Berlitz Venezuela SA Privacy Policy

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 CENTRO DE IDIOMAS BERLITZ DE VENEZUELA, C.A RIF J002574119 with address at Av. Francisco de Miranda, Edificio Parque Cristal, Torre Oeste, Piso 1, Ofic. 3, Los Palos Grandes. State of Miranda. City of Caracas (“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 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 another forum of this type, you should be aware that any personal information you post may 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.

AB Tasty

To continually improve our online services, on our website, we use the service AB Tasty, Rosenstraße 2, 10178 Berlin, Germany (“AB Tasty”). AB Tasty uses cookies. This company processes statistical information about your visit to our website, the referrer URL, the device and browser you are using, your geolocation, language settings, the number and location of clicks, and your IP address.

The legal basis for this data processing is your consent pursuant to Article 6(1)(a) GDPR.

You can withdraw your consent to this data processing at any time with effect for the future by customizing your preferences in our cookie settings. When using AB Tasty, personal data are transferred to third countries.

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, "clicking" on "accept" or continuing browsing the site, or providing your Data through it, constitutes a manifestation of your consent for the Company to process your Data, in accordance with this "Privacy Policy".

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".

In the event that this "Privacy Policy" is available in writing, your signature, 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 and cancel their Data, as well as to oppose their treatment or revoke the consent that they have given us for this purpose, through the procedures established in this Privacy Policy.

IV.- Sensitive data. In no case should The Holder provide the Company with “sensitive personal data” in accordance with the terms of article 2 of Law 25,326, that is, personal data that reveals the racial and ethnic origin, political opinions, religious, philosophical, or moral convictions, union affiliation and information regarding health or sexual life.

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

V.- Obtaining data. The Holder will voluntarily provide his or her Data to the Company, either in writing, verbally, electronically, through surveys, his or her direct entry to the Company's Internet site, or by sending electronic files or 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, requests by email, 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 allows 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 agrees that the Company may also obtain the 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 updating, rectification and, when appropriate, the deletion or submission to the confidentiality of the Data provided, being able to access the database free of charge, at intervals of not less than six months, that which is duly registered in the terms of the Personal Data Protection Law No. 25,326, and its complementary regulations, unless a legitimate interest is accredited for this purpose, in accordance with the provisions of article 14, paragraph 3 of Law No. 25,326.

The National Directorate for the Protection of Personal Data, the control body of Law No. 25,326, 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 email address, information on commercial or consumer preferences, income ranges, educational ranges, age ranges and/or socio-economic level ranges.

This Data may be used in an enunciative but non-limiting manner to (i) Provide you with the goods and/or services that you have requested or in 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 your 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 requests, presentation of resumes or resumes, employment records, or any other similar data such as name, address, telephone numbers, cell phone numbers, and fax numbers, may be required or delivered. Email, 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, (i) internal purposes of the Company, including keeping them as employment records within the Human Resources area of ​​the Company; (ii) Processes of labor hiring 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 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, including credit card number, may be requested; 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, and payments and for the prevention of fraud.

This purpose can be carried out by processing and using 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 the 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 to your Data being transferred, it will be understood that you have given your consent.

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, providers of customer service and support provided in real-time, marketing, providers of email services, 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, it will be processed and stored in a database that 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 an authority.

X.- Access, rectification. The Owner will have the right to access their personal information stored in the Company's database and rectify, limit or update it when required, for which they must send a request by post or email to the Manager, under the following data:

CENTRO DE IDIOMAS BERLITZ DE VENEZUELA, C.A..

Av. Francisco de Miranda, Edificio Parque Cristal, Torre Oeste, Piso 1, Ofic. 3, Los Palos Grandes. State of Miranda. City of Caracas

rr.hh@berlitz.com.ve

The request for access, rectification, cancellation, 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 it is sought to exercise any of the aforementioned rights, and

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

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

The cancellation 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 cancellation and continues to be processed by third parties, the Company must inform you of said request for rectification or cancellation, without any 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 that any change to this "Privacy Policy" or to the privacy policies is notified by publication on the page https://www.berlitz.com/en-ve.

XIII.- Applicable law and jurisdiction. The Privacy Policy presented here is governed by the laws of the Bolivarian Republic of Venezuela. In the event of any controversy regarding the interpretation or fulfillment of these, the Company and the Data Owner submit to the National Commercial Courts based in the city of Caracas.

I CONFIRM THAT I HAVE READ, UNDERSTAND AND ACCEPT THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY.