(i) the website https://www.ripio.com/select (“Website”).
(ii) the digital mobile application "Ripio Select", if it is available for download through mobile devices where it is available ("App").
(iii) the Ripio Select platform ("Platform").
To make it more practical, we will call the Website and the App, as "Platform".
It also describes the processing of information provided or collected on the sites, applications, or collected by us offline in physical venues, or through our call center. We collect automatically anonymous information. Besides, without providing us with any information other than anonymous information it is possible if we collect automatically.
To protect your information OTCIS LLC complies with the regulations in force in the Florida and other US states, in particular, the rules and principles established by Law and the other Provisions that add, modify, regulate, expand, complement or delete them.
OTCIS LLC. is the registered Responsible of the database that contains your Personal Information before the Agency for Access to Public Information of the Argentine Republic.
Below, we point out key concepts to understand and take into account when reading our Policy:
Affiliate: With respect to any specific person, it shall be understood as any other person that controls that specific person, or that is controlled by that specific person, either directly or indirectly, or that together with that other person are directly or indirectly under the common control of a third person. For purposes of this definition, the word “control”, when used with respect to a particular person, means the power to directly or indirectly direct the management and policies of such person through ownership of voting shares. or through the right to elect the majority of the members of the board of said person, and the terms "controlling" and "controlled" have correlative meanings with the foregoing.
Database: is the organized set of Personal Information that is subject to treatment or processing, electronic or not, whatever the modality of its formation, storage, organization or access.
Consent: prior, free, express and informed manifestation by the Owner of the Personal Information to carry out the processing of their Personal Information, which must be recorded in writing, or by other means that allow it to be equated, according to the circumstances.
Transfer: the transfer of information takes place when the Responsible sends the information to a recipient who is inside or outside the country from which it was sent.
Treatment: Systematic operations and procedures, electronic or not, that allow the collection, conservation, arrangement, storage, modification, relationship, evaluation, blocking, destruction, and in general the processing of Personal Information, as well as its transfer to third parties through communications, consultations, interconnections or transfers.
We may collect different types of personal information about our users: identifier/contract information, demographic information (gender and age), payment card information, commercial information, internet data, electronic or devices data, network activity information or similar information.
Information provided by the User
When the User uses services of OTCIS LLC and/or uses the Platform, the User accepts that OTCIS LLC may collect and process certain information about the User, for example: The use of, or access to the Service may require the generation of a User account. To create a User account and communicate with OTCIS LLC, the Companies require the User to provide their registration information you provide when you create an account, enter a promotion, or link your profile, sus as a your first and last name, email address, gender and date of birth and other identifying information, depending on their use of the Service, their telephone number, address, country of residence, nationality, national or local ID number, taxes ID number, national identity document or other document that allows you to be identified, information about your bank account, images (photographs of yourself or copies of your identification documents) requested for the purpose of validating your identity, your financial information such as income, assets, equity, liabilities and credit history, the origin of the resources for the use of the Service and the purposes for which you will use the resources obtained from the use of the Service (jointly, hereinafter, "Personal Information" ). In addition, OTCIS LLC will require the creation of a password to access certain features of the Service, and if necessary information is sent either one-to-one or within a limited group using our message, chat, post, or similar functionality, where are permitted by applicable law to collect this information.
The forms that OTCIS LLC asks the User to complete establish what data is mandatory to complete and what is optional. In the event that the user does not provide the mandatory information, it could cause OTCIS LLC cannot provide or continue to provide the Service or access to the Platform.
The User will have the duty to inform any necessary modification, change or update of his Personal Information and will be responsible for the consequences of not having warned OTCIS LLC in a timely and comprehensive manner. about any of these.
Information our systems collect
OTCIS LLC. collects and processes general, statistical and/or non-personally identifiable information (“Non-Personally Identifiable Information”, or “INIP”), including technical information about your device, the operating system you use and application software.
