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Privacy Policy

Sprachzentrum Buenos Aires Online

Last updated: October 2026

1. Data Controller

Sprachzentrum Buenos Aires Online

  • Address: Bulnes 644, C1176ABL Buenos Aires, Argentina
  • Phone: +54 9 3546 53 2993
  • Email: [email protected]
  • CUIT (tax ID): 27-28985359-1
  • Legal representative: Bárbara Pereyra

Note: This policy complies with Argentina's Personal Data Protection Act (Ley 25.326) and the General Data Protection Regulation (GDPR) of the European Union.

2. Data Protection Officer (for students in the EU)

3. Purposes of Data Processing

3.1 Educational and academic services

  • Legal basis Argentina: Consent of the data subject (Art. 5 Ley 25.326)
  • Legal basis GDPR: Performance of a contract (Art. 6(1)(b) GDPR)
  • Data processed:
    • Identification data (first name, last name, ID or passport number, date of birth)
    • Contact data (address, phone, email)
    • Academic information (language level, progress, grades)
    • Emergency data (emergency contact)
  • Specific purposes:
    • Registration and enrolment in courses (regular, intensive, workshops)
    • Monitoring academic progress on digital platforms
    • Issuing ÖSD certificates and diplomas
    • Academic communication with students and companies
    • Administration of on-site ÖSD examinations
  • Types of courses:
    • Regular courses: 12 sessions of 2.5 hours (extensive once a week, intensive 2-4 times a week)
    • Workshops: 5-12 sessions (once a week)
    • Corporate courses for companies
    • Preparation for ÖSD examinations
  • Retention: For the duration of the academic relationship and 10 years afterwards for certification purposes

3.2 Administration and invoicing

  • Legal basis Argentina: Legal obligation and consent
  • Legal basis GDPR: Legal obligation (Art. 6(1)(c)) and performance of a contract (Art. 6(1)(b))
  • Data processed: Financial data, invoicing information, payment history
  • Retention: According to statutory accounting periods (10 years in Argentina)

3.3 Institutional communications

  • Legal basis Argentina: Consent of the data subject
  • Legal basis GDPR: Consent (Art. 6(1)(a)) or legitimate interest (Art. 6(1)(f))
  • Data processed: Contact data, communication preferences
  • Purpose: Information about courses, events and cultural activities
  • Retention: Until consent is withdrawn

3.4 Security and video surveillance

  • Legal basis Argentina: Legitimate interest and legal compliance
  • Legal basis GDPR: Legitimate interest (Art. 6(1)(f))
  • Data processed: Security camera images
  • Retention: 30 days from recording

3.5 Digital learning platforms

  • Legal basis: Performance of the educational contract
  • Platforms used:
    • Moodle: management of courses, materials and assessments
    • Adobe Connect: live virtual classes
    • Google Workspace for Education: collaboration tools and documents
  • Data processed: Access data, progress on the platforms, activities completed, grades
  • Security: Access through encrypted credentials and secure authentication
  • Retention: For the duration of the course and 2 additional years
  • Features using artificial intelligence: The Moodle platform includes support features that use artificial intelligence, described in section 3.9

3.6 Recordings of classes and learning sessions

  • Legal basis Argentina: Express consent of the data subject (Art. 5 Ley 25.326)
  • Legal basis GDPR: Explicit consent (Art. 6(1)(a) GDPR)
  • Platform: Adobe Connect Server
  • Data processed:
    • Audio and video recordings of classes
    • Voice and image of students and teachers
    • Interactions during class (chat, contributions)
    • Materials shared during the session
  • Specific purposes:
    • Review of the class content by students
    • Catching up on classes missed due to excused absences
    • Evaluating and improving teaching quality
    • Training and supervision of teaching staff
  • Retention: 3 months after the end of the course
  • Access: Only students of the specific course and authorised teaching staff
  • Location: Adobe Connect servers (United States) with appropriate security safeguards

3.6.1 Specific Consent for Class Recordings

Mandatory prior information
Before each recording, participants are informed:

  • That the class will be recorded
  • Of the educational purpose of the recording
  • Of the retention period (3 months)
  • Of the rights of access, rectification and erasure
  • Of the possibility of objecting to the recording

