Privacy Policy
General Conditions
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- This Policy aims to inform, in a clear, concrete, and detailed manner, about the collection, use, and treatment of personal information as well as the protection of personal data in accordance with the provisions of Law No. 25,326 (personal data protection), its regulatory decree, complementary rules, and provisions issued by the Agency of Access to Public Information.
- Use of Bonete and the transfer of information received from Google APIs to any other application will adhere to the Google API Services User Data Policy, including limited use requirements.
- Additionally, this Policy is integrated and forms part of the General Terms and Conditions of BONETE.APP (hereinafter referred to as BONETE).
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Why is privacy important?
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- Privacy is your right to keep your information private, and also to have control over it, knowing who it is shared with, who can see it, who cannot, for how long, and above all, what your information will be used for.
- In order to properly respect your privacy, there are important regulations for the protection of personal data, both at the national and international levels, through which a series of principles and security measures are sought to be complied with to ensure the care of your information. In Argentina, the Protection of Personal Data has been recognized at the constitutional level and regulated through Law No. 25,326 and other complementary regulatory provisions.
- In this context, we want to inform you that by using or requesting our services, it is possible that we collect your personal data, and that is why at BONETE we understand that such processing implies a great responsibility and we strive to the maximum to take care of your information and provide you with all the information and access to the rights that correspond to you.
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What data is being collected?
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- The type of information collected by BONETE, as well as its purposes, depends on the use you make of our services (such as web visitor, interested in receiving quotes, platform clients, etc.). In any case, the data we collect undergo processes necessary to ensure that the data are true, adequate, relevant, accurate, and not excessive in relation to the scope and purpose that motivated their collection. They will be stored, at all times, facilitating the exercise of the rights of their owners and updated if necessary, as well as being deleted in accordance with the provisions of the current regulatory framework.
- Regarding the collected data, BONETE undertakes to respect the principle of data minimization, guaranteeing that the least amount of data possible will be requested and processed, provided that they are sufficient to fulfill the declared purpose.
- In all cases, we inform you that BONETE uses appropriate technology and well-defined personnel practices to process personal data, as well as appropriate information security measures for their protection and processing, in accordance with the provisions of Resolution 47/2018 of the Agency of Access to Public Information.
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What are these data collected for?
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- The purposes that motivate data collection depend on the category of data analyzed. In the case that you are a CLIENT, your data may be used to manage and enable the operation of the BONETE platform. Likewise, your data may be used to send you communications, carry out activities, and training sessions.
- Likewise, the CLIENT understands and accepts that the legality of personal data uploaded to the platform (for example, about event guests, suppliers, employees, etc.) will be the total and exclusive responsibility of the CLIENT, with BONETE only acting as a Data Processor.
- BONETE guarantees that it does not collect data for any purpose other than or incompatible with the purpose stated in this Policy, nor does it collect data through unfair, fraudulent means, or in a manner contrary to current legal provisions.
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With whom will my data be shared?
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- At BONETE, we guarantee that your data will be processed according to the declared purposes, so in some cases, it will be necessary to transfer them to different areas of BONETE including our team that organizes activities, the Marketing department of BONETE, and service providers and/or data processors working on behalf of BONETE, such as contractors, delegates, network of offices, or allies, in order to develop system hosting services, maintenance services, analysis services, email or physical mail messaging services, among others. In all cases, such data processing by BONETE is carried out within the limits and purposes established in the contracts with service providers, always warning about the obligation to take appropriate security precautions, as well as prohibiting them from using your personal information for their own purposes and preventing them from disclosing your personal information to others.
- The information provided by the data subjects will be used only for the stated purposes and objectives, so BONETE undertakes not to sell, license, transmit, or disclose it, outside the organization unless:
- The data subject expressly authorizes us to do so,
- It is necessary to enable our contractors or agents entrusted to provide the services we have entrusted to them,
- It is disclosed to entities that provide advertising, technology, marketing, call center services on our behalf or jointly,
- It is related to a merger, consolidation, acquisition, divestiture, or other restructuring process, or
- As required or permitted by law.
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How are my data being protected?
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- At BONETE, we understand the importance of properly caring for all types of information, but particularly, we are convinced of the importance of properly caring for personal data, in accordance with the provisions of art. 9 of Law No. 25,326.
