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Daniel Alfocea Academy

Privacy policy

What data we process at Daniel Alfocea Academy, what for, with which providers and how to exercise your rights (GDPR and LOPDGDD). Alice & Bob, S.L.

This is a translation for convenience. The Spanish version is the legally binding one.

Last updated: 12 October 2026

Here we tell you what data of yours we process at academy.danielalfocea.com, why, who we share it with, how long we keep it and what you can do about it. It is written to be understood; if something is not clear, write to us.


1. Who processes your data

Alice & Bob, S.L., CIF B67932186, with registered office at Calle Marie Curie, 7, Edificio Beta, Planta 7 Ático — Parque Empresarial Rivas Futura, 28521 Rivas-Vaciamadrid (Madrid), telephone +34 647 879 318, is the data controller.

Daniel Alfocea creates and signs the content; the company is the one that processes the data, sells and invoices.

  • Email for privacy matters: [email protected]
  • Data protection officer: none has been appointed. The processing we do does not consist of the regular and systematic monitoring of data subjects on a large scale, nor does the volume of students and data we process reach a scale that requires it: for that reason we understand that we are not within the cases of article 37 GDPR or article 34 LOPDGDD. If the volume or type of processing changed in a relevant way —for example, if we began to process special categories of data on a large scale—, we would review this conclusion.

This is the full table. If a processing activity is not here, we do not do it.

2.1. Your account and your access

What we processWhat forLegal basis
Email address (it is your login identifier), name, preferred language, time zone and notification preferencesCreating and maintaining your account, and letting you inPerformance of the contract (art. 6.1.b GDPR)
The access links and one-time codes we send youLetting you in without a passwordPerformance of the contract
Device identifier, browser (user agent) and the IP address with which each session was createdShowing you your devices, closing sessions, applying the session limit and detecting shared accountsPerformance of the contract and legitimate interest (art. 6.1.f): protecting the content we sell
Record of which version of the terms and of the privacy policy you accepted, when, from which IP and at what moment (sign-up, new version or purchase)Being able to prove that we informed youLegal obligation (art. 7.1 GDPR) and legitimate interest

We do not do fingerprinting and we do not geolocate you precisely. For the device limit, the session identifier, the IP and the browser are enough, and we read nothing else from your device.

The processing based on legitimate interest in this policy —device limit, detection of shared accounts, watermark, anti-fraud and abandonment notices— rests on this balancing test: the purpose is legitimate (protecting paid content and preventing fraud), the measure is necessary (there is no other way to apply the device limit, the stamping or the abandonment notice without processing that data) and it is proportionate (we use the minimum data possible —session identifier, IP and browser—, we do not do fingerprinting or geolocation, and you can always object, although for the watermark that means we cannot give you the protected content). If you want more detail on this assessment, write to us.

2.2. Your study

What we processWhat forLegal basis
Your progress: what you have watched or read in each lesson, how far, and whenSo you can pick up where you left off, calculate your progress, apply prerequisites and decide whether you are entitled to the certificate. It also decides whether our refund guarantee applies (see terms and conditions of sale)Performance of the contract
Usage signals from the player and the reader (progress, replays, where people get stuck)Improving the content, in aggregate; and detecting that you have stalledLegitimate interest (art. 6.1.f)
What you submit in assignmentsKeeping a record of your submissionPerformance of the contract
Your exam attempts and your gradesMarking, deciding whether you pass and issuing the certificatePerformance of the contract
The «this is wrong» notices you send us about a lessonCorrecting errors in the contentLegitimate interest

2.3. Your certificates and your public face

What we processWhat forLegal basis
Your name, the course, the date, the certificate identifier and its statusIssuing the certificate and making it verifiablePerformance of the contract
Publishing your name on the certificate verification pageSo that whoever receives your certificate can check that it is realLegitimate interest, with right to object: you can ask for your name not to appear and the page will still say the certificate is valid, without identifying you
Your public profile (URL alias, biography, links, certificates shown)Showing your profile if you wantConsent. It is off by default, you turn it on and you turn it off whenever you want
Your ratings of products you have boughtShowing verified ratings on the product pagePerformance of the contract and legitimate interest

Certificate verification pages are not indexable by search engines and there is no list or search by name: they can only be reached with the exact certificate identifier.

