Privacy Policy

Universidad Católica Digital de Guadalupe · Toledo, Spain

This page explains what data about you we process, why we process it, for how long, and what you may require of us. It is written to be understandable; if anything is not, write to us and we will correct it.

The identifying details of the controller—tax identification number, registered address, registration details, and contact address for data protection matters—are provided below. Everything else in this document derives from the platform's own operation and is accurate.

Who processes your data

• Controller: Universidad Católica Digital de Guadalupe.
• Promoted by: Private association of the faithful «Gaudium de veritate (the joy of truth)».
• Registered office: Toledo, Spain.
• Tax identification number: R4500511C
• Address: Calle Río Cabriel, 1, 45007 Toledo
• Contact for data protection: info@iacampus.es

That address handles everything related to your data. We have not appointed a data protection officer (DPO): Article 37 of the GDPR requires one for public authorities and for anyone who, as a principal activity, regularly and systematically monitors people on a large scale or processes on a large scale special categories of data, and that is not our case. If that ever changes, we will appoint one and state so here.

What data we process and why

You declare the country in a scholarship application yourself. We never infer it from your IP address: geolocating means making an inference about a person, and it is also unreliable. The browser also has access to geolocation, the camera, and the microphone disabled throughout the platform.

Live classes are held through Google Meet, and their recordings pass through Google only in transit. When a professor schedules a live class from the campus, the meeting is created in Google Meet using the university's institutional account (@ucaguadalupe.es, in Google Workspace), and it is recorded and transcribed automatically: Google does this within that account. The recording captures what is seen and heard in the meeting: if you speak or turn on your camera, your voice, your image, and the name under which you enter. Meet places the recording and its transcript in that account's Drive, and they are only stored there in transit: as soon as the campus has the recording in its storage, it deletes it from Drive, along with the transcript document; if Google does not allow it to be deleted at that moment, the system tries again a few minutes later. From then on, there is only one copy, the campus copy, stored on OVHcloud in the European Union, under the same rule as any other recorded class: it is course material, retained while the course exists and deleted with it—or earlier, if the professor removes it from the course material. From the transcript, the campus retains the text and its timestamps for captions, and not who said what; like the transcript of any recorded class, that text is used by the AI as material for preparing the course. And the campus does not record who attended: it does not request the participant list or attendance report from Google, because attendance does not count toward your progress—those who cannot attend do not miss the class: the recording arrives automatically in their session. If you prefer not to appear in it, you can follow the class with your camera and microphone turned off.

If you work with us or provide your image and voice

• Teaching and administrative staff: for the employment or professional relationship, in addition to your account, we retain your identity document, telephone number, address, bank account, contract type, start date, and any notes recorded by the administration.
  Legal basis: performance of the contract and legal obligations (Art. 6(1)(b) and (c)). Nothing from this is published: the faculty website displays your name, category, and department, and the bank account is not shown in full, even in the administration panel.
• Digital twin of a faculty member: if you provide your image and voice so that video classes can be produced using them, we retain your voice samples, video footage, and photographs. We treat them as special-category data (Art. 9 GDPR) as a precaution, and the basis is your explicit consent (Art. 9(2)(a)), given in the transfer agreement, which states the purpose for which you provide them.
  They are stored on OVHcloud in the European Union. You may withdraw it at any time: from that moment onward, nothing new is produced using your image or voice, and anything already published is decided separately with you.

How long we retain them

• Conversations with assistants: 36 months, after which they are automatically deleted. The same applies to what you write in the summaries, responses, and help ladder.
• If you requested information and never enrolled: 24 months.
• Your employment record, if you work here (document, bank account, contract): for the duration of the relationship and 6 years after your departure, which is the retention period for accounting records; it is then automatically deleted.
• Academic record (enrollments, grades, degrees): retained. This is not our decision: there is a legal obligation to retain it, and Art. 17(3)(b) of the GDPR excludes from the right to erasure anything that must be retained by law. Nor do we anonymize it, because an anonymous academic record proves nothing.
• Record of what an AI decided about you (what it corrected and with which model): retained separately from the conversation, because the European Artificial Intelligence Regulation requires that it be possible to reconstruct it.
• Record of governance decisions (the log): which staff member performed which action—created a person's account, validated a grade, issued a degree—and the date. It is retained for as long as the academic record to which it refers is retained, because it is what makes it possible to reconstruct who made the decision. If an account is completely deleted, its name and email address in those entries are replaced with «(deleted person)».

Unenrolling does not mean deleting everything, and it is worth knowing this in advance: when you unenroll, the pedagogical interaction is deleted and your access is closed, but the academic record remains for the reasons stated above, and the employment record remains for the period stated above.

Who else sees your data

To operate, the platform relies on providers that act on our behalf and only for the purposes entrusted to them:

• Instituto Santo Tomás de Educación y Familia S.L. (Pozuelo de Alarcón, Madrid): develops and maintains the platform and, for that purpose, may access the data described here. It does so on behalf of the university and only for that purpose, as a data processor (Art. 28 GDPR).
• Artificial intelligence models (OpenAI, DeepSeek, Anthropic, and Gemini—by Google): receive the text necessary to respond or correct. DeepSeek receives only instructional content, to translate and review it: never anything written by a student or visitor—neither what you ask an assistant, nor your answers to an exercise, nor what you write when requesting information—nor even when another provider fails and a substitute must be used. The purposes for which AI is used, what it decides, and what it does not decide are set out in the AI use policy.
• Google Cloud Text-to-Speech: converts text into speech.
• OVHcloud (European Union): stores class videos and backup copies.
• Hostinger (European Union): is the server on which the platform runs, so it hosts the database containing everything described here.
• buzondecorreo.com: delivers the email we send you and hosts the admissions mailbox, so if you write to us, your message passes through it.
• Google Workspace (by Google): hosts the mailboxes with the university's address, @ucaguadalupe.es. If you write to one of them, your message passes through it. Its institutional account is also used to hold live classes through Google Meet: Google records and transcribes the meeting, and the recording passes through its Drive only until the campus retrieves it, as explained above.

