Retorna Holding SpA, a company incorporated under the laws of the Republic of Chile, which operates its communication services between Chile, Colombia and Peru through its companies Retorna Holding SpA, Inversiones Up S.A.S., and Retorna Perú S.A.C., respectively, which we refer to collectively as “Retorna”, has implemented the following personal data processing policy in the countries of application.
The privacy policy includes the Retorna Terms and Conditions. The use of this app, page and its services implies your acceptance, without reservation, of each and every one of the provisions included in the Data Processing and Privacy Policy and the Terms and Conditions. If you do not accept these provisions, you should not use the above-mentioned service.
- GENERAL CONSIDERATIONS
Retorna recognizes and protects the right of any person to know, update and rectify the personal data that exists about them in databases or archives of public or private entities. Likewise, it orders those who have personal data from third parties to respect the rights and guarantees provided for in current legislation when this type of information is collected, processed and circulated. As a general principle, Retorna does not share or disclose any type of information obtained, except when authorized by the customer, or in the following cases:
- When required by a competent authority and prior to compliance with the corresponding legal procedure; and,
- To provide its subsidiaries and/or other group companies or suppliers or operational associates with personal data when this is necessary for the proper provision of the service, its improvement or the offer of new products and/or services, communication and provision of important information and marketing news and promotions.
- INFORMATION OBTAINED BY RETORNA
Retorna obtains the information that the customer provides when they enter the app and completes the necessary data to register as a user and formalize their operations. To use some of the services or access certain content, you must first provide certain personal data, which will only be used for the purpose for which they were collected. When the customer signs up with Retorna and uses this service, they will usually need to provide the following information that is detailed in our Terms and Conditions:- full name, email, type of identity card, identity card number, telephone number, profession, address, recipient alias, payment method and amount.
- information related to your recipient: full name, type of identification, identification number, settlement account or other means of settlement if applicable.
Once Tier2 has been reached by volume of operation operated in the application, the user must register a photograph on the front and back of their identity card together with a selfie photo that allows us to verify the authenticity of the information provided. Also, in cases where Retorna deems appropriate in accordance with internal crime prevention policies, additional information may be collected in order to estimate the origin of the funds or greater background regarding the user's identity. In cases of knowledge of suppliers, the same security and custody criteria will apply as for customer information. Especially for those sensitive or main suppliers, operational information will be collected in the following areas: operational, financial, tax, corporate and statutory composition, final beneficiaries, commitments to the legitimacy of information and regulatory compliance and other information that may be considered of interest for the specific case. In addition, the application may collect certain information automatically, including, but not limited to, the type of mobile device that the customer uses, mobile identification devices unique device, the IP address of your mobile device, the mobile operating system, the type of mobile Internet browsers you use, and information about how to use the application.
- PURPOSES FOR THE PROCESSING OF PERSONAL DATA
Retorna will treat the information provided for the following purposes:- Comply with the obligations contracted between Retorna and the user-customer who owns the personal data at the time of purchasing our products and services. The details of the obligations contracted with Retorna can be found in the Terms and Conditions contract, which can be consulted on our website.
- Provide information that may be of interest, related to our services, products, offers, promotions, alliances, contests, content, as well as our strategic partners.
- Contact our users/clients in order to evaluate the quality of our services, through market studies.
- Respond to requests, complaints, claims and suggestions, under the terms of the Law, made by the Data Subjects.
- Delivery of information to control bodies in accordance with the provisions of the Act.
- Establish controls and security measures in order to protect information and personal data from threats that may arise both internally and externally.
- Communicate the policies, terms and conditions of campaigns, promotions, contests and services offered by the company, and where applicable, deliver the benefits to which users/customers who participate in the programs and/or promotions mentioned above are entitled.
- Advance due diligence processes, knowledge of the customer and controls that prevent the financing of terrorism, money laundering and/or any illegal activity.
- Implementation of supplier knowledge and approval policies.
- SENSITIVE PERSONAL DATA.
- The processing of sensitive personal data will be carried out in accordance with current legislation, ensuring that the owner is duly informed about the purposes of their use and that their express authorization is obtained. The sensitive data collected will be subject to strict security and confidentiality standards, in accordance with the nature of the information.
- With regard to supplier approval and to achieve detailed knowledge of the parties that support business relationships, additional documentation will be required in accordance with the required country supplier knowledge criteria and due diligence practices. This documentation will be treated and guarded with complete security and confidentiality for no purpose other than that of the supplier's knowledge.
- SHARING PERSONAL INFORMATION.
- Retorna does not sell, rent or market your personal information to third parties in any way. However, in order to provide a better service, we may need to share your personal information with natural or legal persons with whom we enter into or have concluded contracts, agreements and/or alliances aimed at ensuring the proper provision of our services and complying with legally and contractually acquired obligations with our customers, suppliers, contractors, employees and collaborators.
- Retorna only establishes business relationships and/or alliances with suppliers with data processing policies that guarantee information security.
- Additionally, it is reported that personal information will be shared with judicial or administrative authorities, when required to carry out their functions, as well as to inform the competent authorities of the activities that we believe in good faith are illegal.
- Retorna reserves the right to provide information about its users to third parties with whom it has business relationships, solely for the purpose of advancing customer knowledge processes.
- RIGHTS OF DATA SUBJECTSAs a collector of certain sensitive data about people who use its application and other services, it has the obligation to guarantee the following rights to its users:
- Know, update and rectify personal data.
- Get a copy of the authorization.
- Process inquiries and complaints following the guidelines established by law and in this policy.
- Access the request to revoke the authorization and/or deletion of personal data when it has been determined that conduct contrary to the law has been committed in the processing by Retorna.
- Free access to your personal data.
- Request the revocation of your authorization and the removal of your personal data from the app at any time, which will lead to your deletion as a customer of Retorna and which, in any case, will not prevent Retorna from maintaining an operational history in order to eventually comply with a request from a competent Authority. This can be done through the channels that Retorna has available to the public, or through the relevant section within the app.
The rights enshrined in this data processing policy may be exercised only by their owner.
- RETURN DUTIES.
Retorna is obliged to comply with the duties imposed by the legislation of the countries of operation, which is why it undertakes to fulfill the following duties:- Request and keep a copy of the respective authorization for the processing of personal data granted by users.
- Clearly inform the user of the purpose of the collection of personal data and the rights granted to them by the authorization granted.
- Guarantee users at any time the exercise of the right to habeas data.
- To process inquiries and complaints made by users.
- Keep the information under the necessary security conditions to prevent its adulteration, loss, consultation, unauthorized or fraudulent use or access.
- Update and rectify personal data when deemed appropriate.
Retorna must obtain prior, express and informed authorization from users for the processing of personal data, if the user does not accept, they will not be able to use the services provided by Retorna.To obtain authorization, users must be informed of the following:- Treatment to which personal data will be subject and its purpose.
- The rights that assist you as a holder provided for in the Act.
- Retorna's identification, email address and contact number.
The authorization given by the user may be obtained based on the user's unambiguous behavior when using the services provided by Retorna, so as to allow a reasonable conclusion that the user granted his consent for the processing of the information. - INTERNATIONAL TRANSFER OF PERSONAL DATA.
- Retorna has the right to transfer personal data of any kind to countries for bank transfers.
- INTERNATIONAL DATA TRANSMISSIONS TO MANAGERS.When Retorna sends personal data to one of its managers, you must, through contractual clauses or through a contract for the transfer of personal data, agree to the following:
- The scope of the processing of personal data.
- The activities that the manager must carry out on behalf of Retorna.
- The obligations that the processor must fulfill with respect to the owner of the personal data.
- The duty of the Processor to process personal data in accordance with the authorized purpose.
- The obligation of the person in charge to adequately protect personal data, as well as to keep confidential with regard to the processing of the transmitted data.
- COMPLAINTS
Complaints are intended to correct, update, or delete data or to file a complaint for the alleged breach of any of the duties contained in the existing regulation and in this policy. The complaint must be submitted by means of a request addressed to Retorna containing the following information:- Name and identification of the owner of the data or the legitimate person.
- Accurate and complete description of the facts giving rise to the claim.
- Physical or electronic address to send the response and report on the status of the procedure.
- Documents and other relevant evidence that you want to assert.
If the complaint is incomplete, the interested party will be required within five (5) days of receiving the complaint to remedy the flaws. After two (2) months have elapsed from the date of the request, without the applicant submitting the required information, it will be understood that he has withdrawn the claim. If the claim is complete, it will be included in the database until the claim is decided. The maximum period for dealing with the claim will be fifteen (15) business days from the day following the date of its receipt. When it is not possible to deal with the claim within that period, the interested party will be informed of the reasons for the delay and the date on which their claim will be dealt with, which in no case may exceed eight (8) business days following the expiration of the first term. - CONTACT
The customer can contact Retorna at [email protected], [email protected], the www.retorna.app support chat, official social networks or at the following offices, depending on where the transaction was based:- Calle 93 No. 17 — 45, OF. 301, in the city of Bogotá, Colombia.
- Isidora Goyenechea 3250 Of 1002, Las Condes commune, Metropolitan Region, Chile.
- El Derby de Monterrico Urbanization, 254 El Derby Avenue; Lima, Peru.
