Privacy Policy

This Privacy Policy governs the collection and use of personal information on the Website.

Qurable will not collect, through the Website, any information that could personally identify you, such as, for example, your name, address, phone number, or email address (hereinafter, "Personal Information"), unless you voluntarily provide it to us. If you do not want us to collect your Personal Information, please refrain from providing it. Please note, however, that browsing the Website, including viewing available time slots to request a demo, does not require you to provide any Personal Information; such information is only needed to confirm a demo request or to allow our sales team to contact you. Notwithstanding the foregoing, Qurable automatically collects certain technical information when you use the Website (for example, IP address, browser type, and device identifiers), as further described in the Cookies and Other Information section of this Privacy Policy.

If you provide us with your Personal Information, please be advised that such Personal Information will be subject to automated processing by Qurable, in accordance with the purposes and terms described in this Privacy Policy.

Qurable will never collect sensitive information and/or data about you, such as data revealing racial or ethnic origin, political opinions, religious, philosophical, or moral beliefs, union membership, or information regarding your health or sex life.

Qurable provides a software-as-a-service platform (the "Platform") that the companies that engage it (the "Clients") use to design, administer, and operate their own loyalty and relationship programs with their customers or members (the "End Users"). With respect to End Users' personal data that Clients upload, collect, or otherwise cause to be processed through the Platform, Qurable acts as data processor, while each Client acts as data controller, determining the purposes and means of such processing and being responsible for obtaining its End Users' consent and complying with the applicable duty to inform them under the data protection laws in force in its jurisdiction.

Depending on the configuration and use each Client makes of the Platform, the End Users' personal data to which Qurable may have access includes, among others, first and last name, ID type and number, address, contact details, and, on an exceptional basis, information related to payment methods.

Qurable will not apply or use the End Users' personal data that it processes on a Client's behalf for any purpose other than as instructed by that Client, nor will it disclose such data to third parties not authorized by that Client, not even for retention purposes.

Once its contractual relationship with a Client has ended, Qurable will destroy the End Users' personal data processed on that Client's behalf, unless the Client expressly authorizes its retention on the grounds that new engagements are reasonably foreseeable, in which case such data may be retained under adequate security conditions for up to two (2) years, or for such longer period as may be required under applicable legal, tax, or accounting obligations.

Qurable does not acquire any ownership right or title over the End Users' personal data that it processes on behalf of its Clients, and does not sell, rent, or otherwise commercialize personal data with third parties.

Qurable collects Personal Information online in cases including, among others, when:

• You use the Website and/or the features or services offered through it.
• You send us questions, inquiries, or comments, or otherwise contact the Website.
• You request information or materials.
• You request a demo of the Platform.

The type of information collected may include your first and last name, ID type and number, phone number, email address, the company or organization you represent (in the case of demo requests or business inquiries), and/or any other information that allows us to identify and contact you, to the extent permitted by applicable law. Whenever you provide Personal Information, and in accordance with applicable law, you represent that the Personal Information provided is accurate, complete, true, and current.

Whenever you provide us with your Personal Information, you give your free, unconditional, express, and informed consent for such Personal Information to be used for the purposes described above, and you authorize it to be processed, stored, and collected in Qurable's systems and records. Accordingly, when you provide your Personal Information directly through the Website, Qurable may use it to respond to your inquiry, request for information, or demo request, and to send you commercial communications about its own products and services, as set forth in Section 4 (Email) of this Privacy Policy. In addition, when your Personal Information forms part of a loyalty program operated by a Client through the Platform, Qurable may share or interconnect it with other Clients participating in the same program or ecosystem, to the extent necessary for its operation (for example, in loyalty programs shared among several brands), always subject to the consent obtained by the relevant data controller(s) involved and, where applicable, to the consent requirements under applicable data protection law. You further give your free, express, unconditional, and informed consent to the terms of this Privacy Policy.

Qurable's ability to share or interconnect Personal Information among different Clients, as described in Section 3.3 for purposes of the Platform's ecosystem functionality, does not change its role as data processor described in Sections 2.5 through 2.9: such interconnection will only take place in accordance with the instructions of the Clients involved, in their capacity as data controllers, and to the extent they have obtained the corresponding consent of their End Users.

Qurable will retain the Personal Information you provide directly through the Website only for as long as necessary to fulfill the purposes for which it was collected, and thereafter for the periods required under applicable tax, accounting, or legal requirements. Data associated with contact forms or requests for business information will be retained for a maximum of 24 months from the last contact, unless an active contractual relationship exists.

Qurable processes your Personal Information on the basis of: (i) your consent; (ii) the necessity of such processing for the performance of a contractual relationship with you or with the Client you represent; (iii) compliance with applicable legal obligations; and/or (iv) Qurable's legitimate interest, such as the security of its systems, fraud prevention, or the improvement of its products and services, as applicable to each processing purpose described in this Privacy Policy.

By requesting a demo, completing a contact form, or otherwise communicating with Qurable through the Website, you accept, consent to, and authorize Qurable to send you emails relating to the Website's content, the services provided by Qurable, your account, or in response to your questions, requests, inquiries, or comments. Qurable may also send you emails with information about products and services offered by Qurable and/or its business partners that may be of interest to you, unless you expressly indicate that you do not wish to receive such emails through the mechanisms implemented by Qurable for that purpose.

You may request, at any time, the removal or blocking of your name from the systems and records referred to in this Privacy Policy by following the procedure set out in this same policy, as well as the discontinuation of informational emails. Every email you receive from Qurable will describe the procedure for opting out of future promotional emails.

