PRIVACY POLICY
This Privacy Policy is effective as of 15 September, 2023.
Any changes made to this policy will be updated and marked accordingly. We’ll only show the most up-to-date policy, but if you’d like to see any past policies or a summary of changes, just let us know at hello@aprovechar.me.
We know your personally identifiable information (Personal Data) (PII) is important to you, such as your IP address, browser settings, email address, and location; and we believe in transparency. This policy explains our privacy practices for our website, www.AprovecharLanguageSolutions.com, as well as for any personalized event information, coaching, or translation work and/or programs, to be known as “Aprovechar” collectively.
This Privacy Policy applies to information we collect when you use www.aprovecharlanguagesolutions.com and any other websites, mobile applications, or services that post a link to this Privacy Policy (collectively, “Aprovechar”). This Privacy Policy describes how Aprovechar Language Solutions, LLC c/o 5000 Thayer Center, Suite C, Oakland, MD 21550 United States (“Aprovechar”, “Company”, “we” or “us”) collects, uses, and shares Aprovechar-related information about you. This Privacy Policy does not apply to information or data about you collected as received outside of Aprovechar, except to the extent it is combined with information or data collected by us via Aprovechar.
You can request any amendments to Personal Data by clicking here or writing us at hello@aprovechar.me.
WHAT WE COLLECT:
We collect contact information. For example, if you sign up for a mailing list or purchase a service from Aprovechar, you’ll be asked to provide your name, email, general location, and/or cell phone number.
We collect whether you’ve completed automated consent via GDPR, if you live in an area under GDPR.
We collect demographic information. We may collect information like your gender and age, and may also collect your general country of origin and zip code. We collect your time zone when you schedule any appointment via our online calendar.
We collect usage information. We may collect information on what site you came from when you enter Aprovechar or if you opt-in to any of our products or services. If you are using a mobile app or laptop with location services enabled in your device, we may collect location information, including your precise location. We may also collect device identifiers, such as IP addresses or browser information. We also collect email open rates and click-through rates.
We may save this data for up to five (5) years for specific business development purposes.
We do not track any sensitive data, including personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, or biometric data for the purpose of uniquely identifying a natural person, data concerning health or a person’s sexual orientation, or data relating to criminal convictions and offences.
WHERE WE TRACK YOUR DATA FROM:
Online services: this includes this website and/or any tertiary Aprovechar websites (Squarespace or Active Campaign), surveys, and/or social media profiles.
Any inbound outreach: this includes email address and social media messages and/or profile information.
WHAT WE USE YOUR DATA FOR:
Services: We use your Personal Data for consumer service purposes, like responding to your enquiries via email. This helps us be more efficient, answer any questions, and improve or develop new products or services.
Contests, marketing, and other promotions: With your consent where required, we may use your Personal Data to provide you with information about goods or services.
Analytics: We use your data to operate, protect, improve, and optimize the overall Aprovechar experience, and use performance analytics and other data research via cookies and Google Analytics.
Please note that your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. Like many other websites and online services, Aprovechar does not alter its practices when it receives a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track”, please visit https://www.allaboutdnt.com.
DIRECT MARKETING AND OPTING OUT:
Direct marketing may include regular newsletters, direct messages sent over social media platforms, such as LinkedIn, YouTube, Instagram, via Active Campaign, or direct emails.
You may opt out of any of these at any time by any of the following:
via the “Unsubscribe” button at the bottom of the newsletters.
via email at hello@aprovechar.me.
via the “Unsubscribe” form here.
via physical mail at Aprovechar Language Solutions, LLC c/o 5000 Thayer Center, Suite C, Oakland, MD 21550 USA.
I have no plans to transfer any data to a country other than the United States (see more about Third-Party Partners below).
THIRD-PARTY PARTNERS:
Aprovechar works with third-party partners who help me provide and improve our products and services. I don’t sell any of your information to outside parties, and never will. I’ve also imposed strict restrictions on how our partners can use and disclose the data we provide.
Aprovechar uses cookies via Google Analytics to track user behavior, exit sites, and entrance sites. This helps me figure out which topics, products, or services are the most interesting for you.
A cookie is a small file placed onto your device that can enable some features and functionality. For example, cookies allow me to identify your device and help you easily share content from Aprovechar.
The type of data collected by Google Analytics includes entrance and exit pages, time spent on a page, new or returning users, and general (anonymized and consolidated) gender and age demographics.
Any data is completely anonymized and is used strictly for business development purposes.
I don’t use any Google Analytics Advertising Tools or show you any ads.
Aprovechar uses Active Campaign to automate certain products and services, such as downloading free resources, accessing certain webpages, or accessing certain information via emails. This can track your name, email address, and click-through rates.
For more information, including specific requests around Google Analytics, please write us at hello@aprovechar.me.
Both Aprovechar and each social media platform process personal information (for example, name, email address, and assessment results) and are therefore considered separate and independent data controllers of participants’ personal information under EU law. That means that each party is responsible for the personal information it processes in providing any services.
DATA PROTECTION:
Obviously, the protection of your data is important to you and to us. We protect your PII through the following:
We anonymize your data as much as possible. Some data through Google Analytics and Squarespace Analytics are already anonymized, and any other data as far as general location is anonymized to the country of source.
Any data, mailing lists, or the like are stored on a cloud-based password-protected account. We have different passwords for each and change these passwords every 90 days.
Calls may be set up by you. We’ll never request your email through Zoom or other platforms without your verbal and/or written consent.
Any YouTube, LinkedIn.com, or other social media platform information is provided by you. We may message you through these platforms and will not request your email address without your verbal and/or written consent.