Forms of consent

  • Active consent: express statement before the recording starts
  • Consent by participation: remaining in the class after the recording notice
  • Right to object: possibility of leaving the session or asking not to be recorded

Students who are minors

  • Parental consent required for recordings that include minors
  • Specific authorisation form signed by parents or guardians
  • Clear information about the educational use of the recordings

Specific rights regarding recordings

  • Access: request a copy of the recordings in which you appear
  • Rectification: not applicable given the nature of recordings
  • Erasure: early deletion upon justified request
  • Objection: right not to be included in future recordings

Specific security measures

  • Access through unique credentials for each student
  • Downloading and redistribution prohibited
  • Access logs to monitor use
  • Automatic deletion after 3 months

3.7 Corporate services

  • Legal basis Argentina: Performance of a commercial contract
  • Legal basis GDPR: Performance of a contract (Art. 6(1)(b) GDPR)
  • Data processed:
    • Contact data of participating employees
    • Information about the contracting company
    • Progress and assessments in corporate courses
  • Purpose: Language training for company staff
  • Retention: For the term of the contract and 5 years afterwards

3.8 Website and online shop

  • Legal basis: Consent and performance of a contract
  • Data processed:
    • Browsing data (Google Analytics)
    • Purchase and invoicing information
    • Contact form data
    • Tracking cookies (Facebook Pixel)
  • Purpose:
    • Processing online purchases
    • Analysis of website behaviour
    • Targeted marketing
    • Responding to enquiries
  • Retention: According to the specific purpose and the consent given

3.9 Features using artificial intelligence

The course platform includes learning support features that use artificial intelligence (AI) services from external providers.

  • Legal basis Argentina: Consent of the data subject (Art. 5 Ley 25.326); for the international transfer, express consent (Art. 12 Ley 25.326 and Decreto 1558/2001)
  • Legal basis GDPR: Consent (Art. 6(1)(a) GDPR)
  • Features:
    • DAIna, course assistant: answers questions about the course, its activities and grammar, and recommends next steps
    • Writing trainer: automatic correction and assessment of texts, which the teaching team can review and change
    • Conversations and speaking practice with AI: practice dialogues by text or voice, with automatic feedback
    • Exam simulations: automatic assessment of the writing and speaking parts
  • Data processed:
    • Questions, texts and messages you write in these features
    • Voice recordings from speaking practice and their transcription
    • Your level, your progress in the course and the results of your activities
    • The rating you give to answers and conversations, and the optional comment
    • Learning profile: language topics in which errors recur in your texts (for example, verb position or spelling). The profile does not contain your texts
  • Purpose:
    • To give immediate help adapted to your level and to the activity you are working on
    • To correct and assess texts and speaking practice as learning support
    • To adapt examples and recommendations based on the learning profile. The profile is not used as a grade or as a diagnosis
    • To evaluate and improve the quality of these features
  • Providers (data processors):
    • Anthropic (United States): assistant answers, correction and assessment of texts
    • OpenAI (United States): transcription of voice recordings and speaking practice
    • Google (United States): speech recognition and speech synthesis
    • ElevenLabs (United States): speech synthesis
    • [VERIFY AND COMPLETE: other speech services used by the speaking practice activities, for example Poodll]
  • Data that is not sent: We do not include your name, your email address or other identification data in what is sent to these providers [VERIFY FOR ALL FEATURES]. Texts and audio may contain whatever information you include yourself; we recommend that you do not enter confidential data
  • Use by the providers: The providers process the data only to deliver the requested service [VERIFY IN EACH PROVIDER'S TERMS: retention period and use for model training]
  • Automatic assessment and human review: Automatic corrections and assessments are a learning aid and may contain errors. Where an automatic assessment affects a grade or a certificate, you may request a review by a teacher. No decisions with legal effects are taken solely on the basis of automated processing
  • Voluntary use: Use of the DAIna assistant and of the conversation practice is voluntary. If you do not want your texts to be assessed automatically, you may request correction by a teacher
  • Access: Questions to the assistant and its answers may be viewed by authorised staff in order to improve the service. Corrections and assessments are visible to you and to the teaching team of your course. The learning profile is only used automatically to adapt the help; the teaching team does not view it
  • Retention: Questions to the assistant, ratings and learning profile: 180 days. Texts, corrections and assessments: as set out in section 9.1
  • Your rights: You may request access to, rectification of and erasure of this data, including the learning profile, and withdraw your consent at any time through the channels given in section 7.3

