Privacy Policy of Berlitz Uruguay S.A.

This ("Privacy Policy") is applicable to the websites and / or the platform for digital services designed for fixed and / or mobile devices developed by the firm BERLITZ URUGUAY S.A. RUT 213554370012, with address at 1309 Bulevar Artigas Street (“Berlitz” and / or the “Company”).

I.- Purpose. This Privacy Policy regulates the form, terms and conditions under which the Company, including its subsidiaries and related companies, are empowered and / or authorized by the Owner to obtain, process and transfer personal data (hereinafter the "Data") of the Holder.

II.- Excluded Data. The Company's website may include links to third-party websites. If you gain access to such links, you will leave the Company's website, for which the Company assumes no responsibility in relation to those third-party websites.

If you post, comment or share personal information, including photos, in any public forum, social network, blog or other forum of this type, you should be aware that any personal information you post can be read, viewed, collected or used by other users of such forums, and may be used to contact you, send you unsolicited messages, or for purposes that neither you nor the Company can control. The Company is not responsible for the personal information that you decide to send to these forums or social networks.

III.- Consent. In the event that this "Privacy Policy" is available through an electronic page (website, Internet page or similar) or any other electronic device, by clicking "accept" or in any other way continue browsing on the site, or by providing your Data through it, constitutes a manifestation of your consent for the Company to process your Data, in accordance with this "Privacy Policy".

That in the event that this "Privacy Policy" is available through sound, audiovisual or any other technology, the fact of providing your Data constitutes a manifestation of your consent for the Company to process your Data, of compliance with this "Privacy Policy".

That in the event that this "Privacy Policy" is available in writing, your signature, name or fingerprint or when providing your Data anywhere on the site, constitutes a manifestation of your consent for the Company to process your data, in accordance with this "Privacy Policy".

That all the information you provide is true and complete. The Holder will respond at all times for the Data provided.

The Holder has the right to access, rectify, update, include and delete their Data, as well as to oppose the treatment of the same if the applicable legislation enables it or revoke the consent that for this purpose has been granted to us, through the procedures that are established in this Privacy Policy.

IV.- Sensitive data. The Holder will in no case provide the Company with “sensitive personal data” in accordance with the terms of article 18 of Law 18,331, that is, personal data that reveals racial and ethnic origin, political opinions, religious, philosophical or moral convictions, union affiliation and information regarding health or sexual life, or biometric data.

In particular, the Owner undertakes not to provide the Company with any Data regarding racial or ethnic origin, present and future health status, genetic information, religious, philosophical and moral beliefs, union affiliation, political opinions or sexual preference, or information biometric.

V.- Obtaining data. The Holder will voluntarily provide his Data to the Company, either in writing, verbally, electronically, through surveys, his direct entry to the Company's Internet site or by sending electronic files or files of any other nature, including but not limited to more non-limiting, direct delivery of information, access to the Internet site of the Company or that of its clients or affiliates (where reference is made to this Privacy Policy), telephone or telemarketing calls, email requests, seminars, conferences or events, etc.

In case of use of, or access to our Internet sites or other electronic means, we inform you that it is possible that our systems collect Data from the Owner such as type of browser, operating system, Internet pages visited, IP address, etc., through "cookies" or "web beacons", among others. Cookies are text files that are automatically downloaded and stored on the hard drive of the user's computer equipment when browsing a specific Internet page, which allow the Internet server to remember some information about this user, including their preferences for the visualization of the pages in that server, name and password. For their part, web beacons are images inserted into an Internet page or email, which can be used to monitor the behavior of a visitor, such as storing information about the user's IP address, duration of interaction time on said page and the type of browser used, among others.

The Owner accepts that the Company may also obtain Owner's Data from other means, such as information obtained from other commercially available sources, such as telephone directories, employment directories, business cards, public databases, etc.

All the information and Data that we collect about the Owner may be combined for the purposes permitted under this Privacy Policy.

The owner of the Data may request the update, rectification and, when appropriate, the deletion or submission to confidentiality of the Data provided, being able to access the database for free, at intervals of not less than six months, the database enabled, the which is duly registered in the terms of the Personal Data Protection Law No. 18,331, and its complementary regulations, unless a legitimate interest is accredited for this purpose, in accordance with the provisions of article 14, of Law No. 18,331.

The Regulatory and Control Unit of Personal Data, the control body of Law No. 18,331, has the power to deal with complaints and claims that are made in relation to non-compliance with the rules on personal data protection.

VI.- Use of the data. The Company may use the Data for any of the following purposes:

Improvement of the commercial process.- In the case of statistical information, internal treatment data, commercial promotions, marketing studies, commercial offers, surveys, advertising matters or similar, we may require general information such as name, address (home and office), telephone numbers, fax and e-mail address, information on commercial or consumption preferences, income ranges, educational ranges, age ranges and / or socio-economic level ranges.

