Privacy and Data Confidentiality Policy

This Policy describes how Enséñame (also referred to as “the Platform,” “we,” or “our”) collects, uses, stores, protects, shares, and deletes the personal data of individuals who interact with its websites, virtual campuses, apps, forms, support channels, store, and other digital assets (collectively, “the Platform”), as well as the confidentiality rules applicable to information managed or obtained through such interactions.

Summary: Enséñame processes personal data to provide, manage, and improve its services as a digital training technology ecosystem, including the creation, management, and deployment of online courses, training programs, learning paths, and educational content (proprietary and third-party), as well as tracking tools, assessment, learning analytics, and reporting.

Data is also used to handle requests, provision user accounts and manage access control, facilitate interaction with content and partner providers, fulfill contractual obligations, and comply with applicable legal obligations.

If you do not agree with this Policy, please refrain from using the Platform or providing personal data to Enséñame.

This Privacy Statement is an integral part of the General Terms and Conditions of Enséñame. Providing your explicit, affirmative, and informed consent to this Privacy Statement is an essential requirement for contracting and/or having any type of relationship with Enséñame, depending on the applicable legislation in each country.

  1. SCOPE, ACCEPTANCE, AND WHO THIS APPLIES TO

1.1. This Policy applies to any individual (“Data Subject”) whose personal data is processed by Enséñame, including: (i) users, students, teachers, tutors, institutional administrators, and Platform visitors; (ii) institutional and corporate clients; (iii) prospects and commercial contacts; (iv) vendors and partners; (v) participants in events, activities, training programs, or communities; and (vi) any other person who communicates or interacts with Enséñame through physical or digital channels.

1.2. Acceptance of this Policy is understood to have been granted when the Data Subject: (i) browses, accesses, or uses the Enséñame platform; (ii) fills out registration, contact, or information request forms; (iii) creates an account or accesses educational content, virtual courses, training programs, or learning paths; (iv) interacts with platform features including tracking, assessment, or reporting tools; (v) requests support or associated services; (vi) acts as an end user, contracting entity, or content provider within the ecosystem; or (vii) authorizes the processing of personal data through any means allowing future reference.

1.3. This Policy is interpreted systematically alongside the Terms and Conditions, specific privacy notices, contracts with institutional or corporate clients, and, where applicable, data processing agreements. In case of conflict, the provision most protective of the Data Subject shall prevail, without prejudice to applicable contractual and legal obligations.

Information you provide directly when registering or using our services:

  • Username or alias for operating on the Enséñame platform.
  • Full name and valid government-issued ID or identification number.
  • Contact information (phone number, address, email address).
  • Bank account details.
  • Payment information and methods.
  • Intellectual property rights information, Brand Protection Program (BPP) membership data, and information about your activity as a reporter.

Information we collect from other sources:

  • Information collected for fraud prevention and regulatory compliance purposes (PEPs lists, OFAC, etc.).
  • Credit information obtained from credit risk databases and/or publicly accessible sources, in accordance with applicable law.
  • Data used for identity verification, obtained from trusted and secure sources such as government agencies, service providers, or commercial partners.
  1. IDENTIFICATION OF THE DATA CONTROLLER

The processing of personal data will be carried out by Etraining S.A.S., acting as the Data Controller under the terms of Law 1581 of 2012, Decree 1377 of 2013, and other applicable Colombian regulations, when processing occurs within Colombian territory or is subject to such legislation.

If personal data processing involves Data Subjects located in the United States, or is subject to U.S. law, the responsible entity will be 3E Innovation Group, in accordance with the applicable jurisdiction. In particular, the Florida Digital Bill of Rights (Sections 501.701–501.722 of the Florida Statutes, enacted by Chapter 2023-201, effective July 1, 2024) may apply where its applicability thresholds are met.

  • Legal name: [●]
  • Tax ID: [●]
  • Principal address: [●]
  • Privacy contact email: [●]
  • Customer service / support channels (PQRSD): [●]
  • Phone: [●]
  • Website: https://ensename.us/

When Enséñame or the aforementioned entities act as Data Processors on behalf of an institutional or corporate client (e.g., managing a campus, course, or learning path), that client serves as the Data Controller, and Enséñame will process data per their instructions, signed agreements, and applicable regulations.

  1. KEY DEFINITIONS

Authorization: The prior, express, and informed consent of the Data Subject to process their personal data.

Privacy Notice: A verbal or written communication informing the Data Subject about data processing policies, how to access them, and the purposes of processing.

Database: An organized collection of personal data subject to processing.

Personal Data: Any information linked to or capable of being associated with one or more identified or identifiable individuals.

Public Data: Data classified as such by law (e.g., content in public records, unless subject to confidentiality).

Semi-Private Data: Data of interest to both the Data Subject and a defined group or sector (e.g., financial data as defined by applicable law).

Private Data: Data that, due to its intimate or confidential nature, is of interest only to the Data Subject.

