{"id":3,"date":"2023-12-08T17:37:22","date_gmt":"2023-12-08T17:37:22","guid":{"rendered":"https:\/\/cubaprimero.org\/?page_id=3"},"modified":"2026-09-04T12:42:28","modified_gmt":"2026-09-04T17:42:28","slug":"privacy-policy","status":"publish","type":"page","link":"https:\/\/cubaprimero.org\/en\/privacy-policy\/","title":{"rendered":"Privacy Policy"},"content":{"rendered":"<div data-elementor-type=\"wp-page\" data-elementor-id=\"3\" class=\"elementor elementor-3\" data-elementor-post-type=\"page\">\n\t\t\t\t<div class=\"elementor-element elementor-element-82db2cd e-flex e-con-boxed e-con e-parent\" data-id=\"82db2cd\" data-element_type=\"container\" data-e-type=\"container\">\n\t\t\t\t\t<div class=\"e-con-inner\">\n\t\t\t\t<div class=\"elementor-element elementor-element-5b5b4fa9 elementor-widget elementor-widget-text-editor\" data-id=\"5b5b4fa9\" data-element_type=\"widget\" data-e-type=\"widget\" data-widget_type=\"text-editor.default\">\n\t\t\t\t\t\t\t\t\t<div class=\"cp-privacy-policy\">\n<style>\n    .cp-privacy-policy {<br \/>\n      max-width: 860px;<br \/>\n      margin: 0 auto;<br \/>\n      font-family: inherit;<br \/>\n      line-height: 1.7;<br \/>\n      color: #222;<br \/>\n    }<br \/>\n    .cp-privacy-policy h1 {<br \/>\n      font-size: 1.9em;<br \/>\n      margin-bottom: 0.2em;<br \/>\n    }<br \/>\n    .cp-privacy-policy .cp-subtitle {<br \/>\n      font-size: 1.15em;<br \/>\n      font-weight: 600;<br \/>\n      margin: 0 0 1em;<br \/>\n    }<br \/>\n    .cp-privacy-policy .cp-dates {<br \/>\n      font-size: 0.95em;<br \/>\n      color: #555;<br \/>\n      margin-bottom: 2em;<br \/>\n    }<br \/>\n    .cp-privacy-policy h2 {<br \/>\n      font-size: 1.25em;<br \/>\n      margin-top: 2em;<br \/>\n      margin-bottom: 0.5em;<br \/>\n      border-bottom: 1px solid #ddd;<br \/>\n      padding-bottom: 0.3em;<br \/>\n    }<br \/>\n    .cp-privacy-policy h3 {<br \/>\n      font-size: 1.05em;<br \/>\n      margin-top: 1.3em;<br \/>\n      margin-bottom: 0.4em;<br \/>\n    }<br \/>\n    .cp-privacy-policy p {<br \/>\n      margin: 0 0 1em;<br \/>\n    }<br \/>\n    .cp-privacy-policy a {<br \/>\n      color: #0066cc;<br \/>\n      text-decoration: underline;<br \/>\n    }<br \/>\n  <\/style>\n<h1>Cuba First<\/h1>\n<p class=\"cp-subtitle\">PRIVACY POLICY FOR MARKETING AND DIGITAL COMMUNICATIONS<\/p>\n<p class=\"cp-dates\">\n    Effective Date: 06\/01\/2026<br>    Last Updated: 06\/01\/2026\n  <\/p>\n<p>This Privacy Policy explains how Cuba Primero collects, uses, shares, and protects personal information in connection with our website, our email and text message communications, our social media and video channels, and our advertising and promotional activities. Please read it carefully. By visiting our website, subscribing to our communications, submitting content to us, or otherwise interacting with our marketing channels, you acknowledge that you have read and understood this Policy.<\/p>\n<h2>1. Who We Are and What This Policy Covers<\/h2>\n<p>Cuba Primero, LLC, a Florida limited liability company (referred to in this Policy as \u201cCuba Primero,\u201d \u201cwe,\u201d \u201cus,\u201d or \u201cour\u201d), maintains its principal place of business at 8181 NW 36th Street, Doral, Florida. We produce and distribute media, cultural, and informational content and we promote that content through our website, electronic mail, text messaging, social media, and paid digital advertising.<\/p>\n<p>This Policy applies to personal information we collect through our marketing and audience channels, which include our website located at cubaprimero.org, any microsite or landing page we operate, our email newsletters and announcements, our text message program, our social media and video pages to the extent we control the data we receive from them, and any event registration, contest, survey, or content submission form we make available.<\/p>\n<p>This Policy is a statement of our practices with respect to marketing information. It is not a contract, it does not create rights beyond those provided by applicable law, and it does not alter any separate written agreement you have signed with us.<\/p>\n<h2>2. What This Policy Does Not Cover<\/h2>\n<p>This Policy does not cover information you provide to any other company, professional practice, or medical facility, including any entity affiliated with or under common ownership with Cuba Primero. Those entities maintain their own privacy practices and, where they are health care providers, their own notices of privacy practices issued under the Health Insurance Portability and Accountability Act and its implementing regulations at 45 C.F.R. Parts 160 and 164. If you are a patient of an affiliated medical practice, the handling of your health information is governed by that practice\u2019s notice of privacy practices and not by this Policy.<\/p>\n<p>Cuba Primero does not solicit, and asks that you do not send us, information about your medical conditions, treatments, diagnoses, or care. If you send us that information through a marketing channel, we will treat it as sensitive and will delete it when we reasonably can, but a marketing channel is not a secure or confidential means of transmitting health information.<\/p>\n<p>This Policy also does not cover the independent practices of third-party platforms, advertising networks, or websites that we link to or that host our content. Section 18 addresses those relationships.