LinguallogyPrivacy policy
Last updated: November 2026
Versión en español: Política de privacidad. If the two versions differ, the Spanish one prevails.
1. Controller
| Controller | Ilya Gerasimets (sole trader, autónomo), trading as Linguallogy and Escapada Lingüística |
|---|---|
| NIF | Y1361773A |
| Address | Plaça del Virrei Amat 3, A2, 08031 Barcelona, Spain |
| info@linguallogy.com |
2. Two different roles
- As controller we handle the data of people who contact us (form, email, WhatsApp or Telegram), of our clients for invoicing, and of our teachers.
- As processor we handle the data of each client company's employees on behalf of that company, which is the controller. Every company contract includes a data processing agreement (art. 28 GDPR).
3. What data we handle
- Contact form: name, company, work email, phone and a good time to call (optional), team size, language, type of request and your message.
- WhatsApp, Telegram or email messages: what you include and your number or username.
- Client employees: first name and surname, the contact each person chooses (phone, Telegram or WhatsApp), written and voice answers to the level check, level, and attendance at each class with a general absence category ("work" or "other justified reason"). We do not record medical details or the specific reason for an absence.
- Monthly check-ins and survey: answered through a link, with no name or contact. Only results aggregated by group are shown, never for groups with fewer than 3 answers.
- Teachers: name and Telegram account, to remind them of each class, log attendance and arrange substitutes.
- Technical data: our hosting provider logs the IP address and technical data of each visit for security.
4. Purposes and legal basis
| Purpose | Legal basis |
|---|---|
| Answering your request and preparing a proposal | Steps taken at your request before a contract (art. 6.1.b GDPR) |
| Teaching a client company's employees | On behalf of the client company, following its instructions and the processing agreement (art. 28 GDPR) |
| Invoicing, tax and accounting | Legal obligation (art. 6.1.c GDPR) |
| Website security | Legitimate interest (art. 6.1.f GDPR) |
We make no automated decisions and do no profiling.
5. How long we keep data
- Requests that don't lead to a contract: up to 12 months.
- Voice recordings from the level check: deleted 30 days after the level report is sent.
- Employee data: for as long as the contract with the client company lasts; afterwards it is returned or deleted as the company instructs.
- Invoices and accounting records: as long as the law requires.
6. Recipients and providers
- The client company sees its employees' level and attendance in its dashboard, and monthly check-in results only aggregated by group.
- Other members of the same group chat can see each participant's name or username. Anyone can use WhatsApp or email instead of Telegram.
- Netlify, Inc. (USA): hosting of this site and the dashboard, and form handling. Transfer covered by the EU-US Data Privacy Framework.
- Supabase, Inc.: database of the join.linguallogy.com dashboard, under a processing agreement and, if data leaves the EU, standard contractual clauses.
- Telegram and WhatsApp (Meta): only when a person chooses that channel. They may process data outside the European Economic Area under their own policies.
- Our email provider, used to communicate with clients and learners.
We never sell or share data with third parties for marketing.
7. Your rights
You can ask to access, correct, delete, object to, restrict or port your data by writing to info@linguallogy.com. Employees of a client company can also contact their employer. You can complain to the Spanish Data Protection Agency (www.aepd.es).
8. Security
We apply appropriate technical and organisational measures and limit access to the people who need it to provide the service.