Sensitive Data: Data that directly impacts the Data Subject’s privacy or whose misuse could lead to discrimination (e.g., health data, biometric data, political or religious affiliation).

Data Processor: A natural person or legal entity that processes personal data on behalf of the Data Controller.

Platform: Websites, virtual campuses, apps, forms, support channels, landing pages, store, and other Enséñame digital assets.

Processing: Any operation performed on personal data, such as collection, storage, use, circulation, or deletion.

Transmission: Processing that involves communicating personal data within or outside Colombian territory so a Data Processor can process it on behalf of the Data Controller.

Transfer: Sending personal data to a recipient who also acts as Data Controller.

  1. PRINCIPLES AND DUTIES OF ENSÉÑAME

Enséñame processes personal data in accordance with the principles of legality, purpose, freedom, accuracy and quality, transparency, restricted access and circulation, security, and confidentiality. In compliance with Colombian and U.S. law, Enséñame: (i) requests authorization when required; (ii) retains proof of authorization; (iii) informs Data Subjects of purposes and rights; (iv) implements security measures; (v) handles inquiries and claims; and (vi) manages data updates, corrections, and deletions as applicable.

This Policy also aims to protect the rights of users, third parties, and Enséñame itself:

  • Defend the tangible and intangible assets of Enséñame.
  • Enforce the rights of Enséñame in the event of Terms and Conditions violations.
  • Enable users and third parties to exercise their own rights.
  1. INFORMATION WE COLLECT

Enséñame collects only the information that is necessary, relevant, and not excessive to fulfill legitimate purposes related to its training solutions, campus administration, and relationships with clients, users, partners, and vendors.

5.1. Information You Provide Directly

  • Identification and contact data: full name, ID type and number (when applicable), email, phone, country/city, job title, institution/company, and other contact details.
  • Account and authentication data: username, password (stored using hashing mechanisms), security answers, language preferences, and account settings.
  • Academic and training data: enrollment in courses/programs, progress history, grades, submissions, activity participation, certifications, attendance, feedback, and learning evidence.
  • Commercial and billing data (when applicable): information needed for quotes, purchase orders, billing, payments, and accounting/tax support. As a general rule, Enséñame does not store full payment card data when external payment gateways are used.
  • Communications: content of messages sent via contact channels, PQRSD forms, chats, tickets, calls, or emails, along with associated responses and tracking.
  • User-generated content: files, text, audio, images, or other materials uploaded or shared by the Data Subject on the campus or enabled channels for learning, support, or collaboration, per applicable Terms and Conditions.

5.2. Information We Collect Automatically

  • Browsing and usage data: IP address, browser type, language, operating system, access date/time, pages visited, clicks, interaction events, navigation paths, session duration, and usage statistics.
  • Technical identifiers: cookies, pixels, tags, and similar technologies; session identifiers; and data necessary for authentication, fraud prevention, and security.
  • Device data: model, configuration, screen resolution, internet provider, advertising identifiers (when applicable and per device settings), and error/diagnostic logs.

5.3. Information We Receive from Third Parties or Permitted Sources

Contracting Entities (Institutional or Corporate Clients): When a public or private organization contracts Enséñame to manage a campus or training environment, it may provide contact, identification, and academic or performance data of its users (students, learners, or staff) to the extent needed to enable access, manage users, track progress, and execute training processes. In these cases, the contracting entity acts as Data Controller, and Enséñame processes data as the Data Processor per their instructions.

Technology Providers: Enséñame may rely on third-party providers for cloud hosting, data analytics, communications, messaging, technical support, authentication/identity verification (when applicable), and cybersecurity. These services may generate technical records, usage logs, navigation events, and platform-related metadata.

Third-Party Platforms and Integrations: When the Data Subject interacts with Enséñame through integrations with external systems (such as communication tools, authentication systems, complementary LMS, or other educational or corporate platforms), or when access is enabled through identity providers, the platform may receive data the Data Subject authorized sharing per those tools’ configurations.

Public Sources: Enséñame may process contact and professional profile data from publicly accessible sources (e.g., institutional websites, business or academic directories) for outreach, service offering, or partnership purposes, where permitted by applicable law.

5.4. Sensitive Data and Data of Minors

As a general rule, Enséñame does not require sensitive data to deliver its services. If a specific project or service requires it, Enséñame will: (i) request explicit authorization; (ii) explain the specific purpose; (iii) inform the Data Subject that providing it is optional; and (iv) apply enhanced security and access controls.

When Enséñame is used by contracting entities or content providers to offer programs for minors (children, adolescents, or youth), it guarantees that personal data processing will be carried out in accordance with the best interests of the child and their fundamental rights, with prior, express, and informed authorization from their legal guardian, and taking the minor’s opinion into account where required by law. This is without prejudice to the responsibilities of contracting entities or content providers as Data Controllers in each case.

