PRIVACY AND DATA PROTECTION POLICY

1. about us

For Polux Capitals it is extremely important to protect the privacy of our clients. This privacy statement provides information about how we handle your personal data, your right to privacy and how we protect you. Therefore, before carrying out any interaction or transaction on the Platform, it is essential that you know and accept all the details of this Privacy Policy. If you do not agree with it, please do not access this Platform, or any page thereof. All information collected in connection with your use of the Platform will be protected in accordance with the privacy policies set forth below. Please take a moment to carefully read this Privacy Policy. If you have any questions about its content, please contact us at lpdp@pollux.finance


BY ACCESSING, CONNECTING OR OTHERWISE USING THE APPLICATION YOU CONFIRM THAT YOU HAVE READ, UNDERSTAND AND AGREE TO THE PROVISIONS IN THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH THE TERMS OF THIS POLICY, YOU SHOULD NOT USE THE APPLICATION.

2. scope

This Privacy Policy ("Policy") informs Users of our policies regarding the processing of personal information we receive from users and its related services (the "Website", "we", "us" or "our"). We use your personal information only to provide and improve customer experience. By opening an account, you agree to the collection, storage and use of information in accordance with this Policy.

3. Collection and use

By accessing and using our Services, you voluntarily agree to this Privacy Policy. If we need to process your Personal Data, we will ask for your consent to the collection, use and disclosure as described below. If you do not agree or are uncomfortable with any aspect of this Privacy Policy, you must immediately discontinue accessing or using our Services.

4. TYPE OF PERSONAL INFORMATION WE PROCESS AND COLLECT

To proceed with account registration, we must process information about you. The information collected depends on how you use our Service. While providing our services, we may collect:

  • So that Polux Capitals, in its capacity as assignee, compares your personal data indicated in the following paragraph with the database of the National Registry of Persons (RENAPER) and/or any public and/or private database, in accordance with the specifications. which are detailed below. This consent for the processing of your personal data extends to those included in your National Identity Document (including biometric fingerprint and facial recognition data in contrast to what is reported by the RENAPER web service). Information about treatment. The data will be processed for the exclusive purpose of validating your identity (biometrics) and verifying the validity of your National Identity Document for the processes linked to the account opening request and/or any other related to the commercial relationship you maintain with Polux. Capitals The compared data will be stored once the validity of the National Identity Document has been verified and validated.
  • Information you may provide us: aliases, CBU/CVU addresses, address, and any other information you choose to provide.
  • Your mobile devices that you use with the Application may provide certain information that can potentially identify you, such as device type (including identifiers), platform type, mobile phone number, your Internet service, operating system, geolocation information, browser that you use, browser language or the pages you visit.
  • By voluntarily providing personal data to us, including, but not limited to, using the Website/Application, you expressly and irrevocably consent to our use of the same in accordance with this Privacy Policy. If you provide us with personal data, you acknowledge and agree that such personal data may be transferred from your current location to Polux Capitals servers and authorized third party servers.

5. HOW WE USE YOUR INFORMATION

We will only use your Personal Data for the purposes for which we collected it as listed above, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purposes. In the event that we need to use your Personal Data for a unrelated purpose, we will update this Privacy Policy and explain the legal basis that allows us to do so. However, this information is used to verify your identity. This includes verifying certain data provided by you and reviewing your eligibility to use our products and services. We use the information we collect about you to provide you with the services we offer, to notify you about changes to our products, and to improve our products.

6. third party use

We may share your personal information or sensitive information as permitted by data legislation or in the limited circumstances set out below. These third parties are limited by law or contract to using the information for secondary purposes beyond the purposes for which the information is shared. We may share your information with trusted third parties when:

  • Special features are provided at your request;
  • Interact with our approved business services partners who are subject to contractual and legal regulations on how they are permitted to handle your data; and,
  • Identity validation using REST API. by RENAPER
  • If you are required to do so by law or within the framework of a legal procedure
  • To security forces and bodies or other public officials when they legitimately request it.
  • When you believe that such disclosure is necessary or advisable to avoid damage or economic loss
  • In the context of an investigation of fraudulent or illegal activities, or that are suspected to be fraudulent or illegal

7. WHAT HAPPENS WHEN THE USER DOES NOT PROVIDE THE NECESSARY INFORMATION

Where we need to process your Personal Data either to comply with the law or to perform the terms of the contract we have with you and you do not provide that data when requested, we may not be able to perform the contract we have or are trying to perform. enter into contact with you.In this case, we may have to stop using our Services. You will be notified if this is the case at that time.

