Tradilex

Privacy policy

This Privacy Policy explains, in clear language, how the Universidad Nacional de Educación a Distancia (UNED) processes the personal data of those who use the Tradilex Platform.

1. Controller

1.1 The controller of the personal data collected through the platform is:

  • Controller: Universidad Nacional de Educación a Distancia (UNED)
  • Tax identification number: Q2818016D
  • Address: Calle Bravo Murillo, 38, 28015 Madrid (Spain)
  • Unit responsible for the activity: TRADIT Research Group (Didactic Audiovisual Translation), Faculty of Philology, Department of Foreign Philologies and their Linguistics
  • Project manager: TRADIT Research Group — tradilex@flog.uned.es

1.2 The data subject may contact the TRADIT research group regarding any matter relating to the processing of their data at: tradilex@flog.uned.es. The UNED has a Data Protection Officer, whom any interested party can contact to exercise their data protection rights at dpd@adm.uned.es.

1.3 The platform is a result of the “TRADILEX” research project (reference PID2019-107362GA-I00), funded by the Spanish Ministry of Science and Innovation and the State Research Agency (MCIN/AEI/10.13039/501100011033).

2. General information on data processing

2.1 We process only the data necessary for the purposes described in this policy, applying the principle of data minimisation: we do not collect data that are not adequate, relevant and limited to what is necessary for each purpose.

2.2 Personal data are obtained from the following sources:

  • a) directly from the data subject, when they register, complete the contact form, create or join a classroom, or generate content on the platform (productions that the user generates in the exercises, insofar as they are linked to their account);
  • b) from teaching staff, when a teacher provides a class code that students enter to link themselves to their classroom;
  • c) from information generated through browsing, by means of cookies and similar technologies, in accordance with the consent given.

2.3 The collection of special categories of data referred to in Article 9 of the GDPR is not envisaged. Users are asked not to include health data, political or ideological views, religious beliefs or other special categories of data in free-text fields, messages or recordings.

2.4 Users guarantee that the data they provide are accurate and undertake to keep them up to date, communicating any changes. When providing third-party data, they must have previously informed the third parties concerned of the content of this policy.

3. Purposes of processing

Each processing activity is described separately below, together with its specific legal basis, the data processed, the retention period and the consequence of not providing the data.

3.1 Management of student registration and accounts

Data processed: email address, first name, surname, city, country and, where applicable, the class code provided by the teacher.

Purpose: to create and manage student accounts, enable authenticated access and, where applicable, link the account to the teacher's classroom.

Legal basis: performance of a task carried out in the public interest (Article 6(1)(e) GDPR), within the framework of the UNED's educational and research activities. Optional fields are processed on the basis of the data subject's consent (Article 6(1)(a) GDPR).

Retention period: while the account remains active. Following its cancellation or a prolonged period of inactivity, the data are deleted or blocked for the applicable limitation periods for any potential liabilities, after which they are deleted.

Consequence of not providing the data: it is not possible to create the account or access features reserved for registered users.

3.2 Management of teacher registration and accounts

Data processed: email address, first name, surname, city and country.

Purpose: to create and manage teacher accounts, enable the creation of classrooms and the generation of class codes, as well as provide feedback to students.

Legal basis: performance of a task carried out in the public interest (Article 6(1)(e) GDPR).

Retention period: while the account remains active; thereafter, deletion or blocking for the applicable limitation periods.

Consequence of not providing the data: it is not possible to create the teacher account or manage classrooms.

3.3 Provision of the educational service and classroom management

Data processed: account data, student-classroom links through the class code, progress in lesson plans and feedback between teaching staff and students.

Purpose: to provide the Didactic Audiovisual Translation educational service, manage classrooms and enable monitoring and feedback.

Legal basis: performance of a task carried out in the public interest (Article 6(1)(e) GDPR).

Retention period: for the duration of the educational relationship; thereafter, deletion or blocking in accordance with the applicable limitation periods.

Consequence of not providing the data: it is not possible to use the platform's educational features.

3.4 Handling of enquiries through the contact form

Data processed: first name and surname, email address, subject, message and, if provided, telephone number.

Purpose: to handle and respond to enquiries and requests submitted through the form.

Legal basis: performance of a task carried out in the public interest (Article 6(1)(e) GDPR); submission of the form by the data subject is voluntary.

Retention period: the time necessary to handle the enquiry and thereafter for the applicable limitation periods for any potential liabilities arising from it.

Consequence of not providing the data: it will not be possible to process or respond to the enquiry. The telephone number is optional and is not necessary to respond by email.

3.5 User voice recordings, subtitles and written responses

Data processed: voice recordings, subtitles and other audiovisual productions generated by users in didactic exercises, as well as the associated metadata.

Purpose: to enable the completion and assessment of subtitling, dubbing and audio description exercises, and to retain the productions within the framework of the lesson plan.

Legal basis: performance of a task carried out in the public interest (Article 6(1)(e) GDPR) for the purposes of carrying out the didactic exercise. Any use exceeding that exercise (academic publications, conference presentations or dissemination materials) is based on the data subject's specific and separate consent (Article 6(1)(a) GDPR).

Retention period: while the educational relationship continues or until the data subject requests their deletion. Productions used for research purposes are retained in accordance with Section 4.3.

Consequence of not providing the data: it will not be possible to complete exercises requiring recording or subtitling; refusal of research use does not affect didactic use.

Voice recordings are processed exclusively for the didactic and research purposes described and are not subject to technical processing aimed at the unique biometric identification of the person; therefore, they do not constitute biometric data falling within the special categories of data under Article 9 GDPR.

