TELEDIPITY, SOCIEDAD ANÓNIMA PROMOTORA DE INVERSIÓN DE CAPITAL VARIABLE (hereafter, “TELEDIPITY”) AS A SOCIALLY RESPONSIBLE COMPANY AND RESPECTFUL OF PERSONAL DATA, PUTS AT YOUR DISPOSAL THIS PRIVACY NOTICE.
TELEDIPITY IS COMMITTED TO PROTECTING YOUR PRIVACY AND WILL NEVER SELL YOUR PERSONAL DATA TO A THIRD PARTY.
THIS DOCUMENT AIMS TO INFORM THE DATA OWNERS THE INFORMATION WE PROCESS AND ITS PURPOSES, AS WELL AS THE PROCEDURES TO EXERCISE THEIR RIGHTS OF ACCESS, RECTIFICATION, CANCELLATION, AND OBJECTION. TELEDIPITY AIMS TO GUARANTEE THE DATA OWNER’S RIGHT TO INFORMATIONAL SELF-DETERMINATION.
THIS PRIVACY NOTICE IS AVAILABLE TO THE DATA OWNER IN THE WEBSITE (https://www.teledipity.com) AND MOBILE APPLICATION, BOTH OPERATING UNDER THE NAME OF TELEDIPITY APP.
With the purpose of facilitating the interpretation of the present document, the terms used with an initial capital letter will have the meaning shown below, which will apply to such terms both in its singular and plural form.
Privacy Notice. – The full extent of the present document.
Application. – The application and website (https://www.teledipity.com) operating under the name TELEDIPITY APP.
Cookies. – Data files stored in the hard drive of the computer or electronic communications device of a user, when browsing in a website or a specific application. It allows exchanging status information between the site and the user’s browser. The status information may reveal means of session identification, authentication or user preferences, as well as any other data stored by the browser regarding the website or Application.
Content Creator. – Third parties that provide online courses for the Application and that receive the User’s email address after their subscription to their content.
Personal Data. – Any information concerning an identified or identifiable individual.
Academic and Employment Data. – Information related to users, such as their educational career, title, professional ID number, position, official address, official mail, among others.
Contact Data. – Information that allows to maintain or establish contact with its Data Owner, such as email address, cell phone number, among others.
Financial and Property Data. – Information related to assets, rights, charges or obligations susceptible of economic valuation, such as movable and immovable property; tax information; credit history; income and expenses; bank accounts; insurance; credit card number; Social Security number; salaries bonds; benefits.
Identification Data. – Information that allows to differentiate the Data Owner from others, such as name, marital status, Unique Population Registration Code (CURP), passport number, voter identification number, place and date of birth, nationality, photograph, address and age.
Numerology Data. – Any information that allows TELEDIPITY to perform a personality analysis of the User, such as aspirational or personality data.
Sensitive Personal Data. – Personal data touching on the most private areas of the Data Owner’s life, or whose misuse might lead to discrimination or involve a serious risk for said Data Owner. In particular, sensitive data is considered that which may reveal items such as racial or ethnic
origin, present and future health status, genetic information, religious, philosophical and moral beliefs, union membership, political views, sexual preference.
Social Media Data. – Information related to the user’s profile, interaction, activities and publications made by the Data Owner in various social network platforms accessible to the public.
Relationship Data. – Information related to a person, based on its personal, professional and commercial relationships.
ARCO Rights. – The rights of access, rectification, cancellation and objection that the Data Owner has, whose exercise is recognized and regulated in the Law, its Regulations and in this Privacy Notice. This concept shall also comprise the rights provided in the GDPR
Data Processor. – The individual or legal entity that, alone or jointly with others, processes personal data on behalf of the data controller.
Primary Purposes. – Primary purposes for which the Personal Data of the Owner is processed. They give origin to the relationship between TELEDIPITY and the Owner and are configured as strictly necessary for the maintenance thereof.
