Last updated: 04/01/2026
1. Introduction
This Privacy Policy explains how FirstClassEnglishResources.com (“the Platform”), operated by Graeme Milling , collects, uses, and protects your personal data. We are committed to handling your data in accordance with the General Data Protection Regulation (GDPR), the Spanish Organic Law 3/2018 on Personal Data Protection and Digital Rights (LOPDGDD), and all other applicable data protection legislation.
By creating an account or using the Platform, you acknowledge that you have read and understood this Privacy Policy.
2. Data Controller
The data controller responsible for your personal data is:
Graeme Milling
Calle Calatayud 6, 2° Izquierdo, Cartagena, Región de Murcia, España
admin@firstclassenglish.com
We do not have a designated Data Protection Officer. For all data protection enquiries, please contact us directly at the email address above.
3. What Data We Collect
When you register for an account, we collect the following personal data:
First name and last name
Country of residence
Username
Email address
Password (stored in encrypted form)
When you subscribe to a paid plan, we additionally process:
Payment information necessary to complete transactions via SWIFT
Subscription tier and billing history
When you use the Platform, we may also automatically collect:
IP address
Login timestamps and session data
Usage data relating to your interaction with the Platform’s content
4. How We Use Your Data
We use your personal data for the following purposes:
Account management: To create and maintain your account and verify your identity.
Service delivery: To provide access to the materials included in your subscription plan.
Payment processing: To manage billing, process payments, and maintain records of transactions via SWIFT.
Communications: To send you transactional emails such as receipts, password resets, and service notifications, and, where you have consented, marketing emails and newsletters about new content and updates to the Platform.
Legal compliance: To meet our obligations under applicable law, including tax and accounting requirements.
Platform improvement: To monitor usage and improve the performance and content of the Platform.
5. Legal Basis for Processing
We process your personal data on the following legal bases under Article 6 of the GDPR:
Performance of a contract (Art. 6(1)(b)): Processing necessary to provide the service you have subscribed to.
Legal obligation (Art. 6(1)(c)): Processing required to comply with applicable law, including financial record-keeping.
Legitimate interests (Art. 6(1)(f)): Processing for the purposes of platform security, fraud prevention, and service improvement.
Consent (Art. 6(1)(a)): Where you have opted in to receive marketing emails or newsletters. You may withdraw this consent at any time by clicking the unsubscribe link in any marketing email or by contacting us at admin@firstclassenglish.com.
6. Cookies and Analytics
SE PUEDE CAMBIAR SEGÚN SI USAMOS ANALYTICS O NO
The Platform may use cookies and similar tracking technologies to monitor usage and improve user experience. This may include the use of Google Analytics, a web analytics service provided by Google LLC. Google Analytics collects anonymised data about how users interact with the Platform.
You can opt out of Google Analytics tracking at any time by installing the Google Analytics Opt-out Browser Add-on.
A full Cookie Policy will be made available on the Platform. [Remove this section entirely if your devs confirm no analytics tools are used.]
7. Marketing Communications
If you have opted in to receive marketing emails, we will use your email address to send you newsletters and updates about new content on the Platform. You may unsubscribe at any time by clicking the unsubscribe link included in every marketing email or by contacting us at admin@firstclassenglish.com. Unsubscribing from marketing communications will not affect the delivery of transactional emails related to your account.
8. Data Sharing and Third Parties
We do not sell your personal data to third parties. We share your data only in the following limited circumstances:
SWIFT, for the purpose of processing subscription payments.
Competent authorities, where we are required to do so by law or legal process.
Any third parties with whom we share data are required to handle it in accordance with applicable data protection law.
9. International Data Transfers
Your data is stored and processed within the European Economic Area (EEA). If any data is transferred outside the EEA — for example, in connection with payment processing — we will ensure that appropriate safeguards are in place in accordance with GDPR requirements.
10. Data Retention
We retain your personal data for as long as your account is active. If you cancel your account, we will retain your data for a period of [3 years / 5 years — confirm with your accountant based on Spanish tax retention requirements] to comply with our legal and accounting obligations, after which it will be securely deleted.
Payment and transaction records may be retained for longer periods where required by applicable tax or financial law.
11. Your Rights
Under the GDPR, you have the following rights in relation to your personal data:
Right of access: You may request a copy of the personal data we hold about you.
Right to rectification: You may request that we correct any inaccurate or incomplete data.
Right to erasure: You may request that we delete your personal data, subject to our legal retention obligations.
Right to restriction of processing: You may request that we limit how we use your data in certain circumstances.
Right to data portability: You may request that we provide your data in a structured, machine-readable format.
Right to object: You may object to processing based on legitimate interests or for direct marketing purposes.
Right to withdraw consent: Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.
To exercise any of these rights, please contact us at admin@firstclassenglish.com. We will respond within one month of receiving your request. You also have the right to lodge a complaint with the Spanish data protection authority, the Agencia Española de Protección de Datos (AEPD), at www.aepd.es.
12. Data Security
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, or disclosure. Passwords are stored in encrypted form and access to personal data is restricted to authorised personnel only. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.
13. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. When we do, we will notify you by email and update the “Last updated” date at the top of this page. We encourage you to review this policy periodically.
14. Contact
For any questions, requests, or complaints regarding this Privacy Policy or the way we handle your data, please contact:
Graeme Milling
admin@firstclassenglish.com