This Application collects some Personal Data from its Users.

Owner and Data Controller

Qinaya s.a.s

Colombia

nit: 901491288-8

Owner contact email: contacto@qinaya.co

Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there

are: Cookies; Usage Data; email address; phone number, password; unique device identifiers.

Complete details on each type of Personal Data collected are provided in the dedicated sections of

this privacy policy or by specific explanation texts displayed prior to the Data collection.

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically

when using this Application.

Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide

this Data may make it impossible for this Application to provide its services. In cases where this

Application specifically states that some Data is not mandatory, Users are free not to communicate

this Data without consequences to the availability or the functioning of the Service.

Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.

Any use of Cookies – or of other tracking tools – by this Application or by the owners of third-party

services used by this Application serves the purpose of providing the Service required by the User, in

addition to any other purposes described in the present document and in the Cookie Policy, if

available.

Users are responsible for any third-party Personal Data obtained, published or shared through this

Application and confirm that they have the third party's consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure,

modification, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational

procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some

cases, the Data may be accessible to certain types of persons in charge, involved with the operation

of this Application (administration, sales, marketing, legal, system administration) or external parties

(such as third-party technical service providers, mail carriers, hosting providers, IT companies,

communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated

list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

● Users have given their consent for one or more specific purposes. Note: Under some

legislations the Owner may be allowed to process Personal Data until the User objects

to such processing (“opt-out”), without having to rely on consent or any other of the

following legal bases. ;

● provision of Data is necessary for the performance of an agreement with the User and/or

for any pre-contractual obligations thereof;

● processing is necessary for compliance with a legal obligation to which the Owner is

subject;

● processing is related to a task that is carried out in the public interest or in the exercise

of official authority vested in the Owner;

● processing is necessary for the purposes of the legitimate interests pursued by the

Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing,

and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a

requirement necessary to enter into a contract.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties

involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country

other than their own. To find out more about the place of processing of such transferred Data, Users

can check the section containing details about the processing of Personal Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this

document or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been

collected for.

Therefore:

● Personal Data collected for purposes related to the performance of a contract between

the Owner and the User shall be retained until such contract has been fully performed.

● Personal Data collected for the purposes of the Owner’s legitimate interests shall be

retained as long as needed to fulfill such purposes. Users may find specific information

regarding the legitimate interests pursued by the Owner within the relevant sections of

this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given

consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may

be obliged to retain Personal Data for a longer period whenever required to do so for the performance

of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the

right to erasure, the right to rectification and the right to data portability cannot be enforced after

expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its

legal obligations, respond to enforcement requests, protect its rights and interests (or those of its

Users or third parties), detect any malicious or fraudulent activity, as well as the following: Device

permissions for Personal Data access, Analytics, Registration and authentication, Access to

third-party accounts, Registration and authentication provided directly by this Application and

Advertising.

For specific information about the Personal Data used for each purpose, the User may refer to the

section “Detailed information on the processing of Personal Data”.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested

in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object

to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing

purposes, they can object to that processing at any time without providing any justification. To learn,

whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the

relevant sections of this document.

Information on advertising

This application has no advertising

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details

provided in this document. These requests can be exercised free of charge and will be addressed by

the Owner as early as possible and always within one month.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users

on this page and possibly within this Application and/or - as far as technically and legally feasible -

sending a notice to Users via any contact information available to the Owner. It is strongly

recommended to check this page often, referring to the date of the last modification listed at the

bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the

Owner shall collect new consent from the User, where required.