MULTUM – Privacy Policy

This privacy policy (hereinafter, the “Privacy Policy”) corresponds to the use of the software offered through the mobile application called “My Concierge”, available in Google Play and App Store (hereinafter, the “Application”) provided by Multum SAU, domiciled at Esmeralda 718, Floor 6, Office F, Autonomous City of Buenos Aires, Argentine Republic, CUIT [single tax identification number] 30-71704528-5 (hereinafter, “MULTUM”).

 

For the purposes of this Privacy Policy, any person using and directly accessing the Application or accessing through an API of third parties that are MULTUM partners shall be considered as the “Users” or the “User”. The Users, in conjunction with MULTUM, shall be considered as the “Parties” or, individually, the “Party”.

 

  1. RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA

1.1.                        The responsible for the processing of Personal Data shall be MULTUM. For MULTUM, the privacy of the User’s personal data is very important. In the event the User has any doubt as to the Privacy Policy, or its implementation, he or she should contact MULTUM, at any time, by email to administrator@multum.digital.

 

  1. USERS’ INFORMATION COLLECTION. PURPOSE

2.1.                        MULTUM shall, through the Application, request the User to provide the following personal data (hereinafter, the “Personal Data”): (i) name and surname; (ii) birth of date; (iii) address, including, where appropriate, name of Neighborhood and lot; (iv) mobile and/or landline phone; (vi) email address.           

 

2.2.                        The User undertakes to guarantee and answer for the veracity, adequacy, validity and authenticity of the Personal Data and of any other information shared through the Application.

 

2.3.                        MULTUM shall process the Personal Data due to the express consent given by the User through the agreement of this Privacy Policy. In this sense, the User agrees that MULTUM may collect his or her information by means of cookies and/or tags or any other automatized information detection method provided by the tools in the Application. The information collected by MULTUM may include surfing behaviour, IP address, logs and other types of information.

 

2.4.                        In addition, MULTUM shall be able to collect and/or store the Users’ IP (Internet Protocol) address or number with the sole purpose of improving the quality of the Service and the operation of the Application. Through the IP number, MULTUM shall be able to identify the Users’ devices when they login in their Accounts. Furthermore, such storage enables the diagnosis of possible connection problems that may arise between the Application and the Users, thus improving the quality of the Service.

 

3.         USE OF THE COLLECTED INFORMATION

3.1.      MULTUM shall use and store the information provided by the Users and the information collected by MULTUM in order to provide the Service and offer constant improvements on the Application.  

 

3.2.      MULTUM shall be able to use the information provided by the Users and the information collected by MULTUM for different purposes, such as:

 

(i)         to perform the registration of the User in the Application. In order to use the Services, MULTUM shall request the User to provide his or her Personal Data for its storage and the generation of a database;

(ii)        to classify the user into the different social segments, their interests and/or demands on the Application. For instance, MULTUM shall determine the Neighbourhood and the role the User has in the family group or, if he or she is a supplier, a building administrator, among other roles offered by the Application;

(iii)       to contact the Users in order to provide information about the Application, the Services or offers that may be of the User’s interests, whether of a financial nature or not, including, but not limiting to, notices or updates on the collection of their building expenses or suppliers that could meet the User’s needs. At all times, the User shall have the right to cancel the aforementioned notices by sending an email to administrator@multum.digital;         

(v)        to protect the Users’ rights and ensure the compliance with the Application's Terms and Conditions;

 

In no case, shall MULTUM be deemed liable for the damages caused by the entities, companies and/or internet sites mentioned in the previous paragraph, with respect to its obligation of protection, confidentiality and privacy of the data which they manage.

 

3.3.      The User understands and agrees that the Application may contain links redirecting to other sites, whose holders are in no way whatsoever related with MULTUM. Under these assumptions, MULTUM shall not be liable for the actions performed by such sites, to which the Privacy Policy shall not be applied. Therefore, MULTUM recommends the examination of the privacy policy in effect on those sites in order to understand the procedures of collection and protection of their information.

 

3.4.      Notwithstanding the foregoing, MULTUM shall share the information that may be required and requested in the appropriate manner by courts or equivalent national or international state bodies, without causing the right to claim in favor of the User.

 

4.         THE APPLICATION

4.1.      MULTUM shall not commercialize any Personal Data with third parties, i.e. it shall not perform the sale, rent or any negotiating act related thereto with natural or legal persons other than MULTUM. Nevertheless, for certain services requested by the Users, MULTUM shall be able to grant, in compliance with the purposes of such services and/or MULTUM’s Services, to third-party companies so that such services can be provided. Furthermore, MULTUM ensures the User the right to access, update, eliminate or correct his or her Personal Data processed by MULTUM through the Application. The User shall carry out the actions mentioned above by himself or herself by way of the login to his or her profile in the Application.

