Privacy policy

WHO WE ARE?

club.confidencial.digital is the website of the Membership Program of confidencial.digital, an independent media outlet directed by journalist Carlos Fernando Chamorro. Our team is recognized for its in-depth investigations, which have positioned CONFIDENCIAL as a highly influential journalistic multiplatform in Nicaragua, Central America, and internationally.

WHAT PERSONAL DATA DO WE COLLECT DURING THE ACTIVATION OF AN ACCOUNT AT CLUB.CONFIDENCIAL.DIGITAL?

When you create a free account or purchase a membership, our website requires you to share some personal data, such as your name, email address, and city of residence, among others. This information is collected solely for editorial purposes and is not shared with third parties. We use it to communicate directly with members of our community, in case follow-up on a reader’s request is needed, conduct surveys, or invite to webinars. Or else, to compile reports internally.

We also offer you the option to log in using your Facebook and Google social media accounts to register at club.confidencial.digital more conveniently and securely. If you do so, please note that you will be sharing your name and email address with us. The personal data shared depends on the settings of your social media platform, but generally, we only store the indicated information. We do not retain any other personal information. Please visit the respective social media platform and review its privacy policy to understand how your data is shared and used in this context.

We collect personal information that you voluntarily provide to us when you register for services, express interest in obtaining information about us or our products and services, when you engage in activities on the services, or when you communicate with us.

Personal information provided by you. The personal information we collect depends on the context of your interactions with us and the services, the choices you make, and the products and features you use. The personal information we collect may include the following:

  • Names
  • Phone numbers
  • Email addresses
  • Usernames
  • Passwords
  • Billing addresses
  • Debit/credit card numbers

Sensitive information. We do not process sensitive information.

Payment data. We may collect the necessary data to process your payment if you make purchases, such as your payment instrument number and the security code associated with your payment instrument. All payment data is stored by PayPal and Tilopay. You can find the links to their privacy notices here: PayPal Privacy Center and Tilopay Privacy Policy.

Social media login data. We may provide you with the option to register with us using the details of your existing social media account, such as your Facebook, Google, Twitter, or other social media account. If you choose to register this way, we will collect the information described in the section called “HOW DO WE HANDLE YOUR SOCIAL LOGIN?” below.

All personal information you provide must be true, complete, and accurate, and you must notify us of any changes to such personal information.

AUTOMATICALLY COLLECTED INFORMATION

In summary: certain information, such as your Internet Protocol (IP) address and/or browser and device characteristics, is automatically collected when you visit our services.

We automatically collect certain information when you visit, use, or browse the services. This information does not reveal your specific identity (such as your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referral URLs, device name, country, location information, information about how and when you use our services, and other technical information. This information is primarily needed to maintain the security and operation of our services and for our internal analytics and reporting purposes.

Like many companies, we also collect information through cookies and similar technologies.

The information we collect includes:

  • Log and usage data. Log and usage data is service-related, diagnostic, usage, and performance information that our servers automatically collect when you access or use our services and that we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings, and information about your activity in the services (such as date and time stamps associated with your use, pages and files viewed, searches, and other actions you take, such as which features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings).
  • Device data. We collect device data, such as information about your computer, phone, tablet, or other device you use to access the services. Depending on the device used, data from this device may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider, and/or mobile carrier, operating system, and system configuration information.
  • Location data. We collect location data, such as information about your device’s location, which may be accurate or inaccurate. The amount of information we collect depends on the type and settings of the device you use to access the services. For example, we may use GPS and other technologies to collect geolocation data that indicates your current location (based on your IP address). You can choose not to allow us to collect this information by either denying access to the information or by disabling Location settings on your device. However, if you choose to opt out, you may not be able to use certain aspects of the services.
  • Information collected when you use our Facebook apps. By default, we access your basic account information from your Facebook account, including your name, email, gender, date of birth, current city, and profile picture URL, as well as any other information you choose to make public. We may also request access to other permissions related to your account, such as friends, check-ins, and likes, and you may choose to grant or deny us access to each individual permission. For more information on Facebook permissions, please refer to the Facebook permissions reference page.

