1. Site Information

1.1. La presente Política de Privacidad (en adelante la “Política de Privacidad”) se aplica a la utilización de los datos personales del Usuario, conforme se describe a continuación, del Sitio Web publicado en la URL: https://www.zirqular.com (en adelante, el “Sitio”), provista por ZIRQULAR (en adelante, “ZIRQULAR”), cuya función principal consiste en ofrecer al Usuario información relacionada a los servicios que ZIRQULAR provee (en adelante, el “Servicio”). En caso de ser necesario, ZIRQULAR podrá complementar esta Política de Privacidad con información y/o términos y condiciones específicos con relación al Servicio.

1.2. Mere access to the Site confers the status of user of ZIRQULAR (hereinafter the "User" or "Users") and expresses full and unreserved acceptance of each and every clause of the Privacy Policy in the version published by ZIRQULAR at the time the User accesses the Site or uses its Service. Consequently, the Privacy Policy shall constitute a valid and binding agreement between the User and ZIRQULAR in relation to 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") agreed with ZIRQULAR before the provision of each Service, which are complemented by the Privacy Policy.

1.3. The purpose of the Privacy Policy is to inform the owners of the Personal Data, as defined below, in respect of which information is being collected, of the specific processing of their data, the purposes of the processing, the contact details for exercising their rights, the periods of conservation of the information and the security measures, among other things.

1.4. The provisions of the Privacy Policy shall apply to all ZIRQULAR Users, whether or not they have submitted their Personal Data.

BEFORE BROWSING AND/OR USING THE SITE AND/OR THE SERVICE, PLEASE READ THIS PRIVACY POLICY CAREFULLY. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, YOU SHOULD REFRAIN FROM USING THE SITE AND/OR THE SERVICE.

2. Responsibility for the processing of your personal data

2.1.  ZIRQULAR shall be the company responsible for the processing of the Personal Data provided by the User on the Site, or collected or processed on the Site, by, for or through or in connection with the Services.

In any event, if the holder of the Personal Data is a visitor to the Site or a User of the Site, any collection, use and sharing of information relating to his or her Personal Data shall be subject to this Privacy Policy, the supplementary Cookie Policy and any updates thereto.

2.2. For ZIRQULAR, the privacy of the User's Personal Data is very important. If the User has any doubts about the Privacy Policy or the use of the Site or the Service, they must contact ZIRQULAR at any time by sending an email to info@zirqular.com.

3. Collecting information from users

3.1. ZIRQULAR processes the User's Personal Data only with the express consent that the User gives by accepting this Privacy Policy. The User also accepts that ZIRQULAR may collect information about him/her using cookies and tags, as well as information provided by the User through the forms on the Site when registering and/or using the Service. In the event that a User of the Site does not wish to accept these cookies, they may configure their browser to give them the option of accepting each cookie and rejecting those they do not wish to accept. 

3.2. All the information that ZIRQULAR collects is detailed below:

1. Information provided by the User: (i) name and surname; (ii) telephone, (iii) email, (iii) address and town, (iv) CV, (v) Linkedin profile, (vi) password to access a personalised profile on the ZIRQULAR website; (hereinafter, collectively, the "Personal Data"). 
2. Passively Collected Information: When the User accesses the Site and/or uses the Service, ZIRQULAR 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 browser type and version, time zone settings, and operating system, geographic locations, usage sessions, time spent on the Site, frequency of use.
3. Information from other sources: ZIRQULAR may receive information about the User from other sources such as public sources, third parties (e.g. consumer reporting agencies).
4. Information from cookies, tags and/or any other automated information detection methods provided by the tools offered on the Site: The information collected by ZIRQULAR may include browsing behavior, IP address, logs, and other types of information. However, ZIRQULAR will not collect personally identifiable information directly from any User using cookies or tags or any other automated information detection method provided by the tools offered on the Site.

4. Purpose of the processing of personal data

4.1. ZIRQULAR processes the User's personal information for the following purposes:

1. Authorise and administer your access to the Site, verify your identity, authenticate your visits and provide the Service to you;
2. To manage, analyse, develop, customise and improve the Site and the Service;
3. To provide the Service and its improvements to Users;
4. Analysis in order to be able to provide Users with the Service, and to improve the method of payment;
5. To send its Users notifications, news and novelties of interest to them, in addition to those of an institutional or legal nature;
6. To analyse the conduct and behaviour of Users as such on its Site, in order to try to improve its Service and to try to provide them with better solutions to their needs;
7. Send information and newsletters about ZIRQULAR, its Services and events via WhatsApp, telephone, post, email, even when our relationship has ended, unless the interested party states otherwise; 
8. To facilitate the fulfilment of legal obligations if requested to do so by courts, or national or international state bodies that require it and request it in the corresponding form. 
9. Obtain a diagnosis of any connection problems that may exist between the ZIRQULAR Site and Users, improving the quality of the Services.

5. Use of information collected from users

5.1. ZIRQULAR shall use and store the information provided by Users and that collected by ZIRQULAR in order to provide the Service and its improvements to Users, in an attempt to meet their needs, for the maximum period established by the applicable legislation.

5.2. ZIRQULAR shall retain and use the Personal Data provided by the User for the period during which the latter uses the Site and/or uses the Service in order to provide the best Service. Once the relationship between the Parties has ended, for whatever reason, ZIRQULAR reserves the right to retain the information until the purpose of its processing has been completed. After the aforementioned period, ZIRQULAR shall proceed to destroy the Personal Data.

5.3.  ZIRQULAR may send its Users notifications, news and updates of interest to them, as well as notifications of an institutional or legal nature in order to offer its Services, provided that this is accepted by the User and provided that the User has not exercised their right to opt-out. 

5.4.  ZIRQULAR may share information with other service companies or websites or similar for the purpose of fulfilling the purpose of the ZIRQULAR Service and improving its quality. Generally, such companies or websites have their own data privacy policies for data protection purposes. However, ZIRQULAR will use its best efforts to ensure that the privacy of the information shared is protected to the best of its ability. Where appropriate, ZIRQULAR will endeavour to enter into express agreements on data protection and data privacy. Notwithstanding the foregoing, ZIRQULAR shall not be liable for any damage caused by such companies and/or websites with regard to their duty to protect the protection, confidentiality and privacy of the data they handle.

5.5. With regard to the processing of personal data of European Union citizens, ZIRQULAR shall comply with the principles and obligations set out in EU Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (GDPR).

5.6.  ZIRQULAR no venderá, alquilará ni negociará ningún Dato Personal a ningún tercero para fines comerciales. Cualquier persona que hubiera provisto información de contacto personal a través del Sitio de ZIRQULAR, podrá enviar un correo electrónico a info@zirqular.com a fin de actualizar, borrar y/o corregir su información personal de contacto. ZIRQULAR responderá dicho requerimiento dentro de las 48 (cuarenta y ocho) horas siguientes a la recepción del mismo vía correo electrónico.

5.7. The ZIRQULAR Website may contain links to other websites that are not owned by ZIRQULAR. Accordingly, ZIRQULAR shall not be responsible for the actions of such websites, to which this Privacy Policy does not apply. We recommend that you examine the detailed privacy policy on those websites to understand the information collection procedures they use and how they protect your personal data.

6. Assignment and transfer of personal data

6.1. Solely for the purposes set out in this Privacy Policy and for the purposes of providing the Service, ZIRQULAR may disclose the User's Personal Data and/or personal information, where necessary, to authorities, ZIRQULAR's partners and other third parties, such as third party service providers used in connection with the Service, for example to perform marketing, advertising, communication, infrastructure and IT services, to customise and improve our Service, to process credit card transactions or other payment methods. When ZIRQULAR engages a service provider it will provide them with the information they need to perform their specific function, which may include Personal Data and other information that the User provides through the Site. These service providers are authorised to use Personal Data only as necessary to provide their services.

6.2. In some cases, such as the Republic of Argentina or the Oriental Republic of Uruguay, personal information may be transferred out of the country to countries with the same or better levels of protection. In the event that personal information is transferred to countries with lower levels of protection, ZIRQULAR will make such 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. In turn, ZIRQULAR may share Users' Personal Data with third parties, with the prior and express consent of the User.

