Last update: October 3, 2026
1. Responsible for the processing
| Owner | Association Sodruzhestvo |
| NIF | G65951345 |
| Social address | Via Augusta, 161, 5th A, 08021 Barcelona |
| Headquarters of activity | Carrer de Provença, 102, 1st floor, 08029 Barcelona |
| info@sodruzhestvo.es | |
| Telephone | 93 127 10 40 |
| Website | https://sodruzhestvo.es |
| Registration | Registered in the Register of Entities of the Generalitat of Catalonia (Department of Justice, Rights and Memory) with number 50180, dated April 12, 2013 |
From now on, «the Center». The denominations Russian-Catalan Cultural Center Sodruzhestvo · Friendship, Russian Academy of Music of Barcelona, Domisolca y Top Languages They are trade names under which the Associació Sodruzhestvo carries out its activities.
2. Commitment
The Center processes personal data in accordance with Regulation (EU) 2016/679 (GDPR) and Organic Law 3/2018 on the Protection of Personal Data and the Guarantee of Digital Rights (LOPDGDD). This policy explains what data we collect, for what purposes, on what legal basis and what rights you have.
3. Data we process
Depending on your relationship with the Center, we can handle:
- Identification data: Name and surname, DNI/NIE/passport, date of birth.
- Contact information: postal address, email address, phone number.
- Academic data: instrument or discipline, level, evaluation history, attendance, submitted exams.
- Data from the parents or legal guardians when the student is a minor.
- Economic and billing data: bank details for direct deposit, payment history.
- Image and voice: photographs and recordings of concerts, auditions, classes and cultural activities (see section 6).
- Navigation data: IP address, device type and browser, pages visited (see the Cookie Policy).
We do not process special categories of data (health, ethnic origin, religious beliefs, etc.) unless you voluntarily provide them to us and they are essential for a specific purpose — for example, an allergy or a need for accessibility that we must take into account in class — in which case we will process them with your explicit consent and solely for that purpose.
4. Purposes and legal bases
| Purpose | Legal basis | Data processed |
|---|---|---|
| Manage your information request through forms, email or phone | Consent (Article 6.1.a GDPR) | Identifiers and contact information |
| Conduct the preliminary interview and the level test | Pre-contractual measures (Article 6.1.b GDPR) | Identifiers, contact information, academics |
| Managing enrollment and providing the contracted training services | Execution of the contract (Article 6.1.b GDPR) | Everything necessary for the activity |
| Billing and collecting fees | Execution of a contract and legal obligation (Article 6.1.b and 6.1.c GDPR) | Identifiers, economic |
| Enrolling the student in Trinity College London exams or official tests | Execution of the contract (Article 6.1.b GDPR) | Identification details, date of birth, academic qualifications |
| Registering the participant in the Festival-Competition «Alborada Rusa» or other cultural activities | Execution of the contract (Article 6.1.b GDPR) | Identifiers, contact information, academics, image |
| Comply with accounting, fiscal and administrative obligations | Legal obligation (Article 6.1.c GDPR) | Identifiers, economic |
| Inform students and families about concerts, auditions, schedules, and activities of the Center via email | Execution of the contract when it relates to the contracted activity (Article 6.1.b GDPR); consent for the rest (Article 6.1.a GDPR) | Contact |
| Publish photos and videos of activities on the website and social media | Express and separate consent (Article 6.1.a GDPR) | Image and voice |
| Guaranteeing the security and operation of the website | Legitimate interest (Article 6.1.f GDPR) | Navigation data |
When the legal basis is the consent, You can withdraw it at any time without affecting the legality of the previous processing. When the basis is the legitimate interest, We have assessed that your rights and freedoms do not prevail over that interest, and you can object at any time by writing to us.
5. Data on minors
The Center provides training starting at the age of 2, so it routinely processes data about minors.
- Minors under 14 years old: The treatment requires the consent of the person who holds parental authority or guardianship. When enrolling, the parent or guardian declares that they have the legal capacity to provide it.
- People over 14 years old: They can give their consent themselves for treatments based on that legal basis, without prejudice to the contractual relationship being formalized by the responsible adult.
- The Center does not collect data from minors without the intervention of the responsible adult and does not request any information beyond what is strictly necessary for the training activity.
