Privacy Policy

Dec 26, 2019

DI-STE-03 PRIVACY NOTICE V01

  1. General and contact information

Legadmi Consulting & System SA (“Legadmi”) with address in Santa Ana, San José, Costa Rica, informs you that for everything related to the processing of your personal data, you may be able to provide us (hereinafter simply referred to as "Personal Data"), Legadmi will be responsible for its protection as it is the technological intermediary or service provider and will be committed to protecting your privacy.

For any information regarding this Privacy Notice or in relation to the exercise of any of your rights derived from the referred Personal Data, including without limitation your rights of access, cancellation and opposition, please contact our Operations Department, in our address mentioned above, email notifications@legadmi.com

The use of the Legadmi websites is considered as a consent for the data collection and other practices described in this privacy notice.

  1. Definitions

2.1.- Personal Data.- Any data related to an identified or identifiable natural person.

2.2.- Sensitive Data.- Information regarding the person's private jurisdiction, such as those that reveal racial origin, political opinions, religious or spiritual convictions, socioeconomic status, biomedical or genetic information, life and sexual orientation, among others.

2.3.- Unrestricted Access Personal Data.- The contents in public databases of general access, as provided by special laws and in accordance with the purpose for which these data were collected.

2.4.- Restricted Access Personal Data.- Those that, although forming part of public access registers, are not of unrestricted access because they are of interest only to their owner or to the Public Administration.

2.5.- Database.- Any file, file, registry or other structured set of public or private personal data that is processed, automated or manual, on the site or in the cloud, under the control or direction of a person in charge , whatever the method of its elaboration, organization or access.

2.6.- Public Access Database.- Those files, files, registry or other structured set of data that can be consulted by any person who is not impeded by a limiting rule, or without more requirement than the payment of a consideration.

2.7.- Owner or Interested Party.- Natural person owning the personal data protected by Law, or his representative.

2.8.- Identifiable Natural Person.- Person whose identity can be determined, directly or indirectly, by means of any information referring to their anatomical, physiological, psychological, economic, cultural or social identity. A natural person will not be considered identifiable if such identification requires time limits or disproportionate activities.

2.9.- Consent of the Owner of Personal Data.- Any expression of will, expressed, free, unequivocal, informed and specific that is granted in writing or in digital media for a specific purpose, by which the owner of the personal data or Your representative consents to the processing of your personal data. If consent is granted in the framework of a contract for other purposes, said contract must have a specific and independent clause on consent to the processing of personal data.

2.10.- File.- Any organized set of personal data, whatever the form, purpose or modality of its creation, storage, organization and access.

2.11.- Data in the Cloud.- File, file, registry or other structured set of data that is accessed using the Internet.

2.12.- Responsible for the Database.- Any natural or legal person, public or private, who administers or, manages or is in charge of, or owns, one or more public or private databases, competent in accordance with the Law, to decide what is the purpose of the database, what categories of personal data should be registered and what type of treatment will be applied to them.

2.13.- Manager.- Any natural or legal person, public or private entity, or any other body that processes personal data on behalf of the person in charge of the database.

2.14.- Technological intermediary or service provider.- Natural or legal person, public or private that provides infrastructure, platform, software or other services.

2.15.- Treatment of Personal Data.- Any operation or set of operations, carried out through automated or manual procedures and applied to personal data, such as collection, registration, organization, conservation, modification, extraction, consultation , use, communication by transmission, broadcast, distribution or any other way that facilitates access to these, collation or interconnection, as well as blocking, deletion or destruction, among others.

2.16.- Automated Data Processing.- Any operation, set of operations or procedures, applied to personal data, carried out through the use of hardware, software, networks, services, applications, on site or in the cloud, or any other technology of the information that allow the collection, registration, organization, conservation, modification, extraction, consultation, use, communication by transmission, diffusion, distribution or any other way that facilitates access to these, collation , or the interconnection, as well as its blocking, deletion or destruction, exchange or digitization of personal data, among others.

2.17.- Distribution, dissemination.- Any way in which personal data is distributed or published, to a third party, by any means, as long as there is an end to commercialize the data or there is profit with the database.

2.18.- Deletion or Elimination.- Procedure by virtue of which the person in charge or the person in charge of the database, deletes or destroys, totally or partially, the personal data of the owner, from its database.

2.19.- Transfer of Personal Data.- Action by means of which personal data of the person in charge of a Personal Database is transferred to any third party other than the Person in charge, of his economic interest group, of the Manager, service provider or technological intermediary, in these cases as long as the recipient does not use the data for distribution, dissemination or marketing.

