Privacy Policy

1. Who is responsible

1.1 The controller of your data is Dashing Media LLC (AXIS by CREZIR), registered in New Mexico.

• Address: 1209 Mountain Road PL NE STE R, Albuquerque, NM 87110, USA
• Privacy email: privacidad@crezir.com
• Phone: +1 954 820 3777

1.2 This policy covers axis.crezir.com. CREZIR (crezir.com) has its own policy. Your HighLevel account, Stripe, WhatsApp and HighLevel’s communities are covered by each company’s own policy.

2. What data we handle

Category	What it includes	Where it comes from
Account and sign-up	Name, email (the one from your HighLevel account if you join through the link), password (stored encrypted), language, country, time zone, how you joined (link, payment or Teams), the HighLevel plan you tell us, personal evidence code, the team you belong to, your consents (date, text and source)	You
AXIS Score and forms	Diagnostic answers, whether you have a HighLevel account, whether you would rather have us do it for you, results by area, contact details	You
Referral status	The status of the HighLevel account you opened through our link (in trial, paying, canceled or not found) and the date we checked	HighLevel (affiliate dashboard)
Learning	Progress by lesson, attempts and results on quizzes and exams (with duration), Daily Review, points, challenges, streak, AXIS Score by area	You · generated by the system
Evidence and answers	Screenshots, public links, execution logs, CSV files, short recordings, Enséñalo (Teach-it) text and voice notes (and their transcripts), final project, verdicts and review messages, an image fingerprint of each screenshot	You · generated by the system
AXIS Tutor	What you type and attach, the tutor’s replies, the lesson and mode, the date	You · generated by the system
Certificates	Code, skill, dates, status, public evidence summary (if you allow it)	Generated by the system
Payments	Plan, amount, dates, charge status, card brand and last four digits. Only Stripe handles the full card number	You · Stripe
Communications and support	Emails and WhatsApp messages we send and receive, email opens and clicks, support tickets	You · generated by the system
Community	Posts, comments and reactions	You
Technical and usage data	IP address, device and browser, language, pages viewed, events (for example, a click on /start), where your visit came from (UTM), first and last visit, security logs	Automatic
Teams	If you are an owner: seats, paths and billing. If you hold a seat: that your owner invited you and what they can see about you	You · the team owner

We do not ask for sensitive data (health, ethnic origin, religion, political opinions, etc.). Do not put it in evidence, in Enséñalo or in the tutor.

3. Why we use it, and the legal basis

The bases are those of Article 6 of the GDPR (Spain and the EU). For everyone else, the last column gives the reason in plain terms.

Why	Legal basis	In plain terms
Create your account, give you access and verify your referral	Contract (6.1.b). Verifying the referral also: legitimate interest (6.1.f)	Needed to give you the service and to check the condition of the free offer
Give you the lessons, progress, AXIS Score, certifications and the verification page	Contract	It is the service you asked for
Review your evidence and Enséñalo answers, and reply to you with the tutor (with AI and with people)	Contract	It is part of the service
Charge, invoice, refund and prevent payment fraud	Contract · legal obligation (6.1.c)	Needed to charge you and follow accounting laws
Detect duplicate screenshots and fraud, and protect the platform (security, anti-bot)	Legitimate interest	So certifications stay meaningful
Improve AXIS: tutor quality, question quality, aggregate metrics	Legitimate interest	To make the service better
Support and community	Contract · legitimate interest	To help you
Service messages: your AXIS Score result, access, payments, AXIS Launch reminders, change notices	Contract or steps at your request · legitimate interest	They are part of the service, or you asked for them
Marketing emails: sequences after the Score, news, offers	Consent (6.1.a): an unchecked box. In Spain, also the LSSI exception (Art. 21.2) for customers and similar products	Only if you agree
WhatsApp messages	Consent: two separate, optional boxes (account notices; news and offers)	Only if you agree, box by box
Analytics and marketing cookies	Consent (see /en/cookies/)	Only if you agree
Show your evidence, name or case; move your explanations into the knowledge base	Consent, separately	Only with your permission, and you can withdraw it
Pass your details to CREZIR when you choose “I’d rather have you do it for me”	At your request (6.1.b) · consent	You ask for it
Reports to your team owner (Teams)	Contract with the owner · the owner’s legitimate interest	The owner pays to see their team’s progress
Keep proof of your consents and defend against claims	Legal obligation · legitimate interest	So we can show what you agreed to

What “I’d rather have you do it for me” means. If you pick it, we pass your name, contact details, language and business type to CREZIR so they can contact you. CREZIR is another brand of the same company.

