PRIVACY POLICY
Publication Date: 6 June 2025
This Privacy Policy governs the procedure for processing and ensuring the security of Personal Data during the provision of the Services.
References to the words "you" or "your" (or similar expressions) refer to the User, depending on the context of this Privacy Policy.
References to the words "we," "our," or "us" (or similar expressions) refer to the Service.
The words “he” / “she” and their derivatives in this document may apply to both male and female individuals, depending on the context.
1. DEFINITIONS
1.1 Services means the marketing services provided to Users through the Website, including marketing support for Amazon sellers, such as keyword research, Search Engine Optimization (SEO), conversion rate improvement, management of Amazon PPC campaigns, and Analytics and Reporting. Services also include online trainings such as online lectures, video tutorials (video lessons), webinars, masterclasses, and practical workshops.
1.2 "ALFA GRADUATES" (hereinafter referred to as the "Company" or "ALFA GRADUATES") is ALFA GRADUATES S.L., a company duly incorporated and existing under the laws of the Kingdom of Spain, with its registered office at C/ Aragó, 208-210, 2º-5ª, 08011 Barcelona, Spain, and NIF B75303453. The Company owns and operates an online platform accessible through its Website, which serves as the primary medium for delivering its services to Users.
1.3 Website means the online platform operated by the Company under the domain name https://alfagraduates.com, through which Users can access information about the Company, request marketing and consulting services, and communicate with the Company regarding the scope and terms of cooperation, including inquiries related to online education or online training.
1.4 User means a natural person or legal entity who accesses or uses the Website for the purpose of obtaining information about the Company, requesting Services, initiating cooperation, or communicating with the Company regarding its offerings.
1.5 Personal Data means any information about the User that enables ALFA GRADUATES to identify the User directly or indirectly, including, but not limited to, name, email address, billing information, IP address, and other similar details related to the transaction or access to the Website.
1.6 Statistical Data means anonymized or aggregated information collected and processed by ALFA GRADUATES for purposes such as website analytics, improving service quality, optimizing website functionality, researching user behavior, and generating reports that do not allow direct or indirect identification of any specific User.
1.7 Data is a general term that refers to both Personal Data and Statistical Data.
1.8 User Consent (hereinafter — "Consent") means a voluntary, specific, informed, and unambiguous indication of the User’s agreement to the processing of their Data by ALFA GRADUATES in accordance with this Privacy Policy, given by means of an active confirmation (such as checking a box or clicking a confirmation button).
1.9 Third Party means any natural or legal person, public authority, agency, or other body that is not ALFA GRADUATES or the User but may receive Data or otherwise be involved in legal or technical relations related to the use of the Website or the delivery of digital products.
1.10 GDPR (General Data Protection Regulation) means the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016) on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, which entered into force on 25 May 2018 and applies to all companies processing the personal data of individuals located within the European Economic Area (EEA), regardless of the company's place of registration.
1.11 Cookies mean small text files that are stored on the User’s device when visiting the Website. Cookies are used to recognize the User’s browser, remember preferences, analyze Website traffic and interactions, improve functionality, and enhance the User experience. Cookies may be session-based (deleted when the browser is closed) or persistent (stored for a defined period). The User may manage or disable Cookies through their browser settings, though some Website features may not function properly as a result.
2. GENERAL PROVISION
2.1 The Company processes and stores Data on the basis of the following legal acts:
2.1.1 Compliance with the principles of lawfulness, fairness, and transparency in accordance with the General Data Protection Regulation (GDPR);
2.1.2 Compliance with applicable data protection legislation of the Kingdom of Spain, including the provisions of the Ley Orgánica 3/2018 on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD).
2.2 The Company shall not be held responsible for the processing of Personal or Statistical Data by any Third Parties that are not controlled by or affiliated with the Service.
3. PERSONAL AND STATISTICAL DATA
3.1 The Company may collect the following Personal Data about the User:
3.1.1 full name;
3.1.2 phone number;
3.1.3 email address;
3.1.4 Payment and billing information, solely to receive payment for the providing Services;
3.1.5 physical address.
3.2 The Company may collect Personal and Statistical Data during communication with the User via email or telephone. In such cases, this data will be processed in accordance with this Privacy Policy.