2.20.- Primary Purposes.- Those Purposes for which Personal Data is mainly requested and for which the relationship between Legadmi and the HOLDER is originated.

2.21.- Secondary Purposes.- Those Purposes that are not essential for the relationship between Legadmi and the HOLDER, but which are analogous or compatible with the Primary Purposes.

  1. Personal data collected

The Personal Data that Legadmi may request are those necessary for the fulfillment of the obligations derived from our relationship with you and / or the legal entity that you represent and which may be: i) full name; ii) contact telephone numbers; iii) email and / or Internet page, and iv) company it represents.

Legadmi will not request data considered sensitive by the Law on Protection of the Person against the Treatment of your Personal Data, Law No. 8968 ("Law”). In case of requesting sensitive Personal Data, we will request your express and written consent to obtain and process it in accordance with the provisions of the Law.

In the event that you do not give your express consent for the processing of your Personal Data, we may be unable to establish a relationship with you.

For any questions or comments regarding the Personal Data in possession of Legadmi, you can contact our Operations Department through the contact information indicated in this Privacy Notice.

  1. Obtaining your Personal Data

Legadmi is not in charge of collecting your Personal Data that is stored in the information systems, your Personal Data may be collected only and exclusively through other means authorized by you, such as the website, email.

Likewise, we inform you that Legadmi websites obtain data automatically through cookies. Cookies are small pieces of information that your browser stores on the computer's hard drive. You can prevent the use of cookies on your computer by configuring your browser accordingly, but please note that this may hamper the functionality of Legadmi sites.

  1. Purposes to collect and use your Personal Data

Your Personal Data will be used for purposes that give rise and are considered necessary for the existence, maintenance and fulfillment of the legal relationship between Legadmi and you. The purposes for which Legadmi will collect and use your Personal Data are: i) the fulfillment and development of the contractual obligations or commercial agreements that you have or may contract with Legadmi as a technological intermediary or service provider; ii) create databases for the provision of our services, and iii) contact you and deal with any complaints, questions or suggestions.

Additionally, your Personal Contact Data will be used to: i) carry out advertising or commercial prospecting purposes; ii) create databases for research, statistical or market purposes; iii) evaluate the quality of Legadmi's services; iv) send notifications, notices, advertising or publicity about our products or services; and v) sending information, magazines and news about our industry or topics that we consider may be of interest to you, as well as news, communications or advertising from Legadmi or its related companies. The aforementioned purposes are not considered strictly necessary for the existence, maintenance or fulfillment of the legal relationship between Legadmi and you, so you may deny the processing of your Personal Data for the aforementioned purposes by sending us an email requesting the above.

5.1 Purposes for the treatment of customer data:

  • Compliance with commercial obligations in the framework of contractual relationships.
  • Process and ensure compliance and delivery of the products and / or services purchased by Legadmi customers, as well as prepare the corresponding invoicing.
  • Sending advertising on Legadmi products and services.
  • Preparation of performance reports by the commercial and marketing areas.
  • Offering of products from the different commercial lines of Legadmi.
  • Communication discounts, promotions and new product launches.
  • Carrying out analysis and profiling of customers to define the products that suit their tastes and purchasing preferences.
  • Communication on the realization of activities and events organized by Legadmi.
  • Development of market research and consumer habits, statistical analysis and reports on customer behavior.
  • Design and offer loyalty and benefit programs for clients.
  • Sending satisfaction surveys or any other mechanism to evaluate the quality of the products and services provided by Legadmi.
  1. How do we protect your Personal Data?

We promise that your Personal Data will be treated under the administrative, physical and technical security measures established by the Law on Protection of the Person against the Treatment of your Personal Data, Law No. 8968 and its Regulations and thus avoid its damage, loss, destruction , theft, loss, alteration and / or unauthorized treatment.

Given that Legadmi stores and carries out the treatment of your Personal Data through computer systems or through the Internet, we inform you that derived from electronic communications are not completely secure and that any computer system is exposed to possible vulnerabilities that may affect its operation or security, Legadmi cannot guarantee that there will be no damage, loss, destruction, loss, alteration or unauthorized treatment, it is Legadmi's absolute commitment to ensure that security protocols are updated to avoid any vulnerability.

