Privacy Policy

Introduction

This document (hereinafter, the "Privacy Policy") describes the types of personal data that Tandu Webs LLC, the owner and developer of Wapu (hereinafter, "Wapu"), collects through the website [wapupay.com](https://www.wapupay.com) and its mobile application, how we use your data, to whom we communicate it, and the rights and options we provide you regarding the use of your personal data and the exercise of your data subject rights. We also describe the measures implemented to protect the security of the personal data collected and how users can contact us to learn about our privacy practices. The entity responsible for processing personal data is Tandu Webs LLC, located in the United States. By using Wapu, you expressly, informedly, voluntarily, and unequivocally consent to the inclusion of all your personal data provided through Wapu in the databases owned and managed by Wapu, as well as to the processing of all your personal data for the purposes described in the following sections of this document and subject to the terms and conditions established herein. By accessing, connecting to, or otherwise using Wapu, you confirm that you have read, understood, agree with, and accept the terms and conditions of this Privacy Policy. If you do not agree with the terms of this policy, you should not use Wapu.

Data Collected

Through Wapu, we collect certain data, including personal data. Personal information is information that can identify you. For Wapu, your privacy and the security of your information are very important. Therefore, we will only request the strictly necessary data for you to use the services that Wapu offers. To this end, Wapu may request and process the following data (this list is not exhaustive): contact details (such as name and surname, addresses, phone number, email); identification numbers; demographic data (such as nationality; date and place of birth, age, gender); a "selfie" photograph; social media information provided by you; status as a politically exposed person; declaration on the origin and legality of funds; and information you provide in relation to your inquiries or comments. We collect this data at the time of your registration, during each update, and also collect personal information about you when you provide information directly to us or interact with us through Wapu. In the case of underage users, we also require authorization from an adult user and clarification of the relationship between them.

Regarding your personal data contained in your National Identity Document, which includes your biometric fingerprint and facial recognition data derived from the selfie photograph you send us, you consent that they be compared with what is reported by the web service of the National Registry of Persons ("RENAPER") and be processed by other identity verification service providers. This specific processing is carried out exclusively to validate the identity and validity of the National Identity Document. Additionally, it is made known that the data referred to in this paragraph are mandatory to ensure the correct identification process and that as a data subject, you may exercise your rights of access, rectification, and deletion of your data at any time upon request to RENAPER.

Furthermore, Wapu may collect information about the devices on which the application is installed, such as those related to the mobile operator, brand, model, and operating system of the device, geolocation, and may monitor traffic, views, interactions, and any other activity on the application (these data may be collected through cookies, web beacons, pixels, canvas fingerprinting, and/or similar technologies). You will be solely responsible for the truthfulness, accuracy, completeness, validity, authenticity, and certainty of the information provided and must notify Wapu of any updates or modifications immediately. Notwithstanding the foregoing, Wapu may verify personal data and/or information provided – by itself or through third parties – using public entities, specialized companies or credit bureaus, among others, which you expressly consent to.

If you do not provide the mandatory personal data for registration and use of services or if falsehoods and/or inaccuracies are detected in the personal data provided, Wapu may suspend and/or cancel your account and/or partially or totally disable your access to Wapu's application and/or services. This does not preclude Wapu from reporting such falsehoods and/or inaccuracies to third parties and/or competent authorities.

Purpose of Processing Personal Data

The data we collect may be used for the following purposes: providing Wapu's services and those of other third parties offering services on Wapu's application; allowing you access to the application and its functionalities; communicating with you; sending promotional materials and other communications; responding to your inquiries; personalizing user preferences and visits to Wapu; offering content tailored to your interests and how you navigate and interact with Wapu; operating, evaluating, and improving our products and services; collecting supporting documentation and other data justifying any type of operation or transaction; complying with legal requirements; preventing illicit activities such as money laundering, tax evasion, fraud; enforcing applicable legal requirements; industry standards; contractual obligations; and our policies. If we intend to use your personal data differently from what is described above, we will inform you specifically at the time of collection. Additionally, through Wapu, we may use third-party analytics services. The web analytics service providers managing these services use technologies such as cookies, web server logs, and web beacons that help us analyze how users use Wapu. The information collected by these means (including IP address) may be disclosed to these analytics service providers as well as other third parties who will use the collected information for purposes such as evaluating Wapu's usage.

Finally, Wapu may contract third-party "analytic solutions" that process collected data from Wapu's application or website regarding visited screens, interaction patterns (such as screen actions, gestures: clicks, scrolling), and device details used to access Wapu's application or website (type, version, model, operating system). This information is used to improve our application. These solutions do not process or collect personal data that allows identifying individual user movements nor track their browsing habits on applications so their processing is not covered by Personal Data Protection Law No 25.326.