8. HOW WE PROTECT YOUR INFORMATION

We strive to protect your information from unauthorized access, use or disclosure. We use a variety of physical and technical measures designed to protect our systems and your personal information. Unfortunately, there is no such thing as completely secure data transmission or storage, so we cannot guarantee that our security will not be breached (by technical measures or by violation of our policies and procedures). Without prejudice to our efforts to protect your information, nothing contained herein constitutes a guarantee of the security of the Application, and you agree to transmit information at your own risk. Please note that the application does not guarantee that your information cannot be accessed, disclosed, altered or destroyed by breach of any of our physical, technical or administrative security measures.

9. DISCLOSURE OF YOUR INFORMATION TO GOVERNMENT AGENCIES AND OTHER ORGANIZATIONS

We may be required by law to grant access to your personal data that we process for the purpose of investigating criminal activities and violations of law, to judicial or other government agencies, in particular law enforcement authorities subject to court orders, subpoenas or otherwise orders.

10. YOUR RIGHTS

Data owners have the following rights: Right to Information: Any person may request from the Agency for Access to Public Information information regarding the existence of personal databases, purposes and those responsible. The information must be clear, comprehensive and complete. Right of Access: The data owner may obtain information on their personal data included in public or private data banks intended to provide reports. The requested information must be provided within TEN calendar days of notification. If the request is not satisfied, the habeas data action will be expedited. This right of access can only be exercised free of charge at intervals of no less than six months, unless a legitimate interest is proven for this purpose. Right to Rectification, Update or Deletion of data: The person responsible or user of the database must proceed with the rectification, deletion or update of personal data within a maximum period of FIVE business days of receiving the claim. Failure to comply with this obligation within the agreed term will enable the habeas data action to be promoted. To comply with said requests, the data owner must submit the form that corresponds to their request (Annex I: Access to data; or Annex II: Rectification, updating or deletion of personal data included in data banks) together with a copy of your ID, to the email address: lpdp@pollux.finance. Polux Capitals will process the request made within the previously established deadlines. The Agency for Access to Public Information, in its capacity as the Control Body of Law No. 25,326, has the power to address complaints and claims filed by those who are affected in their rights due to non-compliance with current regulations regarding the protection of personal data.

11. HOW LONG WE KEEP YOUR PERSONAL DATA

Polux Capitals maintains reasonable procedures to help ensure that your personal data is reliable for its intended use, accurate, complete and up-to-date.

  • We will only retain your Personal Data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements, as well as other factors required by laws to which we are subject.
  • In some circumstances, we may anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without notice to you.
  • When it is no longer necessary to retain your Personal Data, we will securely delete it, subject to applicable laws and regulations.
  • If you request that we stop sending you marketing materials, we will continue to keep a record of your contact details and appropriate information so that we can comply with your request not to be contacted by us. ** Please note that we may be legally required to retain your Personal Data for five years or longer from the date you cease to be our customer, depending on applicable laws or regulations in the jurisdictions in which we operate. **

12. CHANGES TO THIS PRIVACY POLICY

We reserve the right to update or change our Privacy Policy at any time and you should review this Privacy Policy periodically. Your continued use of the Service after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy. If we make material changes to this Privacy Policy, we will notify you either via the email address you provided us or by placing a prominent notice on our Platform.

13. Responsibility

You acknowledge that Polux Capitals is not responsible for any illegal or abusive use of your information. You acknowledge that, in the event you share your information from the Platform on social or other networks, or other third-party sites and/or platforms, your information is subject to the privacy policies of such third-party resources. Polux Capitals may share your personal information with law enforcement, data protection authorities, government officials and other authorities only when Polux Capitals is legally required to do so or has to protect the security of users and the Platform.

14. INFORMED CONSENT

Hereby, in my capacity as DATA OWNER, I give my CONSENT for “Polux Capitals S.A” in its capacity as ASSIGNEE to compare my personal data indicated in the following paragraph with the RENAPER database, in accordance with the specifications. which are detailed below:
AUTHORIZED DATA:

This consent for the processing of my personal data extends to those included in my National Identity Document (INCLUDING BIOMETRIC FINGERPRINT AND FACIAL RECOGNITION DATA) in contrast to what the web service reports. from the NATIONAL REGISTRY OF PERSONS.
INFORMATION ABOUT TREATMENT:

  1. The data will be processed for the exclusive purpose of validating my identity and verifying the validity of my National Identity Document to open a client account.
  2. The confronted data will be destroyed once the validity of the National Identity Document is verified and validated, and cannot be stored.
  3. The data is provided on a mandatory basis, since it is essential to reliably identify the owner, to ensure the correct identification process.
  4. The data owner may exercise the rights of access, rectification and deletion of their data at any time and at their sole request to RENAPER.
  5. In compliance with AAIP Resolution No. 14/2018, we inform you that the AGENCY FOR ACCESS TO PUBLIC INFORMATION, in its capacity as the Control Body of Law No. 25,326, has the power to address complaints and claims filed by those their rights are affected by non-compliance with current regulations on the protection of personal data.