プライバシーポリシー

Who we are

Derechos del Fútbol, LLC, a Delaware limited liability company ("MINERVA", "we", "us"), operates MINERVA Business Academy at minervabusiness.com and is the controller responsible for the personal information described in this Privacy Policy. This policy applies to our website, our online campus, our emails and our other services (together, the "Services").

For any question or request about your personal information, write to info@minervabusiness.com.

Information we collect

• Account information: your name, email address, password (which we store only in protected, hashed form), language, time zone and the choices you make, such as accepting our terms or agreeing to receive marketing emails, together with the date and technical details of each choice.
• Purchase information: the course and offer you buy, your order number, the price, the currency and the country used to set the price, the status of the payment, your receipts and any withdrawal or refund request you make. Card details are processed by Stripe; we do not receive or store your full card number.
• Learning information: your progress, completed lessons, the course materials you download, answers, assessments, submissions and results, your attendance at live sessions and, if a session you take part in is recorded, your image, voice and messages in it, as well as the certificates issued to you and the visibility choices you make for them.
• Communications: the messages you send us, for example through our contact form or by email, our replies and the reminders and notices you choose to receive.
• Technical information: your IP address and the approximate location derived from it (country, region and city), information about your device and browser, and activity and error records (logs) that we keep to operate and secure the Services.
• Cookies and similar technologies: as described in our Cookie Policy.

You must give us the information needed to create an account and to buy a course; without it, we cannot provide those Services. Any other information is optional.

How we use it and legal bases

We use your personal information for the following purposes and on the following legal bases:

• To perform our contract with you: to create and manage your account, process your purchases, give you access to your courses, grade your assessments, issue your certificates, handle withdrawal and refund requests (including checking whether a course has been used), provide support and send you service messages about your account and your purchases.
• For our legitimate interests: to keep the Services secure; to prevent and investigate fraud and abuse, including by verifying the country used to set prices; to improve our courses and Services; to produce our own usage statistics without cookies, including statistics about purchases, enrollments and course activity linked to accounts; and to establish, exercise or defend legal claims. We weigh these interests against your rights, and you can object to this use.
• With your consent: to use analytics and advertising cookies, to send you marketing emails and to show your certificate on its public verification page when you choose to make it visible. You can withdraw your consent at any time; this does not affect the use made before you withdraw it.
• To comply with legal obligations: for example, to keep accounting and tax records and to respond to lawful requests from authorities.

Some assessments are scored automatically against the criteria set for each course, and those scores determine your results and whether you meet the requirements for a certificate. If you believe that a result is wrong, contact us and a member of our team will review it.

Advertising and measurement

We use Google Tag Manager to manage the measurement tags on our website. If you give your consent, we also use:

• Google Analytics, to measure visits and how our website is used;
• Google Ads, to measure the results of our advertising and show you relevant ads on Google services; and
• the Meta Pixel, to measure the results of our advertising and show you relevant ads on Facebook and Instagram.

These services may collect the pages you visit, the courses you view and when you start a checkout, create an account or complete a purchase (with an order reference, the amount and the currency), together with cookie identifiers, your IP address and information about your device and browser. Google and Meta may combine this information with other information they hold about you and use it in accordance with their own policies: see how Google uses information from sites that use its services (external site) and the Meta Privacy Policy (external site).

We load Google Tag Manager, and with it Google's tags, only after you accept analytics or advertising cookies. Until then, and if you reject them, Google receives no information from our website. If you accept only one of these categories, Google's consent mode tells its tags not to use the cookies of the other category. The Meta Pixel is loaded only after you accept advertising cookies.

You can give, refuse or withdraw your consent at any time through the "Cookie preferences" link at the bottom of every page. You can also manage the ads you see in your Google and Meta account settings.

Who we share it with

We do not sell personal information for money. We share personal information only as follows:

• Service providers that process it on our behalf and under our instructions: our server and storage providers; Cloudflare, which delivers and protects our website, identifies the country used to set prices and measures the performance of our pages; Brevo, which sends our emails; Stripe for payments; Vimeo for video playback; and, where a course includes live sessions, video-conferencing providers.
• Google and Meta, for measurement and advertising, only with your consent and as described above.
• People who verify your certificate, who see only the information you choose to show on its verification page.
• Authorities, courts and professional advisers, when the law requires it or when it is necessary to establish, exercise or defend our rights.
• A buyer or successor, if we are involved in a merger, acquisition, financing or sale of all or part of our business, in which case your information will remain subject to this Privacy Policy.

