Privacy Policy

Effective Date: [19.08.2024]

SCOPE

This Privacy Policy (“Policy”) describes how ALTKEY ESA, S.A.S. DE C.V., with NIT 0623-230724-105-6 an El Salvador Corporation (Sociedad de Acciones Simplificadas de Capital Variable) treats personal information that you provide to us through the website on which this Policy is located or through any other method of contact (for example, by email, online forms, attending one of our events or using any of our services) (together, the “Platform”).

NOTICE AT COLLECTION

We collect, and in the past 12 months have collected, the following categories of information from and about you: contact information, identifiers; commercial information; internet or similar network activity; biometric information; geolocation data; audio, electronic, visual or similar information; professional information; education information; and inferences drawn from other personal information. We collect these categories of information from you in order to provide our services to you, to run our business, to communicate with you, and as required by law. We may have disclosed each of these categories of personal information for a business purpose as described below. We have not “sold” personal information in the past 12 months, as that term is defined by the CCPA.

However, we may have “shared” personal information, including identifiers, commercial information, and internet or similar network activity information with third parties for cross-contextual marketing purposes in the past 12 months. For a description of your rights under applicable privacy law, and instructions on how to exercise your rights including opting out of cross contextual marketing on the Platform, please see the Your Privacy Rights section below.

We will retain each of these categories of personal information based on several factors, including is reasonably necessary to (i) provide our products and services or administer our relationship with a consumer; (ii) protect our business, employees, organization, and others; (iii) fulfill our legal and regulatory obligations; and (iv) investigate and address issues which may include safety concerns, potential security incidents or policy violations.

TYPES OF INFORMATION WE COLLECT

We collect information from you and about you. Here are some examples of the information we may collect:

Contact Information. For example, we may collect your name, mailing address, telephone number and email address. We may also collect your mobile phone number.
Information You Submit. We may collect information when you submit a contact form or submit other similar forms that are available through the Platform.
Payment Information. When you purchase an event ticket, we, through our third-party vendors, will collect your payment information.
Attendance Details: If you attend one of our events (in-person or online), your attendance details (for example, your entry time) and your image and/or voice, such as through event recording or CCTV.
Device Information. For example, we may collect the type of device you use to access our Platform. We may also collect your device identifier, IP address or mobile operating system.
Professional Information. For example, we may collect your company name, job title, and other professional information.
Commercial Information. We may collect personal information that could identify you and relates to the services in which you are interested or have considered. We may also collect personal information about your consuming history or tendencies.
Location Information. We may collect information relating to your general location based on your IP address.
Other Information. If you use our website, we may collect information about the browser you are using. We might look at what site you came from, or what site you visit when you leave us.

HOW WE COLLECT YOUR INFORMATION

We collect your information in different ways. Below are some examples of how we may collect your information.

Directly From You. For example, when you submit an inquiry to us, sign up for or attend an event, or otherwise interact with us on the Platform.
Passively. For example, when you visit and navigate our Platform on any device. We may also collect information about users over time and across different websites and devices when you use the Platform.
From Third Parties. We may receive information about you from other sources. For example, this may include receiving information from our business partners, including analytics vendors.
By Combining Information. For example, we may combine information that we collect offline with information we collect through our Platform. We may also combine information we collect about you from the different devices you use to access our Platform.

HOW WE USE YOUR INFORMATION

Examples of how we may use your information include:

To Run and Improve Our Platform and Business. We may use your information to make our Platform and business better. We may also use your information to provide you with information about our business or our initiatives.
To Respond to Your Requests or Questions. This may include responding to your feedback.
To Communicate With You. We may communicate with you about your account or our relationship. We may also contact you about this Policy or our Platform terms and conditions.
For Marketing Purposes. We may provide you with information about our company and our business initiatives. For more information about your choices related to these communications, see the Choices section below.
For Security Purposes. This could include protecting our company and consumers who attend our events or use our products and services. It may also include protecting our Platform.
As Otherwise Permitted By Law or As We May Notify You.
As Requested or Directed By You.

HOW WE SHARE YOUR INFORMATION

We may share your information in the following ways:

Internally. We may share your information with our parent, subsidiary, and affiliate entities.
With Our Service Providers. We may share your information with third parties who perform services on our behalf. For example, this may include companies that send emails on our behalf or help us run our Platform. It may also include vendors and venues that help us host events.
With Event Sponsors. If you register for, or attend, one of our events, we may share your registration information with sponsors of that event.
With Our Business Partners. For example, we may also share personal information with social media sites, advertisers, media buying agencies, advertising networks and advertising service providers for the purposes described in this Policy. We may also share personal information with companies that help us learn more about our partners.
With Any Successors to All or Part of Our Business. For example, if we merge with, are acquired by, or sell part of our business to another entity. This may include an asset sale, corporate reorganization or other change of control.
To Comply With the Law or To Protect Ourselves. For example, this could include responding to a court order or subpoena. It could also include sharing information if a government agency or investigatory body requests. We might share information when we are investigating a potential fraud.
For Other Reasons We May Describe to You.
As Requested or Directed By You.

