Privacy Policy

WEBSITE PRIVACY POLICY

https://www.cmiuniversal.com

I. PRIVACY AND DATA PROTECTION POLICY

In compliance with current legislation, CMI Business School (hereinafter, also Website) undertakes to adopt the necessary technical and organizational measures, according to the appropriate security level for the risk of the data collected.

Laws incorporated into this privacy policy

This privacy policy is adapted to current Spanish and European regulations regarding the protection of personal data on the internet. Specifically, it complies with the following regulations:

• Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR).
• Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights (LOPD-GDD).
• Royal Decree 1720/2007, of December 21, approving the Regulation for the development of Organic Law 15/1999, of December 13, on Personal Data Protection (RDLOPD).
• Law 34/2002, of July 11, on Information Society Services and Electronic Commerce (LSSI-CE).

Identity of the controller of personal data

The controller of the personal data collected on CMI Business School is: Conscious Management Institute S.A. (CMI), with NIF/CIF: A87876587, whose representative is: Conscious Management Institute S.A. (CMI) (hereinafter, the Data Controller). Their contact details are as follows:

Address: Gran Vía de San Francisco, 15 28005 – Madrid – Spain

Contact phone number: 91 172 43 58

Contact email: cmi@cmi.es

Personal Data Register

In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by CMI Business School, through the forms on its pages, will be incorporated into and processed in our file in order to facilitate, expedite, and fulfill the commitments established between CMI Business School and the User or the maintenance of the relationship established in the forms filled out by the User, or to address a request or query from the User. Likewise, in accordance with the provisions of the GDPR and the LOPD-GDD, unless the exception provided for in Article 30.5 of the GDPR applies, a record of processing activities is maintained, specifying, according to their purposes, the processing activities carried out and the other circumstances established in the GDPR.

Principles applicable to the processing of personal data

The processing of the User’s personal data will be subject to the following principles set forth in Article 5 of the GDPR and Article 4 et seq. of Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights:

• Principle of lawfulness, fairness, and transparency: the User’s consent will be required at all times, with completely transparent information about the purposes for which personal data is collected.
• Principle of purpose limitation: personal data will be collected for specified, explicit, and legitimate purposes.
• Principle of data minimization: the personal data collected will be strictly necessary in relation to the purposes for which they are processed.
• Principle of accuracy: personal data must be accurate and kept up to date at all times.
• Principle of storage limitation: personal data will only be kept in a form that permits identification of the User for no longer than is necessary for the purposes for which they are processed.
• Principle of integrity and confidentiality: personal data will be processed in a manner that ensures their security and confidentiality.
• Principle of proactive accountability: the Data Controller will be responsible for ensuring that the above principles are complied with.

Categories of personal data

The categories of data processed at CMI Business School are solely identifying data. In no case are special categories of personal data, as defined in Article 9 of the GDPR, processed.

The categories of data processed at CMI Business School include both identifying data and special categories of personal data as defined in Article 9 of the GDPR.

Special categories of personal data are understood to be those revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

For the processing of special categories of personal data, the User’s explicit consent for one or more specific purposes will always be necessary.

Legal basis for the processing of personal data

The legal basis for the processing of personal data is consent. CMI Business School undertakes to obtain the User’s express and verifiable consent for the processing of their personal data for one or more specific purposes.

The User will have the right to withdraw their consent at any time. Withdrawing consent will be as easy as giving it. As a general rule, the withdrawal of consent will not condition the use of the Website.

On occasions when the User must or may provide their data through forms to make inquiries, request information, or for reasons related to the content of the Website, they will be informed if the completion of any of them is mandatory because they are essential for the correct execution of the operation performed.

Purposes of personal data processing

Personal data is collected and managed by CMI Business School in order to facilitate, expedite, and fulfill the commitments established between the Website and the User or the maintenance of the relationship established in the forms filled out by the latter, or to address a request or query.

Likewise, the data may be used for commercial personalization, operational, and statistical purposes, and activities inherent to the corporate purpose of CMI Business School, as well as for data extraction, storage, and marketing studies to adapt the Content offered to the User, and to improve the quality, operation, and navigation of the Website.

At the time personal data is obtained, the User will be informed about the specific purpose or purposes of the processing for which the personal data will be used; that is, the use or uses that will be made of the collected information.

Personal data retention periods

Personal data will only be retained for the minimum time necessary for the purposes of its processing and, in any case, only for the following period: 12 months, or until the User requests its deletion.

At the time personal data is obtained, the User will be informed about the period for which the personal data will be stored or, where that is not possible, the criteria used to determine that period.

Recipients of personal data

The User’s personal data will not be shared with third parties.

In any case, at the time personal data is obtained, the User will be informed about the recipients or categories of recipients of the personal data.

The User’s personal data will be shared with the following recipients or categories of recipients:

Google Analytics

In the event that the Data Controller intends to transfer personal data to a third country or international organization, at the time personal data is obtained, the User will be informed about the third country or international organization to which the data is intended to be transferred, as well as the existence or absence of an adequacy decision by the Commission.

Personal data of minors

In compliance with Articles 8 of the GDPR and 7 of Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights, only individuals over 14 years of age may give their consent for the lawful processing of their personal data by CMI Business School. If the individual is under 14 years of age, the consent of parents or guardians will be necessary for processing, and this will only be considered lawful to the extent that they have authorized it.

