Our Money-Back Guarantee Ensuring you learn Spanish effectively is our number one priority. It’s important that you feel SpanishVIP is the right fit for your needs. If at any point during your first 7 days of service you feel like SpanishVIP is not the right fit for you, you may be eligible for a full refund of your purchase, no questions asked — minus non-refundable fees (see below). Please visit this article for our up-to-date terms of service and refund policy. SpanishVIP PRIVACY POLICY Updated: September 1, 2024 Data Controller: SpanishVIP, Inc., address: 651 N Broad St, Suite 206, Middletown, Delaware USA Email: support@spanishvip.com At SpanishVIP, we are deeply committed to protecting your personal data. We’ve crafted this Privacy Policy in clear and straightforward language to ensure that you can easily understand our privacy practices. Our goal is to be transparent and accessible in communicating how we handle your information, so you can feel confident that your personal data is safe with us. Before you provide your consent for us to process your personal data or share any information through forms on our website, we kindly ask you to review this Privacy Policy carefully. This will help ensure that you fully understand the terms and conditions under which we operate. This Privacy Policy applies to your use of SpanishVIP’s services, as outlined in our Terms of Service. It explains when, where, and why we process personal data of those who use the SpanishVIP platform, how we use that data, the conditions under which we may share it with others, your rights regarding your personal data, and the measures we take to keep it secure. Access to the SpanishVIP platform, including our website, related software, and mobile application, is available both with and without the need to register an account. You can browse our website without registration, allowing you to explore how SpanishVIP works, review our services, read our blog, and learn more about our tutors and offerings. However, to use the SpanishVIP product and services offered, you will need to register an account first. Limited access to our services is possible without providing personal details, but please note that whenever you access our website, we collect log information and use cookies to track your activity. You have the option to opt out of cookies, except for those necessary for the website’s functionality. If you choose to register with SpanishVIP, we may collect and process cookie identifiers along with the data you provide during registration, including your first name, last name, email, phone number, ZOOM ID or social network ID (if linked through Facebook or Google Calendar), time zone, interface language, IP address, and device type. For registered tutors, additional information such as zip code (For timezone purposes), gender, year of birth, city of residence, and educational experience may also be collected and processed. We may update this Privacy Policy from time to time, so we encourage you to check this page periodically to stay informed of any changes. Any updates will be posted here, with the modification date indicated at the top of the page. In addition, we will notify you of significant changes via email. Occasionally, we may experiment with new features on the SpanishVIP platform that could affect the scope, purposes, or other aspects of personal data processing. In such cases, we will provide prior notice and obtain your consent if necessary. If you have any questions regarding this policy or our services, please contact us at support@spanishvip.com. At SpanishVIP, we collect information through the following methods: (i) information you voluntarily provide to us, and (ii) information automatically collected through your use of the SpanishVIP platform. SpanishVIP collects only the necessary information for the following purposes: SpanishVIP collects and processes personal data that you provide during registration and when you update your account settings. For registration, you’ll need to provide your login credentials (username and password), first name, last name, and email address. You may also choose to enhance your account by adding additional information, such as syncing your Google Calendar with your SpanishVIP schedule, which can help you find suitable time slots with tutors and manage your schedule more effectively. Providing additional information is optional and entirely up to you. If you choose to subscribe to the SpanishVIP Blog, we will collect your email address to send you newsletters, updates, and other types of information. (promotional emails, deals, invitations to free events, etc..) We process any personal data that you freely provide on SpanishVIP, including surveys, forms, questions, comments, testimonials, video testimonials, video reviews, and feedback. Additionally, information (including content and messages) that you post on or through the SpanishVIP platform may be processed and made available to other users (students or tutors). Some content you post cannot be deleted if it’s connected to lessons or interactions used by other users. Unless you opt-out, we retain this information as necessary to resolve disputes, provide customer support, and troubleshoot issues, in accordance with applicable laws. We reserve the right to terminate accounts that misuse our services, as outlined in our Terms of Service. When you use our services, we monitor and analyze web traffic and track your behavior on the platform using cookies and similar technologies. For more details, please refer to our Cookie Policy. We process transaction details, such as transaction ID, date, and time, for any