PRIVACY POLICY
Last updated January 01, 2025
This Privacy Notice for COHIBA IMMIGRATION & CONSULTING INC (doing business as
SuzanneElizabeth_Oficial) ("we," "us," or "our"), describes how and why we might access, collect,
store, use, and/or share ("process") your personal information when you use our services
("Services"), including when you:
• Download and use our mobile application (TIKTOK), or any other application of ours that
links to this Privacy Notice
• Engage with us in other related ways, including any sales, marketing, or events
Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights
and choices. We are responsible for making decisions about how your personal information is
processed. If you do not agree with our policies and practices, please do not use our Services. If you
still have any questions or concerns, please contact us at cohibainc@gmail.com.
SUMMARY OF KEY POINTS
This summary provides key points from our Privacy Notice, but you can find out more details
about any of these topics by clicking the link following each key point or by using our table of
contents below to find the section you are looking for.
What personal information do we process? When you visit, use, or navigate our Services, we
may process personal information depending on how you interact with us and the Services, the
choices you make, and the products and features you use. Learn more about personal information
you disclose to us.
Do we process any sensitive personal information? Some of the information may be considered
"special" or "sensitive" in certain jurisdictions, for example your racial or ethnic origins, sexual
orientation, and religious beliefs. We may process sensitive personal information when necessary
with your consent or as otherwise permitted by applicable law. Learn more about sensitive
information we process.
Do we collect any information from third parties? We do not collect any information from third
parties.
How do we process your information? We process your information to provide, improve, and
administer our Services, communicate with you, for security and fraud prevention, and to comply
with law. We may also process your information for other purposes with your consent. We process
your information only when we have a valid legal reason to do so. Learn more about how we
process your information.In what situations and with which parties do we share personal information? We may share
information in specific situations and with specific third parties. Learn more about when and with
whom we share your personal information.
How do we keep your information safe? We have adequate organizational and technical
processes and procedures in place to protect your personal information. However, 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 defeat our security and improperly collect, access, steal, or modify your
information. Learn more about how we keep your information safe.
What are your rights? Depending on where you are located geographically, the applicable privacy
law may mean you have certain rights regarding your personal information. Learn more about your
privacy rights.
How do you exercise your rights? The easiest way to exercise your rights is by submitting a data
subject access request, or by contacting us. We will consider and act upon any request in
accordance with applicable data protection laws.
Want to learn more about what we do with any information we collect? Review the Privacy Notice in
full.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
4. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
5. HOW LONG DO WE KEEP YOUR INFORMATION?
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
7. DO WE COLLECT INFORMATION FROM MINORS?
8. WHAT ARE YOUR PRIVACY RIGHTS?
9. CONTROLS FOR DO-NOT-TRACK FEATURES
10. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
11. DO WE MAKE UPDATES TO THIS NOTICE?
12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.We collect personal information that you voluntarily provide to us when you express an interest in
obtaining information about us or our products and Services, when you participate in activities on the
Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that 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
Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable
law, we process the following categories of sensitive information:
• financial data
• genetic data
• credit worthiness data
• social security numbers or other government identifiers
Social Media Login Data. We may provide you with the option to register with us using your
existing social media account details, like your Facebook, X, or other social media account. If you
choose to register in this way, we will collect certain profile information about you from the social
media provider, as described in the section called "HOW DO WE HANDLE YOUR SOCIAL
LOGINS?" below.
All personal information that you provide to us must be true, complete, and accurate, and you must
notify us of any changes to such personal information.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services,
communicate with you, for security and fraud prevention, and to comply with law. We may also
process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you
interact with our Services, including:
• To deliver and facilitate delivery of services to the user. We may process your
information to provide you with the requested service.
• To respond to user inquiries/offer support to users. We may process your information to
respond to your inquiries and solve any potential issues you might have with the requested
service.
• To send administrative information to you. We may process your information to send you
details about our products and services, changes to our terms and policies, and other similar
information.
• To enable user-to-user communications. We may process your information if you choose
to use any of our offerings that allow for communication with another user.• To send you marketing and promotional communications. We may process the personal
information you send to us for our marketing purposes, if this is in accordance with your
marketing preferences. You can opt out of our marketing emails at any time. For more
information, see "WHAT ARE YOUR PRIVACY RIGHTS?" below.
• To protect our Services. We may process your information as part of our efforts to keep
our Services safe and secure, including fraud monitoring and prevention.
• To comply with our legal obligations. We may process your information to comply with our
legal obligations, respond to legal requests, and exercise, establish, or defend our legal
rights.
3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL
INFORMATION?
In Short: We may share information in specific situations described in this section and/or with the
following third parties.
We may need to share your personal information in the following situations:
• Business Transfers. We may share or transfer your information in connection with, or
during negotiations of, any merger, sale of company assets, financing, or acquisition of all or
a portion of our business to another company.
4. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
In Short: 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 ability to register and log in using your third-party social media account
details (like your Facebook or X logins). Where you choose to do this, we will receive certain profile
information about you from your social media provider. The profile information we receive may vary
depending on the social media provider concerned, but will often include your name, email address,
friends list, and profile picture, as well as other information you choose to make public on such a
social media platform.
We will use the information we receive only for the purposes that are described in this Privacy Notice
or that are otherwise made clear to you on the relevant Services. Please note that we do not control,
and are not responsible for, other uses of your personal information by your third-party 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 set your privacy preferences on their sites
and apps.
5. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this
Privacy Notice unless otherwise required by law.We will only keep your personal information for as long as it is necessary for the purposes set out in
this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax,
accounting, or other legal requirements).
When we have no ongoing legitimate business need to process your personal information, we will
either delete or anonymize such information, or, if this is not possible (for example, because your
personal information has been stored in backup archives), then we will securely store your personal
information and isolate it from any further processing until deletion is possible.
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and
technical 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
safeguards and efforts to secure 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 defeat
our security and improperly collect, access, steal, or modify your information. Although we will do our
best to protect your personal information, transmission of personal information to and from our
Services is at your own risk. You should only access the Services within a secure environment.
7. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we
knowingly sell such personal information. By using the Services, you represent that you are at least
18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s
use of the Services. If we learn that personal information from users less than 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 age 18, please contact us at cohibainc@gmail.com.
8. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: You may review, change, or terminate your account at any time, depending on your
country, province, or state of residence.
Withdrawing your consent: If we are relying on your consent to process your personal information,
which may be express and/or implied consent depending on the applicable law, you have the right to
withdraw your consent at any time. You can withdraw your consent at any time by contacting us byusing the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS
NOTICE?" below.
However, please note that this will not affect the lawfulness of the processing before its withdrawal
nor, when applicable law allows, will it affect the processing of your personal information conducted
in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our
marketing and promotional communications at any time by clicking on the unsubscribe link in the
emails that we send, or by contacting us using the details provided in the section "HOW CAN YOU
CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing lists.
However, we may still communicate with you — for example, to send you service-related messages
that are necessary for the administration and use of your account, to respond to service requests, or
for other non-marketing purposes.
If you have questions or comments about your privacy rights, you may email us at
9. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-
Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data
about your online browsing activities monitored and collected. At this stage, no uniform technology
standard for recognizing and implementing DNT signals has been finalized. As such, we do not
currently respond to DNT browser signals or any other mechanism that automatically communicates
your choice not to be tracked online. If a standard for online tracking is adopted that we must follow
in the future, we will inform you about that practice in a revised version of this Privacy Notice.
California law requires us to let you know how we respond to web browser DNT signals. Because
there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do
not respond to them at this time.
10. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY
RIGHTS?
In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa,
Kentucky, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee,
Texas, Utah, or Virginia, you may have the right to request access to and receive details about the
personal information we maintain about you and how we have processed it, correct inaccuracies, get
a copy of, or delete your personal information. You may also have the right to withdraw your consent
to our processing of your personal information. These rights may be limited in some circumstances
by applicable law. More information is provided below.
Categories of Personal Information We Collect
We have collected the following categories of personal information in the past twelve (12) months:Category A. Identifiers B. Personal information as
defined in the California
Customer Records statute
C. Protected classification
characteristics under state or
federal law
D. Commercial information E. Biometric information F. Internet or other similar
network activity
G. Geolocation data H. Audio, electronic, sensory,
or similar information
I. Professional or
employment-related
information
J. Education Information K. Inferences drawn from
collected personal
information
L. Sensitive personal
Information
Examples Collected
Contact details, such as real name, alias,
postal address, telephone or mobile contact
number, unique personal identifier, online
YES
identifier, Internet Protocol address, email
address, and account name
Name, contact information, education,
employment, employment history, and
YES
financial information
Gender, age, date of birth, race and ethnicity,
national origin, marital status, and other
NO
demographic data
Transaction information, purchase history,
financial details, and payment information NO
Fingerprints and voiceprints
NO
Browsing history, search history, online
behavior, interest data, and interactions with
NO
our and other websites, applications,
systems, and advertisements
Device location
NO
Images and audio, video or call recordings
created in connection with our business
NO
activities
Business contact details in order to provide
you our Services at a business level or job
NO
title, work history, and professional
qualifications if you apply for a job with us
Student records and directory information
NO
Inferences drawn from any of the collected
personal information listed above to create a
NO
profile or summary about, for example, an
individual’s preferences and characteristics
Citizenship or immigration status, financial
information including account access details, YESdrivers' licenses, debit or credit card numbers,
contents of email or text messages, national
origin, passport numbers, social security
numbers and state id card numbers
We only collect sensitive personal information, as defined by applicable privacy laws or the purposes
allowed by law or with your consent. Sensitive personal information may be used, or disclosed to a
service provider or contractor, for additional, specified purposes. You may have the right to limit the
use or disclosure of your sensitive personal information. We do not collect or process sensitive
personal information for the purpose of inferring characteristics about you.
