Villa de Zecheo

Privacy Policy

1. INTRODUCTION
1.1 This privacy notice (Privacy Notice) sets out the ways in which we, VILLA DE ZECHEO (we, us, our), collect and use your personal data (your personal information) in connection with our business. It also explains what rights you have to access or change your personal data. California residents, please also refer to the Additional Privacy Notice for California Residents in section 14.
2. ABOUT US

2.1 We are a company with our headquarters in the Puerto Rico at the address set out below.

2.2 You can contact us directly as follows:

Villa de Zecheo
Pso Bachon Velazquez, Aguada, Puerto Rico
Email : info@villadezecheo.com
Phone : +17873048644

3. INFORMATION WE MAY COLLECT ABOUT YOU

3.1 Information that you provide to us.

 

3.1.1 We will collect any information that you provide to us when you:

(a) respond to our survey, fill in a form, or use any features of our website;

(b) make an inquiry, provide feedback or make a complaint over the phone, by email or on our website;

(c) submit correspondence to us by post, email or via our website;

(d) and ‘follow’, ‘like’, post to or interact with our social media accounts, including LinkedIn, Twitter and YouTube, Facebook.

 

3.1.2 The information you provide to us will include (depending on the circumstances):

(a) Identity and contact data : title, names, addresses, email addresses and phone numbers, job function, areas of expertise;

 

3.2 Information we collect about you:

(a) Information contained in correspondence : We will collect any information contained in any correspondence between us. For example, if you contact us using a contact form on our website or by email or telephone, we may keep a record of that correspondence;

(b) Information transmitted on the website : We will collect information that you upload or post to our website;

(c) Website usage data : We will collect information about your interactions with the website, including information such as login data, IP address, page views, searches, requests, and other actions on the website; and

(d) Technical data : We will also collect certain information about how you use our website, software platforms and cloud services, as well as the device that you use to access these platforms, even where you have not created an account or logged in. This might include your geographical location, device information (such as your hardware model, mobile network information, unique device identifiers), the data transmitted by your browser (such as your IP address, date and type of the request, content of the request regarding the specific site, time zone settings, access status/HTTP status code, volume of data transmitted, browser type and version, language settings, time zone settings referral source, length of visit to the website, date and time of the request, operating system and interface) number of page views, the search queries you make on the website, files and data accessed/created/deleted, usage information of our communications systems, and similar information. This information may be collected by a third-party website analytics service provider on our behalf and/or may be collected using cookies or similar technologies. For more information on cookies please read the COOKIES section below.

 

3.3 We do not collect “ Special categories ” of particularly sensitive personal information. When we collect special categories of data, we implement additional security measures to limit access to the data and ensure its integrity. This processing is necessary for the purpose of carrying out the obligations and exercising specific rights of Villa de Zecheoin the field of employment and social protection law.

 

3.4 Information we receive from third parties

 

3.4.1 In certain circumstances, we will receive information about you from third parties. For example:

(a) Referrals : we might receive information about you from third parties if you have indicated to such third party that you would like to hear from us, and also via referrals from colleagues or others who believe you may be interested in learning about our products/services.

4. HOW WE USE INFORMATION ABOUT YOU, AND RECIPIENTS OF YOUR INFORMATION

4.1 We will use your information for the purposes listed below either on the basis of:

 

4.1.1 performance of your contract with us and the provision of our services to you;

 

4.1.2 performance of a contract with a third party;

 

4.1.3 your consent (where we request it);

 

4.1.4 where we need to comply with a legal or regulatory obligation; or

 

4.1.5 our legitimate interests or those of a third party.

 

4.2 We use your information for the following purposes:

 

4.2.1 Relationship management : to manage our relationship with you, which will include notifying you about changes to our privacy notice (on the basis of performing our contract with our clients, to comply with our legal obligations and on the basis of our legitimate interests to keep our records updated);

 

4.2.2 Marketing : to keep in contact with you about our news, events, new website features, products or services that we believe may interest you (on the basis of our legitimate interests to provide you with marketing communications where we may lawfully do so);

 

4.2.3 To provide access to our website : to provide you with access to our website in a manner convenient and optimal and with personalized content relevant to you, including sharing your information with our website hosts and developers (on the basis of our legitimate interest to ensure our website is presented in an effective and optimal manner, and on the basis of performing our contract with you, if applicable);

 

4.2.5 User and customer support : to provide customer service and support (on the basis of our contract with you or on the basis of our legitimate interests to provide you with customer service), deal with inquiries or complaints about the website and our business practices;

 

4.2.6 Social media interactions : to interact with users on social media platforms including YouTube, Facebook, and Instagram, for example, responding to comments and messages, posting, ‘retweeting’ and ‘liking’ posts (on the basis of our legitimate interest in promoting our brand and communicating with interested individuals);