In addition, OTCIS LLC collects and processes information related to all operations and activities carried out through the Service, dates, duration and frequency of User sessions and access by any means to the Service, geographical location of the device through which access or use the Service, settings, IP address, browser information, transaction data and any other information to which we have been given access through mobile devices, tablets or computers with which access to, or use the Service (collectively, “Operational Information”). In case of transmission to third parties of the Operational Information in accordance with the terms of this Policy, the owners of the Operational Information will not be identifiable, except in cases of transmission of the Total Information, as defined in point 5 of this Policy .
OTCIS LLC or its service providers may also use various web tools including Cookies, Web Beacons and Tagging on the Platform and advertisements, for the purpose of evaluating and improving the Platform and other electronic offerings, adapting the services, improving your experience User ID and communicate with Users about products and services that may be of interest to them.
Information provided by third parties
The User can choose to give OTCIS LLC. access to certain information stored by third parties, such as social networks (including, without limitation, Facebook, Instagram, and Twitter). The type of information and extent of use that we may give you varies by site or service and is controlled by your privacy settings on that site or service, and by your authorization when associating a third-party managed account with your managed account by OTCIS LLC. Once you have associated your account managed by a third party with your Service user account, you agree that OTCIS LLC may collect, store and use, in accordance with this Policy, the information contained in the account managed by a third party.
Information related to your health, race, ethnic group, sexual orientation, criminal record, religion, union affiliation, moral and political opinions is excluded from this Policy, because in no case will we ask you to provide it to us.
Do Not Track and Do not sell or share my personal information
Please visit Do Not Track and learn how to disable cookies and otherwise make choices with respect to such data collection.
The User accepts that OTCIS LLC may process all User information mentioned in point 4 of this Policy (jointly Personal Information, Non-Personally Identifiable Information and Operational Information hereinafter the "Total Information") for the following purposes:
a) Communicate with the User, provide the Service and comply with contractual commitments;
b) Validate your information, verify your identity, detect or prevent fraud, scams and other crimes, comply with money laundering and terrorist financing prevention regulations and policies, manage and resolve any claim in relation to actual or suspected fraud, scams and other crimes, investigate, evaluate and adjudicate claims, complaints and risks and associate, link, complete, consult, link, bind, use, relate, gather, gather the information related to your digital identity and reputation available in the digital environment, including instant messaging services and applications in any digital format, content social networks, mobile and wearable devices and in general, information related to your interaction on websites, applications and content;
c) Improve, optimize and modify the Service or third-party services. In particular, it is clarified that the use of images and photographs to validate information as a central element so OTCIS LLC can provide its Services to Users safely and can prevent fraud, scams and other crimes. OTCIS LLC may outsource this function to a specialized provider and, in order to better provide its services, incorporate Personal Information (including images and photographs) into a broader database, in order to improve and customize its services in favor of OTCIS LLC or your Affiliates and all of its customers;
d) Collect and analyze data trends, evaluate the performance of the Service, conduct a satisfaction survey, facilitate the design, development, generation and provision of software/platform updates, product support, and other products and services for Users;
e) Prepare advertising and/or marketing campaigns associated with any product and/or service;
f) Evaluate, develop, offer and provide goods and/or services to Users (you will not receive these offers and/or benefits if, in accordance with the first paragraph of point 8, you have chosen not to receive them);
h) Offer advertising or marketing information about products and/or services of these third parties, access to events or promotions, market research or other marketing activities (you will not receive this information if, in accordance with the first paragraph of point 8, would have chosen not to receive it);
g) Comply with the law, regulation, or order issued by a competent authority, or for reasons of public safety, public health, and/or national defense and to comply with regulatory reports, respond to a judicial order or a competent authority.
To comply with the purposes previously detailed, the Total Information may be shared with:
OTCIS LLC. affiliates, business partners and/or collaborators. ii. Service providers of OTCIS LLC, including providers of technology, network, data transmission, person identification, identity validation and other providers that are necessary for OTCIS LLC can correctly provide all its Services through the Platform. iii. National/Federal, State/City public and regulatory authorities.
