Personal

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Last update: March 29, 2023

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PAGUELOFACIL may share the data of the users ("Users") who register in the app ("Platform") and of the persons who contact PAGUELOFACIL through the forms present in its Platform with each of the subsidiaries and companies of the group for the purpose of offering the services requested by the Users through the Platform.

This privacy policy provides information regarding the processing of personal data of our Users, Users of social networks that interact with us and users of the contact form of our Platform, in accordance with the provisions of the General Data Protection Regulation ("GDPR") and Law 81 of 26 March 2019 of the Republic of Panama on the Protection of Personal Data.

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We (and persons acting on our behalf) are committed to protecting and respecting your privacy. Please consider the following:

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We will keep your information secure and private at all times.
We will never give out your information.

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1. Processing of data of Users and persons contacting PAGUELOFACIL

1.1 Data processed

a) Information that Users provide directly to us:

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Registration Data: the information that the User provides when creating an account on the PAGUELOFACIL Platform: User's name and surname, telephone number, e-mail and address.
User Profile Information: the information that the User adds to the Platform in order to be able to use PAGUELOFACIL's services, i.e., the User's cell phone number, delivery address, name of the Merchant, among others. The User can view and edit the personal data of his/her profile whenever he/she deems appropriate. PAGUELOFACIL may store the User's credit or debit card information, in order to facilitate the payment process between users, merchants and services. For this purpose, PAGUELOFACIL has all the certifications required by international security standards, such as PCI. The user can request the elimination of their data at the moment they consider it pertinent.
Additional information that the User wants to share: information that the User may provide to PAGUELOFACIL for other purposes. For example, a photograph of yourself or billing address, if you request to receive invoices from PAGUELOFACIL.
Information about communications with PAGUELOFACIL: PAGUELOFACIL will have access to information provided by Users to resolve doubts or complaints about the use of the platform, either through the contact form, by e-mail or by telephone through the customer service department.
Biometric data to validate your identity when the USER wants to review the data of his/her PAGUELOFACIL digital card, block or unblock the card and change the PIN of the physical card.
USER's bank account information when he/she wants the funds stored in PAGUELOFACIL to be sent to a bank account added by the USER himself/herself. This bank account can be deleted within the application if the USER so desires. The USER is free not to add bank account numbers.
Personal data such as place of work, salary range, residence address, as long as the USER chooses, to apply for their PAGUELOFACIL CARDS. It is part of our "Know Your Customer" (KYC) process. This data is shared to our card issuer provider, for their "Know Your Customer" procedure and to deliver the PAGUELOFACIL CARD to the corresponding user.

Transcription and recording of the conversations held by the USER with PAGUELOFACIL for the processing of incidents, doubts or other queries that may be made.
Information on communications between Users and Merchants: PAGUELOFACIL will have access to the communications that Users make with the Merchants that collaborate with the Platform through the chat provided on the Platform.

b) Information provided to us indirectly by Users:

Data derived from the use of the Platform: PAGUELOFACIL collects data derived from the Use of the Platform by the User each time the User interacts with the Platform.

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Internal identification data or user ID. This ID is created when the USER registers within PAGUELOFACIL. This data is only used for internal control. For the user is an unknown data and can not choose whether it is collected or not because it is created automatically when the user registers within the application.

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The purpose of creating a user ID is only for internal control of PAGUELOFACIL collaborators.

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Application and device data: PAGUELOFACIL stores the device and Application data that the User uses to access the services. These are:

Internet IP address used by the User to connect to the Internet with his computer or mobile phone.
Information about your computer or mobile device, such as your Internet connection, browser type, version and operating system, device type and device ID.
User's account data: information on payments or collections made by the User and the User's identifier within our system.

The User's browsing history and preferences while on the Platform.
Data derived from the User's origin: if the User arrives at the PAGUELOFACIL Platform through an external source (such as a link from another website or a social network), PAGUELOFACIL collects the data from the source from which the PAGUELOFACIL User came.