 

4.2.7 Analytics : to use data analytics to improve our website, products/services, marketing, customer relationships and experiences (on the basis of our legitimate interests in defining types of customers for our website and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy);

 

4.3 As outlined above, in certain circumstances we may use your personal information to pursue legitimate interests of our own or those of third parties. Where we refer to using your information on the basis of our “legitimate interests”, we mean our legitimate business interests in conducting and managing our business and our relationship with you, including the legitimate interest we have in:

 

4.3.1 personalizing, enhancing, modifying or otherwise improving the services and/or communications that we provide to you;

 

4.3.2 ensuring our website is presented in an effective and optimal manner;

 

4.3.3 providing the correct products and services to our website users;

 

4.3.4 promoting our brand and communicating with interested individuals via social media;

 

4.3.5 defining types of customers for our website and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy;

 

4.3.6 keeping our records updated;

 

4.3.7 operating a safe and lawful business;

 

4.3.8 detecting and preventing fraud and operating a safe and lawful business; and

 

4.3.9 and improving security and optimization of our network, sites and services.

 

Where we use your information for our legitimate interests, we make sure that we take into account any potential impact that such use may have on you. Our legitimate interests don’t automatically override yours and we won’t use your information if we believe your interests should override ours unless we have other grounds to do so (such as your consent or a legal obligation). If you have any concerns about our processing please refer to details of “Your Rights” in paragraph 10 below.

5. WHO WE MIGHT SHARE YOUR INFORMATION WITH

5.1 In connection with the purposes and on the lawful grounds described above and in addition to the recipients of your information as described above, we will share your personal information when relevant with third parties such as:

5.1.1 Our service providers : we work with various service providers to conduct our business, who are acting as processors and provide us with:

(a) hosting services on AWS;

(b) marketing and sales engagement services;

(c) video hosting service YouTube;

(d) Google Analytics, a website analytics provider, hosted in USA;

(e) social media plugin services including Meta,  and Google — all hosted in USA;

(f) other professional advisers who may be appointed from time to time, when necessary subject to Independent Contractor Agreements.

 

5.1.2 Regulators and governmental bodies : (i) regulators, governmental bodies and other authorities acting as processors or joint controllers based in the US;

 

5.1.3 Prospective sellers and buyers of our business : any prospective seller or buyer of such business or assets, only in the event that we decide to sell or buy any business or assets; and

 

5.1.4 Other third parties (including professional advisers) : any other third parties (including legal or other advisors, regulatory authorities, courts, law enforcement agencies and government agencies) based in the USA where necessary to enable us to enforce our legal rights, or to protect the rights, property or safety of our employees or where such disclosure may be permitted or required by law.

 

5.2 We do not and will not sell your Personal Data to third parties for monetary or other consideration.

6. COOKIES

This website uses cookies. Cookies are small text files that can be used by websites to make a user’s experience more efficient. We use cookies to personalize content and ads, to provide social media features and to analyze our traffic. We also share information about your use of our site with our social media, advertising and analytics partners who may combine it with other information that you’ve provided to them or that they’ve collected from your use of their services.

 

Depending on your location (for example, if you are in the EU or UK), the law may state that we can store cookies on your device if they are strictly necessary for the operation of this site, and for all other types of cookies we may need your permission. Users in the EU, UK and Switzerland will be prompted to review their permissions upon accessing our website.

 

This site uses different types of cookies. Some cookies are placed by third party services that appear on our pages.

7. HOW WE LOOK AFTER YOUR INFORMATION AND HOW LONG WE KEEP IT FOR

7.1 We operate a policy of “privacy by design” by looking for opportunities to minimize the amount of personal information we hold about you. We use appropriate technological and operational security measures to protect your information against any unauthorized access or unlawful use, such as:

 

7.1.1 ensuring the physical security of our offices;

 

7.1.2 ensuring the physical and digital security of our equipment and devices by using appropriate password protection and encryption in transit, as well as encryption at rest and two-factor authentication whenever feasible and necessary;

 

7.1.3 anonymizing or pseudonymizing data whenever feasible and necessary;

 

7.1.4 maintaining a data protection policy for, and delivering data protection training to, our employees and staff; and

 

7.1.5 limiting access to your personal information to those in our company who need to use it in the course of their work.

 

7.2 We prefer to retain your information until it needs to be updated or deleted. This enables us to tailor our outreach to the types of marketing communications you prefer, provide you with the services that you have requested, and to respect your “Do Not Contact/Unsubscribe” requests. We also may need to keep your information to exercise our legal rights. 