  1. Your rights - How can you access, rectify, cancel or oppose the treatment or transfer of your Personal Data?

As the owner of the Personal Data that you provide us indirectly, you will have, in accordance with the Law on Protection of the Person against the Treatment of your Personal Data, Law No. 8968 and its Regulations, the right to access the Personal Data that we possess and the details of their treatment; rectify if they are incomplete or inaccurate; cancel them in case you consider that they are not required for any of the purposes indicated in this Privacy Notice, are being used for purposes that have not been consented to, or oppose the processing of Personal Data that you have provided for specific purposes .

For the effect of the foregoing, you may request the exercise of your rights of access, rectification, cancellation or opposition to the treatment of your Personal Data before Legadmi in accordance with the provisions of the Law on Protection of the Person against the Treatment of your Personal Data. , Law No. 8968 and its regulations.

  1. Limit the use or disclosure of your Personal Data

You have the right to limit the use or disclosure of your Personal Data for purposes that are not necessary for our legal relationship, so if you no longer wish to receive communications or promotions from us, please send us an email or post addressed to our Privacy Department, indicating this situation and in order to be enrolled in an exclusion list owned by Legadmi, which will be granted an electronic or physical record, as requested. Legadmi will not carry out Distribution or dissemination of Personal Data or any Data of any kind other than the Data Controller.

  1. Revoke your consent to the processing of your Personal Data

You may at any time revoke your consent to the processing of your Personal Data by contacting our Privacy Department. We inform you that in the event that you revoke the consent that you have previously granted us for the treatment of your Personal Data, we will not be able to continue our legal relationship.

  1. Transfer of your Personal Data - With whom do we share your Personal Data?

As part of the management and administration of the business to which Legadmi is dedicated, we will not be able to transfer your Personal Data with any of our parent and / or all or any of our affiliate companies, subsidiaries, licensees, and / or belonging to the same economic group in the Republic of Costa Rica or abroad; In these cases, Legadmi cannot transfer your data without requesting express authorization. Likewise, Legadmi reserves the right not to share your Personal Data with administrative, judicial or governmental authorities of any kind, in the Republic of Costa Rica or abroad, except in the cases provided for in the Law on Protection of the Person against the Treatment of your Personal Data, Law Nº8968 or any other applicable regulations.

Similarly, your Personal Data may not be shared with any prospect, potential buyer or acquirer of the company that maintains Legadmi. Likewise, your Personal Data may not be shared with third parties interested in doing business or establishing a legal relationship with us or you, grant financing, acquire the shares or assets of Legadmi or its shareholders or subsidiaries in the Republic of Costa Rica or around the world. , or in merging with Legadmi.

  1. Storage of your Personal Data

Legadmi, may keep your Personal Data, during the commercial contractual relationship, in databases located in the Republic of Costa Rica or abroad, without any limitation, except for the periods indicated by the applicable legislation, as well as to comply with the purposes indicated in this Privacy Notice, as stipulated in the Law on Protection of the Person against the Treatment of Your Personal Data, Law No. 8968, its Regulations and other applicable regulations.

  1. Modifications to the Privacy Notice, Legislation and Jurisdiction

We reserve the right to make modifications or updates to this Privacy Notice at any time, in response to legislative changes, internal policies or new requirements for the provision or offering of our products.

In case of modifications to this Privacy Notice, you will be notified through the email provided by you. You can also communicate through our website or through communications that we have placed in our offices. In any case, you will have the right to cancel and / or rectify your Personal Data as well as to limit its use and disclosure in case of modifications to the terms of this Privacy Notice.

This Privacy Notice and the treatment of your Personal Data are governed by the Law on Protection of the Person against the Treatment of your Personal Data, Law No. 8968 and the other regulations of the Republic of Costa Rica. The acceptance of this Privacy Notice or the conclusion of a contract of any nature with Legadmi, once the Privacy Notice is made available, implies an express acceptance, in writing, of its terms and its express submission to the courts of the Republic of Costa Rica, for any controversy or claim derived from it, for which it is understood the waiver of any other jurisdiction that due to domicile, present or future may correspond.

If you consider that your right to protection of Personal Data has been violated by some conduct of our employees or our actions or responses, you presume that in the treatment of your Personal Data there is some violation of the provisions set forth in the Law on Protection of Person in front of the Treatment of your Personal Data, Law Nº8968, may file the corresponding complaint or denunciation.

Complete the information requested to obtain a user of our Self-management tool. With this you can enter the tool and manage different information as if you were a collaborator of the organization.

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