HABLO PILOT NOTICE · APPROVED 27 AUGUST 2026
StudiOS privacy notice
This notice applies to the reduced StudiOS pilot with individual accounts and fictional test data. It will be reviewed again before Hablo imports real student records or activates additional modules.
Who is responsible
HABLO EDUCATION, S.L. (NIF B40562837) is the data controller. Its registered office is C/ Legazpi 23 10 10 - Playa de Gandía 46730 - Gandía - Valencia/València and its legal/privacy telephone is (+34) 689 721 239. Privacy and rights requests use admin@habloeducation.es.
What StudiOS handles
Depending on the user role and stage, StudiOS may handle account identity and security data; contact and enrollment records; course, class, attendance and grade records; payment status; student-journey tasks; uploaded identity, visa, university or supporting documents; parent/guardian relationships; and an audit history of important changes.
Why it is used
StudiOS supports admissions, enrollment, educational delivery, attendance follow-up, student and parent information, payment administration, document exchange, university-access support, account security, and legal or operational recordkeeping. Attendance alerts are reviewed by people and do not make automatic decisions.
Who can see records
Access is limited by individual account and role. Students and authorized parents see only linked student records. Teachers see assigned classes and the minimum records needed for teaching and attendance. Agents see their assigned recruitment records. Hablo staff see records needed for their work. External disclosure to UPV, UNED, authorities, advisers, or service providers must have a documented purpose and legal basis.
Minors and sensitive information
Parent access requires a verified relationship or legal authority and is separately revocable. Where consent is the legal basis for a child under 14, it must come from a parent or guardian. Medical justifications and other sensitive files receive narrower access and should be removed as soon as their approved purpose and review period end.
Retention and rights
Hablo is preparing a record-specific retention schedule. Records are kept only for the approved educational, contractual, security, accounting, legal, or claims period, then deleted or minimized. People may request access, correction, deletion where applicable, restriction, objection, or portability and may contact the Spanish Data Protection Agency. Requests go to admin@habloeducation.es.
Service providers and transfers
The pilot uses OpenAI Sites for hosting and storage, with Cloudflare and other listed subprocessors; Supabase for individual-account authentication in Central EU (Frankfurt); and Hablo's existing IONOS mailbox service for invitation and recovery email. Hablo will maintain the applicable processor, transfer, retention and deletion records. Account email uses neutral link-only wording and contains no grades, attendance details, identity documents, medical information, or attachments.
Source policy: Hablo Data Protection Policy. The operational privacy, attendance and medical-document procedure for this reduced pilot was approved by Hablo on 27 August 2026; DPIA/DPO review remains a separate recorded action before real student data.