Privacy Policy

Last modified: September 22, 2023

This Privacy Policies describe the types of personal data that the Company may collect through the Platform, how we use user data, to whom we communicate them and the rights and options that we make available to the users of our Platform regarding the use we make of their personal data and the exercise of the rights of the owners of the data. We also describe the measures implemented to protect the security of personal data collected and how users can contact us to learn about our privacy practices.

The user of the Platform expressly, informed, voluntarily and unequivocally consents to the inclusion of the personal data provided to the Company in its databases, as well as to the processing of their personal data by automated and non-automated means for the purposes described in the following sections of this document and subject to the terms and conditions set forth herein.

By accessing, connecting or using the Platform in any other way, you confirm that you have read, understood, and accepted these provisions regarding the Company’s privacy policies, as well as Fortress Trust LLC and Fortress Blockchain Technologies Inc (together, “Fortress”) privacy policies, available at https://fortresstrust.com/legal-privacy and https://fortress.io/privacy-policy/. In case you do not agree with both Ping’s and Fortress’s privacy policies, refrain from accessing the Platform and using it in any way.

DATA COLLECTED

Through the Platform we collect certain data, which can be inclusive of a personal nature. Personal information is information that can identify you, such as your name, address, bank account number, biometric data, telephone number, email address, a photograph of your face and a photograph of your National Identity Document. We collect your personal data when you provide that information directly to us, even when you register or when you interact with us through our Platform. You are responsible for the accuracy of the personal information you provide to the Company and will be responsible for the consequences of providing false or inaccurate information.

Among the types of personal data we collect are the following:

– Contact information (such as name, current address, postal address, email address and telephone number);

– Demographic data, including date of birth and gender;

– Photographs of your face (the “Selfie Picture”);

– Photographs of your National Identity Document (the “ID Picture”);

– Bank account data;

– Information that the user provides in relation to their questions or comments.

TREATMENT OF PERSONAL DATA

The data we collect can be used for the following purposes:

– Communicate with you;

– Review the authenticity and validity of the photographs that you submit;

– Send you promotional materials and other communications;

– Answer your questions;

– Customize preferences and visits to our Platform and offer content tailored to your interests and the way you navigate and interact with our Platform;

– Operate, evaluate and improve our products and services; and

– Comply with and enforce the applicable legal requirements, the corresponding industry standards, contractual obligations and our policies.

In the case that we are going to use your personal data differently from the one described above, we will communicate it in a timely manner.

Through our Platform, we can also use third-party analytical services. The web analysis service providers that manage these services use technologies such as cookies, network server logs and web beacons that help us analyze the use that users make of our Platform. The information collected by these means (including the IP address) may be brought to the attention of the providers of such analytical services as well as other third parties that will make use of the information collected to, among other purposes, evaluate the use of the Platform.

Ping may also use third-party providers in order to validate your identity. This identity verification services leverage certain technologies in order to detect face liveness and validate the Selfie Picture, as well as to compare it with your ID Picture.

INFORMATION WE SHARE

The personal data of the users that we collect through the Platform may be disclosed to third parties only in accordance with what is described in these privacy policies. Personal data collected through the Platform may be communicated to our subsidiaries and associated entities for the purposes described above. We will also communicate such personal data to service providers that provide services on our behalf in accordance with our instructions and for the purposes detailed in these Privacy Policies. We do not authorize such service providers to disclose or disclose the personal data of users except for those uses that are strictly necessary for the provision of the services or to comply with legal obligations.

The Company understands the importance of maintaining the confidentiality of all data that could be collected. Consequently, the Company undertakes, in order to guarantee such confidentiality, to sign confidentiality agreements with each of the parties that carry out the processing of personal data. The Company and those involved in any phase of the processing of personal data are bound to professional secrecy regarding them.

Likewise, we may disclose your personal data (i) if we are obliged to do so by law or within the framework of a legal procedure, (ii) to the security forces and bodies or other public officials when they legitimately request it, (iii) when we consider that such disclosure is necessary or convenient to avoid physical damage or economic loss, (iv) in the context of an investigation of fraudulent or illegal activities, or that fraudulent or illegal activities are presumed or (v) in case of sale or transfer of the totality or a part of our company or our assets (including cases of restructuring, dissolution or liquidation).

INTERNATIONAL DATA TRANSFER

Your personal data collected through the Platform may be transferred for the purposes described above to entities located in other countries. These countries may not have the same data protection regulations as in your country. In this regard, we inform you that we have implemented safeguards that guarantee an adequate level of protection of personal data when they are transferred to other jurisdictions. These safeguards include contractual clauses or commitments aimed at imposing compliance with the applicable and its complementary regulations. In any event, when using the services of the Platform you are aware of the international transfer of your personal data as indicated in this section.

THE RIGHTS OF THE USER

You may request access, update, modification, review and deletion of your personal data as well as the removal or blocking of your name from the database referred to in this Privacy Policy at the time you wish by contacting for this purpose with us as indicated in the section entitled «Contact Information» of this document.

The right of access to the data may be exercised in accordance with the requirements of the applicable law. 

In the event of any request, you must provide documentation that allows your identification to prove identity and provide the Company with a means to contact you if necessary.

SECURITY OF YOUR PERSONAL DATA

We implement administrative, technical and physical security measures designed to protect your personal data against destruction, loss, alteration, access, communication or accidental, illegal or unauthorized use.

Thus, to prevent unauthorized access, maintain the accuracy of the data and ensure the correct use of the personal data that it provides to us, the Company has put into use certain physical, electronic, administrative and security procedures. We safeguard personal data according to established security standards and procedures and continuously evaluate new technology to protect that information.

However, you acknowledge that the existing technical means that provide security are not impregnable and that even when all reasonable security precautions are adopted it is possible to suffer manipulation, destruction and / or loss of information. Finally, if you believe that your interaction with us is no longer secure (for example, if you believe that the security of an account you have with us has been put at risk), notify us immediately of the problem using the communication channels in the section «Contact Information».

LINKS TO OTHER WEBSITES

Our Platform may contain links to other websites for convenience and user information. These websites may be operated by companies that are not linked to us. Usually, linked websites have their own privacy policies or notices, which we recommend that the user read carefully if they visit any such linked websites. We do not assume any responsibility for the content of websites other than ours, nor for the use made of such websites, nor for their privacy practices.

UPDATES TO THIS PRIVACY POLICY

These privacy policies may be subject to periodic updating and without prior notice to reflect the changes introduced in our personal data practices. In the case of substantial changes, we will notify you by a visible notice on our Platform or by sending an email to the address declared at the time of creating your user account, indicating at the bottom of the privacy policies the date of Your last update. Any modification of these privacy policies will take effect from the moment of its publication on the Platform. Your interaction with us after the introduction of these modifications will mean that you have accepted those modifications.

CONTACT INFORMATION

Users can contact us to update their data or exercise their rights in accordance with these privacy policies by sending an email to info@holaping.com