PRIVACY AND DATA PROTECTION POLICY
I. INTRODUCTION
The SALWARE Foundation, responsible for the educational platform “Salware,” declares its firm commitment to the protection of the personal data of its users, especially minors, strictly complying with current legislation on privacy, information security, and digital rights.
This document regulates the use of the Salware platform, whether accessed from its web version (PWA) or its native mobile application.
II. APPLICABLE REGULATIONS
This privacy policy is adapted to current Spanish and European regulations, specifically:
- Regulation (EU) 2016/679 (GDPR)
- Organic Law 3/2018 (LOPD-GDD)
- Royal Decree 1720/2007
- Law 34/2002 (LSSI-CE)
III. IDENTITY OF THE DATA CONTROLLER
Name: Fundación Salware
NIF: G02863587
Address: Calle Cuesta Blanca 119, 28108 Alcobendas, Madrid
Telephone: 623569819
Email: fundacion@salware.com | info@salware.com
Representative: Ramón Antonio García Salmerón
DPO: alejandro.espinosa@salware.com
IV. PRINCIPLES OF PROCESSING
Salware applies the principles of Article 5 of the GDPR: lawfulness, fairness and transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity and confidentiality, and accountability.
In interactions that require automatic processing (for example, pedagogical analysis, automated response, or classification), Salware uses anonymous or coded identifiers. AI does not have access to personal data such as the student’s name, surname, or contact information. The association between the code and the user remains in the hands of parents or guardians, in the case of minors, or the user themselves, in the case of adults.
V. TECHNICAL AND ORGANIZATIONAL MEASURES
- Encryption and secure storage
- Limited and auditable access
- Registration and traceability of actions
- Reinforced authentication
- Servers in the EU
- SSL Certificate
- Cybersecurity audits
VI. CATEGORIES AND PURPOSE OF DATA
Identifying, academic, and platform usage data are collected, including:
- Name, surname, age, profile picture, educational center, teachers, location
- User-generated educational multimedia content
- Participation in private social networks or AI systems under pedagogical control
Purposes:
- Active learning and management of academic activity
- Verification of teacher identity with educational centers
- Limited commercial use for personalization and service improvements
- Possibility of creating permanent educational profiles using blockchain
VII. PROCESSING OF MINORS’ DATA
Only those over 14 years of age can consent to the processing of their data. For minors, registration must be carried out by parents or guardians, who link their account with that of the minor, thus granting consent.
Consent for educational video calls: By accepting these policies, the use of video calls between minors and other users within the secure environment of the platform is authorized, exclusively for educational purposes.
VIII. PRIVACY ACCORDING TO USER ROLE
- The educational center’s management exclusively accesses aggregated data of general pedagogical interest.
- Teachers access the academic data of students under their direct responsibility.
- Parents and legal guardians access the detailed information of their children.
- The rest of the information remains under the custody of the Foundation and is not shared without authorization.
IX. DATA RETENTION PERIODS
Data is kept until the User requests its deletion. The User will be informed of the specific period or the criteria used to determine it.
X. LEGAL BASIS
The processing is based on express consent, which can be withdrawn at any time with equal ease. In mandatory forms, it will be indicated when the data is essential.
XI. RECIPIENTS
- Salware Education S.L. (technological support)
- Notareye (certification of qualifications)
Possible international transfers will be communicated to the User at the appropriate time. - OpenAI (Artificial Intelligence), exclusively for educational and service improvement purposes, with the aim of providing students, parents, centers, and teachers with advanced tools that facilitate the detection, analysis, and understanding of the academic, emotional, or behavioral development of students, always guaranteeing compliance with current data protection regulations.
XII. USER RIGHTS
Users can exercise the:
- Right of access, rectification, erasure, objection, restriction of processing, data portability, and the right not to be subject to automated individual decision-making
How to exercise rights: Send a request to:
- Email: fundacion@salware.com
- Postal address: Calle Cuesta Blanca 119, 28108 Alcobendas, Madrid
The request must include your name, surname, ID document number (DNI), specific request, address, date, and signature.
XIII. CONFIDENTIALITY AND RESPONSIBILITY
The data will be treated confidentially. The Controller undertakes to guarantee legal or contractual confidentiality on the part of employees or third parties with authorized access.
The Foundation is not responsible for illegal access by third parties or for content generated by external users.
XIV. USE OF DEVICES BY MINORS
Parents acknowledge the risks of using connected devices. They undertake to supervise and prevent the misuse of other applications outside the platform (e.g., TikTok, Instagram, etc.). The Foundation rejects the abuse of screens for unsupervised leisure and recommends a balanced use with healthy habits.
XV. LINKS TO THIRD PARTIES
The site may contain links to external sites with their own privacy policies. The Foundation is not responsible for these contents or their practices.
XVI. COMPLAINTS
In the event of any conflict, the User may contact the Spanish Data Protection Agency: www.agpd.es
XVII. ACCEPTANCE AND CHANGES
The use of the Website implies acceptance of this document. Salware reserves the right to modify this document at any time and will notify users of changes upon entering the platform, where they can consult the changes and reject them if they do not agree. Notifications will not be made by email, SMS, or WhatsApp. Any change will take effect from the moment of the User’s acceptance.