Privacy Policy

Privacy Policy

This privacy policy was last updated on the 15th of May Of, 2018.

General Information

In accordance with article 10 of law 34/2002, of 11 July, on services of the Information society and electronic commerce, we provide the following data:

SmartWater Fish Farm Software Solution S.l. Is domiciled in the street Avenida de la Dehesa 23 28250 Torrelodones, Madrid, with CIF B87084760. Registered in the Mercantile Register of MadridVol. 32,637, Folio 100, Section 8, sheet M-587491, inscription 1.

On the web There are a number of informative content on E-Learning.

Although we have not made substantial changes in the way we process the data on our users, we have updated this policy to shorten it and facilitate its reading, as well as to comply with the General regulations on data protection of the EU which Has entered In force on May 25th, 2018.

Thank you for joining the world’s largest online learning virtual Aquaculture Academy. In SmartWater Fish Farm Software Solution S.L. SmartWater, us, We), we respect the user’s privacy and want him to understand how we collect, use and share the data about him. This privacy policy addresses our data collection practices and describes the user’s rights to access, correct or restrict the use we make of the user’s personal data.

Unless we link to a different policy or indicate otherwise, this privacy policy will apply when the user visits or uses the SmartWater Web site, mobile applications, APIs or related services (Services).

By using the services, the user accepts the terms of this privacy policy. The user must not use the services if he does not agree with this privacy policy or with any other agreement that governs the use that makes the services.


  • 1. What data we obtain
  • 2. How we obtain the data about the user
  • 3. What do we use the user’s data for?
  • 4. With whom we share the user’s data
  • 5. Safety
  • 6. Rights of the user
  • 7. Specific rules of the jurisdiction
  • 8. Updates and contact information
  • Cookie Policy


1. What data we obtain

We collect certain user data directly, such as information that it introduces by itself, data on its participation in courses and data from third-party platforms that the user connects to SmartWater Academy. We also collect some data automatically, such as information about the user’s device and the parts of our services that the user interacts with or spends time using.

1.1 data that the user gives us

We can collect different data from the user or on this, depending on how you use the services. Here are some examples to help the user better understand the data we collect.

By creating an account and using the services, including through a third-party platform, we collect the data that the user provides directly to us, including:

Account data To use some features (such as registering for a course), the user has to create a user account. By creating or updating the user account, we collect and store the data that the user provides to us, such as your email address, password, sex and date of birth, and we assign you a unique identification number ("Account Data").
Student Payment Data If the user makes purchases, we collect some data about purchases (such as the user's name and zip code), as needed to process the order. The user must provide some payment and billing data directly to our payment processing partners, such as name, credit card information and the user's zip code. For security reasons, SmartWater It does not collect or store confidential card cardholder data, such as all credit card numbers or card authentication data.
Instructor Payment Data If the user is an instructor, you can link your PayPal account to the services to receive payments. By linking a payment account, we collect and use certain information, such as the email address of the payment account, the account ID, physical address, or other data required to send payments to the user's account. For security reasons, SmartWater Academy does not collect or store confidential information from the bank account. The collection, use and disclosure of the user's payment and billing data are subject to the privacy policy and other terms of the user's payment account provider.
Data on user accounts in other services We will be able to obtain certain information through the social networks or other online accounts of the user if they are connected to his SmartWater account. If the user logs on to SmartWater Through Facebook or another platform or third party service, we will request your permission to access certain information about that other account. For example, depending on the platform or service, we can collect the name, profile photo, account ID number, logon email address, location, physical location of access devices, sex, birthday and The list of friends or contacts of the user.

These platforms or services put the information at our disposal through their APIs. The information we receive depends on the information that the user (through their privacy settings) or the platform or service decides to provide.

If the user accesses or uses our services through a third-party platform or service, or if you click on any third-party link, the collection, use, and sharing of the user's data will also be subject to privacy policies and OTR Agreements of such third parties.
Sweepstakes, promotions and surveys We may invite the user to conduct a survey or participate in a promotion (such as a contest, a sweepstakes or a challenge), either through the services or a third party platform. If you participate, we will collect and store the data that the user provides to us as part of your participation, as your name, Email address, date of birth, or phone number. Such data shall be subject to this privacy policy, unless otherwise stated in the official Rules of the promotion or other privacy policy. The data collected will be used to administer the promotion or survey, including to inform the winners and distribute the rewards. To receive a reward, the user may have to allow us to publish part of his or her information publicly (such as a winner's page). When we use a third-party platform to administer a survey or promotion, that third party's privacy policy will apply
Communications and assistance If the user contacts us to request assistance or report a problem or concern (regardless of whether or not you have created an account), we will collect and store your contact information, messages and other user data, such as your Name, email address, location, operating system, IP address and any other data that you provide or collect through automated media (which we deal with below). We use this data to respond to the user and investigate your doubt or concern in accordance with this privacy policy.

