Privacy Policy

Effective Date: 03-July-2025
Last Updated: 03-July-2025

This Privacy Policy describes TenPearls LLC’s (“Altiosoft” “us” or “we”) practices regarding personal information collected through 10pearls.com (the “Website”). Altiosoft recognizes the importance of protecting the privacy of your personal information, and we have prepared this Privacy Policy to provide you with important information about the privacy practices applicable to the Website and any other website that links to or refers to this Privacy Policy. This Privacy Policy was last updated on the date above.

By accessing or using the Website, you agree that you have read and understand, and agree to be bound by, this Privacy Policy and the Altiosoft Terms of Use. If you do not agree, discontinue your use of the Website.

Scope of Policy

This Privacy Policy applies to personal information collected through our Website, any related mobile applications, and other services that link to this policy.

Information Collected

Altiosoft collects the following personal information from or about you in order to more seamlessly provide and enhance the quality of the Website:

  • Identifiers: Information provided by you directly through submitting that information through our Website forms (such as the Contact Us page).
  • Usage Data: Information relating to internet activity or other electronic network activity. This includes IP address, operating system type and version, web server type and version, PHP version, database type and version, cookie information, device information, browsing activities, and platform or mobile application use data, referring domain, destination domain and destination path, performance, security, software configuration and availability of our software on your servers and network, website user statistics and website and portal use and viewing activity records, communication preferences.
  • Geolocation data, which includes geographic information derived from a customer’s IP address, MAC address, or mobile device.

How Information Is Collected

The types of information listed above can also be defined by how they are received by us. Such information falls into the following categories:

  • Information You Give Us. We receive and store the information that you enter into our website via submission form, or that you provide directly to us in any other way. We do not share such information with third parties without your consent.
  • Automatic Information. We receive and store certain types of information whenever you interact with us. For example, like many websites, we use information packets called “cookies.” Cookies are small pieces of data that allow a website to “remember” a user’s actions over time. Most browsers are set to accept cookies unless you reconfigure your browser to refuse them or to notify you when you will have received one. If you do not accept cookies, you will not be able to use certain features of the Website. Altiosoft does not currently recognize or respond to browser-initiated “Do Not Track” signals. We may also ask advertisers or other partners to serve ads or services to your devices, which may use cookies or similar technologies placed by us or such third party. For more information, please visit allaboutcookies.org. We may use cookies and other similar methods such as log files, pixel tags, web bugs, web beacons, clear GIFs, or Local.
  • Storage Objects (LSOs) such as HTML5 and Flash to collect information about the ways you interact with and use Altiosoft.
  • Information Collected via Third Parties. We may allow third-party partners such as LinkedIn and Facebook to place tracking technologies (e.g., pixels or cookies) on our website. These tools enable us to analyze the effectiveness of our advertising and marketing, and better understand user behavior. The LinkedIn Insight Tag and the Facebook Pixel, for example, may collect information such as your IP address, browser type, and pages visited. This data may be linked to your LinkedIn profile and used in accordance with LinkedIn’s and Facebook’s privacy policies, respectively. You can manage your ad preferences or opt out of data collection directly through your LinkedIn and Facebook settings. You can opt out of certain data collection or targeted advertising through settings provided by those platforms or industry opt-out mechanisms such as http://optout.aboutads.info/.

By continuing to use our site, you consent to our use of personal information as described in this section. You can manage your cookie preference (including disabling cookies) through your browser settings.

Information from Other Sources.

We do not receive information about you from any other source.

Use of Information

To the extent permitted by applicable law, we make use of the personal information collected in connection with the Website for the following purposes:

  • To provide and improve our Website, product, and services;
  • To optimize operation of the service and provide support to our business functions;
  • To protect against criminal activity, claims and other liabilities;
  • To send customers information regarding Altiosoft and issues specifically affecting Altiosoft;
  • To respond to reviews, comments, or other feedback provided to us;
  • To support and personalize the service to your needs and interests;
  • To protect the security and integrity of our service, content, and our business;
  • To provide more streamlined customer support;
  • To provide you with information, products, or services that you request from us;
  • For benchmarking, data analysis, audits, developing new products, facilitating product, software and applications development, improving our services, conducting research, analysis, studies or surveys, identifying usage trends, as well as for other analytics purposes;
  • To meet our contractual requirements, including the first and second bullet point set forth below under “Sharing of Information”;
  • To comply with applicable legal or regulatory requirements and our policies, as described below in the second bullet point under “Sharing of Information”;
  • To distribute Altiosoft updates and newsletters to customers;
  • For any other purposes disclosed to you at the time we collect your information or pursuant to your consent;
  • To comply with legal bases under applicable law, including contract performance, legitimate interests, legal obligations, and where you have provided consent.

Sharing of Information

Altiosoft does not sell your personal information, nor has Altiosoft sold personal information in the past 12 months. Altiosoft shares and discloses personal information only to the extent set forth below:

  • Mergers, Acquisitions, Divestitures. In the event Altiosoft or any affiliate, portion, group or business unit thereof, undergoes a business transition, such as a merger, acquisition, consolidation, reorganization, divestiture, liquidation or dissolution (including bankruptcy), we may share, disclose or transfer personal information to a buyer, investor, new affiliate, or other successor. In any event, we will notify you before information about you is transferred and becomes subject to a different privacy policy.
  • Law Enforcement and National Security. We may share personal information with legal, governmental, or judicial authorities, as instructed or required by those authorities or applicable laws, or to comply with any law or directive, judicial or administrative order, legal process or investigation, warrant, subpoena, government request, regulatory request, law enforcement or national security investigation, or as otherwise required or authorized by law.
  • Service Providers. We may share your information with trusted third-party service providers who assist us in operating our Website, conducting our business, providing social media services, providing services to you, or our analytics partners, subject to confidentiality obligations. International Transfers. If you are accessing our Website from outside of the United States, be aware that your information may be transferred to and maintained on servers located in the United States or other jurisdictions. We ensure appropriate safeguards are in place to protect personal information transferred internationally. See Section: Outside the US – International Data Transfers below for more information.

Storage of Information

We will not keep your personal information for longer than is necessary, the determination of which depends on several factors:

  • Whether we are required to keep the information for legal or regulatory purposes;
  • Whether we need to keep the information to protect you or us, such as your transaction history;
  • The original purpose of collecting the information;
  • The age of the information;
  • We periodically review the data we hold and securely delete or anonymize personal information that is no longer necessary.

Third Party Sites

Altiosoft may provide links to other websites, mobile applications, resources, or Internet locations over which Altiosoft does not have control (“External Web Sites”). Such links do not constitute an endorsement by Altiosoft of those External Web Sites. Our Privacy Policy does not apply to External Web Sites. Your use of External Web Sites is subject to the terms of use and privacy policies located on the External Web Sites, and we encourage you to read the privacy policies of any External Web Sites with which you choose to interact.

Data Security

We implement reasonable technical and organizational security measures designed to secure and protect personal information from loss, misuse, unauthorized access, disclosure, etc. Please note, we do our best to protect your personal information, however, we cannot fully eliminate security risks associated with the storage and transmission of personal information over the internet or any other public network. Any transmission of personal information is at your own risk.

In the event of a data breach involving your personal information, we will notify you as required under applicable law and describe the steps we are taking to mitigate the effects.

Your Data Protection Rights

Altiosoft would like to make sure you are fully aware of all of your data protection rights. Every customer is entitled to the following:

  • The right to access. You have the right to request copies of your personal data. We may charge you a small fee for this service.
  • The right to rectification. You have the right to request that we correct any information you believe is inaccurate or incomplete.
  • The right to erasure. You have the right to request that we erase your personal data, under certain conditions and as provided by applicable law.
  • The right to data portability. You have the right to request that we transfer the data we have collected toゆる
  • The right to object to processing. You have the right to object to our processing of your personal data in certain circumstances.
  • The right to restrict processing. You have the right to request that we restrict the processing of your personal data under certain conditions.
  • The right to withdraw consent. Where our processing of your personal data is based on your consent (such as the collection of Cookies), you may withdraw that consent at any time.
  • You will not be discriminated against in your use of the services for exercising these rights, though use of the right of erasure may necessarily reduce the functionality of certain processes.
  • If you request to exercise any of these rights, we will respond to you as soon as is practicable.

Please contact us if you wish to exercise any these rights by sending us an email at hello@altiosoft.com.

Children

Our Website is not intended for children under the age of eighteen (18) without parental consent. If you are under the age of 18 and wish to create an account with Altiosoft, you must have your parent or legal guardian create the account on your behalf, submit your personal information, and agree to this privacy policy on your behalf.

Modifications

Altiosoft reserves the right to change this Privacy Statement from time to time. Altiosoft will provide notification of the material changes to this Privacy Statement, such as by sending a notification, posting a notice on the Website, or updating the “Last Updated” date above.