  1. PURPOSES OF DATA PROCESSING — HOW WE USE YOUR DATA

Enséñame processes personal data for the following purposes, based on the Data Subject’s relationship with the platform, their role (end user, contracting entity, or content provider), and the services effectively used:

  • To provide, operate, administer, and improve the Enséñame technology platform, including managing, distributing, and providing access to digital educational content, virtual courses, training programs, and learning paths, along with associated analytics and tracking tools.
  • To create, manage, and authenticate user accounts; enable access to the platform and its content; assign roles; manage enrollments defined by contracting entities; and administer usage permissions within the digital environment.
  • To facilitate interaction among contracting entities, content providers, and end users, including administration of virtual campuses, training spaces, and learning environments within the platform.
  • To manage the training process from the technology side: tracking user progress, recording activities, enabling performance assessment when authorized by content managers, generating reports, and supporting certification or completion record processes.
  • To handle information requests, demonstrations, technical support, and commercial outreach to entities interested in using the platform.
  • To manage PQRSD (inquiries, complaints, claims), user support, technical assistance, request verification, and incident management associated with platform use.
  • To manage pre-contractual and contractual relationships with contracting entities and partners, including proposals, contracts, billing, payments, and compliance with commercial, accounting, and tax obligations.
  • To implement learning and usage analytics (Learning Analytics) for service improvement, aggregated statistics and reporting, and optimization of the user experience on the platform.
  • To ensure information and platform security: prevent, detect, and investigate unauthorized access, fraud, abuse, security incidents, and vulnerabilities, and protect the rights and assets of Enséñame, its users, and third parties.
  • To comply with applicable legal and regulatory obligations, including responses to competent authorities and compliance with data protection, intellectual property, and e-commerce regulations.
  • To send operational and transactional communications (e.g., registration confirmations, credential recovery, system notifications, course updates, or platform reminders).
  • To conduct commercial outreach and prospecting (when applicable), such as sending updates, features, events, or platform-related content, always respecting authorization and opt-out mechanisms.
  • To manage relationships with technology providers and partners, including onboarding, access control, service execution, compliance, and auditing.
  • To implement quality management processes, including satisfaction surveys, usage analysis, internal audits, and continuous service improvement.

Enséñame may anonymize or pseudonymize personal data for statistical, analytical, or service improvement purposes when compatible with the original purpose and applicable regulations. It may also combine Data Subject-provided information with data from public sources or authorized providers for analysis, institutional segmentation, or service improvement, always respecting the Data Subject’s rights, including the right to object where applicable.

  1. AUTHORIZATION AND LEGAL BASIS FOR PROCESSING

In both Colombia and the United States, processing personal data requires the prior, express, and informed consent of the Data Subject, subject to legal exceptions. Enséñame collects such authorization through acceptance checkboxes, campus registrations, privacy notices, contracts, purchase orders, written communications, or any other means allowing future reference.

Depending on the type of activity, Enséñame may process data based on: (i) Data Subject authorization; (ii) execution of a contract or pre-contractual relationship; (iii) compliance with legal obligations; and/or (iv) legitimate interest, particularly for security, fraud prevention, service improvement, and handling requests, provided the Data Subject’s rights and freedoms are not overridden.

  1. DATA PROCESSORS, THIRD PARTIES, AND DATA SHARING

Enséñame does not sell personal data. Enséñame may share or communicate personal data in the following circumstances, and only to the extent necessary to fulfill the stated purpose:

Data Processors (Vendors/Service Providers): Cloud hosting, platform maintenance, analytics, messaging and transactional email, customer support/helpdesk tools, security and cybersecurity services, and other technology or operational services. These parties process data on Enséñame’s behalf, per its instructions, under confidentiality agreements and with adequate security measures.

Institutional or Corporate Clients: Academic and campus usage reports, when the Data Subject participates in a learning path or campus contracted by their institution or employer, to the extent necessary for program management and per the applicable contract and stated purpose.

Government Authorities: When required by law or a valid administrative or judicial order.

Strategic Partners: Only when necessary to execute a joint training project (e.g., co-delivery, joint certification), with appropriate contractual data protection guarantees.

Corporate Transactions: In the event of a merger, acquisition, reorganization, or asset transfer, Enséñame may transfer data per applicable law, ensuring continuity of data protection.

When the Data Subject interacts with third-party links or services (e.g., social media, authentication providers, media players), processing by those third parties is governed by their own privacy policies.

Note: Enséñame does not sell personal data as defined under Law 1581 of 2012 or under the “sale” or “sharing” definitions in U.S. state laws. If future data monetization models fall within such definitions, a clear and visible “Do Not Sell or Share My Personal Information” mechanism will be made available.

  1. INTERNATIONAL DATA TRANSFERS AND TRANSMISSIONS

The technology infrastructure supporting the Platform may involve storing or processing data on servers located inside or outside Colombia, including the United States, depending on the location of cloud, email, analytics, or support providers.

Enséñame will carry out international transmissions to Data Processors under agreements incorporating obligations of confidentiality, security, processing per instructions, and where applicable, equivalent protection standards, in compliance with Colombian regulations.

