PRIVACY POLICY
Effective date: 2022-02-06
1. Introduction
Welcome to Access Manager.
Access Manager (“us”, “we”, or “our”) operates accessmanager.com.ar (hereinafter
referred to as “Service”).
Our Privacy Policy governs your visit to accessmanager.com.ar, and explains how we
collect, safeguard and disclose information that results from your use of our Service.
We use your data to provide and improve Service. By using Service, you agree to the
collection and use of information in accordance with this policy. Unless otherwise
defined in this Privacy Policy, the terms used in this Privacy Policy have the same
meanings as in our Terms and Conditions.
Our Terms and Conditions (“Terms”) govern all use of our Service and together with
the Privacy Policy constitutes your agreement with us (“agreement”).
2. Definitions
SERVICE means the accessmanager.com.ar website operated by Access Manager.
PERSONAL DATA means data about a living individual who can be identified from
those data (or from those and other information either in our possession or likely to
come into our possession).
USAGE DATA is data collected automatically either generated by the use of Service or
from Service infrastructure itself (for example, the duration of a page visit).
COOKIES are small files stored on your device (computer or mobile device).
DATA CONTROLLER means a natural or legal person who (either alone or jointly or
in common with other persons) determines the purposes for which and the manner in
which any personal data are, or are to be, processed. For the purpose of this Privacy
Policy, we are a Data Controller of your data.
DATA PROCESSORS (OR SERVICE PROVIDERS) means any natural or legal
person who processes the data on behalf of the Data Controller. We may use the
services of various Service Providers in order to process your data more effectively.
DATA SUBJECT is any living individual who is the subject of Personal Data.
THE USER is the individual using our Service. The User corresponds to the Data
Subject, who is the subject of Personal Data.
3. Information Collection and Use
We collect several different types of information for various purposes to provide and
improve our Service to you.
4. Types of Data Collected
Personal Data
While using our Service, we may ask you to provide us with certain personally
identifiable information that can be used to contact or identify you (“Personal Data”).
Personally identifiable information may include, but is not limited to:
0.1. Email address
0.2. First name and last name
0.3. Phone Number
0.4. Country
We may use your Personal Data to contact you with newsletters, marketing or
promotional materials and other information that may be of interest to you. You may
opt out of receiving any, or all, of these communications from us by following the
unsubscribe link.
Usage Data
We may also collect information that your browser sends whenever you visit our
Service or when you access Service by or through any device (“Usage Data”).
This Usage Data may include information such as your computer’s Internet Protocol
address (e.g. IP address), browser type, browser version, the pages of our Service that
you visit, the time and date of your visit, the time spent on those pages, unique device
identifiers and other diagnostic data.
When you access Service with a device, this Usage Data may include information such
as the type of device you use, your device unique ID, the IP address of your device,
your device operating system, the type of Internet browser you use, unique device
identifiers and other diagnostic data.
Tracking Cookies Data
We use cookies and similar tracking technologies to track the activity on our Service
and we hold certain information.
Cookies are files with a small amount of data which may include an anonymous unique
identifier. Cookies are sent to your browser from a website and stored on your device.
Other tracking technologies are also used such as beacons, tags and scripts to collect
and track information and to improve and analyze our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being
sent. However, if you do not accept cookies, you may not be able to use some portions
of our Service.
Examples of Cookies we use:
0.1. Session Cookies: We use Session Cookies to operate our Service.
0.2. Preference Cookies: We use Preference Cookies to remember your preferences
and various settings.
0.3. Security Cookies: We use Security Cookies for security purposes.
0.4. Advertising Cookies: Advertising Cookies are used to serve you with
advertisements that may be relevant to you and your interests.
Other Data
While using our Service, we may also collect the following information: sex, age, date
of birth, place of birth, passport details, citizenship, registration at place of residence
and actual address, telephone number (work, mobile), details of documents on
education, qualification, professional training, employment agreements, NDA
agreements, information on bonuses and compensation, information on marital status,
family members, social security (or other taxpayer identification) number, office
location and other data.
5. Use of Data
Access Manager uses the collected data for various purposes:
0.1. to provide and maintain our Service;
0.2. to notify you about changes to our Service;
0.3. to allow you to participate in interactive features of our Service when you choose to
do so;
0.4. to provide customer support;
0.5. to gather analysis or valuable information so that we can improve our Service;
0.6. to monitor the usage of our Service;
0.7. to detect, prevent and address technical issues;
0.8. to fulfil any other purpose for which you provide it;
0.9. to carry out our obligations and enforce our rights arising from any contracts
entered into between you and us, including for billing and collection;
0.10. to provide you with notices about your account and/or subscription, including
expiration and renewal notices, email-instructions, etc.;
0.11. to provide you with news, special offers and general information about other
goods, services and events which we offer that are similar to those that you have already
purchased or enquired about unless you have opted not to receive such information;
0.12. in any other way we may describe when you provide the information;
0.13. for any other purpose with your consent.
