INTRODUCTION
Welcome to the VLRM Privacy Policy.
This Privacy Policy is issued on behalf of VLRM MARKETS, S.A. DE C.V. (“VLRM”). VLRM is incorporated as a company in El Salvador and licensed as Digital Asset Service Provider (DASP). References to “Company”, “We”, “Us” or “Our” in this Privacy Policy, are referring to VLRM, the person responsible for collecting and processing personal data. VLRM is the controller and responsible for this website (“this website”).
PURPOSE OF THIS PRIVACY POLICY
This Privacy Policy aims to provide information on how VLRM collects and processes personal data through the use of this website, including any data provided through this website at login, registration, upon contacting Us or upon signing up to Our newsletter.
This website is not intended for use by minors and We do not knowingly collect any data relating to minors. If We locate or are made aware that any personal information relating to minors has been collected or stored by Us, We will ensure that the processing of such personal information is for a lawful and legitimate purpose and make all reasonable efforts to delete and remove such personal information following the expiration or termination of that lawful and legitimate purpose.
If a user believes We might have any information from or about a child under 18, they are encouraged to contact Us immediately at [email protected].
It is important that this Privacy Policy is read together with Our Cookie Policy and any other Privacy Policy We may provide on specific occasions when We are collecting or processing personal data.
CONTROLLER
We are the controller of personal information in respect of the services We provide, unless stated otherwise. If anyone wishes to contact Us as the controller for the service relevant to them, they are encouraged to contact us using the contact details below.
CONTACT US
Any questions about this website Privacy Policy or Our privacy practices may be directed to [email protected].
Complaints: Users have the right to make a complaint at any time to the consumer protection agency in El Salvador.
We will encourage users with a complaint to contact Us prior to making such a complaint so that we may try to deal with the matter directly..
CHANGES TO THE WEBSITE PRIVACY POLICY AND USERS DUTY TO INFORM US OF CHANGES
It is important that the personal data We hold about users is accurate and current. Users are encouraged to keep Us informed of personal data changes during their relationship with Us.
We keep Our Privacy Policy under regular review. Please check back regularly for updates.
THIRD-PARTY LINKS
This Privacy Policy applies to information collected by this website, however, Our websites may contain links to third-party websites, plug-ins and applications.
Users are made aware that, by clicking on those links or enabling those connections, it may allow third parties to collect or share data about them. We do not control these third-party websites and are not responsible for their privacy policies. When a user leaves Our website, We encourage them to read the Privacy Policy of every website they may visit.
SOURCES OF PERSONAL INFORMATION
We may collect personal information about users when using Our services in order that We may:
- Enhance Our service to users and their experience with Us by collecting information about them in order that We may send, and they may receive marketing or other communications from Us (e.g., marketing emails, alerts, newsletters, etc) or register for an event.
- Enhance Our data security and to better Our service to users by automatically collecting certain information from or about them and your system/device, such as an IP address or UserID.
- Enhance users experience with Us via Cookies and similar technologies included on Our services.
We use third parties who may also collect personal information about users, and to the extent that any personal information is provided to Us by a third-party, other than the data subject, these third parties are responsible in their own right for adherence to all applicable data protection and privacy laws in regards to any data collected by them and provided to Us.
THE DATA WE COLLECT ABOUT USERS
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about users which We have grouped together as follows:
- Identity Data includes first name, last name, username or similar identifier, title, date of birth, selfie and nationality.
- Contact Data includes residential address, email address and telephone numbers.
- Financial Data includes bank account details.
- Transaction Data includes details about payments to and from users, other details of services they have purchased from Us and payments and trade data conducted on the Company’s platform.
- Technical Data includes internet protocol (IP) address, user login data, browser type and version, time zone setting and location, browser plug-in types/versions, operating system/platform, and other technology on the devices users use to access our website.
- Profile Data includes usernames and passwords, purchases or orders made by users, their interests, preferences, survey responses and feedback.
- Usage Data includes information about how users use Our website, products and services.
- Marketing and Communications Data includes user preferences in receiving marketing from Us and Our third parties and your communication preferences.
- Compliance data includes passport copy, selfie, source of funds, and proof of address (telephone bill/utility bill).
We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from users personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, We may aggregate user’s usage data to calculate the percentage of users accessing a specific website feature. However, if We combine or connect aggregated data with users’ personal data so that it can directly or indirectly identify them, We treat the combined data as personal data which will be used in accordance with this Privacy Policy.
We do not collect any special categories of personal data about users (this includes details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about health, and genetic and biometric data).
However, for compliance checks, We may be required to collect information about criminal convictions and offenses.
IF A USER FAILS TO PROVIDE PERSONAL DATA
Where We need to collect personal data by law, or under the terms of a contract We have with a user, and that user fails to provide that data when requested, We may not be able to perform the contract We have or are trying to enter into. In this case, We may have to cancel a product or service with that user, but We will notify them if this is the case at the time.
HOW IS PERSONAL DATA COLLECTED?
We use different methods to collect data from and about users including through:
Direct interactions.
A user may give Us their identity, contact, financial, compliance data by filling in forms or by corresponding with Us by post, phone, email or otherwise. This includes personal data they provide when they:
- apply for Our services;
- subscribe to Our services or publications;
- request marketing to be sent to them;
- enter a competition, promotion or survey; or
- send Us feedback or contact Us.
Automated technologies or interactions
As a user interacts with Our website, We will automatically collect technical data about their equipment, browsing actions and patterns. We collect this personal data by using Cookies and other similar technologies. Please see Our Cookie Policy for further details.
Third parties or publicly available sources
We may also employ the services of third party service providers to help Us in certain areas, such as website hosting, physical security, marketing and market research. Where third party service providers receive user information We will remain responsible for the use of such personal information. We take appropriate steps to ensure that such third parties treat a user’s personal information with the same consideration that We do.
HOW WE USE PERSONAL DATA
We will only use personal data when the law allows Us to. Most commonly, We will use personal data in the following circumstances:
- where We need to perform contractual obligations;
- where it is necessary for Our legitimate interests (or those of a third party) if a user’s interests and fundamental rights do not override those interests; and
- where We need to comply with a legal obligation.
Users may contact Us to find out more about the types of lawful bases that We will rely on to process personal data.
Generally, We do not rely on consent as a legal basis for processing personal data, although We will seek consent before sending any third party or direct marketing communications via email or text message. Users have the right to withdraw consent to marketing at any time by contacting Us.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
| PURPOSE OF PROCESSING | CATEGORY OF DATA | LAWFUL BASIS FOR PROCESSING |
|---|---|---|
| To register a new customer | (a) Identity (b) Contact (c) Compliance | Performance of a contract the user |
| To process and deliver a user’s order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to Us | (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications (f) Compliance | (a) Performance of a contract (b) Necessary for Our legitimate interests (to recover debts due to Us) |
| To manage Our relationship with a user which will include: (a) Notifying a user about changes to Our Terms of Use or Privacy Policy (b) Asking users to leave a review or take a survey | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications | (a) Performance of a contract (b) Necessary to comply with a legal obligation (c) Necessary for Our legitimate interests (to keep Our records updated and to study how customers use Our). |
| To enable users to partake in a prize draw, competition or complete a survey | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications | (a) Performance of a contract (b) Necessary for Our legitimate interests (to study how customers use Our products/services, to develop them and grow Our business) |
| To administer and protect Our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical (d) Compliance | (a) Necessary for Our legitimate interests (for running Our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise) (b) Necessary to comply with a legal obligation |
| To deliver relevant website content and advertisements measure or understand the effectiveness of the advertising We serve to users | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical | Necessary for Our legitimate interests (to study how customers use Our products/services, to develop them, to grow Our business and to inform Our marketing strategy) |
| To use data analytics to improve Our website, products/services, marketing, customer relationships and experiences | (a) Technical (b) Usage | Necessary for Our legitimate interests (to define types of customers for Our products and services, to keep Our website updated and relevant, to develop Our business and to inform Our marketing strategy) |
| To make suggestions and recommendations about goods or services that may be of interest to users | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications | (a) Necessary for Our legitimate interests (to develop Our products/services and grow Our business) (b) Consent |
| To make suggestions and recommendations to you about goods or services that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications | (a) Necessary for our legitimate interests (to develop our products/services and grow our business) (b) Consent |
MARKETING
We strive to provide users with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from Us
Users will receive marketing communications from Us if they have requested information from Us or services from Us and have opted in to receiving such marketing.