payments made through the payment gateways of the SpanishVIP platform. If you’re interested in our business services, we may collect your name, email address, company name, and phone number to provide you with more information about SpanishVIP for Business. Unless you provide explicit consent, SpanishVIP does not process sensitive data nor shall not request you to provide any. We maintain official SpanishVIP pages on social networks like Facebook, TikTok, Instagram, and LinkedIn. When you interact with these pages, such as subscribing or commenting, we may analyze this data to measure the effectiveness of our social media marketing campaigns. Interactions you make with our social media pages may affect your account at SpanishVIP if you’re an active subscriber. During lessons, we may analyze microphone activity to measure your speaking volume and provide an overview of your participation. We do not record your voice, words, or conversation content for this purpose. However, we may record in-session classes for promotional, testimonial, and marketing purposes with your previous consent. To assess your language proficiency, we may process your name, email address, and assessment results. This assessment may occur before or after you register on the SpanishVIP platform. The information of the assessment is completely confidential and will not be shared in any shape or form. We may process your voice recordings, lesson recordings, likenesses, and interactions during group classes, tutoring 1-on-1 lessons, sales calls, webinars, and events. You will always be notified in advance, and your consent will be requested if required. We may process the personal data you voluntarily provide to us for the following purposes. Our primary goal is to personalize your experience with SpanishVIP to the fullest extent possible and to deliver high-quality services in accordance with our Terms of Service. Primarily, we process your personal data to authorize access to our services and to fulfill our obligations under the Terms of Service. Specifically, we use your personal data during registration to help others, whether a tutor or a student, find your account or profile, schedule sessions, participate in lessons, and track your learning progress. To use our services, you will need to provide payment details (e.g., credit card information) and billing information through our trusted third-party payment providers. These providers securely and encryptedly process your personal data. For more details, please refer to our Refund and Payment Policy. We may also request that you complete a language assessment test to determine your level of language proficiency and better tailor our services to your needs. For companies using SpanishVIP’s Business Services, we process the personal data of their Authorized Users to create accounts, enable access to services, provide language assessments, track learning progress, and report on language proficiency. Please note that without the information you provide under our Terms of Service, we cannot offer the full functionality of the SpanishVIP platform. This includes connecting you with other users, enabling communication, and facilitating lessons. We use trusted third-party payment providers to handle payments through an online account, ensuring that your credit or debit card information is not directly processed by us. Your paid balance for one or more lessons is securely stored in your account, as we utilize an integrated iframe for checkouts provided by our payment partners. Tutors receive payment for each confirmed lesson securely through these third-party payment providers. All transactions are secured using SSL encryption protection, ensuring that your payment information is safely processed. Payment information is encrypted and securely stored by our payment partner. Please note that all payment gateways for SpanishVIP should originate only from our official domains: spanishvip.com, go.spanishvip.com, or academy.spanishvip.com. If you are directed to any other site for payment, please contact our support team immediately. Additionally, we may use your payment card transaction data, as shared by our third-party service providers, to confirm that a specific transaction occurred and that you qualify for any promotional offers. For example, we might use the date and amount of your purchase and the last four digits of your card number to verify the transaction against our records. For our referral program, we may generate a personalized referral link for you to share with your friends who might be interested in SpanishVIP. We do not collect your friend’s personal data until they follow the link and access the SpanishVIP platform. For our B2B referral program, you can share the name, job position, and email address of colleagues who may be interested in SpanishVIP Business Services. We will notify your colleagues that we have received their personal data through our referral program at the time of our initial contact. We may contact you via email and other channels, including publicly available notices, for service-related purposes. These communications may include welcome letters, security and legal notices, announcements, updates about SpanishVIP, reminders, suggestions, and other relevant information. We may also use your data to facilitate communication between you and other users on the SpanishVIP platform, such as exchanging messages, conducting video calls, and leaving feedback. You may also receive push notifications through the SpanishVIP mobile application “SpanishVIP Academy”. These notifications can be adjusted using the internal settings on your smartphone. If you receive