Contact Us

Questions about this Privacy Statement or the information practices of Altiosoft should be directed to our privacy team by emailing us at hello@altiosoft.com.

Jurisdiction-Specific Clauses

The following additional clauses apply to you if you are a resident of or otherwise protected by the privacy laws in the specified jurisdictions. These clauses provide extra information and rights specific to those regions, in addition to the provisions stated in our core Privacy Policy above. We clearly indicate which laws are being addressed in each clause.

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California (CCPA/CPRA)

If you are a resident of California, you have specific privacy rights under the California Consumer Privacy Act (CCPA) of 2018, as amended by the California Privacy Rights Act (CPRA) of 2020. These rights are in addition to any general rights described in this Policy:

  • Right to Know: You have the right to request that Altiosoft disclose the categories and specific pieces of personal information we have collected about you, the categories of sources from which the information was collected, the business or commercial purpose for collecting (or selling/sharing, if applicable) the information, and the categories of third parties with whom we share your personal information. Essentially, you can ask us to provide you with a report of the personal data we have about you and how we have handled it in the past 12 months.
  • Right to Delete: You can request that we delete personal information we have collected from you and retained, subject to certain exceptions. For example, we may retain data needed to complete a transaction, detect security incidents, comply with legal obligations, or other exemptions allowed by law. If you request deletion, we will also direct our service providers to delete your information from their records, where required.
  • Right to Correct: You have the right to request that we correct any inaccurate personal information that we maintain about you. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information.
  • Right to Opt-Out of Sale or Sharing: California law gives you the right to opt out of the “sale” or “sharing” of your personal information to third parties. Sale is broadly defined to include not just exchange for money, but also other valuable consideration (it can include some advertising disclosures). Sharing refers to disclosing information for cross-context behavioral advertising (targeted advertising). Altiosoft does not sell personal information for money. We also do not share your personal information for targeted advertising without your consent. If in the future Altiosoft engages in any activity deemed a “sale” or “sharing” under CCPA, we will provide a clear “Do Not Sell or Share My Personal Information” link or mechanism for you to opt out. You can also send an opt-out request to us at any time (see Contact Information above), and we will honor it as required by law.
  • Right to Limit Use of Sensitive Personal Information: If we collect “sensitive personal information” (as defined under California law, e.g. precise geolocation, racial or ethnic origin, health information, etc.), you have the right to direct us to limit the use of that sensitive information to only what is necessary to perform the services or provide the goods. Altiosoft only uses sensitive information for limited purposes (such as processing payment card information for a purchase, or if you voluntarily provide health info for an event accommodation) and does not use or disclose sensitive personal information for purposes that would trigger a right to limit under CPRA. If that changes, we will provide an opt-out/limit mechanism and notify you.
  • Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights. This means, for instance, we will not deny you our services, charge you a different price, or provide a different level or quality of service just because you exercised your rights under the CCPA. However, please note that if you request deletion of certain data, some features of our service that rely on that data may no longer function. In any case, Altiosoft will not retaliate or discriminate in response to your privacy choices.

Submitting CCPA Requests: You (or your authorized agent) can submit requests to know, delete, or correct by contacting us at hello@altiosoft.com. We will need to verify your identity (or your agent’s authority) before processing the request, which may involve asking you for personal information to match against our records. Consistent with California law, you may exercise these rights up to twice in a 12-month period free of charge. Any disclosures we provide will cover at most the 12-month period preceding our receipt of the request, and if applicable we will explain if we have a legitimate reason for not complying with a request.

California “Shine the Light” Law: California Civil Code § 1798.83 (the “Shine the Light” law) allows California residents to ask companies once a year if they have shared personal information with third parties for those third parties’ direct marketing purposes. Altiosoft’s policy is not to disclose personal information to third parties for their own direct marketing without your consent. If you are a California resident and wish to make a request under the Shine the Light law, please contact us with “Shine the Light Request” in the subject line. We will provide a list of categories of personal information disclosed (if any) and the names and addresses of third parties with which we shared personal information for their direct marketing purposes in the immediately preceding calendar year.

California Minors (Online Eraser Law): If you are a California resident under the age of 18 and a registered user of our services, you may request removal of content or information you have publicly posted. Please contact us with details of your request. Note that removal does not ensure complete or comprehensive removal (for example, content that was reposted by others or that we are required to keep by law may not be fully removed).

These California-specific rights and disclosures are effective as of January 1, 2023, and this section of our Privacy Policy is designed to comply with the CCPA/CPRA. For more information about your rights, you may visit the California Attorney General’s CCPA website or consult the text of the law. If you have questions about your California privacy rights, you can always contact us for further information.

Outside the US – International Data Transfers

Altiosoft operates on a global scale, and the personal information we collect may be transferred to and processed in countries outside of your home country. This means your data could be stored on servers in jurisdictions that may not have the same level of data protection laws as your country. For example, if you are located in the European Economic Area (EEA) or the United Kingdom, your personal data might be transferred to the United States or other countries where our servers or service providers are located.

Regardless of where your personal data is transferred, we take steps to ensure that your information remains protected in accordance with this Privacy Policy and applicable law. Altiosoft implements the following safeguards for international data transfers:

  • Adequacy Decisions: Where applicable, we may transfer personal data to countries that have been officially recognized by relevant authorities (such as the European Commission or the UK Government) as providing an adequate level of data protection.
  • Standard Contractual Clauses: In the absence of an adequacy decision, we use approved Standard Contractual Clauses (SCCs) or equivalent data transfer agreements to contractually require that your personal data receives a level of protection consistent with EU/UK data protection law. These SCCs obligate the recipient to safeguard your information and grant you enforceable rights and legal remedies.
  • Other Safeguards: We may rely on other transfer mechanisms where appropriate, such as binding corporate rules (for intragroup transfers), certifications under approved privacy frameworks, or obtaining your explicit consent for specific transfers (where permitted by law). In all cases, we will ensure that any transfer of your personal data is lawful and that appropriate safeguards are in place.

You have the right to inquire about the safeguards we use to export your personal data internationally. If you would like more information about these measures, please contact us using the information in the Contact section.

Note for EEA/UK Individuals: Whenever we transfer your data out of the EEA or UK, we will do so in compliance with Articles 44-49 of the GDPR/UK GDPR. Altiosoft continuously monitors the legal landscape regarding international transfers and will adjust its practices and contractual commitments as needed to ensure ongoing protection of cross-border data flows.

European Union (GDPR)

If you are located in the European Union (EU) or the European Economic Area (EEA), the processing of your personal data is subject to the EU General Data Protection Regulation (GDPR) and applicable EU member state laws. Under the GDPR, you have several important rights (as already outlined in the “User Rights” section above) and we want to reiterate some key points for transparency:

  • Legal Bases for Processing: We ensure that we have a valid legal basis for all personal data processing, as required by Article 6 of the GDPR.
  • EU Data Subject Rights: As an EU data subject, you have the Right to be Informed, Right to Access, Rectification, Erasure, Restriction, Objection, Data Portability, and the right not to be subject to automated individual decision-making (including profiling) under the conditions defined by GDPR. We have described these rights in the section entitled “Your Data Protection Rights” above.
  • Withdrawal of Consent: Where we process your data based on consent, you have the right to withdraw that consent at any time. For example, you can adjust your cookie preferences via your web browser settings and our site. Withdrawing consent will not affect the lawfulness of processing we conducted prior to withdrawal, and it won’t affect processing under other legal bases.
  • Right to Lodge a Complaint: GDPR grants you the right to lodge a complaint with a Supervisory Authority (Data Protection Authority) in the EU. If you believe we have infringed your data protection rights or GDPR requirements, you may contact the supervisory authority in the EU member state of your habitual residence, place of work, or where the alleged infringement occurred. We invite you to contact us first so we can attempt to resolve any issue directly.
  • Representative: Altiosoft is not established in the EU. To the extent legally required, we will designate an EU Representative in accordance with Article 27 GDPR. The contact details of our representative (if applicable) are available upon request.

We process personal data of individuals in the EU in accordance with the GDPR’s principles of lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity/confidentiality, and accountability. This means we only collect what we need for defined purposes, keep data accurate and secure, and retain it no longer than necessary. For more detailed information on how we comply with GDPR or to exercise any rights, please contact us. We are happy to assist and provide additional explanations or copies of data as required.

United Kingdom (UK GDPR)

Residents of the United Kingdom have similar protections under the UK Data Protection Act 2018 and UK GDPR. If you are in the UK, Altiosoft will ensure your personal data is handled in compliance with UK data protection law. In practice, this means:

  • You have the same fundamental rights to access, correct, delete, restrict, or object to the processing of your data, as well as the right to data portability and to not be subject to certain automated decisions. We have described these rights in the section entitled “Your Data Protection Rights” above.
  • You have the right to be informed about how your data is used (which is the purpose of this Privacy Policy and future privacy notices we provide).
  • Withdrawal of Consent: Where we process your data based on consent, you have the right to withdraw that consent at any time. For example, you can adjust your cookie preferences via your web browser settings and our site. Withdrawing consent will not affect the lawfulness of processing we conducted prior to withdrawal, and it won’t affect processing under other legal bases.
  • You have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO) if you believe we have not complied with applicable data protection laws. The ICO’s contact details are: Tel: +44 0303 123 1113; website: ico.org.uk. We invite you to contact us first so we can attempt to resolve any issue directly.
  • Altiosoft is not established in the UK but is subject to UK GDPR. To the extent required under the UK GDPR, we will appoint a UK Representative per Article 27 UK GDPR. We will provide our UK Representative’s contact information upon request.
  • Cross-border transfers from the UK will be handled with similar safeguards as EU transfers. The UK has approved International Data Transfer Agreements and Addendums to the EU Standard Contractual Clauses; Altiosoft will utilize these or other permitted mechanisms for transfers of personal data from the UK to countries not deemed adequate by the UK government. We ensure your data exported from the UK receives protection equivalent to UK standards.

We treat UK individuals’ data with the same care and under the same policies as described for EU data. Unless stated otherwise, all references in this Privacy Policy to GDPR legal bases, rights, and obligations should be read as including the UK GDPR equivalent. We make required UK-specific registrations or filings if needed.

Peru

For individuals in Peru, Altiosoft complies with Peru’s Personal Data Protection Law (Law No. 29733) and its regulations. This law guarantees certain rights and imposes obligations regarding your personal data. In addition to the information provided in this Privacy Policy, the following points apply to Peruvian personal data and users:

  • ARCO Rights: Under Peruvian law, you have the right to Access, Rectify, Cancel, and Oppose the processing of your personal data – these are often referred to as “ARCO” rights. In practice, this means you can request to review the personal data we hold about you, request corrections or updates to any inaccuracies, request deletion or cancellation of data that is excessive or no longer relevant, and object to processing in certain circumstances. You also have the right to be informed about how your data is being used at the time of collection, including the purpose, recipients, and the identity of the data controller. We provide that information through this Privacy Policy future privacy notices.
  • Consent: Peru’s law generally requires prior, informed, express, and unequivocal consent from you for the processing of your personal data, unless an exception applies (for example, when processing is necessary for the performance of a contract you have with us, for compliance with a law, for public interest, etc.). By using our services and providing personal data, you are consenting to its processing as described, to the extent such consent is required. If we collect any sensitive personal data from you, we will obtain explicit written consent, as mandated by law. You have the right to revoke your consent at any time, and we will stop processing your data going forward, although such withdrawal will not affect processing already completed.
  • Data Registration: Altiosoft does not maintain a database of personal data in Peru.
  • International Transfers: Peruvian law imposes restrictions on cross-border data flows. We will only transfer your personal data outside of Peru in compliance with Law No. 29733. Typically, cross-border transfers require that the recipient country or entity provides adequate protection for your personal data, or we must secure your consent for the transfer, or fit another legal exception. Altiosoft will ensure any international transfer of Peruvian personal data is done pursuant to the law’s requirements.
  • Data Subject Assistance: We have procedures to assist Peruvian data subjects in exercising their rights. Requests to exercise ARCO rights can be sent to us via the contact information in this Policy. As required by Peruvian regulations, we may ask you to fill out a specific ARCO request form and verify your identity (or your legal representation) before responding. We will respond within the timeframes established by law. According to current regulations, we will typically respond to access or information requests within 20 business days and to rectification, cancellation, or opposition requests within 10 business days, from the day following the request, with possible extensions as allowed by law. We will inform you in writing of the result of your request.
  • Enforcement and Complaints: The National Authority for Personal Data Protection (ANPD), part of the Peruvian Ministry of Justice, oversees and enforces data protection compliance. If you believe your data protection rights have been violated, you have the right to file a complaint with the ANPD. You also have a Right to Protection, meaning if we do not address your rights requests, you can seek enforcement through the ANPD or judicial authorities. Additionally, in case of violations of the law, you have a right to seek appropriate indemnification for any harm caused.

