This privacy statement is effective as of May 5, 2021. Please note that this privacy statement will be regularly updated to reflect any changes in the way we handle your personal data or any changes in applicable laws.
Below, we provide specific information about:
WHO WE ARE.
SITE INFORMATION.
DATA CONTROLLER OF YOUR PERSONAL DATA.
COLLECTION OF USER INFORMATION.
PURPOSE OF PROCESSING PERSONAL DATA.
USE OF COLLECTED USER INFORMATION.
ASSIGNMENT AND TRANSFER OF PERSONAL DATA.
CONFIDENTIALITY AND SECURITY OF INFORMATION.
CHANGES IN CORPORATE STRUCTURE.
MINORS.
USER RIGHTS REGARDING INFORMATION.
EXCEPTIONS.
ETHICS LINE / WHISTLEBLOWER LINE.
MODIFICATION OF THE PRIVACY POLICY.
CONTACT.
APPLICABLE LEGISLATION AND JURISDICTION.
- WHO WE ARE
Zentricx is an international business and technology consulting firm, focused on data, innovation, and user experience.
We are a multidisciplinary team of professionals, specialists in business, technology, and communication, who work collaboratively with a focus on our clients’ experience.
We develop and implement solutions that help digitize business processes through the implementation of technology tailored to each client’s reality, helping them understand the digital impact on their organization.
1.SITE INFORMATION.
1.1. This Privacy Policy (hereinafter referred to as the “Privacy Policy”) applies to the use of the personal data of the User, as described below, from the website published at the URL: https://zentricx.com (hereinafter, the “Site”), provided by ZENTRICX (hereinafter, “ZENTRICX”), whose main function is to offer the User an assessment (information related to training, products, and contacts with ZENTRICX) and provide industry content (under an innovative methodology based on practice through specific programs, including but not limited to Full Stack Web Development, User Experience (UX) Design, Data Science, Data Analytics, Digital Marketing, among others) (hereinafter, the “Service”). If necessary, ZENTRICX may supplement this Privacy Policy with information and/or specific terms and conditions related to the Service.
1.2. Mere access to the Site confers the status of ZENTRICX user (hereinafter “User” or “Users”) and expresses full and unreserved acceptance of each and every clause of the Privacy Policy as published by ZENTRICX at the time the User accesses the Site or uses its Service. Consequently, the Privacy Policy will constitute a valid and binding agreement between the User and ZENTRICX regarding privacy. Likewise, the use of the Service expresses the User’s full and unreserved acceptance of the Terms and Conditions of Use of the Service (hereinafter, the “Terms and Conditions”) published by ZENTRICX at https://www.zentricx.cloud/politica-privacidad/, which are complemented by the Privacy Policy.
1.3. The purpose of the Privacy Policy is to inform the holders of the Personal Data, as defined below, regarding which information is being collected, the specific treatments of their data, the purposes of the treatments, the contact information to exercise their rights, the retention periods of the information, and the security measures, among other things.
1.4. The provisions of the Privacy Policy shall apply to all Users of ZENTRICX, whether or not they have provided their Personal Data.
1.5. The provisions of the WordPress Privacy Policy shall apply to all Users of ZENTRICX, whether or not they have provided their Personal Data. WordPress.org also collects information that could be considered personally identifiable, such as Internet Protocol (IP) addresses.
BEFORE BROWSING AND/OR USING THE SITE AND/OR THE SERVICE, PLEASE READ THIS PRIVACY POLICY CAREFULLY. IF THE USER DOES NOT AGREE WITH THIS PRIVACY POLICY, THEY SHOULD REFRAIN FROM USING THE SITE AND/OR THE SERVICE.
2.DATA CONTROLLER OF YOUR PERSONAL DATA.
2.1. ZENTRICX will be the company responsible for processing the Personal Data provided by the User on the Site or collected or processed on the Site, for, by, or through the Services, or in relation to them.
