ENPRIVACY POLICY
At DISRUPTING we understand that knowing how your personal information is used and
shared is important to you, so we take the privacy of your personal data seriously.
In the following text you will find more information about our Privacy Policy. By
using or accessing the Services in any way, you acknowledge that you accept the
practices and policies described in our Privacy Policy, and further agree that we
will collect, use, and share information in the ways described below. Remember that
by using DISRUPTING Services you are subject at all times to the Terms of Service,
which include this Privacy Policy. Terms used and not defined in this Policy have
the definitions given to them in the Terms of Service.
Please note that, in compliance with Article 30 and Third Transitory of the Federal
Law on Protection of Personal Data Held by Private Parties (“the Law”), DISRUPTING
has designated a compliance department in charge of processing requests from
holders, and to promote the protection of personal data within our company, who can
be contacted directly at our offices located at the address stated in the
aforementioned paragraph, or at the following e-mail address contacto@disruptinginc.com
What does this Privacy Policy cover?
This Privacy Policy covers our treatment of personally identifiable information
(hereinafter “Personal Information”) that we collect when you access or use our
Services, but it does not cover the practices of companies that we do not own, or
that we do not control, nor the people that we do not direct. As explained in more
detail below, we collect various types of personal information from our users, and
use this personal information internally in connection with our services, including
to personalize, deliver, and improve our services, in order to enable you to set up
a user account and profile, to contact you and allow other users to contact you, to
fulfill your requests for certain products and services, and to analyze how you use
said Services. In certain cases, we also share certain Personal Information with
third parties, but only as described below.
As noted in the Terms of Service, we do not knowingly collect or solicit personal
information from anyone under the age of 18.
Your personal data is very important to us, and will be treated based on the
principles of legality, consent, information, quality, purpose, loyalty,
proportionality, and responsibility in terms of the applicable legislation, in
adherence to the duties of security and confidentiality, and they will be used
exclusively for the purposes listed in our Privacy Policy.
Will DISRUPTING ever change this Privacy Policy?
We are constantly trying to improve our Services, so at some point we may also need to change this Privacy Policy, but in that case, we will notify you of any changes by posting a notice on our Services, or by sending an e-mail and/or through some other means. Please note that if you have opted out of receiving legal notice e-mails from us (or if you have not provided us with your e-mail address), such legal notices will still govern your use of the Services, and you will remain responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, this will mean that you accept all changes. In any case, we proceed to process your personal data in the manner indicated herein, and in strict adherence to it, the Law, its Regulations, and other applicable legislation.
What information does DISRUPTING collect?
DISRUPTING collects information that you provide to us.
We receive and store any information that you intentionally provide to us. For
example, through the registration process and/or through your account settings, we
may collect personal information, such as your name, e-mail address, date of birth,
social security number, telephone number, contact information, bank account,
taxpayer registration number, and third-party account credentials. We may ask you
for certain information to register with us or to use some of our features.
We will contact you if you have provided us with the means to do so. For example, if
you have provided us with your e-mail address, we may send you promotional offers by
e-mail on behalf of other companies or send you an e-mail about your use of the
Services. In the event that you do not wish to receive our communications, indicate
your preferences by following the opt-out instructions included in said e-mails, or
contact DISRUPTING at Av. Presidente Masaryk 29, Colonia Polanco V Section, Zip Code
11560, Miguel Hidalgo, Mexico City, Mexico.
Information that is collected automatically.
Each time you interact with our Services, we automatically receive and record
information from your browser or device in our server logs, which may include your
IP address, geolocation data, device identification, cookie information, type of
browser, and/or device you are using to access our Services, and the page or feature
you requested. “Cookies” are identifiers that we transfer to your browser or device
that allow us to recognize your browser or device and that tell us how and when
pages and features of our Services are visited and by how many people do so. You can
change the preferences in your device to prevent or limit the acceptance of cookies,
but this may prevent you from taking advantage of some of our features. Our
advertising partners may also transmit cookies to your browser or device when you
click on advertisements that appear on our Services. In addition, if you click on a
link to a third-party website or service, that third party may also transmit cookies
to you. Again, we reiterate that this Privacy Policy does not cover the use of
cookies by third parties, and we are not responsible for their privacy policies and
practices. It is important to note that cookies placed by third parties may continue
to track your online activities even after you have left our Services, and such
third parties may not honor “Do Not Track” requests that you have set up on your
browser or device. We may use this data to customize content we think you might like
based on your usage patterns. We may also use them to improve the Services: for
example, this data may tell us how often users use a particular feature of the
Services, and we may use that knowledge to make the Services interesting to as many
users as possible.
