Calle Velázquez 15, 1.º derecha, 28001 Madrid, España
Professional registration
Spanish lawyer · ICAM Membership no. 107770
1. Ownership and scope
Education in Spain and Europe is an independent portal under the tolmos.es domain, owned by Luis Manuel Tolmos Rodríguez-Piñero, who is responsible for its operation, direction and editorial publication. This notice applies to educacion.tolmos.es and its English and Spanish editions.
References to public bodies, universities, schools and organisations identify sources or professional connections. The portal is not an official administrative service and does not represent those organisations. The owner's professional connection with Brains International Schools is disclosed in his profile and should be considered when reading material about that group.
The content and services currently offered on this portal are free of charge. Public pages do not require registration; some tools and analyses require free registration activated after email verification. Registration does not create a paid subscription or require a bank card.
Registered access is free, personal and revocable, with no expiry date. New registrations activate after email verification through a link valid for 24 hours. The personal code is shown on screen and emailed. Recovery requires confirming a link valid for 30 minutes, replaces the previous code and closes its sessions. Revoked access needs owner review. A browser session lasts up to seven days; you can then sign in again with your code. Withdrawing analytics permission does not prevent you from requesting or using access.
3. Artificial intelligence and editorial oversight
This portal forms part of Luis Manuel Tolmos Rodríguez-Piñero’s university research. Its content and tools are developed as resources for analysis, public knowledge sharing and teaching support in university research, under his ownership and independent editorial responsibility.
Content is produced with artificial intelligence assistance through OpenAI Sites. Luis Manuel Tolmos determines the project’s approach and assumes editorial responsibility. Individual legal review will be identified with its date only when performed. AI use is expressly disclosed so readers understand the production process.
AI assistance can introduce errors, omissions or inaccurate interpretations, including after human review. Each item's dates, sources and qualifications form part of its context. Using Sites does not mean OpenAI has validated the content or sponsors the portal.
Official and primary sources are prioritised, distinguishing binding rules, proposals, guidance and editorial recommendations. Oversight and editing do not certify absolute accuracy, continuous updating or regulatory compliance in an individual case. Inaccuracies may be reported to the editorial contact.
Publications, executive briefs and applications provide information, education and guidance. They are not individual legal opinions, education inspection decisions, clinical diagnoses or administrative determinations. Professional decisions require assessment of the particular circumstances and applicable official rules and protocols.
If information differs, check the current official text and its territorial and temporal scope. External links retain their own authorship and terms; inclusion does not endorse everything on the linked site. Third-party costs and conditions must be confirmed with the relevant institution.
Safeguarding and wellbeing tools are not reporting channels, emergency services or case-management systems. Do not enter identifying details of children, medical histories or confidential case information. Use the appropriate public service in an emergency and call 112 where appropriate.
Reasonable efforts will be made to correct reported issues and maintain service availability. This notice does not exclude liability imposed by law or restrict rights that users cannot lawfully waive.
5. Authorship, reuse and participation
Free access does not place all material in the public domain. Original human contributions, selection and structure are protected to the extent recognised by applicable law; third-party documents, images, trademarks and publications retain their rights and licences. No exclusive rights are claimed over mere facts, official legislative texts or unprotected material.
You may share public links and make quotations or other uses allowed by law or the source licence, retaining attribution and context. Contact the owner for other reproductions or editorial uses. Impersonation, bypassing access controls and distributing personal access codes are not authorised.
Comments require active access and prior review. Authors authorise publication of their chosen display name or pen name, text and date. Their email and private registration details are not published. Authors can withdraw their own comments. Spam, personal attacks, children's data and unlawful or off-topic contributions will be excluded. Comments remain separate from editorial content. In Community, moderators may award or remove an editorial badge for a useful contribution; it does not certify professional expertise and is not awarded for posting volume.