Secondary Purposes. – Purposes for which the Owner’s Personal Data is processed that are not strictly necessary for the maintenance of the relationship between TELEDIPITY and the Data Owner. The Owner’s Personal Data Processing for these purposes contributes to the fulfillment of the corporate purpose of TELEDIPITY.
Artificial Intelligence. – Scientific field of computer science that focuses on the creation of programs and mechanisms that can show behaviors considered intelligent.
Law. – The Mexican Federal Law on Protection of Personal Data held by Private Parties.
Regulation. – Regulations to the Federal Law on the Protection of Personal Data held by Private Parties.
Data Controller. – Individual or private legal entity that decides on the processing of personal data. Unless otherwise specified, TELEDIPITY, SOCIEDAD ANÓNIMA PROMOTORA DE INVERSIÓN DE CAPITAL VARIABLE (referred to in the present as TELEDIPITY), stands as Data Controller.
Data Owner. – The individual to whom personal data relates.
Transfer. – Any data communication made to a person other than the Data Controller or Data Processor.
Processing. – Retrieval, use, disclosure or storage of personal data by any means. Use covers any action of access, management, exploitation, transfer or disposal of personal data.
Users. – The individual who uses the TELEDIPITY APP, who, unless stated otherwise, must coincide with the Data Owner.
GDPR. – General Data Protection Regulation.
LGPD. – Lei Geral de Proteção de Dados (for users located in Brazil).
II. PERSONAL DATA CONTROLLER: IDENTITY AND ADDRESS.
The Data Controller is the legal identity named TELEDIPITY, SOCIEDAD ANÓNIMA PROMOTORA DE INVERSIÓN DE CAPITAL VARIABLE (herein, TELEDIPITY), who is committed to comply with the provisions of this Privacy Notice, as well as the Law, its Regulations and the Privacy Notice Guidelines.
TELEDIPITY’s address is Avenida Santa Fe number 481 (four hundred eighty-one), Floor 23 (twenty-three), Lomas de Santa Fe, Zip Code 05349 (zero five three four nine), Cuajimalpa de Morelos, Mexico City, Mexico. This address is required for everything regarding this Privacy Notice, for all obligations that may arise from the Law and its Regulations, as well as to receive all kinds of notifications.
III. PERSONAL DATA SUBJECT TO PROCESSING.
TELEDIPITY informs the Data Owners that the Personal Data stated below, in a categorized way, will be subject to Processing. Likewise, TELEDIPITY informs them that no Sensitive Personal Data will be subject to Processing.
III.I. Users Personal Data:
- Academic and Employment Data.
- Contact Data.
- Financial and Property Data.
- Identification Data.
- Numerology Data.
- Social Media Data.
In terms of 8 of the Law, the Data Owner consents TELEDIPITY to process his/her Personal Data, including those of a financial and property nature. The consent given by the Data Owner is limited only to the purposes described in this Privacy Notice.
The Data Owner undertakes that the information provided will be accurate, current and correct. Likewise, under the penalty of perjury, declares that he/she has authorization from the third parties whose Personal Data he/she transmits to TELEDIPITY. Because of the foregoing, agrees to indemnify and hold harmless TELEDIPITY from any claim or lawsuit derived from the provisions stated in the present paragraph.
TELEDIPITY will get Personal Data from the Data Owner through public access sources, to validate and update the Data Owner’s information. The foregoing, respecting at all times and in all cases, the reasonable expectation of privacy. Mainly, the kind of Data got from public access sources is Social Network Data. Through these sources, TELEDIPITY will validate, update and complement the other Personal Data listed in this section.
IV. PROCESSING PURPOSES.
The Processing of Personal Data carried out by TELEDIPITY aims to establish relationships within the framework of security, trust, and efficiency. The information will be used to fulfill the following purposes:
A. PRIMARY PROCESSING PURPOSES FOR USERS.
- Authenticate the identity of the Data Owners and open a file under their name in an internal and confidential database.
