PRIVACY POLICY

Last updated on December 01, 2023

Dear User,

BrainLogic AI, the company behind Zapia.com, is on a mission to use Artificial Intelligence to help Latin Americans live better lives. For us, the privacy and security of your data is of extreme importance.

As a company working at the forefront of technology, we recognize that Artificial Intelligence can enhance the quality of life of our users. Our approach is not only to innovate, but to do so with responsibility and transparency.

Therefore, we want you to know that at BrainLogic, we prioritize privacy and the protection of your data as one of our core values. We are dedicated to implementing best practices in privacy and data anonymization, ensuring that your experience with Zapia is safe and secure.

With appreciation and commitment, we leave you below, our Privacy Policy.

The BrainLogic AI team

____________________

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have questions or concerns, contact us at [email protected].

This privacy notice for Brainlogic AI SAS ("we", "us", "our"), describes how and why we may collect, store, use and/or share ("process") your information when you use our services ("Services"), by way of example:

You use our mobile application, our service on WhatsApp or other social networks, or services provided from Zapia, Zapia.com or any other application of ours that links to this privacy notice.
You interact with us in other related ways, including sales, marketing or events.

KEY POINTS

This summary provides key points from our privacy notice, but you can find more detail on any of these topics by clicking on the link below each key point or using our table of contents below.

What personal information do we process? When you visit, use or browse our Services, we may process personal information depending on how you interact with us and the Services, the choices you make and the products and features you use. Learn more about the personal information you provide to us.

Do we process sensitive personal information? We may process sensitive personal information where necessary with your consent and/or where permitted by applicable law. Learn more about the sensitive information we process.

Do we receive personal data from third parties? We do not receive any personal data from third parties.

How do we process your information? We process your information to provide, improve and administer our Services, communicate with you, for security and fraud prevention and to comply with the law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

In cases where the user uses Zapia for advice or product search, we may also process your information as follows.

To provide personalized product recommendations based on your preferences, interaction history and specific needs.
To improve the accuracy and relevance of our product recommendations by analyzing search patterns and shopping preferences.
To process and track transactions made through affiliate links.
To measure and optimize the effectiveness of our product recommendations.
To keep records of commissions generated through affiliate programs.

In what situations and with what types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties, but we do not sell or share data with third parties for advertising or marketing purposes. Learn more about when and with whom we share your personal information.

How do we keep your information secure? We have technical and organizational processes and procedures in place to protect your personal information. However, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or warrant that hackers, cybercriminals or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal or modify your information. Learn more about how we keep your information secure.

What are your rights? Depending on where you are located geographically, applicable privacy law may grant you certain rights with respect to your personal information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is to submit a data subject access request, or to contact us. We will consider and act on any request in accordance with applicable data protection laws.

Want to learn more about what we do with the information we collect? Review the full privacy notice.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide when you register for the Services, show interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or when you contact us or use our Services.

Personal Information Provided by You. The personal information we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

names
telephone numbers
email addresses
postal addresses
information you provide to Zapia services.
product search history
purchasing preferences
interactions related to product recommendations
information on purchases made through our recommendations
product selection criteria shared during consultations

Sensitive Information. Where necessary, with your express consent and/or as permitted by applicable law, we may process sensitive information provided directly by you.

Social media login details. We may offer you the option to register with us using your existing social media account details, such as Facebook, Twitter or other social media accounts. If you choose to register in this way, we will collect the information described in the section entitled "HOW WE HANDLE YOUR SOCIAL LOGINS" below.

App Data. If you use our application(s)/service(s), we may also collect the following information if you choose to provide us or third party applications where Zapia operates, access or permission:

Geolocation Information. We may request access or permission to track location-based information from your mobile device, either continuously or while using our mobile application(s), to provide certain location-based services.
Mobile Device Data. We automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, system version and configuration information, device and application identification numbers, browser type and version, hardware model, Internet service provider and/or mobile operator, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the telephone network associated with your mobile device, the operating system or platform of your mobile device, the type of mobile device you are using, the unique ID of your mobile device, and information about the features of our application(s) that you accessed.
Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out of receiving these types of communications, you can disable them in your device settings. This information is primarily necessary to maintain the security and operation of our application(s), for troubleshooting and for our internal analytics and reporting purposes.