WHAT HAPPENS WITH THE COMMENTS YOU LEAVE ON OUR SITE?

When you leave comments on club.confidencial.digital, we collect the data shown in the comments form, as well as the visitor’s IP address and browser user agent string to help spam detection.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: Gravatar Privacy Policy.

After approval of your comment, your profile picture is visible to the public in the context of your comment.

COOKIES

If you leave a comment on our site you may opt-in to saving your name, email address, and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you have an account and you log in to this site, we will set up a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

EMBEDDED CONTENT FROM OTHER WEBSITES

Articles on this site may include embedded content (e.g., videos, images, articles, etc.). Embedded content from other websites behaves in the same way as if the visitor had visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

WITH WHOM DO WE SHARE YOUR DATA AND HOW LONG DO WE RETAIN IT WHEN YOU LEAVE A COMMENT ON OUR WEBSITE?

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users who register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

WHAT RIGHTS YOU HAVE OVER YOUR DATA?

If you have an account on this site or have left comments, you can request to receive an exported file of the personal data we hold about you, including any information you have provided to us. You can also request that we delete any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

In some regions (such as the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right to:

  • Request access to and receive a copy of your personal information.
  • Request rectification or erasure of your personal information.
  • Restrict the processing of your personal information.
  • Object to processing of your personal information.
  • Request portability of your personal information.
  • Not be subject to automated decision-making.

In certain circumstances, you may also have the right to withdraw your consent for the processing of your personal information. You can exercise these rights by contacting us using the contact information provided below.

If you are in the EEA or the UK and believe that we are unlawfully processing your personal information, you also have the right to lodge a complaint with your Member State’s data protection authority or the UK data protection authority.

If you are in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawal of Consent: If we rely on your consent to process your personal information, which may be explicit and/or implicit under applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us using the contact information provided below.

Please note, however, that this will not affect the lawfulness of processing before withdrawal nor, where applicable law permits, processing of your personal information based on legal processing grounds other than consent.

ACCOUNT INFORMATION

If at any time you wish to review or change your account information or cancel it, you can:

Contact us using the contact information provided.

If you request to cancel your account, we will deactivate or delete your account and your information from our active databases. However, we may retain certain information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms, and/or comply with applicable legal requirements.

Cookies and Similar Technologies: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and reject them. If you choose to delete or reject cookies, this could affect certain features or services of our services.

If you have questions or comments about your privacy rights, you can email us at [email protected].

WHERE DO WE SEND YOUR DATA?

Visitor comments may be checked by an automated spam detection service.

ADDITIONAL INFORMATION

How we protect your data

While browsing our website, registering, or conducting an electronic transaction, we always use a secure 256-bit SSL (Secure Socket Layer) encryption connection issued by an authorized certificate authority for this purpose, so all the information you submit through our site is private and processed encrypted.

SSL encryption provides a secure connection between your browser and our server. It is an internet protocol that allows sensitive data (such as your registration information or credit card data) to be encrypted and made unreadable to third parties. Additionally, a valid certificate confirms that the server is trustworthy. Currently, it is also called TLS (Transport Layer Security), which is also compatible with our server.

Regarding payment information — for example, your credit or debit card data — we use PayPal and Tilo Pay as the only payment methods, both services also use SSL technology to protect your information. When you make a payment through these platforms, we do not have access to your financial data.

HOW DO WE HANDLE YOUR SOCIAL LOGIN?

In summary: if you choose to register or log in to our services using a social media account, we may have access to certain information about you.

Our services offer you the option to register and log in using details from your third-party social media account (such as your Google, Facebook, or Twitter logins). When you choose to do this, we will receive certain information from your social media provider profile. The profile information we receive may vary depending on the social media provider in question but often includes your name, email address, friend list, and profile picture, as well as any other information you choose to make public on such social media platform. If you log in with Facebook, we may also request access to other permissions related to your account, such as your friends, check-ins, and likes, and you may choose to grant or deny us access to each individual permission.

