Privacy Policy

Effective as of May 25, 2018

SembraMedia, a California nonprofit public benefit corporation (“SembraMedia”, “we”, “us”, or “our”) recognizes the importance of privacy. We want you to feel confident using our services, and this privacy policy (“Policy”) is to help you understand and describe how we collect, use, and disclose information that we obtain about users of our websites, services, plug-ins, software or other Downloadable Tools (all of which we refer to as the “Platform”). This Policy describes the following:

INFORMATION WE COLLECT

We collect information about you directly from you and automatically through your use of our Platform to allow reoccurring access to our Platform, track your performance and receive updates through our newsletter. We may combine information automatically collected with other information that we have collected about you including from publicly available sources including Google Analytics, and social media platforms such as Twitter, Instagram, Facebook and LinkedIn.

In order to help you protect yourself and your information, we encourage you to provide only that information that is necessary for using our Platform.

SembraMedia is not directed to children under 13 years of age and we do not knowingly collect personal information from children under 13. If we discover that a child under 13 has provided us with personal information, we will promptly delete such personal information from our systems.

INFORMATION YOU PROVIDE VOLUNTARILY

  • User Information. When a User comes to SembraMedia to set up an online account, you voluntarily give us certain information. This can include your name, email address, phone number, physical location, education and training background and any other information you provide us or is required for the use of the Platform.
  • Account Information. Users may give us permission to access their information in other services. For example, with your consent, you may link your SembraMedia account with your Google, Microsoft Office 365 account, or other similar service, which allows us to obtain information from those accounts. The information we get from those services often depends on your settings or their privacy policies, so be sure to check what those are.
  • Billing Information. Our third-party payment processors include PayPal and Stripe (the “Payment Processors”). The Payment Processors will collect and store your billing address and credit card information. We encourage you to visit their privacy policies to ensure you fully understand their respective privacy policies.
  • Projects. We may collect your data when we are carrying out a research project, in order to contact you to see if you wish to participate in such project and, where appropriate, to collect important data about you in order to prepare the reports and documents necessary for the proper development of such information project.

INFORMATION COLLECTED AUTOMATICALLY

Like many websites, we and our service providers use cookies, a small piece of data sent from a website and stored on the user’s computer to track certain types of information when you interact with us through your computer or mobile device subject to your opt-out preferences (see Your Rights and Choices section below). Using these technologies helps us customize your experience with our Services, improve your experience, and tailor marketing messages. Here are some of the types of information we collect:

  • Log & Device data. When you use SembraMedia, our servers automatically record information (“log data”), including information that your browser sends whenever you visit our Website. This log data may include the web address you came from or are going to, your device model, operating system, browser type, unique device identifier, IP address, mobile network carrier, and time zone or location. Whether we collect some or all of this information often depends on what type of device you’re using and its settings. For example, different types of information are available depending on whether you’re using a Mac or a PC, or an iPhone or an Android phone. To learn more about what information your device makes available to us, please check the policies of your device manufacturer or software provider.
  • Cookie data. Depending on how you’re accessing our products and subject to your opt-out preferences, we may use “cookies” (a small text file sent by your computer each time you visit our website, unique to your SembraMedia account or your browser) or similar technologies to record log data. When we use cookies, we may use “session” cookies (that last until you close your browser) or “persistent” cookies (that last until you or your browser delete them). For example, we may use cookies to keep you logged in to SembraMedia. Some of the cookies we use are associated with your SembraMedia account (including personal information about you, such as the email address you gave us), and other cookies are not. To help us make emails more useful and interesting, we often receive a confirmation when you open email from SembraMedia if your computer supports such capabilities. You can opt out of receiving emails from us. Please see the Your Rights and Choices section below.
  • Other Web Site Analytics Services. Subject to your opt-out preferences (see Your Rights and Choices below), we use third-party service providers such as Google Analytics to provide certain analytics and user interactions services to SembraMedia in connection with our operation of our Platform, including the collection and tracking of certain data and information regarding the characteristics and activities of visitors SembraMedia. You may opt-out of Google Analytics’ cookies using the Opt-Out Features on their respective websites.