4. Special Categories of Data

Where special data is processed (health data for educational adjustments):

  • Legal basis Argentina: Express consent (Art. 7 Ley 25.326)
  • Legal basis GDPR: Explicit consent (Art. 9(2)(a) GDPR)
  • Purpose: Necessary pedagogical adjustments
  • Special measures: Additional encryption and restricted access

5. Recipients of Data

5.1 Within Argentina

  • Technology service providers (learning platforms)
  • Financial institutions for payment processing
  • Accountants and legal advisers
  • Education authorities where required

5.2 Argentine public bodies

  • AFIP (Administración Federal de Ingresos Públicos)
  • Ministry of Education of the City of Buenos Aires
  • Courts where legally required

5.3 For students in the EU

  • European educational bodies for the recognition of certificates
  • European consular authorities where necessary

5.4 Providers of artificial intelligence services

  • Providers of language models and speech services acting as data processors for the features described in section 3.9
  • They receive only the content needed to deliver the service, without the student's identification data

6. International Transfers

6.1 From Argentina to the EU

  • Argentina has an adequacy decision from the European Commission
  • Transfers to the EU are permitted without additional safeguards

6.2 From the EU to Argentina

  • Transfers are covered by the adequacy decision
  • For other countries: only with appropriate safeguards (standard contractual clauses)

6.3 International platforms and services

  • Google Workspace for Education (United States) - with standard contractual clauses
  • Adobe Connect Server (United States) - for class recordings
    • Safeguards: Standard Contractual Clauses approved by the European Commission
    • Security measures: encryption in transit and at rest
    • Limited access: only authorised staff of the school
    • Storage period: 3 months at most
  • External certificate server - for storing digital certificates
    • Location: [SPECIFY SERVER LOCATION]
    • Security safeguards: AES-256 encryption, restricted access
    • Purpose: secure storage of issued certificates
    • Period: 5 years for ÖSD certificates, 3 years for internal certificates
  • Artificial intelligence providers (United States) - Anthropic, OpenAI, Google and ElevenLabs, for the features in section 3.9
    • Basis: express consent of the data subject and each provider's contractual data processing terms
    • Data transferred: texts, messages and voice recordings from the activities, without name or email address
    • Security measures: encryption in transit
    • Storage period at the provider: [VERIFY IN EACH PROVIDER'S TERMS]

7. Rights of Data Subjects

7.1 For residents of Argentina (Ley 25.326)

  • Right to information: to know that processing exists and its purpose
  • Right of access: to obtain information about your personal data
  • Right to rectification: to correct inaccurate or outdated data
  • Right to erasure: to request deletion when the data is no longer needed

7.2 For residents of the EU (GDPR)

All of the above rights, plus:

  • Right to restriction: to restrict processing in certain circumstances
  • Right to data portability: to receive data in a structured format
  • Right to object: to object to processing on grounds relating to your particular situation

7.3 Exercising your rights

For all students:

  • Email: [email protected]
  • In person: Bulnes 644, C1176ABL Buenos Aires, Argentina
  • Phone: +54 9 3546 53 2993
  • Documentation required: DNI, passport or valid identity document
  • Response time: 10 working days (Argentina) / 30 days (GDPR)

7.4 Specific rights regarding the features using artificial intelligence

  • Human review: to request that a teacher review an automatic correction or assessment
  • Access to the learning profile: to know which topics appear in your profile
  • Erasure: to request deletion of your questions to the assistant and of your learning profile
  • Withdrawal of consent: to stop using the voluntary features at any time, with no consequences for your enrolment

8. Security Measures

8.1 Technical measures

  • Automated backup system to protect data
  • Password encryption for access to Adobe Connect and Moodle
  • Access to learning platforms through secure authentication
  • HTTPS connections on the website and online shop
  • Regular security updates on all systems
  • Content is sent to the AI providers without the student's identification data and over encrypted connections