3.3 The User acknowledges and agrees that certain interactions with the Company may involve the processing of Data through third-party social media platforms аnd messengers. Such processing may include communication, advertising optimization, analytics, audience targeting, and remarketing activities carried out through tools provided by these platforms аnd messengers. The Company does not control the independent data processing practices of these platforms and/or messengers. Any processing of Personal Data by such platforms and/or messengers is subject to the respective platform’s privacy policies and legal frameworks. By interacting with the Company through these platforms and messengers, the User consents to the processing of their Data under the applicable terms and practices of these platforms and/or messengers.
3.4 The Company does not collect or process sensitive Personal Data of the User, such as racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, health information, or data concerning a person’s sex life or sexual orientation.
3.5 When using the Website or receiving the Company’s Services, certain User Data may be collected for the purposes of ensuring functionality, security, analytics, and improving the performance of the Website. Such Data may be collected through standard web analytics tools, server logs, or built-in technical mechanisms of the Website. This Data may include, in particular:
3.5.1 the User’s device IP address;
3.5.2 interface language and time zone settings;
3.5.3 technical specifications of the device (such as operating system type, device model, and screen resolution);
3.5.4 country or region of access;
3.5.5 phone numbers used by the User to contact Company representatives;
3.5.6 Cookies and other tracking technologies that provide aggregated analytical information.
3.6 ALFA GRADUATES may collect User Data during interaction with the Website and use of the Services, including but not limited to the following methods:
3.6.1 Directly from the User when submitting service requests, filling out contact forms, responding to questionnaires, or otherwise voluntarily providing information through the Website.
3.6.2 Through the use of Website functionality when navigating service pages, submitting cooperation inquiries, or requesting consultations.
3.6.3 In the course of providing Services when delivering marketing or consulting Services, maintaining communication, issuing invoices, or managing ongoing cooperation.
3.6.4 Automatically through technical tools by means of cookies, server logs, and analytics systems that capture technical data such as IP address, browser type, device information, and session behavior.
3.6.5 Via integration with third-party platforms where applicable, when the User interacts with the Website through external tools (such as embedded calendars, forms, or authentication services) within the scope of authorized permissions.
3.6.6 Through User support channels when the User contacts the Company by email, phone, or other communication means to obtain assistance or clarify service-related matters.
3.6.7 From third-party providers in accordance with applicable law or contractual relationships, including providers of communication, analytics, or payment facilitation services engaged by the Company.
3.7 ALFA GRADUATES is entitled to use the collected Data for the following purposes to:
3.7.1 operate, maintain, and manage the functionality of the Website and Services;
3.7.2 process and manage service requests and ongoing cooperation with Users;
3.7.3 register and authenticate Users, where applicable;
3.7.4 respond to User inquiries, messages, and support communications;
3.7.5 send service-related notifications, updates, and administrative messages;
3.7.6 analyze Website usage, optimize performance, and enhance the user experience;
3.7.7 detect and prevent fraud, abuse, and violations of the Terms of Use;
3.7.8 comply with applicable legal obligations, court orders, or requests from competent authorities;
3.7.9 safeguard the rights, legitimate interests, and security of the Company, its Users, or Third Parties;
3.7.10conduct anonymized marketing activities (subject to consent) and statistical evaluations;
3.7.11 generate internal reports and perform business analytics.
4. TRANSFER OF PERSONAL/STATISTICAL DATA
4.1 The Company may transfer User Data to Third Parties in the context of the provision, support, administration, and legal maintenance of the Services. Such transfer is carried out strictly to the extent necessary to achieve the relevant purpose and on the basis of agreements that ensure an appropriate level of Data protection. In particular, the Data may be transferred to the following categories of recipients:
4.1.1 Payment services and banks — in connection with the processing of payments for the Services, including receipt of payments, issuance of refunds, or verification of financial transactions. In such cases, the processing of Data is carried out in accordance with the privacy policy of the respective payment service provider or banking institution.
4.1.2 Contractors, partners, and employees of the Company — in cases where this is necessary for the provision of professional or technical services to the Service, such as legal, accounting, financial, tax, marketing, logistics, administrative, or IT support. These persons act on the basis of data processing agreements and are obligated to ensure the confidentiality and security of the transferred Data.
