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Privacy Policy

Introduction

Harbour.Space ensures all of its online visitors to be confident that we process information about you in accordance with applicable privacy legislation. Our Privacy Policy describes how Harbour.Space handles and protects your personal data in our capacity as a data controller. It also describes your rights and how to proceed in case you wish to exercise them. Customers who subscribe to Harbour.Space services, such as students to our courses, are contractually obligated to comply with the agreement, terms and conditions. Please see our general terms and conditions for more information about our data processing when you apply to a Harbour.Space course.

Harbour.Space is committed to respecting your privacy and protecting your personal data – any information that may identify you as an individual person (such as name, address, pictures and IP address) and which is collected via our digital channels, such as our website, mobile apps and/or other future digital contact interfaces which links to this Privacy Policy.

It is important to us at Harbour.Space that you feel safe in our processing of your personal data. Harbour.Space would never knowingly sell or release your personal data to another party in other ways than as follows from this Privacy Policy and you are always welcome to contact Harbour.Space if you have any questions.

You will find information about how to contact Harbour.Space below.

We welcome you to visit all digital channels managed by Harbour.Space and you do not need to provide any personal data to visit them. However, please be aware that if you do not provide some requested information, access to certain services or parts of our digital channels and certain social media channels may be restricted.

 

Personal data processing

What personal data does Harbour.Space process about you and for what purposes?

1. Application to one of our programs or courses

Type of processing

  • Identification;
  • Correspondence regarding the application procedure;
  • Necessary program entry requirement control legally required and stipulated by Harbour.Space;
  • 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

The legal ground for processing is the performance of the agreement with you to  eximine your application. Data collection is required to fulfill our rights and obligations under this agreement. Should the requested information not be provided, Harbour.Space may not be able to fulfill its obligations according to the agreement and may, therefore, deny your application.

Retention period

The retention period last until you have been accepted/declined entry to the course or programme and as necessary to comply with any such legal obligation to which Harbour.Space is subject.

2. Application for a teaching engagement 

Type of processing

  • Identification;
  • Correspondence regarding the application procedure;
  • Verification of compliance of the entry qualifications is legally required and stipulated by Harbour.Space;
  • 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

The legal ground for processing is the performance of the agreement with you to examine your compliance. Data collection is required to fulfill our rights and obligations under this agreement. Should the requested information not be provided, Harbour.Space may not be able to fulfill its obligations according to the agreement and may, therefore, deny your application.

Retention period

The retention period last until you have been accepted/declined entry to the position or programme and as necessary to comply with any such legal obligation to which Harbour.Space is subject.

3. Compliance with legal obligations

Type of processing

Necessary administration for the fulfilment of the Harbour.Space  legal obligations (e.g. laws and regulations related to bookkeeping, tax payments, educational activity regulations).

Categories of personal data

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

Legal ground

The legal ground for processing is compliance with legal obligations to which Harbour.Space is subject. The processing is necessary to fulfil our legal obligations. In case data is not provided Harbour.Space may not approve your application.

Retention period

The retention period as legally required (e.g. 2 years following graduation from course/program under applicable internal regulations).

4. Customer and student service

Type of processing

  • Questions regarding grades, courses, programs etc. via phone or digital channels (incl. social media);
  • Identification;
  • Claims and support (incl. technical support).

Categories of personal data

  • Name
  • Phone number
  • E-mail
  • Skype
  • Your correspondence
  • Info about your purchase and potential error/complaints.

Legal ground

The legal ground for processing this data is of legitimate interest. The processing is necessary to administer yours and our need to process customer/student service matters. The secondary reason is consent where you have provided your consent to receive product-related information.

Retention period

The retention period is 36 months following the collection of the data or the consent is revoked.

5. Administration of invitations to events and newsletters

Type of processing

  • Identification;
  • Correspondence, surveys and evaluation regarding the event such as confirmation of registration, requests and evaluations.

Categories of personal data

  • Name
  • Phone number
  • E-mail

Legal ground

The legal ground for processing this data is of legitimate interest. The processing is necessary to adhere to Harbour.Space and Harbour.Space customers’ legitimate interest to evaluate, develop and improve Harbour.Space services and systems. The secondary reason is consent where you have provided your consent to receive our invitations and newsletters.

Retention period

The retention period is 36 months following the collection of the data or consent is revoked.