We store the data previously indicated and associate them with the user’s account.

1.2 Data we collect from automated media

When the user accesses services (including course exploration), we collect some data through automated media, including:

System data Technical data on the user's computer or device, such as the IP address, device type, type and version of the operating system, the device's unique identifier, browser, browser language, domain and other system data, and Types of platforms ("System Data").
Usage data Usage statistics on user interactions with services, such as courses you have accessed, time spent on pages or service, pages visited, functions used, search queries, data on The clicks, date and time, and other data related to the use of the services ("Usage Data").
Approximate geographic data An approximate geographic location, including information such as the country, the city and the geographical coordinates, calculated according to the IP address.

The above data is collected by using server log files and tracking technologies, as detailed in the “cookies and data collection Tools” section below. We store them and associate them with the user’s account.

2. How we obtain the data about the user

We will use tools, such as cookies, web signage, Analysis Services and advertising vendors, to collect the above mentioned data. Some of these tools offer the possibility of voluntarily excluding data collection.

2.1 Cookies and data collection tools

As detailed in our Cookie Policy, SmartWater Academy and service providers that act on our behalf (like Google Analytics and third-party advertisers) use server log files and automated data collection tools, such as cookies, tags, scripts, custom links, device or browser fingerprints, and signage Web (as a whole, “Data collection Tools“) by accessing and using the services. When the user uses the services automatically, these data collection tools track certain system data and usage data (as detailed in section 1) and collect them. In some cases, we relate the data collected through these data collection tools with other data that we collect, as described in this privacy policy.

We use cookies (small files that Web sites send to the user’s device to uniquely identify your browser or device, or to store data in your browser) for things such as analyzing the user’s use of the services, Customize your experience, facilitate logon to services, and recognize the user when you return. We use Web signage (small objects that allow us to measure the actions of visitors and users who use the services) for things such as identifying whether a page has been visited, identifying whether an email has been opened and making Advertising in a more efficient way by excluding existing users from certain promotional messages or identifying the source of downloading a new mobile application.

SmartWater Academy Use the following types of cookies:

  • Preferences: Cookies that recall browser data and preference settings that affect the appearance and behavior of services (such as the preferred language).
  • Security: Cookies used to allow logon and access to services; They protect from fraudulent logon and prevent misuse or unauthorized use of the user’s account.
  • Functional: Cookies that store functional settings (such as the volume level that is set for video playback).
  • Session Status: Cookies that track user interactions with services to help us improve the user’s browsing services and experience, to remember logon information and to allow Processing of the purchases of courses that the user performs. are strictly necessary for the services to function properly, so What If you disable them, some features will stop or will not be available.

The user can set the Web browser to alert you of attempts to place cookies on your computer, to limit the types of cookies you allow or to reject cookies in general. If it does, the user may not be able to use some or all of the functions of the services, and their experience may be different or less functional.

Some third-party partners who provide certain features on our site can also use local storage objects (also known as Flash cookies or LSO) to collect or store data.

2.2 Analysis

We use third-party browser and mobile Analysis Services, such as Google Analytics, Hotjar E Intercom, in the services. These services use data collection tools to help us analyze the use of services, including information such as the third party website from which it comes, the frequency with which it visits, the events within the services, The usage and performance data, and the place from which you downloaded the application. We use this data to improve services, to better understand how services work on different devices and to provide information that may be of interest to the user.

2.3 Online Advertising

We use third party advertising services, such as advertising services for Taboo, Facebook and Google, as well as other advertising networks and servers, to offer publicity about our services on other websites and applications that the user uses. The ads can be based on our knowledge of the user, such as their usage data and system data (as detailed in section 1), and the knowledge that these providers of advertising services have on the user according to their data Tracking. Ads can be based on your recent activity or activity over time, and on other sites and services, and can be tailored to your interests.