You can at any time revoke your consent for the transmission to third parties of your Personal Information, by contacting us personally or by email at the addresses specified at the bottom of this Policy. The revocation, depending on its scope, could cause us to no longer be able to continue providing the Service.
Any of the entities indicated in the previous sections may be located outside of the USA including in countries or international or supranational organizations that, in accordance with current applicable legislation, do not provide adequate levels of personal data protection, such as, among others, Argentina or Brazil. Consequently, by accepting this Policy, the User grants his express consent that his Total Information, including his Personal Information, may be transferred internationally by OTCIS LLC, even to countries or international or supranational organizations that do not provide levels of data protection, in accordance with current applicable regulation.
In accordance with the aforementioned purposes, OTCIS LLC may carry out the following activities:
In compliance with the Personal Data Protection regulations, OTCIS LLC has taken adequate measures to protect the security and confidentiality of your Personal Information, guarantee that the provisions of this Policy are respected, protect your Personal Information against loss, misuse and unauthorized access, disclosure, alteration or destruction.
In order to guarantee an adequate level of security of your Personal Information, OTCIS LLC. You can take, among others, the following measures:
a) the encryption of Personal Information, when applicable;
b) measures capable of guaranteeing confidentiality, integrity, availability and treatment services;
c) measures capable of restoring the availability and access to Personal Information quickly in the event of a physical or technical incident;
d) regular verification, evaluation and assessment processes of the effectiveness of technical and organizational measures;
e) periodic evaluation of the risk of destruction, loss or accidental or illegal alteration of Personal Information transferred, conserved or processed in another way, or the unauthorized communication or access to said information;
f) measures to ensure that any person acting under the authority of OTCIS LLC that has access to Personal Information can only process such information following instructions from OTCIS LLC.
Your Personal Information will be treated confidentially, committing ourselves, within the scope of this Policy, to keep it secret and to adopt all necessary measures to prevent its alteration, loss, and unauthorized treatment or access, in accordance with the provisions of applicable law and in this Policy.
You will be able to select the categories of information that you do not want to receive from us, including promotional or advertising information from OTCIS LLC. and/or its Affiliates or third parties, if it is apply. However, while you have a User account, you may not prevent us from sending you non-promotional information, such as information about your User account or about requests or claims in progress. The Service may transfer cookies to the storage unit of the device through which you access or use the Service. Cookies are alphanumeric identifiers that work with your web browser to allow our systems to recognize you and improve your use of the Service. You can delete cookies or prevent us from sending them. Consult the help section of your browser to perform any of these operations. However, we recommend that you allow cookies on our Service: some features of the Service may not operate properly or be disabled entirely if cookies are disabled. Likewise, you may request the revocation of the monitoring of the geographic location of the devices through which you access the Service. However, this revocation could disable some functions or directly prevent the provision of the Service.
The Service may provide links to third party websites. Those websites are not operated by us and are beyond our control. Please be aware that these sites may collect information about you and that by visiting them you will become subject to their own privacy policies, therefore we recommend that you read these and other documents that govern your relationship with the providers of those websites. OTCIS LLC. is not responsible for the privacy practices of these sites and cannot guarantee the security of the information they collect. This Policy applies only to the use of the Service, and not to other applications or third-party websites with which OTCIS LLC. has connections or hyperlinks.
From time to time, OTCIS LLC reserves the right to modify this Policy at any time with immediate effect. The User will be notified of modifications to this Policy through OTCIS LLC deems appropriate (including, without limitation, its publication on the Platform), and accepts that the use of the Service after the notification constitutes full acceptance of the new terms of the Policy.
Likewise, OTCIS LLC reserves the right to enable access and/or transfer the Total Information to an affiliate or third party in the event of total or partial disposal, merger, spin-off or change of control of the company.