Your anonymized data through Google Analytics, Active Campaign, and / or Squarespace Analytics may be exported from the system as we continue our business development efforts. This export is kept on a biometric and password-protected Office 365 account.
We ask for verbal confirmation before recording any video sessions. If we receive that verbal confirmation, the recording is saved to a local folder on a biometric and PIN-protected device. That recording may be saved for business development purposes up to two (2) years.
Any recordings or notes are on a biometric PIN-protected device, and notes that may contain PII (such as location, age, or marital status) are on a password-protected Office 365 account. This information may be saved for business development purposes up to five (5) years.
If you feel uncomfortable about any of the above protections or have any requests for improvement, please write us at hello@aprovechar.me.
ABOUT YOUR CONSUMER RIGHTS:
As a consumer, you have the right to know exactly how we collect your data, what data we collect, how long we store this data for, and how to opt out of it. You also have the following rights under the CCPA, GDPR, and PIPEDA laws:
The right to know about the personal information a business collects about them and how it is used and shared;
The right to delete personal information collected from them (with some exceptions);
The right to opt-out of the sale of their personal information; and
The right to non-discrimination for exercising their CCPA rights.
We respect your consumer rights, and have shared the type of data we collect, how we use this data, and how we share with our third parties. You may request a deletion of all personal information by filling this form here or writing to us at hello@aprovechar.me. Since we do not sell any personal information, the right to opt-out of this sale is not applicable. And we will never discriminate against someone for exercising your privacy rights.
GDPR-SPECIFIC RIGHTS THAT APROVECHAR GRANTS EVERYONE
The right to be informed.
Individuals have the right to be informed about the collection and use of their personal data. This is a key transparency requirement under GDPR.
The right of access.
Individuals have the right to access their personal data and supplementary information. The right of access allows individuals to be aware of and verify the lawfulness of the processing. Click here to request access.
The right to rectification.
Individuals have the right to have inaccurate personal data rectified, or completed if it is incomplete. Click here to request rectification.
The right to erasure.
Individuals have the right to have personal data erased. This right is also known as “the right to be forgotten”. Click here to request erasure.
The right to restrict processing.
Individuals have the right to request the restriction or suppression of their personal data. When processing is restricted, organizations are permitting to store the personal data, but not use it. This right is not absolute and only applies in certain circumstances.
The right to data portability.
Individuals can obtain and reuse their personal data for their own purposes across different services. This right allows individuals to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without hindrance to usability. This right enables consumers to take advantage of applications and services which can use this data to find them a better deal, or help them understand their spending habits.
The right to object.
Individuals have the right to object to:
Data processing based on legitimate interested or the performance of a task in the public interest/exercise of official authority (including profiling);
Direct marketing (including profiling);
Data processing for purpose of scientific/historical research and statistics.
Rights in relation to automated decision and profiling.
This right protects individuals if organizations are carrying out solely automated decision-making that has legal or similarly significant effects on them.
LEGAL BASIS FOR PROCESSING PII:
Under GDPR, there are six legal bases for processing PII:
Consent
Performance of a contract
A legitimate interest
A vital interest
A legal requirement
A public interest
The consent to process data is given by the cookie popup on the Aprovechar website, as well as written or verbal consent to receive marketing materials or any communication from Aprovechar. To withdraw consent at any point, please click here or write to us at hello@aprovechar.me.
Legitimate interest can include something like a marketing activity, where an email address is needed to communicate an upcoming webinar or infographic. It is also necessary to have at least a first name, last name, and email address for full performance of a contract, whether that is for Spanish/English language programs or translation.
At the time of this writing, we do not process nor save data that is a vital interest (required to save someone’s life) or a public interest (a government entity or organization acting on behalf of a government entity).
REPORTING PRIVACY VIOLATIONS:
For those living in the US, you may report privacy violations by the following:
File a complaint with the Office of Civil Rights (OCR).
Listen to recorded information about filing complaints at 1-866-627-7748 (TDD: 1-800-537-7697).
Find out from your state or local consumer agency if your state has laws to protect your privacy.
For those living in countries within the EU, you may
Lodge a complaint with your national Data Protection Authority (DPA) The authority investigates and informs you of the progress or outcome of your complaint within 3 months.
View the full European Commission page here.
While Aprovechar is dedicated to making our services the best they can be, we are not perfect, and sometimes things can go wrong. We ensure the services we provide are in accordance with generally accepted professional practices and standards, and are within the stated objective between any contract we may have with a partner, client and/or partner companies.
LIABILITY LIMITS
In no event shall Aprovechar’s aggregate liability for any damages exceed the amount paid to Aprovechar for the specific project. Some jurisdictions do not allow limitations on incidental or consequential damages, so the above limitation may not apply to you.
ADDITIONAL CODES OF CONDUCT, STANDARDS, TERMS, AND CONDITIONS:
Additional terms and conditions may be given for translation, coaching, speaking, and any programs or courses. You may receive a copy of either by writing us at hello@aprovechar.me. These can cover things such as: basic age limitations, payment, rescheduling or tardiness of appointments, expectations, software and hardware used, and/or material used, among others.
As Aprovechar is still a growing business, we do not currently have any position open of a Data Protection Officer. We hold ourselves to the highest standards possible when it comes to doing business, and am always looking for ways to improve how we do business, including but not limited to meeting facilitation, data collection or privacy, and how to excel at communicating in both English and Spanish. If you have any feedback, please write us at hello@aprovechar.me.
ELIGIBILITY TO USE APROVECHAR
You must be 18 or older to use any Aprovechar. Minors under 18 and at least 13 years of age are only permitted to use Aprovechar with direct consent of a parent or legal guardian. Children under 13 are not permitted to use Aprovechar.