In any case, if the holder of the Personal Data is a visitor to the Site or a User of the same, any collection, use, and sharing of information related to their Personal Data will be subject to this Privacy Policy, the complementary Cookie Policy, and its updates.
2.2. For ZENTRICX, the privacy of the User’s Personal Data is very important. If the User has any questions regarding the Privacy Policy or the use of the Site or the Service, they should contact ZENTRICX at any time by sending an email to innovacion@zentricx.com.
2.3. By accessing our site, the privacy policies of MAILERLITE apply. MailerLite collects both “Personal Data” and “Non-Personal Data” about you and processes this data.
3.COLLECTION OF USER INFORMATION.
3.1. ZENTRICX processes the User’s Personal Data solely with the express consent granted by the User upon accepting this Privacy Policy. Furthermore, the User agrees that ZENTRICX may collect information about them using cookies and tags, as well as any information provided by the User through the forms on the Site when registering and/or using the Service. If a User of the Site does not wish to accept these cookies, they can configure their browser to give them the option to accept each cookie and reject those they do not want.
3.2. Below we detail all the information that ZENTRICX collects:
Information provided by the User: (i) first and last name; (ii) phone number; (iii) state of residence; and (iv) course; (collectively referred to as “Personal Data”) when completing contact forms or subscriptions.
Information collected passively: When the User accesses the Site and/or uses the Service, ZENTRICX may automatically collect and store certain types of information, such as the Internet Protocol (IP) address of the User’s computer or device and other technical information about the use of the computer or device, such as the type and version of the browser, time zone settings, operating system, geographic locations, usage sessions, time spent on the Site, frequency of use, etc.
Information from other sources: ZENTRICX may receive information from the User from other sources such as public sources, third parties (e.g., consumer reporting agencies), etc.
Information from cookies, tags, and/or any other automated information detection method provided by the tools offered on the Site: The information collected by ZENTRICX may include browsing behavior, IP address, logs, and other types of information. However, ZENTRICX does not collect personally identifiable information directly from any User using cookies, tags, or any other automated information detection method provided by the tools on the Site.
4.PURPOSE OF PROCESSING PERSONAL DATA.
4.1. ZENTRICX processes the User’s personal information for the following purposes:
To authorize and manage access to the Site, verify identity, authenticate visits, and provide the Service;
To manage, analyze, develop, customize, and improve the Site and the Service;
To provide the Service and its improvements to Users;
To analyze for the purpose of providing Users with the Service.
To send Users notifications, news, and updates about courses and information of interest according to their preferences, as well as those that constitute institutional or legal notifications;
To analyze User behaviors and actions on the Site to improve the Service and provide better solutions to their needs;
Send information and newsletters about the latest updates from ZENTRICX, its Services, events, promotions, and advertisements via WhatsApp, phone, postal mail, email, even after our relationship has ended unless the interested person expresses otherwise;
Facilitate compliance with legal obligations if requested by courts or national or international state agencies that so require and request it in the appropriate manner.
Obtain a diagnosis of any potential connection issues that may exist between the ZENTRICX Site and Users, improving the quality of the Services.
5.USE OF COLLECTED USER INFORMATION.
5.1.ZENTRICX will use and store the information provided by Users and collected by ZENTRICX in order to provide the Service and its improvements to Users, attempting to meet their needs, for the maximum period established by applicable legislation.
5.2. ZENTRICX will retain and use the Personal Data provided by the User for the period during which the User utilizes the Site and/or the Service in order to provide the best Service. Once the relationship between the Parties has ended for any reason, ZENTRICX reserves the right to retain the information until the purpose of its processing has been fulfilled. Subsequently, ZENTRICX will proceed to destroy the Personal Data.
5.3. ZENTRICX may send Users notifications, news, and updates of interest, in addition to those that constitute institutional or legal notifications for the purpose of offering its Services, as long as this is accepted by the User and the User has not exercised their opt-out right.