Data derived from the management of incidents: if the User addresses the PAGUELOFACIL Platform through the Contact Form, PAGUELOFACIL will collect the messages received in the format used by the User and may use and store them to manage present or future incidents.

Data derived from "cookies": PAGUELOFACIL uses its own and third-party cookies to facilitate browsing for its users and for statistical purposes.

Data derived from external third parties: PAGUELOFACIL may collect information or personal data from external third parties only if the User authorises these third parties to share the aforementioned information with PAGUELOFACIL. For example, in the event that the User creates an account through Facebook, Facebook could give us personal data of the User in the event that he/she has them in his/her Facebook profile (name, gender, age...).

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-Other Data derived from external third parties for the purpose of analyzing behavior, number of clicks, blocking points and other data for continuous improvement of the user experience.

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-PAGUELOFACIL collects diagnostic, failure and performance data from third party providers. We will in no way support sensitive data such as credit card information, banking information, residence address and gender. The purpose of collecting this data is solely for the continuous improvement of the application. This data is collected in real time.

Similarly, if the user accesses PAGUELOFACIL through the products and services offered by Google, the latter may send the user's browsing data to PAGUELOFACIL, with access to the platform through the links created by Google. The information provided by the external third party may be controlled by the user in accordance with the external third party's own privacy policy.

Geolocation Data: provided that Users authorise it, PAGUELOFACIL will collect data related to their location, including the real-time geographic location of the User's mobile device at the time they use the Platform.

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c) Information that Users provide to us indirectly:

-Data on Telephone Contacts: as long as the USERS authorize it, PAGUELOFACIL will read the data of the user's contact list with the only purpose of showing who of their contacts have an account in PagueloFacil, under no circumstances this data is stored or shared with third parties in real time of the USER's mobile device at the moment he/she uses the Application. The USER is in total freedom to deactivate the option in his device that PAGUELOFACIL has access to his contact list. The USER is also free to choose not to share this information.

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2. Purpose

The following are some of the objectives of use within the PAGUELOFACIL Platform:

2.1. Using the PAGUELOFACIL Platform: PAGUELOFACIL uses the data it collects from Users so that they can access and communicate with the PAGUELOFACIL platform, and to provide the services they request through their account in the PAGUELOFACIL application, according to the mechanism described in the "Terms and Conditions".

2.2 . Sending communications: PAGUELOFACIL uses Users' data to send communications via e-mail and/or SMS to the User about the operation of the service.

PAGUELOFACIL may send messages to the USER's cell phone with information related to notifications of actions performed within the application. The USER is free to deactivate this type of notifications from his/her mobile device where the PAGUELOFACIL application is downloaded.

2.3. To detect and investigate fraud and possible crimes: PAGUELOFACIL also uses the information to investigate and analyze how to improve the services it provides to Users, as well as to develop and improve the features of the service it offers. Internally, PAGUELOFACIL uses the information for statistical purposes in order to analyse User behaviour and trends, to understand how Users use the PAGUELOFACIL Platform, and to manage
and improve the services offered, including the possibility of adding new features to the Platform.

PAGUELOFACIL will be able to control all actions that could result in fraud or the commission of any crime related to the payment elements used by the users, PAGUELOFACIL may ask the user for a copy of their identification, as well as certain information about the bank card used for the order request. All data will be, in any case, treated by PAGUELOFACIL with the sole purpose of fulfilling the functions of surveillance and fraud prevention and will be stored as long as the relationship with the user remains in force, as well as in the subsequent period as long as the user's right to present claims or legal actions related to the payment of the products or services requested through PAGUELOFACIL does not expire. The data relating to the credit card used will be kept for the duration of the resolution of the incident and for the following 120 days from the date of resolution. In the event that irregularities are detected in the use of the credit card that could be considered illegal activities, PAGUELOFACIL reserves the right to keep the data provided, and may share it with the competent authorities in order to investigate the case. PAGUELOFACIL may share the data with the authorities based on the legal obligation to prosecute conduct contrary to the applicable regulations.