All personal information you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

Automatically collected information

In short: Some information, such as your Internet Protocol (IP) address and/or browser and device characteristics, is automatically collected when you visit our Services.

We automatically collect certain information when you visit, use or browse the Services. This information does not reveal your specific identity (such as your name or contact information), but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and technical information. This information is necessary primarily to maintain the security and operation of our Services and for our internal analysis and reporting purposes.

Like many companies, we also collect information through cookies and similar technologies.

The information we may collect, depending on how you use Zapia, includes:

Log and Usage Data. Log and usage data is service-related, diagnostic, usage and performance information that our servers automatically collect when you access or use our Services and that we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity on the Services (such as date/time stamps associated with your usage, pages and files viewed, searches and other actions you take, such as the features you use), device event information (such as system activity, error reports (sometimes called "memory dumps") and hardware configurations).
Device Data. We collect device data, such as information about your computer, phone, tablet or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile operator, operating system and system configuration information.
Location Data. We collect location data, such as information about the location of your device, which may be accurate or inaccurate. The amount of information we collect depends on the type and configuration of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information by refusing access to the information or by turning off the Location setting on your device. However, if you choose to opt-out, you may not be able to use certain aspects of the Services.

2. HOW DO WE PROCESS YOUR INFORMATION?

In short: We process your information to provide, improve and administer our Services, communicate with you, for security and fraud prevention, and to comply with the law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

To facilitate account creation and authentication and manage user accounts. We may process your information so that you can create and log in to your account, as well as maintain your account in operation.
To deliver and facilitate the delivery of services to you. We may process your information to provide you with the requested service.
To respond to user inquiries/provide user support. We may process your information to respond to your inquiries and resolve any potential problems you may have with the requested service.
To solicit feedback. We may process your information as necessary to solicit feedback and contact you about your use of our Services.
To send you marketing and promotional communications. We may process the personal information you submit to us for our marketing purposes, if this is in accordance with your marketing preferences. You may opt out of receiving marketing emails from us at any time. For more information, please see "WHAT ARE YOUR PRIVACY RIGHTS?" below.
To show you targeted advertising. We may process your information to develop and display customized content and advertising tailored to your interests, location and more.
To protect our Services. We may process your information as part of our efforts to keep our Services secure, including fraud monitoring and prevention.
To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are more relevant to you.
To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.

3. ON WHAT LEGAL BASIS DO WE PROCESS YOUR INFORMATION?

In summary: We only process your personal information when we believe it is necessary, as described in our Terms and Conditions and we have a valid legal reason (i.e., legal basis) to do so under applicable law, such as with your consent, to comply with laws, provide services to you, enter into or fulfill our contractual obligations, protect your rights or satisfy our legitimate business interests.

The General Data Protection Regulation (GDPR) and the UK GDPR require us to explain the valid legal bases on which we rely to process your personal information. As such, we may rely on the following legal bases for processing your personal information:

Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You may withdraw your consent at any time. To withdraw your consent and delete your Zapia account, please write to us at [email protected].
Performance of a contract. We may process your personal information when we believe it is necessary to perform our contractual obligations to you, including the provision of our Services or at your request prior to entering into a contract with you.
Legitimate Interests We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not override your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described above in order to: Sending information to users about special offers and discounts on our products and services. Develop and display personalized advertising content relevant to our users. Analyze how our Services are used so that we can improve them and retain users. Support our marketing activities. Diagnose problems and/or prevent fraudulent activity. Understand how our users use our products and services to improve the user experience.
Legal Obligations. We may process your information when we believe it is necessary to comply with our legal obligations, such as cooperating with a law enforcement or regulatory agency, exercising or defending our legal rights, or disclosing your information as evidence in litigation in which we are involved.
Vital Interests. We may process your information when we believe it is necessary to protect your vital interests or the vital interests of a third party, such as in situations involving potential threats to the safety of any person.