<\/p>\n<h2>3. Information We Collect<\/h2>\n<h3>3.1 Information You Provide to Us Directly<\/h3>\n<p>We collect the information you choose to give us. Depending on how you interact with us, that may include your name, electronic mail address, mobile telephone number, mailing address or city and state, the language in which you prefer to receive communications, your content and topic preferences, information you include in a message, comment, survey response, contest entry, or event registration, and any photographs, video, audio, written material, or other content you submit to us.<\/p>\n<p>We do not require you to provide any of this information in order to view publicly available content on our website. Information you provide in connection with a subscription, a submission, or an entry is provided voluntarily.<\/p>\n<h3>3.2 Information Collected Automatically<\/h3>\n<p>When you visit our website or open our electronic mail, we and our service providers automatically collect certain technical information. This includes your internet protocol address, which may indicate your approximate geographic location at the city level, your browser type and version, your operating system and device type, screen and window characteristics, the referring website or advertisement that brought you to us, the pages and content you view, the date and time of your visit and how long you remain on a page, the links and buttons you select, the video content you play and how much of it you watch, and whether you opened a message we sent and selected a link within it. We also assign and read cookie identifiers and similar online identifiers as described in Section 4.<\/p>\n<h3>3.3 Information We Receive From Third Parties<\/h3>\n<p>We may receive information about you from advertising and analytics platforms in aggregate or pseudonymous form, from social media and video platforms when you interact with our pages there, from service providers who help us deliver electronic mail and text messages and who report on delivery and engagement, and from vendors who help us confirm that a telephone number is valid and is capable of receiving text messages.<\/p>\n<h2>4. Cookies, Pixels, Tags, and Similar Technologies<\/h2>\n<p>We and our partners use cookies, which are small text files placed on your device, together with pixels, tags, software development kits, local storage, and similar technologies. We use technologies that are strictly necessary to operate the website and keep it secure, technologies that remember your preferences such as your language selection, technologies that measure traffic and understand which content is read and watched, and technologies supplied by advertising platforms that allow us to reach you and people similar to you with advertisements after you leave our website.<\/p>\n<p>Some of these technologies are supplied by third parties, including analytics providers and social media and search advertising platforms, and those third parties may read the identifiers they set across other websites you visit. The information those technologies collect may be combined by the platform with information it already holds about you.<\/p>\n<p>You can control cookies through your browser settings, and most browsers allow you to refuse or delete cookies. Doing so may cause parts of our website to function improperly. Where we make a cookie preference tool available on our website, you may use it to accept or decline non-essential categories of cookies, and you may revisit that tool at any time to change your selections.<\/p>\n<h2>5. How We Use Your Information<\/h2>\n<p>We use the information described above to operate, maintain, and secure our website and our communication systems; to deliver the newsletters, announcements, and text messages you have asked to receive; to produce, program, and distribute our content and to decide what content to create; to measure the reach and performance of our content and of our advertising; to plan, place, and evaluate advertising campaigns, including advertising directed to people who have visited our website or who resemble our existing audience; to respond to your questions, comments, and submissions; to administer contests, surveys, events, and promotions and to notify participants; to detect and prevent fraud, abuse, spam, and unauthorized access; and to comply with law and to establish, exercise, or defend legal claims.<\/p>\n<p>We do not use the information we collect through our marketing channels to make decisions about any person\u2019s eligibility for medical treatment, employment, credit, insurance, or housing.<\/p>\n<h2>6. Advertising, Analytics, and Audience Matching<\/h2>\n<p>We advertise on third-party platforms, and we use analytics and advertising tools supplied by those platforms. In practical terms this means two things you should understand.<\/p>\n<p>First, when you visit our website, advertising and analytics technologies on the site may transmit information about your visit, including page addresses that describe the content you viewed and an online identifier associated with your browser or device, to the platform that supplied the technology. Second, we may provide a platform with a list of contact identifiers, such as electronic mail addresses or telephone numbers of our subscribers, in a hashed or otherwise obscured form, so that the platform can match those identifiers against its own users and show our advertisements to them or to people it considers similar. This practice is commonly described as custom audience or audience matching.