CC English Privacy Policy

Effective on May 1, 2021

Intercambio de Comunidades, Inc., on behalf of its affiliates and subsidiaries (“Intercambio,” “us,” “we,” or “our”) has prepared this Privacy Policy (“Privacy Policy”) to describe to you, or if you represent an entity or other organization, that entity or organization (in either case, “you” or “your”) our practices regarding the personal information that Intercambio collects, uses, and shares on behalf of end users (“Users”) of our English language learning platform called CC English (the “CC English Platform”), available through the website located at ccenglish.org, and through various other websites operated by Intercambio (each, a “Website“) or using mobile and online applications provided by and on behalf of Intercambio (each, an “App”). Capitalized terms not defined in this Privacy Policy, shall have the meanings as defined in the Terms of Service, located at Terms of Service.

By using the CC English Platform you consent to the terms of this Privacy Policy. If you do not agree to the terms and conditions of this Privacy Policy, including having your personal information used in any of the ways described in this Privacy Policy, you may not be able to use certain parts or features of the CC English Platform, and in some instances, this may necessitate the revocation of your account.

Intercambio may update this Privacy Policy from time-to-time at our sole discretion. It is your responsibility to review the Privacy Policy for any changes each time that you use the CC English Platform and you are bound by such changes. Your use of the CC English Platform following us posting a new Privacy Policy on the CC English Platform signifies that you agree to and accept the Privacy Policy as modified.

All requests, questions, concerns, or complaints about your Personal Information or this Privacy Policy, please contact our Privacy Officer by mail or email at the following:

Intercambio
4735 Walnut St, Ste B
Boulder, Colorado 80301, United States.
Email: support@ccenglish.org
Phone: +1 (303) 996-0275 x105

1. COLLECTION OF PERSONAL INFORMATION

Personal Information. Personal information you may provide to us through the CC English Platform or otherwise includes:

Contact details, such as your first and last name, email address, mailing address, phone number.
Registration information, such as your username and password that you set to establish an online account with us, and demographic information such as age, education, gender, interests, and zip code.
Communications that we exchange or you exchange with other Users, including when you contact us with questions, feedback, or otherwise.
Payment and transactional data, such as the information needed to complete your orders and registrations on or through the Service (which does not include credit card information, which is provided by you directly to our processing service provider), and information about products you have purchased from us.
Cookies and internet activity, such as text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns.
Marketing data, such as your preferences for receiving communications about our products, services, activities, events, and publications, and details about how you engage with our communications.
Other information that we may collect which is not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed on the Website at the time of collection.

Sources of Personal Information. We obtain personal information from the following categories of sources:

Personal Information You Provide. Intercambio collects personal information when you voluntarily submit it to us.
Personal Information that is Automatically Collected. In addition to personal information that we may receive directly from you, Intercambio indirectly collects other information from you automatically log information about you, your computer or mobile device, and your activity over time on our Website, and other sites and online services.
Personal Information Obtained from Third Parties. Intercambio may receive personal information about you from other third party sources, including from business partners or data providers. We may merge or combine such personal information with the personal information we collect from you directly or automatically.

2. USE OF PERSONAL INFORMATION

Intercambio’s primary purpose in collecting personal information is to provide the Content and Services that you request on the CCEnglish Platform. Intercambio may also use personal information for various purposes, including without limitation:

• Establish and maintain your account on the CC English Platform.
• Understanding and analyzing the usage trends and preferences of our Users to make the CCEnglish Platform better, diagnose technical issues, prevent fraud, and develop new features and functionality.
• To personalize your experience on the CC English Platform and to deliver information about offers relevant to your interests.
• To verify your identity or determine your eligibility for offers and promotions.
• Contacting you via email in the future to tell you about specials, new products or services, improve marketing efforts, or conduct research and analysis.
• To communicate with you, including responding to any of your requests or questions.
• To provide Users with maintenance and support including responding requests for customer support or responding to your feedback.
• To respond to requests from law enforcement and as required by applicable law, court order, or government investigation.

