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Privacy policy

This is the privacy policy (“Privacy Policy”) for any access and use of the Website, provided by CRYPTOLAB S.A.S., with registered office at Rio Negro Street Nº 350, in the city of Córdoba, province of Córdoba of the Republic of Argentina (“our”, “we”, “us”, “us” or “Xcapit”). Xcapit is the controller of your personal data collected through the website and we are committed to protecting and respecting your privacy.

USE OF THE WEB SITE

‍By accessing and using the Site you acquire the status of “User and/or Visitor”, which implies full acceptance of all provisions of this Privacy Policy and the Cookie Policy.

INTRODUCTION

‍Xcapit is the owner of the website https://www.xcapit.com/ (hereinafter, the “Site”) and is responsible for the processing of personal data of users (“User/s”) who access and use the Site.  By means of this Privacy Policy, and in compliance with Regulation (EU) 2016/679 (“GDPR”) and the Personal Data Protection Act, Xcapit informs Users who make use of the Site, that the processing of those personal data that may be collected through the Site and processed by Xcapit, in order for Users to decide, freely and voluntarily, whether or not they wish to provide the requested information. This Privacy Policy explains who we are, why and how we process personal data collected on the Site and what rights you have and if necessary how to contact us.Xcapit understands the importance of maintaining the confidentiality of all data that may be collected and respects the Personal Data Protection Law No. 25,326 applicable to them, the regulatory decree 1558 of 2001, the provision E60 of 2016, as well as the RGPD (General Data Protection Regulation, or better known as GDPR for its acronym in English (General Data Protection Regulation) which is a standard of the European Union. Thus, it is made known that Xcapit and those involved in any phase of the processing of personal data are bound to professional secrecy regarding them. When you provide us with any personal data, we have legal obligations towards you in the way we use that data. We must collect the information fairly and explain to you how we will use it. For ease of reading, we have divided this Privacy Policy into several sections:
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1. Introduction
2. What information we collect
3. How and why we use/share your information
4. How long we keep your information
5. Security
6. International data transfers
7. Your rights
8. Contact details
9. Changes to the Privacy Policy

It is important that you read this Privacy Policy together with any other privacy notices or fair processing notices we may provide at the time we collect and process your personal data so that you are fully aware of how and why we are using that data.If, for any reason, you do not agree with the terms of this Privacy Policy, we recommend that you do not enter any and/or personal information on the Site.We reserve the right to revise or amend this Privacy Policy at any time to reflect changes in our business or changes in the law. However, it is your responsibility to review this Privacy Policy.

‍1. INFORMATION WE COLLECT

‍What is personal data?
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‍When this Privacy Policy refers to “personal data”, it means data about you from which you could be identified or identifiable by, your name, and/or your contact details.
By law, all organizations that process your personal data are required to process your personal data in certain ways and to ensure that you are provided with an appropriate amount of information about how they use it. You also have various rights to seek information from those organizations about how they are using your data and to prevent them from processing it unlawfully. For more information about these rights, please see the “Your Rights” section of this Privacy Policy.
How and what types of data do we collect from you when you access the Site?
When you access the Site and choose to complete the form provided, we may collect, store and use certain personal information that you provide to us.
The Site has a contact form, the purpose of which is to respond to questions, inquiries or requests to:
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a) Provide information related to the request by electronic means;
b) Provide commercial information by electronic means, provided that express authorization has been given; and
c) Provide details about our services or improve our business strategy. 

The data collected are identifying data: name, surname, company, position, e-mail, telephone, city, area of interest, information that may result from the body of the message.
Xcapit uses specific cookies to obtain non-personal information data, relating to your use of the Site, this anonymous data will be collected mainly for purposes of administration and monitoring of the use and performance of the Site. 
Xcapit does not collect personally identifiable data from the Site when you browse, except when you specifically and knowingly provide it such as your full name and email address.
Personal data will be processed for the time necessary to fulfill your requests, inquiries and other requests. 
The above-mentioned collected data may be used by Xcapit for the purpose of making reports and statistical studies in order to increase the knowledge of the services requested by the Users, as well as to improve the quality of the Site's services. For this purpose, pseudonymization systems are applied, guaranteeing the confidentiality and security of Users' personal data. We may also partner with third parties who may collect anonymous statistical or usage data through your use of the application (including, for example, subcontractors in technical services, business partners, advertising networks, analytics providers, etc.).
We require all third parties to respect the security of your personal data and to process it in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes and only allow them to process your personal data for specific purposes and in accordance with our instructions. You are not obliged to provide your personal data, but if you do not provide it or if you provide wrong, false or inaccurate data, you will not be able to receive information about services and products from Xcapit.
If you have any questions about our use of this technology, please contact us (legal@xcapit.com).