**4.WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In summary: We may share information in specific situations described in this section and/or with the following categories of third parties.

Vendors, Consultants and Other Third Party Service Providers. We may share your information with third-party vendors, service providers, contractors or agents ("third parties") who perform services for us or on our behalf and require access to such information to perform that work. We have contracts with our third parties designed to help protect your personal information. This means that they cannot do anything with your personal information unless they have been instructed to do so. They also will not share your personal information with any organization other than us. They also agree to protect the data they hold on our behalf and to retain it for the period we instruct them to do so. The categories of third parties with whom we may share personal information are as follows:

Affiliate Marketing Programs
Cloud Computing Services
Communication and Collaboration Tools
Data Analysis Services
Data Storage Service Providers
Government Entities
Sales and Marketing Tools
Testing Tools
User Account Registration and Authentication Services
Web Hosting Service Providers

We may also need to share your personal information in the following situations:

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company.
Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to abide by this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
Affiliate Programs and Business Partners. We participate in affiliate programs and collaborate with business partners to provide product recommendations. In this context:
We share anonymous, aggregated data about product interactions and sales conversions with our affiliate program partners.
We use affiliate links that may transmit basic transaction information (such as purchase identifiers) to partner e-commerce platforms.
We do not share personally identifiable information with affiliate programs beyond what is necessary to process transactions.
Data shared with affiliate programs is limited to:
- Anonymous transaction identifiers
- Products purchased
- Transaction values
- Conversion information

5. WHAT IS OUR POSITION REGARDING THIRD PARTY WEBSITES?

In summary: We are not responsible for the security of any information you share with third parties to whom we may link or who advertise on our Services, but who are not affiliated with our Services._

The Services may link to third-party websites, online services or mobile applications and/or contain advertisements from third parties that are not affiliated with us and that may link to other websites, services or applications. Accordingly, we make no warranties with respect to such third parties, and we shall not be liable for any loss or damage caused by your use of such third party websites, services or applications. The inclusion of a link to a third party website, service or application does not imply an endorsement by us. We cannot guarantee the security and privacy of any data you provide to any third party. Any data collected by third parties is not covered by this privacy notice. We are not responsible for the content or the privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to answer your questions.

6. TRANSPARENCY IN PRODUCT RECOMMENDATIONS?

To maintain transparency in our product advisory services:

Your preferences and needs expressed
Objective analysis of product characteristics
Product reviews and ratings
Availability and current market conditions
Our commitment is to provide unbiased and objective recommendations, regardless of existing affiliation agreements.
Users have the right to:
- Request information about our affiliation relationships
- Opting out of product recommendations
- Request referrals without affiliate links

7. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In summary: We may use cookies and other tracking technologies to collect and store your information._

We may use cookies and similar tracking technologies (such as web beacons and pixels) to access or store information. Specific information about how we use these technologies and how you can refuse certain cookies is detailed in our Cookie Notice.

8. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In summary: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third party social media account details (such as your Facebook or Twitter logins). If you choose to do so, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider in question, but will often include your name, email address, friends list and profile picture, as well as other information you choose to make public on that social media platform.

We will use the information we receive only for the purposes described in this privacy notice or as otherwise made clear to you in the relevant Services. Please note that we do not control and are not responsible for other uses of your personal information by your third party social media provider. We recommend that you review their privacy notice to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and applications.

9. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In short: We may transfer, store and process your information in countries other than your own.

Our servers are located in the United States. If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored and processed by us at our facilities and by those third parties with whom we may share your personal information (see "WHEN AND WITH WHOM WE SHARE YOUR PERSONAL INFORMATION" above), in the United States and other countries.

If you are a resident of the European Economic Area (EEA), United Kingdom (UK) or Switzerland, then these countries may not necessarily have data protection or other similar laws as comprehensive as those in your country. However, we will take all necessary steps to protect your personal information in accordance with this privacy notice and applicable law.