Colombia

For individuals in Colombia, Altiosoft handles personal data in accordance with Colombia’s data protection laws, including Statutory Law 1581 of 2012 and its regulatory decrees (often collectively referred to as the “General Personal Data Protection Regime”). We wish to highlight the following for Colombian data subjects:

  • Data Controller Information: Altiosoft acts as a Data Controller when processing personal data. Our contact details are provided in the Contact section. If we were to use a third-party Data Processor in Colombia, we remain responsible for ensuring they also comply with Colombian data protection requirements.
  • Authorization and Purpose: Except as provided by law, we will process your personal data only with your prior, express, and informed authorization. At the time of collection, we will inform you of the specific purposes of processing, your rights, and all required information (in compliance with Article 12 of Decree 1377 of 2013). By accepting this Privacy Policy and providing your data, you are authorizing Altiosoft to use it for the described purposes. We do not collect sensitive personal data or data on minors without meeting the strict consent requirements set by law (e.g., double consent for sensitive data, and parental authorization for minors).
  • Data Subject Rights: As a data subject (“Titular de datos”) in Colombia, you have specific rights under Article 8 of Law 1581 of 2012, including:
    • Right to Know, Update, and Rectify: You can inquire about the personal data we have about you, and request that we update it or correct it if it is partial, inaccurate, or incomplete. This ensures your data is accurate and up-to-date.
    • Right to Proof of Authorization: You may request evidence of the authorization you gave us to process your data, except when processing is allowed without consent (e.g., for public data, or as stipulated by law).
    • Right to Information about Use: Upon request, you have the right to be informed about how your data has been used by Altiosoft. We should inform you, for example, what personal data we hold and what we have done with it (which typically would be outlined in this Policy and any direct responses to you).
    • Right to Withdraw Authorization and/or Request Deletion: You can revoke the consent you gave us and/or demand deletion of your data when our processing does not respect constitutional or legal principles, rights, and guarantees. For instance, if you feel we are using your data beyond the purposes authorized, you have the right to withdraw your consent and request we delete your information, provided there is no legal duty for us to keep it.
    • Right to File Complaints: If you believe Altiosoft or any data processor working for us is violating data protection rules, you have the right to file a complaint with the Superintendence of Industry and Commerce (SIC) in Colombia. The SIC is the national data protection authority that oversees compliance. However, Colombian law generally requires that before filing a complaint with the SIC, you must first raise your concern or request directly with us (the data controller) through a consultation or claim process, and only if we fail to address it within the legal timelines or you disagree with our response can you escalate to the SIC.
    • Right to Free Access: You can access your personal data that we are processing at no cost, at least once per calendar month, or immediately in the case of substantive changes to this Policy that affect your rights significantly.
  • Procedures for Rights Requests: In line with Colombian regulations (Law 1581 and Decree 1377), we have procedures for you to exercise these rights.
    • Consultas (Inquiries): If you want to consult the personal information we have about you, you may submit a request (for example, via email to our contact address). We will respond to inquiries within a maximum of 10 working days from the day after we receive your request. If we need more time (due to complexity), we will inform you of the extension before the initial 10-day period expires, and the extension will not exceed an additional 5 working days.
    • Reclamos (Claims): If you want to correct, update, or delete data, or if you assert an alleged breach of our duties under the law, you can file a claim. The claim should contain your identification, the description of the facts that give rise to the claim, the address, and supporting documents if applicable. We will acknowledge receipt of your claim and, if it’s incomplete, we may ask you to correct it within 5 days. Once a complete claim is received, we will include a legend in our database saying “claim in process” next to the disputed information. We will address your claim within 15 working days from the day after we received it. If we need more time, we will inform you of the reason for the delay and may take up to an additional 8 working days. These timelines are per Article 14 and 15 of Law 1581. We will inform you of the outcome of your claim (whether we made the correction, deletion, or otherwise resolved the issue or not) and if not, we will explain our reasons.
  • Transfers and Transmission: If Altiosoft transfers personal data to third parties (domestically or internationally), we will ensure it is done in compliance with Chapter VIII of Decree 1377 of 2013. International transfers of data to countries that do not provide an adequate level of data protection will be done only: with your express consent, or as necessary for the execution of a contract, or in reliance on one of the exceptions provided by Article 26 of Law 1581 (such as when the transfer is necessary for international cooperation between intelligence agencies, for a contract in your interest, for bank or stock transfers, etc.). We will also sign “Transmission Contracts” (data processing agreements) with any third-party data processors (Encargados) processing data on our behalf, as required by Colombian law, ensuring they comply with our standards and Colombian data protection principles.

By adhering to Colombian data protection provisions, Altiosoft reaffirms that your personal data will be treated lawfully and with utmost respect for your rights. If you have questions about how we process data in Colombia or wish to exercise your Habeas Data rights, please contact us. We can provide information or assist you in Spanish as needed.