6. Personal data protection
The data controller is Luis Manuel Tolmos Rodríguez-Piñero. For questions or to exercise your rights, email LUISMANUEL@tolmos.es.
Only information needed for each function is requested. Optional fields are marked. Without required fields that request cannot be processed, but public pages remain available. Consent for enquiries, comments or analytics is specific: registration does not imply permission for promotional messages.
Community public previews only show editorial questions and the number of reviewed contributions. Approved comments and display names are shared with users who have active access; pending or rejected comments are only shown to their author and moderators. Following a discussion stores its topic and date in your account without enabling emails. Unfollow it to delete that preference; it is also deleted when your account is erased. Moderated news comments also require active membership.
Personalisation stores your chosen role, interests, region or scope, education stage, school type and language. Saved content retains its reference and date until removed or erased with your account. Language suggestions use the approximate connection country supplied by the host, without storing the IP here; they do not determine applicable law or override your language choice.
Email verification and recovery
Data
Email address, verification date and single-use links stored as cryptographic hashes.
Purpose and legal basis
Confirm control of the address before activating a new account or replacing its code. Resend receives the recipient and the content of these service emails. They do not create a promotional subscription.
Retention
Links expire after 24 hours (registration) or 30 minutes (recovery). Temporary details are erased when the link is consumed, or during cleanup accompanying new requests after expiry. The verification date is retained with the account.
Personal profile and optional photograph
Data
Name, workspace display name, role, organisation, optional LinkedIn link and optional photograph. Do not provide children’s details or photographs.
Purpose and legal basis
Personalise the account at the user’s request. These details are not automatically published with comments. Profile details are stored in the portal and the image in its private storage; neither is sent to FormSubmit. A LinkedIn link does not sign you in with that network.
Retention
Edit your profile and remove your photo in My account. Data remains while the account is maintained or until you request erasure. Clearing cookies or signing out does not delete the server profile.
Article reads
Data
With analytics consent: a random event identifier per article and browser tab, article and date. The reading record stores no name, email or IP address.
Purpose and legal basis
Rank articles by recorded reads over the last 7 days (consent). These are not unique people, proof of comprehension or certified measurements; blockers and undetected automation may affect counts.
Retention
Events older than 8 days are purged on new reads and excluded from rankings after 7 days. Clearing the browser does not erase previously submitted events.
Most searched topics
Data
Only with analytics permission: a random event identifier, a topic from a fixed list and date. This statistical record does not receive free-text queries and stores no name, email or IP address.
Purpose and legal basis
Show topics with the most recorded searches over 30 days. At most one search per topic and browser tab is counted; topics appear after at least three records. These are indicative counts, not unique users or certified rankings.
Retention
Events leave the ranking after 30 days; records older than 31 days are purged when new searches are recorded. Clearing browser data does not erase events already submitted.
Enquiries and contact
Data
The name, email, role, optional organisation and message you provide.
Purpose and legal basis
Answer your enquiry with your consent (GDPR Article 6(1)(a)). The enquiry is saved in the portal’s private inbox before an owner notification is attempted through Resend when activated, or FormSubmit while the previous service remains in use; direct email is also available.
Retention
While handling the enquiry; afterwards, only as necessary for legal duties or the defence of claims, with restricted access where appropriate.
Access requests and administration
Data
Contact details, role, optional organisation, purpose, language and access status; codes and sessions are verified using protected identifiers. Abuse prevention keeps an hourly IP hash for at most two hours, without storing the original IP.
Purpose and legal basis
Create and manage the free access you request with your consent (GDPR Article 6(1)(a)). The application is stored in the portal; Resend, or FormSubmit while the previous service remains in use, receives the application details included in the notification sent to the owner.
Retention
While processing the application and maintaining access; afterwards, as required by applicable obligations and liabilities. Session expiry or access revocation does not itself erase the application.
News and Community comments
Data
Display name or pen name, text, language, date and account linkage for moderation and withdrawal.