6.4. With regard to the processing of personal data of citizens of the European Union (EU) and/or European Economic Area, we inform you that:

1. ZIRQULAR may transfer the personal data of Users of the Site and any data that may be generated when using the Site and/or the Service to entities located in the territory of the Republic of Argentina, this being a country declared by the European Commission to have an adequate level of protection in accordance with its Decision 2003/490/EC of 30 June 2003.
2. ZIRQULAR may transfer the aforementioned Personal Data to other entities located in third countries that have been declared by the European Commission to have an adequate level of protection or with which agreements have been signed with the appropriate guarantees imposed by the European authorities (e.g. standard data protection clauses adopted by the Commission, etc.).

7. Confidentiality and security of information

7.1. ZIRQULAR has adopted reasonable security measures to protect Users' information and prevent unauthorised access to their data or any unauthorised modification, disclosure or destruction thereof. The information collected by ZIRQULAR shall be kept strictly confidential. Access to personal data is restricted to those employees, contractors, operators, and representatives of ZIRQULAR who need to know such data in order to perform their duties and to develop or improve our Service. ZIRQULAR holds its suppliers to the same standards of confidentiality. ZIRQULAR does not allow access to this information to third parties outside ZIRQULAR, except at the express request of the User.

7.2. Without prejudice to the foregoing, considering that the Internet is an open, publicly accessible system, ZIRQULAR cannot guarantee that unauthorised third parties will not be able to overcome security measures and use Users' information improperly. In any case, ZIRQULAR maintains security and incident response plans to control incidents related to unauthorised access to the private information it collects or stores.

8. Changes in corporate structure

8.1.   ZIRQULAR reserves the right to transfer the information collected in the event of a sale or merger of ZIRQULAR, or an acquisition of ZIRQULAR's principal assets, or any other transfer of ZIRQULAR to another entity. In such event, ZIRQULAR shall take reasonable steps 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 intended for minors, in the event that a minor has access to them, their use must be supervised by parents, guardians or legal guardians. The Site and/or Service are only permitted for those who are of legal age to contract and are not legally inhibited or in any way prohibited from exercising legal acts, rights and/or obligations. In view of this, minors under 18 years of age are not permitted to access the Site and/or Service, nor are they permitted to provide any Personal Data or any other type of information.

9.2. In addition, since minors may not be able to properly understand the Privacy Policy and its implications, or to make valid choices about the options available through its Services, ZIRQULAR urges all parents, guardians or legal guardians under whose supervision minors accessing the ZIRQULAR Service are placed to actively and carefully participate in the activities of minors on the Internet or through the Site, the online Service used by such minors, the information accessed by such minors, whether when such minors visit the Site, the online Service used by such minors, or the information accessed by such minors, to actively and carefully participate in the activities of minors on the Internet or through the Site, the on-line Service used by such minors, the information accessed by such minors, whether when such minors visit the ZIRQULAR Site or any other third party site, and to teach and guide them on how to protect their own personal information while they are browsing the Internet.

10. Users' rights over information

10.1.  ZIRQULAR shall endeavour, by all means at its disposal, to provide Users about whom it has collected or stored personal information with access to their Personal Data ("Right of Access"), as well as the rectification, modification or updating thereof ("Right of Rectification"), or even the deletion of such personal data ("Right of Removal"), unless ZIRQULAR may deny such requests (hereinafter, the "Requests"), in the event that it is obliged or entitled to retain such Data in accordance with applicable law:

1. For this purpose, the User must send his/her Request by sending an e-mail with the subject "Access to Personal Data" to info@ zirqular.com. ZIRQULAR may require the User to identify himself/herself, which may be verified by ZIRQULAR, and to specify the Personal Data to which he/she wishes to access, rectify or remove.
2. ZIRQULAR may refuse to process Requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardise the privacy of other Users, or are considered impractical, or for which access to Personal Data is not necessary.
3. The service of access, rectification and removal of Personal Data shall be provided by ZIRQULAR free of charge, except where it would require a disproportionate or unreasonable effort, in which case an administration fee may be charged.

10.2. Users also authorise ZIRQULAR to use their Personal Data to send communications and advertising materials (such as newsletters and brochures) relating to ZIRQULAR's activities and/or which, at the sole discretion of ZIRQULAR, may be of interest to Users. Users may at any time request the suspension of such mailings.

10.3. To exercise their rights, Users may send a request to the email address info@zirqular.com.

10.4. Likewise, and in the event of any eventuality, the User is informed that as the owner of his/her Personal Data, he/she has the right to exercise the right of access to the same free of charge at intervals of no less than six months, before the corresponding application authorities, who have the power to deal with complaints and/or claims filed in relation to non-compliance with the rules on personal data protection. 