OTCIS LLC takes all measures within its power to protect the security, integrity and confidentiality of Personal Information. However, the User assumes the risk for any transmission of any type of information under this Policy.
The User will not initiate any claim against OTCIS LLC, nor its Affiliates, and will indemnify and hold harmless OTCIS LLC., its Affiliates, and their officers, representatives and employees, from and against any claim, demand, action, cost , expense (including legal costs and charges and reasonable attorneys' fees) loss, damage and/or loss, direct and/or indirect, judicial and/or extrajudicial, that may arise directly or indirectly from: (i) any action or omission of the User in relation to this Policy; (ii) any action or omission of the User in relation to his Total Information; (iii) any action or claim by third parties against the User and/or against OTCIS LLC., or its Affiliates, in any way related to this Policy or to the information whose collection, treatment and transfer is provided for in this Policy.
The User may request, at any time, access, rectification, updating or delete of their Personal Information, for such purposes, they must share the contact information listed below.
If you contact OTCIS LLC, you must prove your identity so OTCIS LLC can comply with the rules of right of access and proceed, as appropriate, to correct, update or delete it. Requests to delete Personal Information will be subject to any current legal and ethical obligation to report or complete documents or document retention obligations that are imposed on us.
Please note that email communications are not completely secure, so you should not include sensitive data in emails you send to us.
The Personal Information of the User will be kept by OTCIS LLC during the term of subscription to the Service or while your User account remains valid and, upon canceling or terminating your subscription to the Service, or upon closing your User account, until you stop using be necessary or pertinent to the purposes for which it was collected by OTCIS LLC.
In no case may the User revoke consent and request the deletion of their Personal Information from OTCIS LLC when there is a legal or contractual duty that imposes an obligation on OTCIS LLC to keep the Personal Information.
In no case will we transfer your Personal Information to third parties without obtaining your prior consent, unless it is necessary to maintain our relationship with you, to continue providing the Service, or to comply with current data protection regulations. In particular, it is clarified that within the framework of the provision of the OTCIS LLC may transfer your Personal Information to Affiliates for the performance of operations or activities associated with the Service by their Affiliates, consequently, by accepting this Policy, the User expressly consents to authorize the transfer of their Personal Information to OTCIS LLC or their Affiliates. to carry out operations or activities associated with the Service.
The User who, as the owner of the Personal Information, has the power to exercise the right of access to it free of charge at intervals of not less than six months, unless he proves a legitimate interest for that purpose in accordance with the Personal Data Protection regulations.
This Policy is governed without exception and in all its points by the laws of the Florida, and California law when is applicable to their residents, and will be interpreted in accordance with it.
Without limiting the foregoing, in the event of any difference, disagreement or conflict derived from the application, interpretation, validity, and/or scope of this Policy, the User must contact OTCIS LLC in a reliable manner, submitting your claim so that the parties can try to reach an agreement.
The contact information of the registered person in charge of the database is:
In some cases, Some states provide residents with the right to opt out of the selling or sharing of your personal information, or of targeted marketing or advertising based on your personal information.
You may submit a request to opt out of targeted marketing or advertising, or the sale or share your personal information, you may click the “Do Not Sell or Share My Personal Information” link or the platform. Also, we recommend that you clear your personal cookies from the cache of your browsing history.
For all cases, “personal information” is any piece of data that can or does identify you; and for “sell” or “sale” broadly to include the sharing of personal information (including information that does not directly identify an individual) in exchange for anything of value, which isn’t limited to the exchange of money. “Share” is defined narrowly as providing personal information to a third party for cross-context behavioral advertising to a consumer based on information about their activity on multiple websites across the internet. Certain exchanges of personal information aren’t considered a “sale” or “share.” For example, we can’t share your personal information with a service provider that’s contractually prohibited from using your personal information for any purposes beyond the service we specifically requested.