This Privacy Policy describes the conditions under which Idioma Internacional Sociedad Anónima, corporate ID number 3-101-247478, hereinafter (“the Company”), processes the personal data provided by the respective data subjects.. The Company is committed to the security and proper handling ofthe information it processes for the purposes pursued by its organization.

Data Controller

For the purposes of Law No. 8968, the data controller is: Idioma Internacional S.A., legal entity ID 3-101-247478, headquartered at Avenues 2 and 4, Street 38, Matarredonda, San José 10108, Costa Rica.

Information Collected

The necessary information is collected through the Idioma Internacional website, online forms, the BELT (Benchmark Language Test), training programs, and the idi-Jobs platform. This includes, but is not limited to, full name, national ID number, contact information, email address, curriculum vitae and demographic information, images, voice and other biometric data, and any medical records and medical reports provided.

Specific information may be requested to process an order or complete a delivery or billing. All requested information is necessary and, if it is not provided, the Company may be unable to fulfill the purposes described in this policy. The data subject or their representative assumes responsibility for, and guarantees, the truthfulness, accuracy, and currency of the data collected.

Processing of Personal Data

This document covers online forms, the free BELT, the results Idioma produces, access to those results (BELT Lookup), academic data, and the idi-Jobs platform (profile, résumé, and interview video). Processing of personal data refers to any operation or set of operations performed on personal data through automated or manual procedures, including collection, recording, organization, storage, modification, extraction, consultation, use, transmission, dissemination, comparison, interconnection, blocking, assignment, rectification, deletion, anonymization, or destruction.

Purposes of Processing

Idioma Internacional assesses English proficiency through the BELT (CEFR-scored, levels A1–C2), delivers corporate and government training programs, and operates a job board (idi-Jobs, under development). Audiences whose data is processed: website visitors, business prospects, web purchasers, individuals assessed on behalf of companies, individuals assessed at job fairs, corporate and government program students (including minors), job board candidates, candidates for internal positions, employees, suppliers, clients, and partners.

Personal information is used for the following purposes: (i) maintaining a user registry, (ii) including users in the Company’s database for employment opportunities, (iii) informing users about job openings and matching candidate profiles with companies that require similar qualifications, (iv) offering English-learning scholarships, (v) sending service offers, promotions, events of interest, training opportunities, and general communications, (vi) improving products and services, (vii) conducting market analysis, product development, commercial initiatives, promotional initiatives, and data updates, (vi) building the idi-Jobs database records.

The information may also be used for statistical purposes. If the user authorizes it, periodic emails with offers, new products, or advertising information may be sent. These communications may be canceled at any time.

Image and Audiovisual Data

For BELT oral production assessments and virtual interviews conducted through video platforms, the Company may collect, process, store, and share image and audiovisual data, including video recordings, audio recordings, screenshots, and any visual or voice information captured during the process. This data will be processed exclusively for:

• Verification of identity, authenticity, and integrity of the assessments.

• Evaluation, scoring, and quality assurance.

• Internal training and process improvement, including the development of methodologies, platforms, and security protocols.

• Marketing and outreach through the idi-Jobs platform.

Storage and Retention of Image and Audiovisual Data

Video recordings and audiovisual data may be stored for operational, quality assurance, and verification purposes. These records will be retained only for as long as necessary to fulfill the purposes described or to meet legal or audit requirements; the applicable periods are set out in the section “Retention, Deletion, or Anonymization Periods.”

Third-Party Platforms and Providers

The video platforms used in the assessments may involve external providers that process audiovisual data on behalf of the Company under confidentiality and data protection agreements. The Company assumes no liability for any unlawful, improper, or illegitimate use of the information contained in such platforms in breach of those agreements, nor for use by third parties outside their scope.

Control of Personal Information

Individuals may restrict the collection or use of their personal information through the informed consents provided for the Company’s different platforms. When completing forms, users may also choose to accept or decline email communications. Users may exercise their rights of access, rectification, or deletion. Requests may be sent to info@idiomacr.com.

The Company will not sell, transfer, or distribute personal information collected without consent, except where there is a legal basis under Law No. 8968. If necessary for negotiation or formalization processes such as mergers, acquisitions, financing, or assignments, the Company may exchange personal information, providing only what is strictly necessary and ensuring appropriate legal safeguards.

The Company may transfer personal information to companies offering employment opportunities aligned with users’ profiles and is not responsible for misuse of the information transferred.

Retention, Deletion, or Anonymization Periods

Pursuant to Article 11 of Executive Decree 37554-JP, for the purposes of the processing described in this policy, the applicable periods are set as follows:

Category	Proposed Retention Period	Deletion/Anonymization Trigger
Assessment results	Current: 0–2 years / Historical: 2–4 years	Anonymization after 4 years, unless updated
Academic data	5 years after program completion	Deletion upon expiry of the retention period (retaining data needed to reissue certificates)
CV / profile	For as long as the account remains active	Account deletion or inactivity
Interview video	Tied to the candidate’s active presence in the job market	Withdrawal or inactivity — the shortest justifiable period
Inactive accounts	Prior notice at 24 months; deletion at 36 months	Automatic deletion of identifiable data; legal records and anonymized aggregate data are retained

 

Cookies Used on This Website

In order to guarantee the data subject the principles established in Law No. 8968 on the Protection of Individuals with Regard to the Processing of Their Personal Data and Executive Decree No. 37554-JP, we set out below the use of cookies made by this platform, so as to inform you as accurately as possible.