Costa Rica

In Costa Rica, the protection of personal data is governed by Law No. 8968 of 2011, “Protección de la Persona frente al Tratamiento de sus Datos Personales,” and its regulations. If you are a Costa Rican resident or if your personal data is processed in Costa Rica, the following additional points apply:

  • Consent and Collection: Costa Rican law generally requires express consent from the data subject for the collection and processing of personal data, unless an exception applies. By using Altiosoft’s services and providing your data, you are giving us consent to process it for the purposes described. We will inform you at the time of collection if any data is mandatory or optional and the consequences of refusing to provide it. We do not collect sensitive personal data (such as data on race, health, sexual orientation, etc.) unless strictly necessary and with your explicit consent, in line with the law’s requirements. Moreover, we will not collect information from you that is excessive in relation to the purposes (“principio de proporcionalidad”).
  • Data Quality: We strive to ensure that all personal data in our custody is truthful, complete, and accurate, as required by Costa Rican regulations. You have the right to access your data and to dispute or correct any erroneous or outdated information at any time. We have procedures in place (internal protocol) to allow you to review and request correction of your data, as mandated by law.
  • ARCO Rights: Similar to other Latin American regimes, you have derechos ARCO in Costa Rica – the rights of Access, Rectification, Cancellation (Deletion), and Opposition. In practice, this means:
    • Access: You can request that we inform you whether we are processing any personal data about you and request a copy of that data.
    • Rectification: If any personal data is incorrect or incomplete, you can request we correct or update it.
    • Cancellation: You can request that we delete your personal data when it is inappropriate, excessive, or you believe it’s being processed contrary to Law 8968. Do note, the law provides that we may deny erasure if we have a legitimate reason to keep the data (such as compliance with a legal obligation or if the data is needed for a relationship with you). However, if data is canceled, it will be either deleted or kept only for historical/statistical purposes with proper protections.
    • Opposition: You can object to the processing of your personal data, particularly for advertising, marketing, or otherwise if you have legitimate reasons relating to your particular situation. If you object, and the processing is not for a legal obligation, we will cease processing your data for those purposes.

    According to information about Law 8968, Costa Rican citizens have at least the rights to access, rectification, and erasure of their data. We affirm that Altiosoft provides you with these rights. To exercise them, please contact us and clearly indicate you are making an “ARCO rights request for Costa Rica.” We may ask you for identification to verify the request. We will respond within a reasonable time and in accordance with any specific deadlines provided by local law or regulations.

  • Data Security and Confidentiality: Altiosoft will take all necessary technical and organizational measures to ensure your personal data is kept secure and confidential, in compliance with Article 10 of Law 8968. We are aware that unauthorized disclosure of personal data can lead to penalties, so we maintain strict controls to prevent any such incidents. Our employees and any third parties who handle your data are required to maintain confidentiality.
  • Data Registries: If applicable, we will register our database containing personal information with the Costa Rican data protection authority, known as PRODHAB (Agencia de Protección de Datos de los Habitantes), especially if we disclose, commercialize, or transfer personal data to third parties. If we process data purely for internal purposes (e.g., an in-house customer database not shared externally), registration may not be required. We will ensure to abide by the regulations on this matter.
  • International Transfers: Cross-border transfers of personal data from Costa Rica are allowed only if the recipient country or entity provides adequate data protection, or if we have obtained your consent, or if otherwise permitted by law. We will not transfer your personal data to another country without ensuring it’s lawful – for instance, we may use contracts to guarantee that the foreign party will protect your data in line with Costa Rican standards. Note that transferring data to our service providers or affiliates for processing (e.g., cloud storage or IT support) is not considered a third-party disclosure requiring separate consent if it’s within the same economic group or for a service on our behalf, but we remain accountable for those transfers.
  • Enforcement: The data protection authority PRODHAB oversees compliance. If you believe your data has been mishandled, you have the right to lodge a complaint with PRODHAB. However, we encourage you to reach out to us first so we can attempt to resolve your issue directly and promptly.

By addressing these points, Altiosoft shows its adherence to Costa Rica’s privacy requirements. We handle any Costa Rican personal data in accordance with the law’s principles of lawfulness, consent, purpose, proportionality, data quality, security, and confidentiality. If you need this Privacy Policy or information in Spanish for better understanding, please let us know.