2.4. Your purchases

What we processWhat forLegal basis
What you bought, how much you paid, in which currency, when and with which payment referenceGiving you access, assisting you and keeping the accountsPerformance of the contract
Your tax data: country, name or company name, tax ID or VAT number, address; and the result of the VIES register check when you buy as a companyIssuing the correct invoice and applying the right VATLegal obligation (art. 6.1.c)
Evidence of where you are for VAT purposes: declared country, card country and IP address of the purchaseDetermining the country of taxation, as VAT rules requireLegal obligation
Your express waiver of the right of withdrawal: that you ticked it, when and from which IPBeing able to prove that you gave it, if neededLegal obligation and legitimate interest (defence of claims)
Your invoicesComplying with tax and commercial rulesLegal obligation

Your card details do not pass through us. Payment is processed by Stripe inside our page; we never see or store the card number.

2.5. Emails and notices

What we processWhat forLegal basis
Your email, to send you what is essential: access, purchase confirmation, invoice, certificate, security notices, access expiry, support repliesPerforming the contractPerformance of the contract
Your email, to remind you that you left a course half doneSo you don’t forget what you boughtLegitimate interest, and you can turn it off in your preferences
Your email, to send you news, launches and offersMarketingConsent, in a separate box, not pre-ticked and separate from the rest. We may also write to you about similar products if you have already bought from us, with one-click unsubscribe in every mailing (art. 21.2 LSSI)
Whether you opened the email or clicked, and whether it bouncedKnowing whether our emails arrive and stopping writing to those who do not receive themLegitimate interest

You can sign up for a product’s waiting list without having an account. In that case we only store your email, the language if you state it and your consent; the unsubscribe link in every email is your way out, and it always works, with no expiry and without logging in.

No automated email is a no-reply: all carry a reply address that opens a support ticket.

2.6. Content protection

A dynamic watermark with your email or your identifier is painted over the video, in motion; and the PDFs, EPUBs and audios you download are stamped with data that identify you. It is what lets us know where a copy that turns up somewhere came from.

  • What is processed: your email or your account identifier, over the content you yourself are viewing.
  • Legal basis: legitimate interest (art. 6.1.f GDPR). Protecting the content is what makes it viable to sell, and the alternative —a DRM that controls your equipment— would be far more invasive.
  • Your right: you can object; bear in mind that without this measure we cannot give you access to the protected content.

This is, together with the processing of employee data in section 2.8, the one with the most risk of a complaint in this whole policy: it identifies the student inside a copy of the content. We stand by it because the alternative —a DRM that controls your device, or not protecting the content at all— is more invasive or commercially unviable, and because the data we use is the minimum necessary (your email or your identifier, never data about your device) and is only applied to what you yourself are consuming, not to third parties. The legitimate interest assessment for this particular processing is the first one to be drafted within the general LIA of section 2.1.

2.7. Analytics and advertising

WhatHowLegal basis
Our own measurement of visits and conversionsCalculated on our server, without cookies and without storing identifiers in your browserLegitimate interest. It does not identify you
Meta pixel (Facebook/Instagram) in your browserIt loads from the first visit, with no prior banner, on the public site and in the application. Meta receives the pages you view, your IP, your browser and the _fbp cookieLegitimate interest (art. 6.1.f GDPR): measuring the results of our ads. You can object by writing to us
Meta Conversions API (from our server)We send usage events (page view, product you look at, sign-up, free download) with your IP, your browser, the Meta cookies _fbp and _fbc if you have them and, if you have a session, your email and an identifier of your account hashed with SHA-256, whether or not you have accepted cookiesLegitimate interest (art. 6.1.f GDPR). You can object by writing to us
Meta Conversions API: payment page and purchaseWhen you open the payment page and when you pay an order, the event (amount, currency, product, your email and an identifier of your account hashed with SHA-256, your IP, your browser and your Meta cookies _fbp and _fbc if you have them) is sent by the payment platform (billing.danielalfocea.com), with its own policyLegitimate interest
Google Analytics 4 (from our server)Only if you accept Google Analytics in the application’s notice. We do not load its script in your browserConsent
Affiliate attributionA first-party 30-day cookie (academy_ref), only if you accept in the application’s noticeConsent

The public site has no cookie banner. The application has a notice only for Google Analytics and the attribution cookie; rejecting it does not turn off Meta. To avoid Meta you can use a blocker or your browser’s settings (the sending from the server is only stopped by objecting in writing).

The detail of cookies —what each cookie is, who sets it, how long it lasts and how to turn off the pixel— lives in the cookie policy, a separate document. This policy limits itself to declaring the processing.

2.8. If you study with a seat paid for by your company

When a company buys seats for its employees, we give it a report per seat with: whether you have completed the course, your exam grade, your progress percentage and your last activity by week, never by hour. Never schedules, minutes watched or detailed activity.

Your account is yours, not the company’s: if you leave, the seat is freed and the company learns that, not your personal data.

Regarding your employees’ data, we act as processors for your company: we process it only to provide the training service you have contracted, not for our own purposes, and within the instructions set out in the B2B contract with its data protection annex (section 11 of the terms and conditions of sale). Informing your staff about the processing of their data is your responsibility as the client company, as that same contract states, which is signed in writing with each company before any seat is registered.

2.9. Record of who looks at your data

We keep a record each time someone on our team —or a tool with credentials— opens the personal data of a specific student: their progress, their submissions, their exams, their orders and invoices, or their account record. That record is included in the data download you can ask us for, in the part that concerns you.

Legal basis: legal obligation (arts. 5.1.f and 32 GDPR) and legitimate interest.

3. Who we share your data with

We do not sell your data or hand it to anyone so they can advertise to you.

We do work with providers that process data on our behalf. Article 28 GDPR requires a processing agreement with each one, and we have it signed or accepted with all those in this table.

ProviderWhat forWhere it processes the dataTransfer outside the European Economic Area
StripeCollecting and managing payments, refunds and disputesIreland (European entity), with parent company in the United StatesYes. Covered by the EU-US Data Privacy Framework and standard contractual clauses
Bunny (BunnyWay d.o.o.)Serving the video, and storing and serving PDF, EPUB and audioSlovenia (headquarters); storage has a configurable region — it is fixed to Germany (Falkenstein/Frankfurt); the delivery network has points of presence worldwideIn storage, no, as long as the region stays fixed to Germany. In delivery through the distribution network, yes, with no specific transfer mechanism verified
EmailitSending service and transactional emails, including the link you log in withCzech Republic (entity FunFirst s.r.o., Prague)No, according to the provider’s policy — without independent verification
AcumbamailSending campaigns and bulk emailsSpain (Stackscale, Madrid). Owned by Growens (Italy) since 2018, within the European UnionNo
CloudflareServing the pages, protecting them and filtering trafficUnited States, with a global network; no selectable data residency outside enterprise plansYes. Data Privacy Framework and standard contractual clauses
HetznerServers where the platform lives and backupsGermany (European Union)No
SentryCollecting the platform’s technical errors, already filtered of personal data before sendingFrankfurt, Germany (Sentry’s European Union region)No

In addition, we may disclose your data to the tax authorities, to judges and courts, and to law enforcement when the law obliges us.

The article 28 processing agreements are signed or accepted with all the providers in the table:

  • Stripe includes it in its general contract, accepted when the account was opened.
  • Bunny, Hetzner, Cloudflare and Sentry have it accepted in each provider’s dashboard.
  • Acumbamail and Emailit, which do not offer self-service, have it signed in writing.
  • Stripe does not act only as a processor: for the part of payment processing it handles under its own legal obligations (anti-fraud, regulatory compliance), it acts as an independent controller, not on our behalf.
  • Bunny’s storage region is fixed to Germany (Falkenstein/Frankfurt). Sentry processes errors in its European Union region, in Frankfurt.
  • Groq, which comes in when automatic transcriptions arrive, will be added to this table with its processing agreement before receiving any data.

If you want a copy of a specific provider’s processing agreement, write to us.

