Privacy policy
June 1, 2023.
Visotsky Consulting Inc. (collectively referred to as "we", "us" or "we") takes privacy and information security very seriously. Protecting the Personal Information of Users (hereinafter "you", "you" or "you") is one of our key priorities.
In order to respect your rights and freedoms in protecting your Personal Data, this Policy has been developed. It explains the basis on which Personal Data is processed, how and for what purposes, and about your choices relating to that Personal Data.
This Policy applies to all means by which we collect information. For example, we collect information in face-to-face, telephone conversations.
Please read this Policy carefully to understand how we will treat your Personal Information. If you do not agree with our policy, you may not use our Site. By accessing or using the Site, you agree to the terms of this Policy.
This Policy may change from time to time. Your continued use of this Site after we make changes to the Policy is deemed acceptance of those changes, so please check the Policy periodically for updates.
Introduction
This Policy is designed to comply with the applicable laws of the European Union, the United Mexican States, the United States of America.
What terms we use in this Policy:
Applications (Questionnaires) - forms for the collection of your Personal Data posted on the Site and intended to be completed and submitted electronically through the Site. Applications are presented on the Site in the form of questionnaires containing prompt questions;
Button - a graphical element of the Site, highlighted in color and containing an inscription of a contrasting color, indicating a program-related action that will be performed when you click on it;
Cookies are text files placed on your computer (other device) when you visit the Site through a web browser. You can read more about cookies here;
Processing of Personal Data - any action (operation) or set of actions (operations) performed with or without the use of automation means with Personal Data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of Personal Data;
Personal Data means any information relating to you directly or indirectly. Your Personal Data also means information that you provide to us when you access the Site, Platform, Personal Area, register and/or authorize on the Site, Platform and/or Personal Area and use the Site, Platform, Personal Area, Service Packages, fill out an application. More detailed information on the composition of Personal Data can be found in the section on what Personal Data we collect;
Information System User - our employee to whom we have granted access to your Personal Data;
Site - the aggregate of text, graphics, design, images, code, software, photos, videos and other results of our intellectual activity contained on the Internet and located at https://usa.visotsky.com/;
Services - services provided by us to an unlimited number of persons on the terms and conditions set out on the Site;
My Account - a page that is available to you after you have authorized on the Site, i.e. after you have confirmed your identity and left your Personal Data;
Platform - the information resource located at: https://my.bbooster.online/, for us to provide Services/Packages of Services to Customers.
Customer - you, if you intend to purchase or have purchased our Services or a Service Package.
Service Packages means the aggregate of several Services that you intend to purchase or have purchased from us.
The Internet is a global system of interconnected computer networks that uses a set of Internet protocols (TCP/IP) to communicate between networks and devices.
What principles of personal data processing we adhere to:
We follow the following principles when processing your Personal Data:
- Obtaining Consent to Process Data. We process your Personal Data only with your consent, which can be withdrawn by you at any time. Consent is deemed to be obtained at the time you complete your registration on our Site after completing the Application Form. Registration shall be deemed completed when you click on the "Register" button or similar button located under the last prompt question in the Application Form.
- Targeted Data Processing. We limit the processing of your Personal Data to achieve specific, predetermined and legitimate purposes. We do not use your data for other purposes incompatible with those for which it was collected.
- We only process Personal Data that is necessary to achieve the stated purposes of processing.
- Data accuracy and relevance. We take care to ensure that your Personal Data is accurate and up-to-date for the purposes for which it is processed. If data is incomplete or inaccurate, we take the necessary measures to clarify or delete it.
- Data Destruction. Your Personal Data will be destroyed when the purposes of its processing have been achieved or when there is no need for its further use.
We strive to ensure the protection and confidentiality of your Personal Data in accordance with these principles and applicable Personal Data Protection legislation. If you have any questions regarding the processing of your data, you can always contact us for further information.
We do not verify the accuracy of the information about your Personal Data that you provide when completing Applications on our Website. We also do not verify that this Personal Data belongs to you directly, you provide it as your own. We assume that you provide us with your Personal Data in your own interest and have no intention to infringe the rights and legitimate interests of others, our rights or cause them/us losses.
To collect, record, organize, systematize, accumulate, store, clarify (update, modify) and retrieve your Personal Data, we use databases that are located in the United States. This may be necessary to ensure efficient Processing of your data and fulfill the stated purposes of the Processing.