4. Who we share your data with

We do not sell your data. We use vendors that handle data on our behalf (processors) and a few other recipients.

Category	Vendor	Why	What data
Site hosting and backups	Hostinger. Weekly off-site copy: Bunny Storage or Google Drive	Keep the site running and keep copies	Everything we store on the platform
Content delivery and security	Cloudflare (includes Turnstile, the anti-bot check)	Speed, protection against attacks and bots	IP and technical visit data
CRM, email, WhatsApp, automations and community	HighLevel (includes LC Email and its communities feature). The site connects through WP Fusion, a plugin that runs on our site	Send emails and messages, communicate your progress (for example, “Operativo” or “certified”), help and community	Name, contact details, language, country, progress tags, messages
Messaging	Meta Platforms (WhatsApp Business Platform)	Send and receive your WhatsApp messages	Your number and message content
Payments	Stripe	Charge, refund and prevent fraud	Your payment details, which Stripe handles under its own policy
Artificial intelligence	Anthropic (Claude API)	AXIS Tutor, evidence review and Enséñalo grading (Section 7)	What you type and attach, and your context in AXIS
Voice-note transcription		Turn your Enséñalo voice note into text	Your audio
Video	Bunny.net (Bunny Stream), once videos exist	Play lesson videos	Technical playback data
Analytics and advertising (only if you accept those cookies)	Google (Google Analytics 4 and Google Ads) · Meta (pixel)	Measure which pages help and measure our ads	Online identifiers and activity on the site

Also:

• Your team owner (if you hold a Teams seat): sees what is described in Section 8.4 of the Terms.
• CREZIR, only if you ask (Section 3).
• Advisors and authorities: lawyers, accountants and authorities, when the law requires it or to defend a right.
• Change of ownership: if the company is sold or merged, your data may move to the new owner, with the same level of protection.
• Anyone with your certificate code can see its public page (Terms, Section 9.5).

5. International transfers

Dashing Media LLC is in the United States, and our vendors operate in the U.S. and other countries. If you live in Spain or the EU, Mexico or Colombia, your data leaves your country.

• EU/Spain: we use the European Commission’s standard contractual clauses, and the EU-U.S. Data Privacy Framework when the vendor is certified.
• Mexico: vendors act on our behalf as processors. Transfers to third parties are disclosed in this policy.
• Colombia: by accepting this policy you expressly authorize transferring your data to the U.S. and to the countries where our vendors operate.
• In every case: we sign a data processing agreement with each vendor that requires them to protect it.

6. How long we keep it

Data	Period
Account and progress	While you have an account
Screenshots and evidence files	180 days after they are verified. After that we keep only the verdict and its checklist
Final project evidence	While the certificate is valid, plus 90 days
Image fingerprint of screenshots
Enséñalo text and voice notes
AXIS Tutor conversations
Certificates and their verification page	Until expiration
Payments and invoicing	As long as accounting and tax laws require
Proof of your consents	At least 3 years, or 1 year after your contract ends if that is longer
Score contacts that did not create an account
Emails, messages and support tickets
Technical and security logs
Backups
Opt-out list (so we do not write to you again)	As long as needed to honor your opt-out

If you ask us to delete your data, we delete it within 10 business days after we verify your identity. We keep only what the law requires us to keep.

7. Artificial intelligence

7.1 Where we use AI. In two places:

• The AXIS Tutor, an AI assistant you chat with.
• Review of what you submit: AI reviews your evidence and your Enséñalo answers first.

