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Privacy Policy for Users of Zitro Apps

Data Controller

We inform you that the personal data that you provide us in the framework of our contractual relationship will be processed by Zitro SARL, located at 17 Boulevard Royal, 2449 Luxembourg (Luxembourg) and registered at the “Luxembourg Trade and Companies Register” with the identification number B133648 and with tax number (VAT) LU22172122 (hereinafter, “Zitro”) for the purposes described below.

Unless expressly stated otherwise at the time of collection, all collected personal data is mandatory, as said data constitute essential elements for the management, maintenance and control of our contractual relationship. Not facilitating said data will imply the impossibility of processing your request or providing the contracted service. Personal data will be collected exclusively for the purposes indicated in this Privacy Policy.

You agree and acknowledge the veracity and accuracy of the provided data, and that it corresponds to your current status. In this regard, you agree to communicate any changes that may affect said data, in accordance with the procedure established in section “Data Subjects’ rights“.

Purpose of processing

This Privacy Policy sets down the processing of personal data carried out by Zitro in relation with the users that access or contact Zitro throughout its Apps.

Next, you are informed that your data will be processed by Zitro with the following purposes:

  1. I. Based on the contractual relationship:
    • a) To process your application for registration as a client in order to manage our commercial relationship with you.
    • b) To manage, maintain and ensure compliance with the contractual or pre-contractual relationship that binds us.
  2. II. Based on a legal obligation:
    • a) To communicate information to public authorities, regulators or governmental agencies in those cases required by law, local regulations or compliance with regulatory obligations.
  3. III. Based on the legitimate interest of Zitro:
    • a) To perform actions or commercial and/or advertising communications, by any means, including through electronic or equivalent communications, related to products or services similar to those contracted from Zitro.
    • b) To perform profiling based on personal data available to Zitro in order to determine the products and services that may best match your profile, in order to maximize their performance and bring you the best product and service offers that may be of interest to you.
    • c) To conduct satisfaction surveys related to the products and/or services contracted by you, in order to evaluate your satisfaction with them, for the purpose of improving Zitro’s processes and services.
    • d) To manage, process and respond to possible complaints and claims filed by you.
    • e) To perform audio and/or video recordings of you and so store telephone and/or video calls, when expressly indicated. The legitimate interests of Zitro are to maintain quality of service and use the recordings if necessary to protect its legal position in the face of potential conflict.
    • f) To share the data with the rest of Zitro Group’s companies as a consequence of the administrative and computer process centralization particular to the Zitro Group.
  4. IV. Based on your explicit consent:
    • a) If you so authorize it, Zitro can create a profile based on your consumption habits using both internal and external information originating, for example, from sources accessible to the public (promotional census, lists of people belonging to professional groups or open social networks, among others) in order to present you with special offers on products or services tailored to your needs, as well as communicate your data to third parties outside Zitro and who are advertising partners thereof. That is say, companies that allow Zitro to display advertising related to Zitro’s products and services, matching to your preferences when you visit other websites or make use of various social networks, even after the termination of this contract.

Recipients

In the terms described in section “Purpose of processing“, Zitro may communicate your personal data to the following entities:

  1. I. Public authorities, regulators or governmental or jurisdictional bodies in cases required by law, local regulations or compliance with regulatory obligations.
  2. II. Third parties and companies of the Zitro Group with the purposes described in section f) of item III) Legitimate Interest.

In addition to the previous data communications, Zitro collaborates with certain third party service providers that have access to your personal data and that process the aforementioned data in name and on behalf of Zitro pursuant to the provision of services.

Zitro follows strict criteria in its selection of service providers in order to comply with its data protection obligations and commits to signing the relevant data processing contract with them, which will impose, among other things, the following obligations: application of appropriate technical and organizational measures; processing of personal data for the agreed purposes and catering only to the instructions documented by Zitro; and deletion or return of the data to Zitro upon termination of the provision of services.

Specifically, Zitro will engage the provision of services by third-party suppliers that perform their activity, including but not limited to the following sectors: logistics services, legal advice, supplier certification, professional service companies, companies related to maintenance, companies providing technology services, companies providing IT services, physical security companies, instant messaging service providers and call centers.

Sources of the data

Regardless of the personal data you provide, Zitro may carry out the processing of personal data from general or sectoral joint exclusion files, and/or government agencies in accordance with the purposes and legitimizing bases described in the aforementioned “Purpose of processing” section.

In accordance with the above, Zitro will process personal data provided by the aforementioned third parties corresponding to the following categories:

  1. I. Identification data.
  2. II. Postal or electronic addresses.

Specially protected personal data is not obtained from third parties.

Data subjects’ rights

You may revoke the consents provided in the cases foreseen in this Policy at any time, at your simple request. We inform you that in accordance with current legislation you have the right to exercise your rights of access, rectification, erasure and opposition, as well as the right of withdrawal, limitation of processing and the right to portability of your data, by certifying your identity (by means of valid ID or equivalent) at the following address: ZITRO S.A.R.L., 17 Boulevard Royal, 2449 Luxembourg (Luxembourg), or the following email support@letswinup.com.

If you consider that Zitro has not respected any of the aforementioned rights, you will have the right to lodge a complaint with the Luxembourg Data Protection Agency and/or with your local Data Protection Agency.

Data Retention

Your personal data will be kept for the entire duration of the contractual relationship between you and Zitro.

Upon termination, we will proceed to the elimination of your personal data when all the necessary actions to manage and terminate any obligation that may remain between the parties have been taken, having carried out all the necessary administrative procedures, except in those cases in which the delivery of commercial communications is applicable.

Notwithstanding the foregoing, your data will be kept duly blocked, as long as responsibilities can be derived from the execution of our contractual relationship, as well as for the fulfillment of other legal obligations by Zitro.

In this regard, Zitro certifies that it will not process the data unless it is necessary for the formulation, exercise or defense of claims or when this is required to facilitate the same to Public Administration, Judges and Courts during the period of prescription of their rights or legal obligations.