For international transfers to third-party Data Controllers, Enséñame will inform the Data Subject and apply the safeguards required by applicable regulations.

  1. PROCESSING DATA OF MINORS

Enséñame may process data of children and adolescents only when: (i) processing respects and serves the best interests of the minor; (ii) their fundamental rights are protected; (iii) authorization has been obtained from their legal guardian; and (iv) applicable regulations are observed. Enséñame may request minimum information to verify legal guardianship and will retain evidence of authorization.

Enséñame recommends that legal guardians supervise minors’ use of the Platform and review its content and privacy settings.

  1. DATA SUBJECT RIGHTS AND HOW TO EXERCISE THEM

Data Subjects have the following rights, among others: (i) access, update, and correct their data; (ii) request proof of authorization; (iii) be informed about how their data is used; (iv) file complaints with the Superintendence of Industry and Commerce (SIC) for violations; (v) revoke authorization and/or request deletion where no legal or contractual obligation to retain data exists; and (vi) access their data free of charge.

11.1. Inquiries

Data Subjects may submit inquiries about their data through the channels listed in Section 2. Enséñame will respond within ten (10) business days of receipt. If unable to respond within that period, Enséñame will notify the reason for the delay and provide a new date, which may not exceed five (5) additional business days.

11.2. Claims (Correction, Update, Deletion, or Revocation)

If a Data Subject believes data needs to be corrected, updated, or deleted — or identifies an apparent violation — they may submit a claim including: (i) Data Subject identification; (ii) description of facts; (iii) contact address; and (iv) supporting documents.

Enséñame will process claims under Law 1581 of 2012 (for Colombian territory): (i) if incomplete, the requester will be notified within five (5) business days to remedy the gap within five (5) additional business days; (ii) claims will be resolved within fifteen (15) business days, extendable by eight (8) business days with notice to the requester.

11.3. Complaints with the SIC (Colombia)

Data Subjects may file complaints with the Superintendence of Industry and Commerce (SIC) for violations of data protection regulations, after exhausting the inquiry or claims process with Enséñame where required.

11.4. Additional Rights for Florida Residents (U.S.)

If you reside in Florida, you may also exercise the following rights:

  • Request confirmation of whether Enséñame processes your personal information.
  • Request access and data portability in a structured format.
  • Request deletion of your personal data.
  • Opt out of the sale or sharing of personal information.
  • Opt out of targeted behavioral advertising.
  • Object to profiling with significant effects.
  • Appeal decisions made in response to rights requests.

Enséñame does not sell personal information as defined under the Florida Digital Bill of Rights.

  1. INFORMATION SECURITY AND CONFIDENTIALITY

Enséñame adopts reasonable and proportionate technical, human, and administrative measures to protect personal data and information managed on the Platform, preventing tampering, loss, unauthorized access, or fraudulent use. Measures include, as applicable: access controls, role management, encryption in transit, event logging, backups, network segmentation, vulnerability management, staff training, confidentiality agreements, and secure development practices.

12.1. Confidentiality

All non-public information accessed by Enséñame in the context of its relationships with users, clients, partners, or vendors — including training content, materials, institutional documentation, academic data, strategies, or technical or commercial information — will be treated as confidential when: (i) so identified; (ii) it is by nature reserved; or (iii) it is protected by law or contract.

12.2. Restricted Access

Access to personal data and confidential information is limited to authorized personnel and strictly necessary Data Processors, under the principle of minimum necessary access.

12.3. Security Incidents

In the event of incidents compromising personal data, Enséñame will activate its incident management process, assess the risk, implement containment and remediation measures, and carry out required notifications in accordance with applicable regulations and contractual agreements.

  1. DATA RETENTION AND DELETION

Enséñame retains personal data for as long as necessary to fulfill the purposes described in this Policy, and additionally for the periods required to: (i) comply with legal, accounting, tax, and regulatory obligations; (ii) respond to authority requests; and (iii) manage and defend claims.

Once the purpose has been fulfilled and applicable retention periods have expired, Enséñame will delete or anonymize the data, unless a legal or contractual duty to retain it exists.

  1. COOKIES, SIMILAR TECHNOLOGIES, AND ANALYTICS

Enséñame may use cookies and similar technologies to: (i) enable essential features (session, authentication, security); (ii) remember preferences; (iii) measure performance; and (iv) conduct usage analytics to improve the experience.

You can manage your cookie preferences through your browser settings or, when available, through a banner or preference center on the Platform. Blocking certain cookies may affect the functioning of some features.

By using Enséñame, you expressly acknowledge and accept that Enséñame may use tracking systems through cookies, web beacons, and/or similar tracking technologies to understand user interests and behavior, improve service delivery, analyze browsed pages and searches, enhance commercial and promotional initiatives, display relevant content, personalize services, and promote platform security and rules. Personal data obtained through these technologies will not be shared with third parties in any manner other than as described in this Privacy Policy.