3. SHARING OF PERSONAL INFORMATION

In addition to the specific situations discussed elsewhere in this Privacy Policy, Intercambio may share your personal information in the following circumstances:

Related Companies and M&A Transactions. We may share your personal information with companies that are affiliated with us (that is, that control, are controlled by, or are under common control with us). In addition, if we sell all or part of its business or make a sale or transfer of assets or is otherwise involved in a merger or business transfer, we may transfer your personal information to a third party as part of that transaction, including at the negotiation stage.
Consent. We may ask if you would like us to share your personal information with other unaffiliated third parties who are not described elsewhere in this Privacy Policy, and we may do so with your consent.
Service Providers. We may share your personal information with third parties who perform services on our behalf that are necessary for the orderly operation of the CC English Platform. Among other things service providers may help us perform website hosting, app design, maintenance services, database management, web analytics, app analytics, billing, payment processing, fraud protection, credit risk reduction, marketing, or any other use set out in this Privacy Policy.
Legal Compliance. Intercambio may disclose your personal information as required by law to comply with a subpoena, or similar legal process when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, respond to a government request, or to prevent a violation of our Terms of Service.
Chat. The CC English Platform may provide you with the opportunity to chat with other Users through community forums. If you decide to submit personal information through chat, you should be aware that any information you provide in these areas may be read, collected, and used by others who access them.
Referrals. Users may recommend other Users to join the CC English Platform by providing their contact information or selecting friends from a social networking site. Users may also provide personal information about other Users of the CC English Platform such as reviews of the services or products that he or she received, or reference information.

4. ACCESS TO AND CONTROL OVER PERSONAL INFORMATION

You can make the following choices regarding your personal information:

Modifications to Your Personal Information. We rely on you to update and correct the personal information contained in your account. Note that we may keep historical information in our backup files as permitted by law. If the CC English Platform does not permit you to update or correct certain personal information, please contact us as described above.
Promotional E-mails. You may choose to provide us with your e-mail address for the purpose of allowing us to send newsletters, surveys, offers, and other promotional materials related to the CC English Platform, as well as targeted offers from third parties. You can stop receiving promotional e-mails by clicking the “unsubscribe” links in the e-mails or by contacting us as described below. If you decide not to receive promotional e-mails, we may still send you service-related communications, such as those about your account, to fulfill orders for offers you have requested, or deliver notifications about Content or Services you have selected directly to you through the CC English Platform.
Do-Not-Track. Some web browsers and devices permit you to broadcast a preference that you not be “tracked” online. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Intercambio does not seek or knowingly collect any Personal Information about children under 13 years of age. If we become aware that we have unknowingly collected Personal Information from a child under the age of 13, we will make commercially reasonable efforts to delete such information from our database.

If you are the parent or guardian of a minor child who has provided us with Personal Information, you may contact us using the information below to request it be deleted.

5. DATA SECURITY AND INTEGRITY

The computers/servers in which we store personally identifiable information are kept in a secure physical environment. Wherever Intercambio collects sensitive information, that information is encrypted and transmitted to us in a secure way. You can verify this by looking for a closed lock icon at the bottom of your web browser, or looking for “https” at the beginning of the address of the web page.

Intercambio takes reasonable precautions to protect your information. Intercambio follows generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, Intercambio cannot guarantee its absolute security.

6. CHILDREN’S PRIVACY

Intercambio does not intend the CC English Platform to be used by individuals under the minimum age within the jurisdiction within which they reside without the supervision of a parent or guardian of legal age. Intercambio relies upon such parents or guardians to determine if the CC English Platform are appropriate for the viewing, access, or participation by such individuals under the minimum age. If an individual under the minimum age uses the CC English Platform, such individual may only use the CC English Platform under the supervision of a parent or guardian of legal age.

Intercambio does not seek or knowingly collect any personal information about children under 13 years of age. If we become aware that we have unknowingly collected personal information from a child under the age of 13, we will make commercially reasonable efforts to delete such information from our database.

If you are the parent or guardian of a minor child who has provided us with personal information, you may contact us using the information above to request it be deleted.

7. ADDITIONAL PRIVACY POLICY INFORMATION

• Our CC English Platform may include Widgets, which are interactive mini-programs that run on the CC English Platform to provide specific services from another company (e.g., displaying the news, opinions, music, etc). Personal information, such as your email address, may be collected through the Widget. Cookies may also be set by the Widget to enable it to function properly. Information collected by this Widget is governed by the privacy policy of the company that created it.
• The CC English Platform may contain links to other websites and online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or online services that are not associated with us. We do not control third party websites or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use, and sharing of your personal information. We encourage you to read the privacy policies of the other websites and online services you use.
• Intercambio is based in the United States of America. If you are from a country outside of the United States of America with laws governing data collection, use, and disclosure that may differ from U.S. law and you provide personal information to us, please note that any personal information that you provide to us may be transferred to the United States of America. By providing your personal information, where applicable law permits, you hereby specifically and expressly consent to such transfer and processing and the collection, use, and disclosure set forth herein or in the Terms of Service.



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