Third-party marketing
We will get express opt-in consent before We share users’ personal data with any third party for marketing purposes.
Opting out
A user may ask Us or third parties to stop sending marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust marketing preferences, by following the opt-out links on any marketing message sent or by contacting Us at any time.
Where a user opts out of receiving these marketing messages, this will not apply to personal data provided to Us as a result of a product/service purchase, warranty registration, product/service experience or other transaction.
COOKIES
A user may set their browser to refuse all or some browser cookies, or to alert them when websites set or access cookies. Users are notified that if they disable or refuse cookies, some parts of this website may become inaccessible or not function properly. More information about the cookies We use is described in Our Cookie Policy as per https://vlrm.markets.
CHANGE OF PURPOSE
We will only use personal data for the purposes for which We collect it, unless We reasonably consider that We need to use it for another purpose and that purpose is compatible with the original purpose. If a user wishes to get an explanation as to how the processing for the new purpose is compatible with the original purpose, they may contact Us.
If We need to use personal data for an unrelated purpose, We will notify the user and explain the legal basis which allows Us to do so.
Please note that We may process personal data without users’ knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
DISCLOSURES OF PERSONAL DATA
We may share personal information within VLRM in order to provide users with Our services. Access to personal information is limited to those employees, agents and contractors of VLRM who need access to it in order to provide users with Our services and to carry out legal or regulatory obligations.
We may also employ the services of third party service providers to help Us in certain areas, such as website hosting, physical security, marketing and market research. Where third party service providers receive a user’s information, We will remain responsible for the use of such personal information. We take appropriate steps to ensure that such third parties treat such personal information with the same consideration that We do.
We may from time to time be required to disclose personal information to law enforcement bodies, regulators, agencies or third parties under a legal requirement or court order. We act responsibly and take account of your interests when responding to any such requests.
We may have to share personal data with third parties to whom We may choose to sell, transfer or merge parts of Our business or Our assets. Alternatively, We may seek to acquire other businesses or merge with them. If a change happens to Our business, then the new owners may use personal data in the same way as set out in this website Privacy Policy.
We require all third parties to respect the security of personal data and to treat it in accordance with the law. We do not allow Our third-party service providers to use personal data for their own purposes and only permit them to process such personal data for specified purposes and in accordance with Our instructions.
CROSS-BORDER TRANSFERS OF PERSONAL INFORMATION
We share personal data with VLRM related companies. Some of Our external third parties are based outside El Salvador and their processing of personal data will involve a transfer of data outside El Salvador. Whenever We transfer such personal data out of El Salvador, We ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is applied in accordance with applicable law.
- We will only transfer personal data to countries that have been deemed to provide an adequate level of protection for personal data by El Salvador.
- Where We use certain service providers, We may use specific contracts which give personal data the same protection it has in El Salvador.
By providing Us with personal information, that user expressly consents to Our transferring their personal information to countries or jurisdictions which may not provide the same level of data protection as their home country, including without limitation countries or jurisdictions outside El Salvador.
Users may contact Us for further information on the specific mechanism used by Us when transferring personal data out of El Salvador.
DATA SECURITY
We have put in place appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, We limit access to personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process personal data on Our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify users and any applicable regulator of a breach where We are legally required to do so.
DATA RETENTION
How long will personal data be used?
We will only retain personal data for as long as is reasonably necessary in order that We may fulfill the purposes We collected it for and for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain personal data for a longer period in the event of a complaint or if We reasonably believe there is a prospect of litigation in respect to Our relationship with that user.