HOW WE USE YOUR INFORMATION

We may use information that we collect about you, including personal information, to:

  • Based on the execution of our contract with you:
  1. Provide Services. We will use your information to provide our Platform and services to you; to manage your account; to respond to your inquiries; and for other customer service and support purposes. We use the payment information you provide to us in order to alert you of past, current, and upcoming charges, to allow us to present the billing history to you on your billing page in the platform, and to perform internal finance processes, such as checking the status of a credit card charge. In the event of a credit card dispute, we may also share account information with your bank to verify the legitimacy of a charge.
  2. Service related communications. We may send you informational, service and administrative emails to ensure the service is working properly. We will also email you regarding updates on your user account (e.g. assignment updates, teacher communications). These messages are considered part of the service and, in some cases, you may not opt out of these messages.
  3. Responding to your requests. We will also use your information to respond to your questions or comments.
  4. We may contact you to inform you about changes in our services, our service offering and other important service related notices, such as changes to the Policy or about security or fraud notices.
  • Based on our legitimate interest:
  • Understand and improve our products. We will perform research and analysis about your use of, or interest in, our products, services, or content, as well as the products, services or content offered by others. We do this to help make our products and services better and to develop new products and services.
  1. Subject to your opt-out preference, we may send you emails about new product features or other news about SembraMedia or on topics we think would be relevant to you. You may opt out of receiving these communications at any time. Visit the Your Rights and Choices section below.
  2. Subject to your opt-out preferences, and when legally possible, we may develop and display content and advertising tailored to your interests on our services and other sites. See Your Rights and Choices below.
  3. Protecting Rights and Interests. We will use your information to protect our rights and interests as well as the rights and interests of our users and any other person, as well as to enforce this Policy or our Terms of Service.
  • Based on compliance with our legal obligations:
  1. Legal Compliance. We may use your information to comply with applicable legal or regulatory obligations, including informal requests from law enforcement or other governmental authorities.
  • Based on your free consent:
  1. We may develop and display content and advertising tailored to your interests on our services and other sites thought cookies, when you have given your consent to their installation and the applicable legislation requires it for their installation (EU countries). More info in the Cookie Section of this document
  2. We may use your data for the elaboration of media directories or collaborators, as well as reports, according to the different research projects developed by the entity in which you decide to participate.

We also may use your information to manage our business or perform functions as otherwise described to you at the time of collection subject to your consent. Please read all online agreements carefully before accepting them.

WITH WHOM WE MAY SHARE YOUR INFORMATION

We do not share your personal information with others except as indicated within this Policy or when we inform you and give you an opportunity to opt out of having your personal information shared.

We will share information we collect about you, including personal information, in the following ways:

  • With third-party service providers, agents, or contractors. We use other companies, agents or contractors (“Service Providers”) to perform services on our behalf or to assist us with providing services to you. For example, we may engage Service Providers to process credit card transactions or other payment methods. Or, we may engage Service Providers to provide the training services (including data about users’ interactions with our service). These Service Providers may have access to your personal or other information in order to provide these functions. In addition, some of the information we request may be collected by third-party providers on our behalf. We require our Service Providers to agree to take reasonable steps to keep the personal information that we provide to them secure. We do not authorize them to use or disclose your personal information except in connection with providing their services.
  • We may disclose your information to current or future affiliates or subsidiaries for research, marketing, and other purposes consistent with this Privacy Policy.
  • To comply with legal process or to protect SembraMedia and our Users. We may share your data: if we believe that disclosure is reasonably necessary to comply with a law, regulation, legal or governmental request; to respond to a subpoena, court order, warrant, or other legal process; to enforce applicable terms of use or this Policy, including investigation of potential violations thereof; to protect the safety, rights, or property of the public, any person, or SembraMedia; to detect, prevent, or otherwise address, security, or technical issues or illegal or suspected illegal activities (including fraud); or as evidence in litigation in which we are involved, as part of a judicial or regulatory proceeding.
  • Business Transfers.We may engage in a merger, acquisition, bankruptcy, dissolution, reorganization, or similar transaction or proceeding that involves the transfer of the information described in this Policy. In such transactions, customer information is typically one of the business assets that is transferred or acquired by a third-party. If we are acquired by or merged with another company, if we sell or transfer a business unit or assets to another company, in the unlikely event of a bankruptcy proceeding, or as part of any other similar business transfer, you acknowledge that such transfers may occur.
  • Aggregate or De-identified Information.We may disclose aggregate, anonymous, or de-identified information about users for marketing, advertising, research, compliance, or other purposes.