communications from us, you will always have the option to opt out of such communications via a link provided in each message, with the exception of legal notices, essential reminders, notifications, or changes to your user settings on SpanishVIP. Your contact information (including email, phone number, Skype name, etc.) may be used to gather feedback and invite you to participate in research aimed at improving the user experience of our services. This research is conducted for internal purposes only, including: Please note that your feedback will not be video recorded, audio recorded, or webcast without first obtaining your explicit consent. This consent will also be required if your voice and/or image is to be recorded during the research process. We may process your first name, last name, and email address to include you on our mailing list or in our newsletter, sending you commercial or promotional information about our services. Rest assured, we will always request your consent first, and you can opt out of our marketing messages at any time using the mechanisms provided in each message or through the user settings available on the SpanishVIP platform. If you provide us with your phone number, we may also contact you with commercial or promotional information about our services. To promote the SpanishVIP platform through our blog and influencer channels, we offer an affiliate program on our website. If you choose to participate in this program, we will process your information to register you as an affiliate and track the progress of your promotional efforts. With your consent, we may use your postal address in connection with search engine marketing and optimization. Please note that any feedback you provide may be used by SpanishVIP as described in Section 12 of our Terms of Service. This feedback may be utilized for promotional purposes without any additional compensation to you. We may use third-party services, such as Captiv8, Inc. and LiveRamp Holdings, Inc., to analyze the information you provide at the time of registration (such as your name and other identifiers). These services help us perform a matching exercise to identify our most influential students for potential collaboration opportunities with SpanishVIP. As part of this process, we may receive additional personal data from Captiv8, Inc., such as your social media profiles, and establish a joint controllership over your data. If we discover that you are an influencer and decide to propose a collaboration, we will provide you with a detailed privacy notice explaining this processing activity. At SpanishVIP, we take your privacy seriously and ensure that your personal data is shared only as necessary to provide and improve our services, comply with legal obligations, or for other legitimate purposes as described below. We may share your personal data with third-party service providers that assist us in delivering our services. These providers include, but are not limited to: All third-party service providers are required to use your personal data only for the specific services they provide to SpanishVIP and must comply with strict data protection requirements. If you connect your SpanishVIP account with social media platforms (e.g., Facebook, Google), or engage with our content on social networks, we may share your data with these platforms. This may include sharing certain profile information or activity data to enhance your user experience, facilitate logins, or promote our services. Please note that interactions with social media platforms are governed by their own privacy policies. In the event that SpanishVIP undergoes a business transaction such as a merger, acquisition, reorganization, or sale of assets, your personal data may be transferred as part of that transaction. If such a transfer occurs, we will notify you and provide you with any options regarding your data as required by applicable law. For companies that utilize our Business Services, we may share the personal data of Authorized Users with the respective company to facilitate the provision of our services. This may include sharing language assessment results, progress reports, and other relevant information to help the company monitor the effectiveness of the language training provided to their employees. We may share your personal data with independent contractors who work with SpanishVIP to deliver specific services, such as language tutors or curriculum developers. These contractors are bound by confidentiality agreements and are only permitted to use your data to perform services on our behalf. Your personal data may be shared with other users of the SpanishVIP platform in limited circumstances. For example, when you interact with tutors or students on the platform, certain information, such as your profile details, may be visible to them. Additionally, if you participate in community features, such as forums or group lessons, your interactions may be visible to other participants. Your personal data will be stored by SpanishVIP for no longer than necessary to fulfill the purposes for which it was processed. Generally, SpanishVIP retains your personal data as long as your account is active. If there has been no activity on your SpanishVIP account for more than 2 years, your account will be considered inactive. In such cases, or if you decide to delete your SpanishVIP account, we will remove your personal data from our active systems and servers within 90 days, or sooner if required. In the event of ongoing conflicts or legal disputes, SpanishVIP may retain your personal data for a longer period to establish, exercise, or defend legal claims. Once