 

4.2.      If this were not to be possible, the Users that have provided information through the Application shall be able to send an email to administrator@multum.digital with the subject “Personal Data” and a photograph of their ID card, stating their will to access, update, eliminate and/or correct the information pursuant to the provisions in Section 6 of this document.

 

5.         INFORMATION SECURITY AND CONFIDENTIALITY

5.1.      MULTUM shall take any and all reasonable security measures in order to protect the Users’ information and prevent the access of those third parties who are not authorized by MULTUM. The information collected by MULTUM shall be kept strictly confidential. The access is limited only to MULTUM’s employees and representatives who may need to access the Personal Data to perform their duties and/or develop or improve the Service pursuant to the collection and processing purposes aforementioned. MULTUM requires its suppliers to operate with equal or higher confidentiality and security standards.

 

5.3.      MULTUM shall not allow third parties who are not related to MULTUM to access to this information, except in the case of an express request or authorization on the part of the User.

 

5.4.      Notwithstanding the foregoing, MULTUM cannot provide assurance that non-authorized third parties may be likely to breach all security measures and use the Users’ information in an unduly manner. Under these assumptions, MULTUM shall not be responsible for the unlawful interceptions and/or breaches of its systems or databases on the part of non-authorized persons, as well as for the undue use of the information obtained via these means.

 

6.         USERS’ RIGHTS

6.1.      MULTUM shall seek, by all means at its disposal, to allow the Users about whom it has collected or stored personal information to access, amend, eliminate or update their Personal Data, with the exception that MULTUM could be able to reject such requests for being bound or for having the right to keep such Personal Data in accordance with the applicable law.

 

6.2.      Users shall be able to access, update, eliminate or correct by themselves their personal information through the Application. If this were not to be possible for whatsoever reason, the User should send an email to administrator@multum.digital with the subject “Personal Data” and a photograph of their ID card, requesting the access, update, elimination or correction of their Personal Data.

 

6.3.      THE PROPRIETOR OF THE PERSONAL DATA HAS THE CAPACITY TO EXERCISE THE RIGHT TO ACCESS SUCH DATA FREE-OF-CHARGE AT INTERVALS OF NO LESS THAN SIX MONTHS.

 

7.         INTERNATIONAL TRANSFER OF PERSONAL DATA

7.1.      With the sole purpose of complying with the provisions in this Privacy Policy and in order to provide the Service, MULTUM shall be able to transfer the Personal Data and/or the personal information to MULTUM partners and authorities and other third parties, namely those suppliers of technical infrastructure and data hosting services (including, but not limited to, Amazon Web Services) in relation to the Service.

 

In some cases, like the Argentine Republic, the personal information may be transferred abroad to countries with equal or better protection standards. In the event that the personal information is transferred to countries with lower protection standards, MULTUM shall perform those transfers subject to the appropriate safeguards and security measures, such as the standard data protection clauses included in the corresponding agreements or approved by the applicable legal authority.

 

7.2.      Accordingly, the User understands, consents and agrees, by way of this Privacy Policy, that his or her Personal Data may be transferred to other countries, regardless of whether they have an appropriate protection standard. The consent withdrawal on the part of the User shall not render ineffective the aforementioned acts performed by MULTUM.         

 

8.         MINORS

8.1.      In the event that minors (under eighteen-year-olds) access the Application or the Service, their use shall be supervised by their parents, guardians or legal representatives. If there is no prior authorization granted by their parents, guardians or legal representatives, the minors are not allowed to login, nor provide MULTUM with any Personal Data or any other type of information.

 

9.         CHANGES IN THE CORPORATE STRUCTURE

9.1.      MULTUM shall be able to transfer the Users’ collected information in the case of sale, merger or acquisition of the main assets or any other means of transfer that may occur to MULTUM in the future. If these assumptions were to occur, MULTUM undertakes to take the reasonable measures in order to ensure that such information is consistently used in line with this Privacy Policy.

 

10.       EXCEPTIONS 

10.1.    Notwithstanding the dispositions set forth herein, MULTUM shall be able to disclose certain personal information of the Users, where it may consider in good faith that such disclosure is reasonably necessary: (i) to meet a legal requirement, including but not limiting to, a search warrant, a court order or summons; (ii) to meet a requirement issued by a regulating or government authority; and/or (iii) to protect the rights, propriety or security of MULTUM, the Users, or a third party.

 

11.       AMENDMENTS

11.1.    MULTUM shall be able to amend this Privacy Policy where it may deem appropriate. Should the amendments substantially affect the management of the collected Personal Data by virtue of the use of the Service, such amendments shall be notified by a prominent announcement in the Application and by an email to the address stated by the User on the Registration.

 

12.       CONTACT

12.1.    Should the Users have any doubt about the Privacy Policy, or about its implementation, they should contact MULTUM, at any time, by email to the following address: administrator@multum.digital.