Purpose and legal basis
Publish and manage your contribution with express permission (GDPR Article 6(1)(a)). Comments are stored in the portal, not sent through FormSubmit. Approved news comments are public and may be indexed by third parties. Approved Community contributions are only shown to users with active access; public previews do not include member texts or names.
Retention
While published or awaiting administration. Withdrawal removes the text and display name from the operational record; status and necessary account linkage may remain for security and abuse prevention. Withdrawal does not erase third-party copies.
Preferences and optional history
Data
Your selected education role and interests, saved in your account to organise your workspace; local favourites and selections; if cross-device history is enabled, the tool name and last opening date.
Purpose and legal basis
Personalise recommendations and provide your chosen functions. Your role and interests are not public and do not enable emails. Optional history operates with your consent (GDPR Article 6(1)(a)). History does not include answers, wellbeing results, case information or an exact workflow position.
Retention
Change or clear your role and interests in My access. They remain while you keep that selection in your account. Local data remains until you remove it. Account history is deleted when you switch off its setting in your workspace. Cookie removal does not itself disable or delete account history.
Practical learning for adults
Data
Account link, course edition, completed lessons, attempt count, best score and dates. Selected answers are not retained.
Purpose and legal basis
Save progress and issue a private, non-official completion record with consent given at enrolment (GDPR Article 6(1)(a)). The administrator sees totals and self-declared school groups of at least five participants. This does not create rankings or certify compliance.
Retention
Until you erase progress from Learning or your account is deleted. Earlier editions are kept separately. Clearing cookies or signing out does not erase account records. Withdraw consent by erasing all progress without losing access to other portal services.
Educational self-assessment pilot
Data
Campaign, individual code hashes, selected answers, marking, progress and dates; pupil names and emails are not requested.
Purpose and legal basis
A formative pilot agreed in advance with the school, which informs participants and agrees its use. If the school keeps a pupil-code mapping, data is pseudonymous. The AI module does not send answers to an AI service. No FormSubmit or Google analytics. School registration also stores adult representative details, accepted terms and a separate optional dissemination preference. Luis Manuel Tolmos and the school may analyse the aggregate report for this independent exploratory research; non-identifying dissemination requires the separate permission, which can be withdrawn for future use. Method and conditions: /self-assessment/method.
Retention
Until the school or administrator deletes the campaign at the end of the use agreed with the school. Expiry or revocation does not automatically erase responses. Campaign deletion removes codes, sessions, responses and results from the operational database.
Analytics and security
Data
With analytics permission: cookie identifiers, pages and usage events, browser details and connection data processed by Google. Hosting infrastructure also processes technical data needed to deliver and protect the website.
Purpose and legal basis
Google Analytics measurement relies on consent (GDPR Article 6(1)(a)). Proportionate service protection and abuse prevention rely on the legitimate interest in maintaining security (GDPR Article 6(1)(f)).
Retention
Cookies and consent preferences follow the inventory below. Technical records follow security needs and provider conditions; Google's internal retention depends on service configuration, not the browser cookie.
Services involved
Resend handles email verification, access-code delivery and recovery, and owner notifications when enabled. FormSubmit remains the legacy service for enquiry notifications when Resend is not enabled. The portal checks whether the provider accepts a notification, which does not guarantee final delivery. Copies of enquiries, access requests, permissions and comments are stored by the portal using OpenAI Sites and Cloudflare infrastructure. Hosting, storage and email services support technical delivery; Google receives analytics data when you authorise it.
Each provider's terms describe its own processing. FormSubmit's public policy does not specify processing locations or international transfer safeguards. Form submissions are therefore not represented as remaining exclusively in the EU; direct email lets you avoid delivery through FormSubmit. International providers must be used subject to the safeguards required by the GDPR; accepting this notice does not replace those obligations.
Resend receives the destination address and the content of emails needed for access. Its policy covers processing and transfers to the United States; choosing Ireland as the sending region does not establish that all processing stays within the EU.