2.4. To guarantee security and a suitable environment for the safe provision of services: PAGUELOFACIL may use the data for the purpose of ensuring the proper use of the products and services requested on its Platform.
2.5. To comply with the regulations, defence and filing of actions: PAGUELOFACIL informs the user that the conversations carried out through the chat for communication with the Commerce may be reviewed and used by PAGUELOFACIL for the interposition and/or defence of claims and/or necessary legal actions, as well as for the management of incidences in the orders.
2.6. Promotion and commercial offers (online and offline): PAGUELOFACIL uses third-party technology integrated into its Platform to collect your data and preferences and use them with CRM systems and advanced technology for the benefit of Users. Thus, by means of the information collected, the following processing of your data will be carried out:

PAGUELOFACIL, may send by e-mail promotional messages and/or offers related to the service it offers and which may be of interest to the User. PAGUELOFACIL may measure and personalize such advertising according to the preferences of PAGUELOFACIL Users. If the PAGUELOFACIL User does not wish to receive the aforementioned information and/or commercial communications, he/she may opt out at any time to
the option to "Unsubscribe" in the e-mail itself, and consequently, PAGUELOFACIL will immediately cease sending the aforementioned information.
PAGUELOFACIL may also send the User messages and/or offers related to said services by means of "push" notifications consisting of the sending of said promotional messages and/or offers to the User's mobile phone. If the PAGUELOFACIL User does not wish to receive the commercial communications of the present point and the previous 2.1., the User will be able to eliminate them jointly by deactivating their privacy preferences in their profile with a single click.
By using the PAGUELOFACIL Platform, Users may also receive commercial communications from third parties associated with the Platform such as Facebook and Google, all depending on the privacy preferences that the User has in said Platforms.
Users may use their privacy management centre to unsubscribe from online marketing services or cancel their account if they do not agree to receive samples along with PAGUELOFACIL orders.

2.7 . Statistical purposes and analysis of services: PAGUELOFACIL uses the information for statistical purposes in order to analyse User behaviour and trends, to understand how Users use the PAGUELOFACIL Platform, and to manage and improve the services offered, including the possibility of adding new features to the Platform.

PAGUELOFACIL also uses the information to research and analyze how to improve the services it provides to Users, as well as to develop and improve the features of the service it offers. PAGUELOFACIL does not collect data from other applications to improve their performance.

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2.8. SMS messages or e-mails shall be used only for the following purposes:

Exchange of messages between users and PAGUELOFACIL staff.
Phone number validation
E-mail validation
Sending of promotional messages from PAGUELOFACIL to the user.
If the user has performed an action within a merchant affiliated to PAGUELOFACIL, the merchant will display the e-mail address of the person who performed the action.

2.9. Data directly provided by the USER such as credit or debit cards and bank account numbers will not be shared with third parties including PAGUELOFACIL collaborators for any reason. Credit or debit card data is stored within the application in a "tokenized" form to improve the user experience and make any future action easier. The USER is free to decide whether or not to store his/her credit or debit card data within the application. The USER is free to request the PAGUELOFACIL team to remove credit card, debit card and bank account information if he/she so desires.

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3. Legal basis for processing

The processing of Users' data is carried out on the following legal bases:

Executing the contractual relationship once you have registered on the Platform and accepted the Terms and Conditions (e.g. processing your data to deliver a requested order).
On the basis of our legitimate interest (e.g. to carry out checks to prevent fraud through the Platform).
Fulfilling legal obligations (for example, when competent authorities request data in the framework of judicial investigations and/or the filing of actions necessary to protect the interests of PAGUELOFACIL.
Explicit consent for the communication of user data to third parties for the purpose of commercial communications.