<\/p>\n<p>Some privacy laws treat these disclosures as a sale of personal data or as sharing for targeted advertising even where no money changes hands. Section 11 states our position, and Section 16 explains how you may ask us to stop.<\/p>\n<p>Aside from the advertising and analytics disclosures described in this Section and the service provider disclosures described in Section 10, we do not sell, rent, license, or trade your personal information to third parties for their own marketing purposes.<\/p>\n<h2>7. Electronic Mail Marketing<\/h2>\n<p>We send commercial electronic mail only to people who have asked to receive it or who have an existing relationship with us that makes the message expected. Every commercial message we send identifies Cuba Primero as the sender, uses accurate header information and a subject line that is not misleading, discloses a valid physical postal address, and contains a clear and conspicuous mechanism for you to decline further commercial messages. These practices are required by the CAN-SPAM Act, 15 U.S.C. sections 7701 through 7713, and the Federal Trade Commission\u2019s implementing rule at 16 C.F.R. Part 316.<\/p>\n<p>You may withdraw your consent at any time by selecting the unsubscribe link in any commercial message or by writing to us at the address in Section 21. We will honor your request within ten business days, which is the period allowed by 15 U.S.C. section 7704(a)(4)(A), and in practice we act sooner. We may still send you messages that are transactional or relationship in nature, such as a reply to an inquiry you sent us or information about a contest you entered.<\/p>\n<h2>8. Text Message Marketing<\/h2>\n<p>We send marketing text messages only to mobile telephone numbers for which we have obtained prior express written consent. When you give that consent, you agree to receive autodialed or automated marketing text messages from Cuba Primero at the number you provided, you understand that your consent is not a condition of purchasing any property, goods, or services, and you understand that message and data rates may apply. Message frequency varies. These consent requirements arise under the Telephone Consumer Protection Act, 47 U.S.C. section 227, and the Federal Communications Commission\u2019s rules at 47 C.F.R. section 64.1200, and under the Florida Telephone Solicitation Act, section 501.059, Florida Statutes.<\/p>\n<p>You may withdraw your consent at any time and by any reasonable means. Replying STOP, END, QUIT, CANCEL, or UNSUBSCRIBE to any message from us will end the program, and we may send a single message confirming that we have done so. Replying HELP will return contact information for assistance. We honor a revocation of consent as soon as practicable and in no event later than ten business days after we receive it, consistent with 47 C.F.R. section 64.1200(a)(10), and we cease text message solicitations within the period required by section 501.059(10)(c), Florida Statutes. You may also withdraw consent by writing to us at the address in Section 21, and you do not need to use any particular word or format for your request to be effective.<\/p>\n<p>We do not send marketing text messages or place marketing telephone calls before 8:00 a.m. or after 8:00 p.m. in the recipient\u2019s local time zone, and we do not place more than three such calls to the same person on the same subject within a twenty-four hour period, consistent with section 501.616(6)(a) and (b), Florida Statutes. Carriers are not liable for delayed or undelivered messages.<\/p>\n<h2>9. Photography, Video, and Content You Submit<\/h2>\n<p>If you send us a photograph, a video, an audio recording, a written submission, or other material, or if you appear in material recorded at an event we produce or attend, we may use that material in our content, on our website and social media channels, and in our advertising and promotional materials.<\/p>\n<p>Under section 540.08, Florida Statutes, a person\u2019s name, portrait, photograph, or other likeness may not be published or publicly used for purposes of trade or for a commercial or advertising purpose without that person\u2019s consent. Accordingly, before we use identifiable footage or images of a person in advertising or promotion, we obtain a written release from that person, or from a parent or legal guardian if the person is a minor. If you appear in material we hold and you have not signed a release, or if you have signed one and wish to withdraw it as to future uses, write to us at the address in Section 21 and we will address your request.<\/p>\n<p>When you submit content to us, you represent that you own it or have the right to give it to us, that it does not infringe anyone\u2019s rights, and that you have obtained any consent required from other people who appear in it. Unless we agree otherwise in writing, you grant us a non-exclusive, royalty-free, worldwide license to use, reproduce, edit, and publicly display the content you submit in connection with our programming and promotion, and you understand that content you submit for publication is not confidential.