Privacy Policy

Last updated: [02/05/2026]

Data Controller
You are visiting the website www.liralanguage.com owned by the company SPEAKEASY CONSULTING LLC, with registered office at Urb. Alturas del Mar, calle Coral 127, Cabo Rojo, PR 00623.
You can contact us by any of these means:

SPEAKEASY CONSULTING LLC is the Data Controller responsible for the processing of personal data described in this Privacy Policy.

Scope

This Privacy Policy applies to all users who:

  • visit the website
  • contact us
  • book or purchase coaching or educational services
  • subscribe to our newsletter
  • communicate with us by email or forms
  • use our online platforms or services

Our services are offered globally.

While our primary operations are based in Puerto Rico (USA), our technical infrastructure and hosting services are located within the European Economic Area (EEA). Consequently, all processing of your personal data is conducted in accordance with the rigorous security and privacy standards mandated by the General Data Protection Regulation (GDPR).

For detailed information, please refer to the “International Data Transfers and Storage” section below.

Users
The purpose of these conditions (hereinafter Legal Notice) is to regulate the use of the website of SPEAKEASY CONSULTING LLC. makes available to the public.
Access and/or use of this website attributes the condition of the USER, who accepts, from said access and/or use, the general conditions of use reflected here. The aforementioned conditions will apply regardless of the general contracting conditions that, if applicable, are mandatory.

Use of the portal
www.liralanguage.com provides access to a multitude of information, services, programs, or data (hereinafter, “the contents”) on the Internet belonging to SPEAKEASY CONSULTING LLC. or its licensors to which the USER may have access.
The user assumes responsibility for the use of the portal. This responsibility extends to the registration that is necessary to access certain services or content. In said registration, the USER will be responsible for providing truthful and lawful information. As a consequence of this registration, the USER may be provided with a password for which he or she will be responsible, committing to make diligent and confidential use of it.
The USER undertakes to make appropriate use of the content and services (for example, chat services, discussion forums, or news groups) that SPEAKEASY CONSULTING LLC offers through its portal and, by way of example but not limited to, not to use them. for:

  • Involve in illicit, illegal activities or activities contrary to good faith and public order.
  • Spread content or propaganda that is racist, xenophobic, pornographic-illegal, in support of terrorism, or an attack on human rights.
  • Cause damage to the physical and logical systems of SPEAKEASY CONSULTING LLC, its suppliers, or third parties, introduce or spread computer viruses on the network or any other physical or logical systems that are likely to cause the aforementioned damage.
  • Try to access and, where appropriate, use the email accounts of other users and modify or manipulate their messages.
  • Use the website or the information contained therein for commercial, political, or advertising purposes, and for any commercial use, especially in sending unsolicited emails.
    SPEAKEASY CONSULTING LLC reserves the right to withdraw all comments and contributions that violate respect for the dignity of the person, that are discriminatory, xenophobic, pornographic, racist, that attack youth or childhood, order or public safety, or that, in their opinion, will not be suitable for publication.
    In any case, SPEAKEASY CONSULTING LLC will not be responsible for the opinions expressed by users through forums, chats, or other participation tools.

Data Protection
Everything related to the data protection policy is included in the privacy policy document.
Contents. Intellectual and industrial property
SPEAKEASY CONSULTING LLC is the owner of all the intellectual and industrial property rights of its website, as well as the elements contained therein (by way of example: images, photographs, sound, audio, video, software or texts; brands or logos, color combinations, structure and design, selection of materials used, computer programs necessary for its operation, access and use, etc.), owned by SPEAKEASY CONSULTING LLC or its licensors.
All rights reserved. By virtue of the provisions of articles 8 and 32.1, second paragraph, of the Intellectual Property Law, the reproduction, distribution and public communication, including the method of making them available, of all or part of the contents of this website, for commercial purposes, on any medium and by any technical means, without the authorization of SPEAKEASY CONSULTING LLC.

Privacy and Personal Data Processing

In addition to the provisions set out above, SPEAKEASY CONSULTING LLC informs users about how personal data may be collected, used, stored, and protected when interacting with this website and its services.

We collect and process personal information only to the extent necessary to provide our services, operate the website, communicate with users, and comply with applicable legal obligations. We do not sell or rent personal information to third parties.

