Privacy Notice

Company: LLU LATAM SA DE CV
RFC: LLA120216R74
Address: Batallón de San Patricio 111, Floor 26, Colonia Del Valle Oriente, San Pedro Garza García, Nuevo León, C.P. 66260, Mexico
Phone: + 44 7893 926 508
Website: http://cursosphere.mx/
Contact e-mail: __________________________

Effective Date: December 19, 2025
Last Updated: December 19, 2025

1. General Provisions, Purpose and Scope

This Privacy Policy (the “Policy”) sets out the legal grounds, purposes, scope, and conditions for the collection, use, storage, disclosure, and protection of personal data of individuals who use the CursoSphere.mx website (the “Website”, the “Platform”).

This Policy has been developed and is applied by LLU LATAM SA DE CV (the “Company”, the “Operator”, the “Data Controller”) in accordance with the laws of the United Mexican States, including the Federal Law on the Protection of Personal Data Held by Private Parties (Ley Federal de Protección de Datos Personales en Posesión de los Particulares – LFPDPPP), its regulations, and the official guidelines, criteria, and recommendations issued by the National Institute for Transparency, Access to Information and Protection of Personal Data (INAI).

This Policy applies to all users of the Platform without exception, including but not limited to:

• visitors to the Website;
• registered users;
• purchasers of online courses;
• authors, instructors, and other individuals who publish educational content;
• representatives of legal entities and partners interacting with the Platform.

2. Definitions

For the purposes of this Policy, the following terms shall have the meanings set forth below:

Personal Data — any information relating to an identified or identifiable natural person.

Processing of Personal Data — any operation or set of operations performed on personal data, whether or not by automated means, including collection, recording, organization, storage, use, disclosure, blocking, or deletion.

Data Subject — the natural person to whom the personal data relates.

Data Controller — the entity that determines the purposes and means of processing personal data.

3. Data Controller Information

The Data Controller responsible for the processing of personal data is:

LLU LATAM SA DE CV
RFC: LLA120216R74
Registered Address: Batallón de San Patricio 111, Floor 26, Colonia Del Valle Oriente, San Pedro Garza García, Nuevo León, C.P. 66260, Mexico
Phone: + 44 7893 926 508
E-mail: __________________________

4. Categories of Personal Data

In the course of using the Platform, the Company may process the following categories of personal data:

4.1. Identification Data
First name, last name, pseudonym, username, profile photograph, and other information voluntarily provided by the user.

4.2. Contact Data
Email address, telephone number, and other contact details voluntarily provided by the user.

4.3. Account Data
Login credentials, encrypted passwords, profile settings, login history, and security parameters.

4.4. Educational and Content Data
Information regarding purchased courses, learning progress, test results, certificates, comments, reviews, and content uploaded or published by course authors.

4.5. Technical and Usage Data
IP address, device identifiers, browser data, cookies, access logs, and information regarding interactions with the Platform interface.

4.6. Financial Information
The Company does not collect, store, or process users’ payment card details or banking information. All payment transactions are processed exclusively by third-party payment service providers.

5. Purposes of Personal Data Processing

Personal data is processed solely for lawful, specific, and explicit purposes, including:

• registration and administration of user accounts;
• provision of access to educational content and Platform services;
• operation of the online course marketplace;
• administration of relationships between users and course authors;
• delivery of service-related, informational, and legally significant communications;
• ensuring security and preventing fraud and misuse;
• compliance with applicable legal obligations;
• analysis and improvement of Platform functionality and user experience.

6. Legal Grounds for Processing

The processing of personal data is carried out on the basis of:

• the data subject’s free and informed consent;
• the necessity to perform contractual obligations;
• the legitimate interests of the Company;
• compliance with applicable Mexican laws and regulations.

7. Disclosure of Personal Data to Third Parties

The Company may disclose personal data to third parties strictly to the extent necessary to achieve the purposes described above, including:

• payment service providers and financial intermediaries;
• IT service providers, hosting services, and cloud infrastructure providers;
• analytical, marketing, and communication service providers;
• governmental, regulatory, or judicial authorities, where required by law.

The Company requires such third parties to maintain confidentiality and to implement appropriate personal data protection measures.

8. Cross-Border Transfer of Personal Data

In the course of using international services and infrastructure, personal data may be transferred to and processed on servers located outside the territory of Mexico. Such transfers are carried out subject to the implementation of appropriate safeguards ensuring a level of protection comparable to that required under the LFPDPPP.

9. Data Retention Periods

Personal data is retained in a form that permits identification of data subjects only for as long as necessary to fulfill the purposes for which it was collected, or for the period required by applicable law.

10. Data Subject Rights (ARCO Rights)

Data subjects have the rights of Access, Rectification, Cancellation, and Opposition (ARCO), including the right to:

• access their personal data;
• request correction or updating of inaccurate or incomplete data;
• request deletion of personal data;
• object to the processing of personal data.

Requests to exercise ARCO rights may be submitted using the Company’s contact details and will be handled within the timeframes established by Mexican law.

11. Personal Data Security Measures

The Company implements reasonable technical, administrative, and organizational measures to protect personal data against loss, unauthorized access, alteration, or disclosure, including:

• access control mechanisms;
• encryption and pseudonymization;
• restriction of employee access on a need-to-know basis;
• internal security policies and procedures.

12. Processing of Minors’ Data

The Platform is not intended for use by individuals who have not reached the minimum legal age under applicable law without the consent of their parents or legal guardians.

13. Amendments and Updates to This Policy

The Company reserves the right to amend or update this Policy at any time. The current version shall be published on the Website and shall become effective as of the date of publication.

14. Contact Information

For any questions related to the processing of personal data or the protection of privacy, users may contact the Company using the contact information published on the official CursoSphere.mx website.