10.5. Users who are citizens of the European Union may exercise the following rights against ZIRQULAR:

1. Access. You have the right to access your information to find out what Personal Data in particular we are processing.
2. Rectification. You have the right to rectify any inaccurate Personal Data that we are processing.
3. Erasure. You have the right to request the erasure of Personal Data that you no longer wish us to process.
4. Objection. In certain circumstances, and for reasons relating to your particular situation, you have the right to object to our processing of your Personal Data, in which case we will keep it blocked for the period described above.
5. Limitation of processing. You have the right to request the limitation of the processing of your Personal Data to those specific pu rposes you wish.
6. Portability. You have the right to receive the Personal Data that you have provided to us in a structured, commonly used and machine-readable format and to have it transferred to a data controller other than ZIRQULAR.

Para ejercer cualquiera de ellos deberá proceder al envío de una correo electrónico a ZIRQULAR a la siguiente dirección info@zirqular.com en el que adjunte una copia de su documento de identidad o Pasaporte. 

If deemed appropriate, the User may also lodge a complaint with the relevant supervisory authority.

11. Exceptions

11.1. Notwithstanding any other provision in the Privacy Policy to the contrary, ZIRQULAR may disclose certain personal information of Users, where it believes in good faith that such disclosure is reasonably necessary to:

1. Avoiding legal liability;
2. To comply with a legal requirement, such as a search warrant, subpoena or court order;
3. To comply with a requirement of a governmental or regulatory authority; and/or
4. Protect the rights, property or security of ZIRQULAR, Users or a third party.

12. Ethics hotline / Whistleblower hotline

12.1. ZIRQULAR provides the User with a communication channel to anonymously, confidentially and securely report the existence of ethical irregularities by any member of ZIRQULAR (hereinafter, the "Communication Channel"). ZIRQULAR takes all necessary measures to ensure that such irregularities do not occur, and therefore provides the Communication Channel detailed below for the User's cooperation to this end. For further details, we highlight below some examples of irregularities, by way of example, so that the User is kept informed:

1. Economic and financial fraud.
2. Provision of confidential company information.
3. Conflict of interest.
4. Neglect or inappropriate use of the organisation's assets.
5. Inappropriate use of company name, logo and trademarks.
6. Harassment or ill-treatment at work.

In the event that the User contemplates such an irregularity, he/she should not hesitate to report it. Your report will be dealt with promptly, confidentially and professionally.

12.2. This service will be provided by a third party in order to obtain the greatest possible accuracy and objectivity. This means that the personal data and/or information provided by the User once a report is made through the Communication Channels detailed below will be processed by said third parties on behalf of and by order of ZIRQULAR. The User understands and accepts that for the purposes of using the Communication Channel, the data will be processed by said third parties, solely for the purposes of making complaints and promoting an ethical and compliant environment. ZIRQULAR will process the information reported and will forward it to a Committee, which will analyse the implications of the information and the measures to be taken.

12.3. In view of the above, ZIRQULAR shall make the following Communication Channels available to Users:

1. Web Site: www.resguarda.com/zirqular
2. E-mail: denuncias.zirqular@resguarda.com

13. Modification of the privacy policy

13.1. ZIRQULAR podrá modificar la Política de Privacidad en cualquier momento. Las nuevas versiones de la Política de Privacidad serán notificadas mediante publicación de dicha nueva versión en https://www.zirqular.com/privacy/ y notificada por las vías de contacto que el Usuario declare en su caso.

13.2. El Usuario acepta que será dado por notificado de cualquier modificación a la Política de Privacidad una vez que ZIRQULAR hubiera publicado las mismas en https://www.zirqular.com/privacy/, y enviado a la notificación por las vías de contacto declaradas por el Usuario. La aprobación de dicha nueva versión, y que la continuación del Usuario en el uso del Servicio una vez publicada la misma dicha nueva versión se considerará como aceptación de dichas modificaciones a la Política de Privacidad. Sin perjuicio de lo mencionado, el Usuario acepta chequear https://www.zirqular.com/privacy/ periódicamente.

14. Consultations

14.1.  If the User has any doubts about the Privacy Policy or its application, he/she should contact ZIRQULAR at any time by e-mail at info@zirqular.com.