4. How long we keep your data

DataHow long
Your account and what hangs from itWhile you keep it open
After you delete your accountWhat section 6 says is deleted. What the law obliges us to keep is blocked: it is not used for anything, only kept in case an authority or a judge requests it (art. 32 LOPDGDD)
Invoices and billing records6 years, as the Commercial Code requires
Evidence of where you were for VAT purposes10 years, as VAT rules require for the one-stop-shop scheme
Your waiver of withdrawal and your acceptances of the terms5 years, the general limitation period for personal actions
Marketing consent recordWhile you maintain it, and afterwards as proof that you gave it
Your email address after you unsubscribe from marketingKept suppressed, only so that we never write to you again
Session and device records12 months
Unused devices and sessionsExpire on their own after 90 days
Player usage signalsAggregated or pseudonymised after 12-24 months
Record of who accessed your dataWhile you have an account, and afterwards for the time needed to answer for it

The periods that are not imposed by a rule —the 12 months of session records, the 12-24 months of aggregated or pseudonymised usage signals, and the 5 years of the consent and withdrawal-waiver records— are our own criterion: we set them this way because they more than cover the time in which we might need them to answer for a security incident, a fraud or a claim, without keeping the data longer than makes sense. Those for invoices (6 years) and location evidence for VAT purposes (10 years) are imposed by rule and are not negotiable.

5. Your rights

You have the right to access your data, rectify it, erase it, object to some processing, request restriction of processing and request the portability of your data in a structured format.

You can do almost everything yourself, without writing to anyone, from your private area:

  • Download your data. We prepare it in the background and send you a link that is valid for 24 hours and a single use. It counts as access and as portability.
  • Correct your data. Name, language, time zone and preferences, from your profile. The email is changed with double confirmation, in the old inbox and the new one.
  • Object. Half-finished-course reminders and abandonment notices are turned off with a switch in your preferences. Marketing is stopped with the unsubscribe link in any email.
  • Delete your account. From your private area. We ask you for confirmation by email, and when it is done we let you know.

How long we take: one month from your request, as article 12.3 GDPR sets. Account deletion runs step by step through all the systems involved and is not considered finished until every step is done; the confirmation email reaches you at the end, not the beginning.

What is NOT deleted when you delete your account, and why:

What is keptWhy
Your invoices and their tax dataLegal obligation. They are kept 6 years and blocked: only used if the tax authority or a judge requests them from us
The certificates we have already issuedThey keep being verifiable. You can ask for your name not to appear on the verification page
Your address on the mailing listIt goes to suppressed status. It is not fully deleted because it is the only way to guarantee that no future import writes to you again (art. 17.3 GDPR)
The error notices you sent usThey are anonymised: we remove the link to you and keep the notice, which no longer identifies anyone and still serves to fix the content
Aggregated and anonymous metricsThey no longer identify you, there is nothing to delete

If you think we have done something wrong, write to us first. And in any case you can complain to the Spanish Data Protection Agency (www.aepd.es), C/ Jorge Juan 6, 28001 Madrid.

6. Minors

To create an account or buy on the platform you must be 18 years of age or older (decided by Dani on 2026-09-01). At sign-up we ask you to declare it expressly. We do not knowingly create accounts for people under that age; if we detect one, we close it and delete its data.

The LOPDGDD (art. 7) admits valid consent from age 14; 18 is a business decision, not a legal obligation, to avoid the mess of a minor paying with a parent’s card. The same number is in the terms and conditions of sale, section 1.

7. Security

We apply reasonable technical and organisational measures: encryption in transit, role-based access control, a record of who accesses personal data, backups and separation of environments. If a breach occurs that poses a risk to you, we will tell you, and we will notify the Spanish Data Protection Agency within the 72 hours set by article 33 GDPR.

Our procedure for a security breach is: detect it and contain the problem as soon as it is known; assess in the first hours which data and how many people it affects, and what risk it poses to you; if there is a risk to your rights and freedoms, notify the Spanish Data Protection Agency within 72 hours of becoming aware of it (article 33 GDPR), even if we do not yet have all the information —the notification can be completed later—; if the risk is high, also notify you without undue delay, telling you what has happened and what measures to take; and document any breach internally, whether or not we have to notify it (article 33.5 GDPR).

8. If you come from alicebob.io

If you were already a student at alicebob.io, your data has not been transferred to anyone: the controller has always been the same and the only thing that has changed is the platform that hosts it. We told you in the moving email, with the list of new providers and the link to this policy.

9. Changes to this policy

This policy has versions. When we publish a new one that affects you, we show it to you and ask you to accept it the next time you log in; until you do, you can read the text, download your data and delete your account.