5.4. ZENTRICX may share information with other service companies or similar websites to fulfill the purpose of ZENTRICX’s Service and improve its quality. Generally, these companies or websites have their own data privacy policies for protection purposes. Nevertheless, ZENTRICX will make every effort to ensure that the privacy of shared information is protected in the best possible way. In relevant cases, ZENTRICX will attempt to sign express agreements regarding data protection and privacy. However, ZENTRICX will not be responsible for damages caused by such companies and/or websites concerning their duty of protection, confidentiality, and privacy of the data they handle.
5.5. Regarding the processing of personal data of citizens of the European Union, ZENTRICX will adhere to the principles and obligations set forth in Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, regarding the protection of individuals in relation to the processing of personal data and the free movement of such data (GDPR).
5.6. ZENTRICX will not sell, rent, or negotiate any Personal Data to any third party for commercial purposes. Anyone who has provided personal contact information through the ZENTRICX Site may send an email to innovacion@zentricx.com to update, delete, or correct their personal contact information. ZENTRICX will respond to such requests within 48 (forty-eight) hours following receipt via email.
5.7. The ZENTRICX Site may contain links to other websites that are not owned by ZENTRICX. Consequently, ZENTRICX will not be responsible for the actions of such websites, to which this Privacy Policy does not apply. We recommend reviewing the detailed privacy policy on those websites to understand their information collection practices and how they protect your personal data.
6.ASSIGNMENT AND TRANSFER OF PERSONAL DATA.
6.1. Only to fulfill the purposes established in this Privacy Policy and to provide the Service, ZENTRICX may disclose the Personal Data and/or personal information of the User, when necessary, to authorities, ZENTRICX partners, and other third parties, such as third-party service providers used in relation to the Service, for example, to perform marketing, advertising, communication, infrastructure, and IT services, to customize and improve our Service, and to process transactions with credit cards or other payment methods. When ZENTRICX hires a service provider, it will provide the information necessary for them to perform their specific function, which may include Personal Data and other information that the User provides through the Site. These service providers are authorized to use the Personal Data only when necessary to provide their services.
6.2. In some cases, such as in the Argentine Republic or the Eastern Republic of Uruguay, personal information may be transferred out of the country to countries with the same or better levels of protection. If personal information is transferred to countries with lower protection levels, ZENTRICX will carry out those transfers subject to appropriate safeguards and security measures, such as standard data protection clauses adopted in the respective agreements or approved by the applicable legal authority.
6.3. Furthermore, ZENTRICX may share Users’ Personal Data with third parties, with the prior and express consent of the User.
6.4. Regarding the processing of personal data of citizens of the European Union (EU) and/or European Economic Area, it is noted that:
(i) ZENTRICX may transfer the personal data of Users from the Site and those generated while using the Site and/or the Service to entities located in the territory of the Argentine Republic, which has been declared by the European Commission as having an adequate level of protection according to its Decision 2003/490/EC of June 30, 2003.
(ii) ZENTRICX may transfer the aforementioned Personal Data to other entities located in third countries that have been declared by the European Commission as having an adequate level of protection or with which agreements have been made that include the adequate guarantees imposed by European authorities (e.g., standard data protection clauses adopted by the Commission, etc.).
7.CONFIDENTIALITY AND SECURITY OF INFORMATION.
7.1. ZENTRICX has adopted reasonable security measures to protect Users’ information and prevent unauthorized access to their data or any unauthorized modification, disclosure, or destruction of it. The information collected by ZENTRICX will be maintained as strictly confidential. Access to personal data is restricted to those employees, contractors, operators, and representatives of ZENTRICX who need to know such data to perform their functions and develop or improve our Service. ZENTRICX requires its suppliers to adhere to the same standards of confidentiality. ZENTRICX does not allow access to this information by third parties unrelated to ZENTRICX, except at the express request of the User.
7.2. Notwithstanding the above, considering that the internet is an open, public access system, ZENTRICX cannot guarantee that unauthorized third parties will not eventually overcome security measures and improperly use Users’ information. In any case, ZENTRICX maintains security and incident response plans to control incidents related to unauthorized access to the private information it collects or stores.
8.CHANGES IN CORPORATE STRUCTURE.
8.1. ZENTRICX reserves the right to transfer the information collected in the event of a sale or merger of ZENTRICX, or an acquisition of ZENTRICX’s main assets, or any other kind of transfer of ZENTRICX to another entity. In such cases, ZENTRICX will take reasonable measures to ensure that such information is used in a manner consistent with the Privacy Policy.
9.MINORS.
9.1. Although the Site and/or Service are not directed at minors, if a minor accesses them, their use must be supervised by parents, guardians, or legal representatives. The Site and/or Service are only permitted for those of legal age to contract and who are not legally prohibited from performing legal acts, rights, and/or obligations. Therefore, minors under 18 years old are not allowed to access the Site and/or Service, nor to provide any Personal Data or any other type of information.
9.2. Additionally, since minors may not fully understand the Privacy Policy and its implications, nor validly decide on the options available through the Services, ZENTRICX encourages all parents, guardians, or legal representatives supervising minors accessing ZENTRICX’s Service to actively and carefully participate in the activities that the minor undertakes online or through the Site, in the online service used by these minors, and in the information they access, whether visiting the ZENTRICX Site or any third-party site, and to teach and guide them on how to protect their own personal information while browsing the internet.
10.USER RIGHTS REGARDING INFORMATION.
10.1. . ZENTRICX will make every effort to facilitate Users for whom it has collected or stored personal information, access to their Personal Data (“Right of Access”), as well as the rectification, modification, or updating of the same (“Right of Rectification”), or even the cancellation of such personal data (“Right of Removal”), unless ZENTRICX can deny such requests (hereinafter, the “Requests”) if it is obliged or entitled to retain such Data according to applicable legislation.
- a) To this end, the User must send their Request via email with the subject “Access to Personal Data” to innovacion@zentricx.com. ZENTRICX may require the User to identify themselves, which can be verified by ZENTRICX, as well as specify the Personal Data they wish to access, rectify, or remove.
- b) ZENTRICX may refuse to process Requests that are unreasonably repetitive or systematic, that require disproportionate technical effort, that threaten the privacy of other Users, or that are considered impractical, or for which access to the Personal Data is not necessary.
- c) The service for access, rectification, and removal of Personal Data will be provided by ZENTRICX free of charge, except when it requires disproportionate or unreasonable effort, in which case an administrative fee may be charged.
10.2. Additionally, the User authorizes ZENTRICX to use their Personal Data to send communications and advertising materials (such as newsletters and brochures) regarding ZENTRICX’s activities and/or those that, at its sole discretion, may be of interest to Users. Users may request the suspension of such communications at any time.
10.3. To exercise their rights, Users may send a request to the email address innovacion@zentricx.com.
10.4. FURTHERMORE, IN ANY EVENT, USERS ARE INFORMED THAT AS THE OWNER OF THEIR PERSONAL DATA, THEY HAVE THE RIGHT TO ACCESS THEM FREE OF CHARGE AT INTERVALS NO LESS THAN SIX MONTHS, UNLESS A LEGITIMATE INTEREST IS DEMONSTRATED AS PER ARTICLE 14, SECTION 3 OF LAW NO. 25,326 OF THE ARGENTINE REPUBLIC. THE ENFORCEMENT AUTHORITY (IN ARGENTINA, THE AGENCY FOR ACCESS TO PUBLIC INFORMATION, CONTROL BODY OF LAW NO. 25,326) HAS THE AUTHORITY TO ADDRESS COMPLAINTS AND CLAIMS REGARDING NON-COMPLIANCE WITH DATA PROTECTION LAWS.
For contact with the Agency for Access to Public Information: Av. Pte. Julio A. Roca 710, 2nd Floor – City of Buenos Aires www.argentina.gob.ar/aaip datospersonales@aaip.gob.ar Tel. +5411-2821-0047.