Under some United States state privacy laws, allowing Google and Meta to collect information through advertising cookies may be considered a "sale" or "sharing" of personal information, or "targeted advertising". We allow it only if you accept advertising cookies, and you can opt out at any time by rejecting them through "Cookie preferences".

International transfers

MINERVA is based in the United States, and our service providers may process personal information in the United States and in other countries whose data protection laws may differ from those of your country. When the law requires it, we protect these transfers with appropriate safeguards, such as the standard contractual clauses approved by the European Commission, the United Kingdom addendum to those clauses or adequacy decisions, including the EU-U.S. Data Privacy Framework when a provider is certified under it. You can ask us for information about these safeguards by writing to info@minervabusiness.com.

How long we keep it

• Account and learning information: for as long as your account is active. When your account is closed, we delete or anonymise this information within a reasonable period, except for the information we must keep for the purposes below.
• Purchase records: for as long as tax, accounting and other laws require, and as needed to handle claims and chargebacks. Withdrawal and refund requests are kept with the purchase they refer to.
• Certificates: for as long as needed so that anyone with the code can verify them, which is part of their value. You can make a certificate private at any time.
• Usage statistics: the events of our own analytics, for up to 25 months.
• Technical records: sign-in sessions (with your IP address and browser), verification codes and similar records are deleted shortly after they expire, and server logs within 12 months, unless we need them for longer to investigate a security incident or fraud.
• Records of administrative actions, such as changes that our staff make to your account: for as long as needed to show how we handled your account and to establish, exercise or defend legal claims.
• Backups: information deleted from our systems may remain in our encrypted backups until they are replaced in the normal backup cycle, and in any case for no more than 14 months.
• Consent records and communication preferences: for as long as needed to show that we have respected your choices.

Security

We protect personal information with technical and organisational measures appropriate to the risk, including encryption in transit, encryption of sensitive credentials at rest, encrypted backups, role-based access controls for our staff and limits on the personal information that we record in logs. Card payments are handled by Stripe. No system is completely secure: if a security incident affects your personal information, we will notify you and the competent authorities when the law requires it. Please keep your password safe and tell us immediately if you suspect that someone has accessed your account without authorisation.

Your rights

Depending on where you live, you may have the right to:

• access your personal information and obtain a copy of it;
• correct inaccurate or incomplete information;
• have your information deleted;
• receive your information in a structured, machine-readable format and transmit it to another provider (portability);
• object to our use of your information, including for direct marketing;
• ask us to restrict the use of your information in certain cases; and
• withdraw your consent at any time.

If you live in a United States state with a consumer privacy law, such as California, you may also have the right to know what personal information we collect and how we use and disclose it, to opt out of the "sale" or "sharing" of personal information and of targeted advertising, and not to be discriminated against for exercising your rights. You may act through an authorised agent and, if we decline your request, you can appeal the decision by replying to our message.

You can download a copy of your information at any time from the Settings section of your account. To exercise any of your rights, write to info@minervabusiness.com. We may ask you for information to verify your identity. We will respond within the period set by the law that applies to you and in any case within 30 days; if you live in Argentina, we respond to access requests within 10 calendar days and to requests to correct or delete information within 5 business days. You can also stop receiving marketing emails at any time from your account settings.

You also have the right to lodge a complaint with the data protection authority of your country or place of residence.

If you live in Argentina: you may exercise your right of access free of charge at intervals of not less than six months, unless you show a legitimate interest in doing so earlier, as provided in article 14(3) of Law 25,326. The Agencia de Acceso a la Información Pública, as the supervisory authority under Law 25,326, has the power to handle the complaints and claims of anyone whose rights are affected by a breach of the rules on the protection of personal data.

Children

The Services are intended for adults. Minors may use them only as described in our Terms and Conditions, with the consent and supervision of a parent or legal guardian, and the Services are not directed to children under 16. We do not knowingly collect personal information from children under 16 without the consent of a parent or legal guardian. If you believe that a child has given us personal information without that consent, contact us and we will delete it.

Changes

We may update this Privacy Policy from time to time. We will publish each new version on this page with its effective date and, if the changes are significant, we will notify you by email or through the Services before they take effect.

Contact

For any question or request about your personal information, write to info@minervabusiness.com or use our contact form.