Privacy policy

1. Data controller

• Controller: Aula Lume, S.L.U. (trading as RumboNauta)
• Tax ID (NIF): B93944379
• Address: Baixada Praia 121, Saiáns, Vigo (Pontevedra), Spain
• Privacy contact email: hola@rumbonauta.es
• Data protection enquiries: hola@rumbonauta.es. For student data processed in the application, the contact is the data protection officer of the relevant school (section 4).

2. Two very different kinds of data

It's important to distinguish between two entirely separate data processing activities, with different legal bases and different controllers:

3. A) Website data

3.1 Usage statistics (analytics)

Purpose: to measure this website’s audience in order to understand how it is used and improve it. Legal basis: your consent (Article 6(1)(a) GDPR and Article 22.2 of the Spanish LSSI-CE). Analytics is only switched on if you click “Accept analytics” in the notice shown when you enter; if you reject, close or ignore it, Umami is not loaded and no data is sent to it. You can withdraw consent at any time with the “Analytics settings” link in the footer of the home page or from the cookie policy; from then on sending stops, without affecting the lawfulness of earlier measurement.

This site uses Umami to obtain visit statistics. The measurement data is not anonymous but pseudonymous: it does not include your name or email address, but it is linked to a technical identifier. Umami does not use cookies and does not store anything in your browser. To count unique visitors, it computes a pseudonymous identifier from your IP address and browser, combined with a value that is renewed periodically (at most monthly); the IP address is not stored, and this identifier cannot be used to recognise you on other websites or after it has been renewed. The service is provided by Umami Software, Inc. (United States) from its European Union region; according to its public list of subprocessors, part of its network and hosting infrastructure is provided by US companies. Measurement data is kept for 6 months. See our cookie policy for more detail.

3.2 Contact

If you write to us at hola@rumbonauta.es or use the “Request information” form on the home page, we process the data you provide (name, school, email and message content) solely to respond to your enquiry. The form does not store messages on the website: it sends them to that same mailbox. Legal basis: consent (by sending us the message) and legitimate interest in handling the request. Retention: for as long as needed to resolve the enquiry, after which it is deleted unless a longer legal retention period applies.

3.3 Your rights over this data

You can exercise your rights of access, rectification, erasure, objection, restriction of processing, and portability by writing to hola@rumbonauta.es. You may also lodge a complaint with the Spanish Data Protection Agency (AEPD) if you believe the processing does not comply with applicable law.

4. B) Student data inside the application

When a school contracts RumboNauta, students and teaching staff enter data (questionnaire responses, results, alerts) inside the application. For this data:

• The data controller is the school, not Aula Lume, S.L.U.
• Aula Lume, S.L.U. acts solely as data processor, processing the data according to the school's instructions and under the data processing agreement signed with each school, pursuant to Article 28 of the General Data Protection Regulation (GDPR).
• Aula Lume, S.L.U. does not use this data for any purpose of its own beyond providing the contracted service, and does not share it with third parties except where legally required.
• To exercise rights of access, rectification, erasure, or objection over student data, you must contact the relevant school directly, as it determines the purposes and means of the processing and is responsible for handling such requests (passing on the relevant instructions to Aula Lume, S.L.U. as needed).
• Security measures: username/password access control, encrypted connections (HTTPS), and the technical and organisational measures set out in the data processing agreement with each school.

5. Security measures

Aula Lume, S.L.U. applies appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including encrypted communications, access control, and regular backups.

6. Changes

This policy may be updated to reflect legislative changes or changes to the service itself. The version published on this page is always the one in force.

← Back to RumboNauta