Privacy Policy

Privacy Policy

Cookie Policy

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Who we are

For the purposes of the present Legal Notice, ROLALUPA S.L and CAPITAN POMELO are hereinafter referred to as ROLALUPA.

1. ROLALUPA in compliance with Law 34/2002, of 11 July, informs you that its corporate name is ROLALUPA S.L ID number B05508627. Its registered office is at Campus Universitario de Espinardo, 7, 30100; Espinardo Murcia. (Spain). In order to communicate with us, we put at your disposal different means of contact that you will find in our section of Contact.

2. We inform you that the purpose of the website (hereinafter, the 'Web') is to provide the general public with knowledge of the activities carried out by this company and the products and services it provides.

3. Information regarding the products and services offered on the pages of this Web (contracting, characteristics, references to applicable prices, taxes, etc.) is contained on the same page where the product or service is offered.

4. In accordance with the provisions of the law on Protection of Personal Data and the regulations of development, we guarantee the security and confidentiality of data provided by its customers.

5. The intellectual property rights of the Web, its source code, design, navigation structure, databases and the different elements contained therein are the property of ROLALUPA, corresponding to us the exclusive exercise of the rights to exploit them in any form and, in particular, the rights of reproduction, distribution, public communication, making available and transformation.

6. Users are authorized, the partial reproduction of the content of the Web, only and exclusively, if all the following conditions concur:

That it is compatible with the aims of the Web.

That it is carried out with the sole objective and intention of obtaining the information contained for personal and private use, absolutely excluding any purpose or commercial use or for distribution, public communication, transformation or decompilation.

That none of the contents, documents or graphics related to this website are modified in any way.

That no graphic, icon or image available in this Web is used, copied or distributed, separately, of the text or rest of images that accompany it.

7.ROLALUPA is holder of industrial property rights relating to their products and services, and specifically those relating to the registered trademark 'CAPITAN POMELO.

8. Any link from any third party to this site must be to its home page or entry.

9. ROLALUPA does not assume any responsibility derived from the connection or contents of third party links to which reference is made on the Web.

10. Regarding quotations of products and services of third parties, ROLALUPA acknowledges their mere mention or appearance on the Web does not imply the existence of rights or any responsibility whatsoever over them, nor does it imply endorsement, sponsorship or recommendation.

11. The unauthorized use of the information contained in this Web, as well as the injury of the corresponding Intellectual or Industrial Property rights, will give rise to the legally established responsibilities.

12. ROLALUPA reserves the right to carry out modifications and updates of the information contained in its Web or in its configuration and presentation at any time and without prior notice.

13. ROLALUPA does not guarantee the non-existence of errors in the access to the Web, in its content, nor that it is updated, although ROLALUPA will make its best efforts to, where appropriate, avoid, correct or update them.

14. Both access to this website and the use that may be made of the information contained therein is the sole responsibility of the user. The User will be responsible for all actions carried out with their user ID. Specifically, it will be responsible for choosing, as a key and as a reminder of it, passwords and strong phrases, that is, numbers and letters and even, in systems that allow it, punctuation marks and special characters, difficult to guess. In particular, the User will avoid choosing words from the dictionary, words that are related to himself (family name, address, date of birth, etc.) or simple to guess (combinations of names with months, prefixes and suffixes, etc.). ROLALUPA shall not be liable for any consequence, damage or harm that may arise from such access or use of the information.

15. ROLALUPA is not responsible for any possible security errors that may occur or possible damage that may be caused to the computer system of the User (hardware and software), files or documents stored therein, as a result of the presence of viruses in the computer of the User used to connect to the services and content of the Web, a malfunction of the browser or the use of non-updated versions of it.

16. ROLALUPA and the User, expressly waiving any other jurisdiction, submit to the courts of the city of Madrid (Spain) for any dispute that may arise from access to this website.

Privacy Policy

For the purposes of this Legal Notice, ROLALUPA S.L and CAPITAN POMELO are hereinafter referred to as ROLALUPA.