India (Draft Personal Data Protection Bill 2023)

India currently does not have a finalized comprehensive data protection law in force, but a Personal Data Protection Bill 2023 (PDPB 2023) has been drafted (as of the latest update). Altiosoft is committed to aligning its practices with this upcoming legislation and any existing privacy protections under Indiai law (such as the Prevention of Electronic Crimes Act 2016, which covers certain aspects of data misuse). If you are in India, the following information is relevant:

  • Scope: The proposed PDPB 2023 has an extraterritorial scope and would apply to Altiosoft if we: (a) have a presence in India and process personal data; (b) offer goods or services to people in India or monitor their behavior, even if Altiosoft is established outside India; or (c) otherwise process personal data in India. In simpler terms, if we handle personal data of individuals in India, the law is likely to consider us bound by its requirements.
  • Grounds for Processing: The PDPB 2023 (in line with global standards) requires that we have a lawful basis to process personal data. The permissible grounds include your consent, necessity for a contract with you, compliance with a legal obligation, protection of vital interests (life/health), legal requirements (court orders), legitimate interests of the data controller, and certain public interest scenarios (like public health or research). Altiosoft will ensure that for any processing of Indiai users’ data, we will have your consent or another valid legal justification. For instance, we might process data to fulfill a service you requested (contract) or ask your consent for marketing. We will not process sensitive personal data (such as health, biometric, religious or political belief information) or any “critical personal data” except in strict compliance with the law’s provisions, which likely include explicit consent or other narrowly defined exceptions.
  • Data Subject Rights: Once enacted, the law will grant individuals specific rights over their personal data. According to the latest draft, these rights include: the right to access your personal data held by us; the right to have inaccurate data corrected; the right to have your data erased in appropriate circumstances; the right to restrict or prevent processing likely to cause harm or distress; and the right to data portability (to receive your data in a usable format or have it transferred to another service). You would also have the right to register a complaint (grievance) with us and, if not resolved, escalate it to the proposed National Commission for Personal Data Protection (once established). Additionally, you have the right not to be subject to a decision based solely on automated processing (including profiling) that significantly affects you. Altiosoft intends to honor all these rights. We will provide mechanisms for Indiai users to submit requests (e.g., an email to our contact or a web form specifically for data requests). We will respond within the timeframes that the law mandates (the draft Bill suggests a timeline, for example, 30 days to respond to access requests, etc., but we will confirm and comply with the final requirements).
  • Data Breach Notifications: If we experience a data breach affecting Indiai personal data, the draft law would require us to notify the Commission and affected data subjects within 72 hours of becoming aware of the breach (unless the breach is unlikely to harm rights). Altiosoft has internal procedures to manage data breaches and will follow this protocol when the law is effective.
  • Cross-Border Data Transfers: The PDPB 2023 imposes conditions on transferring personal data out of India. Critical personal data (a category defined by the law or designated by the authorities) may be required to be stored and processed only on servers located within India. Other personal data can be transferred abroad if certain safeguards are in place: for instance, if the destination country is approved as having adequate privacy protection, or if we use contracts approved by the Commission, or if we obtain your explicit consent for the transfer (provided it doesn’t undermine national interests). Altiosoft will closely monitor these requirements. If you are in India, we will, by default, aim to store and process your data on servers within India if the law classifies it as “critical personal data.” If we need to transfer any of your personal data internationally (for example, to our headquarters or to use a cloud service), we will do so only in compliance with Indiai law – likely by adopting the Standard Contractual Clauses or obtaining necessary approvals/consents. We will also inform you about such transfers and how your data will be protected.
  • Children’s Data: The draft Bill emphasizes protecting children’s personal data (defined as under 18 years). It requires parental consent for processing children’s data and prohibits practices like behavioral monitoring or targeted advertising directed at children. Altiosoft does not knowingly offer services to children without parental consent and will comply by implementing age verification and parental consent mechanisms for any features that might involve under-18 users. We will also avoid any prohibited profiling or marketing to children as per the law.

Please note that the Indiai Personal Data Protection Bill 2023 is still in draft form. We are tracking its progress and any amendments. This section of our Privacy Policy will be updated once the law is enacted to reflect the final obligations and rights. Our commitment is that, even before formal enactment, we aim to handle Indiai users’ data with a high level of privacy and security in line with international standards and the anticipated law. If you are a user in India and have any concerns or requests regarding your personal data, do not hesitate to reach out via the contact information provided. We will be pleased to assist and to ensure your privacy is protected according to the highest standard applicable.

Privacy Overview
Altiosoft

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