Categories of Data We Collect

Depending on how you interact with our website or services, we may collect the following categories of personal data:

General Information

  • name and surname
  • email address
  • phone number
  • billing address
  • account registration details
  • communications or support requests
  • payment confirmations
  • technical information (IP address, browser type, device, logs)
  • newsletter subscription and engagement data

Educational and LMS Information (Residency Match and courses)

  • course enrollment and attendance records
  • module completion and academic progress
  • assignments and submissions
  • assessments, scores, and evaluations
  • coaching notes and instructor feedback
  • mock interview results
  • platform usage analytics
  • login timestamps and IP addresses
  • session or webinar recordings, where applicable

Purposes and Legal Bases of Processing

SPEAKEASY CONSULTING LLC processes personal data only when there is a valid legal basis to do so and solely to the extent necessary to provide our services, operate our website, and comply with applicable laws.

We process personal data for the following purposes:

  • to operate and maintain our website and online platforms
  • to create and manage user accounts
  • to respond to inquiries, requests, or support communications
  • to schedule and deliver coaching, language training, or consulting sessions
  • to provide access to educational programs, including the Residency Match program and related LMS services
  • to track course enrollment, attendance, academic progress, assignments, assessments, and feedback
  • to conduct mock interviews, coaching evaluations, and learning activities
  • to issue completion records or certifications
  • to process purchases, payments, and invoices through our e-commerce platform (WooCommerce)
  • to maintain billing records for tax and accounting compliance
  • to send newsletters, educational updates, or marketing communications where the user has provided explicit consent
  • to analyze website usage and improve service quality through analytics
  • to protect the security, integrity, and proper functioning of our systems
  • to prevent fraud, misuse, or unauthorized access
  • to comply with legal, regulatory, or contractual obligations

The legal bases for processing may include:

  • performance of a contract when providing purchased services or courses
  • compliance with legal obligations (such as tax, accounting, or regulatory requirements)
  • legitimate business interests, including improving services, ensuring security, and preventing abuse
  • explicit user consent, particularly for marketing communications, cookies, or recordings

We do not process personal data for purposes incompatible with those described above.

Educational Services, Courses, and Coaching

When you enroll in our Residency Match program or any course delivered through our Learning Management System (LMS), we process additional educational and platform-related data necessary to manage and deliver the program.

This information is processed only for service-related purposes and is retained for the duration of the service relationship and for any legally required period thereafter.

Mock interviews, coaching sessions, or webinars may be recorded for educational or quality assurance purposes. Users are notified before recording. Recordings are confidential and may be deleted upon request unless legally required to retain them.

E-Commerce and Transaction Data (WooCommerce)

When purchasing services or products via our website (powered by WooCommerce), we collect billing and order information necessary to process your purchase.

Payment Processing:
We do NOT store full credit card details. Payments are processed securely by third-party processors compliant with PCI-DSS standards.

Order History:
Billing records are retained for tax and accounting compliance.

Marketing Communications / Newsletter

Subscription to our newsletter and promotional communications is voluntary and based on the user’s explicit prior consent.

In compliance with the CAN-SPAM Act (US), GDPR, and CASL:

  • explicit consent is required
  • purpose is clearly stated
  • unsubscribe link included in every email
  • Proof of consent is stored

Emails may contain tracking pixels or link monitoring to measure engagement solely for analytics and service improvement.

Users may unsubscribe at any time.

Consent

By subscribing through our forms, you expressly agree to receive email communications from SPEAKEASY CONSULTING LLC that may include:

  • educational content
  • coaching resources
  • service updates
  • program announcements
  • promotional or marketing information

We do not send marketing emails without consent, and we do not use pre-checked boxes or implied consent mechanisms.

Where appropriate, we may use a double opt-in confirmation process to verify the subscription.

Data collected for newsletters

When subscribing, we may collect:

  • Email address
  • Name (if provided)
  • Date and time of subscription
  • IP address or technical metadata
  • Email engagement data, such as opens or clicks

Purpose

This information is used exclusively to:

  • Send newsletters and educational content
  • Provide updates about services or programs
  • Share relevant announcements or promotional information
  • Analyze the effectiveness of communications and improve content quality

Tracking technologies

Emails may include standard technologies such as tracking pixels or link monitoring to measure open rates and interactions. This information is used solely for statistical and service improvement purposes.

Unsubscribe

Each communication includes a clear and simple method to unsubscribe. The USER may withdraw consent at any time, after which no further marketing communications will be sent.