To prevent unauthorized access, maintain data accuracy, and ensure the proper use of your Personal Information, Qurable has implemented certain physical, electronic, and administrative safeguards and security procedures designed to protect and secure, to the best extent possible, the Personal Information we collect online. Qurable safeguards Personal Information in accordance with security standards and procedures established and commonly used in the industry, and we continually evaluate new technology to better protect that information. Qurable represents that its internal database processes comply with the security and confidentiality standards and legal obligations imposed by the privacy and personal data protection laws of each applicable country.

Notwithstanding Section 7.1, you acknowledge that no existing security technology is impregnable or infallible, and that even where all reasonable security precautions are taken, information may still be subject to tampering, theft, destruction, and/or loss. Should any such event occur, Qurable will act in accordance with the privacy and data protection laws of each applicable country.

Qurable's employees are trained to understand and comply with these principles regarding personal data protection and information security. Qurable's employees are further bound by strict confidentiality obligations with respect to the Personal Information they process in the course of their duties.

By providing us with your information through the Website and accepting Qurable's and the Website's terms and conditions, you expressly consent, acknowledge, authorize, and agree that your personal information may be stored in the jurisdiction where Qurable operates, or that it may be transferred, stored, and processed outside your country of residence.

Upon becoming aware of a security incident affecting personal data processed on a Client's behalf, Qurable will notify the affected Client, providing it with the information available so that the Client may comply with its own notification obligations to authorities and/or End Users, and will cooperate with the Client in investigating, containing, and remediating the incident.

The Website and our services are directed at professionals and businesses. Qurable does not collect, and does not intend to collect, Personal Information from minors. Where applicable, and upon becoming aware that a user is a minor, Qurable will specifically instruct minors not to provide Personal Information on our Website and/or will take reasonable steps to obtain the consent of a parent, guardian, or legal representative before accepting such Personal Information.

Please note that, as a parent, legal guardian, or representative, you are responsible for your minor children's or wards' access to the Website, and we strongly recommend taking appropriate precautions while browsing the Website. To that end, please note that some browsers can be configured to prevent children from accessing certain pages.

With respect to End User data that Clients process through the Platform in connection with their loyalty programs, it is each Client's responsibility, as data controller, to verify compliance with applicable laws regarding minors' personal data, including obtaining consent from their parents, guardians, or legal representatives where required.

If you have voluntarily provided Personal Information through the services available on the Website, you may request access to, review, modification, deletion, or updating of such Personal Information by following the procedure described in Section 10.2.

If you wish to access your Personal Information, or if such Personal Information is inaccurate, outdated, and/or has been deleted, please send your request by email in accordance with the rules applicable in your country as described in Section 12, addressed to the contact address indicated therein, with the subject line "Access," "Rectify," "Delete," and/or "Update," and/or any other subject as applicable, together with the purpose of your request. Such request must include, at a minimum, the following information:

• Name and address, in order to respond to your request within the timeframes established under applicable law;
• A copy of your identity document, passport, or any other document evidencing your identity, or evidencing your legal representative's authority, and, if the request is made through a legal representative, the document evidencing that representative's powers;
• A clear and precise description of the personal data with respect to which you seek to exercise any of the aforementioned rights of access, rectification, objection, cancellation, or revocation, as well as a clear and precise description of your request;
• The date and signature of the requesting party; and
• Any other information or document that may facilitate locating such personal data.

In addition, if you are subscribed to any of the services or communications offered by Qurable, you may unsubscribe at any time by following the instructions included in each communication and for each service.

Qurable will cooperate with the authorities of each country when they formally require information related to our systems and records.

Qurable will respond to requests for access, rectification, updating, or deletion within the timeframes required under the data protection laws applicable in the requesting party's jurisdiction or, failing that, within a reasonable period not exceeding thirty (30) calendar days, counted from the reliable verification of the requesting party's identity.

When a request relates to the personal data of an End User processed by Qurable on a Client's behalf, Qurable will forward the request to the relevant Client so that the Client, as data controller, may handle it as appropriate, and Qurable will provide reasonable technical cooperation to that end.

Qurable's registered office is located at Ayacucho 772, City of Buenos Aires, Argentina. The Website is: https://qurable.co/. Governing Law and Jurisdiction: This Privacy Policy shall be governed by and construed in accordance with the laws of the country in which Qurable is legally domiciled at the time the dispute arises, and the parties submit to the competent ordinary courts of that jurisdiction, for purposes of resolving any dispute relating to the existence, content, scope, interpretation, and/or performance of this Privacy Policy.

The right to access your data and Personal Information may be exercised free of charge by the data subject, provided that the corresponding information is requested at intervals of no less than six months, unless a legitimate interest is shown.

Contact: The contact email address for exercising the rights of access, rectification, updating, and deletion of Personal Information, or for inquiries regarding our privacy policies, is: hello@qurable.co

Personal Information collected through the Website may be transferred, for the purposes described above, to our affiliates, related entities, and service providers in other countries where Qurable operates, including Argentina, Chile, and the United States. Those countries may not have the same data protection laws as the country from which you provided us with your Personal Information. When we transfer your Personal Information to other countries, we will protect it as described in this document.

We have implemented appropriate safeguards, such as standard contractual clauses or other mechanisms recognized under applicable data protection law, to ensure an adequate level of protection for Personal Information transferred outside your country's borders.

Please note that you may file a complaint with the data protection authority having jurisdiction over you, in connection with any breach of personal data protection rules.