the conflict is resolved, all related personal data will be deleted if the standard retention period has expired. We may also retain certain personal data for a longer period if necessary to comply with applicable legal, regulatory, tax, accounting, or other requirements. For personal data collected when you registered on our mailing list or for our newsletter, it will be stored as long as you remain interested in receiving our communications. We will consider you interested until you unsubscribe from the mailing list or newsletter by clicking the link provided in each email. After the expiration of the retention period, SpanishVIP will terminate the processing of your personal data unless otherwise required by applicable legislation. As a data subject, you have certain rights regarding the personal data processed by SpanishVIP. These rights include: You have the right to obtain confirmation from SpanishVIP as to whether personal data concerning you is being processed. You have the right to access your personal data processed by SpanishVIP. This allows you to understand how your data is being used and verify its accuracy. You have the right to request that SpanishVIP corrects any incomplete or inaccurate personal data. If any of your personal information needs to be updated or corrected, you can request that these changes be made. You have the right to request the erasure of your personal data. In most cases, SpanishVIP will delete your data unless there is a legal requirement to retain it. To delete your personal data, you must: You have the right to request the restriction of processing your personal data in certain circumstances. For example, if you contest the accuracy of your personal data or if you want SpanishVIP to retain your data for specific reasons (such as bringing a claim against someone), even if SpanishVIP no longer needs the data for processing. In such cases, instead of erasing your data, its processing will be restricted. You have the right to request that your personal data be transmitted directly from one controller to another, where technically feasible, and when doing so does not adversely affect the rights and freedoms of others. You have the right to object to the processing of your personal data in certain situations: For example, you can object to the use of your data for AI training in your account settings. If you raise an objection, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing. You have the right to withdraw your consent for the processing of your personal data at any time by contacting us. Once we receive your withdrawal request, we will process it promptly and cease processing your personal data unless otherwise required by law. If any of the aforementioned rights apply to you, please contact us as instructed at the end of this Privacy Policy. We will ensure that your request is handled promptly and without charge. If you believe that our use of your data violates your rights, you have the right to lodge a complaint with the relevant data protection authority. Please note that if your personal data is being processed for direct marketing purposes, you have the right to object to such processing at any time, without providing any justification. Upon receiving your objection, we will cease processing your data for direct marketing purposes. We process your personal data both within and outside of the United States. Although the countries where we process data may have different laws, we take measures to ensure high standards of data privacy and compliance. These measures include adhering to the protections outlined in Section 5 of this Privacy Policy. SpanishVIP will respond to your requests related to your data subject rights within one month of receiving the request. In cases where we are overwhelmed by the number of requests or if the request is particularly complex, this period may be extended by up to two additional months. We will inform you of any such extension within one month of receiving your request and provide the reasons for the delay. SpanishVIP takes technical and organizational measures to ensure that your personal data is processed securely. This includes protecting against unauthorized or unlawful processing, as well as accidental loss, destruction, or damage. For example, we work with verified contractors who may have access to your data under strict data processing agreements. In exceptional circumstances, such as when customer support is required, our support specialists may need to access your account. This access allows them to view personal data submitted to your account, including scheduled events if your Google Calendar is synced with the SpanishVIP platform. We will always ask for your permission before accessing your account for troubleshooting. If you prefer, you may edit your Google Calendar privacy settings before granting access. Please note that refusing access may affect the time and quality of customer support. The privacy of children is a priority for us. SpanishVIP services are not intended for use by children under the age of 18 without the supervision of a parent or legal guardian. If you are under the age of 18 but at least 13 years old, you must have a parent or legal guardian set up an account on the SpanishVIP platform, which you may use under their supervision. We do not knowingly collect information from children under the age of 13 and discourage their use of SpanishVIP services. We encourage parents and legal guardians to monitor their children’s internet usage and help enforce our Privacy Policy by instructing them not to provide personal information on the SpanishVIP platform without permission. If