7.2 What data it sees.

Function	What it receives
AXIS Tutor	What you type and attach. Your name, language, country, HighLevel plan and how you joined. Your evidence code. The lesson you are on and its status. Your recent verdicts and your AXIS Score. Passages from the curriculum
Evidence review	The screenshot, link or log you upload. The lesson’s checklist. Your code. When the lesson was started. Whether the fingerprint matches another submission
Enséñalo grading	Your text or the transcript of your voice note, and any names from your account that you mention as an example

7.3 What for. To answer you, guide you, diagnose, give you a verdict and improve the quality of the service.

7.4 Provider. Anthropic (Claude API), on our behalf as a processor. Calls are made from our server, not from your browser. Your data is not used to train models.

7.5 People. A team member may read a random sample of tutor conversations to check quality. People also review your evidence in doubtful cases, in the Implementer final project and in quality audits.

7.6 Automated decisions. Some decisions (approving evidence, grading an Enséñalo, an exam result) are made first by an automated system. You have the right to ask for a person to review them, to give your point of view and to challenge the decision (GDPR, Article 22). Write to us or use the human review button. We reply within 48 business hours.

7.7 What not to type. Passwords, keys, verification codes, payment details, health data, or real data of your clients.

7.8 Notice. The tutor tells you it is an AI. We are telling you here too.

8. Email, WhatsApp and text messages

8.1 Email. Service emails (your AXIS Score result, access, payments, your AXIS Launch route reminders, important notices) do not need separate permission. Route reminders include a link to pause them. Marketing emails (news and offers), including follow-ups after the Score, do: only if you check the box, which starts unchecked. In Spain, we may write to a customer about products similar to those they already bought (LSSI, Article 21). Every email shows the real sender, our mailing address and a one-click unsubscribe link. We honor your unsubscribe within 10 business days at most, and normally right away.

8.2 WhatsApp. Only if you check its boxes, which are separate and optional: one for account notices and one for news and offers. You can check one without the other. We write first using templates approved by Meta. Reply STOP at any time to stop receiving them. Consent is not a condition of purchase.

8.3 Text messages (SMS). In this version of AXIS we do not send SMS. If we ever do, we will ask for separate consent. We will never send you the affiliate link or messages about making money by SMS.

8.4 When we write. Messages we send on our own initiative go out Monday to Friday from 8:00 a.m. to 7:00 p.m., and Saturdays from 9:00 a.m. to 3:00 p.m., in your local time. Never on Sundays or holidays. Replies to someone who wrote to us first, and messages triggered by your own action (sign-up, payment), go out right away.

9. Your rights and how to use them

9.1 How. Email privacidad@crezir.com. To protect you, we confirm your identity: through your signed-in session or a message to your account email. We do not charge for this. We do not treat you worse for using your rights.

9.2 Spain and the EU (GDPR). You can:

• Access your data and get a copy.
• Correct it.
• Ask us to delete it (erasure).
• Ask us to restrict its use.
• Object to certain uses.
• Receive it in a format you can take to another service (portability).
• Withdraw consent at any time (it does not affect what was done before).
• Not be subject to a decision based only on automated processing (Section 7.6).

We reply within one month, extendable by two more months if the request is complex. If you are not satisfied, you can complain to the Spanish Data Protection Agency (aepd.es) or to the authority in your country.

9.3 Mexico (Federal Law on the Protection of Personal Data Held by Private Parties, in force since 2025). This is what the privacy notice must say:

• Who is responsible: Dashing Media LLC, at the address in Section 1.
• What data we handle: that of Section 2. We do not handle sensitive data.
• Necessary purposes (without them we cannot give you the service): create your account, give you the lessons, review your evidence, charge you, security and support.
• Additional purposes (you can say no without losing the service): marketing emails, WhatsApp, analytics and marketing cookies, showing your evidence or case, passing your details to CREZIR.
• How to limit use or disclosure: by not checking the boxes, unsubscribing in one click, changing your cookies, or writing to privacidad@crezir.com.
• ARCO rights: access, rectification, cancellation and opposition. You can also revoke your consent. You use them as Section 9.1 explains. We reply within the deadlines set by law.
• Transfers: those in Sections 4 and 5.
• Changes to the notice: we tell you by email and with a notice on the site.
• Authority: the Secretaría Anticorrupción y Buen Gobierno.