10.5. Regarding Users who are citizens of the European Union, they may exercise the following rights before ZENTRICX:
Access: You have the right to access your information to know what personal data we are processing.
Rectification: You have the right to rectify any inaccurate Personal Data we are processing.
Deletion: You have the right to request the deletion of Personal Data you do not want us to continue processing.
Opposition: Under certain circumstances, and for reasons related to your particular situation, you have the right to object to us processing your Personal Data, in which case we will keep it blocked for the previously described period.
Limitation of processing: You have the right to request the limitation of the processing of your Personal Data to specific purposes you wish.
Portability: You have the right to receive the Personal Data you have provided us in a structured, commonly used, and machine-readable format, and to have it transmitted to another data controller other than ZENTRICX.
To exercise any of these rights, you must send an email to ZENTRICX at the following address innovacion@zentricx.com, attaching a copy of your ID or Passport.
If you deem it appropriate, the User may also file a complaint with the relevant supervisory authority.
11.EXCEPTIONS
11.1. Notwithstanding any other provision to the contrary in the Privacy Policy, ZENTRICX may disclose certain personal information of Users when it believes in good faith that such disclosure is reasonably necessary to:
Avoid legal liability;
Comply with legal requirements, such as a search warrant, subpoena, or court order;
Comply with a request from a government or regulatory authority; and/or
Protect the rights, property, or safety of ZENTRICX, Users, or a third party.
12.ETHICAL LINE/WHISTLEBLOWER LINE
12.1. ZENTRICX offers Users a communication channel to anonymously, confidentially, and securely report the existence of ethical irregularities by any member of ZENTRICX (hereinafter, the “Communication Channel”). ZENTRICX takes all necessary measures to prevent such irregularities from occurring and therefore provides the following Communication Channel for Users to collaborate in this effort. Below are some examples of irregularities, to keep Users informed:
Economic-financial fraud
Disclosure of confidential company information
Conflict of interest
Negligence or inappropriate use of organizational assets
Inappropriate use of the company’s name, logo, and brands
Workplace harassment or mistreatment
If a User observes any of the aforementioned irregularities, they should not hesitate to report it. Their report will be handled promptly, confidentially, and professionally.
12.2. This service will be provided by a third party to obtain the highest accuracy and objectivity possible. This means that those handling personal data and/or information provided by the User once a report is made through the Communication Channels detailed later will be those third parties on behalf of ZENTRICX. The User understands and agrees that for the purposes of using the Communication Channel, those third parties will handle the data solely for the purpose of reporting irregularities and promoting an ethical and compliant environment. ZENTRICX will process the reported information and forward it to a Committee, which will analyze the implications of the information and determine measures to take.
12.3. In this regard, ZENTRICX will make the following Communication Channel available to Users:
innovacion@zentricx.com
13.MODIFICATION OF THE PRIVACY POLICY.
13.1. ZENTRICX may modify the Privacy Policy at any time. New versions of the Privacy Policy will be notified by publishing the new version at https://zentricx.com/politica-privacidad/ and notifying via the contact methods declared by the User.
13.2. The User agrees that they will be deemed notified of any modifications to the Privacy Policy once ZENTRICX has published them at https://zentricx.com/politica-privacidad/, and sent notification via the contact methods declared by the User. Acceptance of the new version and the User’s continued use of the Service after the publication of the new version will be considered acceptance of these modifications to the Privacy Policy. Notwithstanding the above, the User agrees to periodically check https://zentricx.com/politica-privacidad/.
14.CONTACT
14.1. If the User has any questions regarding the Privacy Policy or its application, they should contact ZENTRICX at any time via email at innovacion@zentricx.com.
15.APPLICABLE LEGISLATION AND JURISDICTION
This Privacy Policy will be governed and interpreted according to the current legislation in the Argentine Republic, with any disputes related to it being resolved before the ordinary courts of the Autonomous City of Buenos Aires.