You may request access, rectification, erasure, objection, restriction and, where applicable, portability. Consent can be withdrawn without affecting earlier lawful processing. Write from the email linked to your application and specify your request; further identity information will be requested only when necessary. You may complain to the Spanish Data Protection Agency. AEPD.
New free accounts activate automatically after email verification; the owner can revoke them. Comments are moderated before publication. Tool recommendations are guidance and do not make automated decisions with legal or similarly significant effects on users. Forms are intended for adults and must not be used to submit children's data or specially protected information.
7. Cookies and local storage
Your chosen language is remembered in this browser and, when signed in, in your profile. Only with analytics consent, we count page views, registration starts and submissions, saved events, submitted comments and language choices, aggregated by day, language and entry channel. These first-party counters contain no names, emails, IPs or account identifiers. The dashboard also summarises account registrations and verifications retained for account management, independently of analytics consent.
Cookies and local storage are different browser technologies. Necessary storage supports requested access or remembers privacy choices; analytics is optional. Google Analytics and Google Tag Manager are not loaded before analytics acceptance. Browsing, closing a notice or using the services does not constitute acceptance.
tolmos_pilot_session
First party · necessary
Maintains self-assessment pilot access. Protected from JavaScript access.
Duration: Up to 8 hours, limited by campaign expiry.
tolmos-search:*
Session storage · optional analytics
Avoids counting the same search topic twice in a tab, only with analytics permission. Does not store free-text queries.
Duration: Until tab closure or analytics consent withdrawal.
tolmos-reading:*
Session storage · optional analytics
Avoids counting the same article twice in this tab after analytics consent. Records 30 seconds of visible text, not proof of completed reading.
Duration: Until tab closure or consent withdrawal. Portal event identifiers older than 8 days are purged on new reads; excluded from rankings after 7 days.
tolmos_protocol_access
First party · necessary
Maintains the registered workspace session. Protected from JavaScript access.
Duration: Choice valid for 180 days; permission is requested again afterwards.
_ga / _ga_*
Google Analytics · optional
Distinguishes browsers and sessions to measure use. Loaded with Google Tag Manager only after analytics acceptance.
Duration: Google documents a 2-year default; service configuration and browser limits may reduce this.
tolmos-university-* / tolmos-europe-guide:*
Local storage · chosen functions
Comparisons, favourites, explicitly saved orientation results and study checklist progress.
Duration: Until removed in the tool, with the clear-and-leave option or in browser settings.
sidebar_state, when used
First party · functional preference
Remembers the sidebar menu state.
Duration: Up to 7 days.
Analytics may use persistent identifiers and is not described as completely anonymous. Rejection or withdrawal disables measurement and removes accessible analytics cookies on this site. If tags were already loaded, the page reloads to stop them; the change does not erase data previously sent to Google.
The contact form is saved in the portal; email notification is handled server-side through Resend or the legacy FormSubmit service. Social networks and linked websites apply their own policies when opened. Their cookies cannot be erased by this portal.
You can continue without analytics, change your choice or leave the portal. Clear-and-leave signs out this browser, removes local storage and accessible cookies, and asks the browser to clear cache, storage and tolmos.es cookies, including subdomains where supported. It then opens a blank page.
Removal is limited by browser permissions and compatibility. It does not cover third-party cookies, all data on other subdomains, browsing history, downloads or server records. To complete removal, clear tolmos.es website data in browser settings. To erase applications, your account or submitted information, contact the controller.
9. Contact, corrections and legal framework
For portal enquiries, corrections, copyright or data protection requests, contact the owner directly. Include the relevant URL and reason, without children's information or confidential third-party data.
This notice is interpreted under applicable Spanish and EU law, respecting mandatory jurisdiction rules and user rights. Revisions will be reflected in the review date. Updating this text does not legitimise processing that requires fresh consent.