9.4 Colombia (Law 1581 of 2012). This section is our data processing policy for Colombia.

• Controller: Dashing Media LLC (Section 1).
• Your rights: to know, update and correct your data; to request proof of your authorization; to be told how we use your data; to file complaints with the Superintendencia de Industria y Comercio; to revoke your authorization or ask us to delete your data; to access it free of charge.
• How: by privacidad@crezir.com. We answer inquiries in 10 business days (extendable by 5). We answer claims in 15 business days (extendable by 8).
• Authorization: by registering and accepting this policy, you authorize us to handle your data for the purposes in Section 3 and to transfer it as Section 5 says.
• Sensitive data: we do not ask for it.
• Your data is handled for the length of the relationship and the periods in Section 6.

9.5 United States. We offer the rights in this section to everyone who uses AXIS from the U.S., whether or not they live in California.

California (CCPA/CPRA). If you live in California, you can:

• Know what personal information we have and get a copy.
• Ask us to delete it.
• Ask us to correct inaccurate information.
• Opt out of our selling or sharing your information.
• Not be treated worse for using these rights.

We reply within 45 days, extendable by another 45 if needed. We ask to verify your identity. An authorized agent can make the request for you, with your written permission.

Category (CCPA)	Examples in AXIS	Shared for advertising?
Identifiers	Name, email, IP, online identifiers, evidence code	Only online identifiers, and only if you accept marketing cookies
Customer records	Name, email, plan, payment status	No
Commercial information	Purchases, plan, payment history	No
Internet activity	Pages viewed, clicks, events	Only if you accept marketing cookies
Approximate location	Country, time zone, IP	No
Audio and images	Screenshots, voice notes, short recordings	No
Professional and education information	Progress, evidence, certifications, AXIS Score	No
Inferences	Lowest AXIS Score area, recommended path	No

Selling and sharing. We do not sell your personal information. If you accept marketing cookies, some online identifiers and your activity are sent to Google and Meta to measure ads. California law calls that “sharing.” You can turn it off at any time: in the banner, with the “Do Not Sell or Share My Personal Information” link in the footer, or with your browser’s Global Privacy Control signal, which we honor.

Sensitive information. We do not use it to infer characteristics about you. Your account login details are used only to give you the service.

Other states. If you live in a state with a privacy law, you may have similar rights: access, correction, deletion, portability, and opting out of targeted advertising, sale or profiling. If we deny your request, you can appeal by writing to privacidad@crezir.com with the subject “Appeal.” We reply within the deadlines set by law.

10. Minors

AXIS is only for people 18 and older. We do not knowingly collect data from minors. If we find a minor’s account, we close it and delete the data. If you think that happened, write to privacidad@crezir.com.

11. Security

• Passwords stored encrypted.
• Two-step verification required for administrators, reviewers and team leaders.
• Screenshots and evidence files are stored outside the public folder and served with temporary signed links.
• System keys (for payments, AI, video) are never in your browser.
• Bot protection and usage limits on forms, the tutor and evidence upload.
• Team access by role, with the minimum needed.
• Daily backups and a weekly one stored off the host.
• Encrypted connection (HTTPS).

No system is 100% secure. If a breach affects you, we tell you and notify the authorities as the law requires (in the EU, within 72 hours).

12. Cookies

We use necessary cookies and, with your permission, analytics and marketing cookies. See /en/cookies/ for the details and to change your choice.

13. Changes to this policy

When we change it, we will post the new version with its date. If the change is important, we tell you by email and on the site before it applies.

14. Contact

Dashing Media LLC · 1209 Mountain Road PL NE STE R, Albuquerque, NM 87110, USA

• Privacy and data rights: privacidad@crezir.com
• General contact: axis@crezir.com · +1 954 820 3777
• Support: soporte@crezir.com