6. Direct marketing

Type of processing

Direct marketing by Harbour.Space or through our external partners.

Categories of personal data

  • Name
  • E-mail
  • Phone number
  • Address
  • Navigational information such as information about your computer and your visits to this website including your IP address, geographical location, browser type, referral source, length of visit and pages viewed, correspondence and feedback regarding our services.

Legal ground

The legal ground for processing this data is of legitimate interest. The processing is necessary to adhere to Harbour.Space and Harbour.Space customers’ legitimate interest to evaluate, develop and improve Harbour.Space services and systems.

Retention period

The retention period lasts for 36 months following the end of the course/program or consent is revoked

7. Evaluate, develop and improve Harbour.Space services and systems for - Harbour.Space customers in general

Type of processing

  • Improve visitors’ browsing experience by personalizing the website and improve our services;
  • Administration of our website and our relationship with you including to provide services to you which you may request from Harbour.Space and/or to provide and monitor our services to you;
  • Conducting optional online surveys (e.g. to receive feedback regarding the quality of our service);
  • Establish material for improvement of our services such as courses and programs;
  • Provide our customers the possibility to improve our services;
  • Development of material to improve our IT systems with the purpose of raising the security for Harbour.Space and our visitors.

Based on the data we collect (purchase history, age, gender) Harbour.Space may carry out analysis that may include you being sorted into a customer segment. The analysis is however never carried out on an individual level. The result from the analysis is used for improving our services and developing our webpage.

Categories of personal data

  • Age, residence, correspondence/feedback, purchase and user generating data (incl. click and visit history), technical data such as browser type, domain names, internet service provider (ISP) etc.), info about your interaction with Harbour.Space (log data, how long different pages have been reviewed, answering times, download errors, how you reach and leave the service etc.)
  • Navigation information about your computer and your visits to this website including your IP address, geographical location, browser type, referral source, length of visit and pages viewed.
  • Correspondence and feedback regarding our services.

Legal ground

The legal ground for processing this data is of legitimate interest. The processing is necessary to adhere to Harbour.Space and Harbour.Space customers’ legitimate interest to evaluate, develop and improve our services and systems.

Retention period

The retention period is 36 months following the collection of the data.

8. Prevent misuse of a service or prevention and investigation of a criminal offence against Harbour.Space

Type of processing

  • Prevent spam, phishing, harassment, incorrect logins to user accounts or similar activities;
  • Development and improvement of our IT systems with the purpose of raising the security for the company and our visitors.

Categories of personal data

  • Age, residence, correspondence/feedback, purchase and user generating data (incl. click and visit history), technical data (incl. IP number, web instalments, operating system, screen resolutions, platform), info about your interaction with Harbour.Space (log data, how long different pages have been reviewed, answering times, download errors, how you reach and leave the service etc.)
  • Navigational Information such as information about your computer and your visits to this website including your IP address, geographical location, browser type, referral source, length of visit and pages viewed.
  • Correspondence and feedback regarding our services.

Legal ground

The legal ground for processing is the legal obligation to which Harbour.Space is subject or Legitimate Interest. Where no legal obligation exists, the processing is necessary to adhere to our legitimate interest of preventing misuse of a service or to prevent and investigate criminal offences against Harbour.Space.

Retention period

The retention period lasts for 36 months following collection of the data.

 

Sensitive personal data and personal identification numbers

Sensitive personal data includes any information that reveals your race or ethnicity, political views, religious or philosophical beliefs, membership in a trade union, as well as personal data regarding your health or private life.

Harbour.Space may process the following sensitive personal data when carrying out our services: Personal identification number, copy of passport, emergency contact details, as stated above. Sensitive personal data may be collected from you if you purchase our services or choose to attend our courses, programs and/or events (or other sessions or events organized by Harbour.Space or on our behalf). You may in such case choose to submit your sensitive personal data to Harbour.Space about, for example, your special learning needs or dietary requirements.

Personal identification numbers are only processed when needed to ensure your identification or if strictly needed. Harbour.Space limits the use of personal identification numbers.

Harbour.Space has additional measures in place to protect sensitive personal data, personal identification numbers, and confidentiality. Harbour.Space will use your sensitive personal data to deliver our services to you, meet your requirements, or deal with any requests made by you. Personal data and other sensitive information, such as credit card numbers and/or location data, collected on our website and/or transmitted to other websites are protected through the use of encryption such as the Secure Socket Layer (SSL) protocol.