Secrecy and security of personal data

CMI Business School undertakes to adopt the necessary technical and organizational measures, according to the appropriate security level for the risk of the data collected, to guarantee the security of personal data and prevent the accidental or unlawful destruction, loss, or alteration of personal data transmitted, stored, or otherwise processed, or unauthorized communication or access to such data.

The Website has an SSL (Secure Socket Layer) certificate, which ensures that personal data is transmitted securely and confidentially, as the transmission of data between the server and the User, and vice versa, is fully encrypted.

However, because CMI Business School cannot guarantee the impregnability of the internet or the total absence of hackers or others who fraudulently access personal data, the Data Controller undertakes to notify the User without undue delay when a personal data security breach occurs that is likely to result in a high risk to the rights and freedoms of natural persons. In accordance with Article 4 of the GDPR, a personal data security breach is understood as any security breach that causes the accidental or unlawful destruction, loss, or alteration of personal data transmitted, stored, or otherwise processed, or unauthorized communication or access to such data.

Personal data will be treated as confidential by the Data Controller, who undertakes to inform and ensure, through a legal or contractual obligation, that such confidentiality is respected by its employees, associates, and any person to whom the information is made accessible.

Rights derived from the processing of personal data

The User has the following rights concerning CMI Business School and may, therefore, exercise against the Data Controller the following rights recognized in the GDPR and Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights:

• Right of access: This is the User’s right to obtain confirmation as to whether or not CMI Business School is processing their personal data and, if so, to obtain information about their specific personal data and the processing that CMI Business School has carried out or is carrying out, as well as, among other things, available information about the origin of said data and the recipients of communications made or planned for them.
• Right to rectification: This is the User’s right to have their personal data modified if it is inaccurate or, taking into account the purposes of the processing, incomplete.
• Right to erasure (“the right to be forgotten”): This is the User’s right, provided that current legislation does not establish otherwise, to obtain the erasure of their personal data when they are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn their consent to the processing and there is no other legal basis for it; the User objects to the processing and there is no other legitimate reason to continue with it; the personal data has been unlawfully processed; the personal data must be erased in compliance with a legal obligation; or the personal data has been obtained as a result of a direct offer of information society services to a minor under 14 years of age. In addition to erasing the data, the Data Controller, taking into account available technology and the cost of its implementation, must take reasonable steps to inform controllers who are processing the personal data of the data subject’s request for the erasure of any links to that personal data.
• Right to restriction of processing: This is the User’s right to restrict the processing of their personal data. The User has the right to obtain restriction of processing when they contest the accuracy of their personal data; the processing is unlawful; the Data Controller no longer needs the personal data for the purposes of the processing, but the User requires them for the establishment, exercise, or defense of legal claims; and when the User has objected to processing.
• Right to data portability: In cases where processing is carried out by automated means, the User will have the right to receive their personal data from the Data Controller in a structured, commonly used, and machine-readable format, and to transmit them to another data controller. Whenever technically feasible, the Data Controller will directly transmit the data to that other controller.
• Right to object: This is the User’s right to object to the processing of their personal data or to have the processing of their personal data by CMI Business School ceased.
• Right not to be subject to a decision based solely on automated processing, including profiling: This is the User’s right not to be subject to an individualized decision based solely on the automated processing of their personal data, including profiling, unless current legislation establishes otherwise.

Thus, the User may exercise their rights by written communication addressed to the Data Controller with the reference “RGPD-https://www.cmiuniversal.com”, specifying:

• User’s name, surname, and copy of ID. In cases where representation is admitted, identification by the same means of the person representing the User will also be necessary, as well as the document proving the representation. The photocopy of the ID may be replaced by any other legally valid means of identification.
• Request with the specific reasons for the request or information to which access is desired.
• Address for notification purposes.
• Date and signature of the applicant.
• Any document supporting the request made.

This request and any other attached document may be sent to the following address and/or email:

Postal address: Gran Vía de San Francisco, 15 28005 – Madrid – Spain

Email: cmi@cmi.es

Links to third-party websites

The Website may include hyperlinks or links that allow access to third-party websites other than CMI Business School, and which are therefore not operated by CMI Business School. The owners of such websites will have their own data protection policies, being themselves, in each case, responsible for their own files and their own privacy practices.

Complaints to the supervisory authority

In the event that the User considers that there is a problem or infringement of current regulations in the way their personal data is being processed, they will have the right to effective judicial protection and to file a complaint with a supervisory authority, in particular, in the State where they have their habitual residence, place of work, or place of the alleged infringement. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (https://www.aepd.es/).

II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

It is necessary for the User to have read and agree with the conditions on personal data protection contained in this Privacy Policy, as well as to accept the processing of their personal data so that the Data Controller can proceed with it in the manner, for the periods, and for the purposes indicated. The use of the Website will imply acceptance of its Privacy Policy.

CMI Business School reserves the right to modify its Privacy Policy, according to its own criteria, or motivated by a legislative, jurisprudential, or doctrinal change by the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. The User is recommended to consult this page periodically to be aware of the latest changes or updates.

This Privacy Policy was updated to adapt to Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR) and Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights.