AFnet policies

1. Objective

This policy applies to all processing of personal data carried out by AFnet and has the objective of informing the user regarding the way in which AFnet carries out the processing of personal data (including details of the type of personal data collected and the purpose of processing) and regarding the rights of the user in relation to their personal data.

2. Contact – How can I contact?

In case of having any questions about the Privacy Policy, the user can contact AFnet through the following means:

The user may establish direct and effective communication with AFnet by written communication sent to the designated email address: info@afnet.org.

In addition, information of the officer in charge of processing your personal data is listed below:

Trade name: AFnet Identity of the controller: AFnet Email: info@afnet.org

3. Processing identification – How do we collect personal data?

In compliance with current regulations on the protection of personal data, especially:

The California Privacy Rights Act 2023 (CPRA)

AFnet collects personal data in its possession when the user: (i). completes the forms of www.afnet.org ('Site'); (ii). subscribes to the newsletter; (iii). answers a poll or completes a web form; (iv). completes a printed form; (v). sends an email or communicates by phone, which are then loaded in the corresponding forms;

4. Personal Data Collected - What personal data do we collect?

AFnet collects information when visiting their web page, and mainly by completing its registration forms.

The following data is collected: full name, email, and phone number.

As a rule, when personal data is requested to use a service or access certain content, its delivery will not be mandatory, except for those cases where it is specifically indicated that it is data required for the provision of the service. In this case, the user may freely choose not to register and/or not to contract the services.

The user declares and guarantees that all the data provided by them are true and correct and undertakes to keep them updated. The changes may be communicated to the Data Protection Delegate or to the address indicated in Section 2 hereof.

Likewise, the user acknowledges that the data required by AFnet are necessary, adequate, and not excessive to carry out the purposes expressed in Section 5 hereof, which would be impossible to fulfill if said data are not provided.

Any false or inaccurate statement that occurs as a result of the information and data given, as well as the damages that such information may cause, will be the responsibility of the user.

5. Purpose - What do we use personal data for?

The personal data requested to the user will be used for the following purposes:

To provide our Service and fulfill your requests. We use your information to provide and maintain our Service, to process and fulfill your requests, to communicate with you about your use of our Service or changes to our Service, to respond to your inquiries, and for other customer service and business administration purposes. For example, when you enroll in a newsletter, we may use your personal information to deliver that newsletter to you.

Identification and authentication purposes. We may use your information for identification and authentication purposes. For example, when you enter your account login ID and password to enter one of our registration or login portals, we use your login credentials to authenticate your identity.

Personalization. We use your information to tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experience while using the Service.

Marketing and promotional purposes. We may use your information to send you news and newsletters, event updates, and to communicate with you about new features, offers, events, or products, or to otherwise contact you about information we think may be of interest to you. We may also use your information to display advertisements to you on our site (including to sell advertising space on the Service) and on other unaffiliated websites and services.

Research and reporting. We may use your information to administer surveys and questionnaires (online and offline) for research and reporting purposes to help us better serve individuals by learning more about their needs and the quality of the products, services, and educational information we provide. The survey responses may be utilized to determine the effectiveness of our Service, various types of communications, advertising campaigns and/or promotional activities.

Combining information. We (and our third-party business partners on our behalf) may merge, co-mingle, or otherwise combine information, including your personal information, in furtherance of the purposes described above.

To comply with legal obligations. We may use your information to comply with our legal obligations or to exercise or defend our rights or the rights of a third party, including complying with law enforcement or government authority requests and participating in compliance audits.

To protect us and others. We may use your information where we believe it necessary to investigate, prevent, or take action regarding suspected or actual illegal activities, fraud, situations involving potential threats to the safety of any person or to otherwise enforce this Policy, our Terms and Conditions, and the integrity of the Service.

Deidentified data. We may also deidentify or anonymize your data in such a way that you may not reasonably be re-identified by us or another party, and we may use this deidentified data for any purpose permitted under applicable law. To the extent we deidentify any data originally based on personal information, we will maintain and use such data in deidentified form and will not attempt to reidentify the data.