4.1.3 Counterparties in connection with corporate events — including within the scope of mergers, acquisitions, reorganizations, financing, asset sales, establishment of joint ventures, or during bankruptcy proceedings. In such cases, the transfer of Data is carried out in accordance with the applicable legal requirements while observing the rights of the User.
4.1.4 Authorized government bodies, courts, law enforcement agencies — in cases where such transfer is mandatory in accordance with legal requirements, in particular on the basis of a court decision, request from an authorized government authority, or other procedures provided by law.
4.2 All Data transfers are carried out in compliance with the principles of data minimization, lawfulness, proportionality, and appropriate protection of Data in accordance with the provisions of this Policy and applicable data processing legislation.
5. USER CONSENT
5.1 The User provides voluntary, informed, specific, and unambiguous Consent to the processing of their Data in accordance with this Privacy Policy by performing any of the following actions:
5.1.1 clicking the “Send,” “Submit,” “Request,” or similar button that involves submitting a form containing Personal or contact data
5.1.2 requesting Services or initiating cooperation through the Website
5.1.3 confirming acknowledgment of this Privacy Policy by checking the appropriate box (checkbox) or using another technical method made available on the Website
5.1.4 continuing to use the Website after being notified of updates to this Privacy Policy
5.1.5 contacting the Company through any communication channel and voluntarily providing Data necessary to process the request
5.2 Consent is granted to the extent necessary to enable communication, provision of Services, and fulfillment of contractual obligations. In the event of withdrawal of Consent, the Company reserves the right to restrict or terminate the User’s access to certain features of the Website, including the ability to request Services or continue ongoing cooperation.
5.3 By giving Consent to the processing of Data, the User confirms that they are aware of the terms of this Privacy Policy and agrees to the following:
5.3.1 their Data may be processed for the purpose of providing Services, facilitating communication, and delivering User support
5.3.2 their Data may be used to generate and deliver Service confirmations, invoices, and administrative notifications
5.3.3 their Data may be transferred to Third Parties (such as payment processors, analytics providers, or hosting services) in cases provided for by this Privacy Policy and applicable law
5.3.4 their Data may be used for Statistical purposes in anonymized form
5.3.5 they are responsible for the accuracy and relevance of the Personal Data provided
5.3.6 in the event of withdrawal of Consent, the Company may be unable to continue providing certain Services that require identification or communication with the User
5.3.7 the processing of Data is carried out by the Company in compliance with the principles of lawfulness, proportionality, purpose limitation, and data minimization
6. STORAGE AND PROTECTION OF PERSONAL/STATISTICAL DATA
6.1 The Company applies all necessary technical, organizational, and legal measures to ensure the security and confidentiality of the Data, as well as to prevent unauthorized access, loss, alteration, or disclosure.
6.2 The Company protects and stores the User’s Data against:
6.2.1 loss;
6.2.2 unlawful use, transfer, disclosure, modification, deletion, and/or destruction.
6.3 The Company has the right to retain the User’s Personal and Statistical Data for a period of 3 (three) years after the termination of the relationship in the following cases:
6.3.1 for statistical accounting purposes;
6.3.2 if required by applicable law;
6.3.3 if necessary for business operations;
6.3.4 for conducting marketing analytics.
7. LEGAL GROUNDS FOR PROCESSING PERSONAL/STATISTICAL DATA
7.1 The processing of User Data by the Company is carried out on one or more of the following legal bases:
7.1.1 User Consent — the User voluntarily, specifically, informedly, and unambiguously provides Consent for the processing of their Data for one or more defined purposes, including the provision of Services, communication, and, where applicable, analytical or marketing purposes (subject to separate Consent);
7.1.2 Compliance with legal obligations — processing is conducted where necessary to comply with applicable laws, including those related to Personal Data protection, accounting, taxation, or consumer protection;
7.1.3 Protection of vital interests — in exceptional circumstances, Data may be processed to protect the life, health, or safety of the User or another individual
7.1.4 Legitimate interest of the Company — where processing is reasonably necessary for the operation of the Website, delivery of Services, fraud prevention, performance improvement, internal analysis, or safeguarding of rights and information security, provided that such interests do not override the fundamental rights and freedoms of the User.
7.2 Where the legal basis for processing the User’s Data is their Consent, the User has the right to withdraw such Consent at any time. To exercise this right, the User may submit a written request to the following email address: alfagraduates@gmail.com Upon withdrawal of Consent, the Company reserves the right to discontinue the provision of Services that technically or operationally require identification or continued interaction with the User.
7.3 The Company undertakes to cease processing of the Data and permanently delete it within thirty (30) calendar days from the date of receipt of the withdrawal request, unless retention is required by law (e.g., for tax or accounting purposes).
8. USER RIGHTS (EEA JURISDICTION)
8.1 This section of the Privacy Policy governs the processing of Data belonging to Users who are residents of the member states of the European Economic Area (EEA), in accordance with the provisions of the General Data Protection Regulation (Regulation (EU) 2016/679, GDPR). The processing of such Users’ Data is carried out on lawful grounds and in compliance with the principles of lawfulness, transparency, proportionality, purpose limitation, and data minimization as set forth by the GDPR.
8.2 When processing personal and statistical data, the Company grants the User the following rights:
8.2.1 Right of access (Article 15 GDPR). The User may contact us directly to access the Data we hold about them, as well as any additional information provided for in Article 15 of the General Data Protection Regulation (GDPR).
8.2.2 Right to erasure (Article 17 GDPR). The User has the right to request the deletion of their Data. In such a case, the Data will be permanently deleted in accordance with Article 17 GDPR, unless legal exceptions apply.
8.2.3 Right to data portability (Article 20 GDPR). The User has the right to receive their Data in a structured, commonly used, and machine-readable format and to transmit it to another controller or request its direct transmission to a third party, where technically feasible, pursuant to Article 20 GDPR.
8.2.4 Right to rectification (Article 16 GDPR). The User has the right at any time to request the update, correction, or completion of inaccurate or incomplete Data in accordance with Article 16 GDPR.
8.2.5 Right to object (Article 21 GDPR). The User has the right to object at any time to the processing of their Data on grounds relating to their particular situation, pursuant to Article 21 GDPR.
8.2.6 Automated individual decision-making, including profiling (Article 22 GDPR). The User has the right not to be subject to a decision based solely on automated processing, including profiling, if such a decision produces legal effects concerning them or similarly significantly affects them, as set forth in Article 22 GDPR.
9. SUBMISSION OF A REQUEST
9.1 The User has the right to submit a request to the Company if they believe that the processing of their Data is carried out in violation of applicable law or the provisions of this Privacy Policy, or in order to exercise their rights as a data subject.
9.2 The request shall be submitted in writing to the Service’s email address:alfagraduates@gmail.com
9.3 The User’s request must include:
9.3.1 a clear statement of the User’s demands to the Service;
9.3.2 a description of the alleged violation or the subject of the request;
9.3.3 sufficient identifying information to verify the User’s identity;
9.3.4 contact details for feedback.
9.4 The Company has the right to refuse to consider the request if:
9.4.1 the request lacks specific demands or is insufficiently formulated;
9.4.2 the User’s identity cannot be verified or is doubtful;
9.4.3 the information provided is inaccurate or incomplete.
9.5 If it is not possible to identify the User or verify the relevance of the Data, the Company has the right to request clarifications or additional information. Upon receiving a response, the User must submit a new or corrected request.
9.6 The Company is obligated to provide a response or fulfill the request within 30 calendar days from the date of its proper receipt.
10. LIABILITY
10.1 The Company informs the User that Personal and Statistical Data may be used for the proper functioning of the Website and the provision of Services. If the User does not agree to such processing, they should not use the Website or interact with the Services.
10.2 The Company shall not be liable for any consequences arising from the provision of false, inaccurate, or incomplete Personal or Statistical Data by the User, including cases where such Data prevents the proper performance of the Services.
10.3 The Company is not responsible for any damages, losses, or violations of User rights resulting from the use of Data by Third Parties without the Company’s knowledge, including external services with which the User interacts (such as payment systems, analytics providers, or communication platforms). In such cases, the processing of Data is governed by the privacy policies of the respective Third Parties.
10.4 The Website may contain links to Third-Party websites or services. The privacy practices of such resources are not covered by this Privacy Policy, and the Company disclaims responsibility for the collection, storage, or use of User Data by such websites or services.