8.2 Organisational measures

  • Annual data protection training for staff
  • Access policies based on the need to know
  • Confidentiality agreements with all staff
  • Procedures for responding to security incidents
  • Internal audits every six months

8.3 Physical security

  • Access control to the premises
  • Security cameras in common areas
  • Locked cabinets for paper documents
  • Secure destruction of documents

9. Data Retention

9.1 General periods

  • Official ÖSD certificates: 5 years (for reissue and validation)
  • Internal course certificates: 3 years (for reissue)
  • Grades and assessments: 3 years from the end of the course
  • General academic data: 2 years from the end of the course
  • Class recordings: 3 months from the end of the course
  • Questions to the DAIna assistant and ratings: 180 days
  • Learning profile: 180 days from each observation
  • Voice recordings from speaking practice and exam simulations: [SPECIFY PERIOD]
  • Administrative and invoicing data: 10 years (statutory accounting obligation)
  • Video surveillance data: 30 days
  • Marketing communications: until consent is withdrawn
  • Contact data: 1 year after the end of the relationship

9.2 Retention criteria

  • Necessity for the purpose of the processing
  • Statutory retention obligations
  • Limitation periods for legal claims
  • Legitimate interest of the school

10. Tracking Technologies

10.1 Cookies and website

  • Technical cookies: necessary for the online shop to work
  • Google Analytics: analysis of website behaviour (subject to prior acceptance)
  • Facebook Pixel: tracking for targeted marketing (subject to prior acceptance)
  • Session cookies: to keep user sessions active
  • For more information: Cookie Policy, available on the website

10.2 Learning platforms

  • Monitoring of academic progress
  • Statistics on the use of learning resources
  • Connection and activity data
  • Learning profile and use of the features using artificial intelligence (see section 3.9)

11. Minors

11.1 In Argentina

  • Under 13: consent of parents or guardians is mandatory
  • Between 13 and 18: may give consent with parental assistance
  • Special authorisation: required for class recordings involving minors

11.2 In the EU

  • Under 16 (or a lower age depending on the member state): parental consent required
  • Recordings: express authorisation from both parents or guardians

11.3 Special measures for minors

  • Specific forms: authorisation signed by parents or guardians for:
    • Enrolment in courses
    • Class recordings
    • Use of digital platforms (Moodle, Adobe Connect)
    • Use of the features using artificial intelligence (section 3.9)
  • Age verification: mandatory at enrolment
  • Enhanced protection: limited access to minors' data
  • Communication with parents: progress reports to parents or guardians

12. Security Incidents

12.1 Notification to authorities

  • Argentina: AAIP within 72 hours if there is a risk
  • EU: data protection authority within 72 hours

12.2 Communication to data subjects

  • Direct notification where there is a high risk to rights and freedoms
  • Clear information about the nature of the incident
  • Measures taken and recommendations

13. Changes to this Policy

  • Changes will be notified 30 days in advance
  • Publication on the website and direct communication to active students
  • For substantial changes: request for new consent where required

14. Supervisory Authorities

14.1 In Argentina

Agencia de Acceso a la Información Pública (AAIP)

14.2 In the European Union

Students residing in the EU may contact:

  • The data protection authority of their country of residence
  • Or the Spanish Data Protection Agency (Agencia Española de Protección de Datos, AEPD) as lead authority:

15. Contact Information

15.1 General enquiries

  • Email: [email protected]
  • Phone: +54 9 3546 53 2993
  • Address: Bulnes 644, C1176ABL Buenos Aires, Argentina

15.2 Exercising your rights

15.3 Security emergencies

Statement of Compliance

This Privacy Policy has been designed to comply simultaneously with:

  • Ley 25.326, Personal Data Protection Act (Argentina)
  • Decreto Reglamentario 1558/2001 (Argentina)
  • General Data Protection Regulation - GDPR (European Union)
  • AAIP provisions (Argentina)

Last legal review: October 2026

Acceptance: By enrolling in our courses or using our services, you accept the terms of this Privacy Policy. You may withdraw your consent at any time by contacting us through the channels indicated.

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