We endeavor to ensure the security and confidentiality of your Personal Data and to comply with all relevant regulations and laws related to the protection of Personal Data. If you have any questions or require further information regarding the processing of your data, do not hesitate to contact us. We are here to help and provide you with the support you need.
What information we collect from you:
We collect various data about you and other users in accordance with the Policy and our objectives. This data may include Personal Information about users, as well as technical and other information related to their activities on our Site.
Technical information, such as cookies, helps us identify you and other users. Cookies are text files that we use to Process data about how users interact with our Site, Platform and Personal Area. For example, we may know which pages have been visited, how much time you or another user has spent on a page, or what services have been ordered. If you wish, you can disable the use of cookies in your browser settings. The Cookie Policy contains more detailed information about their processing.
Technical information also includes information that is automatically transmitted to us when you use our Site, Platform and/or Personal Area through the software on your device. Such information includes:
- Internet activity data such as pages visited, date and time of url clicks, etc.
- Information about the device and browser you use to access the Internet, including ip address and device type.
- Data about interactions with advertisements we display outside of our Site, such as number of views, frequency and depth of views.
We use third-party user location software (maxmind.com), web analytics (Google Analytics) and end-to-end business analytics (Roistat) to obtain additional information about user interactions with our services.
The collection of anonymized data using third-party software is determined by the copyright holders of that software themselves. We have no control over this process and have no direct influence over the composition and terms of such anonymized data collection.
We process Personal Data, technical information and other information of Customers (Clients) for the duration of the agreement between them and us. With respect to other users who are not Customers (Clients), the processing of their Personal Data occurs throughout their use of our Site and our other resources.
When using our Site, Platform and/or Personal Account, third party software may be used. As a result of such use, your data may be shared and transferred to third parties in an anonymized form. This means that the transmitted data cannot be used to identify specific individuals and will remain anonymous.
What we do with your personal data:
Processing your Personal Data includes activities such as recording, systematizing, accumulating, storing, clarifying (updating, modifying), extracting, using, transferring (disseminating, providing, accessing), depersonalizing, blocking, deleting and destroying your Personal Data. This applies to data for the processing of which we need to obtain your written consent.
By registering, authorizing and using our Website, Platform and Personal Area, as well as filling out Applications (Questionnaires), you consent to the processing of your Personal Data. This data may be transferred to third parties as part of our agreement with you (if you are a Customer or Client) or for the implementation of partnership programs with such third parties, even if such transfer is made outside the United States, Mexico or the European Union (the place where the Personal Data is stored), to the territory of other countries (cross-border transfer).
We process your Personal Data with or without the use of automation tools.
Please note that your Personal Data is processed by us in the United States, to which you consent.
Our information systems Process Personal Data of the following categories of subjects:
- our employees;
- our Customers (Clients);
- performers, contractors and other third parties who provide services and/or carry out work commissioned by us;
- participants of the events we organize;
- subscribers to our newsletter;
- media partners, invited guests and presenters at events we organize.
This Policy applies to all processes related to Personal Data Processing, including collection, recording, systematization, accumulation, storage, clarification, extraction, use, transfer, depersonalization, blocking, deletion and destruction of data. These processes may be carried out with or without the use of automation tools.
By using our Site and the GetCourse Platform and other resources provided by us, you unconditionally consent to our Personal Data Processing Policy and Terms. You may also express your agreement to this Policy by subscribing to our mailing lists or by providing us with written consent to the Processing of Personal Data.
Our Site is not directed to people who are under eighteen (18) years of age in the European Union (depending on jurisdiction) and Mexico, or sixteen (16) years of age in the United States under local law. We do not collect information from such people. If you are under these ages, you should not provide us with any personal information on or through the Site.
We do not knowingly collect information from children under the age of thirteen (13). If we inadvertently receive personal information from a child under the age of thirteen (13) without parental consent, we will delete that information immediately.
If you have reason to believe that we have Personal Information from a child under the age of thirteen (13), please contact us at visotsky.nyc@visotsky.com.
We use the Personal Data and information you provide to us solely for the following purposes:
- To fulfill our obligations to you if you are our Customer (Client) and use our Site, Platform, My Account, and materials and other intellectual resources in obtaining our Services.
- Establishing and maintaining communications with you.
- Sending you communications of an informational and other nature to your e-mail address.
- Improving the quality of service and upgrading our Site, Platform and My Account.