Harbour.Space will only disclose your sensitive personal data to the third parties as referred to in this Privacy Policy or where Harbour.Space considers it absolutely necessary – such as to establish appropriate security or confidentiality obligations.

 

Sources of information

Harbour.Space only processes data you have provided or that Harbour.Space registers based on your purchases and the use of our services. In certain cases, Harbour.Space may supplement this data with information from third parties for the purpose of evaluating and improving our digital channels and services.

The information that Harbour.Space collect from third parties is as follows:

  1. Address information from public registries to ensure we have the right address;
  2. Information from social media for marketing or anti-fraud purposes.

     

Information to other parties

Data processors

Other than as provided in this Privacy Policy, Harbour.Space will not knowingly share the personal data you provide with any third party. In cases where it is necessary for Harbour.Space to carry out our services, we may retain external suppliers (processors) for services in connection to our digital channels or the services. These suppliers may process personal data and sometimes require limited access to personal data collected via our digital channels or services. Harbour.Space uses the following types of suppliers:

  • Payment solutions (banks, other payment service providers);
  • Marketing (social media, media agencies, advertising services, CRM providers);
  • IT (companies that handle necessary operations, technical support and maintenance of our IT solutions, such as Google);
  • Events, statistics and surveys (companies that handle evaluations, statistics and surveys of our services).

Harbour.Space endeavours to limit third-party access and only share information that is necessary to enable suppliers to carry out their work. Harbour.Space always checks that our suppliers can meet our high standards and provide sufficient safeguards and require them to protect your personal data in accordance with this Privacy Policy and refrain from using or disclosing your personal data for any purpose other than providing Harbour.Space with the agreed product or services.

Other data controllers

Harbour.Space may also share your personal data with companies that are independent data controllers:

  1. Government agencies of Spain or Thailand if Harbour.Space is required to do so by law;
  2. Companies offering payment solutions and student benefits (banks and other payment service providers).

When personal data is shared with an independent data controller, this Privacy Policy is no longer applicable.

Transfers to third countries

Harbour.Space strives at all times to keep personal data within the European Economic Area (EEA) but engage suppliers located outside of the EEA such as Google, Facebook, Mailchimp and Bitrix24.

During support and maintenance, Harbour.Space may have to transfer the information outside of EEA, also when Harbour.Space shares data with our group companies in order to carry out our services.

Any such data will always be kept to a minimum relevant for the purpose. No matter where your personal data is transferred Harbour.Space always take appropriate technical and organizational measures to ensure that the security level is the same as in the EEA and at an adequate security level, for example by using the EU Commission’s Standard Clauses or ensure that the supplier is Privacy-Shield registered.

 

Amendments to the privacy policy

Harbour.Space reserves the right to change this Privacy Policy. Changes to the terms of the policy will be notified on harbour.space web page, one month before the change of terms enters into force. The current terms and conditions are available at https://harbour.space/privacy-policy

You should not supply Harbour.Space with any personal data if you do not accept changes which are made to this Privacy Policy.

 

Deletion of data

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

 

Your rights  

You are entitled once each year and free of charge to request information regarding the personal data, if any, about you which Harbour.Space processes and to have any erroneous information corrected. Please note that Harbour.Space may request additional details about you in order to ensure secure and effective handling of your request and to ensure that the information is provided to the correct person.

Should you have reason to believe that any personal data that Harbour.Space holds about you is inaccurate, please let us know and we will update the information.

You may request us to delete personal data we hold about you. For example, if the information is no longer necessary to fulfil the purpose they were collected for, they are processed in an illegal way, or you opt-out from direct marketing. Please note that, when legally required, Harbour.Space could decline your request, for example, if the data is needed for tax or bookkeeping purposes, or are necessary to defend legal claims.

You also have the right to request limitations of the processing of your personal data. In such cases, Harbour.Space may need to investigate the situation further prior to reaching a decision. Please be aware that you always have a right to opt-out from direct marketing activities and request limitation of processing based on legitimate interest – including potential profiling for direct marketing purposes.

When you provide Harbour.Space with your consent or the processing is based on the fulfillment of an agreement with you, you have, during certain circumstances a right to have your data transferred to another data controller. 