YOUR RIGHTS AND CHOICES

  • In order to keep your personal information accurate and complete, you can log in to review and update your account information, including contact and billing information, via your account settings or Mis Clases page. You may also contact us to request information about the personal data we have collected from you and to request a correction, modification or deletion of such personal information. We will do our best to honor your requests subject to any legal and contractual obligations. If you would like to make a request, cancel your account or request we delete or no longer use your account information to provide you Services, contact us at contacto@SembraMedia.org  or the address set forth at the end of this Policy. Subject to applicable law, we will retain and use your account information only as necessary to comply with our legal obligations, resolve disputes and enforce our agreements. 
  • We also inform you that, if you are a European resident, you also have the right to restrict the processing of your data and to object to the processing when it is carried out on the basis of our legitimate interest or for the performance of a contract. Likewise, you have the right to withdraw your consent at any time without such withdrawal affecting the data processing done so far. Finally, you have the right to lodge a complaint with the [Supervisory Authority] if you consider that your right to data protection has been violated at any time.
  • E-mail. As described above, if you do not wish to receive promotional emails from us, you may opt out at any time by following the opt-out link contained in the email itself. Please note that it may take up to ten (10) days to process your request. Please also note that if you opt out of receiving marketing communications from us, we may continue to send to you service-related emails, which are not available for opt-out. If you do not wish to receive any service-related emails from us, you have the option to deactivate your account.
  • You may also refrain from providing, or withdraw, your consent for cookies. Your browser’s help function should contain instructions on how to set your computer to accept all cookies, to notify you when a cookie is issued, or to not receive cookies at any time.
  • Third-Party Analytics Services. Some of the services used provide the ability to opt-out. You may opt-out of Google Analytics’ services using Opt-Out Features on their respective websites. The Google Analytics service is provided by Google Inc. You can opt-out from Google Analytics service from using your information by installing the Google Analytics Opt-out Browser tool: google.com/dlpage/gaoptout. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: www.google.com/policies/privacy. We also use social media remarketing technology, which may include Twitter, Instagram, Facebook and LinkedIn. These social media platforms may use cookies, web beacons and similar technologies to collect or receive information from our website and other websites using that information to provide measurement services and ad targeting. You can opt out of the collection and use of information for ad targeting by following Facebook’s published opt- out instructions: www.facebook.com/help/568137493302217.  Additionally, you can opt out of additional web-tracking technologies via the Digital Advertising consumer choice page: http://optout.aboutads.info.
  • Additional Rights. Subject to local law, you may have additional rights under the laws of your jurisdiction regarding your personal data, such as the right to complain to your local data protection authority.

SECURITY AND STORAGE OF INFORMATION

We have taken reasonable steps to help protect the personal information we collect. These measures include using SSL encryption and two-factor authentication. Unfortunately, no measures can be guaranteed to provide 100% security. Accordingly, we cannot guarantee the security of your information in all circumstances.

You should take steps to protect against unauthorized access to your device and account by, among other things, choosing a robust password that nobody else knows or can easily guess and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

We retain the personal data we collect for so long as reasonably necessary to fulfill the purposes for which the data was collected, to perform our contractual and legal obligations, and for any applicable statute of limitations periods for the purposes of bringing and defending claims.

THIRD-PARTY LINKS

Our Platform may contain links to third-party websites and applications. Subject to your opt-out preferences (see Your Rights and Choices), we may also use third-party advertisers, ad networks, and other advertising, marketing, and promotional companies, to serve advertisements on our websites. Any access to and use of such linked websites and applications is not governed by this Policy but instead is governed by the privacy policies of those third parties. We do not endorse these parties, their content, or any products and services they offer, and we do not endorse these parties, their content, or any products and services they offer, and we are not responsible for the information practices of such third-party websites or applications.