And three things that do NOT process your data, so that the list does not mislead by omission. The automation that handles the admissions mailbox and creates information requests (n8n) is our software running on that same server: it is not a third party, and your message does not leave it. An external service, UptimeRobot, checks every few minutes that the platform responds: it requests a technical address that contains no data about anyone, so it sees nothing about you. And there is not yet a payment gateway: when there is one, it will be identified here before any payment is collected.

There are international transfers, because some of these providers are outside the European Union. The artificial intelligence models are located in these countries: OpenAI (United States), Anthropic (United States), Gemini (United States), and DeepSeek (China). Nothing about you is sent to DeepSeek: only instructional content, as stated above. Transfers to the United States are covered by adequacy decisions and the European Commission's standard contractual clauses.

We do not sell or disclose your data to anyone else, and we do not use third-party analytics: visits to the public-facing site are counted in-house, without an IP address, cookie, or identifier of any kind. The only information stored consists of three daily counters:

• how many times each page has been viewed;
• the site from which it was reached—only the site's name, never the complete address, because a search address would contain what you typed;
• and how many times the website assistant was used, how many questions were asked, and which website page it led to when one of its outputs was clicked, without identifying who asked or what the questions concerned.

We do not know who you are when you view the website.

Cookies

We use three, and all three are technical cookies—the kind the law does not require consent for:

• idioma: remembers which language you prefer to read in.
• session: keeps your session within the campus and also stores the code that protects the public forms—the login form, the registration form, the password-recovery form, and the information-request form. This is why it may appear before you have an account: without it, these forms could not be submitted securely.
• no_contar: only if you request it by visiting any page with ?no_contar=1. It keeps your visits out of the public-facing site's count. It lasts one year and stores nothing other than a «1».

That is why you will not see a cookie banner: there is nothing to consent to.

What we store in your browser

In addition to cookies, the campus remembers a few preferences about how you view the pages on your own device—and not on our servers. They do not leave your browser, we do not receive them, and they do not identify anyone:

• uca-modo-lectura: whether you prefer a light or sepia background.
• campusSidebarCollapsed: whether you have the side menu collapsed.
• avatares_aviso: whether you have already closed a notice on the digital professors screen.

And two drafts, so that you do not lose what you are writing if you reload or close the page. These do contain what you have written, which is why we state: they do not reach us until you submit the form, and they are automatically deleted.

• formulario-pasos:…: what you have written so far in the information-request form—name, email, telephone number, and message. It exists only in that tab: it is deleted when you submit the form and when you close the tab.
• tfg_borrador_…: the comment you are writing to submit with your Final Degree Project. It is deleted upon submission, and one more than two days old cannot be recovered.

You can delete them from your browser at any time; the only consequence is that you will see the pages as they appear by default again, or lose the draft.

Automated decisions

No decision affecting you is made automatically. AI proposes—a correction, a grade, a learning path—and a person always validates it before it counts. Publishing a lesson, finalizing a grade, and issuing a degree require the intervention of a faculty member or the administration. This is what keeps the platform outside Article 22 of the GDPR, and it is explained in detail in the AI use policy.

If you believe an automatic correction is unfair, you may challenge it: a person will review it, and we will respond to you in writing within 10 business days.

Your rights

At any time, you may ask us to access your data, rectify it, erase it, restrict its processing, object to its processing, and take it elsewhere (data portability). If you gave us your consent, you may withdraw it at any time, without affecting anything done up to that point.

You do not need to request access: if you have an account, your user menu contains a “Download my data” option that immediately provides a file containing everything we retain about you—your academic record and your activity on the campus—ready for you to read or take elsewhere. It also states what is not included and why: your account credentials, which are not data that informs you about anything, and the identifier of the person who wrote to you, because your right of access cannot affect the rights of other people.

Nor do you need to request erasure: that same menu contains an “Unenroll me” option that closes your access and deletes anything we are not required to retain. Before asking you, it shows what will be retained and what will be deleted, with the numbers in front of you. What is not deleted is your academic record—your enrollments, grades, and degrees we have issued to you—and this is not our decision: Article 17(3)(b) of the GDPR excludes from the right to erasure anything that must be retained by legal obligation. Nor do we anonymize it, because an anonymous academic record certifies nothing: anonymizing it would be destroying it under another name. If you have no academic record—an account that never reached enrollment—it is deleted in full.

The other rights—rectification, restriction, objection, and portability—are requested from the address above and handled within one month.

If you believe we have not handled this properly, you may file a complaint with the Spanish Data Protection Agency (www.aepd.es). We would appreciate it if you told us first, but you are under no obligation to do so.

Changes to this policy

If we change anything that affects you, we will state it here and—when appropriate—write to you about it. You are reading version 42a55f6782a184a9, which is the version currently in force. That reference is stored with your account when you register, together with the date, so it will always be possible to know which text you accepted.