6. Retention of Data
We will retain your Personal Data only for as long as is necessary for the purposes set
out in this Privacy Policy. We will retain and use your Personal Data to the extent
necessary to comply with our legal obligations (for example, if we are required to retain
your data to comply with applicable laws), resolve disputes, and enforce our legal
agreements and policies.
We will also retain Usage Data for internal analysis purposes. Usage Data is generally
retained for a shorter period, except when this data is used to strengthen the security or
to improve the functionality of our Service, or we are legally obligated to retain this data
for longer time periods.
7. Transfer of Data
Your information, including Personal Data, may be transferred to – and maintained on –
computers located outside of your state, province, country or other governmental
jurisdiction where the data protection laws may differ from those of your jurisdiction.
If you are located outside Costa Rica and choose to provide information to us, please
note that we transfer the data, including Personal Data, to Costa Rica and process it
there.
Your consent to this Privacy Policy followed by your submission of such information
represents your agreement to that transfer.
Access Manager will take all the steps reasonably necessary to ensure that your data is
treated securely and in accordance with this Privacy Policy and no transfer of your
Personal Data will take place to an organisation or a country unless there are adequate
controls in place including the security of your data and other personal information.
8. Disclosure of Data
We may disclose personal information that we collect, or you provide:
0.1. Disclosure for Law Enforcement.
Under certain circumstances, we may be required to disclose your Personal Data if
required to do so by law or in response to valid requests by public authorities.
0.2. Business Transaction.
If we or our subsidiaries are involved in a merger, acquisition or asset sale, your
Personal Data may be transferred.
0.3. Other cases. We may disclose your information also:
0.3.1. to our subsidiaries and affiliates;
0.3.2. to contractors, service providers, and other third parties we use to support our
business;
0.3.3. to fulfill the purpose for which you provide it;
0.3.4. for the purpose of including your company’s logo on our website;
0.3.5. for any other purpose disclosed by us when you provide the information;
0.3.6. with your consent in any other cases;
0.3.7. if we believe disclosure is necessary or appropriate to protect the rights, property,
or safety of the Company, our customers, or others.
9. Security of Data
The security of your data is important to us but remember that no method of
transmission over the Internet or method of electronic storage is 100% secure. While we
strive to use commercially acceptable means to protect your Personal Data, we cannot
guarantee its absolute security.
10. Your Data Protection Rights Under General Data Protection Regulation
(GDPR)
If you are a resident of the European Union (EU) and European Economic Area (EEA),
you have certain data protection rights, covered by GDPR.
We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use
of your Personal Data.
If you wish to be informed what Personal Data we hold about you and if you want it to
be removed from our systems, please email us at app@accessmanager.com.ar.
In certain circumstances, you have the following data protection rights:
0.1. the right to access, update or to delete the information we have on you;
0.2. the right of rectification. You have the right to have your information rectified if
that information is inaccurate or incomplete;
0.3. the right to object. You have the right to object to our processing of your Personal
Data;
0.4. the right of restriction. You have the right to request that we restrict the processing
of your personal information;
0.5. the right to data portability. You have the right to be provided with a copy of your
Personal Data in a structured, machine-readable and commonly used format;
0.6. the right to withdraw consent. You also have the right to withdraw your consent at
any time where we rely on your consent to process your personal information;
Please note that we may ask you to verify your identity before responding to such
requests. Please note, we may not able to provide Service without some necessary data.
You have the right to complain to a Data Protection Authority about our collection and
use of your Personal Data. For more information, please contact your local data
protection authority in the European Economic Area (EEA).
11. Your Data Protection Rights under the California Privacy Protection Act
(CalOPPA)
CalOPPA is the first state law in the nation to require commercial websites and online
services to post a privacy policy. The law’s reach stretches well beyond California to
require a person or company in the United States (and conceivable the world) that
operates websites collecting personally identifiable information from California
consumers to post a conspicuous privacy policy on its website stating exactly the
information being collected and those individuals with whom it is being shared, and to
comply with this policy.
