Who is responsible for processing your personal data?

We DJASOME will be responsible for the personal data obtained from you when you visit our websites, by telephone or email, entered on any of our printed forms, as a result of our commercial relations with you, or derived from your browsing habits.

David J Anderson School of Management Europe S.L., is a private company with fiscal identification number B95941357 and registered address in Calle Alameda Urquijo 2, planta 6,48008 Bilbao (Spain) info@djaa.com

When do we process your personal data?

We process your personal data in the following cases:

• You register for a course with David J Anderson School of Management;

• You download content directly from our websites or apps;

• You subscribe to our newsletters;

• You inquire or contact directly with DJASOME regarding our courses, programs, products, or services;

• You participate by submitting content in our blogs, workspaces, forums, or webinars;

• You participate in our surveys, marketing researches and studies;

• You visit our websites or interact with our marketing communications and you are tracked by cookies or similar technologies.

For what purpose do we process your personal data?

We process your personal data for the following purposes:

• To manage the registration to the courses offered by DJASOME;
• To process downloads of our contents from our websites or apps;
• To manage the subscription to our newsletter;
• To send you personalized commercial communications about the courses offered by DJASOME;
• To publish your comment and content in our blogs, workspaces, forums, or webinars;
• To carry out marketing researches and studies for statistical purposes and to produce anonymous aggregate data;
• To create a ‘commercial profile” based on the information you provide and other information derived from your browsing habits for purpose of offering you personalized information about our courses, events, products, and services;
• To submit your alumni data to Kanban University for the purpose of issuing credentials and certificates.

How long will we keep your personal data?

We will retain the personal data that you provide to us where you purchase our products or services as long as there is a mutual business relationship or commercial interest and you do not request their deletion. Afterwards, we will retain your personal data where we have an ongoing legitimate business need, complying with legal retention periods, enforcing contracts, or resolving disputes.

If you have chosen to receive personalized marketing communications from us, we will retain information about your marketing preferences derived from the information you provide to us and from cookies and other tracking technologies as long as you do not request their deletion.

If you have subscribed to our newsletter your data will be retained until you request their deletion. You can unsubscribe at any time through a link that you will find in the footer of our emails.

We will retain your alumni data until you request their deletion. The deletion of your alumni data will result in the permanent cancellation of your personal information including your KU class certificates and credentials. After the deletion of your information, you would be able to access your KU certificates and credentials exclusively through Kanban University.

If you want further information about our retention periods, please contact us at the following email address: David J Anderson School of Management info@djaa.com

What are the legal basis for processing your personal data?

We collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you.

The legal basis for collecting and using your data will depend on the personal information concerned and the specific purposes on which we collect it.

Based on the contractual relationship with you:
• When you register for our courses and events;
• When you sign up in our websites and apps for access to licensed content;
• When you purchase our products and services.

Based on your consent:
• When you subscribe to our newsletter;
• When you accept to receive personalized information about our courses and events;
• When you accept to receive personalized information about our products and services;
• When you accept to participate in surveys, marketing researches, and studies;
• When you accept that we submit your alumni data to Kanban University for the purpose of issuing credentials and certificates;
• When you inquire us by email, telephone, or contact form regarding our courses, programs, products, or services;
• When you post your comment and content in our blogs, workspaces, forums, or webinars; and
• When you accept the use of the cookies;

Based on our legitimate business interest:
• To carry out analysis and marketing research about our alumni, clients, subscribers, and users; and
• To keep our clients, students, and alumni informed about our courses, events, products, and services that better suit their needs and preferences.

Based on the compliance with our legal obligations, as applicable, we may use your personal information for management and administrative purposes.

Who do we share your personal data with?

In general, we do not share your personal data with third parties, except for the purposes of legitimate business interests, compliance with a legal obligation, performance of a task carried out in the public interest, or situations similar to these.

We may disclose your personal data to the following third parties:
• Training platforms to deliver class materials to our students and manage the courses;
• Payment processing providers to manage the purchases of our courses, products, and services;
• Kanban University to issue credentials and certificates for our alumni;
• Service providers to provide general business services such as financial and accounting services, hosting services, customer support, and marketing assistance;

These service providers are prohibited from using your personal data except for specific services purposes, and they are required to maintain the confidentiality of your personal information.

Who do we transfer your personal data with?

We will send your name, surname, and email address to Kanban University to create your personal alumni account and send you certificates of course completion.

Your alumni data will be processed by an organization established outside the European Union, Kanban University, with the registered office in 1570 W Armory Way Ste 101, #188, Seattle, WA 98119 USA

According to the GDPR, sharing personal data of EU citizens to the United States is considered an international transfer.

In compliance with the GDPR, we will transfer your personal data to Kanban University only if we have obtained your explicit consent to share your student information.

Kanban University will create automatically your KU Alumni profile that will be displayed in the KU Alumni directory (https://edu.kanban.university/alumni).

Your KU Alumni profile page, publicly viewable by anyone, will display the following information:
• Your full name, as submitted by the class instructor;
• The class(es) you attended, including class name, class type, date, location, instructor;
• Your digital class certificate of completion;
• Any additional information that you have added including a bio or photo.

To manage your personal data, including the request to change your Alumni profile to “private” status, please contact Kanban University by email to privacy@kanban.university. For more information review the Privacy Policy of Kanban University (https://resources.kanban.university/project/privacy).

We may share your personal data with non-EU third-party processors only where it is necessary for the provision of the training. Some of the third parties may be based on countries that may not have equivalent privacy and data protection laws to the European Union. We will make use of the appropriate safeguards for the transfer of your personal data.

Which are your rights when you provide us your data?

Anybody has the right to obtain confirmation as to whether or not, at DJASOME, we are processing personal data that concerns them.

Moreover, you have the right to access your personal data, as well as to request the rectification of incorrect data and, if applicable, its deletion or withdrawal when, among other reasons, the data are no longer necessary for the purposes for which they were gathered.

Under certain circumstances, you can request that restrictions be applied to the processing of your data. In such cases, we will only keep the data for exercising or defending against any possible claims.

Under certain circumstances and for reasons related to your specific situation, you can object to the processing of your data. In such cases we will stop processing the data, except for cases in which we are legally obliged to do so or to exercise or defend against any possible claims.

Under certain circumstances, you have the right to receive your personal data in a structured, commonly used, and machine-readable format, in order to be transmitted to another data controller.

You can exercise your rights and withdraw your consent, if applicable, at any time by contacting us at the following email address: David J Anderson School of Management info@djaa.com.

We will respond to any request for the exercise of the data protection rights as soon as possible and, in principle, not later than one month. This period may be extended where necessary.

You have the right to lodge a complaint with the Spanish Data Protection Supervisor (https://www.aepd.es) if you consider that the processing of your personal data does not comply with the GDPR regulations.