Original policy last updated: 23 August 2026

1. Data controller

The controller of the data processed through this platform is ASOCIACIÓN PEDAGÓGICA ILER, tax identification number G39810619, registered in Spain’s National Register of Associations, Section 1, national number 621441, with its address at Calle Menéndez Pelayo, 16, 6.º D, 39700 Castro Urdiales (Cantabria), Spain.

Contact email for privacy matters: formacion@createctura.es.

2. Data we process

Depending on how you use the website, we may process:

  • identification and contact details, such as name, username, email address and country;
  • account and profile information you choose to provide;
  • information about enrolments, purchased courses, orders, payment amounts, methods and status;
  • progress, activities, answers and participation within courses;
  • communications, enquiries and support requests;
  • information needed to organise online meetings and, if you participate with your camera or microphone, your image or voice;
  • technical and security data, such as IP address, browser, access logs and cookies.

Createctura does not store your complete card or payment account details. These are processed directly by the relevant payment provider.

3. Purposes and legal bases

We process data to:

  • Create and manage your account, enrolment, access and progress: performance of the contract or steps requested before entering into a contract.
  • Manage orders, payments, invoicing and accounting obligations: performance of the contract and compliance with legal obligations.
  • Deliver courses, answer questions and organise meetings: performance of the purchased service.
  • Respond to enquiries and provide support: performance of the contract or a legitimate interest in responding to communications received.
  • Prevent fraud, spam and unauthorised access and protect the platform: legitimate interest and compliance with security obligations.
  • Send notices strictly related to your account, orders or courses: performance of the contract. These notices will not be used for advertising unrelated to the service.
  • Add you, at your request, to external support groups such as WhatsApp: your voluntary decision. Subsequent use of that service is subject to its own terms and privacy policy.
  • Record online meetings: you will be informed before recording begins. You can participate without a camera and ask questions through means that do not reveal your image. Where necessary, the corresponding consent will be requested.
  • Use non-essential cookies: consent, which you can withdraw at any time through the cookie preferences panel.

4. Recipients and providers

Providers needed to host and maintain the website, send email, protect it against abuse, deliver video conferences, host videos and process payments may access the data. Services that may be involved include WordPress/LearnPress, the hosting provider, Google reCAPTCHA, embedded video platforms, Zoom, WhatsApp, PayPal and Stripe. Bank transfers and Bizum are handled by the relevant banking institutions.

Each provider processes data under its own terms and, when acting as a processor, the applicable agreement. Some providers may process data outside the European Economic Area using the legally required mechanisms, such as adequacy decisions or standard contractual clauses.

We do not sell personal data or disclose it for third-party advertising.

5. Retention

Account, enrolment and progress data will be retained for as long as the account or access is needed and afterwards for the time strictly necessary to address liabilities. Orders and proof of payment will be retained for the applicable tax, accounting and statutory periods, which may extend to between four and six years. Enquiries will be retained while being handled and afterwards for the period needed to demonstrate that they were addressed.

Backups and technical logs are deleted on a rotating basis in accordance with the service’s security cycles.

6. Your rights

You may request access, rectification, erasure, objection, restriction or portability of your data, and withdraw consent without affecting processing carried out previously. Write to formacion@createctura.es, stating the right you wish to exercise and providing the information needed to identify your account. We may request additional proof where necessary to avoid disclosing data to another person.

If you believe your rights have not been respected, you may lodge a complaint with the Agencia Española de Protección de Datos at www.aepd.es.

7. Security and accounts

We apply reasonable measures to protect information. You must keep your password confidential and notify us if you suspect unauthorised use. The platform is intended for adults and professionals; it is not designed for minors to create accounts on their own.

8. Cookies and similar technologies

The website may use:

  • Technical or necessary cookies: these enable sign-in, maintain sessions, remember essential preferences, manage purchases, provide course access and protect forms and accounts. They do not require consent when essential to the requested service.
  • Preference cookies: these remember non-essential display or usage choices.
  • Statistics cookies: if enabled, these help show how the website is used in aggregate.
  • External service cookies: these may be set when playing embedded videos, using reCAPTCHA or accessing a payment provider.

Non-essential cookies and external content that requires them will load only after your choice. The cookie panel allows you to accept, reject or configure the available categories and change your decision later. You can also delete cookies through your browser, although disabling necessary cookies may prevent access to your account, courses or payment.

The specific list of cookies, their providers, purposes and durations is displayed and updated in this website’s preferences panel or cookie statement (currently in Spanish).

9. Changes

We may update this policy when services or applicable obligations change. We will indicate the date of the latest update and notify you of significant changes where necessary.