Information Collected from Other Websites and Third Parties and Do Not Track Policy.
Through cookies we place on your browser or device, we may collect information about
your online activity after you leave our Services. Like any other usage information
we collect, it will allow us to improve the Services, personalize your online
experience, and do certain other things described in this Privacy Policy. Your
browser may offer you a “Do Not Track” option, allowing you to tell operators pf
websites and web applications and services (including behavioral advertising
services) that you do not want those operators to track some of your online
activities over time and across different websites. Our Services do not currently
support Do Not Track requests, which means that we collect information about your
online activity while you use the Services and after you leave the Services. We may
also collect the following information, including Personal Information: • Social
Media Contacts. We collect information from your social media and other contacts if
you choose to share it with us. • Public information. We may collect publicly
available information about you. • Information from third parties. We may collect
and receive information about you, including Personal Information, from third
parties, including financial institutions and our service providers, for identity
verification, fraud protection, and other purposes. We may also receive demographic
information about you from third parties that will help us better understand our
users and improve and market our Services. Health information. If you or your
employer use the Services to administer your benefits or health benefits, we may
receive medical information about you and your dependents in order to provide the
Services in accordance with applicable law. Health information may include
information about your insurance company, insurance plan, and claims you submit for
coverage. We use administrative, physical, and technical measures designed to
protect your health information in accordance with applicable privacy and security
laws. • Market research programs. If you participate in a market research program or
survey, we may collect information about you, including Personal Information.
Will DISRUPTING share any Personal Information it receives?
We may only share your Personal Information with third parties as described below in
connection with the provision of the Services:
Information that has been de-identified. From time to time, we may de-identify your
Personal Information so that it does not identify you as an individual and we may
provide that information to the public in reports on the Services.
Advertisers: We allow advertisers and/or business partners (“Advertisers”) to choose
the demographic information of users who will see their advertisements and/or
promotional offers and you agree that we may provide any information we have
collected from you to any Advertiser for that it can select the appropriate audience
for said advertisements and/or offers. Through the Services we may send you a file
(known as a “web beacon”) from an advertising network. Web beacons allow ad networks
to provide us and advertisers with anonymous and aggregated audits, research, and
reports. Web beacons also allow ad networks to show you targeted ads when you visit
other websites. Because your web browser must request these ads and web beacons from
the ad network's servers, these companies can view, edit, or set their own cookies,
just as if you had requested a web page from their site. You can choose not to allow
the tracking of web beacons that third parties perform through our Services by
setting the Do Not Track option in your browser; Please note that we do not control
whether these third parties honor “Do Not Track” requests.
Related Companies: In certain situations, companies or third-party websites with
which we are related or affiliated may sell or provide products or services to you
through or in connection with the Services (either individually or jointly with us).
You can recognize when a related company is associated with such a transaction or
service, and we will share your Personal Information with that related company only
to the extent that it is associated with such a transaction or service. We have no
control over the policies and practices of third-party websites or companies
regarding privacy or any other matter, so if you decide to engage in any transaction
or service related to a related website or company, please review their entire
policies. of said companies or websites.
Our representatives or agents: We employ other companies and individuals to perform
tasks on our behalf and we need to share your information with those companies and
individuals, including our financial advisors, to provide products or services to
you. Unless we tell you otherwise, our representatives or agents are not permitted
to use the Personal Information we share with them beyond what is necessary to do
business with us
User Profiles and Information Submissions: Certain user profile information,
including your name, location, and any video or image content that user has uploaded
to the Services, may be displayed to other users to facilitate user interaction
within the Services. the Services or fulfill your requests for our Services.
Remember that any content you upload to your user profile, along with any Personal
Information or content you voluntarily disclose online so that other users can see
it, will be publicly available and can be collected and used by anyone.
Business Transfers: We may choose to buy or sell assets, and we may share and/or
transfer customer information in connection with evaluating and closing such
transactions. In addition, if any entity buys our business (or our assets), or if we
go out of business, declare bankruptcy, or undergo some other change of control,
Personal Information may be one of the assets that is transferred to or acquired by
a third party.
Protection from DISRUPTING and Others: We reserve the right to access, read, retain,
and disclose any information we deem necessary to comply with either the law or a
court order, including providing such information to our legal counsel; enforce or
apply our Terms of Service and other agreements; or protect the rights, property, or
safety of DISRUPTING, our employees, our users, or others. For the avoidance of
doubt,
contacto@disruptinginc.com may also
share your information, including Personal Information, with the following persons
and entities:
- • • Banks and other financial institutions;
- • • Government agencies and tax authorities, as required to provide the Services;
- • • Group health plans, insurance companies and other third parties, such as doctors, hospitals and pharmacies, as necessary for these any Services related to benefits and benefits; and
- • • Credit Rating Agencies: You authorize contacto@disruptinginc.com to obtain credit reports about your business and to report negative credit information about your business to others, including, without limitation, to the appropriate taxing authorities;
Is my Personal Information safe?