After unsubscribing:

  • you will stop receiving marketing emails immediately
  • we may retain minimal information only to ensure compliance with your opt-out request

Legal compliance

Our email communications practices are designed to comply with applicable regulations, including:

  • The General Data Protection Regulation (GDPR)
  • The CAN-SPAM Act (United States)
  • the Canadian Anti-Spam Legislation (CASL), where applicable

We do not sell or share email addresses for third-party marketing purposes.

Data Retention

We retain data only as necessary:

  • client/service data → relationship + up to 5 years
  • billing records → tax requirements
  • support → 2 years
  • logs → 12 months
  • newsletter → until unsubscribed
  • educational/course data → duration of the program + reasonable administrative period
  • recordings → limited retention or until deletion request

After these periods, data is deleted or anonymized.

Legal basis and purpose of processing

Personal data is processed for one or more of the following reasons:

  • To perform services requested by the USER
  • To comply with legal or regulatory obligations
  • To manage contractual relationships
  • To improve website functionality and user experience
  • Based on the USER’s consent for marketing communications

Third-Party Processors

We use trusted third-party service providers such as:

  • LMS platforms
  • cloud hosting providers
  • video conferencing tools
  • payment processors
  • email marketing platforms
  • analytics services

These providers process data only on our behalf under confidentiality and data protection agreements.

Disclosure of information

Personal data may be shared only when necessary with trusted service providers who assist in operating the website or delivering services, including hosting providers, payment processors, email platforms, or analytics tools. These providers process data solely on behalf of SPEAKEASY CONSULTING LLC and under appropriate confidentiality and security measures.

Information may also be disclosed when required by law or legal process, or in the event of a merger, acquisition, or business transfer.

International Data Transfers and Storage

Because our services are provided online, personal data may be transferred across international borders.

SPEAKEASY CONSULTING LLC operates from Puerto Rico (United States). However, our primary hosting infrastructure and servers are located within the European Economic Area (EEA).

This means that personal data is transferred FROM the United States (Puerto Rico) TO the European Union for storage and processing.

We make this transfer intentionally because the European Union provides stronger privacy and technical safeguards under the General Data Protection Regulation (GDPR), ensuring a high level of protection for your information.

To safeguard these transfers, we implement:

  • Standard Contractual Clauses (SCCs)
  • secure hosting agreements
  • encrypted communications
  • restricted access controls

All hosting and processing agreements with our European providers include Standard Contractual Clauses (SCCs) or equivalent safeguards to ensure lawful international data transfers in both directions when necessary.

By using our services, you acknowledge and consent to this international transfer and storage of your data in the EEA.

Data Security

SPEAKEASY CONSULTING LLC implements appropriate technical and organizational measures to protect personal data against unauthorized access, loss, misuse, or alteration.

These measures include:

  • restricted access controls
  • secure hosting environments
  • encrypted databases
  • staff confidentiality obligations
  • regular security monitoring

All data transmitted between your browser and our website is protected using SSL (Secure Sockets Layer) encryption through HTTPS connections. This ensures that personal or payment information cannot be intercepted during transmission.

However, no system can guarantee absolute security.

Your Privacy Rights

Regardless of your country of residence, and independently of any legal framework, SPEAKEASY CONSULTING LLC voluntarily grants all users GDPR-level privacy rights as a best-practice standard.

You may exercise the following rights at any time:

  • Access your personal data
  • Correct inaccurate or incomplete data
  • Request deletion (“Right to be Forgotten”), subject to legal retention requirements
  • Restrict or object to processing
  • Request data portability
  • Withdraw consent at any time
  • Unsubscribe from marketing communications

The exercise of these rights does NOT depend on Spanish law or European residency. They apply contractually to all users globally. 

We will respond to verified requests within a maximum of thirty (30) days.

To exercise your rights, contact:
support@speakeasy-consulting.com 

Exclusion of guarantees and responsibility
THE USER acknowledges that the use of the website and its contents and services is carried out under his or her exclusive responsibility.
Specifically, by way of example only, SPEAKEASY CONSULTING LLC does not assume any responsibility in the following areas:

  • The availability of the operation of the website, its services and contents, and its quality or interoperability.
  • The purpose for which the website serves the USER’s objectives.
  • The violation of current legislation by the USER or third parties, and specifically, the intellectual and industrial property rights owned by other people or entities.
  • The existence of malicious code or any other harmful computer element that could cause the USER’s or third party’s computer system. It is up to the USER, in any case, to have adequate tools for the detection and disinfection of these elements.
  • Fraudulent access to content or services by unauthorized third parties, or, where appropriate, the capture, elimination, alteration, modification, or manipulation of messages and communications of any kind that said third parties may make.
  • The accuracy, veracity, timeliness, and usefulness of the content and services offered, and the subsequent use that the USER makes of them. SPEAKEASY CONSULTING LLC will use all reasonable efforts and means to provide updated and reliable information.
  • Damage caused to computer equipment during access to the website, and damage caused to USERS when it originates from failures or disconnections in telecommunications networks that interrupt the service.
  • Damages or losses arising from circumstances that occur due to unforeseen events or force majeure.

