Privacy Policy

The website https://recourcesforedu.com/ (“Website”) and Mobile application “Simon Trading Lab” are owned by Resources For Education Ltda (“Company”). The commercial name of the company is “Simon Trading Lab”. The Company is registered under registration Number: 853203078, with the registered company address at Edificio Mendiola, Piso 4, Oficina 4 San Jose, Costa Rica.

At the Company one of our main priorities is the privacy of our visitors. This Privacy Policy document contains types of information that is collected and recorded by the Company and how we use it. By accessing Website or using Mobile Application, we assume you accept this Privacy Policy. Do not continue to use the Company’s Website or Mobile Application if you do not agree to take all of the terms and conditions stated on this page. This Privacy Policy applies only to our online activities and is valid for visitors to our Website and users of Mobile Application with regards to the information that You shared and/or collect in the Company. This policy is not applicable to any information collected offline or via channels other than this Website and/or Mobile Application. Please read the following information carefully to understand our practices regarding your Personal data.

This following terminology applies to Privacy Policy: "Client", "You" and "Your" refers to you. "The Company", "Ourselves", "We", "Our" and "Us", refers to our Company. "Party" or "Parties" refers to both the You and ourselves. Any use of the above terminology or other words in the singular, plural, capitalization and/or he/she or they, are taken as interchangeable and therefore as referring to same.Some words that start with a capital letter and are not defined herein shall be defined according to the Service Agreement.

  1. Acceptance of Privacy Policy

    1. By using the Website and/or Mobile Application, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy and all applicable laws and regulations. If you are using the Website and/or Mobile Application on behalf of a company or other legal entity, you represent that you have the authority to bind such entity to these terms. Downloading the Mobile Application and giving consent to all legal documents provided therein will give rise to the existence of a contractual relationship with us, as regulated by our Service Agreement, and all matters between you and us relating to Services will be deemed to fall within the subject matter of that same contractual relationship.
    2. Furthermore, the existence of this contract between you and us will also serve as the legal basis for a number of our processing activities involving your Personal data, as detailed below.
    3. “Personal data” means data relating to a living individual (i.e. natural person) who can be identified from the data (information) we hold or possess. This includes, but is not limited to, your name and surname (including maiden name where applicable), contact details (including mobile and home phone number and personal email address) as well as online identifiers and/or any other information we possess. The term “personal information”, where and when used in this Privacy Policy, shall have taken the same meaning as Personal data. Personal data does not include data where the identity has been removed (anonymous data).
    4. “Processing” means any activity that involves use of Personal data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including, organizing, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring Personal data to third parties.
    5. Accordingly, the purpose of this Privacy Policy is to set out the basis on which we will process your Personal data when you:
      1. visit and use Website and/or Mobile Application, regardless of where you visit or use them from;
      2. obtain your User ID;
      3. apply for, receive, pay, and/or use any of our services accessible in Website and/or Mobile Application.

  2. Changes to Privacy Policy

    1. We reserve the right to modify or update Privacy Policy at any time. We will notify you of any significant changes by posting the new Privacy Policy. Any changes will be effective immediately upon posting to the Website. You are responsible for reviewing this policy regularly to ensure you are aware of any changes. Your continued use of the Website and/or Mobile application after any changes constitutes your acceptance of the new version of Privacy Policy.

  3. Personal Data We Collect

    1. We may collect, use, store, share and disclose different kinds of Personal data about you which (for purely indicative purposes) we have grouped together as follows:
      1. Identity Data - includes your first name, maiden name (where applicable);
      2. Contact Data - includes address, billing address, email address and contact number (telephone and/or mobile);
      3. Transaction Data - includes details about:
        1. your subscriptions, purchases and transactional activity;
        2. your transactional history;
        3. your use of the services (including your service requests);
        4. the payments made to and from you;
      4. Usage Data - includes details about how you use our Mobile Application and the Website;
      5. Technical Data - includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices which you (whether a client or otherwise) use to access and browse the Website and/or Mobile Application.
      6. Website Visit Data - includes the full Uniform Resource Locators (URL), clickstream to, through and from the Website and/or Mobile Application (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page.
    2. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal data but is not considered Personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Website Visit Data to calculate the percentage of users accessing a specific feature of the Website.
      1. However, if we combine or connect Aggregated Data with your Personal data so that it can directly or indirectly identify you, we treat the combined data as Personal data which will be used in accordance with this Policy.
    3. Except us, there is no legal person that is allowed to collect your Personal data from our Website and/or Mobile Application.
    4. Please note, that upon using any links on our Website and/or Mobile Application to other websites, applications, services, such websites, applications, services may collect your Personal data.
      1. We are in no way responsible for collecting your Personal data by any other persons except us (and/or our affiliates).
      2. Upon following any link from the Website please get familiar with their Privacy Policy before engaging with them in any way.

