Marketing Communications Policy

Section 01

Who This Policy Applies To

This Marketing Communications Policy applies to any individual who has provided their email address to Fluensys and who may receive marketing or promotional communications from us. This includes:

Individuals who have completed the Fluensys Skills Check or Proficiency Profile diagnostic and opted in to receive updates
Prospective students who have submitted an enquiry through the website or any intake form
Current or former students who have not opted out of marketing communications
Any individual who has subscribed to Fluensys communications through another channel

This policy covers marketing and promotional emails only. Transactional communications — such as diagnostic results, booking confirmations, and programme-related correspondence — are governed separately by our Privacy Policy and do not require marketing consent.

Section 02

What We Send

Fluensys marketing communications may include:

Educational Content

Study tips, exam preparation guidance, CEFR-level reading and listening resources, grammar explanations, and exam technique articles relevant to Cambridge, IELTS, EOI Catalunya, and TOEFL.

Programme and Service Updates

Information about new or updated Fluensys programmes, changes to pricing or availability, and announcements about new features of the diagnostic tool.

Promotional Offers

Time-limited enrolment offers, discounts on diagnostic access, and referral incentives, where applicable. All promotional communications will be clearly identified as such.

Diagnostic Follow-Up

Where a student has completed the free Skills Check but not yet purchased the Proficiency Profile, Fluensys may send a follow-up communication within 48 hours of the diagnostic submission. This follow-up is sent only where the student has given marketing consent at intake and is limited to one message per diagnostic session.

What we do not send: Fluensys does not send unsolicited commercial email. We do not share your email address with third parties for marketing purposes. We do not send communications on behalf of examination bodies, partner organisations, or any third party.

Section 03

How We Obtain Consent

Fluensys collects marketing consent in accordance with Article 21 of the LSSI-CE and Article 6(1)(a) of the GDPR. Consent is:

Freely given — consent is never a condition of accessing the diagnostic tool or any other service
Specific — obtained separately from acceptance of terms and conditions or the privacy policy
Informed — the nature of communications is described clearly at the point of consent
Unambiguous — obtained via a positive opt-in action; pre-ticked boxes are never used

Consent at the Diagnostic Intake

The first page of the Fluensys Skills Check and Proficiency Profile includes an optional, unticked checkbox with the following wording, or equivalent:

"I would like to receive study tips, exam guidance, and updates from Fluensys by email. I can unsubscribe at any time."

Students who do not tick this box will receive diagnostic results and transactional emails only. They will not be added to the marketing list.

Consent Records

For each subscriber, Fluensys records the date and method of consent, the version of the consent wording presented, and the email address provided. These records are retained for as long as the individual remains subscribed and for a period of three years thereafter, in accordance with our accountability obligations under GDPR.

Section 04

Lawful Basis for Marketing

Activity	Lawful Basis	Notes
Sending marketing emails to new subscribers	Consent (Art. 6(1)(a) GDPR + LSSI-CE Art. 21)	Opt-in required at intake; no pre-ticked boxes
Sending marketing emails to existing students (soft opt-in)	Legitimate interests (Art. 6(1)(f) GDPR) + LSSI-CE Art. 21(2)	Applies only where student has purchased a service and communications relate to similar services. Opt-out must be offered on every email.
Diagnostic follow-up email (within 48 hours)	Consent (Art. 6(1)(a) GDPR) where opt-in was given at intake	Not sent without consent; limited to one message per diagnostic session
Segmenting and personalising communications by CEFR level or exam target	Legitimate interests (Art. 6(1)(f) GDPR)	Uses anonymised diagnostic output only; no special category data

Section 05

How We Use Your Data

For the purposes of marketing communications, Fluensys processes the following data:

Email address
First name, where provided, for personalisation
Exam target and approximate CEFR level, used to send relevant content
Consent date, method, and wording version
Email engagement data such as open and click events, provided by our email platform

This data is used solely to send the communications described in Section 2 and to maintain accurate records of consent. We do not use marketing data to build individual profiles beyond what is necessary to send relevant, appropriately targeted communications.

Marketing data is retained for as long as you remain subscribed. On unsubscription, your email address is suppressed rather than deleted, in order to ensure that no further marketing emails are sent. Suppression records are retained for three years. Full deletion of all marketing data can be requested by contacting us directly.

For full details of how Fluensys handles personal data, including your rights, data transfers, and retention periods, please refer to our Privacy Policy.

Section 06

Your Rights

In relation to the personal data Fluensys holds for marketing purposes, you have the right to:

Withdraw consent at any time, without affecting the lawfulness of processing carried out before withdrawal
Access the personal data Fluensys holds about you, including your consent record
Rectify any inaccurate or incomplete data
Erase your marketing data on request, subject to any overriding retention obligations
Object to processing based on legitimate interests, including the soft opt-in described in Section 4
Restrict processing while a complaint or objection is being resolved
Portability of your data in a structured, machine-readable format on request

To exercise any of these rights, contact us at privacy@fluensys.es. We will respond within one calendar month. If you believe your rights have been violated, you may lodge a complaint with the AEPD at www.aepd.es.

Section 07

How to Unsubscribe

You can stop receiving Fluensys marketing communications at any time using any of the following methods:

Unsubscribe link: Every marketing email sent by Fluensys contains a clearly visible unsubscribe link at the bottom of the message. Clicking this link will remove you from the marketing list immediately.
Email request: Send an unsubscribe request to privacy@fluensys.es from the email address you wish to remove. We will process your request within five working days.

Unsubscribing from marketing communications does not affect your receipt of transactional emails related to any active or past programme with Fluensys, such as results emails, booking confirmations, or invoices.

Processing time: Unsubscribe requests made via the email link are processed immediately by our email platform. Requests submitted by email are processed manually within five working days. During this period, you may receive one further communication if a send was already scheduled before your request was received. This is not a violation of your opt-out request.

Section 08

Third-Party Platforms

Fluensys uses the following third-party platforms in connection with marketing communications:

Resend

Transactional and marketing emails are delivered via Resend, a US-based email delivery platform. Resend processes email addresses and delivery metadata on behalf of Fluensys under a data processing agreement. Resend infrastructure is hosted in the EU where applicable. For details, see Resend's Privacy Policy.

Supabase

Subscriber consent records and associated diagnostic data are stored in Fluensys's Supabase database, hosted in the EU (Ireland). Supabase processes data under a data processing agreement with Fluensys. For details, see Supabase's Privacy Policy.

Future platforms: If Fluensys adopts a dedicated email marketing platform (such as Mailchimp or a comparable service) for campaign delivery, this section will be updated to reflect that change and the appropriate data processing agreement will be in place before any subscriber data is transferred.

Section 09

Changes to This Policy

This policy will be updated if Fluensys changes how it conducts marketing communications, adopts new platforms, or if applicable law requires amendments. Material changes — particularly those that affect the lawful basis for sending or the types of communications sent — will be communicated to active subscribers by email before taking effect.

The version number and effective date at the top of this document will be incremented on each update. Previous versions are available on request.

Section 10

Contact

For any question related to Fluensys marketing communications or to exercise your rights, contact us at:

Email: privacy@fluensys.es

Postal address:CARRER DE ROS DE OLANO 21, BARCELONA, SPAIN 08012

Response time: Within one calendar month of receipt

To lodge a complaint with the Spanish supervisory authority:

Agencia Española de Protección de Datos (AEPD)
C/ Jorge Juan, 6, 28001 Madrid, Spain
www.aepd.es
Telephone: +34 901 100 099