4. Recipients of the data

PAGUELOFACIL guarantees that all trades, technicians, suppliers, or independent third parties are bound by contractually binding promises to process information that is shared with them in accordance with PAGUELOFACIL's instructions, this Privacy Policy, as well as applicable data protection legislation. We will not transfer your personal data to any third party not subject to our instructions and no communication will include selling, renting, sharing or otherwise disclosing personal customer information for commercial purposes in a manner contrary to the commitments made in this Privacy Policy.

4.1. During the execution of an order data may be shared with:

The Merchant, who executes the mandate to collect payment for a product or service. In the event that the User contacts the Merchants directly and provides their data directly to them, PAGUELOFACIL will not be responsible for the use made by the suppliers.
By the Customer Care services contracted by PAGUELOFACIL for the purpose of warning the User about possible incidents or requesting the reason for a negative evaluation of the service. PAGUELOFACIL will be able to use the data provided for the purpose of managing incidents that may occur in the provision of services.
The Platform so that the amount can be debited from your account.
By telecommunications service providers, when they are used to send communications on orders or incidents related to these services
Providers offering satisfaction survey services carried out by PAGUELOFACIL.

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5. User rights

You have the right to be informed about how we use your personal information.

We provide this privacy notice to explain how we use your personal information.

2. You can ask to see the personal information we hold about you (this is making a personal data access request).

We offer you a copy of the personal information we keep about you. This right is subject to exceptions. For example, we can only provide you with information that is required and permitted by law, and we cannot provide you with personal information about other people.

3. You may ask us to correct your personal information if you believe it is incorrect.

We may correct incomplete or inaccurate information. Before updating your file, we may need to verify the accuracy of new information you have provided to us.

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4. You can ask us to delete your personal information.

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You may ask us to delete your personal information if:

There is no good reason for us to continue using it.
You gave us your consent to use the information and have now withdrawn that consent.
He has objected to our using the information
We are required by law to delete the information.

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5. You may object to us processing your personal information for marketing purposes.

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6. You can object to us processing your information

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7. You may ask us to transfer your personal information.

If we can, and if regulatory requirements permit, we will provide your personal information in a structured, commonly used, computer-language format.

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If the user wishes to review, modify or delete his/her data from the PAGUELOFACIL app, he/she can contact us by e-mail at info@paguelofacil.com.

Business

I. General

This document is an integral part of the Terms and Conditions of PagueloFacil. The user gives his consent from the moment of registration on the website, to use his information in accordance with these policies.

PagueloFacil has always considered the processing of personal data to be a very valuable privilege, and is concerned to ensure that this information is properly protected, respecting the principles of honesty, legality and transparency and, on 25 May 2018, the EU Regulation 2016/679 on the processing of personal data and the free movement of such data (General Data Protection Regulation, "GDPR") will be directly applicable in all Member States of the European Union.

The business model of PagueloFacil requires that information about the Users is collected and revealed in some assumptions. PagueloFacil recognizes that the privacy of the information of its Users is very important and by virtue of it, precautions are taken for the safeguard of the information through effective computer security systems.

This section explains in detail what PagueloFacil can do with this information so that the user is aware of these circumstances beforehand.

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II. On the information that is collected

The User can enjoy the services of PagueloFacil being a Registered User, for it, the User will have to provide the personal and financial data, in a complete and exact way, that are detailed in the section "Personal Information". The information that can be required and stored is: full name, user pseudonym to identify yourself in the website, address, date of birth, email, telephone, credit or debit card number, address where the account statement arrives, expiry date of the card, type of card, among others.

PagueloFacil keeps the faculty to confirm the personal data provided through public entities or specialized companies, for which, the User expressly authorizes PagueloFacil to confirm the information deemed necessary. The obtained information will be treated confidentially.

The processing of Data for each of the above-mentioned purposes may be carried out in paper, automated or electronic form, and in particular by ordinary mail or e-mail, telephone (e.g. automated calls, SMS), fax and any other IT channel (e.g. websites, mobile applications).