  4. How is Your Personal Data Collected?

    1. We generally use different methods to collect data from and about you including through:
      1. Obtaining a User ID - some information may be collected upon downloading the Mobile Application and giving consent to this Privacy Policy.
      2. Direct Interactions - you provide this information, which will then be collected and processed.
        1. You may give us your Identity, Contact data by filling on our forms or by corresponding with us by post, phone, email or otherwise.
      3. Automated technologies or interactions - when you interact with our Website and/or Mobile Application, we may automatically collect Technical and Usage Data about your equipment, browsing actions and patterns.
        1. We may collect this Personal data by using Cookies, server logs and other similar technologies.
        2. The Company follows a standard procedure of using log files. These files log visitors when they visit websites.
        3. The information collected by log files include internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. These are not linked to any information that is personally identifiable. The purpose of the information is for analyzing trends, administering the site, tracking users' movement on the Website, and gathering demographic information.

  5. Cookies and Web Beacons

    1. Like any other website, the Company uses "Cookies". These cookies are used to store information including visitors' preferences, and the pages on the Website that the visitor accessed or visited.
    2. The information is used to optimize the users' experience by customizing our Website and functionalities, content based on visitors' browser type and/or other information.
    3. You can set your browser to refuse all or some browser cookies, or to alert you when the Website sets or accesses cookies. If you disable or refuse cookies, please note that some parts of the Website may become inaccessible or not function properly.
    4. Third-party ad servers or ad networks uses technologies like cookies, JavaScript, or Web Beacons that are used in their respective advertisements and links that appear on the Company, which are sent directly to users' browser. They automatically receive your IP address when this occurs. These technologies are used to measure the effectiveness of their advertising campaigns and/or to personalize the advertising content that you see on websites that you visit. Note that the Company has no access to or control over these cookies that are used by third-party advertisers.

  6. How We Use Your Personal Data

    1. We will only use your Personal data when the law allows us to. Most commonly, we will use your Personal data in the following circumstances:
      1. Where you wish to enter into a customer relationship with us;
      2. Where we need to perform any agreement (including without limitation Service Agreement), we have or which are about to enter into with you as a customer;
      3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
      4. Where we need to comply with a legal or regulatory obligation.
    2. “Performance of Contract” means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. This includes our Service Agreement or other applicable terms of business.
    3. “Legitimate Interest” means our interest to conduct and manage our business affairs appropriately and responsibly, to protect the reputation of our business, and to provide our customers with the best possible service and the users of the Websites and/or Mobile Application with a secure experience.
      1. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before your Personal data is processed for our legitimate interests. We do not use your Personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
    4. “Comply with a legal obligation” means processing your Personal data where it is necessary for compliance with a legal or regulatory obligation to which we are subject.

  7. Marketing

    1. You may receive marketing communications from us (which may consist of newsletters, industry and legislative updates, mailshots, publications and/or information about our events, seminars and webinars) where:
      1. you have entered into an ongoing commercial or contractual relationship with us; and
      2. provided that you have not opted out of receiving marketing from us.
    2. We will get your express opt-in consent before we share your Personal data with any third parties (including our affiliated entities) for marketing purposes. You can ask us to stop sending you marketing communications (unsubscribe) at any time by following the opt-out (unsubscribe) links on any marketing communication sent to you.

