Last modified: June 1st, 2024

AES LLC (hereinafter, “the Company”, “We”, “Us”) is firmly committed to regulatory
compliance and the privacy and protection of personal data. Accordingly, in the present
Privacy Policy, the User (hereinafter “the User”, “you”, “your”) will find all the relevant
information to better understand what we do with your personal data.

We may update this Privacy Policy according to new legislative or jurisprudential
requirements and/or business needs, among others. Any update or modification of the
present Privacy Policy will be considered applicable from the moment of its publication
on the website. Therefore, the User is recommended to review this Privacy Policy
regularly.

Please bear in mind that to access and use our website you must be an adult and have
the legal capacity to enter into contracts, according to the applicable national laws and
regulations of your birth or residence country.

Without affecting your rights under applicable legislation, the present Privacy Policy is
not contractual or part of your contract with us.

This Privacy Policy will always be available on this website so that the data subjects can
always consult them.

For any doubts or questions related to this Privacy Policy, you can contact our
Customer Service Team.

What Does Personal Data Mean?

For the purposes of this Privacy Policy, “personal data” means all data that identifies a
data subject or that could be used to identify him/her, such as the data you provided
when filling in your application form in order to obtain or renew the DS-l60 form. Moreover, we process your personal data when contacting our Customer Service Team as well as processing other information provided by you when browsing this website or from your IP address.

Who Is the Personal Data Controller?

The Company, as stated in our Terms and Conditions will be the controller of any
personal data collected from you, including, but not limited to, when you browse our
website, fill in your application form in order to obtain or renew the DS-l60 form, and/or
you contact our Customer Service Team by means of email.

When Does This Privacy Policy Apply?

This Privacy Policy applies to the personal data that we collect, use, and process from
you as a User and/or Customer of our website.

Our website may contain functionalities or links that may redirect you to third-party
websites. In this case, please note that these third-party websites are not operated by
us, so we cannot assume any responsibility for the information and content provided on
them, nor for the correct provision of the functionalities and/or services offered by these
third parties since we have no control over this. These third-party websites are bound by
their own cookie and privacy Policies.

What Type of Personal Data Do We Collect and Process?

We collect the following categories of personal data:

• Direct interactions: such as when you complete the application form on our
  website, or when we ask you for additional information, or when you fill in our
  Contact Form, or when you contact our Customer Service Team directly via
  email.

• Automated technologies: we may automatically collect information like your IP
  address, the sections you consult on our website, or the time that you remain on
  our website by using cookies, whether our own or from third parties.

• Payment data: We will only request your credit or debit card information on the
  payment page in connection with the costs for our Services. The captured data
  will be sent securely to our certified payment service providers for the
  authorization of the corresponding transaction. In no case do we visualize or
  access the complete data of your credit or debit card. It is the customer’s
  responsibility if he/she enters, provide, or sends his/her card information through
  channels not authorized by the Company.

 

In all cases, we only process personal data which is strictly necessary for the fulfilment
of the purposes described above. In this sense, if you provide us with more information
than that which is expressly required, you consent to the processing of said information
for the informed purpose/s for which you are sending it.

In order to be able to properly use our Services now and at any other time thereafter,
you must provide us with accurate, truthful, up-to-date, and complete information, about
your current personal situation.

If you provide us with the personal data of third parties, whether these are from minors
or adults, you confirm that you have informed them about the purposes for which their
personal data will be processed and you guarantee that you have obtained their prior
and express consent to communicate their personal data to us. In this sense, if you
provide us with the personal data of a minor, you guarantee that you are a parent and/or
legal guardian and, therefore, you consent to the processing of your child/ward’s
personal data.

According to the above, the Company will not be held responsible if:

• The users and/or Customers are not adults nor have the legal capacity to
  contract the Services offered on this Website in accordance with the laws and
  regulations of their birth or residence country. In this sense, it is the sole
  responsibility of parents and/or legal guardians to exercise adequate control over
  their minor children’s/ward’s online activity and to prevent their access to
  websites whose content is not suitable or recommended for minors and that
  allow the sending of personal data without the prior authorization of their parents
  or legal guardians.

• The Company has received an adult’s personal data and/or private information
  from an individual who is not the same as who is using the Services, without
  having requested his/her consent to communicate to us his/her personal data. In
  such a case, the Company will inform the interested person how his/her personal
  data and/or private information has been collected and, where appropriate, we
  will ask the individual who provided the personal data to the Company to confirm
  he/she requested the consent of the data subject and, where appropriate, to
  amend this circumstance.

• The circumstances are beyond our reasonable control, such as being provided
  with erroneous, incomplete, and/or fraudulent information from you as a user
  and/or Customer. You will be solely responsible for the inaccuracy or lack of
  veracity of the information provided.

Moreover, note that the Company is not a law firm and, therefore, does not provide legal
advice or legal representation. No attorney-client relationship is formalized by using the
Services offered herein. The Services offered through this Website do not replace, in
any case, a licensed attorney or specialized law firm. Therefore, if you think you need it,
we recommend that you consult with a duly licensed attorney.

What Do We Use Your Personal Data For?

Please be informed that you are only required to provide the personal data and
information strictly necessary to fill in your selected application form in order to obtain a
translated application form and/or to submit a query by means of our Contact Form. In
this sense, if you provide us with more information than that expressly required, you
consent to the processing of it for the purpose/s for which you are sending it.