- Registering you on the Site, Platform and My Account and helping you manage your account.
- Executing justice in the event of a request by authorized authorities.
- Implementation of partnership programs with third parties.
- Fulfillment of legal requirements.
- Notifying you about the services we provide and how we provide them.
- To analyze the results you have achieved when using our services.
- Contacting you to clarify your intent to purchase our Services as described on the Site.
- Contracting with you to provide our Services, including invoicing, notices and information related to the provision of the Services.
- Processing your inquiries and Applications received by us.
- Developing and adjusting our marketing policies to suit your preferences based on your location and position.
We aim to use your Personal Data only in accordance with the purposes set out in this section and within the law to ensure that your privacy and data security is protected.
We do not verify the accuracy of the Personal Data you provide or your capacity to act.
Here is a list of your Personal Data that we process:
- Surname, first name, middle name;
- Email address;
- Contact phone number;
- Messaging accounts;
- Links to social media profiles (pages);
- Your image (photograph);
- Additional information that you provide to us through the Site, Platform, Application Form, My Account, and in the course of providing the Services within the Service Packages.
This information allows us to contact you, to provide you with our services, and to improve our service and meet your needs. We process this information in compliance with applicable Personal Data Protection legislation and with your consent, including where required. We always strive to keep your Personal Data secure and confidential and only use it for the purposes set out in this Policy.
Our rights in relation to the Personal Data you have provided to us
We have the right to conduct statistical and research work based on your anonymized Personal Data. We may also provide access to this research to third parties for advertising targeting purposes. By submitting an Application on the Site, registering on the Platform or creating a Personal Account, you consent to the transfer, processing, storage, and other operations with your Personal Data, including such research and receiving targeted advertising. However, you may withdraw this consent at any time by contacting us at the address listed on the Site: https://usa.visotsky.com/.
We may disclose information about you to law enforcement or other government agencies as part of a legal process or investigation pursuant to a court order, an enforceable request, or as part of a cooperative effort under applicable law.
We may share information about you with third parties to detect and stop fraudulent activity, troubleshoot technical or security problems.
We may share your Personal Information with other users of the Site and Platform, webinars, online and offline events, if such sharing is necessary to fulfill our obligations to other users or you under agreements entered into, including in anonymized form.
We may establish requirements for mandatory information (Personal Information) that you are required to provide in order to use the Site, Platform and/or My Account. However, if certain information is not labeled as mandatory, its provision or disclosure is at your discretion.
We store your Personal Data only for the time necessary to fulfill the purposes of Personal Data Processing. The retention period for Personal Data may be prescribed by law or provided for by your consent provided to us. After the expiry of the retention periods, your Personal Data will be destroyed or anonymized.
In accordance with the purposes of processing and legal requirements, we may transfer Personal Data to the following categories of third parties:
- our subsidiaries and companies within our group of companies;
- to our external contractors and companies with whom we have contracts;
- to governmental and other authorities as required by law.
The transfer of Personal Data to foreign countries that do not provide an adequate level of protection of your rights (countries that are not signatories to the Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data ETS No. 108) may only take place with your consent and/or for the fulfillment of a contract and/or in accordance with legal requirements.
For transfers of Personal Data received from the European Union to third parties in countries that do not provide an adequate level of protection for Personal Data under the GDPR, contracts containing "Standard Contractual Clauses" (SCC) adopted by the European Commission or a competent authority and approved by the European Commission are entered into with the relevant third parties to ensure that your rights and freedoms are respected.
To obtain information about the list of third parties to whom your Personal Data is transferred and copies of the Standard Contractual Clauses used in such contracts, you should contact us. We are obliged to provide you with this information upon your request.
What rights do you have in relation to the Personal Data you share with us
Please familiarize yourself with the rights set out below:
- When you post information about yourself on our Site, Platform, Application (Questionnaire) or Personal Profile, you may make it publicly available. Please understand that such information may be detected by search engines and may involve risks of disclosure of personal, family and other confidential information.
- You have the right to delete or modify the information you provide at any time. You can do so by performing the necessary actions on our Site, Platform and in Personal account, or if this is not possible, by contacting us at visotsky.nyc@visotsky.com. Please note, however, that in some cases we may continue to use your Personal Data where permitted by law.