You may manage, configure, or delete cookies at any time through your browser settings. Note that disabling cookies may limit your ability to access certain platform features and functionality.

Browser-specific cookie management guides:

  • Internet Explorer: http://windows.microsoft.com/es-es/windows-vista/block-or-allow-cookies
  • Microsoft Edge: https://support.microsoft.com/help/4027947/microsoft-edge-delete-cookies
  • Firefox: https://support.mozilla.org/kb/enable-and-disable-cookies-website-preferences
  • Google Chrome: http://support.google.com/chrome/bin/answer.py?hl=en&answer=95647
  • Opera: http://help.opera.com/Windows/11.50/en/cookies.html
  • Safari (Mac): http://www.apple.com/legal/privacy/en/cookies/

Cookie categories used:

  • Essential: required for authentication and security.
  • Functional: remember user preferences.
  • Analytical: measure traffic and performance.
  • Advertising / behavioral marketing: personalize offers.

Users may configure preferences through a Consent Management Center.

  1. LINKS TO THIRD-PARTY SITES AND SOCIAL MEDIA

The Platform may include links to third-party websites or services (e.g., social media or partner sites). Enséñame does not control or take responsibility for those parties’ privacy practices. We recommend reviewing their privacy policies before providing any personal data.

  1. CHANGES TO THIS POLICY

Enséñame may update this Policy to reflect regulatory changes, operational adjustments, or improvements to its privacy and security practices. The current version will always be available on the Platform and identified by its last update date. For material changes, Enséñame will make reasonable efforts to notify users (e.g., a notice on the Platform or an email to the registered address).

  1. PRIVACY CONTACT / DATA PROTECTION OFFICER

To exercise your rights, submit inquiries or claims, or make privacy-related requests, you may contact Enséñame through the channels listed in the preliminary sections of this Policy.

  1. AUTOMATED DECISIONS, PROFILING, AND ARTIFICIAL INTELLIGENCE

Enséñame may use advanced analytics, machine learning (ML), artificial intelligence (AI), and statistical modeling tools to:

  1. a) Analyze learning behaviors, academic progress, and performance.
  2. b) Generate personalized pedagogical recommendations.
  3. c) Detect anomalous behavior.
  4. d) Prevent fraud or misuse of the Platform.
  5. e) Improve the user experience and optimize training content.

When such tools involve automated decisions that produce legal effects or significantly affect the Data Subject, they have the right to:

  • Request human-in-the-loop review.
  • Request algorithmic transparency and model explanations.
  • Contest the decision.
  • Request manual review.

 

Enséñame will not utilize user-generated content (UGC) to train generative AI models without explicit opt-in consent. 

 

Enséñame may designate a Data Protection Officer (DPO) to coordinate implementation of this Policy and handle Data Subject requests:

  • Name / Title: [●]
  • Email: [●]
  • Address: [●]

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Terms of Service

  1. CORPORATE INFORMATION AND ECOSYSTEM STRUCTURE

ENSÉÑAME is a digital platform focused on the management, distribution, and delivery of digital educational content. Global ownership of its technological assets, software developments, digital infrastructure, and structural components belongs to 3E INNOVATION GROUP CORP (hereinafter, the “Parent Company”). Within the territory of Colombia, the Platform is operated by ETRAINING S.A.S., a company identified under Tax ID (NIT) 830.147.547-1, which acts as the authorized operator and commercial and authorized legal representative (hereinafter, the “Local Operator”).

3E INNOVATION GROUP CORP acts as an international strategic partner and licensing provider of the technological infrastructure, software components, and evolutionary updates of the Platform, under licensing and technology cooperation agreements.

Depending on the contracted service and applicable jurisdiction, the contractual relationship may be established with the Local Operator, the Parent Company, or both, as expressly indicated in the applicable commercial proposal, service order, or specific contract.

Governing Law by territory:

  • Colombia: Applicable provisions include electronic commerce rules under Law 527 of 1999, consumer protection (Law 1480 of 2011), and personal data protection (Law 1581 of 2012 and its regulatory decrees).
  • United States: Services to U.S.-based users may be subject to applicable federal and state consumer protection and trade practices laws, including the Federal Trade Commission Act (15 U.S.C. §§ 41–58). When the State of Florida is involved, the Florida Deceptive and Unfair Trade Practices Act (FDUTPA, Chapter 501, Part II, Florida Statutes) may also apply.

ENSÉÑAME commits to providing clear, truthful, sufficient, and up-to-date information about its Platform features, terms of use, and service scope, and to maintaining reasonable standards of quality, suitability, security, and functionality in accordance with applicable law in each jurisdiction. ENSÉÑAME is committed to the principles of good faith, transparency, accountability, and user/consumer protection in the delivery of its digital services.

  1. NATURE OF THE ENSÉÑAME ECOSYSTEM

ENSÉÑAME is not merely an isolated technology tool — it is a digital platform designed to support training, upskilling, and skills development through the management, distribution, and access to digital educational content in organizational environments.