Depending on the types of advertising services we use, you can place cookies or other tracking technologies on your computer, phone, or other device to collect data about your use of our services, and you can access these technologies from Tracking to provide these custom ads to the user. To help provide personalized advertising, we can provide these service providers with a hidden and anonymous version of the user’s email address (in an unreadable format for the human) and the content they share publicly in The services.

When using mobile applications, the user can also receive custom advertisements in the applications. Apple IOS, Android OS and Microsoft Windows provide their own instructions on how to control advertising Custom in the applications. For other devices and operating systems, the user must review his or her privacy settings or contact the platform operator.

3. What do we use the user’s data for?

We use user data to do things like providing our services, communicating with the user, troubleshooting, protecting from fraud and misuse, upgrading and updating our services, analyzing how people use our Services, offer personalized publicity and as required by law or necessary for reasons of security and integrity.

We use the data we collect through the user’s use of the services to:

  • Provide and manage services, including displaying custom content and facilitating communication with other users;
  • Process requests and orders for courses, products, specific services, information or functions performed by the user;
  • Contact the user about your account at:
    • Answer your questions and concerns;
    • Send you administrative messages and information, such as messages from instructors and assistant professors, notifications of changes in our service and updates of our agreements;
    • Send you information and messages in applications about your progress in courses, rewards programs, new services, new features, newsletters and other available courses (which you can voluntarily exclude at any time);
    • Send Notifications Push To your wireless device to provide updates and other relevant messages (which you can manage on the mobile app’s options or Settings page);
  • Manage account preferences;
  • Facilitate the technical functioning of services, including problem-solving, security of services and prevention of fraud and misuse;
  • Solicit user feedback;
  • Learn more about the user by linking their data to additional data through thirdparty data providers or by analyzing data with the help of analysis service providers;
  • Identify unique users on different devices;
  • Adapt ads to different devices;
  • Improve our services and develop new products, services and functions;
  • Analyze trends and traffic, and track purchases and usage data;
  • Announcing services on third-party websites and applications;
  • As required or permitted by law; Or
  • If, at our absolute discretion, we consider it necessary to guarantee the safety or integrity of our users, employees, third parties, the public or our services.

4. With whom we share the user’s data

We share some data about the user with instructors, other students, companies that provide services, our business partners, data analysis and enrichment providers, social network providers of the user, companies that They help to make promotions and surveys, and advertising companies that help us to promote our services. We can also share user data as needed for security, legal compliance or as part of corporate restructuring. Finally, we can share data in other ways if it is added or depersonalized, or if we obtain the user’s consent.

We may share the user’s data with third parties under the following circumstances or as described in this privacy policy:

