness of communications and marketing campaigns. The organization ties information gathered by clear gifs to customer personal data.

Advertising

Harbour.Space partners with a third-party advertising network to display advertising on its website or manage advertising on other websites. The advertising network partner uses cookies and clear gifs to collect non-personal information about your activities to provide targeted advertising based on your interests.

Third-party tracking technologies are not covered by this Privacy Policy. Harbour.Space does not have access to or control over such technologies.