PRIVACY POLICY
AVANZA EXTERNALIZATION OF SERVICES URUGUAY S.A. ("Avanza")
This document (hereinafter, "Policy") sets forth Avanza's rules regarding the treatment of personal information ("Personal Data") that the user transmits or communicates to this Web site.
This Web Site (the "Site") is owned by Avanza.
The Personal Data provided to Avanza through this Site will be stored with the necessary technical and organizational measures to guarantee its security and avoid its alteration, loss, unauthorized processing or access.
Avanza reserves the right to modify this Policy in order to adapt it to its needs and to provide an effective service to users. In that sense, it is recommended to frequently review this Privacy Policy to identify successive updates or changes to it.
1. Storage of Personal Data
Avanza, domiciled in Vázquez 1386, Montevideo, Uruguay, is the legal entity responsible for the treatment of the Personal Data that the user communicates through his interaction with this Site.
2. Regulations applicable to the processing of Personal Data
The processing of Personal Data referred to in this Policy shall be carried out in accordance with the following Uruguayan regulations: Law No. 18.331 of August 11, 2008, on Personal Data Protection and Habeas Data Action, Law No. 19.670 of October 15, 2018, Decrees No. 414/2009 of August 31, 2009 and 64/020 of February 17, 2020, as amended and supplemented.
3. Sources of Personal Data Collection
Avanza processes the Personal Data that the user transmits in his/her interaction with this Web site and those that may come from different public and private sources, as permitted by the Personal Data Protection Regulations.
4. Purposes of the processing of Personal Data - Granting of consent - Consequences of refusal
The Personal Data that the user will transmit through the Site will be used exclusively for Avanza's own commercial purposes and those of other companies of the Skytel Group (including _______________, hereinafter the "Skytel Group") sending information, commercial documentation, newsletters and e-mails offering services and products, creating profiles and personalized offers, promotions, gifts, advertising, market research and financial evaluations. Acceptance of this Policy by means of the option at the bottom of the Policy shall be understood as the user's express consent to the processing of the Personal Data collected. Personal Data will be retained to the extent that Avanza deems necessary and for compliance with legal and regulatory obligations.
The user authorizes Avanza to transmit his or her Personal Data to Skytel Group companies.
Avanza may also collect Personal Data that are contained or intended to be contained in publicly available sources, as well as Personal Data relating to creditworthiness and solvency, the processing of which does not require the consent of the owner.
The Personal Data mentioned in the preceding paragraphs are important and necessary for Avanza to be able to provide its services effectively. The user's refusal to provide the Personal Data that browsing the Site requires or the refusal to accept this Policy will result in the impossibility of communication through this Site.
5. About the Use of Cookies
Additionally, the Site collects information through the use of its own and third party cookies in order to enhance the user experience and to better understand how the user interacts with the Site.
A cookie is a unique, random number that is stored in your computer's browser. The cookie does not identify the user browsing the website, only the computer you are using to visit the site. Cookies allow Avanza to collect information from the user's browsing that is not personally identifiable (i.e., it is completely anonymous). For example, through the use of cookies Avanza can know how many users visit the Site, which sections they access or which web browser they use when they visit the Site.
Notwithstanding the foregoing, if the user does not want information collected through the use of cookies, he/she can deactivate their use by modifying the configuration parameters of his/her browser, for which it is advisable to consult the browser's instructions. Deactivation does not prevent the visualization of the content of the Website nor does it interfere with the user's navigation.
6. Personal Data Processors
Avanza, as part of the processing of the Personal Data referred to in this Policy, may entrust part or all of such processing to other natural and/or legal persons, referred to as "Data Processors".
These Data Processors may be partners, suppliers or third parties hired to assist in the performance of the contractual and/or commercial relationship or to help Avanza improve the services it offers. They may also be data analysis providers and search engines that assist Avanza in improving and optimizing the services offered.
7. Transfer of Personal Data
Avanza, as part of the processing of Personal Data, may carry out the national or international transfer of the Personal Data obtained to natural and/or legal persons other than the Data Processor.
The user gives his/her prior, express and informed consent for the transfer of his/her Personal Data abroad.
8. Exercise of rights
Avanza will enable the holders of the Personal Data referred to in this Policy to exercise their rights of access, rectification, updating, inclusion, deletion of their data and challenge of personal assessments, in person at its offices in Vázquez 1386, Montevideo, Uruguay. Until no communication to the contrary is received, the processing carried out shall be considered legitimate.