Your account is password protected for privacy and security purposes. To prevent unauthorized access to your account and Personal Information, you must select and protect your password appropriately, and you must limit access to your computer or device and browser by logging out after you have finished accessing your account. We strive to protect the privacy of your account and other Personal Information we have on file, but unfortunately, we cannot guarantee complete security. Unauthorized access or use and other factors may compromise the security of user information at any time.
What Personal Information can I access?
Through your account settings option, you can access and, in some cases, edit or delete the Personal Information that you have provided to us. The information that you can view, update, and delete may change as the Services change. If you have any questions about how to view or update the information we have on file about you, please contact us at contacto@disruptinginc.com
What are my options?
You can always choose not to disclose information to us, but please note that you may need to provide certain information to register with us or to use some of our features. As we explained before, you may be able to add, update, or delete information. However, when you update the information, we may keep a copy of the out-of-date information in our records. Certain information may remain in our records after you delete such information from your account. We may use any aggregate information derived from or incorporating your Personal Information after you update or delete it, but not in a way that personally identifies you.
ARCO rights and their exercise
You, as the owner, have the right to: (i) have access to your personal data in our possession and know the details of their treatment, (ii) rectify your personal data if it is outdated, inaccurate or incomplete, (iii) cancel your personal data when you consider that they are not being used in accordance with the applicable principles, duties and obligations, to the extent that they are not necessary to comply with the obligations derived from our employment relationship and as permitted by the applicable legislation, or (iv) oppose the processing of your personal data for specific purposes. These rights are known as the “ARCO Rights”.
Exercising ARCO rights
The request to exercise ARCO Rights must be submitted at our address located at Av.
Presidente Masaryk 29, Polanco V section, C.P. 11560, Miguel Hidalgo, Mexico City,
Mexico, addressed to the attention of the compliance department
contacto@disruptinginc.com, accompanied by the following information and documentation:
Identification data of the owner of the personal data and/or his legal representative.
In the event that the application is submitted through a legal representative, a copy of
the document proving that character must be attached.
The clear and precise description of the personal data with respect to which you seek to
exercise the ARCO Rights, as well as the right or rights you wish to exercise. The
request must be signed at the end of the document and initialed at the bottom of each
page.
Address to hear and receive the response from DISRUPTING, and, where appropriate, future
communications and/or notifications, or your wish that our response and/or future
notifications or responses be sent via email, indicating the respective account.
Copy of the current official identification of the owner of the personal data and, where
appropriate, of his legal representative.
Once the request to exercise ARCO Rights is at our disposal, regardless of the form in
which it is received, the response will be issued within a period not exceeding 20
(twenty) business days from its receipt. Which we will inform you through the chosen
means of contact. Once DISRUPTING's response is received, you will have a period of 15
(fifteen) business days to issue your response. The aforementioned deadlines could be
extended only once for an equal period, as long as the circumstances of the case justify
it.
If you are dissatisfied, you can contact us immediately through the indicated means,
remaining at your entire disposal to address any concerns. If you do not respond to our
response within the indicated period, we will understand in good faith that you agree
with the response.
If the request to exercise ARCO Rights is about the exercise of the right of access, we
will make your information or personal data available to you through simple copies
and/or electronic documents.
As responsible, we may deny the exercise of ARCO Rights in the cases permitted by the
Law and its Regulations, for which reason you must be informed of the reason for said
refusal. The refusal may be partial, in which case we will make the access,
rectification, cancellation or opposition in the appropriate part.
Revocation of consent to the processing of your Personal Data
You, as the owner of the Personal Data, can revoke your consent for the processing of your personal data following the same procedure as for the exercise of your ARCO Rights, in the understanding that once your request for revocation is at our disposal, we will issue our response within a maximum period of 5 (five) business days.
Options to limit the use or disclosure of your Personal Data
You, as the owner of your personal data, can limit the use or disclosure thereof by following the same procedure as for the exercise of your ARCO Rights, in the understanding that once your request is at our disposal, we will issue our response in a period of no more than 5 (five) business days.
What if I have questions about this policy?
If you have any questions or concerns regarding our privacy policies, please send us a detailed message at contacto@disruptinginc.com e and we will try to resolve your concerns.