The purpose of the website (hereinafter the 'Web') is to provide the general public with access to the language training services provided by the company ROLALUPA S.L. The use of the Web implies acceptance of this Privacy Policy.

ROLALUPA is committed to protecting your personal data. We tried to write down this Privacy Policy in the most clear and plain language possible. Likewise, we tried to provide you with our privacy commitments in a transparent and easily accessible way. That said, we hope you will get all needed details to be assured your personal data is safe with us.

Before you give us your consent on the processing of your personal data or provide us with your personal data within any form on our website, we kindly ask you to read carefully this Privacy Policy, so we can be sure that you completely understand the conditions under which we would cooperate.

This Privacy Policy applies to your use of the Services of ROLALUPA, as defined in our Terms of Service. ROLALUPA offers you options concerning data we process, use and share as described in this Privacy Policy and Cookies Policy. This Privacy Policy explains when, where, and why we process personal data about people who use ROLALUPA, how we use it, the conditions under which we may disclose it to others, your rights in respect of your personal data, as well as how we keep it secure.


Anyone can access our Website without necessity to provide its personal data. Therefore, limited use of the Services is always possible without the provision of your personal data (for example, browse the Website, check how ROLALUPA works, look through the list of tutors, read the ROLALUPA Blog, review the variety of services etc.). When you are a registered User ROLALUPA may collect from you and process Cookie identifiers and those data you specifically provide us with upon registration, including first name, last name, email, phone number, Skype ID or social network ID (if assigned through Facebook or Google+ or if accessing Google Calendar), time zone, interface language, IP address, and device type, as well.

Specifically, if you are a tutor, we may also collect and process, besides the aforementioned information, the other data provided by you, including zip-code, gender, year of birth, city of living, and education experience. Registered Users may additionally provide us with added profile pictures as well as chosen currency to perform actions pursuant to our Payment Policy. You can find out more about the specific cases of data collection and the purposes of processing of such data in separate section of this Privacy Policy. We may change this Privacy Policy from time to time, so please check this page to ensure that you’re happy with any changes. We will post those changes on this page and update the Privacy Policy modification date at the top of this page. The additional notifications on any amendments will be sent to your email. Any questions regarding this Policy and our services should be sent to

What is personal data and what is processing of personal data. Main definitions Personal data is any information relating to you and that alone or in combination with other pieces of information gives the opportunity to a person that collects and processes such information to identify you as an individual. Processing of the personal data means any operation with your personal data, whether or not by automated means, as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing; means you as a user of Capitan Pomelo.Consent of the data subject/user is any freely given, specific, informed and unambiguous indication of the data subject/user's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

Allow you to access practice, chat or review the subscribed product. Know the progress statistics of the subscribed product, even from your mobile device.

Contact you to give you information about your learning, internships, progress, conversations, certificates, registrations, renewals, offers. These communications can be made by e-mail, telephone or text messages. The form of communication chosen will depend on the reason for the communication.

Manage payments for the products contracted, ROLALUPA keeps banking information for us, so your payment methods will only be useful for managing payments for your subscriptions, registrations, renewals, offers, access to events, buying conversations.

ROLALUPA’s lawful bases for processing ROLALUPA will processes your personal data only when we have lawful bases. Specifically, ROLALUPA processes your personal data if:

• processing is based on the consent you have given;

processing is necessary to provide our services to you according to our Terms of Service which constitute a contract between you and us as regards to information services of ROLALUPA;

processing is necessary for the purposes of the legitimate interests, including, for example, those prescribed by the data protection legislation, those necessary to protect your vital interests or vital interests of another natural person; or for the performance of a task carried out in the public interest or in the exercise of official authority vested in us. As regards this lawful basis, you have the right to object to such processing. In all cases, we will notify you about applied legal basis for processing and other relevant details, before we start processing of your personal data on the specific legal basis, unless we are not able to do so in accordance with our obligations under any applicable legislation.