Having said that, we use your personal data for the following purposes:

• To provide you with our Services and, when necessary, we will also probably ask
  you for additional information/documentation if the provided one is incomplete
  and/or erroneous.

• To attend to your information and/or refund inquiries sent to our Customer
  Service Department.

• To send you operational emails regarding our Service, such as payment
  confirmation emails.

• For administrative purposes related to processing and managing the Services
  offered, such as accounting and billing tasks and verification of your payment
  information.

• To comply with our legal obligations, legal requirements, laws, and regulations,
  and/or to respond to judicial, police, or other authority requirements.

• To protect, investigate, and prevent fraudulent, unauthorized, or illegal activities
  on or through this website.

• To improve our website, services, and customer support, and to enhance your
  user experience on our website by analyzing your behavior while browsing this
  website.

What Is the Legal Basis for Processing Your Personal Data?

We only process your personal data when there is a legal basis for doing so. The legal
basis will depend on the reason we collect and process your personal data.

In almost all cases the legal basis will be:

• The consent that you provided us with for the processing of your personal data in
  connection to the purposes informed at the time of collection of your data (i.e., to
  respond to your information queries when you contact our Customer Service
  Team).

• The execution of the contract when purchasing our Services or when sending
  you operational emails to keep you updated when sending you a payment
  confirmation email.

• To comply with our legal obligations and/or to attend administrative, judicial,
  police, or the corresponding authorities’ official requirements.

• Our legitimate interest to (i) offers an enhanced user experience when you
  access and use this website and to operate it efficiently, (ii) verify the Customer’s
  identity and monitor fraudulent activity in order to preserve the security and
  integrity of our website; (iii) defend and address our rights in the event that a
  claim regarding our professional services may arise.

How Long Do We Keep Your Personal Data?

We will only keep your personal data for as long as is necessary to fulfill the purposes
for which they are being processed and, beyond that, your personal data will be
retained, and duly blocked, until the Company has complied with its legal obligations
and has met with its business needs, objectives, and strategies. In this sense, your
personal data will be kept, for example, for as long as is needed in order to address and
defend our legitimate interests regarding any claims in connection with the Services
offered; until your request for information and/or refund is answered; to finish the
investigation of detected fraudulent or illicit activity; we will retain the Cookie data
providing that you do not revoke its consent.

Once the necessary retention period has ended, your personal data will be securely
deleted from our information systems.

Furthermore, if you had provided us with your consent to process your personal data for
specific purposes, note that you can withdraw said consent at any time. Upon receiving
your withdrawal request, we will proceed to delete your personal data.

Who Do We Share Personal Data With?

We may communicate your personal data to the following third parties, including, but
not limited to:

• (i) The Foreign consulates or embassies for the purpose of submitting your
  application,

• (ii) Credit and debit card companies to process payments and (when necessary)
  conduct fraud checks,

• (iii) Public agencies and/or administrative or judicial authorities, as well as the
  police, where required by applicable laws and regulations,

• (iv) Law firms to respond to any claims relating to our Services and/or to protect
  our legitimate interests,

• (v) Technology service providers who host our information systems and/or
  provide us with technology, tools, or support,

• (vi) Providers who assist us in properly providing our Services.

The third parties mentioned above may have their headquarters within the European
Economic Area; therefore, your personal data will not be subject to international
transfers. In this regard, we inform you that we will only carry out a personal data
international transfer to recipients settled in countries that offer an adequate level of
data protection or, failing that, we will apply the appropriate safeguards required by the
current applicable law and regulations on the protection of personal data in order to
ensure that your personal data is properly protected and that your individual rights and
freedoms are guaranteed.

How Do We Protect Your Personal Data?

Your trust is very important to us. For that reason, your personal data is stored
confidentially and securely in our information systems. We have established the
appropriate technical and organizational measures to safeguard and protect your
personal data against illegal or unauthorized access, loss, or accidental destruction,
damage, use, and illegal or unauthorized disclosure.

Likewise, we have taken reasonable precautions to guarantee that all our staff, as well
as the suppliers or collaborators who have access to Customers’ personal data, have
received adequate training regarding the processing of the personal data collected and
that they comply with said data protection obligations.

Although We will do our best to guarantee the protection of your personal data
transmitted through our website and/or that you may provide to us by other means such
as by email, please bear in mind that you should also take precautions to keep your
personal data safe e.g., you must not enter or confirm bank details by means of fake
messages and/or websites.

What Rights Do You Have and How Can You Exercise Them?

You may exercise your rights of access, rectification, erasure, restriction of processing,
and objection, as well as the right to the portability of your personal data, with a written
request addressed to us via our Contact Form.

You may modify the “privacy settings” of your web browser to set up the tracking
cookies at any time. Also, you can install programs or add-ons to your browser, known
as “Do Not Track” tools, which will allow you to choose the Cookies you want to allow.
Generally, we will respond to data protection rights requests within one (1) month.
Occasionally, this period may be extended by two (2) further months where necessary,
considering whether your request is particularly complex or if you have made several
requests. In this case, we will notify you of this event and explain the reasons for the
delay to you.

Finally, we inform you that, where you consider it appropriate, you have the right to
lodge a complaint before the corresponding Supervisory Authority, especially if you
consider that your data protection rights have not been adequately addressed.
We remain at your disposal for any doubts or questions you may have about the
present Privacy Policy or the processing of your personal data. If so, please do not
hesitate to contact us via our Contact Form.