  • With the user’s instructors: We share the data we have on the user (except the email address) with the instructors or assistant professors of the courses in which they are registered or on which they request information so that they can improve their courses for the user and For other students. These data can include things like the city, the country, the browser language, the operating system, the device configuration, the site that has taken you To SmartWater Academy And the user’s activities in SmartWater Academy. If we collect Other information about the user (such as age or sex), we can also share. We will not share the user’s email address with the instructors and assistant professors. We will also allow our instructors to implement Google Analytics In the pages of their courses to track the sources of traffic in their courses and optimize those pages.
  • With other students and instructors: Depending on the user’s configuration, the shared content and profile data may be publicly visible, even for other students and instructors. If the user asks a question to an instructor or assistant professor, the user’s information (including its name) may also be publicly visible to other users, depending on the user’s settings.
  • With service providers, contractors and agents: We share user data with thirdparty companies that provide services on our behalf, such as payment processing, data analysis, marketing and advertising services (including revaulting advertising), email services and Accommodation, and customer service and assistance. These service providers can access the user’s personal data and are required to use them only as directed to provide our requested service.
  • With business partners: We have agreements with other websites and platforms to distribute our services and direct traffic to SmartWater. Depending on the user’s location, we will be able to share your data with these partners.
  • With data analysis and enrichment services: As part of our use of third-party analytics tools like Google Analyticsand data enrichment services such as Clearbit, we share certain contact information, account data, system data, usage data (as detailed in section 1) or depersonalized data, as needed. Custom data is those in which we have deleted things, such as the name and email address of the user, and have replaced them with a token-shaped ID. This allows these vendors to provide Analysis Services or relate the User data with information from public databases (including contact and social networking information from other sources) We do this to communicate with the user in a more efficient and personalized way.
  • To drive social networking functions: Social networking features in services (like Facebook’s I like button) will allow the third party social networking provider to collect things, such as the user’s IP address and what services page you are visiting, and set up a cookie to Activate the function. User interactions with these functions will be governed by the privacy policy of the third party company.
  • To manage promotions and surveys: We will be able to share the user’s data as necessary to administer, market or sponsor the promotions and surveys in which he decides to participate, as required by applicable law (such as providing a list of winners or making the files Required) or in accordance with the rules of the promotion or survey.
  • To advertise: If we decide to offer publicity in the future, we will be able to use and share certain system data and use data with advertisers and third-party networks to show general demographic information and preferences. We will also be able to allow advertisers to collect system data through data collection tools (as detailed in section 2.1) and use this data to provide the user with specific announcements in order to customize the experience of the User (through advertising depending on the behavior) and perform web analysis. Advertisers will also be able to share with us the data they collect about the user. For more information or voluntarily opt out of advertising participation according to the behavior of advertising networks, see section 6.1 (User options regarding the use of your data) below. The user must take into account What If it is voluntarily excluded, it will continue to receive generic ads.
  • For security and legal compliance: We may disclose user data to third parties if (at our sole discretion) We believe in good faith that disclosure:
    • is permitted or required by law;
    • It is requested as part of a judicial, governmental or legal investigation, order or process;
    • It is reasonably necessary as part of a subpoena, court order or other legally valid requirement;
    • It is reasonably necessary to enforce our terms of use, our privacy policy and other legal agreements;
    • It is necessary to detect, prevent or combat fraud, misuse, possible violations of the law (or of rules or regulations) or technical or safety problems; Or
    • It is reasonably necessary, at our discretion, to protect against imminent damages to the rights, property or security of SmartWater, of our users and employees, of members of the public or of our services.
    • We may also disclose user data to our auditors and legal advisors to assess our obligations and disclosure rights under this privacy policy.
  • During a change in control: Yes SmartWater Academy You submit to a commercial transaction, such as a merger, acquisition, corporate disinvestment or dissolution (including bankruptcy), or a sale of all or part of your assets, we may share, disclose, or transfer all user data to the Organization Successor during such transition or in consideration of a transition (even during the due diligence process).
  • After aggregation/depersonalization: We may disclose or use aggregate or depersonalized data for any purpose.
  • With the user’s permission: With the user’s consent, we will be able to share data with third parties outside the scope of this privacy policy.

5. Safety

We will use appropriate security measures depending on the type and confidentiality of the data that is stored. As with any Internet-connected system, there is always a risk of unauthorized access, so it is important that you protect the user’s password and that you contact us if you suspect that there has been a non-access Authorized to your account.

SmartWater It takes appropriate security measures to protect against unauthorized access, alteration, disclosure or destruction of the user’s personal data that we collect and store. These measures vary depending on the type and confidentiality of the data. Unfortunately, however, no system can be completely safe, so we cannot guarantee that communications between the user and SmartWater Academy, the services or any information provided to us in connection with the data we collect through the services will be free from unauthorized access by third parties. The user’s password is an important part of our security system, and it is the user’s responsibility to protect it. You must not share your password with third parties, and if you believe your password or account is in jeopardy, you must change it immediately and contact, To report their concerns.

6. Rights of the user

The user has some rights regarding the use of his/her data, including the possibility of voluntarily excluding promotional emails, cookies and the collection of their data by some analysis vendors. You can update or cancel your account from our services, and you can also contact us to make requests for individual rights on your personal data. Parents who believe that we have inadvertently collected personal data about their minor children should contact us to help remove such information.

6.1 User options regarding the use of your data

The user may decide not to provide certain data, but may not use some functions of the services.

  • To stop receiving our promotional communications, the user can voluntarily exclude them through the mechanism to cancel the subscription that is Included in the promotional communication received, or by changing the Email preferences in your account. The user must keep in mind that regardless of the settings of e-mail preferences, we will send you transactions and relationship messages regarding services, such as administrative confirmations, order confirmations, important updates on services and warnings about our policies.
  • The user’s browser or device can allow you to control cookies and other types of local data storage. The user’s wireless device can also allow you to control the collection or sharing of the location or other data. The user can manage the LSO of Adobe through his Site Storage Settings panel.
  • In order to obtain information and control the cookies that are used for the personalized advertising of the participating companies, the user can consult the pages of exclusion of the consumer of the Network Advertising Initiative and the Digital Advertising Alliance, or if it is in the European Union, visit the site Your Online Choices. To exclude advertising displayed on Google or customize ads on Google’s Display network, the user can visit the Google AD Setup Page. To exclude specific ads from Taboo, the user can consult the opt-out link in his or her Cookie Policy.
  • To stop allowing Google Analytics, Hotjar, Mixpanel, ZoomInfo Or Clearbit Use your data for analysis or enrichment, the user can consult the Google Browser Disable Add-on Analytics The Excluding cookies from Hotjar The Excluding cookies from Mixpanel The Policy of ZoomInfo and the Mechanism of data claim Clearbit.

If the user has any doubts about their data, about the use we make of them or about their rights, you can contact us by sending a message to the address

6.2 Access, updating and deletion of user’s personal data

The user can access and update his or her personal data that SmartWater Collects and maintains it as follows:

  • To update the data that the user provides directly, you must log in to your account and update it at any time.
  • To cancel your account:
    • If the user is a student, he/she must visit his/her profile Configuration page and follow the steps indicated Here.
    • If the user is an instructor, you must follow the steps below.
    • If the user has a problem to cancel your account, you should contact us through or through our Support Center.
    • The user must bear in mind that, even after canceling his account, a part or all of his data may still be visible to other users, including, but not only, the data (a) that the user or other persons have copied, stored or disseminated (including in course comments); (b) that the user or other persons have shared or disseminated (including in the user’s shared content); or (c) that have been posted on a third-party platform. Even after you cancel the user’s account, we’ll keep your data while we have a legitimate purpose for do so (and in accordance with applicable law), for example, to help with legal obligations, resolve disputes or enforce our agreements. We may retain and disclose such data pursuant to this privacy policy upon cancellation of the user’s account.
  • To request access, correct or delete the user’s personal data, you must send an email to The answer can take up to 30 days. To protect the user, we may ask you to send the application through the email address associated with the user’s account, and we might need to verify your identity before you carry out the application. The user must keep in mind that we will retain some data if it is legally justified, for example, for the maintenance of compulsory records and for carrying out transactions.

6.3 Our policy on children

We recognize children’s privacy interests and encourage parents and guardians to actively participate in their children’s online activities and interests. Children under the age of 13 (or under 16 in the European Economic Area) should not use the services. If we find that we have collected personal data from children under those ages, we will take reasonable steps to eliminate them.

Parents who believe that Udemy may have collected personal data from children under those ages may submit an application to be removed from the address

7. Specific rules of the jurisdiction

In accordance with article 10 of law 34/2002, of 11 July, on services of the Information society and electronic commerce, we provide the following data:

SmartWater Fish Farm Software Solution S.l. Is domiciled in the street Severo Ochoa 3 Oficina 1A 28232 Las Rozas, Madrid, with CIF B87084760. Registered in the Mercantile Register of MadridVol. 32,637, Folio 100, Section 8, sheet M-587491, inscription 1.

On the web There are a number of informative content on E-Learning.

Its main objective is to provide customers and the general public with information regarding the company, the products and services offered.

8. Updates and contact information

When we make any substantial changes to this policy, we will inform users by email, through a notice on the product or through another mechanism required by law. The changes will enter into force on the day they are published. The user can contact us by email, if you have any questions, concerns or conflict.

8.1 Changes to this privacy policy

Once in a while, we will be able to update this privacy policy. If we make any substantial changes to it, we will inform the user by email, through a notice published in the services or as required by applicable law. We will also include a summary of the major changes. Unless otherwise noted, the modifications will enter into force on the day they are published.

To the extent permitted by applicable law, if the user continues to use the services after the date of entry into force of any change, access to and/or use by the user shall be deemed an acceptance of (and an acceptance to comply and be linked to) the policy of privacy reviewed. The revised privacy policy replaces all previous privacy policies.

8.2 Interpretation

Capital terms not defined in this policy are defined as specified in the Terms of Use Of SmartWater. Any version of this privacy policy in a non-English language is provided for the convenience of the user. If there is a conflict with a version in another language, the user accepts that the English version prevails.

8.3 Questions

If the user has any questions, concerns or conflicts with respect to our privacy policy, you may contact our privacy team (including our responsible for the protection of specific personal information) by sending a message to the address