PRIVACY POLICY
BEFORE USING THE WEBSITE AND THE SERVICES OFFERED THROUGH IT, PLEASE READ THIS PRIVACY POLICY CAREFULLY, WHICH APPLIES TO ALL ACTIVITIES CARRIED OUT THROUGH THE APPLICATION AND/OR THE WEBSITE (the “Privacy Policy”).
INTRODUCTION
The mobile application belo.app (the "App") and the website called www.belo.app (the "Website") are the exclusive property of Gralcey S.A., RUT: 218765580018, domiciled at Andes 1365, Escritorio 308, - Montevideo, Uruguay ("Gralcey''). For the purposes of this Privacy Policy, any reference made to the Website shall also be understood to be made with respect to the App.
This Privacy Policy is governed by the Constitution and Law No. 18.331 (the "Protection of Personal Data" and "Habeas Data") and the provisions issued from time to time by the Enforcement Authority.
Gralcey respects and protects the privacy of its users (collectively, "Users") and this Privacy Policy is intended to inform you how any personal data provided by Users or collected by Gralcey will be used when Users use the services available on the Website, whether provided by Gralcey or by third party providers outside Gralcey (the "External Providers" and the "Services", respectively).
If you, as a User of the Website, do not want Gralcey to collect and process your personally identifiable information, please abstain from browsing or registering on the Website or providing your personal data.
1. WHAT PERSONAL DATA DO WE COLLECT FROM YOU?
1.1. When using the Website, you may be required to voluntarily provide certain personal data that, as such, identifies you. Gralcey may also collect certain personal data automatically or collect information from other sources (all, the "Personal Data"), such as:
(a) First name(s), last name(s), address, nationality, telephone number, e-mail address, Gralcey customer number, User account details and passwords.
(b) Transactional information about your requests, transactions and purchases through the Website.
(c) Personal data of a patrimonial and financial nature; credit information related to economic solvency evaluations; relevant information in the event of being a politically exposed person; declaration on the origin and legality of funds; information collected for fraud prevention purposes; compliance with information regimes and means of payment.
(d) Personal data and information collected through cookies and similar technologies.
(e) Personal data posted on social networks provided by you.
(f) Personal information about you when you provide information directly to Gralcey or when you interact with Gralcey and/or External Providers on the Website.
1.2. You are not required to provide your Personal Data, but if you do not provide it or if you provide incomplete, false or inaccurate data, Gralcey will not be able to provide its management services and you will not be able to use the Services available on the Website or your ability to do so may be significantly impeded or hindered.
2. WHAT DO WE USE YOUR PERSONAL DATA FOR?
2.1. Your Personal Data will be used for the following purposes:
(a) In order for Gralcey to identify and contact you, to enable you to register, access, use and browse the Website and to verify your identity in compliance with legal requirements.
(b) So that Gralcey can provide you with the Services offered through the Website, process your requests and transactions, prepare and maintain a record of the transactions you make on the Website and follow up on them, manage the Services, including the payment processing service.
(c) To respond to requests and inquiries you have made through the Website, either about Gralcey's products and services and/or to maintain contact with you, address your comments, complaints and suggestions, as well as to provide you with support.
(d) In order to improve our Services and the functionality of the Website.
(e) To send you direct marketing and advertising communications, contact you in the future and inform you about products or services that we believe may be of interest to you, both from Gralcey and its affiliates and/or business partners. You may always request to be removed from the promotional or advertising mailing list by sending an e-mail to [email protected].
(f) To fulfill legal obligations and requirements of competent authorities.
(g) To protect the rights, property or safety of Gralcey, or any of our affiliates, business partners or customers.
(h) To carry out marketing, advertising, commercial prospecting and/or market research activities, develop internal studies on your interests and behaviors, to offer you better services and products, as well as to carry out statistical studies, elaboration of profiles to improve our commercial and promotional initiatives.
(i) To elaborate credit analysis profiles, judicial and extrajudicial collections.
2.2. In any case, Gralcey will only use your Personal Data for the purposes stated herein. The use of your Personal Data for any other purpose that is not compatible with those previously detailed will be communicated to you before we proceed to its treatment.
3. WITH WHOM DO WE SHARE YOUR PERSONAL DATA?
3.1. We will only share your Personal Data with third parties when this is necessary:
(a) With companies linked and/or affiliated to Gralcey, in order to communicate with you and to provide the Service.
(b) With External Providers that assist Gralcey in providing the Services, such as payment processing companies; computer system providers; cloud service providers; general technology service providers, call centers or customer service centers; advertising or marketing agencies; data analysis agencies; insurance, legal and/or financial consultants; agents and representatives.
(c) With financial institutions and any other company that may be necessary to carry out the purchase of crypto assets through Gralcey.
(d) To comply with applicable laws or regulations, judicial or administrative proceedings, or to protect and defend the rights or property of Gralcey. For example, we may share your Personal Data with any competent state authority or body, government agency or court, in cases where disclosure is necessary to comply with applicable law or regulation, to exercise, establish or defend our rights, or to protect your vital interests or those of any other person, among others.
(e) To act in urgent circumstances to protect the safety of Users of the Website or the public.
(f) During an audit process of Gralcey, with the auditors and their principals, always subject to confidentiality obligations.
(g) In the event of a sale of Gralcey, merger, reorganization, dissolution or similar event in which Personal Data is part of the assets involved or transferred, we will share your Personal Data with the resulting buyer or entity.
3.2. In connection with (a), (b) and (c) above, the Personal Data will not be used by the External Providers for any purpose other than that for which it was transferred to you by Gralcey and will always be processed on Gralcey's instructions.
3.3. Personal Data, when shared, may be transferred to the aforementioned third parties located inside or outside Uruguay, even when the third parties are located in countries that Uruguayan law considers do not offer adequate protection.
4. USE OF COOKIES
4.1. Gralcey may store information on your computer through the use of "cookies" to improve the quality of the visit on the Website. Cookies are small files that store information about the computer of the person accessing a website, such as the IP address, the date and time of access, the IP address of the website you linked to the Services, the file name or words you searched for on a web page, articles, and information about the browser and operating system used. They allow the entity that places the cookie on the user's device to recognize the user across different websites, devices and/or browsing sessions. Cookies serve many useful purposes, such as the following:
(a) Cookies can remember the user's login credentials, so that you do not have to enter those credentials each time you log in to the Website.
(b) Cookies help Gralcey understand which parts of the Website are the most popular, because they help show which pages and features visitors access and how long they stay on the pages. By studying this kind of information, Gralcey can better adapt the Website and provide Users with a better experience.
(c) Cookies help Gralcey understand which advertisements Users have seen so that Users do not receive the same advertisement each time they access the Website.
(d) Cookies help Gralcey provide Users with relevant content and advertisements by collecting information about their use of the Website and other websites and applications.
4.2. When you use a web browser to access the Website, you can set your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. Each browser is different, so you should check the "Help" menu of your browser for information on how to change your cookie preferences. Your device's operating system may contain additional controls for cookies.
4.3. Please note, however, that the Website may be designed to work through cookies and disabling cookies may affect your ability to use the Web Site or some parts of the Website.
5. WEBSITE SECURITY
Gralcey has implemented the necessary technical and organizational security measures to ensure the security of your Personal Data and safeguard them from modification, loss, processing and/or unauthorized access, taking into account the state of technology, the nature of the data stored and the risks to which they are exposed, whether as a result of human action or the physical or natural environment.
6. LINKS TO AN EXTERNAL SITE
Gralcey may link to sites created and maintained by public and private organizations that may include or offer third party products or services. Gralcey is not responsible for the security and privacy practices or the content of third party websites linked to the Website. Gralcey does not control or guarantee the accuracy, relevance, adequacy or completeness of the information contained in such sites and is not responsible for the content or activities of such sites. If you click on a link to an external site, you will leave the Web Site and will be subject to the privacy and security policies of the owners/sponsors of the external site. The processing of Personal Data by the third parties responsible for the aforementioned websites is not covered by this Privacy Policy, so please read those privacy and security policies carefully.
7. MODIFICATIONS TO THE PRIVACY POLICY
7.1. We may modify this Privacy Policy at any time. In the event that significant changes are made to the Privacy Policy, we will notify you by posting the modified Privacy Policy on the Website platform and/or by sending you an email message in order for you to accept it in case we require your approval. We will also update the "last updated" date at the top of this Privacy Policy. In the event that we communicate changes to you by email, the date we send the email will be deemed to be the date you received the email.
7.2. It is important that you read the amended Privacy Policy. Acceptance of the Privacy Policy and its updates is not mandatory, but may be a necessary requirement in order to use the Services provided through the Website. If you do not wish to accept the revised Privacy Policy, Gralcey may have difficulty continuing to provide the Services to you on the Website and in some cases may be prevented from processing your Personal Data to provide the Services to you. The latest version of this policy is dated August 20, 2021.
8. YOUR RIGHTS
8.1. The responsible for the database where your Personal Data is stored is Gralcey S.A., RUT: 218765580018, domiciled in Andes 1365, Escritorio 308, Montevideo, Uruguay CP: 11.000. You have the right to request and obtain information about your Personal Data. You also have the right to request the rectification, updating and, if applicable, deletion of your Personal Data.
8.2. Gralcey will delete your Personal Data when they are no longer necessary for the provision of the Services. For technical reasons this process may take some time. In certain cases, Gralcey may retain your Personal Data when there is an obligation to maintain the Personal Data, or for the statute of limitations period for any potential action against Gralcey. However, during such time or period the Personal Data will be kept encrypted and non-operational, until deletion.
8.3. Users may contact Gralcey at any time to exercise their rights by sending an email to [email protected].
9. QUESTIONS
If you have any questions about this Privacy Policy, please contact us at the following email address: [email protected].