GLOBAL PRIVACY POLICY

This Global Privacy Policy explains how we process your personal data when you browse our website, request information, register for our courses or programs, purchase our services, use our learning platform, or otherwise interact with us through any channel.

This policy is designed to provide clear and transparent information about the processing of personal data under applicable laws, including European data protection law and, where applicable, certain U.S. state privacy laws.

We recommend that you read this policy carefully before providing us with your personal data.

1. Data Controller

Controller: MD FORMACION Y PROCESOS, S.L.
Tax ID (NIF): B97455380
Registered address: Calle Uruguay 8, 12, 46007 Valencia, Spain
Privacy contact email: hola@inscolearning.com
Website: INSCO Learning

2. Scope of this Policy

This policy applies to personal data processed by MD FORMACION Y PROCESOS, S.L. in relation to:

visitors to the website;
individuals requesting information or commercial contact;
students, clients and prospective clients;
representatives and employees of client or partner companies;
attendees of webinars, events, demonstrations or informational sessions;
users of the learning platform, campus or LMS;
individuals who interact with our communications, forms, campaigns or corporate profiles.

In certain forms, registration processes or tools, we may provide additional information or specific notices at the time the data is collected.

3. Categories of Personal Data We Process

During the previous 12 months and, more generally, depending on how you interact with us, we may have processed the following categories of personal data:

3.1. Identification and contact data

Name, surname, email address, phone number, company, job title, country, business address and other contact details.

3.2. Commercial and relationship data

Information requests, communication history, interest in courses or services, quotations, proposals, commercial follow-up and preferences related to our services.

3.3. Contractual, administrative and billing data

Data necessary to manage registrations, orders, contracts, collections, payments, invoicing, administrative incidents and customer service.

3.4. Academic or training usage data

Purchased courses, progress, access to content, participation in activities, tutoring, assessments, results, technical or academic questions and support associated with service delivery.

3.5. Browsing and digital usage data

IP address, browser type, online identifiers, device, operating system, language, pages visited, time spent browsing, interactions with the website, platform, forms, campaigns or emails, as well as data obtained through cookies or similar technologies.

3.6. Professional or business data

Company, department, role, professional position, training interests, sector, type of plant or business activity related to the requested services.

3.7. Audio-visual or event participation data

Image, voice or attendance data when you participate in webinars, online meetings, recorded sessions or similar activities, where applicable.

3.8. Inferences or preferences

We may infer interests or preferences related to our services, courses, training areas or professional activity for personalization, support, internal analysis or communications, where appropriate.

3.9. Sensitive data

As a general rule, we do not request special categories of personal data and we do not use sensitive data for purposes that would require an additional right to limit processing under applicable law. If, in a specific case, it becomes necessary to process special category or sensitive data, we will do so only where there is a sufficient legal basis and with the safeguards required by law.

4. How We Obtain Your Data

We may obtain your personal data:

directly from you, through forms, emails, phone calls, meetings, webinars, purchases, registrations or any other contact channel;
from your company or organization, when it manages your participation in a training activity or service;
automatically, through your use of the website, platform, emails or similar technologies;
from service providers or collaborators acting on our behalf;
from partners, event organizers, commercial collaborators or referral sources, where appropriate;
from publicly available sources, to the extent permitted by applicable law.

5. Purposes of Processing and Legal Bases

We process your personal data for the following purposes:

5.1. To respond to information requests, contact requests or demonstrations

We use your data to answer enquiries, prepare proposals, carry out commercial follow-up and provide information about courses, programs or services.

Legal basis: pre-contractual measures and, where appropriate, consent.

5.2. To manage contracts, registrations, orders and service delivery

We process your data to handle purchases, registrations, contracts, access to training, service delivery, support and management of the relationship with clients or students.

Legal basis: performance of a contract and compliance with legal obligations.

5.3. To manage access to and use of the learning platform

We process your data to provide access to the campus or platform, organize content, record progress, provide tutoring, support, assessments and activities related to training.

Legal basis: performance of a contract.

