Website privacy policy

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Contents

INI PAGOS S.A. (“INI”), domiciled at Del Valle Iberlucea 2295, Beccar, Provincia de Buenos Aires, República Argentina, is the controller responsible for the processing of the personal data collected through the website www.ini.live and its subdomains (the “Site”).

In this privacy policy (the “Privacy Policy”) we explain what personal data we collect through the Site, what we use it for, with whom we may share it, and what rights the individuals who provide it have. We recommend that you read it carefully.

1.Scope

This Privacy Policy applies exclusively to the personal data processed in connection with browsing and using the Site, including the contact forms, information requests, subscriptions and job applications submitted through it.

The Site is institutional and informational in nature and does not allow services to be contracted. The processing of personal data related to the contracting or use of INI’s products and services is governed by the terms and conditions, agreements and specific policies of each service, which shall prevail over this Privacy Policy to the extent applicable.

2.Applicable law

INI processes personal data in accordance with Ley N° 25.326 de Protección de los Datos Personales (Argentine Personal Data Protection Law, the “Personal Data Protection Law”), its Decreto Reglamentario N° 1558/2001 (Regulatory Decree), Ley N° 27.483, which approves Council of Europe Convention 108 and its amending Protocol, and the provisions and resolutions issued by the Agencia de Acceso a la Información Pública (Agency for Access to Public Information, the “AAIP”), as well as any rules that may amend, supplement or replace them in the future.

3.Definitions

For the purposes of this Privacy Policy, the following terms shall have the meanings set out below:

  • Personal Data: information of any kind relating to identified or identifiable natural persons or legal entities.
  • Data Subject: the person whose Personal Data is being processed.
  • Processing: any operation or procedure, whether electronic or not, that enables the collection, retention, organization, storage, modification, evaluation, blocking, destruction and, in general, the handling of Personal Data, as well as its assignment to third parties.
  • User: any person who accesses, browses or uses the Site.
  • Cookies: small files that the Site stores on the User’s device to remember information about their browsing, and other similar technologies.

4.Personal Data we collect

We may collect the following categories of Personal Data:

  1. a)Data provided by the User: when the User completes a form, requests information or a demo, subscribes to our communications or applies for a job opening, we may collect identification and contact data (for example, first and last name, email address, telephone number), professional data (for example, company, position, country) and any other information the User chooses to include in their message or résumé.
  2. b)Automatically collected data: when the User browses the Site, we may collect technical information, such as IP address, browser and device type, operating system, pages visited, date and time of access, referring site and approximate geographic location, through Cookies and similar technologies.

Providing Personal Data through the Site’s forms is voluntary. However, the fields marked as mandatory are necessary to handle the User’s request; if they are not completed, we may be unable to process it.

The Site is not intended to collect sensitive data or payment card or bank account data. We ask Users not to include that type of information in the forms or messages they send us.

5.Purposes of processing

We use Personal Data for the following purposes:

  1. a)to respond to inquiries and requests for information or demos, and to manage commercial contact prior to any potential engagement;
  2. b)to send institutional communications, news, event invitations and information about our products and services, where the User has requested or consented to it;
  3. c)to manage recruitment processes for those who apply through the Site;
  4. d)to operate, maintain, analyze and improve the Site and the browsing experience, and to compile usage statistics;
  5. e)to protect the security of the Site and prevent misuse, fraud or unlawful activities; and
  6. f)to comply with legal obligations and with requests from competent authorities, and to exercise or defend INI’s rights.

INI may anonymize or aggregate the information collected, so that it does not allow any Data Subject to be identified, and use it for statistical or analytical purposes or to improve its services. Such information does not constitute Personal Data.

7.Cookies

The Site uses first-party and third-party Cookies for the following purposes:

  1. a)Necessary Cookies: enable the basic operation and security of the Site.
  2. b)Analytics Cookies: allow us to understand how the Site is used and to improve its content and performance.
  3. c)Functionality and marketing Cookies: allow the User’s preferences to be remembered and the effectiveness of our campaigns to be measured.

The User may configure their browser to accept, reject or delete Cookies, and may also manage their preferences through the settings tools available on the Site. Disabling certain Cookies may affect the operation of the Site. Third-party Cookies are governed by the privacy policies of their respective providers.

8.Disclosure of Personal Data to third parties

INI does not sell Personal Data. We may only share it in the following cases:

  1. a)Service providers: who assist us in operating the Site and in our activities (for example, cloud hosting and storage services, customer relationship management, email delivery, web analytics and recruitment). These providers act on behalf of INI, in accordance with its instructions and subject to confidentiality and security obligations, and may not use the Personal Data for their own purposes.
  2. b)INI group companies: including parent companies, subsidiaries or affiliates of INI in the Argentine Republic or abroad, for the same purposes described in this Privacy Policy.
  3. c)Authorities: when required by law, a court order or a request from a competent authority.
  4. d)Corporate transactions: in the context of a merger, spin-off, acquisition, reorganization or total or partial transfer of INI’s assets or business, in which case the acquirer shall be bound by this Privacy Policy.

Anyone involved in any stage of the processing of Personal Data is bound to keep it confidential, in accordance with Article 10 of the Personal Data Protection Law.

9.International transfers

Some of our providers and INI group companies may be located, or store information, outside the Argentine Republic. In such cases, INI will carry out international transfers of Personal Data in accordance with Article 12 of the Personal Data Protection Law and AAIP regulations, either to countries that offer adequate levels of protection or through the adoption of contractual clauses or other safeguards that ensure an adequate level of protection.

10.Retention of Personal Data

We will retain Personal Data only for as long as necessary to fulfill the purposes for which it was collected, or for as long as necessary to comply with legal obligations or to exercise or defend rights. Once those periods have elapsed, the Personal Data will be deleted or anonymized.

11.Security and confidentiality

INI adopts reasonable technical, organizational and physical measures to protect Personal Data against loss, alteration, and unauthorized access, use or disclosure, in line with the regulations in force and the security standards applicable to the payments industry in which it operates.

Notwithstanding the foregoing, no system for transmitting or storing information over the Internet is completely secure. In the event of a security incident affecting Personal Data, INI will take the necessary measures to mitigate its effects and will make the notifications required under applicable regulations.

12.Rights of Data Subjects

The Data Subject may at any time exercise their rights of access, rectification, updating and deletion of their Personal Data, as well as withdraw their consent and object to receiving commercial communications. To do so, they must send their request to the contact address indicated in Section 16, providing proof of their identity or, where applicable, of the representation claimed.

INI will respond to access requests within ten (10) calendar days, and to rectification, updating or deletion requests within five (5) business days of receipt, in accordance with Articles 14 and 16 of the Personal Data Protection Law. Deletion will not proceed where it could harm the rights or legitimate interests of third parties, or where there is a legal obligation to retain the data.

The data subject has the right to exercise the right of access to their personal data free of charge at intervals of no less than six months, unless a legitimate interest is shown for that purpose, as set forth in Article 14, subsection 3 of Ley Nº 25.326. The AGENCIA DE ACCESO A LA INFORMACIÓN PÚBLICA, in its capacity as the Supervisory Authority of Ley Nº 25.326, has the power to address the complaints and claims filed by those whose rights are affected by non-compliance with the regulations in force on personal data protection.

13.Minors

The Site is intended for persons over eighteen (18) years of age and for businesses. INI does not knowingly collect Personal Data from minors. If we become aware that we have received data from a minor, we will delete it.

15.Changes

INI may amend this Privacy Policy to adapt it to regulatory, operational or Site changes. The current version will always be published on the Site, indicating the date of its last update. Where the changes are material, we will give notice through the Site or by other reasonable means.

16.Contact

For any questions about this Privacy Policy or to exercise their rights, the User may contact:

INI PAGOS S.A.

Address:
Del Valle Iberlucea 2295, Beccar, Provincia de Buenos Aires, República Argentina.