10.5 The Company shall not be held liable for:
10.5.1 loss, damage, or unauthorized disclosure of Data resulting from illegal actions by Third Parties, cyberattacks, system vulnerabilities, or technical failures beyond the Company’s control;
10.5.2 inability to provide or the improper provision of Services due to the User’s submission of false, incomplete, or outdated Data;
10.5.3 technical issues, interruptions, or errors in the operation of the Website not caused directly by the Company;
10.5.4 the User’s use of the Website or Services for unlawful purposes or in violation of this Privacy Policy or the Terms of Use;
10.5.5 any consequences arising from the User’s submission of false, misleading, or inaccurate information.
10.6 The User is solely responsible for:
10.6.1 the accuracy, completeness, and relevance of all information and Data they provide via the Website;
10.6.2 maintaining the confidentiality of their account access credentials (such as email, passwords, or access links);
10.6.3 all actions taken using their account or communication identifiers, unless they can demonstrate the absence of their fault.
10.7 While the Company applies all reasonable technical and organizational measures to protect Data, transmission of information over the Internet is never entirely secure. The User acknowledges and accepts the inherent risks of transmitting Data online and assumes responsibility for such transmission.
11. COOKIES
11.1 Cookies do not transmit viruses or malware to your device, as the data contained in Cookies is not altered during transmission and does not affect your device’s performance. Cookies function similarly to logs — recording User activity and storing information about the current state of interaction, which is updated each time the Website is visited.
11.2 When providing Services, the Company may use the following types of Cookies:
11.2.1 Session Cookies (temporary) — exist only during the current session of Website use and are typically deleted by the browser once the window is closed.
11.2.2 Persistent Cookies — stored for a predetermined period of time and sent to the server each time the relevant website is visited again.
11.2.3 Third-Party Cookies — used when a page contains content from external resources (such as embedded links or widgets) and may track browsing history across different websites.
11.2.4 Web Analytics Cookies — used to analyze User behavior when navigating the Website.
11.3 The Company uses Cookies for the following purposes:
11.3.1 User authentication and identification;
11.3.2 web analytics;
11.3.3 marketing analytics;
11.3.4 analysis of User preferences and behavior;
11.3.5 storing personal settings and preferences;
11.3.6 session tracking;
11.3.7 storing statistical data;
11.3.8 analyzing Website performance and effectiveness.
11.4 In most cases, browsers are set by default to allow the storage of Cookies on the User’s device. However, the User may change these settings at any time — for example, to block the automatic storage of Cookies or to receive notifications about their use. Detailed information about managing Cookies is available in the settings of the specific web browser used.
12. AGE POLICY
12.1 The Company provides Services only to individuals who have reached the age of majority or the age of consent in accordance with the legislation of the jurisdiction in which the User resides. The Company does not process Personal or Statistical Data of individuals who have not reached such age.
12.2 The Company reserves the right, without prior notice and without any legal consequences for itself, to:
12.2.1 terminate the provision of Services to an individual who has not reached the established age;
12.2.2 delete all Personal and Statistical Data of such an individual.
12.3 If you become aware of the use of the Company by a person who has not reached the age of majority or the age of consent according to their jurisdiction, please notify us by contacting our support team at: alfagraduates@gmail.com
13. CHANGES TO THE PRIVACY POLICY
13.1The Company has the right to periodically make changes to this Privacy Policy in order to improve security measures, clarify the conditions for Data processing, and ensure compliance with the applicable legislation of the Kingdom of Spain and the European Union, including the General Data Protection Regulation (GDPR).
13.2 The User is responsible for independently reviewing updates to the Privacy Policy. Continued use of the Website after changes have been made shall constitute confirmation of acknowledgment and acceptance of the updated terms. The Company is not liable for any consequences resulting from the User’s failure to review the current version of the document.
13.3 The date of the last update to the Privacy Policy is indicated in the “Last Updated” field at the top of the document.
13.4 Electronic copies of the Privacy Policy published in the Website are official, valid, legally binding, and applicable during the use of the Website.
14. CONTACTS
14.1 The User has the right to contact the Service’s support team at the following email address: alfagraduates@gmail.com to exercise their rights under this Privacy Policy, in the event of a violation, or to ask a question.
