The Privacy Policy of www.smartfense.com is applicable to all users of the website and of its services from the moment of acceptance of the Terms and Conditions of Use, and its aim is that Users know how DIGITAL CONTENT MACHINE S.A., CUIT 30-71517937-3, located at Salta 182, San Francisco, Córdoba, Argentina (hereinafter, the Company) will treat your personal data. }

1. General Provisions

Users’ personal information is extremely important for the Company. That is why we use all administrative and technical resources within our reach as well as all legal safeguards necessary to ensure the personal data and privacy protection. This Privacy Policy applies to all Users’ personal information obtained as a result of the use of the website and the contracting of the services offered therein.

2. Data collection methods

The Company will collect Users personal data through forms and interactions within the website, from business contracts made and electronic communications established with the Users. It will not be necessary to provide any personal data for browsing the webpage.

3. Purpose

In compliance with the provisions of Law 25.326, Sec. 2, 7 and 8, the Company will not request information that is incompatible with the purpose of the website or its services, or that directly or indirectly reveals sensitive data of Users, such as data that reveal racial or ethnic origin, political opinions, religious, philosophic, or moral convictions, union membership, information regarding health or sexual life. In the same way, the Company suggests that Users should not include this information in their communications or interactions through the website.

4. Collected data

The personal data that the Company collects through the website are name, last name, email and data that could be obtained in the subject and the body of the message. The data obtained from hiring its services are name, last name, company name, email, address, telephone number, tax identification, tax situation, bank details.

5. Confidentiality

Personal information is completely confidential and the Company will take security measures to avoid its unauthorized use in accordance with the provisions of Law 25.326 of Personal Data Protection of Argentina, and in accordance with privacy normative standards of the European Union and Latin America.
Private communications that may occur between the Company’s staff and Users or visitors will also be considered as confidential. The access to all this information will be restricted by technological tools and strict internal controls.
However, electronic communications between the User and the Company with suggestions and inquiries and/or in compliance with conditions of promotions, contests or publicity will not be considered confidential.

6. Information Administration

The data obtained is added to a database ownership of the Company, responsible both for its management and its treatment. The Company will use the information for the following purposes: a) identification and authentication, b) administration and commercial management, c) service improvement, d) statistics purposes, e) delivery of informative newsletters regularly, f) delivery of material, notifications, promotions or publicity and similar activities. Personal data will not be disseminated or used for a different or incompatible purpose to the mentioned one when entering them to the database.
The company may employ other companies and/or natural persons to perform tasks or functions on their behalf. Among the examples of this type, we can mention sending postal and electronic mail, sending regular communications, removing repetitive information from user lists, analyzing data in statistical form, etc. These companies and/or persons have access to personal information necessary to fulfill their tasks and functions, but they cannot use it for other purposes.
If it were a communication of direct publicity not required or previously consented by the User, the Company will grant the possibility of being removed of blocked from this specific database.
In case of assignment or use for a different purpose, the Company will request Users’ free, express and informed consent. In case of sale, assignment, merger, consolidation, sale of all or a substantial part of its assets, the Company may disclose or transmit this information to third parties.

7. Database Registry

The data collected by the website are added to a database of which the Company is responsible. It is registered at the National Directorate for Personal Data Protection of the Ministry of Justice and Human Rights of the Nation (Argentine Republic) under registry no. 33.313 in compliance with the provisions of Law 25.326, Sec. 3.
The National Directorate for Personal Data Protection, Body for the control of Law 25.326, has the power to deal with complaints and claims related to failure to comply with the rules on protection of personal data. The website for consulting about registered taxpayers is www.jus.gob.ar/datospersonales

8. Rights

The User has the power to exercise the right to access their data free of charge at intervals of no less than 6 months, unless a legitimate interest to that effect is accredited, as established in Law 25.326, Sec 14, Subsection 3. The National Directorate for Personal Data Protection, Body for the control of Law 25.326, has the power to deal with complaints and claims related to failure to comply with the rules on protection of personal data.
Likewise, it is hereby stated that the owner of the data may at any moment request the removing or blocking of their name from the databank (Law 25.326, Sec 27. Subsection 3). This is done in compliance with the provisions of Decree 1558/2001, Sec. 27, paragraph 3, which establishes that in each communication for advertising purposes made by mail, telephone, email, Internet or another distance means to be known must be indicated, in a express and prominent way, the possibility for the owner of the data to request the removal or block, fully or partially, of their name from the database. On request of the interested party, the name of the person responsible or user of the databank that provided the information must be informed.

9. Procedure

If the User wants to make effective their right to data access, rectification, update, deletion and confidentiality, they must take into consideration the following:

  1. The request for obtaining information, rectifying, updating or deleting personal data must be made by email to info@smartfense.com through the confirmation of identity by scanning the ID card and lawful right.
  2. Once the request has been received and approved, we will reply in an accessible and understandable language, with prior confirmation of identity, within ten (10) consecutive days for the request of information, while, the request for rectification, update or deletion of data, we will do it in five (5) working days.
  3. We will inform in the most concrete and clearly possible way, and we will reply according to the preference that the interested party has expressed in their request. In no case may the report reveal data belonging to third parties.
  4. The information may be denied when in such a way it could impede judicial or administrative proceedings in progress.

10. Information Security

The Company is responsible for maintaining all the time the security of personal information provided by Users, by implementing the necessary internal technical and organizational measures to guarantee the security and confidentiality of data, and trying by all means to avoid unauthorized access to it, in compliance with Law 25.326, Sec. 9, of Personal Data Protection, and Provision 11/2006 of National Directorate for Personal Data Protection relating to 'Security Measures for the Treatment and Preservation of Personal Data Contained in Files, Registries, Banks and Non-state Public and Private Databases'. However, because of the current state of technology, the Company can not guarantee that unauthorized access will never occur.

11. Cookies Use

Users know and accept that the Company can use a tracking system through the use of cookies. Cookies are files hosted in the hard disk, with a limited duration in time to help to customize the services. They facilitate the use and navigation in our webpage, being in some cases essential for their running. Cookies allow to collect data at the same time for Users’ authentication, identity validation and the evaluation of the behavior and demographics of Users in order to offer them a better service.
Likewise, they may be used for statistics purposes such as: date of the first visit, number of times visited, date of the last visit, URL and domain from which it comes, browser used, screen resolution, among other actions of the User. Cookies are also used for promoting and enforcing rules and site security. All this information will not be associated with Users’ personal data. Nevertheless, the User can deactivate and/or delete them through their browser knowing that, with this option, it is possible not to access certain contents of the website.

12. Links with other websites

The website may contain links or advertising links with third-parties websites. However, the Company does not have any control, nor does it hold any responsibility for the policies or data protection measures of other applications and/or other websites.

This Privacy Policy is an integral part of the Terms and Conditions of Use of the Company.

Last modification: June 8th, 2017