Privacy Policy

Inglés Hotelero is a brand of Diego Lujan Studio LLC, a Texas limited liability company ("we", "us", "the Company"). This policy explains what personal data we collect, why, who we share it with, how long we keep it, and the rights you have over it. It applies to our websites (ingleshotelero.com and hotelenglishtraining.com), the training platform at app.ingleshotelero.com, the planned WhatsApp add-on, and related communications.

We sell to hotels, not to individuals. In most cases the hotel that enrolls its employees is the controller of those employees' data and we process it on the hotel's instructions. Where we decide the purposes ourselves — our own marketing site, our own contact form — we are the controller.

1. Who is responsible

Diego Lujan Studio LLC (trading as Inglés Hotelero), Texas, United States.
Contact: hola@ingleshotelero.com

2. What we collect

2.1 Data you give us directly

• Contact and demo requests: name, job title, work email, phone number (optional), property or organization name, city, team size, positions of interest, and any comments you add.
• Employee enrollment (provided by the hotel): employee name, position, preferred language variant, and the phone number used for the planned WhatsApp add-on.
• Assessments and practice: written answers, voice recordings, transcripts of those recordings, and the CEFR scores and feedback generated from them.
• HR users: name, work email, role, and the property or organization they manage.

2.2 Data collected automatically

• IP address, browser and device type and pages requested, in our web host's technical logs. We do not use site analytics today.
• Strictly necessary session data and preferences (language, currency display).

We do not collect payment card numbers ourselves; payments are handled by our payment processor.

3. Why we use it

• To answer demo requests and follow up commercially.
• To run placement exams, score spoken answers, deliver daily practice and generate CEFR records.
• To show the hotel's HR team each employee's level and progress.
• To send service messages: practice reminders, inactivity notices, account and billing notices.
• To improve the product using aggregated, de-identified usage data.
• To comply with law and respond to lawful requests.

We do not sell personal information, and we do not share it for cross-context behavioral advertising. We do not use employee data to train third-party AI models.

4. Legal bases

Where a legal basis is required: performance of a contract (delivering the service the hotel bought), legitimate interests (security, product improvement, business-to-business marketing to business contacts), consent (where we ask for it, for example a messaging opt-in), and legal obligation.

5. Who we share it with

Only with service providers that process data on our behalf under contract, and only what each one needs:

• Hosting and database: Supabase (database, authentication, file storage) and Netlify (website hosting and functions).
• Speech and scoring: OpenAI (speech-to-text transcription of recordings) and Anthropic (AI scoring and coaching text). Under their API terms these providers do not use our data to train their models by default.
• Audio generation: ElevenLabs, for pre-generated practice audio. No personal data is sent — only our own script text.
• Messaging: Twilio and Meta (WhatsApp Business), if the WhatsApp add-on is enabled for a property (planned; not live today).
• Email: Resend, for transactional and lifecycle email.
• Payments: Stripe.
• The contracting hotel or group: its HR users see their own employees' levels, progress and assessment results.
• Authorities: when required by law or court order, or to protect rights and safety.

We do not share employee data between unrelated hotels.

6. International transfers

We are a US company and our providers operate primarily in the United States. If you are outside the United States, your data will be transferred to and processed in the United States. Where required we rely on contractual safeguards with our providers.

7. How long we keep it

• Voice recordings from placement exams: deleted automatically 180 days after they are made. Scores, transcripts and feedback are kept as part of the employee's record.
• Voice recordings from daily practice: deleted automatically after 30 days.
• Employee records (name, position, levels, progress): kept while the hotel's account is active. Employees are deactivated, not deleted, when they leave, so the hotel's history stays intact; a hotel can request full deletion of an employee's data at any time.
• Account and billing records: kept as long as tax and accounting law requires after the relationship ends.
• Contact-form data: kept while we are in an active sales conversation, and deleted on request.

8. Security

Encryption in transit (TLS) and at rest with our providers; role-based access control; row-level security in the database so a hotel can only ever read its own data; and single-use, revocable login links for employees rather than passwords. No system is perfect. If a breach affects you, we will notify you and any regulator as the law requires.

9. Your rights

Depending on where you live, you may have the right to access, correct, delete, or receive a copy of your personal data; to object to or restrict certain processing; and to withdraw consent. To exercise any right, email hola@ingleshotelero.com. We will verify your identity and respond within the time the law requires — for most requests, within 45 days in the United States and 30 days in Canada.

If you are an employee enrolled by your hotel, we may direct your request to the hotel, which controls that data, and help it respond. We will not retaliate against anyone for exercising a privacy right.

9.1 California residents (CCPA/CPRA)

You have the right to know what personal information we collect and how we use it (this policy), to delete it, to correct it, and to opt out of sale or sharing. We do not sell or share personal information as California law defines those terms, and have not done so in the preceding twelve months. We do not use or disclose sensitive personal information for purposes other than providing the service. You may designate an authorized agent to make a request on your behalf.

9.2 Canadian residents (PIPEDA and provincial law)

We collect, use and disclose personal information with consent or as permitted by law, for the purposes above. You may access and correct your personal information and withdraw consent, subject to legal or contractual limits. Data may be stored and processed outside Canada, including in the United States, where it is subject to US law. Complaints may be directed to us first, and to the Office of the Privacy Commissioner of Canada.

9.3 Residents of Mexico, Spain and the EU/EEA

The Spanish-language policy at ingleshotelero.com/privacidad describes ARCO rights under Mexican law and applies to users in Mexico. EU/EEA and UK users have GDPR and UK GDPR rights, including the right to lodge a complaint with a supervisory authority.

10. Cookies

We do not use analytics or advertising cookies. The site keeps nothing in your browser beyond what it needs to work. If we ever install a traffic-measurement tool, we will update this section before turning it on. We do not run advertising trackers. You can block cookies in your browser; some preferences will then not persist.

11. Children

Our services are for working adults enrolled by their employer. We do not knowingly collect data from anyone under 16.

12. Changes

We will post changes here with a new date. For material changes affecting active customers, we will notify HR users by email at least 15 days in advance.

13. Contact

hola@ingleshotelero.com
Diego Lujan Studio LLC · Inglés Hotelero · Texas, United States