Information We Share

The personal data we collect through Wapu may be disclosed to third parties only as described in this Privacy Policy. The personal data collected through Wapu may be communicated for fulfilling the aforementioned purposes to our affiliates and associated entities, branches, agencies, representations, parent companies, subsidiaries, controlled entities linked to Wapu or with which Wapu has a commercial relationship for providing services such as our strategic partners related to certain products we offer. We will also disclose such personal data to service providers who provide services on our behalf according to our instructions and for purposes detailed in this Privacy Policy such as our hosting service providers cloud storage call centers among others. In no case do we authorize these service providers to disclose or reveal your personal data except for those uses strictly necessary for providing services on our behalf or complying with legal obligations.

Wapu understands the importance of maintaining confidentiality over all collected data respects Personal Data Protection Law No 25.326 applicable thereto thus it is made known that those involved in any phase of processing personal data are bound by professional secrecy regarding them while Wapu signs confidentiality agreements implements policies processes ensuring secrecy over processed personal data.

We may also disclose your personal data (i) if required by applicable law (including but not limited to Central Bank Republic Argentina ("BCRA"), Financial Information Unit ("UIF"), Federal Administration Public Revenue (AFIP), National Social Security Administration (ANSES) among others); (ii) within judicial proceedings or compliance with competent authority requests; (iii) law enforcement bodies public officials when legitimately requested; (iv) when deemed necessary convenient preventing physical harm economic losses; (v) within investigations fraudulent illegal activities presumed fraudulent illegal activities.

Lastly authorizes transferring personal data case sale transmission whole part company assets including restructuring dissolution liquidation regarding information provided Central Debtors BCRA made known within ten days request latest classification assigned along justifying reasons according evaluation performed entity total debt amount financial system classifications arising latest available information "Central Debtors Financial System". Information rights access knowledge credit information registered person Central Debtors BCRA available: [BCRA Credit Situation](https://www.bcra.gob.ar/bcrayvos/Situacion_Crediticia.asp)

Data Transfers

You understand consent personal data collected through Wapu may be transferred purposes detailed above subjects listed above possibly involving international transfers jurisdictions lacking same level protection existing Argentina providing adequate protection levels under local regulations when transferring personal data other countries protecting described herein accordance applicable legislation thus made known whenever required regulation implemented safeguards ensuring adequate protection level terms law provisions Public Information Access Agency.

Security of Your Personal Data

The collected data will be kept strictly confidential reserved only used extent relationship with Wapu remains valid usage strictly necessary fulfilling purposes detailed above complying all applicable regulations particularly Personal Data Protection Law No 25.326 complementary norms hereinafter "Personal Data Protection Regulations". All stored within database owned registered National Personal Data Protection Registry ensuring security criteria diligence applied safeguarding own information maintaining administrative technical physical security measures designed protecting provided personal data against accidental illegal unauthorized destruction loss alteration access communication usage thus preventing unauthorized access maintaining accuracy ensuring correct usage provided online applying certain physical electronic administrative security procedures safeguarding securing collected online continuously evaluating new technology protecting information guaranteeing internal processes databases comply legal security confidentiality obligations imposed Personal Data Protection Regulations however acknowledges existing technical means providing security are not impregnable even adopting reasonable security precautions possible suffering manipulations destruction loss information finally believes interaction no longer secure example believes account security compromised notify immediately problem using any communication channels.

User Rights Choices

Wapu presumes veracity all provided information consequently does not verify nor assumes obligation verifying veracity validity sufficiency authenticity provided assumes responsibility keeping updated all times accessing modifying rectifying deleting updating personal data anytime contacting us accessing free provided intervals no less six months unless legitimate interest effect according Personal Data Protection Regulations incorrect wishes update rectify delete update correct delete request without cost exercising access rectification updating deletion rights according Personal Data Protection Regulations email  indicating right wants exercise complying identity verification process indicated effect stored while relationship remains valid ten years thereafter additional period required applicable legislation accounting legal purposes Public Information Access Agency control body Law No 25.326 authority handling complaints claims non-compliance personal data protection norms.

Links Other Websites

Wapu may contain links other websites convenience information operated companies unrelated usually linked websites own privacy policies notices recommend reading visiting linked websites assumes responsibility content websites different own nor usage practices privacy.

Updates Privacy Policy

Wapu reserves right making modifications updates Privacy Policy anytime without prior notice reflecting changes introduced practices regarding personal data according Personal Data Protection Regulations substantial changes notifying previously email push notification App publishing updated version Privacy Policy website [wapupay.com](https://www.wapupay.com) indicating last modification date modifications Privacy Policy effective date notification within ten days following notification modifications introduced communicate email non-acceptance dissolving contractual relationship expiration period considered acceptance new Privacy Policy continuing binding both parties publication interaction after introduction modifications signifies acceptance modifications.

Contact Information
Phone: 
If you wish contacting updating exercising rights queries regarding scope policy concerns privacy security provided information contact directly email