- Provide profiling services and recommendations related to spirituality, personal growth and numerology.
- Contact the Data Owners by any means to manage and monitor their requests for products or services.
- Provide recommendations for books, online courses, podcasts, and audiobooks.
- Membership processing, so that the User can request the Services.
- To feed the Artificial Intelligence database and algorithm to provide better recommendations and profiling services on aspects related to spirituality, personal development and numerology.
- Address requests for the exercise of ARCO Rights, revocation of consent and solve any doubt, complaint, clarification or suggestion regarding the protection of Personal Data.
- Contact the Data Owner to clarify and monitor payments.
- Contact the Data Owner to answer complaints, suggestions, and comments regarding the services contracted.
- Register and update the information of the Data Owner in TELEDIPITY’s systems for its conservation, identification, and consultation, as well as to comply with legal provisions and requirements from competent authorities.
B. SECONDARY PROCESSING PURPOSES FOR USERS.
- Generate a record in TELEDIPITY’s contact’s database.
- Contact the Data Owners for the purpose of notifying updates in the Application, reports on the Processing and status of their Personal Data, as well as changes in this Privacy Notice or in the Terms and Conditions of the Application.
- Evaluate the quality of TELEDIPITY’s support.
- Sending promotional and advertising information, as well as information on new services or products, invitations to events, courses or seminars, monthly newsletters, and information or news bulletins.
- Provide recommendations on businesses, products or services of third parties, which may be of the Data Owner’s interest.
- Use the Data Owner’s information for statistical purposes or internal analysis.
- TELEDIPITY may use the Data Owner’s information to: (a) improve browsing experience by personalizing the Websites and to improve the Subscription Service; (b) send information to the Data Owner which TELEDIPITY thinks may be of interest by email or other means; (c) send marketing communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest to the Data Owner, and (d) provide other companies with statistical information about TELEDIPITY’s Data Owners— but this information will not be used to identify any individual user.
- TELEDIPITY may contact the Data Owner on behalf of external business partners about a particular offering that may be of interest to them. In those cases, TELEDIPITY will not transfer the Data Owner’s unique Personal Information to the third party
TELEDIPITY will use the Data Owner’s information only in compliance with this Privacy Notice. Data Owners who subscribe to the TELEDIPITY Application are obligated through TELEDIPITY’s agreements with them to comply with this Privacy Notice.
TELEDIPITY will never sell the Personal Data of the Data Owner to any third party.
V. MECHANISMS SO THAT THE DATA OWNERS MAY REFUSE THE PROCESSING OF THEIR PERSONAL DATA FOR SECONDARY PURPOSES.
If the Data Owner does not want his Personal Data to be used for all or any of the Secondary Purposes in the previous section, the Data Owner must send an email to the address privacy[at]teledipity.com with the subject “Objection of Processing for Secondary Purposes.”
In the body of the email, the Data Owner must specify for what purposes he/she wishes to express his refusal, as well as his Identification Data so that his request is fulfilled.
VI. PERSONAL DATA TRANSFERS.
TELEDIPITY will carry out the following Transfers of the Owner’s Personal Data:
- TELEDIPITY transfers the Users’ email to the Content Creators of whom the Data Owner downloads content to allow the Content Creators to send promotional information regarding the products or services they offer.
- Likewise, TELEDIPITY will carry out the Transfers listed in article 37 of the Law, for which the Owner’s consent is unnecessary.
