Original policy last updated: 29 September 2026

Privacy policy contents

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.
  • Enable exchanges within the campus: performance of the purchased service. Questions, replies and photos you publish are visible to authorised participants in the same course and the teaching team during course access; the history is retained with restricted access to address liabilities and substantiate training where applicable. Avoid sensitive data or identifiable images of children or other people. For private matters, write to formacion@createctura.es.
  • Record online meetings: prior information and consent to include identifiable contributions, with separate optional permission for reuse, as detailed below.
  • Use non-essential cookies: consent, which you can withdraw at any time through the cookie preferences panel.

Meetings, recordings and reuse of contributions

Before recording, we will explain its purpose, audience and participation options. A recording may include your image, voice, displayed name and contributions. We will request individual permission to include identifiable contributions in the recording made available to authorised course participants who cannot attend live. You may keep your camera and microphone off and ask questions in the chat; the trainer may rephrase them without identifying you. Refusing permission does not prevent you from participating or completing the training.

Separately and optionally, at the beginning of the meeting you may authorise the reuse of excerpts of your identifiable contributions as teaching material in future Createctura courses, accessible to their authorised participants. This permission does not cover advertising, social media or public distribution. We will collect an individual affirmative response, for example through a form, poll or recorded statement, and retain your identity, date, response and the version of the notice alongside the session. Purchasing a course, remaining silent or leaving your camera or microphone on does not constitute permission. Chat content, including names and screenshots, will not be reused.

We will not need to request permission for each excerpt as long as the use stays within the authorised scope and consent remains valid. Before each reuse, we will check permission; if it is missing or has been withdrawn, we will exclude or effectively anonymise the contribution. You may withdraw permission by writing to formacion@createctura.es, without affecting the lawfulness of earlier use. We will stop new uses and remove or anonymise the affected excerpts in the materials we manage. Publishing this policy does not itself authorise the use of previous recordings.

Subsidised training and participation evidence

Where applicable, we process identification, enrolment, connection, progress, assessment and attendance data to organise and substantiate the training, on the basis of applicable legal obligations and service delivery. Necessary evidence may be shared with the participating employer, its designated adviser and competent bodies such as FUNDAE and SEPE, according to their functions. This evidence is retained separately from audiovisual content intended for other courses.

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, 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.

ILER manages formacion.createctura.es, which is hosted by LucusHost, S.L.U. Meetings use an ILER Zoom account and recordings are hosted on Vimeo. Course recordings are intended exclusively for authorised participants; links, credentials and copies must not be shared with third parties. Each provider’s role and the applicable safeguards depend on the service contracted.

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.

Recordings are not automatically deleted after each meeting. Replay access remains available for the period communicated for the course. Excerpts containing identifiable contributions authorised for future training are retained while necessary for that purpose and while consent remains valid; we will review their necessity before reuse and when the planned educational use ends, deleting or anonymising them when no longer necessary. The mere possibility of future use does not justify indefinite retention. We may retain trainer content where we hold the necessary rights. Evidence of permission and legal records is kept with restricted access for the time needed to demonstrate compliance and address liabilities; this does not require retaining complete videos.

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.