1.1 We are committed to safeguarding the privacy of our website visitors and service users.
1.2 This policy applies where we are acting as a data controller with respect to the personal data obtained through our website and third party lead gen forms like Wix, Facebook, Linkedin, et. al; in other words, where we determine the purposes and means of the processing of that personal data.
1.5 In this policy, "we", "us" and "our" refer to La Escuelita Costa Rica. For more information about us, see Section 13.
2.1 This document was created using a template from SEQ Legal (https://seqlegal.com/free-legal-documents/privacy-policy).
3. How we use your personal data
3.1 We may process data about your use of our website and services ("usage data"). The usage data may include your geographical location, browser type, and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analyzing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
3.3 We may process your account data. The account data may include your name and email address. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
3.4 We may process information that you post for publication on our website or through our services ("publication data"). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
3.5 We may process information contained in any inquiry you submit to us regarding goods and/or services ("inquiry data"). The inquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
3.6 We may process information relating to transactions, including purchases of goods and/or services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details, your card details, and the transaction details. The source of the transaction data is our payment services provider. The transaction data may be processed for the purpose of supplying the purchased goods and/or services and keeping proper records of those transactions. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
3.7 We may process [information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is our legitimate interests, namely communications with our website visitors and service users.
3.8 Please do not supply any other person's personal data to us, unless we prompt you to do so.
4. Providing your personal data to others
4.1 We may disclose your personal data to our professional advisers insofar as reasonably necessary for the purposes of obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4.2 Your personal data held in our website database will be stored on the servers of our hosting services providers in Wix.com.
4.3 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
5. International transfers of your personal data
5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
5.2 The hosting facilities for our website are situated in Ireland and Portugal. The European Commission has made an "adequacy decision" with respect to the data protection laws of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which you can obtain from https://eugdpr.org/.
5.3 Wix is situated in Ireland.The European Commission has made an "adequacy decision" with respect to the data protection laws of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which you can obtain from https://eugdpr.org/.
5.4 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
6. Retaining and deleting personal data
6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3 We will retain your personal data as follows:
(a) Usage data will be retained for a minimum period of 2 years following the date of collection, and for a maximum period of 5 years following that date.
(b) Account data will be retained for a minimum period of 2 years following the date of closure of the relevant account, and for a maximum period of 5 years following that date.
(c) Publication data will be retained for a minimum period of 2 years following the date when the relevant publication ceases to be published on our website or through our services, and for a maximum period of 5 years following that date;
(d) Inquiry data will be retained for a minimum period of 2 years following the date of the inquiry, and for a maximum period of 5 years following that date;
(e) Transaction data will be retained for a minimum period of 2 years following the date of the transaction, and for a maximum period of 5 years following that date];
(f) Notification data will be retained for a minimum period of 2 years following the date that we are instructed to cease sending the notifications, and for a maximum period of 5years following that date (providing that we will retain notification data insofar as necessary to fulfill any request you make to actively suppress notifications.
6.4 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
7. Your rights
7.1 In this Section 7, we have listed the rights that you have under data protection law.
7.2 Your principal rights under data protection law are:
(a) the right to access - you can ask for copies of your personal data;
(b) the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
(c) the right to erasure - you can ask us to erase your personal data;
(d) the right to restrict processing - you can ask us to restrict the processing of your personal data;
(e) the right to object to processing - you can object to the processing of your personal data;
(f) the right to data portability - you can ask that we transfer your personal data to another organization or to you;
(g) the right to complain to a supervisory authority - you can complain about our processing of your personal data; and
(h) the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
7.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
7.4 You may exercise any of your rights in relation to your personal data [by written notice to us, using the contact details set out below].
8. About cookies
8.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
8.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
8.3 Cookies do not typically contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
9. Cookies that we use
10. Cookies used by our service providers
11. Managing cookies
11.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can, however, obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647 (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) https://help.opera.com/en/latest/security-and-privacy/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
11.2 Blocking all cookies will have a negative impact upon the usability of many websites.
11.3 If you block cookies, you will not be able to use all the features on our website.
12.1 We may update this policy from time to time by publishing a new version on our website.
12.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
12.3 We will notify you of significant changes to this policy by email.
13. Our details
13.1 This website is owned and operated by BLINDSPOT SA.
13.2 We are registered in Costa Rica under registration number 3-101-747766, and our registered office is at Combai Mercado Urbano, local 11.
13.3 Our principal place of business is at Combai Mercado Urbano, local 11.
13.4 You can contact us:
(a) by post, to Combai Mercado Urbano, local 11, postal code 10201, San José, Escazú.
(b) using our website contact form.
(c) by telephone, on 506-4703-0956
(d) by email, using the email address published on our website.