We will use the information we receive only for the purposes described in this privacy notice or as otherwise clarified to you in the respective services. Please note that we do not control or are responsible for other uses of your personal information by your external social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information and how you can configure your privacy preferences on their sites and apps.

HOW DO WE KEEP YOUR INFORMATION SECURE?

In summary: our aim is to protect your personal information through a system of technical and organizational security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our security measures and efforts to protect your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to circumvent our security and improperly collect, access, steal, or modify your information. While we will make every effort to protect your personal information, the transmission of personal information to and from our services is at your own risk. You should only access the services within a secure environment.

DO WE COLLECT INFORMATION FROM MINORS?

In summary: we do not knowingly collect or market to children under the age of 18.

We do not knowingly solicit data from or market to children under 18 years of age. By using the services, you represent that you are at least 18 years old or that you are the parent or guardian of such a minor and consent to such minor’s use of the services. If we learn that personal information from users under 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under 18 years of age, please contact us at [email protected].

YOUR RIGHTS REGARDING YOUR PERSONAL DATA

Right to Request Deletion of Data — Deletion Request

You may request the deletion of your personal information. If you request us to delete your personal information, we will honor your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) another consumer’s exercise of their right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be necessary to protect against unlawful activities.

Right to Be Informed — Information Request

Depending on the circumstances, you have the right to know:

  • if we collect and use your personal information;
  • the categories of personal information we collect;
  • the purposes for which the collected personal information is used;
  • if we sell or share personal information with third parties;
  • the categories of personal information sold, shared, or disclosed for business purposes;
  • the categories of third parties to whom personal information was sold, shared, or disclosed for business purposes;
  • the business or commercial purpose for collecting, selling, or sharing personal information; and the specific pieces of personal information we collect about you.

According to applicable law, we are not required to provide or delete consumer information that is not identified in response to a consumer request, nor to re-identify individual data to verify a consumer request.

  • Right to Non-Discrimination for Exercising Privacy Rights
  • We will not discriminate against you if you exercise your privacy rights.
  • Right to Limit the Use and Disclosure of Confidential Personal Information
  • We do not process sensitive consumer personal information.
  • Verification Process

Upon receiving your request, we will need to verify your identity to determine that you are the same person with whom we have information in our system. These verification efforts require us to ask you to provide information so that we can compare it with the information you have previously provided. For example, depending on the type of request you submit, we may ask you to provide certain information so that we can compare it with the information we already have on record, or we may contact you through a communication method (e.g., phone or email) that you have provided to us previously. We may also use other verification methods as the circumstances dictate.

We will only use the personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for purposes of verification. However, if we cannot verify your identity from the information we already maintain, we may request that you provide additional information to verify your identity and for security or fraud-prevention purposes. We will delete such additional information as soon as we finish verifying you.

Other Privacy Rights

  • You may object to the processing of your personal information.
  • You may request the correction of your data if it is incorrect or no longer relevant, or request to restrict the processing of information.
  • You may designate an authorized agent to request the CCPA on your behalf. We may deny a request from an authorized agent who does not submit proof that they have been validly authorized to act on your behalf following the CCPA.
  • You may request to opt out of the future sale or exchange of your personal information. Upon receiving a request for opt-out, we will act upon it as soon as possible, but no later than fifteen (15) days from the date of submission of the request.

To exercise these rights, you may contact us by sending a request to the data subject access, by emailing us at [email protected], or by referring to the contact details at the end of this document. If you have a complaint about how we handle your data, we would like to hear from you.

HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

You have the right to request access to the personal information we collect from you, to change that information, or to delete it. To request a review, update, or deletion of your personal information, you may make your request via the email address indicated below.

HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have any questions or comments about this notice, you can email us at [email protected] or contact us by mail at:

Membership Program
From the presidential house, 400 meters west. In front of the George Angulo gym.
San Jose, San Jose 10101
Costa Rica