 USERS OUTSIDE THE USA

Our application and database servers are located in the United States. If you are an individual located in the European Economic Area, the United Kingdom, Canada or another jurisdiction outside of the United States with laws and regulations governing personal data collection, use, and disclosure that differ from United States laws, please be aware that information we collect (including through the use of methods such as cookies and other web technologies) will be processed and stored in the United States or in other countries where we or our third-party services providers have operations. By submitting your personal information to SembraMedia and using SembraMedia, you acknowledge that your personal data may be transferred to, processed and stored in the United States or in another jurisdiction that may not offer the same level of privacy protection as the country where you reside or are a citizen. This is because, without such transfer, it would not be possible to provide any of the services listed on the website or in the various projects.

In any case, SembraMedia is committed to implement all measures and procedures that are within its power to secure your personal data and your rights over them.

 CALIFORNIA DISCLOSURES

Under the California “Shine The Light” law, California residents may opt out of our disclosures of personal information to third parties for their direct marketing purposes. California residents may request a list of all third parties with respect to which we have disclosed any information about you for direct marketing purposes and the categories of information disclosed. If you are a California resident and want such a list, please send us a written request by email to contacto@SembraMedia.org with “California Privacy Rights” in the subject line. It is important to note that this opt-out does not prohibit disclosures made for non-marketing purposes.

COOKIE POLICY

SembraMedia, on its own account or that of a third party contracted to provide measurement services, may use cookies and other similar data storage and retrieval mechanisms in terminal equipment (hereinafter, “Cookies”).

Through the use of cookies it is possible that the server where the website is hosted recognizes the browser used by the user, in order to make navigation easier, allowing, for example, access to users who have previously registered, access to areas, services, or promotions reserved exclusively for them without having to register each visit. They are also used to measure the audience and traffic parameters, as well as to control the progress and number of entries.

WHAT ARE COOKIES?

A cookie is a file that is installed in the user’s browser when accessing certain pages or applications. Cookies allow the owner of a website or app, among other things, store and retrieve information about browsing habits of a user or your computer and, depending on the information they contain and the way you use your computer, can be used to recognize the user.

TYPES OF COOKIES

By domain management entity

  • First-party cookies
  • Third-party cookies

By time of permanence

  • Session Cookies
  • Persistent cookies

By purpose

  • Technical cookies
  • Personalization cookies
  • Analytics cookies
  • Behavioral advertising cookies

WHAT TYPES OF COOKIES DOES THIS WEBSITE USE AND WHAT ARE THEIR PURPOSES?

By the entity managing the domain:

  1. First-party cookies: are those that are sent to the user’s terminal equipment from a computer or domain managed by the editor itself and from which the service requested by the user is provided.
  2. Third-party cookies: those that are sent to the user’s terminal equipment from a computer or domain that is not managed by the editor, but by another entity that processes the data obtained through the cookies.

By the time of their permanence: 

  1. Session cookies: these are a type of cookies designed and used to collect and store data while the user accesses a web page. As their name suggests, these cookies are stored in the terminal until the end of the user’s browsing session.
  2. Persistent cookies: are those in which the data remain stored in the terminal and can be accessed and treated for a period defined by the person responsible for the cookie, and that can range from a few minutes to several years.

By their purpose:

  1. Technical Cookies: are those that allow the user to navigate through a web page and the use of the different options or services that exist in it, including that are used to allow the management and operation of the website and enable its functions and services.
  2. Personalization Cookies: are those that allow to remember information for the user to access the service with certain features that can differentiate your experience from that of other users.
  3. Analysis Cookies: are those that allow us to quantify the number of users and thus perform the measurement and statistical analysis of the use made by users of the service offered. To do this, your browsing on our website is analyzed in order to improve the supply of products or services that we offer.
  4. Behavioral advertising cookies: are those that store information on user behavior obtained through the continuous observation of their browsing habits, allowing the development of a specific profile to display advertising based on the same.