- You have the right to request confirmation that we are processing your Personal Information. If processing does take place, you have the right to review your Personal Data and to obtain information about the purposes of the processing, the categories of data processed, the actions taken with the data, the recipients and safeguards for the transfer of the data to third parties, the processing timeframe, the sources of the data and the application of automated processing to your data. You also have the right to obtain a list of the Personal Data being processed.
- If we use your consent as a basis for processing your Personal Data, you have the right to withdraw your consent at any time. Each consent to processing that you provide to us sets out the procedure for withdrawing consent. If you wish to withdraw any of the consents we have provided, you may use the provided procedure set out in such consent.
- You have the right to request that your Personal Data be corrected if you find errors or inaccuracies in it. For this purpose, you may make changes to your Personal Information, taking into account the purposes for which it is processed.
You also have the right to initiate the restriction of processing of all or part of your Personal Data in the following cases:
- If you believe that the data contains inaccuracies, we will temporarily restrict the processing to confirm its correctness.
- If you discover that your data is being improperly processed and would prefer to restrict its use instead of deleting it.
- If we no longer need your Personal Data but you may need it to protect your rights in legal claims, lawsuits or proceedings.
If you object to the processing of your data, we will temporarily restrict processing to determine whether our legitimate grounds for this processing override your grounds of objection.
You may request the deletion of your Personal Data from our systems and/or other material sources if one of the following conditions is met:
- Your Personal Data is no longer needed for the purposes for which it was collected.
- You withdraw your consent to the processing of the data and there is no other lawful basis for the processing.
- You object to the processing of your data and we have no legitimate grounds for further processing of your data.
- The data is being processed unlawfully.
Data deletion is required to comply with our legal obligation under statutory requirements.
If you were a minor under the age of 16 (or other age under the applicable laws of your country) at the time your Personal Data was collected and the data was not collected with the consent of your legal representative for the purpose of providing services over the internet. Further details can be found in the section on what we do with your Personal Data.
- You have the right to request a list of your Personal Data provided by us for processing in a structured, universal and machine-readable format. You may also instruct us to transfer this list to a third party if we have the appropriate technical capability to do so. It is important to note that when we transfer Personal Data to a third party in this way, we are not responsible for any actions that this third party may take with your Personal Data in the future.
-You have the right to object to the processing of some or all of your Personal Data if the processing is carried out for the purposes stated when you provided the data to us. However, there are cases where our legitimate grounds for processing may override your interests, rights and freedoms, or the processing is necessary to justify or contest legal claims.
You have the right to request that we restrict the processing of your Personal Data for the purposes of marketing activities.
In the event that we violate your rights in any way with respect to the Processing of Personal Data, you have the right to lodge a complaint with the supervisory authority responsible for data control and protection.
We are committed to respecting your rights and ensuring that we process your Personal Data in a secure and responsible manner. If you have any questions or queries about this, please contact us at visotsky.nyc@visotsky.com. We are always available to assist you.
When we start processing your Personal Data. The period of your consent to process Personal Data
We begin processing your Personal Data as soon as we receive your consent to do so. This processing continues until your consent expires or you withdraw it.
The validity of your consent to the Processing of Personal Data is indefinite and begins to run from the moment we obtain your consent when you complete an Application on the Site or otherwise explicitly.
If you decide to withdraw your consent to the Processing of Personal Data, you may do so at any time. To do so, you must send a personal statement to us at visotsky.nyc@visotsky.com. As soon as we receive your application, the processing of your Personal Data will cease immediately and all your Personal Data will be destroyed.
What about confidentiality?
We are committed to keeping your Personal Data confidential and not disclosing it to third parties without your consent, except where such disclosure is required by applicable law.
Protection of your Personal Data
We take necessary and sufficient legal, organizational and technical measures to ensure the protection of the Personal Data you provide to us. This allows us to protect your data from unauthorized or accidental access, destruction, alteration, blocking, copying, dissemination and other unlawful acts of third parties.
To this end, we restrict access to your information to other users of the Site and Platform, our employees and partners, except where the provision of such information is necessary to fulfill our obligations to you or as required by law.
We also ensure that your submitted information, including Personal Information, is not combined with third party statistics. We use your information only for internal statistics and do not disclose it to third parties except as set out in our Policy.
It is important to note that we do not sell or transfer your information to individual third parties. Such information may only be transferred when we partially or completely reorganize our company.
We take technical and organizational measures to enable you to access and edit your submitted Personal Information as necessary.