TELEDIPITY’s Transfers include:
|Third Party Receiver||Purpose||Consent|
|Administrative and/or judicial authorities.||Compliance with legal provisions. Compelled Disclosure: TELEDIPITY reserves the right to use or disclose the Data Owner’s Personal Data if required by law or if TELEDIPITY reasonably believes that use or disclosure is necessary to protect its rights or to comply with a law, court order, or legal process||Not necessary.|
|Content Creators.||Sending promotional information regarding the products or services offered.||Necessary.|
|Acquirer.||If TELEDIPITY or its assets are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information gathered by TELEDIPITY and the TELEDIPITY App.||Necessary, if given the case.|
Because transferring the User’s email to the Content Creators and Acquirers requires the User’s consent, under article 36 of the Law, by accepting this Privacy Notice, the User allows TELEDIPITY to transfer his/her email address to the Content Creators and/or Acquirers. The transfer to Content Creators has the purpose of the Data Owner being added to the emailing list of promotional information regarding products or services.
In case the User does not accept or wishes to oppose to the Transfer of their Personal Data, the User must use the mechanisms, provided in section V of the present Privacy Notice, so that he/she may refuse the Processing of Personal Data for Secondary Purposes.
VIII. THIRD PARTIES PERSONAL DATA TRANSFERS.
As part of the services offered by TELEDIPITY APP, the User will find the Compatibility Reports. For TELEDIPITY to be able to generate such reports, the User must provide data from third parties. It is important to mention that the User must have the third parties’ consent to Transfer their data to TELEDIPITY.
Consequently, the User declares, under oath, that the data that he/she will transfer to TELEDIPITY is real, updated, and accurate, and that, likewise, the third party consents the transfer.
IX. MEANS AND PROCEDURE FOR THE EXERCISE OF ARCO RIGHTS.
TELEDIPITY acknowledges the Data Owners’ ARCO Rights over their Personal Data, which consist on the following:
- Access Right: Knowing what Data Owner’s Personal Data is in TELEDIPITY’s possession and what are the purposes of their processing.
- Rectification Right: Request the correction of the Data Owner’s Personal Data in case they are inaccurate, outdated, erroneous or incomplete.
- Cancellation Right: Request for the elimination of any registration or copy, either physical or electronic, of the Data Owner’s Personal Data.
- Objection Right: Request to cease the use of the Data Owner’s Personal Data. This includes the right to request: (a) that Personal Data is not used to contact the Data Owners; (b) to have Personal Data removed from any solicitation list that TELEDIPITY uses, and (c) to opt-out of being solicited by TELEDIPITY or third parties.
These rights are exercised by means of a written request sent via email to the address privacy[at]teledipity.com with the subject “Exercise of ARCO Rights”. The aforementioned email address corresponds to the department that will process the requests and may be contacted by the Data Owners at any time.
In the body of the message, the Data Owner must provide the following information:
- Full name and address.
- A clear and precise description regarding the Personal Data over which the Data Owner intends to exercise any of the ARCO Rights, in addition to any document that allows its location.
- Mention of the ARCO Right that the Data Owner intends to exercise and the motivation to do so.
- The arguments that support the Data Owner’s position.
- If they request the Rectification of data, the Data Owners shall precise the modifications to be made and the documentation supporting the reason for the required changes.
In addition, the following documents must be attached to the application:
- To verify the Data Owner’s identity, the request must be sent from the same email address associated with the Data Owner’s account.
- Document that proves that the personal information is in possession of TELEDIPITY.
- In the event that the Data Owner does not personally submit the request, whoever does so must prove there are authorized to do so. This can be done through a public deed or power of attorney signed before two witnesses, along with official IDs of the Data Owner and its representative.
Once the Data Owner’s request has been received, TELEDIPITY will send an acknowledgment of receipt via email. Subsequently, TELEDIPITY will respond to the Data Owner’s request by email within 20 (twenty) business days, starting from the date in which it was received.
The Data Owner must consider that, to have sufficient elements to meet the request, TELEDIPITY may ask to the Data Owner to submit, within 5 (five) business days and at the address referred to in section II, original copies of the documents attached to the application or any additional information that helps to process the request. The Data Owner will have 10 (ten) days to fulfill this requirement. In this case, the term of 20 (twenty) days for TELEDIPITY to respond to the request will start on the following day on which the Data Owner fulfilled the requirement.