If you would like to know how Harbour.Space processes personal data, send a written and signed request to Harbour.Space. You will find our contact information below.

 

Links

Our digital channels may include links to websites which are provided by other group companies or companies which do not belong to the Harbour.Space group. This Privacy Policy shall not apply to such websites. You should, therefore, review the privacy policy of any such website before you provide personal data.

 

Security

Harbour.Space takes all appropriate technical and organizational security measures which are necessary to the safeguard personal data against unauthorized access, modification, or destruction. However, providing personal data over digital channels always entails a risk since it is not possible to completely protect technical systems from unauthorized access.

 

Information about children

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

 

Social media and external websites

The Harbour.Space website includes social media features, such as a Facebook ‘Like’ button and also widgets, such as the ‘Share this’ button, or interactive mini-programs that run on our website. These features may collect your IP address, which pages you visit on our website, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by third parties or directly on our website. This Privacy Policy does not apply to these features. Your interactions with these features are governed by their privacy policies and other routines of the companies providing them.

Our 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

If you have any questions regarding our Privacy Policy or any other question regarding our processing, please contact us:

Harbour.Space BCN S.L.

Carrer de Rosa Sensat, 9-11, 08005

Barcelona, Spain

hello@harbour.space

 

Cookies & technologies

Cookies are a small text file consisting of letters and numbers sent from our web server and stored on your browser or device.

They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. The cookies Harbour.Space uses usually improve the services Harbour.Space offers you. Some of the Harbour.Space services need cookies to work properly, while others improve the services for you. Harbour.Space uses cookies for overall analytical information regarding your use of Harbour.Space services. Harbour.Space uses cookies to save functional settings such as language and other tasks. Harbour.Space also uses cookies that allow Harbour.Space to target relevant marketing to you. Cookies allow Harbour.Space to understand who has seen which pages, and to determine the most popular areas of our web site.

Harbour.Space uses cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole.

Harbour.Space uses different cookies:

  • Session cookies are temporary cookies that end when you close your browser or device;
  • Permanent cookies remain on your computer until you delete them or they expire;
  • Prebook cookies are set by the site you visit;
  • Third-party cookies are set by another site. At Harbour.Space, these are primarily used for analysis (such as Google Analytics);
  • Similar techniques store information in your browser or device in a manner similar to cookies.

Use of Google Analytics

As part of Harbour.Space’s marketing, Harbour.Space analyzes information about the use of harbour.space website and activity on Harbour.Space’s pages on social media. For example, using Google Analytics, we will analyze behaviour for creating more relevant ads and offers, as well as for developing Harbour.Space’s products and services. In addition, Google Analytics helps to evaluate the use of harbour.space for services related to website activities and internet usage.

How to control cookies

You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Harbour.Space subscription service or websites you visit.

Your browser or device enables you to change the settings for usage and extent of cookies. Go to the settings of your browser or device to learn more how to adjust cookies settings. For example you may block all cookies, only accept first-party cookies or delete cookies when you close your browser. Please note that some of our services may not be working if blocking or reading cookies.

Clear gifs (web beacons/web bugs)

Harbour.Space uses a software called clear gifs (also known as web beacons or web bugs), that helps us better manage the website and subscription service by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, used to track the online movements of online users. Unlike cookies which are stored on users’ computer hard drives, clear gifs are embedded invisibly on web pages or in emails and are about the size of the period at the end of this sentence. Harbour.Space uses clear gifs in our HTML-based emails to let Harbour.Space know which emails have been opened by recipients. This allows Harbour.Space to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. Harbour.Space ties the information gathered by clear gifs in emails to our customers’ personal data. If you would like to opt-out of these emails, please see the section ‘Opting Out and Unsubscribing.’

Advertising

Harbour.Space partners with a third party advertising network to either display advertising on our website or to manage our advertising on other websites. Our advertising network partner uses cookies and clear gifs to collect non-personal information about your activities on this and other websites to provide you targeted advertising based upon your interests. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by clicking here: http://preferences.truste.com/ or, if located in the European Union, by clicking here: http://www.youronlinechoices.eu/. Please note this act does not opt you out of being served to advertise. You will continue to receive generic ads.

The use of cookies and web beacons by any tracking utility company is not covered by our Privacy Policy. Harbour.Space does not have access to or control over third-party tracking technologies.

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