PRIVACY AND DATA PROTECTION POLICY
Last Updated: January 1st, 2025
Welcome to the Privacy and Data Protection Policy (hereinafter, the “Policy”) of Constructora Virtual EIRL (hereinafter, the “Company” or “we”), located at Av. Rómulo Betancourt 559, Santo Domingo. This Policy describes how we collect, use, protect, and share personal data (hereinafter, the “Data”) of users (hereinafter, the “User” or “you”) who interact with our WhatsApp Business account, the integration with the Make platform (“Make”), and/or any other channel or medium the Company may use to provide its services.
The confidentiality and protection of your Data is one of our priorities. Therefore, we encourage you to read this Policy carefully before using or continuing to interact with our services.
1. SCOPE AND ACCEPTANCE
1.1. Scope of Application. This Policy applies to the collection and processing of Data carried out when you (i) interact with our WhatsApp Business account, (ii) use or communicate through the Make platform that we integrate to automate workflows, and/or (iii) access our websites or other digital media that we enable to manage our communications and services.
1.2. Acceptance. By interacting with our WhatsApp Business account or through any other channel described, you acknowledge and accept this Policy. If you do not agree with its content, please refrain from using and interacting with those channels.
1.3. Applicable Regulations. Our Policy is in compliance with the data protection laws and regulations applicable in the relevant jurisdiction. If any specific adaptation is required (e.g., to comply with the European Union’s GDPR or local regulations), we will make the necessary adjustments to ensure regulatory compliance.
2. DATA WE COLLECT
2.1. Personal Data. We may request or collect Data that can individually identify you, such as:
• Full name
• Phone number
• Email address
• Interaction data (messages sent, date and time of communication, etc.)
2.2. Technical and Usage Data. We may also automatically collect certain information when you interact with our platforms, for example:
• Device information (device type, operating system, unique identifier, etc.)
• IP addresses and approximate geolocation data (to the extent permitted by law)
• Session and browsing data (date, time, and duration of interactions, sections visited, etc.)
2.3. Sensitive Data. The Company does not deliberately request or process sensitive data (e.g., data related to health, sexual orientation, political or religious beliefs). We kindly request you not to include this type of information in your messages or forms. If, on your own initiative, you provide us with sensitive data, it will be understood that you give your express consent for the limited processing of said data solely for the purpose of the established communication.
3. PURPOSES OF DATA PROCESSING
The collected Data is used for the following purposes:
1. Providing and improving our services through WhatsApp Business and the integration with Make (for example, to respond to inquiries, manage requests, or provide technical support).
2. Personalizing the User experience, by sending relevant information about products, services, promotions, or events that may be of interest to you.
3. Managing the commercial or contractual relationship with the User, including handling billing, collections, and other administrative matters.
4. Complying with applicable legal obligations, as well as with requests from competent authorities.
5. Ensuring the security of our platforms, systems, and processes, preventing fraud, abuse, or unauthorized access.
4. LEGAL BASIS FOR PROCESSING
4.1. Consent. Where required by law, we will request your express consent to collect and process your Data, for example, for sending promotional or commercial information.
4.2. Contractual Execution. Processing your Data may be necessary for the performance of a commercial or contractual relationship, for example, to process payments or manage the provision of our services.
4.3. Legitimate Interest. We may process your Data when it is necessary for the Company’s legitimate interests, provided these interests do not override your fundamental rights and freedoms.
4.4. Legal Obligation. In certain circumstances, processing your Data will be necessary to comply with legal obligations or respond to requests from authorities.
5. DATA SHARING AND TRANSFERS
5.1. Service Providers and Third Parties. In order to provide services and fulfill the purposes described above, we may share your Data with:
• Providers of technological services (including the Make platform), data hosting, and support.
• Providers that facilitate management, accounting, billing, and/or marketing tasks.
5.2. International Transfers. Should we need to transfer your Data to a country or jurisdiction other than your place of residence for operational reasons, we will ensure the implementation of appropriate security measures to guarantee an adequate level of protection in accordance with the applicable regulations.
5.3. Legal Requirements. We may disclose your Data if it is reasonably necessary for the following purposes:
• To comply with legal provisions, court orders, or requests from competent authorities.
• To protect the rights, property, and safety of the Company, its employees and customers, or third parties.
6. DATA RETENTION
6.1. Retention Periods. We will only keep your Data for as long as it is necessary for the purposes described in this Policy, or as long as there is a legal obligation to do so. Once the Data is no longer needed for the stated purposes, it will be securely deleted or anonymized, except where there is a legal requirement to retain it.
6.2. Retention Criteria. The retention period for your Data will depend on the legal basis for processing and the commercial or contractual relationship we have with you.
7. USERS’ RIGHTS
7.1. Right of Access, Rectification, and Erasure. Depending on the relevant jurisdiction, you may have the right to:
• Access your Data and receive information about how it is processed.
• Rectify any inaccurate or incomplete Data.
• Request the erasure of your Data when it is no longer needed for the purposes described, and there is no legal obligation to retain it.
7.2. Right to Object and Restrict Processing. You may object to the processing of your Data at any time for legitimate reasons, and you may request restriction of processing in certain circumstances, for example, while a dispute regarding the accuracy of your Data is being resolved.
7.3. Right to Data Portability. If applicable under data protection regulations, you have the right to receive your personal Data in a structured, commonly used, and machine-readable format and to transfer it to another data controller.
7.4. Exercise of Rights. To exercise any of the above rights, please contact us through the channels indicated in Section 9 of this Policy. We may request additional information to verify your identity and process your request.
8. SECURITY MEASURES
We implement technical, administrative, and organizational security measures to protect your Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction, such as:
• Using encryption protocols (where applicable) for data transmission.
• Logical and physical access controls, as well as internal confidentiality policies and security procedures.
• Periodic assessments of our data protection practices to keep them up to date and effective.
Despite our commitment to safeguarding your Data, no system is entirely secure or free of errors. We encourage you to take necessary security measures, such as protecting your devices and avoiding sharing sensitive personal information through insecure channels.
9. CONTACT
If you have any questions, concerns, or requests regarding this Policy, or if you wish to exercise your data protection rights, please contact us through the following means:
• Email: constructoravirtual@outlook.com
• Phone: (849) 650-4020
• Address: Av. Rómulo Betancourt 559, Santo Domingo
We are committed to responding to your inquiries within a reasonable time and, in any event, within the time limits established by applicable law.
10. CHANGES TO THIS POLICY
We reserve the right to update or modify this Policy at any time, whether to reflect changes in our data processing practices or to comply with new legal requirements. When material changes occur, we will notify you by means of a prominent notice on our website, WhatsApp Business channel, or any other appropriate medium. Continued use of our services after the publication of any changes will constitute your acceptance of those changes.
By using our services, including interacting with our WhatsApp Business account and the integration with the Make platform, you acknowledge that you have read, understood, and accepted the terms of this Privacy and Data Protection Policy. If you do not agree with its content, please refrain from using these services.
Constructora Virtual EIRL
Av. Rómulo Betancourt 559
Santo Domingo
(809) 683-7871
constructoravirtual@outlook.com
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