Privacy Policy
Last updated: May 2026
1. Introduction
This Privacy Policy explains how we collect, use, and protect your personal data when you use our website and online courses. We are committed to processing your data in accordance with the EU General Data Protection Regulation (GDPR) and the Spanish Organic Law on Data Protection (LOPDGDD).
2. Data Controller
The data controller responsible for processing your personal data is:
- Legal name: Inversiones Jarafuel, S.L.
- Tax ID (CIF): B72793656
- Registered office: C/ General Ibáñez, 2 - Esc. Izda - 1A, 28231, Las Rozas (Madrid), Spain
- Email: info@carlosmanagement.com
3. Data We Collect
We collect the following categories of personal data:
- Identification data: name and email address you provide when creating an account or purchasing a course.
- Billing data: billing name, address and tax ID, processed by our payment provider (Stripe) on our behalf.
- Usage data: pages visited, lessons viewed, video progress, downloads, and device or browser metadata.
- Communications: messages you send us via email or contact forms.
4. Purposes of Processing
We process your personal data for the following purposes:
- To create and manage your student account.
- To process your purchases and issue invoices.
- To grant you access to the courses you have purchased and track your progress.
- To provide customer support and respond to your inquiries.
- To analyse and improve the website and the courses (only with your consent for non-essential analytics).
- To comply with our legal and tax obligations.
5. Legal Basis
The legal basis for each processing activity is:
- Performance of a contract for account creation, course delivery and payment processing.
- Legal obligation for tax, accounting and consumer protection compliance.
- Consent for non-essential cookies and analytics, and for any commercial communications.
- Legitimate interest for fraud prevention, network security and improvement of our services.
6. Recipients and International Transfers
We share your data only with the service providers strictly needed to operate our service, acting as data processors under our instructions:
- Stripe Payments Europe, Ltd. — payment processing.
- Vercel Inc. — website hosting and infrastructure.
- Wasabi Technologies, Inc. — secure storage of course videos and downloadable materials.
- Google Ireland Limited — Google Analytics, only when you give explicit consent.
- Resend, Inc. — transactional emails (login links, purchase receipts).
Some of these providers may transfer data outside the European Economic Area. In such cases, transfers are protected by Standard Contractual Clauses approved by the European Commission and additional safeguards where required.
7. Data Retention
We keep your personal data for as long as your student account is active, and afterwards for the periods required by law (typically up to six years for accounting and tax purposes). Course progress data is retained while you have access to the course you purchased.
8. Your Rights
Under the GDPR, you have the right to access, rectify, delete, restrict, port and object to the processing of your personal data, as well as the right to withdraw consent at any time when processing is based on it.
To exercise these rights, write to us at info@carlosmanagement.com with a copy of an identification document. You may also lodge a complaint with the Spanish Data Protection Agency (www.aepd.es) if you consider that your rights have not been respected.
9. Security
We apply technical and organisational measures appropriate to the risk of the processing, including transport encryption (HTTPS), access controls, password hashing, and regular backups. No system is fully secure, but we work continuously to keep your data protected.
10. Changes to this Policy
We may update this Privacy Policy from time to time. The latest version will always be available on this page, with the date of the last update at the top.
For any questions about this document, you can contact us at info@carlosmanagement.com.