5.4. To manage operational and service communications

We process your data to send notices regarding courses, access, incidents, operational changes, billing, support, updates or any other communication necessary for service delivery.

Legal basis: performance of a contract and legitimate interest.

5.5. To send marketing communications

We may send you information about courses, programs, events, content, updates or services from INSCO by electronic means when:

you have given us your consent; or
there is a prior contractual relationship and the communications concern services similar to those previously contracted, always with the option to object in each communication.

Legal basis: consent or legitimate interest, as applicable.

5.6. To organize webinars, events, informational sessions and surveys

We process your data to manage your registration, participation and follow-up in activities organized by us or with third-party collaborators.

Legal basis: pre-contractual measures, contractual performance, consent or legitimate interest, depending on the case.

5.7. To improve the website, user experience and security

We process certain data for maintenance, security, fraud prevention, detection of unauthorized access, internal analysis, statistics and continuous improvement of our processes, services and digital assets.

Legal basis: legitimate interest and, where required by law, consent through cookie settings or equivalent tools.

5.8. To comply with legal obligations and defend our rights

We process your data where necessary to comply with tax, accounting, corporate, regulatory or data protection obligations, or for the establishment, exercise or defence of legal claims.

Legal basis: compliance with a legal obligation and legitimate interest.

6. Recipients and Data Disclosures

As a general rule, we do not sell your personal data for monetary consideration.

However, we may disclose or make personal data available to third parties where necessary for service delivery, operational purposes or where there is a legal obligation.

The following categories of recipients may access the data, as processors, recipients or third parties, as appropriate:

hosting, cloud infrastructure and technical support providers;
learning platform, LMS or educational technology providers;
email, CRM, automation, support or customer service providers;
analytics providers, web analytics tools or marketing tools;
payment processors, financial entities and administrative service providers;
professional advisors, auditors, consultants, lawyers or accounting firms;
collaborators or partners involved in delivering a requested activity;
public administrations, authorities, courts, tribunals or law enforcement bodies where legally required.

6.1. Behavioral advertising, sharing and targeted advertising in the U.S.

Depending on the website configuration, accepted cookies and technological tools actually used at any given time, certain online identifiers, browsing data or inferences may be made available to analytics or advertising providers. Under certain U.S. state laws, this type of disclosure may be considered a “sale,” “sharing,” or use for “targeted advertising,” even where there is no sale in the traditional monetary sense.

Where required by applicable law, we will provide opt-out mechanisms for such processing, including, where appropriate, cookie management tools or recognition of universal preference signals.

7. International Data Transfers

As some of our providers may be located outside the European Economic Area or may provide services involving remote access from third countries, we may carry out international data transfers.

In such cases, we will adopt appropriate safeguards as provided by applicable law, such as:

adequacy decisions adopted by the competent authority;
standard contractual clauses;
appropriate contractual and organizational commitments;
any other valid safeguard under applicable law.

If you would like more information about the international transfers we carry out and the safeguards applied, you may request it via the email address stated in this policy.

8. Retention Periods

We will retain personal data for the period necessary to fulfil the purpose for which it was collected and, afterwards, for the legally required retention periods to address possible liabilities.

As a general guideline:

information and contact requests: for the time necessary to respond to the request and for a reasonable follow-up period afterwards, unless you object or withdraw consent where applicable;
contractual and client/student data: while the relationship remains active and during the applicable statutory retention periods;
learning platform data: while course or program access remains active and for the period necessary to evidence service delivery and manage incidents;
marketing communications: until you withdraw your consent or object;
browsing and cookie data: as provided in the Cookie Policy or in the relevant preference management tool.

When determining retention periods, we may take into account the nature, sensitivity and volume of the data, the potential risk arising from unauthorized use, the purposes of processing and applicable legal requirements.

9. Rights of Individuals in Europe

If you are located in the European Union or in a jurisdiction with equivalent rights, you may exercise, under the terms provided by applicable law, the following rights:

access to your personal data;
rectification of inaccurate or incomplete data;
erasure of your data where applicable;
objection to processing;
restriction of processing;
data portability, where applicable;
withdrawal of consent at any time, without affecting the lawfulness of processing carried out before withdrawal.