We may also collect other personal information outside of these categories through instances where
you interact with us in person, online, or by phone or mail in the context of:
• Receiving help through our customer support channels;
• Participation in customer surveys or contests; and
• Facilitation in the delivery of our Services and to respond to your inquiries.
We will use and retain the collected personal information as needed to provide the Services or for:
• Category A - 5 YEARS.
• Category B - As long as the user has an account with us
• Category L - 5 YEARS
Sources of Personal Information
Learn more about the sources of personal information we collect in "WHAT INFORMATION DO
WE COLLECT?"
How We Use and Share Personal Information
Learn more about how we use your personal information in the section, "HOW DO WE
PROCESS YOUR INFORMATION?"
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract
between us and each service provider. Learn more about how we disclose personal information to in
the section, "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"
We may use your personal information for our own business purposes, such as for undertaking
internal research for technological development and demonstration. This is not considered to be
"selling" of your personal information.
We have not disclosed, sold, or shared any personal information to third parties for a business or
commercial purpose in the preceding twelve (12) months. We will not sell or share personal
information in the future belonging to website visitors, users, and other consumers.Your Rights
You have rights under certain US state data protection laws. However, these rights are not absolute,
and in certain cases, we may decline your request as permitted by law. These rights include:
• Right to know whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request the deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of the processing of your personal data if it is used for targeted
advertising (or sharing as defined under California’s privacy law), the sale of personal
data, or profiling in furtherance of decisions that produce legal or similarly significant
effects ("profiling")
Depending upon the state where you live, you may also have the following rights:
• Right to access the categories of personal data being processed (as permitted by
applicable law, including Minnesota’s privacy law)
• Right to obtain a list of the categories of third parties to which we have disclosed
personal data (as permitted by applicable law, including California's and Delaware's
privacy law)
• Right to obtain a list of specific third parties to which we have disclosed personal data
(as permitted by applicable law, including Minnesota's and Oregon's privacy law)
• Right to review, understand, question, and correct how personal data has been profiled
(as permitted by applicable law, including Minnesota’s privacy law)
• Right to limit use and disclosure of sensitive personal data (as permitted by applicable
law, including California’s privacy law)
• Right to opt out of the collection of sensitive data and personal data collected through
the operation of a voice or facial recognition feature (as permitted by applicable law,
including Florida’s privacy law)
How to Exercise Your Rights
To exercise these rights, you can contact us by submitting a data subject access request, by
emailing us at cohibainc@gmail.com, or by referring to the contact details at the bottom of this
document.
Under certain US state data protection laws, you can designate an authorized agent to make a
request on your behalf. We may deny a request from an authorized agent that does not submit proof
that they have been validly authorized to act on your behalf in accordance with applicable laws.
Request Verification
Upon receiving your request, we will need to verify your identity to determine you are the same
person about whom we have the information in our system. We will only use personal information
provided in your request to verify your identity or authority to make the request. However, if wecannot verify your identity from the information already maintained by us, we may request that you
provide additional information for the purposes of verifying your identity and for security or fraud-
prevention purposes.
If you submit the request through an authorized agent, we may need to collect additional information
to verify your identity before processing your request and the agent will need to provide a written and
signed permission from you to submit such request on your behalf.
Appeals
Under certain US state data protection laws, if we decline to take action regarding your request, you
may appeal our decision by emailing us at cohibainc@gmail.com. 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 submit a complaint to your state
attorney general.
California "Shine The Light" Law
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 by using the contact details
provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"
11. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this Privacy Notice from time to time. The updated version will be indicated by an
updated "Revised" date at the top of this Privacy Notice. If we make material changes to this Privacy
Notice, we may notify you either by prominently posting a notice of such changes or by directly
sending you a notification. We encourage you to review this Privacy Notice frequently to be informed
of how we are protecting your information.
12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at cohibainc@gmail.com or
contact us by post at:
COHIBA IMMIGRATION & CONSULTING INC
529 NW PRIMA VISTA BLVD
PORT ST LUCIE, FL 34983
United States13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE
COLLECT FROM YOU?
Based on the applicable laws of your country or state of residence in the US, you may have the right
to request access to the personal information we collect from you, details about how we have
processed it, correct inaccuracies, or delete your personal information. You may also have the right
to withdraw your consent to our processing of your personal information. These rights may be limited
in some circumstances by applicable law. To request to review, update, or delete your personal
information, please fill out and submit a data subject access request.
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