If the request is declared appropriate, and the Data Owner has accredited personality and the ownership of the ARCO Right that he/she intends to exercise, the Access to Personal Data, the requested changes, the Cancellation or the response to the Objection will be made within 15 (fifteen) business days counted from the date on which the request was answered.
For requests for Access to Personal Data, the delivery of information will proceed, after providing proof of identity of the applicant or their representative, accordingly. We shall make such delivery in single copies at the address mentioned in section II, or in electronic documents to the mailing address from which the request was sent.
In the event that the purpose of the request is the Objection, the Processing of Personal Data will cease on the following business day to the date in which the affirmative answer was notified to the Data Owner.
X. USE OF MECHANISMS IN REMOTE OR LOCAL MEANS OF ELECTRONIC, OPTICAL OR OTHER TECHNOLOGY COMMUNICATION, COLLECTION AND TRACE, AUTOMATIC AND SIMULTANEOUS, OF PERSONAL DATA.
Cookies are not used to run programs or deliver viruses to the Data Owner’s computer. Cookies are uniquely assigned to the Data Owner and can only be read by a Web server in the domain that issued the Cookie. One of the primary purposes of Cookies is to provide a convenience feature to save Data Owners time. The purpose of a Cookie is to tell the Web server that the Data Owner has returned to a specific page. For example, if the Data Owner personalizes pages in the Mobile Application, or purchases a specific product, a Cookie helps TELEDIPITY recall their specific information on subsequent visits. When the Data Owner returns to the same Website, the information they previously provided can be retrieved, so they can easily use the customized features.
Although most browsers accept Cookies automatically, the Data Owner can adjust its browser so that it does not allow them. To disable cookies, follow the instructions bellow:
- Internet Explorer: https://support.microsoft.com/es-mx/help/17442/windows-internet-explorer-delete-manage-cookies
- Firefox: https://support.mozilla.org/es/kb/habilitar-y-deshabilitar-cookies-sitios-web-rastrear-preferencias?e=es&redirectlocale=es&as=s&s=deshabilitar+cookies&r=0&redirectslug=Habilitar+y+deshabilitar+cookies
- Safari: https://www.apple.com/legal/privacy/es/cookies/
- Chrome: http://support.google.com/chrome/bin/answer.py?hl=es&answer=95647
If Data Owners choose to decline Cookies, they may not be able to fully experience the interactive features of the TELEDIPITY App, Products or Websites they visit. TELEDIPITY keeps track of the Websites and pages they visit within TELEDIPITY, in order to determine what portion of the TELEDIPITY App is the most popular or most used. This Data is used to deliver customized content and promotions within the Teledipity Application to customers whose behavior indicates that they are interested in a particular subject area.
Examples of Cookies TELEDIPITY uses:
- Session Cookies. We use Session Cookies to operate our Service.
- Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
- Security Cookies. We use Security Cookies for security purposes.
- Advertising Cookies. Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.
i. IP Address: Such Personal Data will be processed solely for network traffic analysis, data analysis for the improvement of the system, for authentication and prevention against identity theft or data security breach, as well as for authenticating or to identify users or third parties that use the Application. We will make no transfer of such Personal Data to third parties outside TELEDIPITY.
ii. Log Files: TELEDIPITY may collect demographic information, such as ZIP code, age, gender, preferences, interests and favorites using log files that are not associated with the Data Owner’s name or other personally identifying information. There is also information about the Data Owner’s computer hardware and software that is automatically collected by the TELEDIPITY App. This information can include IP address, browser type, domain names, access times and referring website addresses. This information is used by TELEDIPITY for the operation of the TELEDIPITY Application, to maintain quality, and to provide general statistics regarding use of the TELEDIPITY App. For these purposes, we do link this automatically collected data to Personal Data such as name, email address, address, and phone number.
