Privacy policy

1. Introduction

The purpose of this Privacy Policy is to inform you, in accordance with the provisions of the applicable regulations, of the processing of personal data obtained through the website www.turingdream.com (hereinafter, the “Website”)

Access to and use of the Website grants you the status of user (hereinafter, “User/s”) and implies knowledge and acceptance of the conditions included in this Privacy Policy.

2. Who is the Data Controller?

Identity: TURING DREAM, S.L. (hereinafter, “TURING DREAM”)

NIF: B56525512

Address: C/ Zarza, 4. 28250 Torrelodones, Madrid

Telephone: +34 91 859 13 62

Email: [email protected]

3. What happens if you are under 14 years old?

Please remember that you must be 14 years old to be able to register on this Website.

If you are under 14 years old, your father, mother or guardian must read this Privacy Policy and authorize your registration request as a User of the Website. To do so, your father, mother or guardian must complete the registration form following the instructions that appear on the screen and providing the data requested at each step of the registration process.

In any case, TURING DREAM will check the data and/or documentation provided with your registration request and may request any data or document that is necessary to complete and confirm said registration. It may also automatically cancel any request that has not been completed in accordance with the procedure described. In any case, TURING DREAM will not assume any liability arising from non-compliance by the User, his/her father, mother or guardian with the provisions of this section.

4. How do we collect personal data?

TURING DREAM collects information from Users when they use those features of the Website that require them to provide certain personal data. Specifically, TURING DREAM will record the following information:

• Contact form and/or sending of emails: the personal data (including, but not limited to, name, surname, and email address) that the User voluntarily provides through the aforementioned form and/or by sending an email to the address indicated for such purposes on the Website.

• Subscription to the newsletter and/or sending of commercial communications: the personal data (including, but not limited to, name, surname, and email address) that the User voluntarily provides us through the form enabled to subscribe.

• User registration form: the personal data (including, but not limited to, name, surname, email address, authorization from the father, mother, or legal guardian if the user is under 14 years of age) required in the form enabled to register and/or manage your account as a User of the Website.

• Hiring of the artificial intelligence teaching assistant (“AI Tutor”): the personal data (including, but not limited to, name, surname, email address, ID/NIF, authorization of the father, mother, or legal guardian if the user is under 14 years of age) required during the online hiring process of the aforementioned assistant for our products through the Website.

• Regarding the use of the AI ​​Tutor: The data collected on the User's academic performance, including, but not limited to, their grades, time spent reading, speed of comprehension, participation in activities, identified areas of improvement and progress in each area or subject of tutoring.

• Customer service chat: the personal data (including, but not limited to, name, surname, and email address) or any other data that the User provides in their query or request made through the aforementioned chat.

• Regarding the “Work with us” form: the personal data, including the CVs that the Users send us.

The use of the different forms and/or functionalities enabled on the Website is voluntary. However, some fields are necessary to correctly address your request, so the User's refusal to provide the information required in the mandatory fields will prevent TURING DREAM from responding to your request.

5. For what purpose do we process your data?

The personal data that the User provides us through the forms and functionalities enabled on the Website will be processed for the purposes and legal bases listed below:

• Consent of the interested party (Art. 6.1, letter “a” of the GDPR)

o To attend to and respond to queries or requests made by Users through the web contact form or the chat enabled on the Website, and/or by sending emails to the addresses provided for such purposes.

o With the User's prior authorization, to send the newsletter and commercial communications by electronic means about the products and/or services offered by TURING DREAM.

o With the User's prior authorization, to create academic profiles, analyze the User's aptitudes and academic performance, in order to identify areas for improvement and offer recommendations in accordance with the specific needs of each User.

• The application of pre-contractual measures (Art. 6.1, letter “b” of the GDPR)

o To manage your participation and assess your candidacy for current or future personnel selection processes carried out by TURING DREAM.

• Execution of the legal relationship established between TURING DREAM and the Users of the Platform (Art. 6.1, letter “b” of the GDPR):

o Allow access and management of the area reserved for registered Users on the Website.

o The provision of the contracted service through the Website (Tutor IA), including access to it, its billing and the management of payments, as well as any other service derived from said relationship (e.g. the attention of requests addressed to the customer service).

• Compliance with the legal obligations applicable to TURING DREAM as a result of the treatments described above (Art. 6.1, letter “c” of the GDPR).

6. To which recipients will we communicate your data?

The personal data of the Users will not be communicated to third parties, except for the fulfillment of legal obligations to which TURING DREAM is subject.

7. For how long will we keep your data?

Personal data will be kept by TURING DREAM

• In the case of the contact form, chat, and/or emails, only for the time necessary to attend to and manage each specific request made by the User.

• In the case of newsletters and/or commercial communications, until the User revokes the consent given for their receipt.

• In the case of Users registered on the Website, for the entire duration of the contractual relationship derived from the status of registered user and until it ends in accordance with the provisions of the General Conditions applicable at any time.

• In the case of contracting the AI ​​Tutor, for the entire duration of the contractual relationship derived from the provision of the service contracted by the User and until it ends in accordance with the provisions of the General Conditions applicable at any time.

• In the case of the “Work with us” form, for a maximum period of 1 year. After this period, your data may be out of date, so we will proceed to delete all your information.

After the aforementioned periods, the personal data of the Users may be blocked and kept by TURING DREAM to address any potential liabilities arising from the processing and only during the limitation period of said liabilities. After this period, the personal data will be deleted by TURING DREAM.

8. How should I update my personal data?

The User guarantees that the personal data provided to TURING DREAM through this Website are true, correct, current and complete. The User is responsible for informing TURING DREAM of any modification or update of these, by sending a communication to the postal or electronic addresses provided in the section “How do I exercise my rights?” and following the instructions contained therein.

9. What happens if I provide TURING DREAM with data about third parties?

As a general rule, Users are prohibited from providing personal data relating to third parties. However, in the event that the User provides personal data of third parties, they must, prior to including or communicating their data to TURING DREAM, inform said persons of the content of this Privacy Policy. The User guarantees that they have obtained the prior consent of these third parties for the communication of their personal data to TURING DREAM for the purposes set out in this Privacy Policy.

10. How do I exercise my rights?

Users have the right to withdraw their consent for the processing of their data at any time. Users may also exercise their rights to access, rectify, delete and transfer their data, to limit and oppose their processing, and to not be subject to decisions based solely on the automated processing of their data, where applicable, before TURING DREAM.

For such purposes, they may use the following channels, always enclosing a photocopy of their ID or any other document that allows their identity to be verified:

• By letter to the address: C/ Tampico, 9. 28250 Torrelodones, Madrid

• By email to: [email protected]

Finally, if the User is aware of or considers that a fact may constitute a breach of the applicable regulations on data protection, they may file a claim with the Spanish Data Protection Agency.

11. Updates and changes to the Privacy Policy

TURING DREAM reserves the right to make changes to this Privacy Policy. When such changes occur, Users will be notified by means of notices on the Website, by email or through any other appropriate procedure depending on the circumstances.