If we discover unlawful processing of your Personal Data, whether by us or by a person acting on our behalf, we are obliged to immediately stop such unlawful processing. If the lawfulness of the processing becomes impossible, we are obliged to destroy your Personal Data. We take all of these measures in accordance with the law and as part of our obligations to you.
We take the following measures to protect your Personal Data:
- We secure the storage media of Personal Data.
- We identify and authenticate all users of our information system (Site) and access objects.
- We determine the list of persons who are granted access to your Personal Data as part of their job duties.
- We appoint a person responsible for ensuring the security of Personal Data in the information system.
- Manage user accounts of our information system (Site) and apply measures to differentiate user access rights.
- We apply anti-virus protection to the information system with Personal Data.
- We conduct periodic inspections of the conditions of Personal Data Processing.
- We organize training of users of our information system (Site) through briefings, especially those who have permanent or temporary access to your Personal Data.
Please note the following points:
- The Site, Platform and Personal Account are not publicly available sources of Personal Data. However, through certain of your actions or the actions of other users, your Personal Data may become available to an unspecified number of individuals, and you consent to this.
- We may send newsletters and promotional materials to the email address and contact phone number you provide when you register on the Site, Platform and/or Personal Area or complete an Application. You consent to such sending, however, you also have the right to opt-out of informational or marketing mailings.
- We are not responsible for the use of your Personal Data by third parties with whom you interact when using the Site, Platform and/or Personal Account.
If you have reason to believe that your interaction with us is no longer secure, for example, if you suspect that the security of your account has been compromised or your credentials are no longer secure, please notify us immediately.
To do so, you can send an email to visotsky.nyc@visotsky.com. We take such communications very seriously and respond immediately to any suspicions or concerns about the security of your Personal Information and accounts.
Our staff will take the necessary steps to review the situation and ensure the security of your data. Your safety and the protection of your Personal Information is our priority and we do everything we can to keep it safe and secure.
Notice of Cookie Use
Cookies are used on our Site. Please note that Cookies are not Personal Data as they are non-personal information.
We collect and store the IP address, domain name, browser type and operating system used on your device when you visit our Site. This information is collected in a depersonalized form and is used to maintain traffic statistics. We analyze this information to promptly identify and correct technical problems with our Site.
Cookies allow us to improve your experience interacting with the Site by providing you with more convenient features and personalized content. However, please remember that you can change your browser settings at any time to opt out of cookies or to receive notifications when they are sent.
We value your privacy and are committed to keeping your data as secure as possible. For more information on how we use Cookies, please see our Cookies Policy. If you have any questions or require additional information, please contact us at visotsky.nyc@visotsky.com.
Important information for residents of the State of California (USA)
In compliance with the California Consumer Privacy Act (CCPA), we provide the following information about the categories of Personal Information we collect, use and disclose about California residents and their rights.
During the past 12 months, we have collected the following categories of Personal Data in accordance with the CCPA:
Category A: Identifiers such as name, contact information, IP address, and other online identifiers.
Category B: Personal information as defined in the California Customer Records Act, such as name, contact information, medical information, insurance information, education information, employment information, and government-issued identification numbers.
Category C: Characteristics of protected classifications under California or U.S. federal law, such as age, sex, disability status, primary language, race, citizenship, and marital status.
Category D: Commercial information such as transaction information and purchase history.
Category E: Internet or online activity information, such as browsing history and interactions with the Site.
Category F: Audio, electronic, visual and similar information, such as photographs or audio and video recordings created in connection with our business activities.
Category G: Inferences drawn from any of the Personal Information listed above to create a profile, such as an individual's preferences and abilities.
If you are a California resident, you have certain rights with respect to your Personal Data, such as the right to access your data, the right to erasure, the right to block the transfer of your data to third parties, and others. You can read your rights in this Policy.
Sometimes our actions may be considered a "sale" of Personal Data under the CCPA, Data Categories A, B, C, E, F, G. This term is broadly interpreted to include the transfer of Personal Data to third parties who are not service providers or acting at your direction. We do not sell your Personal Data; sharing information from publicly available public records is not considered a "sale" of Personal Data. In addition, in some cases, we may share your Personal Information with our subsidiaries or contractors for limited purposes.
We are committed to protecting your privacy and ensuring that we have complete control over your data. If you have any questions or need additional information, please contact us at visotsky.nyc@visotsky.com.