‍COOKIE POLICY 

‍The cookie policy is a statement to visitors and/or users about what cookies are active on our website.Cookies are small data files that a web server stores in a browser when a web page is visited.  The purposes of these files are varied, including collecting information about the user's browsing habits and activity within the web. They also enhance the browser experience by remembering that you are logged in and thus make using our websites more enjoyable for you. 
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The types of cookies used on our website are:

- Necessary cookies help make a website usable by enabling basic functions such as page navigation and access to secure areas of the website. The website cannot function properly without these cookies.
- Preference cookies allow the website to remember information that changes the way the site behaves or looks, such as your preferred language or the region you are in.
- Statistics cookies help to understand how visitors interact with web pages by gathering and providing information anonymously.
- Marketing cookies are used to display relevant and engaging advertisements to visitors on web pages. 
- Session cookies collect information only while the visitor remains on our website, after which they are deleted.
- Third-party cookies are used to tell us how a visitor uses our website, for example, which pages they visit and how long they spend on them. This helps us better understand how people use our site and how they access it, which helps us create better campaigns.

Within the scope of the GDPR, the data processed by cookies for the above purposes is justified to protect our legitimate interests and those of third parties in accordance with art. 6 para. 1 sentence 1 letter f GDPR.
Most browsers accept cookies automatically. However, you can set your browser so that no cookies are stored on your computer or a message always appears before a new cookie is created. However, the complete deactivation of cookies may result in you not being able to use all the functions of our website.

‍3. USE OF DATA

 a. Legal basis for processing your information

‍We will only use your personal data where we are permitted to do so by law. Generally, we will use your personal data in the following circumstances:

- Where you have asked us to do so, or have given your consent for us to do so;
- Where we need to do so in order to perform a contract we have entered into with you;
- Where it is necessary for our legitimate interests (or those of a third party) and your fundamental rights do not override those interests;
- Where we need to comply with a legal or regulatory obligation.
- Marketing: you will receive marketing messages from us if you have given us your consent to do so. To unsubscribe from marketing emails at any time, you should contact us to let us know if you do not wish to receive any marketing materials from us at legal@xcapit.com.

Depending on how and why you provide us with your personal data, we may share it in the following ways:

- We may share your personal information with any member of our group, which means our subsidiaries, and our controller. 
- With selected third parties, including business partners, suppliers and subcontractors for the performance of any contracts we enter into with them or with you; or
- With analytics that assist us in improving the Site.

Your personal information may be disclosed to third parties in the following events:

- If we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets;
- If “Xcapit” or substantially all of its assets are acquired by a third party, in which case personal information held by us about our customers will be one of the transferred assets; or
- If we are under a duty to disclose or share your personal information in order to comply with any legal obligation or to protect the rights, property, or safety of our company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.     

  b. Links to Third Party Sites

‍The Site may contain links to and from the websites of our partner networks, advertisers and affiliates. The Site may also provide links to social networking websites. All third party websites are beyond our control and are not covered by this Privacy Policy. If you access third party sites using the links provided, the operators of those sites may collect information from you that they may use, in accordance with their own privacy policies. Please check these policies before you submit personal data to those third party sites. 

‍4. RETENTION PERIOD OF YOUR DATA 

‍We will retain your personal information in our systems, only for as short a period as is reasonably practicable, in order to provide you with the products and services you have requested, including for the purpose of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period where required to do so by law or to comply with applicable laws or regulations or with any competent state body, government agency or competent court in the event that we receive an order to do so, or if we reasonably believe that there is a prospect of litigation in respect of our relationship with you.You may ask us to delete your data: see “7. User's Right” below for more information.

‍5. SECURITY

‍Xcapit undertakes to adopt the necessary technical and organizational measures in accordance with the regulations in force in order to guarantee the security of personal data and to prevent the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or unauthorized communication or access to such data. Personal data will be treated as confidential by the data controller, who undertakes to inform and to ensure by means of a legal or contractual obligation that such confidentiality is respected by its employees, associates, and any person to whom it makes the information accessible. We have sufficient security measures for the protection, confidentiality and security of your personal data in order to restrict access to them to unauthorized persons. Also, our employees, and/or third parties involved in any phase of the processing of your personal data will keep confidentiality regarding them, an obligation that will subsist until after the end of the relationship between such persons.Xcapit responsibly guarantees the protection of your information. We have implemented appropriate physical, electronic and administrative security measures to prevent your personal data from being lost, used or altered, disclosed or accessed in an unauthorized manner,In this sense, all your data will be stored in a database owned by Xcapit which is registered in the National Registry of Personal Data Protection. To ensure the security of the personal data you provide to Xcapit, we will apply the same criteria and the same degree of diligence that Xcapit applies to safeguard its own information. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and are subject to a duty of confidentiality.We have implemented procedures to deal with any suspected personal data breaches and will notify you and any applicable regulator of a breach where we are legally obliged to do so.