- Therefore, at BONETE, great effort is made to have security measures aimed at protecting the data of the Owners, seeking to prevent their alteration, loss, unauthorized uses, and access. More specifically, and in compliance with due diligence for data processing, BONETE implements human, administrative, and technical protection measures that are reasonably within its reach and that are in line with the best practices established by Resolution 47/2018 of the Agency for Access to Public Information.
- Regarding the information security measures established by BONETE for the proper processing of personal data, reference is made to the Information Security Policies established by BONETE, which are mandatory accepted by all internal and external personnel who carry out any type of activity or operation with BONETE, and in which all duties and obligations are defined, as well as the technical aspects of the measures implemented to guarantee the integrity, confidentiality, and availability of information, particularly personal data.
- In addition to BONETE, all individuals (internal and external) involved in the processing of personal data have the obligation of confidentiality and to comply with the information security measures that are relevant, an obligation that persists even after the contractual relationship has ended.
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What are my rights and how can I exercise them?
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- All data subjects can consult the Agency for Access to Public Information free of charge regarding the existence of files, records, or databases, their purposes, and the identity of their controllers. This agency is responsible for the National Registry of Databases, which is publicly and freely accessible.
- In accordance with Disposition 10/2008 of the Agency for Access to Public Information, the Data Subject has the right to exercise access to their personal data free of charge at intervals not less than six months, unless a legitimate interest is proven according to the provisions of article 14, paragraph 3 of Law No. 25,326. The NATIONAL DIRECTORATE OF PERSONAL DATA PROTECTION, the control body of Law No. 25,326, has the authority to handle complaints and claims filed regarding non-compliance with data protection regulations.
- According to Chapter III “Rights of data subjects” of Law No. 25,326, all data subjects have the following rights:
Right to information
- In accordance with Article 13 of Law No. 25,326, any person can request information from the control agency regarding the existence of files, records, databases, or personal data banks, their purposes, and the identity of their controllers. The register that is carried out will be publicly and freely accessible.
Right of access
- In accordance with Article 14 of Law No. 25,326, at any time and free of charge, the data subject, upon proof of their identity, has the right to request and obtain information about their personal data from BONETE.
- BONETE undertakes to respond to and provide the requested information within ten calendar days of receiving the request in a verifiable manner. This information will be sent electronically, to the contact channels authorized by the data subject, to which a report containing all the requested information will be sent, in a clear and non-coded manner and, if applicable, accompanied by an explanation, in language accessible to the average knowledge of the population, of the terms used, in compliance with Article 15 of Law No. 25,326.
- BONETE will keep contact channels enabled so that data subjects can exercise their rights and, in this regard, implement the procedures provided for in this Policy.
Right to rectification or updating
- In accordance with Article 16 of Law No. 25,326, every person has the right to have their personal data rectified and updated, which are included in a database.
- BONETE undertakes to respond and provide access to the exercise of these rights of rectification and updating of the data subject’s personal data, carrying out the necessary operations for this purpose within a maximum period of five business days from the receipt of the data subject’s claim or notice of error or falsity.
- In the event of transfer or transfer of data, and whenever reasonable and technically possible, BONETE undertakes to notify the rectification or deletion to the assignee within the fifth business day after the data processing.
- BONETE will keep contact channels enabled so that data subjects can exercise their rights and, in this regard, implement the procedures provided for in this Policy.
Right to erasure
- In accordance with Article 16 of Law No. 25,326, every person has the right to have their personal data erased or subject to confidentiality, which are included in a database.
- BONETE undertakes to respond and facilitate the exercise of the right to erasure of the data subject’s personal data, carrying out the necessary operations for this purpose within a maximum period of five business days from the receipt of the data subject’s claim.
- The data subject must understand that the right to erasure does not apply when it could cause harm to the rights or legitimate interests of third parties, or when there is a legal obligation to retain the data.
- In the event of transfer or transfer of data, and whenever reasonable and technically possible, BONETE undertakes to notify the rectification or deletion to the assignee within the fifth business day after the data processing.
- BONETE will keep contact channels enabled so that data subjects can exercise their rights and, in this regard, implement the procedures provided for in this Policy.