a personal data breach occurs that is likely to result in a high risk to your rights as a data subject, we will inform you and the respective data protection authorities of the incident without undue delay. We will also take steps to minimize any such risks. SpanishVIP does not share personal data with third parties for their direct marketing purposes, and our services do not support “Do Not Track” requests. As part of the SpanishVIP platform functionality, we may process the personal data of our tutors and students in ways that may involve profiling. For example, we use machine-learning algorithms to analyze various data metrics and determine tutor rankings and visibility to students. This is done to improve the matching efficiency between students and tutors on the platform. Please note that this type of processing is necessary to provide our services. If you wish to request human intervention, express your point of view, or contest decisions made by algorithms, please contact us at support@spanishvip.com. SpanishVIP does not sell your personal data, nor will ever sell your personal data in any way shape or form. The Website works with Mediavine to manage third-party interest-based advertising appearing on the Website. Mediavine serves content and advertisements when you visit the Website, which may use first and third-party cookies. A cookie is a small text file which is sent to your computer or mobile device (referred to in this policy as a “device”) by the web server so that a website can remember some information about your browsing activity on the Website. First party cookies are created by the website that you are visiting. A third-party cookie is frequently used in behavioral advertising and analytics and is created by a domain other than the website you are visiting. Third-party cookies, tags, pixels, beacons and other similar technologies (collectively, “Tags”) may be placed on the Website to monitor interaction with advertising content and to target and optimize advertising. Each internet browser has functionality so that you can block both first and third-party cookies and clear your browser’s cache. The “help” feature of the menu bar on most browsers will tell you how to stop accepting new cookies, how to receive notification of new cookies, how to disable existing cookies and how to clear your browser’s cache. For more information about cookies and how to disable them, you can consult the information at All About Cookies. Without cookies you may not be able to take full advantage of the Website content and features. Please note that rejecting cookies does not mean that you will no longer see ads when you visit our Site. In the event you opt-out, you will still see non-personalized advertisements on the Website. The Website collects the following data using a cookie when serving personalized ads: Mediavine Partners (companies listed below with whom Mediavine shares data) may also use this data to link to other end user information the partner has independently collected to deliver targeted advertisements. Mediavine Partners may also separately collect data about end users from other sources, such as advertising IDs or pixels, and link that data to data collected from Mediavine publishers in order to provide interest-based advertising across your online experience, including devices, browsers and apps. This data includes usage data, cookie information, device information, information about interactions between users and advertisements and websites, geolocation data, traffic data, and information about a visitor’s referral source to a particular website. Mediavine Partners may also create unique IDs to create audience segments, which are used to provide targeted advertising. If you would like more information about this practice and to know your choices to opt-in or opt-out of this data collection, please visit National Advertising Initiative opt out page. You may also visit Digital Advertising Alliance website and Network Advertising Initiative website to learn more information about interest-based advertising. You may download the AppChoices app at Digital Advertising Alliance’s AppChoices app to opt out in connection with mobile apps, or use the platform controls on your mobile device to opt out. For specific information about Mediavine Partners, the data each collects and their data collection and privacy policies, please visit Mediavine Partners. Data Collected: Stores user-uploaded avatars for user profiles, which include personal data like images. Data Collected: Collects personal data such as names, addresses, and contact information during the checkout process. Data Collected: Collects personal data submitted through forms, including names, email addresses, and messages. Data Collected: Optimizes and compresses images uploaded to the site, which may include personal data if the images contain identifiable information. Data Collected: Transfers personal data from form submissions, such as names, emails, and messages, to the HubSpot CRM. Data Collected: Collects personal data and cookies to serve personalized ads, including browsing activity and demographic information. Data Collected: Collects personal data through surveys, such as names, contact information, and responses. Data Collected: Collects personal data such as names, email addresses, and other information entered into forms. We hope this Privacy Policy helps you understand how your personal data will be handled at SpanishVIP. We are committed to protecting your privacy so you can use our services with confidence. If you have any questions, feel free to contact us at support@spanishvip.com. Your SpanishVIP Team