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Personal Key

Duly registered Users will have a Personal Password which will be used by the User to pay and request funds among other activities. The User shall keep the password confidential and shall not share it with other persons. In addition, the User shall be responsible for all actions requiring the use of his/her Personal Password, which implies that he/she shall be responsible for paying all fees accrued as a result of the use of that Personal Password.

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III. Confidentiality of information

PagueloFacil will take the measures that are within its reach to protect the privacy of the information of the Users. Therefore, PagueloFacil will not share the Personal Information either in an onerous or free way, with the exception of the ways established in the present document. Besides, the User authorizes PagueloFacil to give total or partially Personal Information to the controlled, controlling or linked companies with PagueloFacil.

In a particular way, in relation to Commerce, PagueloFacil handles in a confidential way the information of the Buyer User of the Commerce, so that the Commerce only knows the necessary information of the buyer and not the relevant data to the financial or economic information of the Buyer User.

In case of judicial orders or of any public authority in which PagueloFacil is forced to deliver information, PagueloFacil is not responsible for this information. Also, in case that third parties get access to some information in an illegitimate way, PagueloFacil is not responsible for the use of the information.

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IV. Security and storage of information

PagueloFacil considers that the information of its Users is an asset that must be protected from any loss or undue access. Therefore, several security techniques are used to protect such data from unauthorized access by users from inside or outside the company. PagueloFacil is obliged to comply with all the applicable regulation in the matter of security measures applicable to the Personal Information to reduce this risk. PagueloFacil has an Extended Validation SSL certificate, a PCI DSS certificate and GDPR (General Data Protection Regulation) compliance.

Despite the above, it is necessary to take into account that perfect security does not exist on the Internet, therefore, PagueloFacil is not responsible for illegitimate appropriations and violation of its systems or databases by unauthorised persons and the respective use of such information.

All the personal data of the Users will be stored in an automated file of personal data that resides in Panama. The User when registering in PagueloFacil confirms that he is informed of the residence of this file and authorizes this international transfer of his data, in the cases in which his country of domicile is different from the one of the residence of the file.

It applies to the processing of personal data wholly or partly by automatic means, as well as to the processing otherwise than by automatic means of personal data contained in or intended to be contained in a filing system.

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V. How does PagueloFacil use the information?

The collection of information allows us to provide Users with the most convenient features and services and to customise services for the benefit of Users. The Personal Information collected is used for the following purposes:

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Disclose information to acquiring banks and credit card associations of purchase behaviour and card-related account profiles in order to eliminate fraud and illicit behaviour.
To develop commercial and advertising initiatives for offers, content and services through the analysis of visited web pages and User searches in order to improve their presentation.
Send information about new services, news about PagueloFacil and publicity about products or services of interest to the user. By this means the User expressly authorizes PagueloFacil to send information regarding its services; however, the User can request not to be included in the lists to send this information, to do so in the section "Change of notification preferences" shown in clause VII.
Share Personal Information with service providers or outsourcing companies such as transportation services, media or intermediaries in the management of payments, insurance, call centers, loyalty programs among others in order to improve or facilitate services and operations. PagueloFacil will take care that certain standards are met through the signing of agreements of privacy of the User's information, especially the EU Regulation 2016/679 (GDPR). However, PagueloFacil is not responsible for the improper use of the information that these providers make. In some occasions, the providers will collect the information directly from the Users and in these cases, the User may receive a notification about this activity, and it will be at the User's discretion the information that he/she wants to provide and the uses that will be made of it. In case the User provides additional information, under his own initiative, the providers will use such information according to their own policies, therefore, PagueloFacil is not responsible for such use. If it is decided to disclose information to third parties different to the providers to which reference is made, the consent of the user will be required.
In case of disputes between the Users and PagueloFacil, the latter will be able to provide Personal Information to entities such as insurance companies, arbitration courts or any competent court. If it is not possible to provide the information simultaneously, and as far as it is not possible, the information will be provided gradually without undue delay.