8. HELP KEEP YOUR INFORMATION SAFE

8.1 You can also play a part in keeping your information safe by being vigilant to any fraudulent emails that may appear to be from us. Any emails that we send will come from an email address ending in ‘@villadezecheo.com’.

9. INTERNATIONAL TRANSFERS OF YOUR INFORMATION

9.1 In compliance with the Privacy Shield Principles, Villa de Zecheo commits to resolve complaints about our collection or use of your personal information. Individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us directly at info@villadezecheo.com(full contact details are provided in section 2.2 above). Villa de Zecheo has a policy of responding to individuals within forty-five (45) days of an inquiry or complaint.


10. YOUR RIGHTS TO THE INFORMATION WE HOLD ABOUT YOU

10.1 You have certain rights in respect of the information that we hold about you, including (to the extent each of these rights are provided to you by applicable law):

 

10.1.1 the right to be informed of the ways in which we use your information, as we seek to do in this Privacy Notice;

 

10.1.2 the right to ask us not to process your personal data for marketing purposes;

 

10.1.3 the right to request access to the information that we hold about you;

 

10.1.4 the right to request that we correct or rectify any information that we hold about you which is out of date or incorrect;

 

10.1.5 in certain circumstances, the right to ask us to stop processing information about you; and

 

10.1.6 the right to lodge a complaint with the relevant authority in your country of work or residence;

 

10.1.7 the right to withdraw your consent for our use of your information in reliance of your consent (refer to paragraph 4 to see when we are relying on your consent), which you can do by contacting us using any of the details at the top of this Privacy Notice;

 

10.1.8 the right to object to our using your information on the basis of our legitimate interests (refer to paragraph 4 above to see when we are relying on our legitimate interests or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground;

 

10.1.9 the right to receive a copy of any information we hold about you (or request that we transfer this to another service provider) in a structured, commonly-used, machine-readable format, in certain circumstances; and

 

10.1.10 the right to ask us to limit or cease processing or erase information we hold about you in certain circumstances.

 

10.2 How to exercise your rights

 

10.2.1 You may exercise your rights above by contacting us using the details in paragraph 2 of this Privacy Notice or, in the case of preventing processing for marketing or survey research activities, by checking certain boxes on forms that we use to collect your data to tell us that you don’t want to be involved in those activities. 

 

10.2.2 Please note that we may need to retain certain information for our own record-keeping and research purposes. We may also need to send you service-related communications relating to your website user account even when you have requested not to receive marketing or survey research communications.

 

10.3 What we need from you to process your requests

 

10.3.1 We may need to request specific information from you to help us confirm your identity and to enable you to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

 

10.3.2 You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We will try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

11. SHARING DATA DIRECTLY WITH THIRD PARTIES

11.1 You may attend an event hosted by us where you communicate personal information directly with other attendees. We are not responsible for how such third parties use personal data provided by you.

 

11.2 Please be responsible with personal information of others when using our website and the services available on it. We are not responsible for your misuse of personal information, or for the direct relationship between you and others when it takes place outside of the website or our services.

12. THIRD-PARTY LINKS

12.1 The website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

13. CHANGES TO THIS PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

13.1 We may make changes to this Privacy Notice from time to time. We will post any changes to our site, or notify you of any material changes by e-mail.

 

13.2 It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us by updating your profile account information (for clients using our Gateway), reaching out to your regular contact at Villa de Zecheo, or by contacting us via the details at the top of this Privacy Notice.

14. ADDITIONAL PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

14.1 This Additional Privacy Notice for California Residents supplements the information contained elsewhere in Villa de Zecheo’s Privacy Policy and applies solely to visitors, users, and others who reside in the State of California. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

 

14.2. Information We Collect and Share. We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”).

This information is used for the purposes outlined in section 4 of this Privacy Policy. We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

 

14.3 Do Not Sell My Personal Information. In the preceding twelve (12) months, we have not sold any personal information, and do not intend to sell any personal information going forward.

 

14.4 Your Rights and Choices. The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

 

14.4.1 Access to Specific Information and Data Portability Rights. You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting that personal information.
  • The categories of third parties with whom we share that personal information and the personal information categories that each category of recipient obtained.
  • The specific pieces of personal information we collected about you (also called a data portability request).

14.4.2 Deletion Request Rights. You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service providers to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

14.5 Exercising Access, Data Portability, and Deletion Rights. To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

  • Calling us at +17873048644
  • Emailing us at info@villadezecheo.com

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
  • We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

14.6 Response Timing and Format. We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

 

14.7 Non-discrimination. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: deny you goods or services; charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; provide you a different level or quality of goods or services; suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

 

14.8 Contact Information. If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us by:

  • Calling us at +17873048644
  • Emailing us at info@villadezecheo.com

This Privacy Notice was last updated as of February 2, 2023.