In accordance with the CCPA, we have disclosed the following categories of Personal Data listed in the law to third parties for our operational business purposes as set forth in this Policy during the preceding 12 months:
Category A: Identifiers such as name, contact information, IP address and other online identifiers.
Category B: Personal information as defined in the California Customer Records Act, such as name, contact information, education information, medical information, insurance information, employment information, and state-issued identification numbers.
Category C: Characteristics of protected classifications under California or federal law, such as age, sex, disability status, primary language, race, citizenship, and marital status.
Category D: Commercial information such as transaction information and purchase history.
Category E: Internet or online activity information, such as browsing history and interactions with our Site.
Category F: Audio, electronic, visual and similar information such as calls and video recordings.
Category G: Inferences drawn from any of the Personal Data listed above to create a profile, such as about an individual's preferences and abilities.
Information about the third parties to whom these categories of Personal Data are shared can be found in the section on our rights in relation to your Personal Data.
We strive to be transparent about the collection and use of your data and provide this information in accordance with the CCPA so that you can make informed decisions about your Personal Data. If you have any questions or need further clarification, please contact us at visotsky.nyc@visotsky.com.
If you are a California resident, you have certain rights with respect to your Personal Data under the CCPA:
You may request information from us about the categories of Personal Data we have collected about you and the source categories from which that data was obtained.
You may also request specific portions of your Personal Data that we have collected and the business or commercial purpose for collecting that data, if such information is applicable.
You have the right to request information about the categories of Personal Data that we have shared or disclosed with other parties and the categories of third parties to whom that data has been shared or transferred, if any.
You may request the deletion of your Personal Data (personal information) that has been collected by us. To do so, you must send your request to visotsky.nyc@visotsky.com and we will verify the request, which may require you to confirm that you have control over the email address associated with your Personal Information and confirm that you are the one actually interacting with us. If necessary, we may ask for additional information to verify your request, and if you are making a request on someone else's behalf, additional confirmation may be required.
In addition, you have the right to opt out of the "sale" of your Personal Data (personal information) to third parties and to limit the use of your "sensitive personal information" (as defined in the CCPA) for behavioral advertising purposes. The right to opt-out has certain exceptions, for example, it does not apply to sharing information with vendors who provide the services we need. An opt-out request will not affect our business operations unless there is a "sale" of your Personal Information.
To exercise your rights, you may send an email to visotsky.nyc@visotsky.com to inform us of your intention to opt out of the sale or sharing of your Personal Information or to limit the use of your "sensitive personal information."
We are committed to responding to requests under the CCPA within 45 days, but this timeframe may be extended to 90 days if operationally necessary.
It is important to note that you have the right to be free from unlawful discrimination when exercising your rights under the CCPA. This means that we cannot refuse to provide services to you or change the terms of service because of your request to protect your Personal Information.
CalOPPA (California Online Privacy Protection Act) is a law that requires us to post this Policy on our Site.
We do not support the "Do Not Track" ("DNT") feature, which allows users to set a preference in their web browser so that their online activities are not tracked by third parties, including Internet services.
It is important to note that the provisions of this section apply only to California residents and shall prevail in the event of a conflict with other provisions of the Policy.
Important information for EU and EEA residents
If you are a resident of the European Union (European Economic Area), you have certain data protection rights under the General Data Protection Regulation 2016/679 (GDPR). The GDPR applies to these Terms.
To find out what Personal Data we hold about you, to request erasure or to exercise other rights under this section, you may email visotsky.nyc@visotsky.com.
You are granted the following rights to protect your Personal Data:
- The right to access, update or delete your Personal Data. You may request access to your Personal Data, update information, or delete your data in accordance with this section.
- Right to rectification. If your Personal Data is incomplete or inaccurate, you have the right to have it corrected.
- Right to object. You may object to our processing of your Personal Data.
- Right to restriction. You may request that we restrict our processing of your Personal Data.
- Right to data portability. You may receive a copy of your Personal Data that we hold about you in a structured, machine-readable and commonly used format.
- Right to withdraw consent. You may withdraw your consent to the processing of your Personal Data at any time. We will no longer have the right to continue to process your Personal Data based on the consent you have previously provided.
- The right not to be subject to automated decision-making, including profiling. This right allows you not to be subject to automated decision-making that could significantly affect you.
- The right to lodge a complaint with the European Union supervisory authority (or your country's supervisory authority). If you believe that we are violating your rights in relation to the collection and use of your data, you have the right to lodge a complaint with your country's data protection authority.