This website uses its own cookiesto personalize and facilitate the user’s browsing as much as possible. cookiesare associated only with an anonymous user and their computer and do not provide references from which the user’s personal data can be deduced. Users may configure their browser to notify them of and reject the installation of cookiessent by this website, without affecting their ability to access the content. However, please note that the website’s performance may be reduced.

We use persistent cookies, which are stored on the user’s device and allow browsing information to be retrieved on the next visit. They have an expiration date. These cookies allow us to personalize your visits based on your preferences (for example, country and language).

In addition, this website uses the following third-party cookies:

• ASP.NET_SessionId, ids, sAct: These cookies are session identifiers provided by the Microsoft ASP server and the system itself. They are used to identify a user who has logged in to our website.

• CookiesUserAccepted: This cookie is generated automatically when the website’s cookie policy is accepted, so that we do not show you the notice again once you have accepted it.

• Cookies implemented by Google:

• __utma: Used to distinguish users and sessions. The cookie is created when the JavaScript library runs and no __utma cookie exists. The cookie is updated every time data is sent to Google Analytics. (Default duration: two years from set/update.)

• __utmt: Used to throttle the request rate. (Default duration: 10 minutes.)

• __utmb: Used to determine new sessions or visits. The cookie is created when the JavaScript library runs and no __utmb cookie exists. The cookie is updated every time data is sent to Google Analytics. (Default duration: 30 minutes from set/update.)

• __utmc: Not used in ga.js. Set for interoperability with urchin.js. Historically, this cookie worked together with the __utmb cookie to determine whether the user was in a new session or visit. (Default duration: end of browser session.)

• __utmz: Stores the traffic source or campaign that explains how the user reached the site. The cookie is created when the JavaScript library runs and is updated every time data is sent to Google Analytics. (Default duration: six months from set/update.)

• __utmv: Used to store visitor-level custom variable data. This cookie is created when a developer uses the _setCustomVar method with a visitor-level custom variable. It was also used for the retired _setVar method. The cookie is updated every time data is sent to Google Analytics. (Default duration: two years from set/update.)

Advertising Cookies

These cookies allow us to effectively manage the advertising space on our website and on third-party websites, tailoring ad content to the service requested or to the way you use our website.

This website uses the Google AdWords remarketing tool. This tool allows ads to be published on Google’s Display Network based on users’ previous visits to our website. To achieve this, the pages of our website include a remarketing code or tag that sets cookies to determine the type of ad shown to the user based on their browsing on the website. Remarketing lists are kept in a database on Google’s servers, where all cookie IDs associated with each list or interest category are stored. Regarding remarketing cookies, users may disable Google’s use of cookies by visiting Google’s Ads Settings opt-out page. More information here: http://www.google.es/intl/es/policies/technologies/ads/ http://www.google.es/intl/es/policies/technologies/ads/

DoubleClick Advertising Cookie (Google)

DoubleClick is a third-party ad service for certain websites. Its http://www.google.es/intl/es/policies/technologies/ads/privacy policy is available at DoubleClick uses cookies to improve advertising. They are typically used to target ads based on content relevant to a user, improve campaign performance reporting, and avoid showing ads the user has already seen. DoubleClick cookies do not contain personally identifiable information. Sometimes the cookie contains an additional identifier similar to the cookie ID. This identifier is used to identify an advertising campaign to which a user has previously been exposed; however, DoubleClick stores no other data in the cookie, and no data allows personal identification.

Disabling or Deleting Cookies

You may exercise your right to disable or delete cookies from this website at any time.These actions are carried out differently depending on the browser you are using.

All modern browsers allow you to change cookie settings.These settings are usually found under “Options” or “Preferences” in your browser menu. You may also configure your browser or email client, and install free add-ons, to prevent web bugs from downloading when you open an email.

Below is guidance on how to access the cookie settings menu and, where applicable, private browsing in each of the main browsers:

• Internet Explorer: Tools > Internet Options > Privacy > Settings. see Microsoft Support or the browser’s Help.

• Firefox: Tools > Options > Privacy >History> Custom Settings. For more information, see see Mozilla Support or the browser’s Help.

• Chrome: Settings > Show advanced settings >-Privacy > Content settings. For more information, see Google Support or the browser’s Help.

• Safari: Preferences> Security. For more information, see Apple Support or the browser’s Help.

What Happens If I Disable Cookies?

To help you understand the possible effects of disabling cookies, here are some examples:

• The website will not be able to adapt its content to your personal preferences.

• It will not be possible to customize your geographic preferences, such as language.

• You will not be able to share content from this website on Facebook, X, or any other social network. All social networks use cookies; if you disable them, you will not be able to use any social network.

• The website will not be able to perform web analytics on visitors and traffic, which will make it harder for the website to remain competitive.

Additional Notes

• Neither this website nor its legal representatives are responsible for the content or accuracy of the privacy policies of the third parties mentioned in this cookie policy.

• Web browsers are the tools that store cookies,and it is from your browser that you should exercise your right to delete or disable them. Neither this website nor its legal representatives can guarantee the correct or incorrect handling of cookies by those browsers.

• In some cases, cookies must be installed so that the browser remembers your decision not to accept them.

• In the case of Google Analytics cookies, Google stores the cookies on servers located in the State of New York, United States of America, and undertakes not to share them with third parties, except where necessary for the operation of the system or where required by law.

• For any questions or complaints arising from this cookie policy, you may contact us at: info@idiomacr.com