The Ecosystem is defined as an adaptable, customizable platform aligned with each organization’s identity, built to WCAG accessibility standards and multi-device compatibility, ensuring a consistent and inclusive experience from any device.

Key capabilities include:

  • Acts as a technology intermediary facilitating interaction among end users, contracting entities, and content providers.
  • Supports the creation and management of structured learning paths.
  • Integrates with third-party systems (communication platforms, analytics tools, and video conferencing) to expand functionality and improve the user experience.
  1. ACCEPTANCE AND LEGAL CAPACITY

Accessing, registering, browsing, or using the Ecosystem constitutes full, express, and unconditional acceptance of these Terms.

The User declares that they have sufficient legal capacity to enter into binding contracts and, if acting on behalf of a legal entity, represents that they have the authority to legally bind that entity. The User also warrants that all information provided during the registration or contracting process is truthful, complete, and up to date.

The Local Operator and/or the Parent Company may request additional documentation to verify identity, prevent fraud, comply with regulatory obligations, or mitigate legal or reputational risks.

  1. DEFINITIONS

Data Messages: Information generated, sent, received, stored, or communicated by electronic, optical, or similar means, including Electronic Data Interchange (EDI), the Internet, email, telegram, telex, or fax.

Electronic Commerce: Encompasses the sending, transmission, reception, and storage of data messages by electronic means. Any questions regarding the validity and effectiveness of data messages and related e-commerce activities shall be governed by applicable law.

Cookies: Text strings stored by the Platform on the user’s device to track activities and preferences.

Platform Operator: The entity responsible for managing the Platform, represented for purposes of these Terms by ETRAINING S.A.S., or any natural or legal person it designates.

Pop-Ups: Internet windows or notices that appear automatically at any time while using the Platform, primarily used for formalizing transactions between Users.

Artificial Intelligence (AI): Probabilistic algorithmic systems used for pedagogical personalization, adaptive learning, performance analysis, and assisted content generation, including the AI Chat available for academic management.

Proctoring: A secure exam functionality that uses authentication tools including facial recognition, fingerprint scanning, and document verification to validate user identity and ensure the integrity of assessments.

Platform: The technological infrastructure, software, modules, digital tools, integrations, APIs, and features offered under a SaaS model.

Services: The full suite of technological, methodological, editorial, consultative, and advanced analytics solutions offered within the Ecosystem.

User Content: All information, data, text, images, files, databases, or materials uploaded or incorporated into the Platform by the User.

  1. REGISTRATION AND MANAGED ACCOUNTS

To access certain Platform features, the User must register and create an account by providing valid, verifiable, and up-to-date information. The account is personal and non-transferable, and its use is subject to these Terms.

The User is responsible for the accuracy of the information provided and for keeping their login credentials strictly confidential. The User must immediately notify ENSÉÑAME of any unauthorized use of their account.

When registration is made using a corporate email account or within the framework of a contractual relationship with an organization, that organization may assume ownership or administration of the account — including the ability to manage access, modify settings, reassign content, or delete the account — which the User expressly acknowledges and accepts.

The User is solely responsible for all activities carried out through their account on the Platform.

  1. TECHNOLOGY SERVICE MODEL

The ENSÉÑAME Platform is delivered as a digital technology service (SaaS) supported by modern databases and cutting-edge development frameworks. To ensure reliability and continuity, the service runs on leading cloud infrastructure with resilience features, redundant backups, and disaster recovery protocols.

The Operator provides 24/7 multichannel support through technical and pedagogical helpdesks, with immediate response and ongoing guidance. The service includes onboarding, training, and practical resources to ensure fast platform adoption.

The User acknowledges that AI-powered tools, such as the assisted chat, operate on probabilistic models. Responsibility for any strategic or academic decisions made based on AI-generated outputs rests exclusively with the User.

The User agrees to use the Platform in good faith and in compliance with applicable law and these Terms, refraining from any conduct that could compromise the operation, security, integrity, or reputation of the Platform, the Local Operator, the Parent Company, or third parties.

ENSÉÑAME may rely, in whole or in part, on technology infrastructure, services, or content provided by third parties, and therefore does not guarantee the permanent availability or uninterrupted continuity of all services or content offered.

The User acknowledges that ENSÉÑAME does not guarantee specific academic, training, or professional outcomes from use of the Platform. The User is solely responsible for making use of the available content and tools.

  1. CONTENT AND PROVIDER RELATIONSHIPS

The Platform may host, distribute, or make available educational content developed by ENSÉÑAME as well as by third-party providers, institutions, or strategic partners.

The User acknowledges that in these cases ENSÉÑAME acts as a technology intermediary, and that responsibility for the quality, accuracy, legality, and ownership of third-party content rests exclusively with the respective providers.

ENSÉÑAME reserves the right to remove, suspend, or restrict access to any content when there are indications of regulatory non-compliance, infringement of third-party rights, or risk to the integrity of the Platform.