Links
If www.liralanguage.com includes links or hyperlinks to other Internet sites, SPEAKEASY CONSULTING LLC will not exercise any type of control over said sites and content. In no case will SPEAKEASY CONSULTING LLC assume any responsibility for the contents of any link belonging to a third-party website, nor will it guarantee the technical availability, quality, reliability, accuracy, breadth, veracity, validity, and constitutionality of any matter or information contained in any of said links. hyperlinks and other sites on the Internet. Likewise, the inclusion of these external connections will not imply any type of association, merger, or participation with the connected entities.

Exclusion Rights
SPEAKEASY CONSULTING LLC reserves the right to deny or withdraw access to the portal and/or the services offered without prior warning, at its own request or that of a third party, to those users who fail to comply with the content of this legal notice.

Ownership and Licenses The Website and its entire contents, features, and functionality (including but not limited to all information, course materials, software, text, displays, images, video, and audio, and the design, selection, and arrangement thereof) are owned by SPEAKEASY CONSULTING LLC, its licensors, or other providers of such material.

  • Proprietary Content: Our educational resources, original texts, logos, methodologies, and course structures are protected by United States and international copyright, trademark, trade secret, and other intellectual property or proprietary rights laws.
  • Third-Party & AI Assets: Certain visual assets used on the platform may be licensed from third parties or generated using artificial intelligence tools. While specific AI-generated components may not be subject to federal copyright protection, the compilation, arrangement, and presentation of these materials within our platform constitute the proprietary trade dress and intellectual effort of Speakeasy Consulting LLC.

Generalities
SPEAKEASY CONSULTING LLC will pursue non-compliance with these conditions, as well as any improper use of its portal, by exercising all civil and criminal actions that may correspond to it by law.

Children’s Privacy
Our services are not directed to children under 13. We do not knowingly collect personal information from children under 13 in compliance with the Children’s Online Privacy Protection Act (COPPA). If discovered, such data will be deleted immediately.

Right to Privacy (Puerto Rico Constitutional Protection)

All processing of personal data respects the fundamental right to privacy recognized by the Constitution of the Commonwealth of Puerto Rico.

We commit to handling personal information with transparency, proportionality, and necessity, limiting collection strictly to what is required to deliver our services.

Data Breach Notification

In the event of a security breach that compromises personal data, SPEAKEASY CONSULTING LLC will promptly investigate the incident and notify affected users and, where applicable, relevant authorities within seventy-two (72) hours of becoming aware of the breach, in accordance with GDPR standards and applicable Puerto Rico and U.S. laws.

Notifications will include the nature of the breach, potential risks, and recommended protective steps.

Cookies and Tracking Technologies

We use cookies and similar technologies to ensure proper site functionality and improve user experience.

  • Essential cookies: required for security, shopping cart, and LMS login
  • Analytics cookies: measure traffic and usage

Essential cookies are necessary and cannot be disabled.

Analytics or non-essential cookies are activated only after the user provides prior and affirmative consent through our cookie banner or preference tool, in accordance with GDPR best practices.

Users may accept, reject, or customize cookie preferences at any time.

Disabling cookies may affect certain website features.

Governing Law and Jurisdiction

This Privacy Policy and the relationship between the User and SPEAKEASY CONSULTING LLC shall be governed by and interpreted in accordance with:

  • the laws of the Commonwealth of Puerto Rico
  • applicable federal laws of the United States

including, where applicable:

  • CAN-SPAM Act
  • Children’s Online Privacy Protection Act (COPPA)
  • Federal Trade Commission Act (FTC Act)

Any dispute, claim, or controversy arising out of or relating to this Privacy Policy or our services shall be subject exclusively to the state courts of Puerto Rico AND the United States federal courts located in Puerto Rico for matters of federal jurisdiction.

By using our services, you expressly consent to venue and jurisdiction in these courts.

Modification of this legal notice and duration
We may update this Privacy Policy. Updates will be posted with a new “Last updated” date.