<\/p>\n<h2>10. How and With Whom We Share Information<\/h2>\n<p>We share personal information with service providers who perform functions on our behalf and who are contractually restricted from using the information for their own purposes, including website hosting and content delivery providers, electronic mail and text message platforms, analytics providers, form and survey providers, event registration providers, information technology and security vendors, and our attorneys, accountants, and insurers. We share information with advertising platforms as described in Section 6.<\/p>\n<p>We may also disclose information when we believe in good faith that disclosure is required by law, by subpoena, by court order, or by another lawful demand from a government authority; when disclosure is necessary to investigate suspected fraud, a threat to the safety of any person, or a violation of our terms; and in connection with a merger, financing, reorganization, or sale of assets, in which case we will require the recipient to honor the commitments in this Policy as to information transferred.<\/p>\n<p>We do not disclose your personal information to affiliated companies for those companies\u2019 own independent marketing purposes unless you have separately consented.<\/p>\n<h2>11. Sale of Personal Data and Sensitive Data<\/h2>\n<p>We do not sell personal data for money. As explained in Section 6, we do disclose online identifiers and contact identifiers to advertising and analytics platforms for targeted advertising, and some statutes define a sale broadly enough to include disclosures of that kind made for valuable consideration. We disclose this so that you can make an informed choice, and Section 16 tells you how to opt out.<\/p>\n<p>We do not sell sensitive personal data and we do not sell biometric personal data. We do not knowingly collect biometric identifiers, precise geolocation data, government identification numbers, financial account numbers, or health information through our marketing channels, and we ask that you not send them to us.<\/p>\n<h2>12. How Long We Keep Information<\/h2>\n<p>We keep personal information only as long as we need it for the purpose for which it was collected, or for a longer period where a law, a regulation, a contract, an insurance requirement, or a reasonably anticipated legal claim requires us to keep it. Subscriber contact information is kept for as long as the subscription remains active and for a reasonable period afterward. Records of consent to receive text messages and records of revocation of that consent are retained for at least five years, which reflects the four-year federal catch-all limitations period at 28 U.S.C. section 1658 and the four-year Florida limitations period for an action founded on a statutory liability at section 95.11(3)(e), Florida Statutes, with a margin. Website analytics data is retained in accordance with the settings of the analytics platforms we use. Submitted content and releases are retained for as long as we use the content and afterward as proof of the right to have used it.<\/p>\n<h2>13. Security<\/h2>\n<p>We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, alteration, and destruction, including encryption of our website in transit, access controls that limit staff access to what each person needs, and contractual security obligations imposed on our service providers. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for keeping confidential any password or access credential we issue to you.<\/p>\n<h2>14. Notification in the Event of a Security Breach<\/h2>\n<p>If we determine that a breach of security has compromised your personal information as that term is defined in section 501.171, Florida Statutes, we will notify you without unreasonable delay and no later than thirty days after we determine that a breach occurred or that there is reason to believe one occurred, subject to any delay requested by a law enforcement agency. Where a breach affects five hundred or more residents of Florida, we will also notify the Florida Department of Legal Affairs within the period that section 501.171(3) requires.<\/p>\n<h2>15. Children\u2019s Privacy<\/h2>\n<p>Our website and our communications are directed to adults. We do not knowingly collect personal information from children under thirteen years of age, and we do not knowingly permit children under thirteen to subscribe to our electronic mail or text message programs. The Children\u2019s Online Privacy Protection Act, 15 U.S.C. sections 6501 through 6506, and the Federal Trade Commission\u2019s rule at 16 C.F.R. Part 312, as amended effective June 23, 2025 with full compliance required by April 22, 2026, govern the online collection of personal information from children under thirteen.<\/p>\n<p>If we learn that we have collected personal information from a child under thirteen without verifiable parental consent, we will delete it promptly. A parent or legal guardian who believes we hold information about their child may write to us at the address in Section 21 and we will confirm what we hold, delete it on request, and stop any further collection. We also do not knowingly send marketing text messages to persons under eighteen years of age.