‍6. INTERNATIONAL TRANSFER OF DATA

‍Please note that some of our service providers may be based outside of Argentina. These service providers may work for us or for some of our suppliers and may be involved in, among other things, fulfilling your request for information, products and services. When we transfer your data to a service provider, we seek to ensure that adequate safeguards are in place to ensure that your personal data is held securely and that your rights as a data subject are respected. Transfers of personal data are made:To a country recognized as providing an adequate level of protection;To a country that does not provide adequate protection, but whose transfer has been governed by contractual clauses that guarantee the implementation of other cross-border transfer solutions to provide adequate protection.By submitting your personal information, you agree to this transfer, storing or processing.Any of our suppliers or partners may be located outside Argentina, including in countries or international or supranational organizations that, under applicable law, do not provide adequate levels of protection for personal data, such as, among others, Brazil or the United States. Consequently, by accepting this Privacy Policy you expressly consent that your total Information, including your Personal Information, may be transferred internationally by Xcapit, including to countries or international or supranational organizations that do not provide adequate levels of protection for personal data, in accordance with the applicable legislation in force.You may at any time revoke your consent to the transmission to third parties of your Personal Information, as well as to the deletion of your data, by contacting us via e-mail at the address specified in section 8. Contact, of this policy.If you wish to obtain more information about the mechanism through which your Personal Information is transferred, please contact us by sending an e-mail to legal@xcapit.com.

‍7. USER RIGHTS

‍The User may exercise the rights of access, rectification, deletion, opposition, and, if applicable, limitation of processing and portability of data by sending an email to legal@xcapit.com.When communicating (through the corresponding channel informed in the present policy) to ask us to exercise your rights, we have the right to ask you to prove that you are who you say you are. We may ask you to provide copies of relevant identification documents to help us verify your identity.It will help us process your request if you clearly indicate what right you wish to exercise and, if applicable, why you are exercising it. The clearer and more specific you can be, the more quickly and efficiently we will be able to deal with your request. If you do not provide us with sufficient information, we may delay action on your request until you have provided us with additional information (and where this is the case, we will tell you).As a data subject, you have a number of rights in relation to your personal data. Below, we describe the various rights you have and how you can exercise them:

a. Right of access.

‍You may, at any time, request to obtain information about your Personal Data by consulting what data we hold about you.Please note that this entitles you to receive a copy of the Personal Data we hold about you so that you can check that it is correct and ensure that we are processing that Personal Data lawfully. It is not a right that allows you to request personal data about other people, nor is it a right to request specific documents from us that do not relate to your personal data. You may exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a subject access request. It is not necessary to complete a specific form to make this type of request.

b. Right to rectification and deletion. 

You may, at any time, request that we correct personal information we hold about you that you believe to be incorrect or inaccurate. Please note that we may ask you to verify any new information you provide to us and we may take our own steps to verify that the new information you have provided to us is correct.You may also ask us to delete personal data that we control if you no longer believe we should hold it (you may have heard this right described as the “right to be forgotten”). While we will do our best to honor your request and your personal data, it may not always be possible to delete all of your personal data, as there may be legal requirements to keep certain personal data or technical limitations on the data we can delete.You may exercise this right at any time by using the contact details detailed here and requesting that your personal data be rectified or deleted and on what basis you are requesting this. In the event that you would like us to replace inaccurate data with new data, you must tell us what that new data is. It is not necessary to complete a specific form to make this type of request, but you should do so by e-mail to the address specified in section 8. Contact, of this policy.

c. Right to restrict processing

‍If by processing your personal data on the basis of a legitimate interest you believe that your fundamental rights and freedoms are affected, or if you believe that those legitimate interests are not valid, you have the right to ask us to stop processing them by sending an email to the address specified in section 8.

d. Right to stop receiving notifications 

‍You may ask us to stop sending you various types of communications, advertisements, etc., via e-mail at the address specified in section 8. Contact us, of this policy.

e. Withdrawal of consent

‍Where we rely on your consent to process your personal data, you may withdraw your consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide you with certain products or services. If this is the case, we will notify you at the time you withdraw your consent.

‍8. CONTACT

‍If you have any questions regarding this Privacy Policy, if you wish to exercise any of your rights set forth above, or if you believe that the Privacy Policy has not been followed, please contact us by sending an e-mail to legal@xcapit.com. 

‍9. CHANGES TO THE PRIVACY POLICY

‍The App, the Site, the Services and our business may change from time to time. As a result, we may change this Privacy Policy at any time. When we do, we will post an updated version on this page, unless otherwise required by applicable law. By continuing to use the App, Sites or Services after we have posted an updated Privacy Policy, or have notified you if applicable, you accept the revised Privacy Policy and the practices described therein.