Last updated: December 29, 2025

Nexara Digital LLC (“Nexara,” “we,” “us”) respects your privacy. This Policy explains what data we collect, how we use it, who we share it with, how long we retain it, and what rights you have depending on your location (including the EU/EEA/UK and the United States).

This Policy applies to: clubx12.com, forms, landing pages, services, communications (email/WhatsApp/calls), and any other related interaction or service agreement involving Club X12 and all services included within it

1) Data Controller

Controller: Nexara Digital LLC
Address: 150 SE 2nd Ave STE 1403 #6240, Miami FL 33131, United States of América
Privacy Email: [email protected]
General Email: [email protected]
Phone: +1 772 774 0180

If you are located in the EU/EEA/UK and Nexara offers services or monitors behavior within Europe, it may be necessary to appoint an EU Representative (Article 27 GDPR). See: gdpr-info.eu
EU Representative (if applicable): Teachtravel Technology S.L., Paseo de la Castellana, 200, 28046, Madrid (Spain)
Email: [email protected]

2) What Personal Data We Collect

Depending on how you interact with us, we may collect the following:

Identification and contact details: name, surname, email, phone number, company, country/city.

Account data (if applicable): credentials, preferences.

Service/operational data: information you provide via forms, support tickets, calls, meetings, messages, or shared files.

Billing/contract data: billing address, tax information, purchase history (note: we do not store full card details when using external payment gateways; this is handled by the payment provider).

Technical and usage data: IP address, device, browser, cookies/identifiers, navigation events, analytics, logs.

Marketing: preferences, opens/clicks, basic segmentation.

We do not intend to collect sensitive data (e.g., health, political views, etc.). If you accidentally send such data, we may delete or block it when reasonable.

3) Purposes: What We Use Your Data For

We use your data to:

Respond to inquiries and requests (contact, demos, support).

Deliver and manage services (registration, execution, follow-up, customer care).

Handle administrative and billing processes (contracts, payments, accounting).

Improve and secure the website and services (security, fraud prevention, audits, quality assurance).

Conduct marketing and commercial communications (only when legally permitted): newsletters, promotions, remarketing, event invitations.

Comply with legal obligations (tax/accounting requirements, requests from authorities).

4) Legal Bases (EU/EEA/UK)

If you are located in the EU/EEA/UK, we process your data under the following legal bases (depending on the case):

Consent (e.g., newsletters or certain cookies).

Performance of a contract or pre-contractual measures.

Legitimate interest (e.g., security, service improvement, basic analytics, reasonable marketing where appropriate).

Legal obligation.

5) Cookies and Similar Technologies

We may use cookies and similar technologies (first-party and third-party) for:

site functionality,

security,

analytics,

personalization,

advertising/remarketing (if you enable it or if permitted by applicable law).

You can manage cookies via [your preference banner/center] and/or your browser settings.

6) Who We Share Your Data With (Recipients)

We may share data with:

Service providers who help us operate: hosting, email/SMS/WhatsApp, CRM, analytics, payments, support, video calls, automation, storage, etc.

Professional advisors (legal, tax, audit) when necessary.

Authorities, if required by law or in response to a valid legal request.

We do not "sell" personal data in the traditional sense. However, certain U.S. laws consider some forms of digital advertising as “sale/sharing”; for this reason, we provide opt-out mechanisms where applicable (see U.S. section). oag.ca.gov +1

7) International Transfers (Especially EU/EEA/UK → U.S.)

As a U.S.-based company, some providers or systems may be located in the United States or other countries.

When required by regulation (EU/EEA), we use valid mechanisms such as:

Standard Contractual Clauses (SCCs) issued by the European Commission (Decision 2021/914) — EUR-Lex

EU–U.S. Data Privacy Framework (DPF) if the recipient is certified — European Commission

For the UK, transfer tools like the IDTA or the UK Addendum — ICO

8) Data Retention

We retain data only as long as necessary to:

provide the service,

respond to your request,

comply with legal obligations (e.g., tax/accounting),

or where there is a legitimate need (e.g., security).

Marketing: until you unsubscribe or withdraw your consent (if applicable).

9) Security

We apply reasonable technical and organizational measures to protect your data (access controls, encryption when applicable, backups, minimum privilege policies, etc.). No system is 100% invulnerable — but we’re not taking a “flip-flop” approach to security.

10) Your Rights (EU/EEA and UK)

If you are located in the EU/EEA or the UK, you have the right to:

Access, rectify, delete, object, restrict processing, and data portability.

Withdraw your consent when it is the legal basis (without affecting prior processing).

File a complaint with your data protection authority (e.g., AEPD in Spain or another European authority).

To exercise your rights: email us at [[email protected]] with the subject “Privacy” and state your request. We may ask for information to verify your identity.

11) U.S. Privacy Notice (CCPA/CPRA + State Laws, When Applicable)

Depending on your state and whether Nexara meets legal thresholds, you may have the right to:

Know/access the personal data we collect about you.

Delete your personal data.

Correct inaccurate data (CPRA). — oag.ca.gov

Opt out of:

the “sale” of personal data,

“sharing” for behavioral/targeted advertising,

profiling with significant effects (in some states). — Husch Blackwell

Limit the use/disclosure of sensitive personal information (CPRA). — oag.ca.gov

Not be discriminated against for exercising your rights.

11.1) How to Exercise Your Rights (U.S.)
You may submit your request to: [[email protected]]
Subject: “US Privacy Request”

Please include: your name, email, state of residence, and the right you wish to exercise. We will reasonably verify your identity.

11.2) “Do Not Sell or Share” / Advertising Opt-Out
If applicable to you, Nexara will offer:

a link on the website: “Do Not Sell or Share My Personal Information” / “Opt-out of Targeted Advertising”, and/or

recognition of signals such as Global Privacy Control (GPC), where appropriate. — oag.ca.gov

11.3) Colorado: Universal Opt-Out
If you’re in Colorado and it applies, we recognize universal opt-out mechanisms for sales/targeted advertising as required. — coag.gov

11.4) Appeals
In some states (e.g., Virginia), you may appeal a decision regarding your request. If denied, we will provide a way to file a complaint with the appropriate authority. — Office of the Attorney General of Virginia

12) Minors

Our services are not directed at children under 13 years old (or the applicable minimum age). If we discover that we have inadvertently collected data from a minor, we will delete it.

13) Changes to This Policy

We may update this Policy to reflect legal, technical, or operational changes. We will publish the current version along with its effective date.

14) Contact

For any questions regarding privacy:
[email protected]
Nexara Digital LLC — 12186 SW 131 ST AVE, Miami, FL 33186
Tel: +34 916 199 587