According to CalOPPA we agree to the following:
0.1. users can visit our site anonymously;
0.2. our Privacy Policy link includes the word “Privacy”, and can easily be found on the
home page of our website;
0.3. users will be notified of any privacy policy changes on our Privacy Policy Page;
0.4. users are able to change their personal information by emailing us at
app@accessmanager.com.ar.
Our Policy on “Do Not Track” Signals:
We honor Do Not Track signals and do not track, plant cookies, or use advertising when
a Do Not Track browser mechanism is in place. Do Not Track is a preference you can
set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of
your web browser.
12. Your Data Protection Rights under the California Consumer Privacy Act
(CCPA)
If you are a California resident, you are entitled to learn what data we collect about you,
ask to delete your data and not to sell (share) it. To exercise your data protection rights,
you can make certain requests and ask us:
0.1. What personal information we have about you. If you make this request, we
will return to you:
0.0.1. The categories of personal information we have collected about you.
0.0.2. The categories of sources from which we collect your personal information.
0.0.3. The business or commercial purpose for collecting or selling your personal
information.
0.0.4. The categories of third parties with whom we share personal information.
0.0.5. The specific pieces of personal information we have collected about you.
0.0.6. A list of categories of personal information that we have sold, along with the
category of any other company we sold it to. If we have not sold your personal
information, we will inform you of that fact.
0.0.7. A list of categories of personal information that we have disclosed for a business
purpose, along with the category of any other company we shared it with.
Please note, you are entitled to ask us to provide you with this information up to two
times in a rolling twelve-month period. When you make this request, the information
provided may be limited to the personal information we collected about you in the
previous 12 months.
0.2. To delete your personal information. If you make this request, we will delete
the personal information we hold about you as of the date of your request from our
records and direct any service providers to do the same. In some cases, deletion
may be accomplished through de-identification of the information. If you choose to
delete your personal information, you may not be able to use certain functions that
require your personal information to operate.
0.3. To stop selling your personal information. We don’t sell or rent your personal
information to any third parties for any purpose. We do not sell your personal
information for monetary consideration. However, under some circumstances, a
transfer of personal information to a third party, or within our family of
companies, without monetary consideration may be considered a “sale” under
California law. You are the only owner of your Personal Data and can request
disclosure or deletion at any time.
If you submit a request to stop selling your personal information, we will stop making
such transfers.
Please note, if you ask us to delete or stop selling your data, it may impact your
experience with us, and you may not be able to participate in certain programs or
membership services which require the usage of your personal information to function.
But in no circumstances, we will discriminate against you for exercising your rights.
To exercise your California data protection rights described above, please send your
request(s) by email: app@accessmanager.com.ar.
Your data protection rights, described above, are covered by the CCPA, short for the
California Consumer Privacy Act. To find out more, visit the official California
Legislative Information website. The CCPA took effect on 01/01/2020.
13. Service Providers
We may employ third party companies and individuals to facilitate our Service
(“Service Providers”), provide Service on our behalf, perform Service-related services
or assist us in analysing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our
behalf and are obligated not to disclose or use it for any other purpose.
14. Analytics
We may use third-party Service Providers to monitor and analyze the use of our
Service.
15. CI/CD tools
We may use third-party Service Providers to automate the development process of our
Service.
16. Behavioral Remarketing
We may use remarketing services to advertise on third party websites to you after you
visited our Service. We and our third-party vendors use cookies to inform, optimise and
serve ads based on your past visits to our Service.
17. Links to Other Sites
Our Service may contain links to other sites that are not operated by us. If you click a
third party link, you will be directed to that third party’s site. We strongly advise you to
review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies
or practices of any third party sites or services.
For example, the outlined privacy policy has been made using PolicyMaker.io, a free
tool that helps create high-quality legal documents. PolicyMaker’s privacy policy
generator is an easy-to-use tool for creating a privacy policy for blog, website, e-
commerce store or mobile app.
18. Children’s Privacy
Our Services are not intended for use by children under the age of 18 (“Child” or
“Children”).
We do not knowingly collect personally identifiable information from Children under
18. If you become aware that a Child has provided us with Personal Data, please contact
us. If we become aware that we have collected Personal Data from Children without
verification of parental consent, we take steps to remove that information from our
servers.
19. Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any
changes by posting the new Privacy Policy on this page.
We will let you know via email and/or a prominent notice on our Service, prior to the
change becoming effective and update “effective date” at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to
this Privacy Policy are effective when they are posted on this page.
20. Contact Us
If you have any questions about this Privacy Policy, please contact us by email:
app@accessmanager.com.ar.