  8. Disclosure of Your Personal Data

    1. We may have to grant access to, disclose or share your Personal data with the parties set out below (which may be in or outside your jurisdiction) for the purposes set out in Section 6 of this Privacy Policy:
      1. Suppliers and external providers that we engage to process information on our or your behalf, including to provide you with the information and/or services which you may have requested;
      2. Affiliated group entities, which are involved in the provision of Services;
      3. Any other entities, if you agree by using their direct link(s) provided by the Website and/or Mobile Application.
      4. To any third parties, we may (or may not) disclose any, all or some information (gained from Mobile Application) that we possess. Such disclosure shall not contain Personal Data and have a sole purpose of making the provision of our Services better.

  9. Children's Information

    1. The Company does not knowingly collect any Personal Identifiable Information from children under the age of 18.
    2. If you think that your child provided this kind of information on our Website, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.

  10. Data Security

    1. We have put in place appropriate security measures to prevent your Personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed (i.e. to safeguard its integrity and confidentiality). We also regularly review and, where practicable, improve upon these security measures.
    2. We also limit access to your Personal data to strictly those employees, agents, contractors, and third parties that have a professional ‘need-to-know’. They will only process your Personal data on our instructions and they are subject to a duty of confidentiality. All our employees and agents have received appropriate training on data protection.
    3. We have put in place procedures to deal with any suspected Personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
    4. To the extent possible, we may anonymize the data which we hold about you when it is no longer necessary to identify you from the data which we hold about you. In some circumstances, we may even pseudonymize your Personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

  11. Prohibition on Transferring Your Device to Third Parties

    1. You are strictly prohibited from sharing your registered device with an assigned User ID with any third party for Your security.
    2. All information regarding your User ID is stored in an encrypted format to protect your data.
    3. If you suspect that your data has been compromised, please contact us immediately.

  12. Your Legal Rights Under GDPR

    1. General Data Protection Regulation (GDPR) shall be implemented for EU users.
    2. You have rights under data protection laws in relation to your Personal data:
      1. Right to Access - you may request a copy of the Personal data we hold about you;
      2. Right to Rectification - you may request correction of inaccurate or incomplete data;
      3. Right to Erasure (Right to be Forgotten) - you may request the deletion of your personal data under certain circumstances (according to law and/or Company’s legal documents (Privacy Policy));
      4. Right to Restriction of Processing - you may request to limit the processing of your data;
      5. Right to Data Portability - you may request to receive your data in a structured, commonly used, and machine-readable format;
      6. Right to Object - you may object to the processing of your Personal data under certain circumstances (according to law and/or Company’s legal documents (Privacy Policy));
      7. Right to Withdraw Consent - you may withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
    3. If you wish to exercise any of the rights set out above, please contact us at moralesme@recourcesforedu.com.
    4. We try to respond to all legitimate requests within a period of 30 calendar days from the date of receiving your request. Occasionally it may take us longer than mentioned period 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.

  13. How to Delete Personal Data and Your User ID Information

    1. If you wish to delete your personal data or your User ID, you can do so by following these steps:
      1. Open the Mobile Application from your device with an assigned User ID;
      2. Find your specific User ID number;
      3. Contact the moralesme@recourcesforedu.com adding to your request information regarding your User ID and the action you want the Company to complete;
      4. Our support team may (or may not) request any additional information in order to identify you and/or confirm that it is you who is willing to delete your User ID from the record.
    2. Once your User ID information is deleted, all personal data associated with your User ID will be permanently removed from our servers, except where we are required to retain it for legal or regulatory reasons.
    3. The time period of deleting personal data may take up to 30 calendar days.

  14. Governing Law

    1. This Privacy Policy is governed by and construed in accordance with the laws of Costa Rica.
    2. Any legal action or proceeding arising under this Privacy Policy will be brought to the courts exclusively in the accordance of the legislation of Costa Rica and you consent to the jurisdiction of such courts.

  15. Complaints

    1. You have the right to lodge a complaint at any time to a competent supervisory authority on data protection matters, such as (in particular) the supervisory authority in the place of your habitual residence or your place of work.
    2. We would, however, appreciate the opportunity to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance.

  16. Contact Information

    1. If you have any requests or questions about these Privacy Policy or your Persona data, or if you would like to send us your comments, please contact us at moralesme@recourcesforedu.com.