We have previously attempted to contact you both through support and via email at privacy@trimble.com. We did not receive a response through the email channel, and support advised us to submit our inquiry through this forum.
We are currently evaluating SketchUp 2026 for potential use in public educational centers in Spain.
In this context, after reviewing the Trimble Privacy Notice and assessing its alignment with the General Data Protection Regulation (EU) 2016/679 (GDPR) and Spanish data protection law (LOPDGDD), we have identified several aspects that may require clarification, particularly in an educational environment:
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Age-based user distinction: While the policy refers to the 13-year threshold under COPPA and mentions 14+ in an educational context, it does not clearly establish the 14-year threshold required by Spanish law as a standard for EU users.
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Specific policy for minors: We could not identify a clearly differentiated and accessible privacy policy specifically addressed to minors in line with European requirements.
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Purposes of data processing: The policy includes purposes such as behavioral advertising, profiling, and marketing, which do not appear necessary for educational use and may conflict with the principle of data minimization.
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Data subject rights: While most rights are covered, the right not to be subject to automated decision-making (Article 22 GDPR) is not explicitly recognized, and the right to restriction of processing appears only partially developed.
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Transparency and third parties: Although the policy is comprehensive, some aspects (such as categories of data shared with third parties and specific security measures) could benefit from greater clarity.
Given the interest in using your software in certain courses and educational levels, we kindly ask you to review the points outlined above and inform us, where applicable, whether any measures are planned or already in place to ensure full compliance with current European data protection regulations in an educational context.