The data subject to treatment will not be used for purposes other than or incompatible with those mentioned above and that motivated its collection. Notwithstanding the foregoing, it is stated that the recorded data may be used, in addition to the purposes for which it was expressly collected, for the purpose of carrying out statistics, managing incidents, or conducting market studies. However, in the event that personal data is processed for a purpose other than that initially specified when collecting said data, a compatibility analysis will be carried out by AFnet in accordance with applicable regulations. The processing will only be authorized if the original purpose is compatible with the new purpose or allowed in accordance with an independent legal basis. In these cases, the user will be informed of the changes in purpose or legal justification for the processing of their data.

We remind the user that they can oppose the sending of commercial communications (unsubscribe) and stop receiving emails from AFnet, reliably notifying AFnet, which will proceed to interrupt in the shortest possible time after receiving such communication. For this purpose, it may send an email to the address indicated in Section 2 or directly follow the unsubscribe instructions detailed at the end of each email from AFnet.

6. How do we use your information?

We will use the information we collect about you for the following purposes:

• Administration info
• Creating user account
• Customer feedback collection
• Manage customer order
• Support
• Targeted advertising
• Site protection
• Manage user accounts
• Processing payment: Stripe

If we want to use your information for any other purpose, we will ask for your consent and use your information only when we receive your consent and then only for the purpose(s) for which consent will be granted, unless we are required by law to do otherwise.

We will retain your personal information with us for 24 months after user accounts remain idle or for as long as necessary to fulfill the purposes for which it was collected, as detailed in this Privacy Policy.

7. Consent

By providing personal data to AFnet, the user declares to accept its processing fully and without reservation by AFnet. The user gives his/her free, express, and informed consent to AFnet's use of the data collected for the purposes indicated in Section 5.

8. Validity - How long do we keep it?

The data will be destroyed or archived when it is no longer strictly necessary or relevant for the purposes described in Section 5 above.

9. Confidentiality / Assignment / International Transfer - Do we disclose data to third parties?

AFnet will keep collected personal data private and confidential and will not use it for purposes other than those set out in Section 5 hereof. The user's personal data collected by AFnet will not be transferred, sold, exchanged, transmitted, and/or communicated to third parties outside AFnet without the user's consent, except for legal obligations and/or for the purpose of providing the services to the user.

AFnet may share certain user-provided personal information internally within AFnet, with certain departments, such as administration, marketing, or IT.

Finally, you should be aware that AFnet may disclose your information in cases related to business transfers, compliance with the law, protection and facilitation of rights, public safety, and deidentified data use.

10. Security - How do we ensure data security?

AFnet implements necessary technical and organizational measures to protect personal data. While no system is completely secure, AFnet continuously monitors for security threats and promptly addresses any incidents.

11. Data owner rights and procedures to respond to their exercise

Users have rights to access, rectify, delete, restrict processing, and transfer their personal data, among others, in compliance with applicable laws. Requests should be directed to info@afnet.org.

12. Training

AFnet provides training to employees handling personal data to ensure compliance with privacy regulations.

13. Links to third parties

AFnet is not responsible for third-party websites linked from its Site and encourages users to review their privacy policies.

14. Children's Privacy

AFnet does not knowingly collect data from children under 13 without parental consent and complies with all relevant child data protection laws.

15. Cookies

AFnet uses cookies for analytics, advertising, and improving user experience, in line with its Cookie Policy.

16. Approval

By using the Site, users agree to AFnet's Privacy Policy and Terms and Conditions.

17. Do United States residents have specific Privacy Rights?

You may have certain rights regarding our processing of your personal information under applicable local law. If our processing of your personal information is governed by such laws, this section provides you with additional information regarding your rights and our processing of your personal information under applicable local law.

MARKETING COMMUNICATIONS

We may send periodic promotional emails to you. You may opt-out of promotional emails by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving promotional emails, we may still send you emails about your account or any services you have requested or received from us.