To determine the appropriate retention period for personal data, We consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of personal data, the purposes for which We process personal data and whether We can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
We apply a general rule of keeping personal information for as long as is required in order that We may fulfill the purposes for which it was collected. However, in some circumstances, We may retain personal information for longer periods of time (for instance, where We are required to do so in accordance with legal, tax or accounting obligations).
In specific circumstances, We may also retain personal information for longer periods of time so that We have an accurate record of users’ dealings with Us in the event of any complaints or challenges.
We maintain a retention procedure which We apply to records in Our care. In all cases, where information is no longer required We will ensure it is disposed of in a secure manner and, where required by applicable law, We will notify the user when such information has been disposed of.
In some circumstances, users may ask Us to delete their data.
In some circumstances, We will anonymise personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case We may use this information indefinitely without further notice.
USERS’ LEGAL RIGHTS
Under certain circumstances, users have rights under data protection laws in relation to your personal data, as follows:
Data subject access request. This will enable a user to receive a copy of the personal data We hold about them and to check that We are lawfully processing it.
Request correction of the personal data that We hold. This will enable a user to have any incomplete or inaccurate data We hold about them corrected, though We may need to verify the accuracy of the new data they provide to Us.
Request deletion of your personal data. This will enable a user to request Us to delete or remove personal data where there is no good reason for Us continuing to process it. They also have the right to request Us to delete or remove their personal data where they have successfully exercised their right to object to processing. This may occur in instances where We may have processed their information unlawfully or where We are required to erase their personal data to comply with local law. Note, however, that We may not always be able to comply with their request of erasure for specific legal reasons which will be communicated to the user, if applicable, at the time of their request.
Object to processing of personal data where We are relying on a legitimate interest (or those of a third party) and there is something about a user’s particular situation which makes them want to object to processing on this ground as they feel it impacts their fundamental rights and freedoms. Users also have the right to object where We are processing their personal data for direct marketing purposes. In some cases, We may demonstrate that We have compelling legitimate grounds to process their information which override their rights and freedoms.
Request restriction of processing of your personal data. This enables a user to request Us to suspend the processing of their personal data in the following scenarios:
- If they want Us to establish the data’s accuracy.
- Where Our use of the data is unlawful but they do not want Us to erase it.
- Where they need Us to hold the data even if We no longer require it as they need it to establish, exercise or defend legal claims.
- They have objected to Our use of their data but We need to verify whether We have overriding legitimate grounds to use it.
Request the transfer of personal data to you or to a third party. We will provide to a user, or to a third party they have chosen, their personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information for which they initially provided consent for Us to use or where We used the information to perform a contract with them.
Withdraw consent at any time where We are relying on consent to process personal data. However, this will not affect the lawfulness of any processing carried out before a user withdraws their consent. If they withdraw their consent, We may not be able to provide certain products or services to them. We will advise them if this is the case at the time they withdraw their consent.
No fee usually required
Users will not have to pay a fee to access their personal data (or to exercise any of the other rights). However, We may charge a reasonable fee if their request is clearly unfounded, repetitive or excessive. Alternatively, We could refuse to comply with their request in these circumstances.
What We may need from users
We may need to request specific information from users to help Us confirm their identity and ensure their right to access their personal data (or to exercise any of their other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact the user to ask for further information in relation to their request to speed up Our response.
These rights are not absolute and they do not always apply in all cases.
GLOSSARY
Lawful basis
Legitimate Interest means the interest of Our business in conducting and managing Our business to enable Us to give the best service/product and the best and most secure experience. We make sure We consider and balance any potential impact on users (both positive and negative) and their rights before We process their personal data for Our legitimate interests. We do not use personal data for activities where Our interests are overridden by the impact on the user (unless We have their consent or are otherwise required or permitted to by law). Further information about how We assess Our legitimate interests against any potential impact on users in respect of specific activities is available by contacting Us.
Performance of Contract means processing users’ data where it is necessary for the performance of a contract to which they are a party or to take steps at users’ requests before entering into such a contract.
Complying with a legal obligation means processing users’ personal data where it is necessary for compliance with a legal obligation that We are subject to.
Last edited: 11/10/2024