If you detect that a minor has provided data without the appropriate authorization, please write to us info@sodruzhestvo.es and we will delete it.
6. Images and recordings
The Center's activities include concerts, auditions, festivals, and exhibitions that are graphically documented.
- The capture and publication of identifiable images of students requires express, specific and separate consent of the registration fee, collected through a specific form. In the case of minors, it is paid by the parent or guardian.
- The consent is can be revoked at any time. When we revoke it, we will remove the images from our own channels with the utmost diligence, although we cannot guarantee their removal from copies or reproductions made by third parties in advance.
- No images of minors are published that include data that allow their location (school, home, schedule).
- Images of public events in which attendees are not identified individually may be published under Article 8.2.c of Organic Law 1/1982.
7. Recipients of the data
Your data will not be disclosed to third parties except in the following cases:
Responsible for the processing (service providers who access the data on behalf of the Center, bound by the data processing conditions of Article 28 of the GDPR):
- Hostinger International Ltd. (Lithuania), hosting of the website and email.
- CookieYes Limited (United Kingdom), management of the cookie consent registry.
Assignments based on a legal basis:
- Trinity College London (United Kingdom), for the registration, holding and certification of official examinations, when the student requests them.
- Tax administration and competent public agencies, When there is a legal obligation.
- Banking entity of the Center, For the management of the collection of fees.
The Center does not disclose data to any other third parties, nor does it sell or use them for advertising purposes.
8. International transfers
The hosting of the website and the email is done on servers located in the European Union.
Transfers to Trinity College London and a CookieYes Limited, Both in the United Kingdom, they are relying on the European Commission's adequacy decision of June 28, 2021, which recognizes the United Kingdom with a level of protection equivalent to the European one.
The Center does not make international transfers other than those indicated. You can request additional information by writing to info@sodruzhestvo.es.
9. Retention periods
| Type of data | Time limit |
|---|---|
| Inquiries and requests for non-materialized information | 1 year since last contact |
| Academic data and student file | During the formative relationship and 5 years after its completion |
| Accounting and fiscal documentation | 6 years (Commercial Code) and up to 4 years for tax purposes from the end of the declaration period |
| Data for the sending of communications | Until withdrawal of consent or opposition |
| Images and recordings published | Until the withdrawal of consent |
| Registration of the consent to cookies | 1 year |
After the deadlines have expired, the data are blocked and remain exclusively available to judges, courts and competent administrations during the limitation period for actions, after which they are deleted.
10. Your rights
You can exercise the following rights at any time:
- Access: Knowing what data we process about you.
- Correction: correct inaccurate or incomplete data.
- Elimination: request that we delete your data when it is no longer necessary.
- Opposition: object to treatments based on legitimate interest.
- Limitations: request that we suspend the processing while a claim is being verified.
- Portability: receive your data in a structured and commonly used format, or have them transmitted to another responsible party.
- Withdrawal of consent: at any time and without retroactive effects.
- Not being subject to automated decisions with legal effects. The Center does not perform profiling or take automated decisions.
How to exercise them: Write to info@sodruzhestvo.es or at Via Augusta, 161, 5th A, 08021 Barcelona, indicating the right you exercise and attaching a copy of an identification document. We will respond within a maximum of one month, extendable by two more months in complex cases.
Claim: if you believe that we have not properly addressed your request, you can file a complaint with the Spanish Data Protection Agency (www.aepd.es, C/ Jorge Juan 6, 28001 Madrid) or before Catalan Data Protection Authority (apdcat.gencat.cat).
11. Security
The Center applies appropriate technical and organizational measures to ensure a level of security appropriate to the risk: encryption of communications using an SSL certificate, restricted access to student data to personnel who need it for their role, and periodic backups of the website.
In the event of a security breach that poses a high risk to your rights, we will notify you without undue delay.
12. Accuracy of the data
You guarantee that the data provided is truthful and you agree to inform us of any changes. If you provide data from third parties — for example, from a minor under your care or a family member — you declare that you have their consent or the necessary legitimacy to do so, and you assume the responsibility of informing them of the content of this policy.
13. Modifications
The Center may modify this policy to adapt it to regulatory changes or new services. The current version will always be the one published on this page, with an indication of the date of update. If the changes are substantial, we will notify you using the available contact methods.