Privacy Policy

1. Introduction

Portfolioum (hereinafter, "we," "our," "ours," or "the Company") respects your privacy and is committed to protecting your personal data. This privacy policy will inform you how we care for your personal data when you visit our website or use our services, regardless of where you visit from, and will inform you about your privacy rights and how the law protects you.

This privacy policy has been designed to comply with Bolivian personal data protection legislation and establishes the basis on which we will process any personal data we collect from you or that you provide to us. Please read carefully to understand our practices regarding your personal data.

2. Data Controller

Portfolioum is the controller of the personal data you provide to us through this website or in the context of our services.

Contact details:

• Full entity name: Portfolioum S.R.L.
• Mailing Address: Av. Beni 5th ring, Innovation Tower Building, 8th Floor, Office 802, Santa Cruz de la Sierra, Bolivia
• Phone: +591 3 345 1271
• Email: privacidad@portfolioum.com

3. Personal Data We Collect

Personal data means any information about a person from which they can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store, and transfer different types of personal data about you, which we have grouped as follows:

• Identity Data: includes first name, last name, title.
• Contact Data: includes email address, phone number, mailing address.
• Technical Data: includes internet protocol (IP) address, login data, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
• Usage Data: includes information about how you use our website and services.
• Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use, and share Aggregated Data such as statistical or demographic data. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.

4. How We Collect Your Personal Data

We use different methods to collect data from and about you, including:

• Direct interactions: You may give us your Identity and Contact Data by filling in forms or by communicating with us by post, phone, email, or otherwise.
• Automated technologies or interactions: As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies and other similar technologies. For more information on how we use cookies, please see our Cookie Policy.
• Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources such as analytics providers, technical service providers, advertising networks, search information providers.

5. Purposes of Data Processing

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.
• Where we have obtained your consent for a specific processing.

The purposes for which we will use your personal data include:

• To register you as a new customer.
• To process and deliver our services, including managing payments.
• To manage our relationship with you, including notifying you about changes to our terms or privacy policy.
• To administer and protect our business and this website.
• To deliver relevant website content and advertisements to you.
• To measure or understand the effectiveness of the advertising we serve to you.
• To make suggestions and recommendations to you about services that may be of interest to you.

6. Legal Basis for Processing

The legal basis for processing your personal data will depend on the specific purpose for which we collect the data. However, we will generally rely on:

• Consent: when you have given your explicit consent to the processing of your personal data for one or more specific purposes.
• Performance of a contract: when the processing is necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering into a contract.
• Legitimate interest: when the processing is necessary for our legitimate interests or those of a third party, provided that your interests or fundamental rights do not prevail over those interests.
• Compliance with legal obligations: when the processing is necessary to comply with a legal obligation to which we are subject.

7. Disclosure of Your Personal Data

We may share your personal data with the parties set out below for the purposes set out in this privacy policy:

• Service providers who provide IT and system administration services.
• Professional advisers including lawyers, bankers, auditors, and insurers.
• Tax, regulatory, and other authorities that require reporting of processing activities in certain circumstances.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

8. International Transfers

Some of our external third-party service providers are based outside of Bolivia, so their processing of your personal data will involve a transfer of data outside the country.

Whenever we transfer your personal data out of Bolivia, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where we use certain service providers, we may use specific approved contracts which give personal data the same protection it has in Bolivia.

9. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

10. Data Retention

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

11. Your Legal Rights

Under Bolivian data protection legislation, you have rights in relation to your personal data, including:

• Right of Access: Request access to your personal data.
• Right of Rectification: Request correction of your personal data.
• Right of Erasure: Request deletion of your personal data.
• Right of Objection: Object to processing of your personal data.
• Right to Restriction of Processing: Request restriction of processing of your personal data.
• Right to Data Portability: Request transfer of your personal data to you or to a third party.
• Right to Withdraw Consent: Withdraw consent at any time where we are relying on consent to process your personal data.

If you wish to exercise any of the rights set out above, please contact us at privacidad@portfolioum.com. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

12. Data Erasure Requests

You have the right to request the deletion of your personal data at any time. To do so, send a written request to privacidad@portfolioum.com with the subject "Data Erasure Request."

We will process your request within 10 business days of its receipt and confirm when your data has been deleted from our systems. Please note that some data may be retained if there is a legal obligation to do so or if it is necessary for the protection of our legal rights.

13. Changes to this Privacy Policy

We may update our privacy policy from time to time. We will post any changes on this page and, if the changes are significant, we will provide you with a more prominent notice or send you a direct notification.

We recommend that you review this privacy policy periodically to be informed about how we are protecting your data.

14. Contact

If you have any questions about this privacy policy or our privacy practices, please contact our data protection officer at:

Email: privacidad@portfolioum.com
Phone: +591 3 345 1271
Mailing Address: Av. Beni 5th ring, Innovation Tower Building, 8th Floor, Office 802, Santa Cruz de la Sierra, Bolivia

You have the right to make a complaint at any time to the Bolivian data protection authority. However, we would appreciate the chance to deal with your concerns before you approach the data protection authority, so please contact us in the first instance.

15. Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve it.

For detailed information on the cookies we use, the purposes for which we use them, and how you can exercise your choices regarding our use of your cookies, please see our Cookie Policy.

You can set your cookie preferences at any time by clicking the "Set Cookies" button below: