TELEDIPITY is committed to protecting your privacy. We will never sell your data to third parties, and we deliberately avoid using third-party ad services and retargeting cookies.

Last Update: August 12, 2024

TELEDIPITY, SOCIEDAD ANÓNIMA PROMOTORA DE INVERSIÓN DE CAPITAL VARIABLE (hereafter, "TELEDIPITY") AS A SOCIALLY RESPONSIBLE COMPANY AND RESPECTFUL OF PERSONAL DATA, PUTS AT YOUR DISPOSAL THIS PRIVACY NOTICE.

TELEDIPITY IS COMMITTED TO PROTECTING YOUR PRIVACY AND WILL NEVER SELL YOUR PERSONAL DATA TO A THIRD PARTY.

THIS DOCUMENT AIMS TO INFORM THE DATA OWNERS THE INFORMATION WE PROCESS AND ITS PURPOSES, AS WELL AS THE PROCEDURES TO EXERCISE THEIR RIGHTS OF ACCESS, RECTIFICATION, CANCELLATION, AND OBJECTION. TELEDIPITY AIMS TO GUARANTEE THE DATA OWNER'S RIGHT TO INFORMATIONAL SELF-DETERMINATION.

THIS PRIVACY NOTICE IS AVAILABLE TO THE DATA OWNER IN THE WEBSITE (https://www.teledipity.com) AND MOBILE APPLICATION, BOTH OPERATING UNDER THE NAME OF TELEDIPITY APP.

I. DEFINITIONS.

With the purpose of facilitating the interpretation of the present document, the terms used with an initial capital letter will have the meaning shown below, which will apply to such terms both in its singular and plural form.

Privacy Notice. – The full extent of the present document.
Application. – The application and website (https://www.teledipity.com) operating under the name TELEDIPITY APP.
Cookies. – Data files stored in the hard drive of the computer or electronic communications device of a user, when browsing in a website or a specific application. It allows exchanging status information between the site and the user's browser. The status information may reveal means of session identification, authentication or user preferences, as well as any other data stored by the browser regarding the website or Application.
Content Creator. – Third parties that provide online courses for the Application and that receive the User's email address after their subscription to their content.
Personal Data. – Any information concerning an identified or identifiable individual.
Academic and Employment Data. – Information related to users, such as their educational career, title, professional ID number, position, official address, official mail, among others.
Contact Data. – Information that allows to maintain or establish contact with its Data Owner, such as email address, cell phone number, among others.
Financial and Property Data. – Information related to assets, rights, charges or obligations susceptible of economic valuation, such as movable and immovable property; tax information; credit history; income and expenses; bank accounts; insurance; credit card number; Social Security number; salaries bonds; benefits.
Identification Data. – Information that allows to differentiate the Data Owner from others, such as name, marital status, Unique Population Registration Code (CURP), passport number, voter identification number, place and date of birth, nationality, photograph, address and age.
Numerology Data. – Any information that allows TELEDIPITY to perform a personality analysis of the User, such as aspirational or personality data.
Sensitive Personal Data. – Personal data touching on the most private areas of the Data Owner's life, or whose misuse might lead to discrimination or involve a serious risk for said Data Owner. In particular, sensitive data is considered that which may reveal items such as racial or ethnic origin, present and future health status, genetic information, religious, philosophical and moral beliefs, union membership, political views, sexual preference.
Social Media Data. – Information related to the user's profile, interaction, activities and publications made by the Data Owner in various social network platforms accessible to the public.
Relationship Data. – Information related to a person, based on its personal, professional and commercial relationships.
ARCO Rights. – The rights of access, rectification, cancellation and objection that the Data Owner has, whose exercise is recognized and regulated in the Law, its Regulations and in this Privacy Notice. This concept shall also comprise the rights provided in the GDPR
Data Processor. – The individual or legal entity that, alone or jointly with others, processes personal data on behalf of the data controller.
Primary Purposes. – Primary purposes for which the Personal Data of the Owner is processed. They give origin to the relationship between TELEDIPITY and the Owner and are configured as strictly necessary for the maintenance thereof.
Secondary Purposes. – Purposes for which the Owner's Personal Data is processed that are not strictly necessary for the maintenance of the relationship between TELEDIPITY and the Data Owner. The Owner's Personal Data Processing for these purposes contributes to the fulfillment of the corporate purpose of TELEDIPITY.
Law. – The Mexican Federal Law on Personal Data Protection held by Private Parties.
Regulation. – Regulations to the Federal Law on Personal Data Protection held by Private Parties.
Data Controller. – Individual or private legal entity that decides on the processing of personal data. Unless otherwise specified, TELEDIPITY, SOCIEDAD ANÓNIMA PROMOTORA DE INVERSIÓN DE CAPITAL VARIABLE (referred to in the present as TELEDIPITY), stands as Data Controller.
Data Owner. – The individual to whom personal data relates.
Transfer. – Any data communication made to a person other than the Data Controller or Data Processor.
Processing. – Retrieval, use, disclosure or storage of personal data by any means. Use covers any action of access, management, exploitation, transfer or disposal of personal data.
Users. – The individual who uses the TELEDIPITY APP, who, unless stated otherwise, must coincide with the Data Owner.
GDPR. – General Data Protection Regulation.
LGPD. – Lei Geral de Proteção de Dados (for users located in Brazil).

II. PERSONAL DATA CONTROLLER: IDENTITY AND ADDRESS.

The Data Controller is the legal identity named TELEDIPITY, SOCIEDAD ANÓNIMA PROMOTORA DE INVERSIÓN DE CAPITAL VARIABLE (herein, TELEDIPITY), who is committed to comply with the provisions of this Privacy Notice, as well as the Law, its Regulations and the Privacy Notice Guidelines.

TELEDIPITY's address is Perif. Blvd. Manuel Avila Camacho 184 (one hundred and eighty four), floor 9 (nine), Reforma Social, Miguel Hidalgo, zip code 11650 (one one six five zero), Mexico City, Mexico. This address is required for everything regarding this Privacy Notice, for all obligations that may arise from the Law and its Regulations, as well as to receive all kinds of notifications.

III. PERSONAL DATA SUBJECT TO PROCESSING.

TELEDIPITY informs the Data Owners that the Personal Data stated below, in a categorized way, will be subject to Processing. Likewise, TELEDIPITY informs them that no Sensitive Personal Data will be subject to Processing.

III.I. Users Personal Data:

Contact Data.
Financial and Property Data.
Identification Data.
Numerology Data.

In terms of 8 of the Law, the Data Owner consents TELEDIPITY to process his/her Personal Data, including those of a financial and property nature. The consent given by the Data Owner is limited only to the purposes described in this Privacy Notice.

The Data Owner undertakes that the information provided will be accurate, current and correct. Likewise, under the penalty of perjury, declares that he/she has authorization from the third parties whose Personal Data he/she transmits to TELEDIPITY. Because of the foregoing, agrees to indemnify and hold harmless TELEDIPITY from any claim or lawsuit derived from the provisions stated in the present paragraph.

IV. PROCESSING PURPOSES.

The Processing of Personal Data carried out by TELEDIPITY aims to establish relationships within the framework of security, trust, and efficiency. The information will be used to fulfill the following purposes:

A. PRIMARY PROCESSING PURPOSES FOR USERS.

Authenticate the identity of the Data Owners and open a file under their name in an internal and confidential database.
Provide profiling services and recommendations related to spirituality, personal growth and numerology.
Contact the Data Owners by any means to manage and monitor their requests for products or services.
Provide recommendations for books, online courses, podcasts, and audiobooks.
Membership processing, so that the User can request the Services.
Address requests for the exercise of ARCO Rights, revocation of consent and solve any doubt, complaint, clarification or suggestion regarding the protection of Personal Data.
Contact the Data Owner to clarify and monitor payments.
Contact the Data Owner to answer complaints, suggestions, and comments regarding the services contracted.
Register and update the information of the Data Owner in TELEDIPITY's systems for its conservation, identification, and consultation, as well as to comply with legal provisions and requirements from competent authorities.

B. SECONDARY PROCESSING PURPOSES FOR USERS.

Generate a record in TELEDIPITY's contact's database.
Contact the Data Owners for the purpose of notifying updates in the Application, reports on the Processing and status of their Personal Data, as well as changes in this Privacy Notice or in the Terms and Conditions of the Application.
Evaluate the quality of TELEDIPITY's support.
Sending promotional and advertising information, as well as information on new services or products, invitations to events, courses or seminars, monthly newsletters, and information or news bulletins.
Provide recommendations on businesses, products or services of third parties, which may be of the Data Owner's interest.
Use the Data Owner's information for statistical purposes or internal analysis.
TELEDIPITY may use the Data Owner's information to:
1. improve browsing experience by personalizing the Websites and to improve the Subscription Service;
2. send information to the Data Owner which TELEDIPITY thinks may be of interest by email or other means;
3. send marketing communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest to the Data Owner, and
4. provide other companies with statistical information about TELEDIPITY's Data Owners— but this information will not be used to identify any individual user.
TELEDIPITY may contact the Data Owner on behalf of external business partners about a particular offering that may be of interest to them. In those cases, TELEDIPITY will not transfer the Data Owner's unique Personal Information to the third party
TELEDIPITY will use the Data Owner's information only in compliance with this Privacy Notice. Data Owners who subscribe to the TELEDIPITY Application are obligated through TELEDIPITY's agreements with them to comply with this Privacy Notice.

TELEDIPITY will never sell the Personal Data of the Data Owner to any third party.

V. MECHANISMS SO THAT THE DATA OWNERS MAY REFUSE THE PROCESSING OF THEIR PERSONAL DATA FOR SECONDARY PURPOSES.

If the Data Owner does not want his Personal Data to be used for all or any of the Secondary Purposes in the previous section, the Data Owner must send an email to the address privacy[at]teledipity.com with the subject "Objection of Processing for Secondary Purposes."

In the body of the email, the Data Owner must specify for what purposes he/she wishes to express his refusal, as well as his Identification Data so that his request is fulfilled.

VI. PERSONAL DATA TRANSFERS.

TELEDIPITY will carry out the following Transfers of the Owner's Personal Data:

TELEDIPITY transfers the Users' email to the Content Creators of whom the Data Owner downloads content to allow the Content Creators to send promotional information regarding the products or services they offer.
Likewise, TELEDIPITY will carry out the Transfers listed in article 37 of the Law, for which the Owner's consent is unnecessary.

TELEDIPITY's Transfers include:

VII. CONSENT

Because transferring the User's email to the Content Creators and Acquirers requires the User's consent, under article 36 of the Law, by accepting this Privacy Notice, the User allows TELEDIPITY to transfer his/her email address to the Content Creators and/or Acquirers. The transfer to Content Creators has the purpose of the Data Owner being added to the emailing list of promotional information regarding products or services.

In case the User does not accept or wishes to oppose to the Transfer of their Personal Data, the User must use the mechanisms, provided in section V of the present Privacy Notice, so that he/she may refuse the Processing of Personal Data for Secondary Purposes.

VIII. THIRD PARTIES PERSONAL DATA TRANSFERS.

As part of the services offered by TELEDIPITY APP, the User will find the Compatibility Reports. For TELEDIPITY to be able to generate such reports, the User must provide data from third parties. It is important to mention that the User must have the third parties' consent to Transfer their data to TELEDIPITY.

Consequently, the User declares, under oath, that the data that he/she will transfer to TELEDIPITY is real, updated, and accurate, and that, likewise, the third party consents the transfer.

IX. MEANS AND PROCEDURE FOR THE EXERCISE OF ARCO RIGHTS.

TELEDIPITY acknowledges the Data Owners' ARCO Rights over their Personal Data, which consist on the following:

Access Right: Knowing what Data Owner's Personal Data is in TELEDIPITY's possession and what are the purposes of their processing.
Rectification Right: Request the correction of the Data Owner's Personal Data in case they are inaccurate, outdated, erroneous or incomplete.
Cancellation Right: Request for the elimination of any registration or copy, either physical or electronic, of the Data Owner's Personal Data.
Objection Right: Request to cease the use of the Data Owner's Personal Data. This includes the right to request: (a) that Personal Data is not used to contact the Data Owners; (b) to have Personal Data removed from any solicitation list that TELEDIPITY uses, and (c) to opt-out of being solicited by TELEDIPITY or third parties.

These rights are exercised by means of a written request sent via email to the address privacy[at]teledipity.com with the subject "Exercise of ARCO Rights". The aforementioned email address corresponds to the department that will process the requests and may be contacted by the Data Owners at any time.

In the body of the message, the Data Owner must provide the following information:

Full name and address.
A clear and precise description regarding the Personal Data over which the Data Owner intends to exercise any of the ARCO Rights, in addition to any document that allows its location.
Mention of the ARCO Right that the Data Owner intends to exercise and the motivation to do so.
The arguments that support the Data Owner's position.
If they request the Rectification of data, the Data Owners shall precise the modifications to be made and the documentation supporting the reason for the required changes.

In addition, the following documents must be attached to the application:

To verify the Data Owner's identity, the request must be sent from the same email address associated with the Data Owner's account.
Document that proves that the personal data is in possession of TELEDIPITY.
In the event that the Data Owner does not personally submit the request, whoever does so must prove there are authorized to do so. This can be done through a public deed or power of attorney signed before two witnesses, along with official IDs of the Data Owner and its representative.

Once the Data Owner's request has been received, TELEDIPITY will send an acknowledgment of receipt via email. Subsequently, TELEDIPITY will respond to the Data Owner's request by email within 20 (twenty) business days, starting from the date in which it was received.

The Data Owner must consider that, to have sufficient elements to meet the request, TELEDIPITY may ask to the Data Owner to submit, within 5 (five) business days and at the address referred to in section II, original copies of the documents attached to the application or any additional information that helps to process the request. The Data Owner will have 10 (ten) days to fulfill this requirement. In this case, the term of 20 (twenty) days for TELEDIPITY to respond to the request will start on the following day on which the Data Owner fulfilled the requirement.

If the request is declared appropriate, and the Data Owner has accredited personality and the ownership of the ARCO Right that he/she intends to exercise, the Access to Personal Data, the requested changes, the Cancellation or the response to the Objection will be made within 15 (fifteen) business days counted from the date on which the request was answered.

For requests for Access to Personal Data, the delivery of information will proceed, after providing proof of identity of the applicant or their representative, accordingly. We shall make such delivery in single copies at the address mentioned in section II, or in electronic documents to the mailing address from which the request was sent.

In the event that the purpose of the request is the Objection, the Processing of Personal Data will cease on the following business day to the date in which the affirmative answer was notified to the Data Owner.

X. USE OF MECHANISMS IN REMOTE OR LOCAL MEANS OF ELECTRONIC, OPTICAL OR OTHER TECHNOLOGY COMMUNICATION, COLLECTION AND TRACE, AUTOMATIC AND SIMULTANEOUS, OF PERSONAL DATA.

TELEDIPITY APP uses Cookies to help the Data Owner personalize his or her online experience and for other specific features or functions. A Cookie is a text file that is placed on the Data Owner's hard drive by a Web server. Cookies can facilitate the use of an application, by saving passwords and preferences while the owner navigates in it.

Cookies are not used to run programs or deliver viruses to the Data Owner's computer. Cookies are uniquely assigned to the Data Owner and can only be read by a Web server in the domain that issued the Cookie. One of the primary purposes of Cookies is to provide a convenience feature to save Data Owners time. The purpose of a Cookie is to tell the Web server that the Data Owner has returned to a specific page. For example, if the Data Owner personalizes pages in the Mobile Application, or purchases a specific product, a Cookie helps TELEDIPITY recall their specific information on subsequent visits. When the Data Owner returns to the same Website, the information they previously provided can be retrieved, so they can easily use the customized features.

The Application does not use Cookies to get personal identification data from the Data Owner's device that were not originally sent as part of the Cookies.

Although most browsers accept Cookies automatically, the Data Owner can adjust its browser so that it does not allow them. To disable cookies, follow the instructions bellow:

If Data Owners choose to decline Cookies, they may not be able to fully experience the interactive features of the TELEDIPITY App, Products or Websites they visit. TELEDIPITY keeps track of the Websites and pages they visit within TELEDIPITY, in order to determine what portion of the TELEDIPITY App is the most popular or most used. This Data is used to deliver customized content and promotions within the Teledipity Application to customers whose behavior indicates that they are interested in a particular subject area.

Examples of Cookies TELEDIPITY uses:

Session Cookies. We use Session Cookies to operate our Service.
Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
Security Cookies. We use Security Cookies for security purposes.

By the use of Cookies, TELEDIPITY APP will collect the following data:

IP Address: Such Personal Data will be processed solely for network traffic analysis, data analysis for the improvement of the system, for authentication and prevention against identity theft or data security breach, as well as for authenticating or to identify users or third parties that use the Application. We will make no transfer of such Personal Data to third parties outside TELEDIPITY.
Log Files: TELEDIPITY may collect demographic information, such as ZIP code, age, gender, preferences, interests and favorites using log files that are not associated with the Data Owner's name or other personally identifying information. There is also information about the Data Owner's computer hardware and software that is automatically collected by the TELEDIPITY App. This information can include IP address, browser type, domain names, access times and referring website addresses. This information is used by TELEDIPITY for the operation of the TELEDIPITY Application, to maintain quality, and to provide general statistics regarding use of the TELEDIPITY App. For these purposes, we do link this automatically collected data to Personal Data such as name, email address, address, and phone number.

TELEDIPITY may employ third party companies and individuals to facilitate the Application services, to provide the services on TELEDIPITY's behalf, to perform Service-related tasks or to assist TELEDIPITY in analyzing how the Service is used.

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These third parties have access to Personal Data only to perform these tasks on TELEDIPITY's behalf and are obligated not to disclose or use it for any other purpose:

i. Analytics

TELEDIPITY may use third-party Service Providers to monitor and analyze the use of the TELEDIPITY App.

Cloudflare Analytics

This website uses Cloudflare Web Analytics (Cloudflare, Inc. 101 Townsend St, San Francisco, CA 94107). This lightweight, privacy-focused analytics tool operates without using client-side state mechanisms such as cookies or localStorage. Cloudflare Analytics does not collect personal information, track users across different websites, or employ "fingerprinting" techniques using IP addresses, User Agent strings, or any other data for analytics purposes. You can read Cloudflare's Privacy Policy, GDPR compliance page, and their Web Analytics page within their Trust Hub for more information.

Amplitude

Amplitude is an application analytics service for recording the User interactions with the TELEDIPITY APP, which helps TELEDIPITY deliver a better user experience. This analytics service does not rely on browser cookies to collect information about the user. The User can opt-out of having made their activity on the Service available to Amplitude Analytics by submitting a formal written request to privacy[at]teledipity.com. For more information on the privacy and GDPR practices of Amplitude, please visit https://amplitude.com/privacy

ii. CAPTCHA

We use Cloudflare Turnstile, an application from Cloudflare, Inc. (101 Townsend St, San Francisco, CA 94107, USA) on our website. Cloudflare Turnstile allows us to distinguish real users of the website from automated programs (bots) without the users having to do a CAPTCHA task. In this way we ensure the IT security of the website and protect our website from attacks and spam.

In order to distinguish human users from bots, Cloudflare Turnstile collects and evaluates the IP address, header, user agent, browser information, and session data such as session duration and website interactions of the users on some devices. The analysis begins automatically as soon as a user accesses our website. Personal user data is also transmitted to the USA, which does not have the same level of data protection as that provided by the GDPR. Therefore, the data transfer to the USA is legally secured by EU standard contractual clauses, which you can find here.

As far as users are using the latest versions of macOS or iOS, Cloudflare Turnstile can identify human users via private access tokens without processing user data.

Data processing is carried out to safeguard our legitimate interests and is justified in accordance with Article 6 (1) (f) GDPR. We have a legitimate interest in protecting our website from malicious attacks and ensuring the functionality of the website.

Detailed information about the processing of personal data by Cloudflare can be found in Cloudflare's data protection policy.

iii. Advertising

TELEDIPITY does not currently engage third-party service providers to display advertisements or track user behavior across different websites through the use of cookies, pixels, or other tracking technologies. Our commitment to user privacy includes refraining from cross-site tracking and targeted advertising practices.

Future Changes

If our practices regarding advertising or user tracking change in the future, we commit to:

Providing advance notice to all users through email and in-app notifications.
Updating our privacy policy to reflect these changes in detail.
Obtaining necessary consents and opt-out mechanisms in compliance with applicable data protection laws.

iv. Behavioral Remarketing

TELEDIPITY does not use remarketing services to advertise on third party websites after you visited the TELEDIPITY APP. Though this practice was previously used, it has been discontinued as of August 15, 2022.

Historical Information

If you visited the Teledipity App prior to August 15, 2022, the following information about opting out of previous remarketing practices may be relevant:

Facebook remarketing service is provided by Facebook Inc. You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950 . To opt-out from Facebook's interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217 . Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA , the Digital Advertising Alliance of Canada or the European Interactive Digital Advertising Alliance in Europe, or opt-out using your mobile device settings. For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation

v. Payments

TELEDIPITY may provide paid products and/or services within the TELEDIPITY APP. In that case, TELEDIPITY uses third-party services for payment processing (e.g. payment processors).

TELEDIPITY will not store or collect the payment card details of the User. That information is provided directly to our third-party payment processors whose use of the personal information of the User is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

The payment processors TELEDIPITY works with are:

Apple Store In-App Payments – Their Privacy Policy can be viewed at https://www.apple.com/legal/privacy/en-ww/
Google Play In-App Payments – Their Privacy Policy can be viewed at https://www.google.com/policies/privacy/
Stripe – Their Privacy Policy can be viewed at https://stripe.com/us/privacy

vi. Social Media Features

The TELEDIPITY App includes social media sharing buttons in our blog section, specifically:

Share on Facebook button
Share on Twitter button
Share on LinkedIn button
Share on Pinterest button

These buttons are simple links that, when clicked, open a new window to the respective social media platform with a pre-filled share dialog. TELEDIPITY does not directly collect or process any data through these sharing buttons.