Regarding third-party system integrations (such as video conferencing or analytics services), the User accepts that ENSÉÑAME provides the technical connectivity but is not responsible for the availability, failures, or security policies of those external platforms, which are governed by their own terms and conditions.

  1. PRICING, PAYMENTS, AND BILLING

To subscribe to any plan or service offered by ENSÉÑAME, the User must follow the instructions available on the website or platform, which may include providing a valid credit card, debit card, or other authorized payment method to pay the applicable fee or price (the “Fee”), which will be linked to their account.

If the User contracts additional services or upgrades their plan, they will not need to re-enter payment information — the payment method already linked to the account will be used, unless the User modifies it.

Before confirming a purchase, ENSÉÑAME will provide the User with a summary of the pricing terms and key features of the selected service.

Payments may be made by bank transfer (when enabled) or through a third-party payment platform. Use of the payment platform is subject to its own terms and privacy policy, which the User must accept. Payment method data is stored directly by the payment platform, which is solely responsible for its handling and security. ENSÉÑAME does not have direct access to full payment card details and is not liable for the operation, availability, or issues of the payment platform.

Since the Services are digital in nature and may begin immediately upon contracting, the right of withdrawal may not apply where permitted by applicable law and the User has expressly accepted the immediate start of service delivery.

Upon confirming a purchase, the User will receive a confirmation email with instructions for accessing and using the Service. Access and activation of the Service are contingent on receipt of payment or authorization by the relevant financial institution.

For recurring services or subscriptions, the Fee will be automatically charged at each renewal period using the payment method linked to the account at that time. Only one primary payment method is permitted per account, unless ENSÉÑAME expressly enables otherwise.

If no valid payment method is associated with the account or a charge cannot be processed, ENSÉÑAME will notify the User and may temporarily suspend access to the Service until the payment situation is resolved.

In the event of non-payment, ENSÉÑAME — through the Local Operator (ETRAINING S.A.S.) or the Parent Company (3E INNOVATION GROUP CORP), as applicable — may limit, suspend, or restrict access to the Platform and its associated content, features, data, and services. If non-payment continues for thirty (30) calendar days, ENSÉÑAME may cancel the contracted service. In that event, associated data, content, and records may be retained for up to an additional thirty (30) days, after which they may be permanently deleted with no possibility of recovery, unless a legal or contractual obligation requires otherwise.

The User or contracting entity may reactivate the service within the indicated periods by paying any outstanding amounts, including fees corresponding to the period during which the service was suspended, where applicable.

The User may update billing information and tax details at any time through their account on the Platform.

Specific pricing terms — including rates, number of users, storage, enabled features, service levels, and billing model — will be defined in the commercial proposal, service order, or specific contract with the Local Operator, the Parent Company, or both. Unless otherwise agreed, services may operate on a prepaid basis and may renew automatically at the end of each billing cycle.

Since the digital service is considered delivered from the moment access is activated, payments are non-refundable, except as expressly required by applicable law. In Colombia, the right of withdrawal under Law 1480 of 2011 may apply where applicable.

For users located in the United States, these provisions shall be interpreted and applied in accordance with applicable consumer protection law, including the Federal Trade Commission Act (15 U.S.C. § 45) and, where applicable, the Florida Deceptive and Unfair Trade Practices Act (FDUTPA). ENSÉÑAME will ensure that all suspension, cancellation, automatic renewal, and non-refund conditions are communicated to the User in a clear, prior, and transparent manner, in compliance with applicable consumer protection requirements.

  1. INTELLECTUAL PROPERTY

All industrial and intellectual property rights covering the Services offered by ENSÉÑAME — including its website, applications, technology platforms, tools, content, navigation structure, source code, interfaces, features, trademarks, trade names, logos, distinctive signs, text, images, graphics, databases, and software — belong exclusively to ENSÉÑAME, its supporting companies, or their licensors, and are protected by applicable national and international intellectual property law.

The User is only authorized to access and use the Services as set forth in these Terms and within legally permitted limits. Unless ENSÉÑAME grants express written authorization, the User may not reproduce, transform, distribute, publicly communicate, make available to third parties, create derivative works from, extract, reuse, or exploit by any means the Services, the website, or any of their elements.

Contracting the Services does not constitute, in any case, a transfer or assignment of industrial or intellectual property rights owned by ENSÉÑAME. ENSÉÑAME grants the User a personal, limited, revocable, non-exclusive, and non-transferable license to access and use the Services in accordance with these Terms.

The User retains ownership of all content, data, information, or materials they upload, store, share, or generate through the Services (User Content). ENSÉÑAME does not acquire ownership rights over User Content, except as strictly necessary to provide the Service.