You may also object at any time to receiving marketing communications.

To exercise your rights, you may write to: hola@inscolearning.com

You may also lodge a complaint with the competent supervisory authority if you believe we have not processed your data in accordance with the law. In Spain, the supervisory authority is the Spanish Data Protection Agency (AEPD).

10. Additional Rights for Residents of Certain U.S. States

Where a U.S. state privacy law applies to our processing, residents of those states may have, to the extent provided by law, some or all of the following rights:

to confirm whether we process their personal data;
to access personal data or know the categories of data we process;
to know the categories of sources from which the data originates;
to know the business or commercial purposes of the processing;
to know the categories of third parties to whom the data is disclosed;
to request correction of inaccurate data;
to request deletion of personal data;
to obtain a portable copy of the data, where applicable;
to opt out of sale, sharing or targeted advertising, where applicable;
to opt out of certain profiling activities with legal or similarly significant effects, where applicable;
not to receive discriminatory treatment for exercising their rights;
to appeal a denial of their request, where applicable.

These rights may vary depending on the state of residence, the type of processing and the applicability thresholds of each law.

10.1. How to exercise U.S. privacy rights

You may exercise your rights by writing to: hola@inscolearning.com

Please clearly indicate the right you wish to exercise and provide the information reasonably necessary for us to verify your identity and process the request. Where necessary, we may request additional information for verification and security purposes.

Where permitted by law, an authorized agent may submit requests on your behalf, subject to appropriate verification.

10.2. Appeals

If we deny your request and the applicable law provides a right to appeal, you may appeal our decision by replying to the denial email or by writing to hola@inscolearning.com with the subject line Privacy Appeal, explaining why you believe the request should have been granted.

10.3. Universal preference signals

Where required by applicable law, we may recognize technical opt-out preference signals such as Global Privacy Control with respect to processing related to sale, sharing or targeted advertising, to the extent that such signals are valid, technically supported and legally required to be honored.

10.4. California-specific disclosures

For California residents, and to the extent that the California Consumer Privacy Act applies:

the categories of personal information we collect are described in section 3;
the categories of sources are described in section 4;
the business or commercial purposes are described in section 5;
the categories of third parties to whom we disclose information are described in section 6;
our retention approach is described in section 8.

Depending on the tools used at any given time, certain disclosures of online identifiers, internet activity or inferences to analytics or advertising providers may be considered sharing or targeted advertising under California law. Where applicable, we will provide the legally required opt-out mechanisms.

11. Minors

Our services are not generally directed to minors. We do not knowingly collect personal data from minors where this is not permitted under applicable law.

If we become aware that we have received personal data from a minor without proper authorization or sufficient legal basis, we will take reasonable steps to delete or block such data.

Anyone providing data on behalf of a third party guarantees that they are authorized to do so and that the data provided is accurate, current and truthful.

12. Automated Decision-Making

As a general rule, we do not make decisions based solely on automated processing that produce legal effects concerning the data subject or similarly significantly affect them.

If such processing were to be applied in a specific case, we would inform you accordingly where required by law.

13. Cookies and Similar Technologies

We use cookies and similar technologies for website operation, browsing analysis, security, personalization and, where appropriate, marketing or advertising.

Further information on the use of these technologies and your configuration options is set out in our Cookie Policy and, where applicable, in the consent or preference management tool available on the website.

14. Information Security

We apply reasonable and appropriate technical and organizational measures to protect personal data against loss, alteration, unauthorized access, improper disclosure or unlawful processing, taking into account the state of the art, the nature of the data and the risks associated with processing.

15. Changes to this Policy

We may update this Global Privacy Policy where necessary due to legal, regulatory, operational, technical or processing changes.

Where the changes are material, we will communicate them by reasonable means, by visible notice on the website or through other appropriate channels, where applicable.

Publication date: 10 April 2026

16. Contact

If you have questions about this policy or about the processing of your personal data, you may contact us at:

MD FORMACION Y PROCESOS, S.L.
hola@inscolearning.com