3.6 Cookies and third-party embedded content

Data processed: identifiers and browsing data managed through cookies and similar technologies, including those generated by embedded video content.

Purpose: to enable the technical operation of the site (necessary cookies) and, subject to acceptance, preference and statistical purposes and, where applicable, marketing purposes, as well as the playback of embedded video.

Legal basis: user consent for non-essential cookies (Article 6(1)(a) GDPR and Article 22(2) of Law 34/2002); strictly necessary cookies are based on the provision of the service requested by the user.

Retention period: the lifespan of each cookie indicated in the Cookie Policy; consent is requested again periodically and may be withdrawn at any time.

Consequence of not providing the data: refusal of non-essential cookies does not prevent browsing, although it may limit certain features, such as embedded video playback.

Detailed information on the cookies used, their purpose and management is set out in the Cookie Policy, accessible from the website.

3.7 Use for scientific research, dissemination and knowledge transfer purposes

Data processed: platform usage data and user productions that, where applicable, are incorporated into research studies, preferably in anonymised or pseudonymised form.

Purpose: scientific research in the field of Didactic Audiovisual Translation and the dissemination and knowledge transfer of its results, within the framework of the TRADILEX project.

Legal basis: performance of a task carried out in the public interest (Article 6(1)(e) GDPR), with the safeguards provided for in Article 89 GDPR; when identifiable user productions are used, the user's specific consent is also obtained (Article 6(1)(a) GDPR).

Retention period: the period necessary for the research purposes, applying pseudonymisation or anonymisation measures; anonymised data, as they do not permit identification, fall outside the scope of data protection.

Consequence of not providing the data: refusal to participate in research uses does not affect access to or educational use of the platform.

4. Specific sections

4.1 Special categories of data

Special categories of data referred to in Article 9 GDPR are not processed. Voice recordings are processed for didactic and research purposes and not for the biometric identification of the person; therefore, they do not constitute biometric data falling within a special category.

4.2 Processing for scientific research purposes (Article 89 GDPR)

Processing for research purposes is carried out by applying the appropriate safeguards under Article 89 GDPR, in particular data minimisation and, whenever possible, pseudonymisation or anonymisation of the data. The use of identifiable user productions for publication or dissemination purposes requires the user's specific and separate consent, which may be withdrawn at any time.

4.3 Automated decision-making

No decisions are made based solely on automated processing of data that produce legal effects concerning the data subject or similarly significantly affect them.

5. Recipients and processors

5.1 The data are not disclosed to third parties, except where legally required or where necessary for the purposes described. Certain providers access the data as processors, on behalf of and following the controller's instructions, under the contract required by Article 28 GDPR. The categories of processors are:

  • a) provider of platform hosting and infrastructure;
  • b) provider of the cookie consent management tool;
  • c) provider of the video platform used for embedded content;
  • d) providers of email and communications services.

5.2 The exercise of data protection rights may also be carried out through the UNED Data Protection Office and its Electronic Office.

6. International transfers of data

6.1 The inclusion of embedded video content may involve the disclosure of data to Google LLC (YouTube), based in the United States, when the user consents to the cookies associated with such content. This transfer is covered by the European Commission adequacy decision concerning the EU-US Data Privacy Framework, insofar as the importing entity is a participant in that framework.

6.2 Except as stated above, no international transfers of data are envisaged. If such transfers occur in the future, users will be informed and the safeguards required by Chapter V of the GDPR will be adopted.

7. Rights of the data subject

7.1 The data subject may exercise the following rights in relation to their data:

  • a) access: to know whether their data are being processed and obtain a copy thereof;
  • b) rectification: to correct inaccurate or incomplete data;
  • c) erasure: to request the deletion of their data when, among other circumstances, they are no longer necessary for the purpose;
  • d) restriction: to request that processing be restricted in certain cases, with the data being retained only for specific purposes;
  • e) portability: to receive their data in a structured, commonly used format, or have them transmitted to another controller, where applicable;
  • f) objection: to object to processing on grounds relating to their particular situation;
  • g) not to be subject to decisions based solely on automated processing that produce legal or similarly significant effects.

Where processing is based on consent, the data subject may withdraw it at any time, without affecting the lawfulness of processing carried out before its withdrawal.

7.2 To exercise these rights, the data subject may contact the Data Protection Officer at dpd@adm.uned.es, the UNED Data Protection Office (Calle Bravo Murillo, 38, 28015 Madrid) or through the UNED Electronic Office, after verifying their identity. The request will be addressed within one month, extendable in accordance with the GDPR.

7.3 The data subject has the right to lodge a complaint with the Spanish Data Protection Agency (Calle Jorge Juan, 6, 28001 Madrid; www.aepd.es), particularly if they consider that they have not obtained satisfaction in exercising their rights.

8. Data security

8.1 The controller implements appropriate technical and organisational measures to ensure data security, including encryption in transit and at rest of sensitive information, authentication-based access controls, activity logging and backups. These measures are reviewed periodically to keep them in line with the state of the art.

8.2 Staff and collaborators who access the data are subject to confidentiality obligations. In the event of a data security breach that poses a risk to the rights of data subjects, the controller will act in accordance with Articles 33 and 34 of the GDPR.

9. Changes to the Privacy Policy

9.1 The controller may amend this Privacy Policy to adapt it to regulatory or technical changes or changes to the platform’s activities. Amendments will take effect upon publication. Where changes are substantial, users will be informed through the means available on the platform.

10. Date of last update

Effective from the date of publication.