These Data may be used in an enunciative but not limited way to (i) Provide you with the goods and / or services that you have requested or in respect of which you have expressed interest; (ii) To seek an efficient service and provide better service to the user, as well as to improve their experience in the use of certain products and / or services; (iii) Send and present you goods and / or services that may be relevant or attractive, including your participation in promotions, offers and advertising campaigns; (vi) Inform about changes or new products or services that are related to the one contracted or acquired by the client; (v) Comply with obligations contracted with our clients; (vi) Evaluate the quality of the service, or carry out internal studies on consumer habits.

Contact or employment information.- In the case of job offers or applications, presentation of resumes or resumes, employment records or any other similar data such as name, address, telephone numbers, cell phone numbers, fax, may be required or delivered. e-mail, photographs, information on academic degrees, regarding academic and work history (previous jobs) and data related to interest in jobs, including skills and abilities, contact information, socioeconomic status and job claims (including salary).

This Data may be used, but not limited to, for (i) internal purposes of the Company, including keeping them as employment records within the Human Resources area of ​​the Company; (ii) Processes of employment contracting or provision of independent services; (iii) For the purpose of providing references in the event that another person or company requests reports on possible candidates for a position, job or commission; (iv) For internal legal purposes, including compliance with Social Security or similar obligations; (v) For the purpose of publishing them if required as part of a human resources offering strategy.

Information for commercial operations.- In the event that the Data is requested to carry out a commercial operation, information such as financial information may be requested, including credit card number; and other unique information, such as user identification and passwords, billing or transactional information, bank details, etc.

The financial information specified above, including that related to the number of credit cards is used exclusively to process credit applications, payments and for the prevention of fraud.

This purpose can be carried out through the treatment and use of the Data directly through the Company or third parties to whom the data is transferred in accordance with the provisions of the following section.

VII.- Storage, disclosure and transfer of Data. The Data may be transferred, stored and processed in a country other than where it was provided, in which case we transfer the information in accordance with applicable information protection laws.

The Holder understands and accepts that the Company is authorized to use, store, disclose, transfer, as well as to sell, assign, lease or in any other way commercialize or transfer the Data. In this case, the Company will enter into contracts with third parties to whom it provides the Data, in which the restrictions and other terms and conditions of this Privacy Policy will be incorporated.

If you do not express your opposition for your Data to be transferred, it will be understood that you have given your consent to do so.

Regardless of the foregoing, the Company may also provide part of the Data to suppliers of goods or services that require to know this information. These providers include, but are not limited to, credit card processors, real-time support and customer service providers, marketing, email service providers, automated data processors. and carriers. These service providers are obligated, by contract, to maintain the confidentiality of the Data in accordance with this Privacy Policy.

VIII.- Data storage. Once the data is received, they will be processed and stored in a database owned by the Company, which can be managed by the Company or by a third party (within or outside the country where the Data was provided) with which the Company has a contract for such purposes.

The Company will incorporate protection mechanisms in order to avoid "as far as possible" deviations, adulteration, loss, consultation or unauthorized treatment of the Data.

IX.- Confidentiality. The Company will not disclose the data to unauthorized third parties except when such disclosure is required by law or order of authority.

X.- Access, rectification. The Holder will have the right to access their personal information stored in the Company's database and rectify, delete or update it when required, as well as to request the inclusion of their data, for which they must send a request by postal mail or to the Manager, under the following information:

Berlitz Uuguay S.A.

Boulevard Artigas 1309, Montevideo

The request for access, rectification, deletion, inclusion, update or opposition must contain and accompany the following:

The name of the Holder and address or other means to communicate the response to your request;

The documents that prove the identity or, where appropriate, the legal representation of the Holder

The clear and precise description of the personal data with respect to which one seeks to exercise any of the aforementioned rights, and

Any other element or document that facilitates the location of the Owner's personal data.

XI.- Suppression or Revocation. In the event of requests for the total deletion of Data or revocation of consent, they must be made in accordance with the provisions of the previous section.

The deletion of Data will give rise to a blocking period after which the Data will be deleted. The Company may keep the Data exclusively for the purposes of the responsibilities arising from the treatment.

When the Data has been transmitted prior to the date of rectification or deletion and continues to be processed by third parties, the Company must inform you of said request for rectification or deletion, without any other additional obligation on your part.

XII.- Modifications. The Company reserves the right to make changes to these privacy policies at any time and adapt them to new legislation, jurisprudence, as well as market practices. The Owner agrees and agrees that any change to this "Privacy Policy" or to the privacy policies is notified by posting it on the Internet page

XIII.- Applicable law and jurisdiction. The Privacy Policy presented here is governed by the laws of the Oriental Republic of Uruguay. In the event of any controversy regarding the interpretation or compliance of these, the Company and the Data Owner submit to the competent Courts based in the city of Montevideo.