CHILDREN UNDER 13

The Platform where this Policy is located is meant for adults. We do not knowingly collect personally identifiable data from persons under the age of 13. If you are a parent or legal guardian and think your child under 13 has provided us with information, please contact us at pbf-es@planblugano.zendesk.com. You can also write to us at the address listed at the end of this website Policy. Parents, you can learn more about how to protect children’s privacy on-line here.

CHOICES REGARDING YOUR INFORMATION

You have certain choices about how we use your information. Certain choices you make are browser and device specific.

Marketing Communications:

You can opt out of receiving our marketing communications. Note that you will still receive transactional messages from us, including information about your account and responses to your inquiries.

Cookies & Other Tracking Technologies:

Cookies: You can adjust your browser to control cookies to require your affirmative acceptance for new cookies, automatically reject cookies and/or delete or disable existing cookies. How you do so depends on the type of cookie and the browser that you are using. For more information on how to control browser cookies, click here. If information about your browser is not available through this page, please search your browser for instructions about how to opt-out of cookie collection.
Matamo: We may use Matamo on our Platform to help us understand how you use our Platform.

YouTube: We may use YouTube cookies to help us understand how you use our Platform. Read more at YouTube’s embedding videos information page.

Email Tools: You can also change your email settings to block the automatic download of images in email messages, as such images may contain technologies that help us understand how you interact with the message.
Note that deleting or blocking cookies may impact your experience on our website, as some features may not be available. Certain options you select are browser and device specific.

Our Do Not Track Policy:

Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals. If you block cookies, certain features on our sites may not work. If you block or reject cookies, not all of the tracking described here will stop.
Options you select are browser and device specific.

YOUR PRIVACY RIGHT

Based on your state or country of residence, you may have the rights listed below with respect to the personal information that we maintain about you. We may take steps to verify your identity, as permitted or required under applicable law, before we process your request. Verification may include asking you to provide information about yourself that we can match against information already in our possession.

Notice. This means that you can request that we disclose what personal information we have collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we have disclosed personal information, and the specific pieces of personal information we have collected about you.
Deletion. This means that you can request that we delete personal information about you which we have collected from you.
Correction. This means that you can request that we correct inaccurate personal information that we maintain about you.
Limit the Use or Disclosure of Sensitive Personal Information. The California Consumer Privacy Act (“CCPA”) provides a right for consumers to request that business limit the use or disclosure of their “sensitive” personal information. In our normal business operations, we do not process “sensitive personal information” as that term is defined under CCPA. Please do not submit this information to us.
Opt-Out of the Sale or Sharing of Personal Information. You may have the right to opt out of the “sale” or sharing of personal information with third parties for cross-contextual marketing purposes. We do not knowingly “sell” any personal information, including any personal information relating to consumers under the age of 18. If you would like to opt out of our sharing of your personal information for cross-contextual marketing purposes, you may modify the cookie settings on the Platform by clicking on the Consent Preference at the left bottom corner of the landing page and confirm your preference.
Withdraw Consent. You may withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Agents that you have authorized to act on your behalf may also submit requests as instructed below. The agent must also provide evidence that they have your written permission to submit a request on your behalf. If we are unable to verify the authenticity of a request, we may ask you for more information or may deny the request.

Individuals who wish to exercise their rights under this section can contact us at pbf-es@planblugano.zendesk.com. Please include your name, email address, state of residence, and indicate you are making a “Privacy Rights” request. If we deny your rights request and you would like to appeal, you may contact us at pbf-es@planblugano.zendesk.com.

Should you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you may contact the supervisory authority of your country.

Security

The Internet is not 100% secure. We cannot promise that your use of our Platform will be completely safe. We encourage you to use caution when using the Internet. We use reasonable means to safeguard personal information under our control. A user id and a password are needed to access certain areas of our Platform. It is your responsibility to protect your username and password.

STORAGE AND TRANSFER OF INFORMATION

Information we maintain may be stored in or outside of your country. You understand and agree that we may transfer your personal information to other countries, including El Salvador and the United States. This Platform is subject to the laws of El Salvador, which may not provide the same level of protections as those in your own country. Personal information processed and stored in another country may be subject to disclosure or access requests by the governments, courts or law enforcement or regulatory agencies in that country according to its laws.

By using our Platform or by providing us with personal information, you consent to any such transfer of information outside of your country.

LINKS

Our Platform may contain links to other third-party sites that are not governed by this Policy. If you click on a link to a third-party site, you will be taken to a site we do not control. We are not responsible for the privacy practices used by third-party sites. We suggest that you read the privacy policies of those sites carefully. We are not responsible for these third-party sites.

HOW TO CONTACT US

If you have any questions, comments or concerns with respect to our privacy practices or this Policy, or wish to update your information, please feel free to contact us at pbf-es@planblugano.zendesk.com or by telephone at +41 (0)76 460 83 14. You may also write to us at the following address:

ALTKEY ESA, S.A.S. DE C.V., with NIT 0623-230724-105-6 with its registered office at Entre 63 y 65 Avenida Sur, Pasaje 1, Casa 1, Colonia Escalón San Salvador, El Salvador – Re: Plan B – El Salvador Privacy Policy

CHANGES IN POLICY

From time to time, we may change our Policy. We will notify you of any material changes to our Policy as required by law. We will also post an updated copy on our Platform. Please check our Platform periodically for updates.