TELEDIPITY may employ third party companies and individuals to facilitate the Application services, to provide the services on TELEDIPITY’s behalf, to perform Service-related tasks or to assist TELEDIPITY in analyzing how the Service is used.
These third parties have access to Personal Data only to perform these tasks on TELEDIPITY’s behalf and are obligated not to disclose or use it for any other purpose:
i. Analytics: TELEDIPITY may use third-party Service Providers to monitor and analyze the use of the TELEDIPITY App.
- Amplitude is an application and web analytics service for recording the User interactions with the TELEDIPITY APP, which helps TELEDIPITY deliver a better user experience. For more information on the privacy practices of Amplitude, please visit https://amplitude.com/privacy
iii. Advertising: TELEDIPITY may use third-party Service Providers to show advertisements to you to help support and maintain the TELEDIPITY App.
- Facebook remarketing service is provided by Facebook Inc. You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950 . To opt-out from Facebook’s interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217 . Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA , the Digital Advertising Alliance of Canada or the European Interactive Digital Advertising Alliance in Europe, or opt-out using your mobile device settings. For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation
v. Payments: TELEDIPITY may provide paid products and/or services within the TELEDIPITY APP. In that case, TELEDIPITY uses third-party services for payment processing (e.g. payment processors).
The payment processors TELEDIPITY works with are:
- Gumtree – Their Privacy Notice can be viewed at https://www.gumtree.com/privacy_policy
vi. Social Media Features: The TELEDIPITY App includes Social Media Features, such as the Facebook Like button and Widgets, the Share This button or interactive mini programs. These features may collect the Data Owner’s IP address, page visit information, and may install a Cookie to enable the features to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on the TELEDIPITY Application. This Privacy Notice does not apply to these features. The Data Owners’ interactions with these features are governed by the Privacy Notices and other policies of the companies providing them.
vii. External Websites: TELEDIPITY sometimes provides links to other websites. TELEDIPITY does not control, and is not responsible for, the content or practices of these other websites. TELEDIPITY’s provision of such links does not constitute an endorsement of these other websites, their content, their owners, or their practices. This Privacy Notice does not apply to these other websites, which are subject to any privacy and other policies they may have.
viii. Public Forums: TELEDIPITY offers publicly accessible message boards, blogs, and community forums. The Data Owner should keep in mind that if they directly disclose any information through those public message boards, blogs, or forums, this information may be collected and used by others. TELEDIPITY will correct or delete any information you have posted on the TELEDIPITY APP if the Data Owner makes a request, as described in “MEANS AND PROCEDURES FOR THE REVOCATION OF CONSENT” below.
ix. “Do Not Track” Signals: TELEDIPITY does not support Do Not Track (“DNT”). Do Not Track is a preference Data Owners can set in your web browser to inform websites that you do not want to be tracked. Data Owners can enable or disable Do Not Track by visiting the Preferences or Settings page of their web browser.
x. Clear Gifs (Web Beacons/Web Bugs): TELEDIPITY employs a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that help us better manage the TELEDIPITY APP by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a Data Owner’s computer hard drive, clear gifs are embedded invisibly on Web pages or in emails and are about the size of the period at the end of this sentence. TELEDIPITY uses clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows TELEDIPITY to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. TELEDIPITY ties the information gathered by clear gifs in emails to our customers’ Personal Data. If you would like to opt-out of these emails, please see “MEANS AND PROCEDURES FOR THE REVOCATION OF CONSENT”.
XI. MEANS AND PROCEDURES FOR THE SECURITY OF PERSONAL DATA
TELEDIPITY uses a variety of security technologies and procedures to help protect Personal Data from unauthorized access, use or disclosure. TELEDIPITY secures the Personal Data provided by the Data Owner on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure.
The security of the Data Owner’s Personal Data is important to TELEDIPITY, but the Data Owner must keep in mind that no method of transmission over the Internet, or method of electronic storage is 100% secure. While TELEDIPITY strives to use commercially acceptable means to protect the Personal Data of all Data Owners, we cannot guarantee its absolute security.