Data We Collect: ROLALUPA collects from you only the following information and only for the stated below purposes: (a) Account for students ROLALUPA collects and processes personal data submitted by you upon registration and further editing of settings in your Account. For the registration purposes, you submit your login credentials (username and passwords), first name, last name and email. You may edit your Account with additional information at your sole discretion. Additional information may help you to get more from the Services, for instance, finding a necessary tutor. At the same time you are not required to provide additional information, not specifically necessary for the registration, it is your choice. (b) Profile for tutors ROLALUPA collects and processes personal data submitted by you upon registration and further editing of your Profile. For the registration purposes, you submit your login credentials (username and passwords), first name, last name and email. (c) Minors: As a matter of principle, ROLALUPA is directed towards users who have reached the age of majority. Any use by minors without the consent of their legal guardians is prohibited. Lesson Nine therefore reserves the right to delete all data relating to underage users if no consent from the legal guardians is available.

In the event of registration on the platform as a tester, registration on the website and access to the services implies acceptance of this Policy and the conditions established by ROLALUPA on this page for the provision of the test service indicated. Once the trial period has ended, ROLALUPA will provide the user with information on the offers and conditions of the service.The data provided by those interested in ROLALUPA's services, through forms or by subscribing to the Newsletter or trial services, will become part of a file under the responsibility of ROLALUPA S.L., companies domiciled at the Espinardo University Campus, 7, 30100; Espinardo Murcia. (Spain), in order to offer the owner of such data, by any means, information on the services and products marketed by ROLALUPA S.L.

ROLALUPA may also process information provided by you (including content and messages) that you post on/through our Website, including personally identifiable information. By so doing, you acknowledge that any information you share through the Services will be available to ROLALUPA and to other users of the Services (students/tutors). You also acknowledge that parts of your content cannot be deleted from the Service as it may be connected to the Lessons created by you and used by other users (students/tutors). From our turn and unless you opt-out, we retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law. We reserve the right to terminate the accounts of visitors who use these services in a manner inconsistent with the Terms of Service.

Finally, the website may allow, at certain times, the collection of data from candidates in personnel selection processes. In these cases the purpose of the treatment will be limited to the management of these processes.



Espinardo University Campus, 7, 30100; Espinardo Murcia. (Spain). Telephone: +34 617658142. E-mail: Users may exercise at any time before ROLALUPA S.L. their rights of access, rectification, cancellation and opposition with respect to the processing of their personal data and under the terms provided in current law. These requests must be addressed to direcció, indicating the content of the request and providing a copy of a document that validly accredits the identity of the applicant.