LIST OF COOKIES BY ISSUER:

Cookie name

Issuer

Tipe

Retention period

More info

_ga, _gid, _gat_gtag_UA_66411009_1

Google

Analysis

2 years

https://policies.google.com/privacy?hl=es

_Secure-3PSIDCC, 

Google

Advertising

1 year

https://policies.google.com/privacy?hl=es

__Secure-1PAPISID

Google

Advertising

2 years

https://policies.google.com/privacy?hl=es

APISID

Google

Advertising

2 years

https://policies.google.com/privacy?hl=es

HSID

Google

Advertising

2 month

https://policies.google.com/privacy?hl=es

__Secure-1PSID

Google

Advertising

2 years

https://policies.google.com/privacy?hl=es

SID

Google

Personalization

2 years

https://policies.google.com/privacy?hl=es

SIDCC

Google

Analysis

1 years

https://policies.google.com/privacy?hl=es

__Secure-3PAPISID

Google

Advertising

2 years

https://policies.google.com/privacy?hl=es

__Secure-1PSIDCC

Google

Advertising

2 years

https://policies.google.com/privacy?hl=es

SSID

Google

Personalization

2 years

https://policies.google.com/privacy?hl=es

__Secure-3PSID

Google

Advertising

2 years

https://policies.google.com/privacy?hl=es

SAPISID

Google

Personalization

2 years

https://policies.google.com/privacy?hl=es

AEC

Google

Advertising

2 years

https://policies.google.com/privacy?hl=es

ANID

Google

Personalization

2 years

https://policies.google.com/privacy?hl=es

NID

Google

Personalization

2 years

https://policies.google.com/privacy?hl=es

OTZ

Google

Advertising

2 years

https://policies.google.com/privacy?hl=es

OGPC

Google

Personalization

2 years

https://policies.google.com/privacy?hl=es

This information table will be updated as soon as possible when the services offered on this site change. However, it is possible that the information table may temporarily not include a cookie, tag or other similar device due to an update, although there will always be devices with identical purposes to those included in this chart.

WHO ARE THE RECIPIENTS OF THE INFORMATION? WHERE ARE THEY LOCATED?

The information collected through Cookies may be used both by SembraMedia and by third party collaborating companies, such as web analytics operators and agents, for the purposes described in the previous section. 

Some of these collaborators may be located in third countries whose legislation does not offer an equivalent level of data protection; however, the user may consult the appropriate guarantees they offer so that international data transfers are carried out taking into account the rights and freedoms of the data subjects. 

The user can learn more about these third parties, as well as the types of cookies they install, the purposes for which they process the data, the guarantees they offer to carry out international transfers, the retention periods and how preferences can be configured with respect to them, through their privacy policies. In any case, SembraMedia is not responsible for the accuracy and content of the privacy policies offered by those third parties on their websites.

COOKIES MANAGEMENT

Taking into account the information provided through this Cookie Policy, below we provide you with information on how you can manage the cookies used on the web through the different options offered by the most common browsers (Explorer, Firefox, Chrome, Safari and Opera). The Help function of most browsers tells you how to configure your browser to not accept cookies, to notify you each time you receive a new cookie, as well as to completely disable all cookies.

So, for example, you can find information on how to manage your cookie preferences in the most common browsers through the following links:

Firefox from here.

Chrome from here.

Microsoft Edge from here.

Safari from here.

Opera from here.

If your browser is not among the above, please consult the specific documentation for your browser.

The opt-out mechanism creates a cookie that allows us to remember that you do not want additional cookies. However, if you delete cookies after you have asked for them to be deleted, you will have to repeat the process.

These changes only apply to the browser through which you are currently logged in. To delete cookies from other devices, you must follow the process described for those devices.

If you prevent the installation of all cookies on the website, some functionalities of the website as well as some content may be affected.  

CHANGES TO THE POLICY

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, and if we do we’ll post any changes, including any material changes, on this page, so please be sure to check back periodically. If you continue to use SembraMedia after those changes are in effect, you agree to the revised Policy.

CONTACTING US

If you have any questions about this policy or otherwise need to contact us for any reason, you can reach us at contacto@SembraMedia.org, 1818 Clyde Ave., Los Angeles, CA 90019.