XII. MEANS AND PROCEDURES FOR THE REVOCATION OF CONSENT.
At any time and for any reason, the Data Owner may revoke the authorization given to TELEDIPITY for the Processing of his Personal Data. TELEDIPITY states that, for the fulfillment of specific purposes, the revocation of consent could mean the impossibility of continuing the relationship between both parties.
In this case, the revocation of the consent will be carried out under the following procedure:
- Sending an email to the address privacy[at]teledipity.com with the subject “Revocation of Consent.”
- In the message’s body the following should be noted:
- Data Owner’s full name.
- The reason for the request.
- To verify the Data Owner’s identity, the request must be sent from the same email address associated with the Data Owner’s account.
TELEDIPITY will respond to the Data Owner’s request by email within 10 (ten) business days from the date in which we received it. The Data Owner must consider that, to have sufficient elements to meet the request, TELEDIPITY may ask the Data Owner to submit, within 5 (five) business days and at the address referred to in section II, other information that helps to process the application. The Data Owner will have 10 (ten) days to fulfill TELEDIPITY’s request. In this case, the term of 10 (ten) days for TELEDIPITY to respond to the request will start on the day following that in which the Data Owner fulfilled the requirement.
XIII. RESPONSIBLE FOR PROCESSING ARCO RIGHTS APPLICATIONS, LIMITATION OF USE AND DISCLOSURE, AS WELL AS REVOCATIONS
If the Data Owners wish to revoke their consent, limit the use and disclosure of their personal information, as well as Access, Rectify, Cancel or Object the Processing of their Personal Data, they must do so through the Department designated by TELEDIPITY, whose contact information is listed below:
(i) Responsible: TELEDIPITY’S DATA PROTECTION DEPARTMENT.
(ii) Email address: privacy[at]teledipity.com
(iii) Phone number: 5047 7500 ext. 2110
XIV. MEANS TO LIMIT THE USE OR DISCLOSURE OF PERSONAL DATA.
TELEDIPITY commits to execute legal acts, adopt privacy, Personal Data protection and information security policies, as well as to implement security measures to guarantee the protection of the Data Owner’s Personal Data.
TELEDIPITY stores personal information in databases with limited access, in controlled facilities with security mechanisms. TELEDIPITY commits to ensure that the information provided by the Data Owner is considered and processed confidentially.
TELEDIPITY provides alternative mechanisms to the exercise of ARCO Rights so that the Data Owners limit the use and disclosure of their Personal Data. In this sense, to avoid receiving publicity, the Data Owner can register in the Public Registry to Avoid Publicity (REPEP) of the Federal Consumer Attorney’s Office (PROFECO), in the link https://repep.profeco.gob.mx.
Data Owners may unsubscribe from TELEDIPITY marketing communications by clicking on the “unsubscribe” link located on the bottom of our e-mails, by replying with the word “STOP” to any of our text messages, or by emailing a request to privacy[at]teledipity.com. Customers cannot opt-out of receiving transactional emails related to their account with TELEDIPITY.
TELEDIPITY will not use the TELEDIPITY App to send unsolicited commercial email from third parties or include any content in violation of applicable laws. Every email sent from the TELEDIPITY App will include an easy to read “opt-out” mechanism and other required information.
The TELEDIPITY App will, from time to time, include commercial email related exclusively to TELEDIPITY products and services, as well as recommended books and online courses from third parties TELEDIPITY deems relevant to the Data Owner’s profile and needs.
In case the Data Owner wishes to know more about this section, he/she may send an email to the address privacy[at]teledipity.com with the subject “Limitation of Use or Disclosure,” expressing doubts, comments, and suggestions regarding his/her purpose.
