Privacy Policy
1. General Provisions
ElevatELT wants to offer the best experience through its service; for that reason, we care about the privacy of our users, making this document (the “Policy”) available to inform about the policies and procedures related to the processing of information and personal data collected from users through the website and/or virtual platforms (hereinafter collectively, the “Platform”).
Users who access our services through the Platform agree to be bound by the provisions of this Policy, accept that their personal information will be collected through questionnaires, registrations, electronic forms, and other means provided and/or required virtually on the Platform, and authorize ElevatELT to use and process all information provided to ElevatELT.
ElevatELT reserves the right to modify the Privacy Policy, which will be communicated via email with reasonable advance notice before it takes effect.
2. Definitions
- “Cookie”: The data file stored on the user’s device when they access the Site.
- “Data Processor”: A natural person or legal entity that collects, stores, retains, uses, blocks, or deletes personal data of Users on behalf of SONRISAS ONLINE, by virtue of a legal relationship that binds them and defines the scope of their actions.
- “User” and/or “Users”: Any natural person, natural person with a business, or legal entity that registers on the Platform for the purpose of acquiring courses, products, and/or services offered on the Platform.
- “Platform”: Includes: (i) the website www.ElevatELT.net and (ii) the corresponding mobile device applications. The Privacy Policy applies only to information that Users provide to us through the Platform.
- “External Servers”: We use other companies, agents, or contractors to provide external services. For example, payment processing and other forms of payment, customer support, data analysis and improvement (including information related to our users’ interaction with our service).
- “Personal Data”: Any information about a natural person that identifies or makes them identifiable through reasonably usable means; such as their names, surnames, phone number, email address, and other information that ElevatELT deems appropriate to request in order to adequately provide the services and/or products offered on the Platform.
- “General Information”: Information that, on its own, does not identify the User, but may be required by ElevatELT in order to provide its services.
Hereinafter, the term “Personal Data” shall be understood to refer to both the Personal Information and the General Information provided by Users.
3. What personal information/data do we collect and process?
We also collect User information related to: (i) content shared within the Platform, (ii) course data (product behavior and usage, comments, and created projects), (iii) payment data, (iv) purchase data. ElevatELT may request other Personal Data it deems appropriate at any given time.
Without prejudice to the above, for security reasons, ElevatELT does not collect or store: (i) sensitive cardholder data (such as full credit card numbers or card authentication data), (ii) instructor data, (iii) data about the user’s accounts on other services, unless they are connected to the ElevatELT account.
We use various international payment gateways to process course payments, such as Paypal, Stripe, Apple, Compropago, Ebanx Bank Transfer, Pago Efectivo, PayU, among others, which process all such information. By accepting this Privacy Policy, you agree to share your information with the aforementioned payment gateways. We do not have access to credit card data or information within a Paypal account.
We give Users the option to add more information to their profile. Users may include a profile photo, a brief description, the country and city they are from, their date of birth, and a cover image.
4. Why do we collect and use user data?
ElevatELT will collect and use the information it gathers to: (i) present the Platform and its content; (ii) provide and coordinate with the User information about the services they request; (iii) notify Users of changes to the Platform; (iv) allow Users to participate in interactive Platform features; (v) provide support to Users; (vi) validate the accuracy of the information provided; (vii) update and consult contact details and other relevant information; (viii) handle User inquiries and requests; (ix) manage User preferences regarding their accounts; (x) conduct statistical studies necessary to enhance ElevatELT’s services and improve the User experience, as well as trends and traffic, and to track purchases and usage data; (xi) ensure compliance with information security protocols; among other purposes related to the service provided by ElevatELT to the User; and (xii) facilitate the technical functioning of the services, including troubleshooting, service security, and fraud and misuse prevention.
- System Administration: We may use the User’s Personal Data for the purposes of administering our systems, assisting in the diagnosis of server problems, monitoring system performance and traffic, and gathering demographic information.
- Communication and Advertising: We will use Personal Data to periodically send the User announcements, offers, and advertising about the products offered on the Platform to their email address. If the User consents to receiving unsolicited promotional material, they will click the checkbox “I expressly agree to receive promotional and/or commercial material from ElevatELT”, located at the end of the Policy. Notwithstanding this, if the User accepts the sending of advertising but later wishes to withdraw their consent, they may request that advertising be stopped by emailing info@elevatelt.net.
- Service Providers: If we decide to engage third-party services involving the User’s Personal Data (for example, security services, payment gateways, data management and storage, call centers, among others), we will transfer the User’s Personal Data as necessary for the providers to carry out their services, whether to domestic or international service provider companies. In such cases, those providers are obligated to maintain the confidentiality of the information they have or may have access to, including their employees or subcontractors. It should be noted that ElevatELT will not be responsible for obligations that correspond to Service Providers.