COOKIESService Use, Cookies and other Similar Technologies When you use our Services, we monitor and analyze web traffic and keep track of your behavior while using our Services. We may receive the information about your IP address, proxy server and operating system, the web browser or your mobile carrier and location based on phone settings. Please, specifically refer to our Cookies Policy for further details as to our use of cookies and similar technologies. (5) Billing information Details of transactions you carry out through our Website (as ID, date and time of transaction). (6) Enterprise When you wish to share your contact details for more information regarding ROLALUPA Enterprise one-onone online language training for international teams, as name, email, company name and phone number. (7) Sensitive data Unless you expressly agree, Preply does not process your sensitive data. 4. Data We Collect: Purposes We may process your personal data you provided us voluntarily with for the purposes defined below. From our perspective, we process your personal data to personalize the use of ROLALUPA to the fullest extent possible and to provide you with the high-quality Services under the Terms of Service. (1) Provision of Services Primarily, we process your personal data to authorize access to our Services and to fulfill our obligations under the Terms of Service for Services provision. Specifically, we use your personal data upon registration to help others (be it a tutor or a student) to find your account or profile. In order for you to use the Services you will need to provide payment (e.g. credit card details) and billing information pursuant to our Payment Policy through our partners - service providers (payments), which process your personal data encrypted and securely. (2) Payment Services We use third party payment services to bill you through an online account payment in lieu of directly processing your credit/debit card information. Your paid balance for one or more lessons is safe in your account as we use an integrated iframe for checkouts from our partners-payment providers (Braintree, Stripe, PayPal) and tutors get payment for each confirmed lesson. Correspondingly all transactions are secured as our partners-payment providers use SSL encryption protection. All payment information is stored encrypted and securely by Braintree, a PayPal service. We do not store your payment information on our servers. (3) “Tell-A-Friend” For referral service purposes named “Tell-A-Friend”, you may provide your friend’s name and email address. Pursuant to that, we will automatically send your friend a one-time email inviting him or her to visit the Service. ROLALUPA stores this information for the sole purpose of sending this one-time email and tracking the success of our referral program. Of course, your friend may contact us at to request that we remove this information from our database. (4) Communications We may also contact you via email and other ways, including through publicly available notices, for the Services-related purposes (welcoming letter, security and legal notices, announcements, ROLALUPA updates, reminders, suggestions etc.). We could also use your data to enable you to communicate with other users through ROLALUPA. We may contact you by email and other ways, including through publicly available notices, for service related purposes (welcome letter, security and legal notices, announcements, ROLALUPA updates, reminders, suggestions etc.). We may also use your data to enable you to communicate with other users through ROLALUPA. Your contact data (including email, phone number, etc.) may also be used for gathering feedback. We may contact you to participate in research to improve the user experience of our product. The research will be used for internal purposes only, including: -Feature development and product updates; -Marketing activities; -Customer Support updates; -Other service updates for improving your experience. Any other personal data provided in your feedback will not be collected or processed. Your feedback will not be video recorded, audio recorded, or webcast by the Interviewer. Your voice and/or image will not be recorded either. Having received the communications from us, you are always able to opt-out to such communications in each message, excluding legal notices, or change of user settings on ROLALUPA. (5) Marketing We may process your first name, last name and email on our mailing list or for the newsletter and send you messages with some commercial or promotional information about our Services. But don’t worry, you may always opt-out from our marketing messages, using the mechanisms described under the respective link in each message, and through the user settings available on ROLALUPA. (6) Advertising We may process your first name, last name and email in order to occasionally send you information on products, services, special deals, and promotions. You can sign up for these emails from us on our registration page. Out of respect for your privacy, we present the option not to receive these types of communications. (7) Analytics and Development In order to find the points of interest on our Services and for the purposes of analytics, we monitor and analyze web traffic and keep track of your behavior within our Services. This enables us to provide services that are relevant to you and boost the quality of our Services. The data concerned within this activity are Cookies and Usage data, such as the parts of our Services you visit, the date and duration of your visit, and type of the device you used during your visit. All your data stated in this paragraph is collected and further processed in a manner that does not allow your identification. For these purposes, we use Google Analytics for Firebase, Hotjar Heat Maps & Recordings, Amplitude Analytics,, and Intercom, the use of which ensures compliance with our privacy commitments. We may also carry out polls and surveys through ROLALUPA using external GDPR-compliant services. You are not obliged to respond to them and you may opt-out of such polls and surveys through user settings. In order to inform, optimize and serve you relevant advertising based on your past use of our Services, we may process your Usage Data and Cookies. Please, follow our Cookies Policy for additional information. (8) Support In case of any disputes on ROLALUPA and other Services-connected issues, we may use data (including communications) to resolve such matters and/or respond to any complaints. (9) Well-known service providers, such as google analytics, will help us to ensure that your data is secure within ROLALUPA. ROLALUPA has contractors and subsidiaries in other countries, including those outside the European Economic Area, who may have access to your personal data. At the same time, in all cases we pass your personal data to other persons we ensure that your personal data is being protected and used only within the purposes specified in this Privacy Policy. This is achieved by using only certified services and products, signing data processing agreements for protection of personal data with contractors and partners (including the Standard Data Protection Clauses Adopted by the European Commission and compliant with the EU data protection laws), as well as taking technical measures to ensure the information is protected when stored, used and while being processed and transferred. By ticking the respective box when providing us with your personal data you agree to such transfer and processing within the purposes set in this Privacy Policy.

How long will the personal data be processed and stored by ROLALUPA? Your personal data will be stored by ROLALUPA no longer than is necessary for the purposes for which the personal data is processed. Generally, ROLALUPA retains your personal data as long as your account is active. In case your account expires or you decide to delete your account ROLALUPA retains your personal data not longer than 90 days after the account is expired. However, in case of conflict situations in progress ROLALUPA may store personal data for 180 days period or more if the processing is necessary for the establishment, exercise or defence of legal claims and for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject in case of an expired account or in case data subject requested to delete his personal data. Upon the expiry of this period or earlier, if a conflict situation is settled, all personal data gets deleted. In case you are not using your account or profile for more than 180 (one hundred eighty) days following the last payment and\or last activity on Preply, your account will be considered expired and gets deleted. Along with your account or profile all personal data processed by ROLALUPA will be erased. As you are entitled to delete your account or profile after such request it will be permanently removed within 30 days or earlier from our active systems, servers and back-ups. By deleting your account or profile all your personal data will be removed as well within 90 days. As to Personal Data collected when you registered on our mailing list or for the newsletter, will be stored as long as you are interested in receiving our emails. We consider that you’re interested in this until you unsubscribe from the mailing list or from the newsletter by clicking the respective link contained in each of our emails. After the expiration of retention period, ROLALUPA shall terminate the processing of your personal data, unless otherwise is set by the relevant legislation. 7. Your rights as data subject regarding your personal data ROLALUPA processes: a) right of confirmation - to obtain from ROLALUPA the confirmation as to whether or not personal data concerning you is being processed; b) right of access to your personal data processed by ROLALUPA; c) right to rectification – ask ROLALUPA to have incomplete personal data requiring corrections completed; d) right to erasure (right to be forgotten) – request ROLALUPA to erase personal data. In most cases Preply will erase it unless otherwise required by legislation; e) right of restriction of processing. For example, you could contest the accuracy of your personal data or in case ROLALUPA is not interested in processing of your personal data any longer, but you want ROLALUPA to do this for different reasons, for example, to bring some claim for somebody and, instead of the erasure of information, its processing will be just restricted. f) right to data portability - to have your personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others; g) right to object to processing of your personal data by ROLALUPA when the processing is related to the performance of our task carried in the public interest or in the exercise of official authority vested in us. The other case is if we process your data for the purposes of the legitimate interests pursued by us or by a third party and you believe that such interests are overridden by your interests or fundamental rights and freedoms. If you make a request with objection to processing, we will no longer process the personal data unless we are able to demonstrate compelling legitimate grounds for the processing; h) Automated individual decision-making, including profiling. Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, or (3) is not based on the data subject's explicit consent.

After you have logged in (with user name and password), ROLALUPA uses cookies with which you can be identified for the duration of your visit. Cookies are also used generally on the website, e.g. to show ads or to measure the success rates of advertising. Cookies are small files stored on your computer or mobile device which identify the device to our server and also provide additional data. Other technologies such as pixel tags, web bugs, web storage and similar files fulfill the same purpose. A cookie is saved on your computer.

One type of cookie automatically expires after your session has ended. This is called a session cookie. Your user settings, in particular, are saved as session cookies so that ROLALUPA can always be used in the form you require. Another permanently stored anonymous cookie contains the version number of your Flash player. When you log in, you also have the option of saving your user name and password locally in encrypted form on your computer. You can save this cookie permanently for automatic log in with the function “Log me in automatically on this computer”. In addition to this, user settings, such as language selection, language recognition settings, user IDs for various applications, are saved in both session cookies and permanent cookies by ROLALUPA in order to facilitate the use of ROLALUPA.

You switch off the use of cookies for our website or in general in the settings of your Internet browser. You can find out how this functions from the website of your Internet browser supplier. For the Internet Explorer you can find the relevant instructions at, for Firefox at, for Apple Safari at and for Google Chrome at However, deactivating cookies will mean that a number of functionalities, e.g. automatically logging in to the website, will no longer operate as intended.