9. Time of conservation of Personal Data
We will retain your Personal Data for as long as necessary for the lawful purpose for which it was obtained, provided that we have a legitimate interest in retaining it, for example, until the termination of our contract and/or until the statute of limitations for legal action is possible in order to defend ourselves against legal claims. We are also required by law to retain your Personal Data for a period of time to prevent and detect fraud, detect and evidence money laundering and for economic audits.
10. Additional information
Avanza confirms that it has adopted appropriate security levels for the safeguarding and confidentiality of information, respecting the measures applicable to each category and type of processing.
Avanza also confirms that it respects the principles of legality, consent, purpose, proportionality, quality, availability of resources, and adequate level of protection provided for in the Personal Data Protection Regulation.
11. Obligations regarding the accuracy of information
All information provided to Avanza must be truthful and verifiable. To this end, Users guarantee the authenticity of all information provided and undertake to keep it up to date, and shall be liable for all damages resulting from any inaccuracy, whether suffered by Users, employees, collaborators, customers, the general public, Avanza or third parties.
12. Obligations of Users
By using this Site, users undertake:
- Not to damage, disable or deteriorate the computer systems that enable the use of the Site, those of Avanza, other users or third parties, or the content incorporated and/or stored therein.
- Not to modify the aforementioned systems in any way and, consequently, not to use modified versions of systems for the purpose of obtaining unauthorized access to the Site.
- Not to interfere with or interrupt access to and use of the Site, servers or networks, or to fail to comply with the requirements, procedures and regulations of the network connection policy.
Avanza may act by any means it deems pertinent and appropriate against any use of the Site that is contrary to this Policy, infringes or violates intellectual property rights or any other rights of Avanza, other users or third parties, and may withdraw or suspend use of the Site at any time and without prior notice.
Avanza reserves the right to modify, at any time and without prior notice, the presentation, configuration and functionalities of the Site, and may interrupt, deactivate and/or cancel any of the content and/or services presented, integrated or incorporated, without expression of cause and without liability.
13. Links
This Privacy Policy applies exclusively to the Site and does not extend to links to other Web sites or to the content contained therein or to the accesses made through them, which are beyond Avanza's control.
In this sense, the use of, for example, Apple Store, Google Play, Facebook, WhatsApp, LinkedIn, as well as any other tool, application or content, accessed even from Avanza's applications or Site, is/are excluded from the protection described above in terms of Personal Data. Therefore, access to sites, portals, services, applications and content, among others, other than those regulated herein, is the sole responsibility of those who access, Avanza disclaims all liability for the processing of personal information and the consequences of actions or omissions, including any loss or damage caused to the natural or legal person who accesses the content or uses the services, third parties, equipment, etc.
The Internet connection required for access and use of the site is the responsibility of the users.
14. Access
In the case of minors under eighteen years of age and/or incapable persons, access to the Site must have the authorization of their legal representatives, who are understood to have given their prior, express and informed consent on their behalf, Avanza reserving the right to request their ratification in writing, if it deems it pertinent.
Users undertake to use the site in compliance with current national regulations, good customs and public order, undertaking in all cases not to cause damage to Avanza, other users or third parties.
In their merit, they shall refrain from using the site for illicit purposes or effects, prohibited in this Policy, in technical or legal rules harmful to the rights and interests of Avanza, other users or third parties, or that may in any way damage, render useless, overload, deteriorate or impede its normal use, as well as any computer equipment of Avanza, employees, collaborators, customers and third parties.
Intellectual Property
All trademarks, trade names or distinctive signs of any kind that may appear are the property of Avanza or third parties other than the user, without it being understood that the use or access attributes to users any right over such trademarks, trade names or distinctive signs of any kind.
Users are responsible for the comments and content they share through social networks through their own accounts and declare that they are the authors or own the rights to the content disseminated, communicated or shared, exonerating Avanza from any damages and claims in this regard.
In case of content that infringes intellectual property rights or is harmful to rights, please contact us by e-mail at xxxx@xxxxxxx
16. Responsibility
The user exonerates Avanza from any liability for damages of any and all nature that may be due to the lack of availability or continuity of the operation of the Site, accesses provided as they are. In particular, but not exclusively, access failures.
17. Jurisdiction and Applicable Law
This Policy is governed, without exception and in all its clauses, by the laws of the Oriental Republic of Uruguay and shall be interpreted in accordance with them.
Any controversy derived from this document related to its existence, validity, interpretation, scope or compliance shall be submitted to the Courts of the city of Montevideo, Uruguay, and the users expressly waive any other jurisdiction or venue.
MTEL PARAGUAY S.A
Telephone number (021) 419 8000