European Commission Standard Contractual Clauses:

We have implemented measures to protect your personal information, including the use of the European Commission's Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third party suppliers. These clauses require all recipients to protect all personal information they process, whether it originates from the EEA or the UK, in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar adequate safeguards with our third party service providers and partners, and further details can be provided on request.

10. HOW LONG DO WE KEEP YOUR INFORMATION?

In summary: We retain your information as long as necessary to fulfill the purposes described in this privacy notice, unless otherwise required by law.

We will only retain your personal information as long as necessary for the purposes set forth in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this notice will require us to retain your personal information for more than thirty-six (36) months after termination of the user's account.

Where we do not have an ongoing legitimate business need to process your personal information, we will delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in back-up files), then we will securely store your personal information and isolate it from any further processing until such time as deletion is possible.

11. HOW DO WE PROTECT YOUR INFORMATION?

In summary: We seek to protect your personal information through a system of technical and organizational security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cyber criminals or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal or modify your information. While we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

12. WHAT ARE YOUR PRIVACY RIGHTS?

In summary: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland and some Latin American countries, you have rights that allow you greater access to and control over your personal information. You may review, change or terminate your account at any time.

In some regions, you have certain rights under applicable data protection laws. These may include the right (i) to request access to and obtain a copy of your personal information; (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) to not be subject to automated decisions. In certain circumstances, you may also have the right to object to the processing of your personal information. You may make such a request by contacting us using the contact details provided in the "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" section below.

We will consider and act on any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and believe that we are unlawfully processing your personal information, you also have the right to lodge a complaint with your Member State data protection authority or the UK data protection authority.

If you are located in Switzerland, you can contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we rely on your consent to process your personal information, you have the right to withdraw your consent at any time. You may withdraw your consent at any time by contacting us using the contact details provided in the "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" section below or by updating your preferences.

However, please note that this will not affect the lawfulness of the processing prior to your withdrawal nor will it affect the processing of your personal information carried out on lawful grounds of processing other than consent.

Opt out of receiving marketing and promotional communications You may unsubscribe from our marketing and promotional communications at any time by clicking the unsubscribe link in the emails we send, by replying "STOP" or "UNSUBSCRIBE" to the SMS messages we send, or by contacting us using the details provided in the "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" section below. You will then be removed from the marketing lists. However, we may still contact you, for example, to send you service-related messages necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

In connection with our product advisory services, you have the right to:

Request a record of product recommendations received. This may not be available depending on the time that has passed since the recommendation was made.
Delete your search history and product preferences
Disable product recommendation customization
Opting out of affiliate conversion tracking
Request information on what data is shared with affiliate programs

Account information

If at any time you wish to review or change your account information or terminate your account, you may:

Please contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and Similar Technologies: Most web browsers are set to accept cookies by default. If you prefer, you can generally choose to set your browser to delete cookies and to reject cookies. If you choose to delete or reject cookies, this may affect certain features or services of our Services. You may also opt out of receiving interest-based advertising from advertisers on our Services.

If you have questions or comments about your privacy rights, you can email us at [email protected].

13. CONTROLS FOR DO-NOT-TACK FUNCTIONS

Most web browsers and some mobile operating systems and mobile applications include a "Do Not Track" ("DNT") feature or setting that you can enable to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, a uniform technology standard for recognizing and implementing DNT signals has not yet been finalized. Therefore, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted in the future that we must follow, we will inform you of that practice in a revised version of this privacy notice.

14. DO WE MAKE UPDATES TO THIS NOTICE?

In summary: Yes, we will update this notice as necessary to comply with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by sending you a notice directly. We encourage you to review this privacy notice frequently to stay informed about how we are protecting your information.

15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO), by email at [email protected], or contact us by mail at:

Brainlogic AI SAS
Juan Pablo Pereira
Luis Alberto de Herrera
1052/1109
Montevideo 11300
Uruguay

16. HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM YOU?

You have the right to request access to, change or delete the personal information we collect about you. To request to review, update or delete your personal information, please write to us at [email protected].