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[DRAFT] This is a placeholder pending legal review. It is NOT a binding document.

UPDATED TBD

Privacy Policy

[TBD-LAWYER] Intro to the Privacy Policy: identity of the data controller, GDPR legal basis, DPO contact, and a summary of what data is collected and why.

Data we collect

[TBD-LAWYER] Exhaustive list of categories of personal data collected: identification, contact, payment (via Stripe), app usage, approximate location, instructor profile photo, professional certification.

Purpose and legal basis

[TBD-LAWYER] Purpose for each category (contract performance, legal obligations, legitimate interest, consent), GDPR legal basis (Art. 6), and retention periods.

Sharing with third parties

[TBD-LAWYER] Processor list: Supabase (hosting + DB), Stripe (payments), Resend (email), GA4 (analytics). DPAs signed, international transfers (US with SCCs), DAC7 reporting to the Spanish tax authority.

Your GDPR rights

[TBD-LAWYER] Data-subject rights: access, rectification, erasure, objection, restriction, portability. Procedure (email privacy@…). Right to lodge a complaint with the AEPD.

Cookies and analytics

[TBD-LAWYER] Strictly necessary cookies (session, locale), analytics cookies (GA4), opt-out, and reference to the cookies policy (TBD if split into its own page in v1.2).

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