Privacy & Cookie Policy
Introduction to Our Privacy Policy
GENERAL
1. How We Collect Information
3. Data We Collect: Scope
(1) Account for Students
(2) Subscription to the SpanishVIP Blog
(3) Posting of Information
(4) Service Use, Cookies, and Other Similar Technologies
(5) Billing Information
(6) SpanishVIP for Business
(7) Sensitive Data
(8) Pages on Social Networks
(9) Analysis of Speech Activity
(10) Language Assessment
(11) Video Lessons, Sales Calls, Events, and Webinars
4. Data We Collect: Purposes
(1) Provision of Services
(2) Payment Services
(3) Referral Programs
Refer your Friend Program
B2B Referral Program
(4) Communications
(5) User Research
(6) Marketing and Promotion of SpanishVIP
(7) Identifying Influencers for Potential Collaborations
5. How Is Personal Data Shared?
(1) Categories of Third-Party Service Providers
(2) Use of Social Network Platforms
(3) Data Transfer in Case of Change of Control or Asset Disposition
(4) Companies Using SpanishVIP Business Services
(5) SpanishVIP Independent Contractors
(6) Other Users of the SpanishVIP Platform
6. How Long Will the Personal Data Be Processed and Stored by SpanishVIP?
7. Your Rights as a Data Subject Regarding Your Personal Data Processed by SpanishVIP
(1) Right of Confirmation
(2) Right of Access
(3) Right to Rectification
(4) Right to Erasure (Right to Be Forgotten)
(5) Right of Restriction of Processing
(6) Right to Data Portability
(7) Right to Object to Processing of Your Personal Data by SpanishVIP
(8) Right to Withdraw Consent at Any Time
8. Other Privacy Commitments
(1) Cross-border Transfers
(2) Time for Reply and Reaction
(3) Security
(4) Accessing Account to Provide Support
(5) Children’s Privacy
(6) Breach Notifications
(7) “Do Not Track” Requests
(8) Automated Decision-Making and Profiling
(9) Sale of Personal Data
Mediavine Programmatic Advertising (Ver 1.1)
1. AdRoll
2. ClickBank
3. Drip
4. Facebook Analytics for Apps
5. Google Analytics (Universal Analytics & GA4)
6. HubSpot Analytics and CRM
7. LearnWorlds
8. LiveChat
9. Matomo (Self-hosted)
10. Stripe
11. VK Like Button and Social Widgets
12. Avatar Manager
How Data is Used: This data is stored indefinitely unless manually removed by the user or administrator.
User Rights: Users can request the deletion of their avatar or any associated data by contacting support.
Sharing of Data: Avatar Manager does not share data with third parties.
Opt-out Options: Users can opt out of avatar use by avoiding the upload feature or requesting their avatar’s removal.
13. Checkout Field Editor and Manager for WooCommerce
How Data is Used: This data is used to manage and process orders.
Sharing of Data: Data may be shared with payment processors or shipping companies but is never sold to third parties.
User Rights: Users can manage or request the deletion of their data by contacting customer support.
Data Retention: Data is retained as long as necessary for order fulfillment or legal compliance.
Opt-out Options: Users can opt out by not providing information at checkout.
14. Contact Form 7
How Data is Used: Data is used to respond to inquiries or provide customer support.
Sharing of Data: Data is not shared with third parties unless required by law.
User Rights: Users can request the deletion of their form submissions or personal data by contacting us directly.
Opt-out Options: Contact Form 7 does not store cookies, and users can opt out by choosing not to submit the form.
15. Imagify
How Data is Used: Imagify processes images but does not store them permanently.
Opt-out Options: Users can opt out by not uploading images for compression or optimization.
Sharing of Data: The plugin does not directly store personal information but processes image files as necessary for site performance.
16. Integration for Contact Form 7 and HubSpot
How Data is Used: Data is used for marketing or customer relationship management purposes.
Sharing of Data: Data may be shared with HubSpot’s marketing services but is not sold to third parties.
User Rights: Users can request deletion of their data or opt out of marketing communications via links in emails or by contacting support.
Data Retention: Follows HubSpot’s guidelines and local legal regulations.
17. Mediavine Control Panel
How Data is Used: Data is used for ad personalization and tracking purposes.
Sharing of Data: Mediavine shares data with advertising partners but complies with GDPR and CCPA regulations.
Opt-out Options: Users can manage cookie preferences or opt out of personalized ads through the cookie consent banner or their browser settings.
18. SurvForm
How Data is Used: Data is used for feedback and research purposes.
Sharing of Data: Data is stored securely and is not shared with third parties unless required by law.
User Rights: Users can request the deletion of their survey responses or opt out by not submitting responses.
Data Retention: Survey data is retained only as long as necessary for analysis.
19. WPForms Lite
How Data is Used: Data is used for processing submissions and responding to inquiries.
Sharing of Data: Data is not shared with third parties unless legally required.
User Rights: Users can request the deletion of their form submissions by contacting us directly.
Opt-out Options: WPForms Lite does not use cookies, and users can opt out by choosing not to submit forms or by contacting support to manage their data.