Procedure and requirements for submitting requests
- For any of these cases, it is necessary for the data subject to consider the following procedure and the considerations detailed below:
- The data subject and/or their representative will prove this condition by providing a copy of the relevant document and their identity document, which can be provided in physical form or by email if the documents have been digitized. In the event that the data subject is represented by a third party, the respective power of attorney must be attached, which must be notarized. The attorney must also prove their identity accordingly.
- The claim will be made by means of a request addressed to BONETE’s Legal department, including the identification of the data subjects, a description of the facts giving rise to the claim, the address, and the documents that the claimant wishes to submit. If the claim is incomplete, BONETE may require the interested party, within five (5) days following receipt of the claim, to remedy the deficiencies. In this Manual, an ANNEX is attached as a model for exercising the right of access to personal data.
- If two (2) months have elapsed since the date of the request without the applicant providing the requested information, it will be understood that they have withdrawn the claim. In the event that BONETE is not competent to resolve the claim, it will transfer it to the appropriate authority within a maximum period of two (2) business days and inform the data subject of the situation, thereby relieving itself of any claims or liability for the use, rectification, or deletion of the data.
- Upon receipt of the complete claim, a legend will be included in the database stating “Claim in progress” and the reason for it, within a period not exceeding two (2) business days. This legend must be maintained until the claim is decided.
- The maximum term for handling the claim will be ten (10) business days from the day following the date of receipt. When it is not possible to address the claim within this period, the data subject will be informed of the reasons for the delay and the date on which their claim will be addressed, which in no case shall exceed five (5) business days following the expiration of the initial term.
- It is necessary to clarify, regarding the exercise of the right to deletion of data, that this implies the total or partial elimination of the personal information of the data subject contained in the records, files, databases, or treatments carried out by the controller or processor.
- BONETE, as the controller, may refuse to delete the data when:
- The data subject has a legal or contractual duty to remain in the database.
- The deletion of data obstructs judicial or administrative actions related to tax obligations, the investigation and prosecution of crimes, or the updating of administrative sanctions.
- The data is necessary to protect the legally protected interests of the data subject; to perform an action based on public interest, or to comply with a legal obligation acquired by the data subject.
- BONETE will document and store the requests made by data subjects or interested parties in the exercise of any of the rights, as well as the responses to such requests.
Contact Methods
- For any inquiries, complaints, or exercise of rights, the data subject may contact datospersonales@bonete.app.
Use of Google Calendar Authentication
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- 8.1 By opting for Google Calendar authentication in Bonete, the client grants permission for Bonete to access certain data and permissions related to their Google Calendar account. This information will be used solely for the purpose of enabling synchronization between the Bonete platform and the client’s Google Calendar account.
- Bonete will only access specific and necessary information to perform synchronization, such as events, dates, and times. No other personal or confidential information of the client will be accessed without their express consent.
Sync Responsibility
- The client is solely responsible for the accuracy and truthfulness of the data and events in their Google Calendar account. Bonete is not responsible for errors or discrepancies in event synchronization.
- Bonete undertakes to make reasonable efforts to ensure adequate synchronization between the platform and Google Calendar. However, perfect synchronization at all times is not guaranteed due to possible technical limitations of third parties.
- Any modification or deletion of events in the client’s Google Calendar account through the Bonete platform will be directly reflected in the client’s Google Calendar account and vice versa.
Privacy and Security of Google Authentication
- Bonete undertakes to maintain the privacy and security of data obtained through Google Calendar authentication, following the standards described in the general Terms and Conditions.
- The client understands that authentication with Google Calendar may require authorization to access their Google account, and these permissions can be revoked at any time from the client’s Google account.
- Bonete will not store or retain confidential information from the client’s Google Calendar account beyond what is necessary for event synchronization.
Acceptance of Google Calendar Authentication Terms
- Activation of the synchronization function with Google Calendar in Bonete implies acceptance of these specific terms and conditions.
- If the client does not agree with any of these terms and conditions, it is recommended not to enable synchronization with Google Calendar in the Bonete platform.
- These terms and conditions complement and should be considered along with the general Terms and Conditions of use of the Bonete platform. By using Google Calendar authentication in Bonete, the client declares to have read, understood, and accepted these additional terms and conditions. If you have questions or need assistance, do not hesitate to contact us through the provided support channels.