DATA RETENTION

Your personal information will be held for only so long as it is necessary for the purpose for which it was originally collected, and in accordance with applicable local law. We will retain your personal information for the period necessary to fulfill the purposes outlined in this Policy. When assessing retention periods, we first examine whether it is necessary to retain the personal information collected and, if retention is required, work to retain the personal information for the shortest possible period permissible under applicable law. To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of the personal information, the purposes for which we process the personal information, and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

YOUR PRIVACY CHOICES AND RIGHTS

Depending on the jurisdiction in which you live, you may have the following rights under applicable local law:

• Right to request access and a copy of your personal information and information relating to how it is processed;
• Right to request deletion of your personal information;
• Right to request the correction or update of the personal information we hold about you;
• Right to opt-out of “sales” of your personal information and “sharing” of your personal information for cross-context behavioral advertising purposes (as these terms are defined under applicable law);
• Right to opt-out of targeted advertising;
• Right to limit our use of your sensitive personal information;
• Right to not be unlawfully discriminated against for exercising your rights.

These rights may be limited or denied in some circumstances. For example, we may retain your personal information where required or permitted under applicable law. You may also opt-out of our “sale” or “sharing” of your personal information through privacy preference signals recognized under applicable local law, such as the Global Privacy Control (GPC), but please note that this signal will be linked to your browser only. For more information on the GPC and how to use a browser or browser extension incorporating the GPC signal, see https://globalprivacycontrol.org/.

VERIFICATION PROCESS

In order to protect your information, we will confirm a requestor’s identity before responding to any request. To start the process, you must provide your name and email. We will ask you at least one question, and you must reply by email with the correct answer for each question based on your previous interaction with us. If we still cannot verify your identity as required by applicable laws, we will let you know and may ask additional questions. Otherwise, we will acknowledge your request and contact you later with our full response. We will only send verification questions from info@afnet.org. Before sending a verification response, please double-check the email address. If you receive an email that appears to be from us but is not from our verification email address listed above, do not respond. Any information we gather through this process will only be used for consumer verification, security procedures, or fraud-prevention. We will delete any verification information as soon as practical after processing your request.

AUTHORIZED AGENTS

You may designate an authorized agent to exercise your rights under applicable laws on your behalf. Pursuant to applicable laws:

• You must provide the authorized agent written permission to exercise your rights under applicable laws on your behalf.
• We may deny a request from an authorized agent on your behalf if the authorized agent does not submit proof that he, she, or it has been authorized by you to act on your behalf if we request such proof, as permitted by applicable laws.
• Even if you use an authorized agent to exercise your rights under applicable laws on your behalf, pursuant to applicable laws we may still require that you verify your own identity directly to us.

FINANCIAL INCENTIVES

"Financial incentive" means a program, benefit, or other offering, including payments to consumers as compensation, for the disclosure, deletion, sale, or sharing of personal information.
The law permits financial incentives or a price or service difference if it is reasonably related to the value of the consumer's data. A business must be able to explain how the financial incentive or price or service difference is reasonably related to the value of the consumer's data.
The explanation must include:

• a good-faith estimate of the value of the consumer's data that forms the basis for offering the financial incentive or price or service difference; and
• a description of the method the business used to calculate the value of the consumer's data.

We may decide to offer a financial incentive (e.g., price or service difference) in exchange for the retention, sale, or sharing of a consumer's personal information.
We do not offer financial incentives to collect personal information and we will not discriminate against you if you exercise any of the rights provided by applicable laws set forth in this Privacy Policy. Please note that a legitimate denial of a request for information, deletion, or to opt-out is not discriminatory, nor is charging a fee for excessive or repetitive consumer requests as permitted by applicable laws.

APPEALS

If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at info@afnet.org. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may contact the Attorney General to submit a complaint.

CALIFORNIA RESIDENTS

California Civil Code Section 1798.83, also known as the 'Shine The Light' law permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

18. Modifications - Is this the most current version?

This is the current version of the AFnet Privacy Policy, updated on January 29, 2025.
AFnet may at any time and without prior notice, modify this Privacy Policy. Such modifications will be operative from their publication on the Site or when they are notified to users by any means, whichever occurs first. The user must keep informed about the terms included here by entering periodically.