PRIVACY POLICY

The Hosting Company, LLC. is committed to protecting your personal data and respecting your privacy. In this Privacy Policy we describe how we collect and process your personal data. The Privacy Policy also describes your rights towards us and how to exercise them.

Please contact us at soporte@hablasinpin.com should you have any questions about this Privacy Policy or in general regarding your personal data.

THIS PRIVACY POLICY IS RELEVANT FOR ANYONE VISITING OUR WEBSITE, USING OUR SERVICES, PRODUCTS OR OTHERWISE INTERACTING WITH US. IT IS IMPORTANT THAT YOU READ AND UNDERSTAND OUR PRIVACY POLICY BEFORE USING OUR SERVICES AND PRODUCTS.

1. What information about you is collected, how will we use it and how is it legal for us to do so?

We collect personal data in a variety of ways, such as when you visit our website, download our app, interact with electronic advertisement, use our services, make a purchase, contact us and use our customer portal.

Categories of personal data we may collect and process:

• Registration and account information: your phone number, name, email, profile picture, address, password, time zone, language and currency.
• Device and connection information: We collect device and connection-specific information when you install, access, or use our services. This includes information like hardware model, operating system information, app version, browser information, and mobile network, connection information including phone number, mobile/phone operator or internet service provider, language and time zone, and IP, device operations information, and identifiers like device identifiers. When you install the Habla Sin Pin app, you’ll also be asked to allow us access to your mobile device’s address book. A copy of the phone numbers, names and, if applicable, account identifiers for Nauta services, of all your contacts (whether they are a Habla Sin Pin customer or not – but only name, phone number and Nauta account identifier) will be collected in order for us to provide functionality and administer our services.
• Activity and usage information: e.g. information about your use of our services and other activities in relation to Habla Sin Pin, such as information about when you registered to use our services, how you use our services, items you purchase, the features you use, your services settings, the time, frequency, and duration of your activities and interactions (e.g. the phone numbers and/or other identification details of the calling and receiving party, the start time, call duration, messages, mobile money top-ups, delivery notices), log files, and diagnostic, crash, website, and performance logs and reports.
• Location Information: We collect device location information.
• Customer support and social media: If you use our Customer Support service, interacts with us on our social media channels or in any other way, we may keep a record of that interaction, including the correspondence such as copies of emails and your email address.
• Behavioral and tracking details: e.g. location data, behavioral patterns, personal preferences, IP-number, cookie identifiers, unique identifier of devices you use to access and use the services and our websites.
• Payment information: We collect billing details, name, address, email address, bank details and other financial information corresponding to your selected method of payment.

The data that is collected we use for different purposes in accordance with the list below. Basically, we use the data to provide, perform and improve our services.

2. Security measures for personal data

We process your personal data in accordance with applicable data protection legislation and regulations. To protect your personal data from unauthorized disclosure or access, misuse, loss, alteration or destruction we have implemented appropriate legal, technical and organizational security measures. The implemented security measures are created to ensure a level of security appropriate to the risks that are associated with our data processing activities. Should you have any questions related to our security measures please contact soporte@hablasinpin.com.

3. Sharing Information

We work with carefully selected third-party service providers (or group companies) to operate, provide, improve, understand, customize, support, and market our services. For example, we work with companies to distribute our apps, provide infrastructure, delivery, supply location, prevent fraud or other criminal behavior, storing data, process payments, help us understand how our services are used, market our services and customer support. In connection herewith, we may share personal data with these service providers and, in some cases, also receive personal data from them.

In addition, we may also share your personal data in the following situations: upon request we may provide authorities (for example the police and the tax authority) with personal data if we have a legal obligation to do so; in order to enforce or apply our Terms of Service and/or any other agreement with you; or to protect the rights, property, or safety of us, our users, or others; and finally in case of a sale of the assets of Habla Sin Pin or a group company or corporate restructuring or as a result of a change of control of Habla Sin Pin or a group company.

When sharing your data, we are dedicated to make sure that the relevant third party shall have appropriate legal, technical and organizational measures to protect and safeguard the personal data in accordance with applicable data protection legislation, relevant supervisory authorities’ applicable regulations and guidelines regarding security of personal data and what is otherwise appropriate.

We promise to never sell your personal data to a third party unless we have your explicit permission to do so.

4. Communications and notifications

Habla Sin Pin may use your personal data to communication with you. The communication may include messages about updates, faults, alerts and other types of issues relating to technical aspects and/or the usability of the app and other parts of the services. Such communication is considered part of the service.

Occasionally we may ask you to provide information on your experiences of using the app or other parts of the services which will be used to improve the quality and provision of the services. You are under no obligations to provide any such information. Such information is used for the purposes of reviewing improving our services.

Habla Sin Pin may from time to time contact you by email, phone, SMS or through any other appropriate information channel to keep you up to date with news about Habla Sin Pin and the services, including new products, campaigns, promotions and payment methods.

If you don’t want to receive promotional messages from Habla Sin Pin you can unsubscribe by following the instructions in the promotional message you have received or by contacting our customer support at soporte@hablasinpin.com.

Promotional SMS messages to US Customers

We may occasionally send promotional SMS to customers residing in the USA. To cancel these messages text STOP to the number you received the SMS from. If you want to join again, just let us know by sending an email to soporte@hablasinpin.com and we will start sending promotional SMS to you again. As always message and data rates may apply for any messages sent to you from Habla Sin Pin and from you to Habla Sin Pin.

5. Changes to the Privacy Policy

We are constantly innovating and looking for new ways to improve our services. We therefore reserve the right to update or modify this Privacy Policy at any time, with or without notice, to reflect such improvements or any other changes to our business or in order to comply with applicable data protection legislation.

Our Privacy Policy is always available on our website so that users, at all times, can be aware of what personal data we collect, how and for what purpose the data is processed and under what circumstances such information may be shared. You are advised to review the Privacy Policy periodically so that you are aware of any modifications. If you do not agree with the terms of the Policy, you should not use the services.

6. Data retention

Collected personal data is kept for as long as it’s needed for us (however no longer than two years and 10 months after your account was closed) unless we are legally required to keep the data in our records for a longer period. When Habla Sin Pin saves data for other purposes than contractual obligations (for example to fulfill book keeping requirements or requirements to keep records of phone calls for lawful intercept) we only keep the data for as long as it’s necessary and legal for each purpose.

7. Your rights to access, rectification and erasure

Under applicable data protection legislation, you have the following rights in relation to personal data.

• Right to access – You have the right to obtain information from Habla Sin Pin about any personal data being processed about you and access to such data, if any.
• Right to rectification – You have the right to obtain the rectification of inaccurate personal data about yourself.
• Right to erasure (“the right to be forgotten”) – You have the right to obtain the erasure of data about you if the data is no longer necessary for the purpose it was collected for. There might be legal obligations for Habla Sin Pin to keep the data anyway, that stops Habla Sin Pin from immediately erasing the data. In that case we can block the data we are required to keep, from being used for other purposes than the fulfilment of the legal requirements or anonymize the data.

If you would like to exercise the rights to your personal data or should you have any other questions in connection with this Privacy Policy, please contact us at soporte@hablasinpin.com.

Updated: October 2021