- Other Types of Disclosure: Without prejudice to any contrary provision contained in this Policy, we reserve the right, and the User hereby expressly authorizes us, to share their Personal Information or General Information: (1) in response to subpoenas, court orders, or legal or administrative proceedings of any nature, or to establish, protect, or exercise our legal rights or defend ourselves against claims, administrative proceedings, and investigations of any nature; (2) if we believe it is necessary to investigate, prevent, or take action regarding potentially illegal activities, fraud, or situations involving potential threats to the safety of any person or property; (3) if we believe it is necessary to investigate, prevent, or take action regarding significant abuse of the Platform’s infrastructure, denial-of-service attacks, or attempts to compromise the security of the Information; and (4) if we are acquired or merged with another entity, and in cases of corporate reorganizations, asset sales, or bankruptcy.
- Surveys: We may send to your email address and/or through text messages or any other available means, surveys about the services we provide through the Platform and/or about any other topic of interest to ensure the improvement of our services.
By virtue of the foregoing, ElevatELT will transfer Users’ Personal Information domestically and internationally for the purposes detailed in this section, for which Users provide their informed, prior, and express consent.
5. User Rights
Users may access, rectify, oppose, and cancel their Personal Data (“ARCO Rights”), as well as exercise the other rights granted by law, which may be exercised by submitting a request to the following email: info@elevatelt.net.
ElevatELT’s response to the exercise of ARCO Rights by the User is subject to the provisions and timelines established by the Personal Data Protection Regulatory Framework.
Without prejudice to the foregoing, ElevatELT may retain certain information from a User who requests deletion, in order to serve as evidence in the event of a potential claim against ElevatELT for liabilities arising from the processing of such information. The duration of such retention may not exceed the legal statute of limitations for such liabilities.
6. How can a user request access, rectification, cancellation, and/or opposition of their personal data?
In accordance with ARCO rights, the user has the following rights:
- Right of Access: Allows you to find out whether your personal data is being used in ElevatELT’s database and to request information about the origin of such data.
- Right of Rectification: Allows you to update or complete any missing personal data. You must specify which data you wish to modify or add in the request and attach a supporting document.
- Right of Cancellation: Gives you the ability to request the deletion of your personal data provided that:
- They are no longer necessary in relation to the purpose for which they were collected.
- The term established in your service contract has expired.
- Deletion will not proceed when personal data must be retained for reasons strictly required by applicable law or by the relationship between the data controller and the data subject.
7. Third-Party Processing – Data Processors
Whenever ElevatELT entrusts the processing of personal data to a third party, or allows third parties access to its databases for the provision of a specific service (“Data Processors”), ElevatELT will take into account the following specifications:
- Any processing of Personal Data carried out by a third party other than ElevatELT must be governed by an agreement with the Data Processors (the “Data Processor Agreement”) which expressly establishes that the processing of Personal Data will be carried out following ElevatELT’s instructions and in accordance with the Data Regulatory Framework. Likewise, ElevatELT will establish with the Data Processors that Personal Data will only be processed for the authorized purposes or those set out in the contract, so that the Data Processor will not use it for any other purpose or improperly disclose it to other parties.
- The Data Processor Agreement must stipulate the security measures that the Data Processor is obligated to implement, such as the protection of Personal Data and its return or destruction upon completion of the engagement.
- The Data Processor Agreement must establish that, in the event of non-compliance by the Data Processor, the violating party will be held liable to ElevatELT and to the authorities for any unauthorized processing or use of Personal Data.
- If the Data Processor needs to subcontract parts of the services it agreed to provide to third parties, it must obtain prior authorization from ElevatELT, and this will only proceed if the subcontractor assumes the same obligations as the Data Processor.
- The Data Processor Agreement must also establish confidentiality obligations regarding the information accessed by the Data Processor, with such obligations remaining in force even after the contract term has ended.
8. Incorporation of Personal Data into a Database
In accordance with the Personal Data Protection Regulatory Framework, ElevatELT informs Platform Users that the User’s Personal Information will be incorporated into databases owned by ElevatELT.
The databases will be stored through External Servers and the data retention period will be in accordance with the purpose of its storage. Without prejudice to this, the User hereby authorizes ElevatELT to retain certain information after the purpose has been fulfilled, so that it may serve as evidence in the event of a potential claim against ElevatELT for liabilities arising from the processing of such information.
9. Security Measures
ElevatELT guarantees the protection of Users’ Personal Data and prevents its alteration, loss, processing, and/or unauthorized access, taking into account the nature of the stored data and the risks to which it is exposed, all in accordance with the Personal Data Protection Regulatory Framework.
ElevatELT employs various security measures using industry-standard technology and processes to prevent unauthorized access, misuse, or disclosure. Notwithstanding this, ElevatELT is not responsible for illegal interceptions or violations of its systems or databases by unauthorized parties, nor for the improper use of information obtained through such means, or any illegitimate intrusion beyond ElevatELT’s control and not attributable to it.
ElevatELT is not responsible for any damages or losses that may arise from interference, omissions, interruptions, computer viruses, telephone failures, or disconnections in the operational functioning of the electronic system, or from delays or blockages in the use of the Platform caused by factors beyond ElevatELT.
Likewise, ElevatELT assumes no liability for any damages, fines, or legal actions that may arise as a result of the failure of the External Servers contracted for the Platform to comply with their obligations.
Additionally, the ElevatELT Platform may contain links to other websites; however, it assumes no responsibility for the content of the privacy policies and/or practices of other websites. When a User accesses a link that redirects them to another website, they must accept and be subject to the privacy policy of that website.
10. Cross-Border Data Flows
The servers, providers, and/or computers used by ElevatELT to provide its services may be located outside the country or under another governmental jurisdiction. The User authorizes ElevatELT to transfer, store, and process their Personal Data internationally (“Cross-Border Flow”) in accordance with the provisions of the Personal Data Protection Regulatory Framework, for which they express their prior, informed, free, express, and unambiguous consent.
11. Accuracy of Personal Data
Each User is responsible for the truthfulness, accuracy, currency, and authenticity of the information provided, and undertakes to keep it duly updated. Without prejudice to the foregoing, the User authorizes ElevatELT, if it deems appropriate, to verify the accuracy of the Personal Data provided, through information obtained from publicly accessible sources or from entities specialized in providing such information.
12. Personal Information Requested by Public Authorities
ElevatELT undertakes not to disclose or share the User’s Personal Data without the User’s proper consent, with the exception of information requests from public authorities acting within the scope of their functions and competencies, pursuant to court orders and/or legal provisions.
13. Cookies and Other Information
We use cookies or similar technology to offer you content tailored to your interests and to store your password so that you do not have to re-enter it each time you return to the Platform. It is important to note that we use different types of cookies, data collection tools, profile analysis, and online advertising.
A cookie is a file that is sent for the purpose of requesting permission to be stored on your computer; once you accept the file, the cookie is created and serves to gather information about web traffic and also facilitates future visits to a recurring website. Another function of cookies is that websites can recognize you individually and therefore provide you with the best personalized service.
Our website uses cookies to identify which pages are visited and how frequently. This information is used solely for statistical analysis and the information is then permanently deleted. You can delete cookies at any time from your computer. However, cookies help provide a better website service; they do not give access to information on your computer or about you, unless you choose to share it directly. You may accept or decline the use of cookies; however, most browsers automatically accept cookies as they help provide a better web experience. You can also change your computer settings to decline cookies. If cookies are declined, you may not be able to use some of our services.
14. Consent
Users declare that they have read this Policy in advance and provide their free, express, unambiguous, and informed consent for ElevatELT to process their Personal Data; they also confirm that they have been informed about what information is collected, how it will be collected, and the purpose of collecting their Personal Data.
15. Minors
In the event that ElevatELT collects and processes the Personal Data of minors, as necessary and indispensable for the development of the contractual relationship with the minor User, ElevatELT will inform the data subject and/or their legal guardian about the purposes of processing the Personal Data, in accordance with the provisions of Article 14 of the Personal Data Protection Law.
16. Policy Updates
ElevatELT expressly reserves the right to modify and/or update this Policy at any time, in accordance with regulatory changes or requirements, or due to service-related adjustments made at ElevatELT’s discretion.
Any modification and/or update to this Policy will take effect from the date of its publication on the Platform.
Likewise, ElevatELT will make its best efforts to notify Users of such modifications through their registered email or by posting a notice on the Platform.
17. Assignment of Contractual Position
The User expressly authorizes the assignment of this Policy and of the Personal Data in favor of any person who (i) becomes bound by this Policy; and/or (ii) becomes the new controller of the databases containing the Personal Data.
Following the assignment, ElevatELT will have no responsibility with respect to any events occurring from the date of the assignment. The new database controller will assume each and every one of ElevatELT’s obligations established in this Policy with respect to the processing, safeguarding, and retention of Personal Data.
18. Applicable Law
19. Contact
ElevatELT welcomes any questions, complaints, or comments regarding the Privacy Policy. Please send us an email at info@elevatelt.net.
I declare that after having read the Privacy Policy, I expressly accept all the terms contained therein and further authorize ElevatELT to send me promotional and/or commercial material.
ABOUT US
ElevatELT is a professional English teacher training organization dedicated to empowering educators through innovative, internationally aligned development programs.
Built on over three decades of experience in English language teaching and more than 12 years in teacher education and mentoring, ElavatELT brings together academic expertise, practical classroom knowledge, and a strong commitment to educational excellence.