When you use these buttons to share content, you will be interacting directly with the respective social media platforms (Facebook, LinkedIn, X, or Pinterest). TELEDIPITY has no control over and accepts no liability in respect of what happens after a sharing button is clicked. Any cookies or other tracking identifiers that may be placed once these links are clicked are placed outside of this site by the respective social media platforms. To avoid potential trackers placed outside of this website, simply avoid clicking these sharing links.

This site uses only necessary cookies as outlined in our Cookie Notice section. We do not set any additional cookies or employ any tracking mechanisms through these sharing buttons.

Please note that when you use these sharing buttons, you will be subject to the privacy policies and terms of service of Facebook and Twitter. We encourage you to review these policies:

Facebook Privacy Policy: https://www.facebook.com/policy.php
Twitter Privacy Policy: https://twitter.com/en/privacy
LinkedIn Privacy Policy: https://www.linkedin.com/legal/privacy-policy
Pinterest Privacy Policy: https://policy.pinterest.com/en/privacy-policy

vii. External Websites

The TELEDIPITY APP sometimes provides links to other websites. TELEDIPITY does not control, and is not responsible for, the content or practices of these other websites. TELEDIPITY's provision of such links does not constitute an endorsement of these other websites, their content, their owners, or their practices. This Privacy Notice does not apply to these other websites, which are subject to any privacy and other policies they may have.

viii. "Do Not Track" Signals

TELEDIPITY does not support Do Not Track ("DNT"). Do Not Track is a preference Data Owners can set in your web browser to inform websites that you do not want to be tracked. Data Owners can enable or disable Do Not Track by visiting the Preferences or Settings page of their web browser.

ix. Clear Gifs (Web Beacons/Web Bugs)

TELEDIPITY employs a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that help us better manage the TELEDIPITY APP by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a Data Owner's computer hard drive, clear gifs are embedded invisibly on Web pages or in emails and are about the size of the period at the end of this sentence. TELEDIPITY uses clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows TELEDIPITY to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. TELEDIPITY ties the information gathered by clear gifs in emails to our customers' Personal Data. If you would like to opt-out of these emails, please see "MEANS AND PROCEDURES FOR THE REVOCATION OF CONSENT".

x. Customer Service

The TELEDIPITY APP uses the ticketing system, Gorgias, a customer service platform of Gorgias Inc. (180 Sansome St, Suite 1800, San Francisco, CA 94014), to process customer inquiries. To this end, Personal Data such as first name, surname, postal address, phone number, email address, is collected by our email system and sent to Gorgias in order to be able to process requests from Data Owners. For more detailed information about data processing by Gorgias, visit Gorgias's Privacy Policy at https://www.gorgias.com/legal/privacy. For any questions, regarding Gorgias' Privacy Policy, Data Owners can also refer to Gorgias' data protection agreement at: https://www.gorgias.com/legal/data-processing-agreement. Data Owners who contact us by email or order products on the TELEDIPITY APP will have some Personal Data transmitted to Gorgias for processing of their specific inquiry. The data provided shall be treated confidentially. The data provided and the message history with the TELEDIPITY APP is stored for follow-up questions and contacting. Use is optional and serves to improve the customer service for the TELEDIPITY APP. Data Owners who do not agree to data collection and data storage in Gorgias' external system should notify us at privacy[at]teledipity.com. We shall offer alternative contact options for submitting service requests.

xi. Contact Forms

You have the option of contacting us via the contact forms on the Teledipity APP. We process the personal data you transmit to us on the basis of your consent. You can revoke your consent at any time by sending us a message via the contact form or by email with effect for the future. If your request serves to conclude a contract with us, we will process your request on the basis of Article 6 Paragraph 1 Letter b of GDPR.

Some forms in the Teledipity APP use the provider Basin (Moonshot Ventures Inc., 30060 Harris Rd, Abbotsford BC V4X 1V6, Canada). The data provided when using the contact forms will be processed by Basin and may be transferred to countries outside the European Union (EU) and the European Economic Area (EEA). More information on Basin' compliance with GDPR requirements can be found here, as well as in Basin's Privacy Policy.

Some contact forms in the Teledipity APP use the provider Getform (UXPLUS LTD, Company Number: 1135742986-90 Paul Street, 3rd Floor, EC2A 4NE London, United Kingdom). The data provided when using these contact forms will be processed by Getform in strict compliance with the EU General Data Protection Regulation ("GDPR"). More information on Getform's compliance with GDPR requirements and practices can be found in their Privacy Policy.

xii. Cloudflare Bot Management

To enhance website security and performance, we utilize Cloudflare's Bot Management services, a service provided by Cloudflare, Inc. (101 Townsend St, San Francisco, CA 94107, USA). This tool helps us identify and manage bot traffic, ensuring a smoother and safer user experience. The data collected by Cloudflare is strictly related to website traffic patterns and does not include personal information. All data is subjected to one-way encryption, further protecting your anonymity.

XI. MEANS AND PROCEDURES FOR THE SECURITY OF PERSONAL DATA

TELEDIPITY uses a variety of security technologies and procedures to help protect Personal Data from unauthorized access, use or disclosure. TELEDIPITY secures the Personal Data provided by the Data Owner on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure.

The security of the Data Owner's Personal Data is important to TELEDIPITY, but the Data Owner must keep in mind that no method of transmission over the Internet, or method of electronic storage is 100% secure. While TELEDIPITY strives to use commercially acceptable means to protect the Personal Data of all Data Owners, we cannot guarantee its absolute security.

XII. MEANS AND PROCEDURES FOR THE REVOCATION OF CONSENT.

At any time and for any reason, the Data Owner may revoke the authorization given to TELEDIPITY for the Processing of his Personal Data. TELEDIPITY states that, for the fulfillment of specific purposes, the revocation of consent could mean the impossibility of continuing the relationship between both parties.

In this case, the revocation of the consent will be carried out under the following procedure:

Sending an email to the address privacy[at]teledipity.com with the subject "Revocation of Consent."
In the message's body the following should be noted:
- Data Owner's full name.
- The reason for the request.
To verify the Data Owner's identity, the request must be sent from the same email address associated with the Data Owner's account.

TELEDIPITY will respond to the Data Owner's request by email within 10 (ten) business days from the date in which we received it. The Data Owner must consider that, to have sufficient elements to meet the request, TELEDIPITY may ask the Data Owner to submit, within 5 (five) business days and at the address referred to in section II, other information that helps to process the application. The Data Owner will have 10 (ten) days to fulfill TELEDIPITY's request. In this case, the term of 10 (ten) days for TELEDIPITY to respond to the request will start on the day following that in which the Data Owner fulfilled the requirement.

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XIII. RESPONSIBLE FOR PROCESSING ARCO RIGHTS APPLICATIONS, LIMITATION OF USE AND DISCLOSURE, AS WELL AS REVOCATIONS

If the Data Owners wish to revoke their consent, limit the use and disclosure of their personal information, as well as Access, Rectify, Cancel or Object the Processing of their Personal Data, they must do so through the Department designated by TELEDIPITY, whose contact information is listed below:

Responsible: TELEDIPITY'S DATA PROTECTION DEPARTMENT.
Email address: privacy[at]teledipity.com

XIV. MEANS TO LIMIT THE USE OR DISCLOSURE OF PERSONAL DATA.

TELEDIPITY commits to execute legal acts, adopt privacy, Personal Data protection and information security policies, as well as to implement security measures to guarantee the protection of the Data Owner's Personal Data.

TELEDIPITY stores personal data in databases with limited access, in controlled facilities with security mechanisms. TELEDIPITY commits to ensure that the information provided by the Data Owner is considered and processed confidentially.

TELEDIPITY provides alternative mechanisms to the exercise of ARCO Rights so that the Data Owners limit the use and disclosure of their Personal Data. In this sense, to avoid receiving publicity, the Data Owner can register in the Public Registry to Avoid Publicity (REPEP) of the Federal Consumer Attorney's Office (PROFECO), in the link https://repep.profeco.gob.mx.

Data Owners may unsubscribe from TELEDIPITY marketing communications by clicking on the "unsubscribe" link located on the bottom of our e-mails, by replying with the word "STOP" to any of our text messages, or by emailing a request to privacy[at]teledipity.com. Customers cannot opt-out of receiving transactional emails related to their account with TELEDIPITY.

TELEDIPITY will not use the TELEDIPITY App to send unsolicited commercial email from third parties or include any content in violation of applicable laws. Every email sent from the TELEDIPITY App will include an easy to read "opt-out" mechanism and other required information.

The TELEDIPITY App will, from time to time, include commercial email related exclusively to TELEDIPITY products and services, as well as recommended books and online courses from third parties TELEDIPITY deems relevant to the Data Owner's profile and needs.

In case the Data Owner wishes to know more about this section, he/she may send an email to the address privacy[at]teledipity.com with the subject "Limitation of Use or Disclosure," expressing doubts, comments, and suggestions regarding his/her purpose.

XV. PERSONAL DATA STORAGE PERIOD.

In compliance with the quality principle, TELEDIPITY will safeguard all the Personal Data of the Data Owner for the necessary and adequate time to fulfill the purposes for which TELEDIPITY collected them. Subsequently, TELEDIPITY will apply a blocking period prior to the cancellation of Personal Data.

XVI. INFORMATION FOR USERS RESIDING IN BRAZIL

This part of the document integrates with and supplements the information contained in the rest of the Privacy Notice and is provided by TELEDIPITY and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as "we", "us", "our").

The provisions contained in this section apply to all Users who reside in Brazil, according to the "Lei Geral de Proteção de Dados" (Users are referred to below, simply as "you", "your", "yours"). For such Users, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.

This part of the document uses the term "personal data" as it is defined in the Lei Geral de Proteção de Dados (LGPD).

The grounds on which we process your personal information:

We can process your personal data solely if we have a legal basis for such processing.

Legal bases are as follows:

Your consent to the relevant processing activities;
Compliance with a legal or regulatory obligation that lies with us;
The carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments;
Studies conducted by research entities, preferably carried out on anonymized personal data;
The carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract;
The exercising of our rights in judicial, administrative or arbitration procedures;
Protection or physical safety of yourself or a third party;
The protection of health – in procedures carried out by health entities or professionals;
Our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; and
Credit protection.

To find out more about the legal bases, you can contact us at any time using the contact details provided in this document.

Your Brazilian privacy rights, how to file a request and our response to your requests.

Your Brazilian privacy rights:

You have the right to:

Obtain confirmation of the existence of processing activities on your personal data;
Access to your personal data;
Have incomplete, inaccurate or outdated personal data rectified;
Obtain the anonymization, blocking or elimination of your unnecessary or excessive personal data, or of information that is not being processed in compliance with the LGPD;
Obtain information on the possibility to provide or deny your consent and the consequences thereof;
Obtain information about the third parties with whom we share your personal data;
Obtain, upon your express request, the portability of your personal data (except for anonymized information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded;
Obtain the deletion of your personal data being processed if the processing was based upon your consent, unless one or more exceptions provided for in art. 16 of the LGPD apply;
Revoke your consent at any time;
Lodge a complaint related to your personal data with the ANPD (the National Data Protection Authority) or with consumer protection bodies;
Oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law;
Request clear and adequate information regarding the criteria and procedures used for an automated decision; and
Request the review of decisions made solely on the basis of the automated processing of your personal data, which affect your interests. These include decisions to define your personal, professional, consumer and credit profile, or aspects of your personality.

You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights.

How to file your request:

You can file your express request to exercise your rights free from any charge, at any time, by sending an email to privacy[at]teledipity.com with details of your request or via your legal representative.

How and when we will respond to your request:

We will strive to promptly respond to your requests. In any case, should it be impossible for us to do so, we'll make sure to communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your personal data, we will indicate to you the physical or legal person to whom you should address your requests, if we are in the position to do so.

In the event that you file an access or personal information processing confirmation request, please make sure that you specify whether you'd like your personal data to be delivered in electronic or printed form.

You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead. In the latter case, we'll respond within 15 days from the time of your request, providing you with all the information on the origin of your personal data, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.

In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal data in order to enable such third parties to also comply with your request – except in cases where such communication is proven impossible or involves a disproportionate effort on our side.

Transfer of personal data outside of Brazil permitted by the law:

We are allowed to transfer your personal data outside of the Brazilian territory in the following cases:

When the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution bodies, according to the legal means provided by the international law;
When the transfer is necessary to protect your life or physical security or those of a third party;
When the transfer is authorized by the ANPD;
When the transfer results from a commitment undertaken in an international cooperation agreement;
When the transfer is necessary for the execution of a public policy or legal attribution of public service;
When the transfer is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitration procedures.

XVII. MODIFICATIONS TO THE PRIVACY NOTICE.

TELEDIPITY informs the Data Owner that we may change this Privacy Notice at any time and manner, always taking into account the legislation in this matter.

TELEDIPITY informs the Data Owners that any changes to the Privacy Notice will be notified through the publication of an informative message and its updated version on the App and/or by sending an email to the address that the Data Owner has provided.

XVIII. DATE OF LAST UPDATE.

August 12, 2024

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