We are committed to complying with the GDPR and respecting your data protection rights by enabling you to exercise those rights with respect to your Personal Data.
Under this Policy and this section, you agree that we have the right to request proof of your identity before responding to requests related to the exercise of your rights. This may be necessary to ensure the security and protection of your data and to prevent unauthorized access to your personal information.
The provisions of this section of the Policy apply solely to you if you are a citizen of the European Union (European Economic Area) and shall override (and supersede) the provisions of other sections of this Policy where there is a conflict.
Important information for residents of Mexico
We are the data controller of your Personal Data and are responsible for the processing of Personal Data that is subject to the Federal Law on the Protection of Personal Data held by Private Persons of 05.07.2010 (Ley Federal de Protección de Datos Personales en Posesión de los Particulares, LFPDPPP) hereinafter referred to as the Law.
We use your Personal Data in accordance with the purposes set out in this Policy. All of these purposes, with the exception of marketing purposes, are necessary to maintain the relationship between you and us. If you wish to opt out of receiving marketing communications from us, you can email us at visotsky.nyc@visotsky.com to have your contact information removed from our marketing databases.
We share your Personal Data with third parties as described in this Policy, both within and outside of Mexico. For such transfers of Personal Data, we have obtained your consent or your consent is not required, except for transfers of Personal Data in the event of a merger, consolidation or sale of our assets or our affiliates. In the event of a merger, consolidation or sale of assets, we will transfer your Personal Data to. Successor Company. Your use of the Services/Service Packages constitutes your consent to such transfer. If you do not consent to such transfer of Personal Data, you may email us at visotsky.nyc@visotsky.com.
ARCO Rights. We must respond to inquiries related to your exercise of ARCO rights within 20 business days after we receive your request. If necessary and in accordance with the Act, this timeframe may be extended to 40 business days. Our response is provided electronically to your e-mail address that was provided in the request.
If your request to access, correct or delete Personal Data is granted, we take the appropriate action as requested within the timeframes specified in the Act. We also inform you of the implementation of actions related to the exercise of your ARCO rights.
In the event that we cannot fulfill your request, we will provide you with a reasoned notice of the reasons for refusing to access, correct or delete Personal Data.
We will not require you to provide payment for your exercise of your ARCO rights, except as required by the Act, when your requests are excessive or repetitive. In such cases, we may establish a reasonable fee in accordance with the Act.
If we need additional information from you under this section to confirm your identity or to understand what information you intend to access, correct, cancel or object to, we may request additional documents from you within 5 days of receiving your request. You will have 10 days to respond to our additional request, beginning on the day following the day we receive it. If you do not respond within this period, your request will be deemed not received. We will provide an email response within 20 days of receipt of your request or additional information, if applicable. We will fulfill your request within 15 days after we receive all required documents.
You have the right to withdraw your consent to the Processing of Personal Data if we process your data on the basis of your consent. To do so, you send your request by email to: visotsky.nyc@visotsky.com marked "Withdrawal of Consent" and a brief statement of your request. If you withdraw your consent to the processing of Personal Data, your ability to use the Services/Service Packs, Personal Account, Site or Platform may be restricted.
We will respond to your requests in accordance with the applicable laws of the United Mexican States and the Act. We may refuse to process your requests if they may jeopardize the privacy of others or our intellectual property.
The provisions of this section apply only to citizens of the United Mexican States and shall override (and supersede) the provisions of other articles of this Policy in the event of a conflict.
Final Provisions
We reserve the right to make changes to this Policy. You should read the current text of the Policy each time you access our Services (Service Packages), the Site, Platform and/or Personal Account.
The new version of the Policy comes into effect from the moment it is posted on the Site. If you continue to use our Services/Packages of Services, the Site, the Platform and/or the Personal Area after the new version of the Policy has been posted, it means that you fully accept the updated version of the Policy and its terms and conditions.
If you do not agree with the terms of the Policy, please do not continue to use our Services/Packages, Site, Platform and Personal Area.
Our contact information is Visotsky Consulting inc, Address: 368 9th Ave 6FL New York, NY 10001, Email: visotsky.nyc@visotsky.com, Phone: +1 347 604 0113.
Exclusion of inconsistencies
Where an agreement between us and you contains provisions regarding the use of your Personal Data, the provisions of the Policy and that agreement apply to the extent not inconsistent with the Policy.