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VI. Legal Requirements

PagueloFacil will cooperate with the judicial or administrative authorities to guarantee the faithful fulfillment to the law and with the purpose of safeguarding the integrity and security of the society and its Users. Therefore, PagueloFacil will be able to provide Personal Information of its Users at the request of any authority for the effects of its investigations in cases such as: protection of industrial and intellectual property rights, fraud prevention and other matters, and for its part, the User authorizes PagueloFacil Comercios to provide the information that at its discretion considers pertinent for the faithful fulfillment of the law.

PagueloFacil according to its discretion and when it considers necessary to consider that the activity of a User is suspicious or there are indications that he/she tries to commit a crime or harm a person, it will be able to provide Personal Information of a User to other Users or third parties to enforce the Terms and Conditions of PagueloFacil and other Policies of the site and with the purpose of cooperating with the execution and fulfillment of the law. This power will be exercised by PagueloFacil regardless of whether or not there is a judicial or administrative order to that effect.

VII. Change in notification preferences

If the User does not want to receive e-mails containing advertising, promotions or news by PagueloFacil can change your notification preferences by making a request to info@paguelofacil.com. In this section the User will be able to comment his preferences to be taken into account by PagueloFacil in the promotions, advertisements and news.

VIII. Rights of access, rectification and deletion of personal information

The User has the right to access, rectify and cancel his/her Personal Information. On the other hand, he/she is obliged and responsible for the truthfulness, accuracy and validity of the information he/she provides and is obliged to keep it updated. Once registered in PagueloFacil, the user will be able to review and modify the information that has been sent such as:

The e-mail address, however, for security purposes, PagueloFacil will retain the above information.
The information provided in the registration such as: company, address, postal code, country, telephone number, fax number, e-mail and others.
The Personal Security Key.

The purpose of retaining some information that the User has requested to be removed is for use in cases of disputes or complaints or for problem detection and resolution. In addition, for security, technical and legal reasons, the User should not expect that his or her Personal Information will be permanently and automatically deleted from the databases. The consent referred to in points 1), 2), and 3) above is optional. The lack of such consent will make it impossible for PagueloFacil to carry out the aforementioned activities.

PagueloFacil will be able to modify at any moment the terms and conditions of these Information Reservation Policies, all this attached to the EU Regulation 2016/679 (GDPR). If it decides to introduce any material change to the Information Reservation Policies, Users will be notified by publishing an updated version of the Policies in this section, by sending a notification or informing it on the home page or other sections of the site to keep you updated of the changes made.

If material changes are made to the way in which Personal Information is managed, the User will be notified in order to allow the User to make an informed decision as to whether or not he/she agrees to his/her Personal Information being used in the proposed manner. If he/she does not agree to those terms, the contractual relationship will then be dissolved and his/her Personal Information will not be used in any manner other than that which was disclosed at the time it was collected. Silence on the part of the User shall be deemed to constitute acceptance of the changes.

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IX. Final considerations

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About Minors

To access the services the User must be a person with legal capacity to contract; therefore, persons who do not meet this requirement should refrain from registering on the site unless they do so through their legal representative.

According to EU Regulation 2016/679 (GDPR) If the child is under 16 years of age, the processing shall only be considered lawful if consent was given or authorised by the holder of parental authority or guardianship over the child, and only to the extent that it was given or authorised. Member States may provide by law for a lower age for such purposes, provided that such lower age is not less than 13 years.

Notification of a personal data security breach to the supervisory authority.

In the event of a breach of security of personal data, PagueloFacil shall notify the competent supervisory authority in accordance with Article 55 without undue delay and, if possible, no later than 72 hours after it has become aware of it, unless such a breach of security is unlikely to constitute a risk to the rights and freedoms of natural persons. If the notification to the supervisory authority does not take place within 72 hours, it shall be accompanied by an indication of the reasons for the delay.

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Validity

The 2020 updates to the privacy policy described herein are effective upon acceptance by new Users and are valid as of 16 April 2020.

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