By using the Service, the User grants ENSÉÑAME a non-exclusive, royalty-free, worldwide, time-limited license (limited to the duration of the contractual relationship) to access, host, technically reproduce, process, and use User Content solely to the extent necessary to:

  • Provide the contracted Services.
  • Ensure proper platform operation, maintenance, and improvement.
  • Comply with legal obligations or requirements from competent authorities.
  • Enforce these Terms.
  • Detect, prevent, or address fraud, technical incidents, or security issues.
  • Protect the legitimate rights and interests of ENSÉÑAME, other users, or third parties.

The User warrants that they hold all necessary rights, licenses, and authorizations over their User Content for its use through the Services and for granting the above license to ENSÉÑAME. The User is solely responsible for their User Content and agrees to indemnify and hold ENSÉÑAME harmless from any claims, damages, losses, or expenses (including legal fees) arising from any infringement of third-party rights.

ENSÉÑAME does not permit use of the Services for activities that infringe intellectual property rights or other third-party rights. ENSÉÑAME may remove, block, or delete content for which there is substantiated notice of infringement or reasonable evidence of rights violation, and reserves the right to act without prior notice when necessary to comply with applicable law or protect its legitimate interests.

  1. ACCEPTABLE USE AND RESTRICTIONS

The User agrees to use the Ecosystem in compliance with applicable law and good faith. The following are strictly prohibited:

  • Using the platform content or features to train external artificial intelligence models without prior express written authorization.
  • Reverse engineering, decompiling, decoding, or hacking any technology used by ENSÉÑAME to deliver the Service.
  • Impersonating another person or entity, or falsely representing or misrepresenting your affiliation with any person or entity.
  • Negligently using a third-party digital certificate or using it in violation of the conditions established by the relevant certification service provider.
  • Interfering with, disrupting, or compromising the security of the Service, the ENSÉÑAME website, or the servers and networks used to provide the Service.
  • Taking any action that damages, disables, overloads (as determined by ENSÉÑAME at its sole discretion), or degrades the Service, website, or access methods, or impairs their normal use by other users.
  • Circumventing any measure used by ENSÉÑAME to prevent or restrict access to the Service (or to other accounts, computer systems, or associated networks).
  • Accessing the Service through unauthorized programs, applications, or tools, including any malicious attempt to gain control of the Service, cause service interruptions, or conduct unauthorized performance or benchmark testing.
  • Reverse engineering, decompiling, disassembling, or attempting to discover the source code, underlying ideas, or algorithms of any part of the Service, except to the extent expressly permitted by applicable law.
  • Copying, renting, leasing, distributing, downloading, reproducing, transmitting, displaying, selling, licensing, or otherwise exploiting any Service or website content outside of the uses expressly authorized in these Terms.
  • Using the Service to send unsolicited electronic communications (spam), viruses, malware, or any other malicious code, or for any activity that violates applicable law or infringes third-party rights.
  • Developing competing products or services based on the platform’s features or methodology.
  • Extracting data through automated techniques such as scraping, bots, or spiders.
  1. DATA PROTECTION

The processing of personal data is governed by applicable regulations. In Colombia, Law 1581 of 2012 and its regulatory decrees apply. The User authorizes the international transfer of data when necessary for service delivery. ENSÉÑAME will act as a Data Processor with respect to information uploaded by the User when applicable.

The User expressly authorizes the processing of sensitive data — including facial recognition and fingerprint data — when these are required for identity verification, multi-factor authentication (MFA), or Proctoring services. This data will be collected exclusively for purposes related to service delivery and the fulfillment of contractual obligations.

  1. CONFIDENTIALITY

All technical, strategic, methodological, or commercial information exchanged between the parties shall be treated as confidential. Confidentiality obligations remain in effect throughout the contractual relationship and for five (5) years following its termination.

  1. LIMITATION OF LIABILITY

The total cumulative liability of ENSÉÑAME, the Local Operator, and the Parent Company shall not exceed the greater of: one hundred U.S. dollars (USD $100.00) or the amount paid by the User during the twelve (12) months preceding the event giving rise to the claim.

ENSÉÑAME shall not be liable for indirect damages, loss of business revenue/consequential damages.

  1. TERMINATION

The contractual relationship may be terminated due to breach, default, misuse, or. by the User’s own decision in accordance with the cancellation procedures set forth herein.

Upon termination, the User will lose access to the Platform and content may be deleted in accordance with defined technical retention periods, unless a legal obligation to retain it exists.

  1. GOVERNING LAW AND JURISDICTION

When the contract is entered into with ETRAINING S.A.S., it shall be governed by the laws of the Republic of Colombia, and any dispute shall be subject to the exclusive jurisdiction of the courts of Bogotá D.C.

When the contract is entered into with 3E INNOVATION GROUP CORP, it shall be governed by the laws of the United States, specifically the State of Florida.

When the contract is entered into directly with the Parent Company, the law and jurisdiction agreed upon in the specific contract shall apply.

  1. AMENDMENTS

ENSÉÑAME reserves the right to modify these Terms at any time, at its sole discretion. All modifications will be communicated to Users and will take effect upon publication on the Platform.

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