SEBA | LEARN

1. Introduction

LomloeHub ("we," "us," "our," or "Company") is committed to protecting your privacy and ensuring transparency about how we collect, use, and protect your personal data. This Privacy Policy explains our practices regarding personal information collected from teachers, educational administrators, students, families, and other users of our platform.

We comply with all applicable data protection laws, including the General Data Protection Regulation (GDPR), Spanish data protection legislation (LSSI-CE, LOMLOE), and Catalan privacy regulations enforced by the Autoritat Catalana de Protecció de Dades (AAPD).

2. Data Controller

LomloeHub

Catalonia, Spain

Email: [email protected]

Data Protection Officer: [email protected]

3. What Personal Data We Collect

3.1 Information You Provide Directly

Account information: Name, email address, phone number, school/institution name
Profile data: Job title, subject area, grade level, educational qualifications
Content you create: Lesson plans, calendar entries, educational materials, assessments
Communication: Messages, feedback, support requests, survey responses
Payment information: Billing address, subscription details (processed securely via third parties)

3.2 Information Collected Automatically

Device information: Device type, operating system, browser type
Usage data: Pages visited, features used, time spent, search queries
Technical data: IP address, log files, cookies, session identifiers
Location data: General geographic location (country/region level only)

3.3 Information from Third Parties

Educational institution records (with proper authorization)
OAuth providers (Manus authentication system)
Analytics services (Google Analytics, performance monitoring)
Payment processors (for subscription management)

4. Legal Basis for Processing

We process your personal data based on the following legal grounds:

Processing Purpose	Legal Basis
Account creation and authentication	Contract performance
Service delivery	Contract performance
Analytics and service improvement	Legitimate interest
Marketing communications	Consent (opt-in)
Legal compliance	Legal obligation
Security and fraud prevention	Legitimate interest

5. How We Use Your Data

We use your personal data for the following purposes:

Providing and improving LomloeHub services
Authenticating your identity and managing your account
Delivering personalized educational content and recommendations
Analyzing usage patterns to enhance platform functionality
Communicating important updates, security alerts, and service changes
Responding to your inquiries and providing customer support
Conducting research on educational effectiveness and LOMLOE compliance
Complying with legal obligations and protecting our rights
Preventing fraud, abuse, and unauthorized access

6. Data Sharing & Third Parties

We do not sell your personal data. We may share data with:

Service providers: Cloud hosting, analytics, payment processing (under data processing agreements)
Educational institutions: Only with explicit authorization from authorized administrators
Legal authorities: When required by law or to protect rights and safety
Business partners: Only with your explicit consent for specific purposes

All third parties are contractually obligated to protect your data with the same level of security we maintain.

7. Student & Minor Data Protection

LomloeHub takes special care to protect the privacy of students and minors:

Age-appropriate processing: We minimize data collection for users under 16 years old
Parental consent: For users under 14, parental/guardian consent is required
Educational purpose only: Student data is used exclusively for educational delivery
No marketing: Students do not receive marketing communications
Enhanced security: Student data receives additional security protections
Data retention: Student data is deleted upon request or end of enrollment

8. Data Security

We implement comprehensive security measures to protect your data:

Encryption: SSL/TLS encryption for data in transit; AES-256 for data at rest
Access controls: Role-based access and authentication requirements
Regular audits: Security assessments and penetration testing
Incident response: Documented procedures for data breach notification
Employee training: Regular data protection and security training
Compliance: ISO 27001 standards and GDPR compliance measures

While we implement strong security measures, no system is completely secure. We encourage you to use strong passwords and enable two-factor authentication.

9. Your Privacy Rights

Under GDPR and Spanish data protection laws, you have the following rights:

Right of access: Request a copy of your personal data
Right to rectification: Correct inaccurate or incomplete data
Right to erasure: Request deletion of your data ("right to be forgotten")
Right to restrict processing: Limit how your data is used
Right to data portability: Receive your data in a portable format
Right to object: Opt-out of certain processing activities
Right to withdraw consent: Revoke consent for optional processing
Right to lodge a complaint: File a complaint with data protection authorities

To exercise any of these rights, contact us at [email protected]. We will respond within 30 days.

10. Data Retention

We retain your data only as long as necessary:

Active accounts: Data retained while account is active
Account deletion: Data deleted within 30 days of account closure
Educational records: Retained per institutional policies and legal requirements
Analytics data: Aggregated data retained for 13 months
Legal obligations: Data retained as required by law (e.g., tax records for 6 years)

11. International Data Transfers

LomloeHub primarily operates within the EU/EEA. If data is transferred outside this region, we ensure appropriate safeguards including Standard Contractual Clauses (SCCs) and adequacy decisions. Users have the right to request information about specific transfer mechanisms.

12. Contact & Complaints

For privacy inquiries or to exercise your rights:

LomloeHub Privacy Team