<\/p>\n<h2>16. Your Choices and Your Rights<\/h2>\n<p>You may decline further commercial electronic mail at any time by using the unsubscribe link in any message. You may end our text message program at any time by replying STOP. You may control cookies through your browser settings and through any cookie preference tool we make available. You may ask us to stop using your information for targeted advertising, including custom audience and audience matching, by writing to us at the address in Section 21.<\/p>\n<p>In addition, and whether or not any particular statute requires it of us, we will honor the following requests from any individual who submits one and whose identity we can reasonably verify. You may ask us to confirm whether we hold personal information about you and to give you a copy of it. You may ask us to correct information that is inaccurate. You may ask us to delete information we hold about you. You may ask us to stop processing your information for targeted advertising or for the sale of personal data as those terms are defined in the Florida Digital Bill of Rights, sections 501.701 through 501.722, Florida Statutes. You may ask us to provide your information in a portable, readily usable format. We will not deny you goods or services, charge you a different price, or provide you a lesser level of service because you exercised any of these rights.<\/p>\n<p>To make a request, write to us at the address in Section 21 and describe what you are asking for. We will respond within forty-five days of receipt, and if we need more time we will tell you within that period and take no more than an additional forty-five days. We may ask you for information sufficient to verify that the request comes from you or from a person you have authorized to act for you. If we decline a request in whole or in part, we will tell you why and how to appeal that decision to us, and we will decide the appeal within sixty days and explain the basis for our decision in writing.<\/p>\n<h2>17. Global Privacy Control and Do Not Track<\/h2>\n<p>Some browsers and extensions transmit an opt-out preference signal, such as the Global Privacy Control. Where our website is technically able to receive and process such a signal, we treat it as a request to stop processing that browser\u2019s information for targeted advertising and for the sale of personal data. Browsers also transmit a Do Not Track signal, for which no common industry standard for compliance has been adopted, and our website does not currently respond to it.<\/p>\n<h2>18. Third-Party Websites, Platforms, and Content<\/h2>\n<p>Our website, our messages, and our social media pages contain links to and content from websites and platforms we do not control. When you follow a link or interact with embedded content, the operator of that website or platform collects information about you under its own privacy policy and terms, and we are not responsible for its practices. Our presence on a social media or video platform does not place that platform\u2019s independent data collection under our control. We encourage you to read the privacy policy of any third-party service before you use it.<\/p>\n<h2>19. Users Located Outside the United States<\/h2>\n<p>Our website and communications are intended for users located in the United States, and our information is stored and processed in the United States. The privacy and data protection laws of the United States may differ from those of the country in which you are located, and they may offer less protection. If you access our website or subscribe to our communications from outside the United States, you do so on your own initiative and you consent to the transfer of your information to, and its storage and processing in, the United States.<\/p>\n<h2>20. Changes to This Policy<\/h2>\n<p>We review this Policy at least annually and we may revise it at other times. When we revise it, we will change the Last Updated date at the top and post the revised Policy on our website. If a revision materially changes how we use information we have already collected, we will provide notice that is reasonable under the circumstances, which may include an electronic mail notice or a prominent notice on the website, and, where the law requires it, we will obtain your consent before applying the change to information we already hold.<\/p>\n<h2>21. How to Contact Us<\/h2>\n<p>Questions, requests, and complaints about this Policy or about our handling of personal information may be sent to Cuba Primero at 8181 NW 36th Street, Doral, Florida, by electronic mail to <a href=\"mailto:contact@cubaprimero.org\">contact@cubaprimero.org<\/a>. We ask that you describe your request with enough detail that we can identify what you are asking for and locate the information involved.<\/p>\n<p>Florida residents may also contact the Florida Department of Legal Affairs, Office of the Attorney General, PL-01 The Capitol, Tallahassee, Florida 32399-1050.<\/p>\n<\/div>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t<\/div>","protected":false},"excerpt":{"rendered":"<p>CUBA PRIMERO PRIVACY POLICY FOR MARKETING AND DIGITAL COMMUNICATIONS Effective Date: 06\/01\/2026 Last Updated: 06\/01\/2026 This Privacy Policy explains how Cuba Primero collects, uses, shares, and protects personal information in connection with our website, our email and text message communications, our social media and video channels, and our advertising and promotional activities. 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