XV. PERSONAL DATA STORAGE PERIOD.
In compliance with the quality principle, TELEDIPITY will safeguard all the Personal Data of the Data Owner for the necessary and adequate time to fulfill the purposes for which TELEDIPITY collected them. Subsequently, TELEDIPITY will apply a blocking period prior to the cancellation of Personal Data.
XVI. INFORMATION FOR USERS RESIDING IN BRAZIL
This part of the document integrates with and supplements the information contained in the rest of the Privacy Notice and is provided by TELEDIPITY and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
This part of the document uses the term “personal information“ as it is defined in the Lei Geral de Proteção de Dados (LGPD).
The grounds on which we process your personal information:
We can process your personal information solely if we have a legal basis for such processing.
Legal bases are as follows:
- Your consent to the relevant processing activities;
- Compliance with a legal or regulatory obligation that lies with us;
- The carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments;
- Studies conducted by research entities, preferably carried out on anonymized personal information;
- The carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract;
- The exercising of our rights in judicial, administrative or arbitration procedures;
- Protection or physical safety of yourself or a third party;
- The protection of health – in procedures carried out by health entities or professionals;
- Our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; and
- Credit protection.
To find out more about the legal bases, you can contact us at any time using the contact details provided in this document.
Your Brazilian privacy rights, how to file a request and our response to your requests.
Your Brazilian privacy rights:
You have the right to:
- Obtain confirmation of the existence of processing activities on your personal information;
- Access to your personal information;
- Have incomplete, inaccurate or outdated personal information rectified;
- Obtain the anonymization, blocking or elimination of your unnecessary or excessive personal information, or of information that is not being processed in compliance with the LGPD;
- Obtain information on the possibility to provide or deny your consent and the consequences thereof;
- Obtain information about the third parties with whom we share your personal information;
- Obtain, upon your express request, the portability of your personal information (except for anonymized information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded;
- Obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in art. 16 of the LGPD apply;
- Revoke your consent at any time;
- Lodge a complaint related to your personal information with the ANPD (the National Data Protection Authority) or with consumer protection bodies;
- Oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law;
- Request clear and adequate information regarding the criteria and procedures used for an automated decision; and
- Request the review of decisions made solely on the basis of the automated processing of your personal information, which affect your interests. These include decisions to define your personal, professional, consumer and credit profile, or aspects of your personality.
You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights.
How to file your request:
You can file your express request to exercise your rights free from any charge, at any time, by sending an email to privacy[at]teledipity.com with details of your request or via your legal representative.
How and when we will respond to your request:
We will strive to promptly respond to your requests. In any case, should it be impossible for us to do so, we’ll make sure to communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your requests, if we are in the position to do so.
In the event that you file an access or personal information processing confirmation request, please make sure that you specify whether you’d like your personal information to be delivered in electronic or printed form.
You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead. In the latter case, we’ll respond within 15 days from the time of your request, providing you with all the information on the origin of your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.
In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request – except in cases where such communication is proven impossible or involves a disproportionate effort on our side.
Transfer of personal information outside of Brazil permitted by the law:
We are allowed to transfer your personal information outside of the Brazilian territory in the following cases:
- When the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution bodies, according to the legal means provided by the international law;
- When the transfer is necessary to protect your life or physical security or those of a third party;
- When the transfer is authorized by the ANPD;
- When the transfer results from a commitment undertaken in an international cooperation agreement;
- When the transfer is necessary for the execution of a public policy or legal attribution of public service;
- When the transfer is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitration procedures.
XVII. MODIFICATIONS TO THE PRIVACY NOTICE.
TELEDIPITY informs the Data Owner that we may change this Privacy Notice at any time and manner, always taking into account the legislation in this matter.
TELEDIPITY informs the Data Owners that any changes to the Privacy Notice will be notified through the publication of an informative message and its updated version on the App and/or by sending an email to the address that the Data Owner has provided.
XVIII. DATE OF LAST UPDATE.
September 28, 2020.