DIVEO ARGENTINA S.A. PRIVACY POLICY
At DIVEO ARGENTINA S.A. we do everything possible to ensure that you understand how we collect, use, and disclose personal data. This Privacy Notice outlines the way we process personal data of individuals who are not our employees but with whom we have relationships through our customers, subcontractors, contractors, service providers, suppliers, professional and business partners (such as universities and research institutions), investors and resellers, government and lobbying contacts, visitors to our website, and other relevant stakeholders.
“Personal data” means information that identifies an individual or relates to an identifiable individual.
You are not required to provide your personal data to DIVEO ARGENTINA S.A. If you choose not to provide your personal data to DIVEO, we may not be responsible for delivering enhancements to our products or services, all features and/or responding to inquiries you may have.
We may include additional and/or updated privacy information to this notice about our privacy practices that are specific to a product, service, or jurisdiction, and the details can be accessed through the applicable product or service or via our privacy center.
2 Personal Data We Collect
We collect the following categories of personal data as outlined in this notice:
Identification Data
Name, surname, job title, handwritten or electronic signature, date and place of birth, passport numbers or other official identification numbers, nationality and/or residence information, photographs, images, gender.
Contact Data
Personal address, email address, social media IDs, and phone number.
Role-Based Data
Job position, company name, business address, business phone number, business email, length of employment.
Professional Experience
CV, work history, educational information and qualifications, background checks, and evaluations.
Access Data
DIVEO ID, IDs used for security purposes, login credentials for accessing online services and platforms, user IDs and passwords, traffic and location data, and other technical information.
Financial Data
Bank account and payment card information.
Marketing and Communications Data
Your preferences for promotional and marketing communications, language, interests, participation in promotions or surveys, responses to promotional communications displayed or sent to you, preferred methods for receiving promotional communications, recordings of phone calls with customer service and other representatives, and other comments/preferences you may express during the business relationship.
Usage Data
Details of access to services and online platforms, network sessions, and data about your use of our equipment, electronic communication systems, and property, including computers, mobile devices, email, internet, phone, and voicemail.
Relationship History
Details of transactions, sales, purchases, usage, your communications with us, your account with us, details of gifts, travel and representation, details of your complaints, claims, and general inquiries.
User-Generated Content
Electronic content when using our systems, such as training records, voice and interactive communications like blogs, chats, use of webcams and network sessions, feedback on our products and services, and other content you may create or share, such as posts on our social media pages, blogs, and comment sections.
Visitor and Event Data
Dietary restrictions, travel and accommodation details, facility access passes, photographs and videos taken at one of our events or webinars, images or recordings made or captured by CCTV and other security measures at our facilities, interactions with our systems, and other specific details of an event, webinar, or conference you attended.
Device Data
When accessing our online services, our web servers automatically create logs of your visit. These typically include your IP address, access times, referring websites, pages visited, links and features used, content viewed or requested, browser or application type, language, and other similar information. When you use our services or interact with us through telecommunications networks, the telecommunications operator may transmit to DIVEO certain additional information, such as your mobile subscription number, as a standard part of this communication.
2.1 Sensitive Data
Unless we request it, we ask that you do not provide or post sensitive personal data (e.g. personal passcodes, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometric or genetic characteristics, criminal records, or trade union membership).
3 How We Use Personal Data
We use your personal data for legitimate business purposes as outlined in the summary below. Please select the section that best reflects your relationship with us.
3.1 Managing Our Business Relationships with Customers, Business Partners, and Suppliers
Implement due diligence checks on potential and existing customers, business partners, and suppliers, as well as background and suitability checks on individuals. Onboard new customers and suppliers, set up accounts, and manage accounts on an ongoing basis. Offer products and services to customers, provide customer service, and contact customers and suppliers for these purposes. Manage our business operations and improve the functionality of our products and services. Purpose: Implement due diligence checks on potential and existing customers, business partners, and suppliers, as well as background and suitability checks on individuals.
Categories of Personal Data: Identification data and contact data; role-based data; financial data; relationship history; also for background checks: professional experience; operational data; access data; relationship history.
Legal Basis: Legitimate interests, for example to comply with internal compliance policies or to assess an individual’s qualifications for a particular project. Legal obligations*, for example relating to anti-money laundering, fraud prevention, anti-corruption, sanctions and trade restrictions, or access to national infrastructure. Consent to conduct background checks when requested by end customers.
3.2 Improving and Developing Our Products, Services, and Ways of Working
Collaborating with you in your capacity as a professional for product development purposes, research programs, and industry-wide initiatives. Managing individuals’ participation in research to help develop DIVEO ARGENTINA S.A.’s products and services. Aggregating and/or anonymizing personal data to analyze our products, services, governance, and ways of working. Purpose: Collaborating with you in your capacity as a professional for product and/or service development purposes.
Examples of Processing Activities:
Contacting you to obtain information about your work experience, for example, in the context of the development of our products or services or those of our affiliates or business partners; working with you on events, publications, meetings, advisory panels, and research projects or programs; inviting you to take part in special programs, activities, events, promotions, marketing activities, or policy initiatives. Some may have additional rules that include information about how we will use and disclose your personal data.
Categories of Personal Data:
Identification data and contact data; role-based data; professional experience; access data; marketing and communications data; usage data; relationship history; user-generated content; visitor and event data.
Legal Basis: Legitimate interests and consent, for example, to use your name in publications.
3.3 Providing and Maintaining Our Website and Other Online Platforms, Applications, and Systems
Individual platforms, applications, and systems may have additional requirements for how we will use and disclose personal data, which will be provided at the time of use.
Improving and Developing Existing and New Websites
Providing assistance and responding to inquiries from website users, including requests to manage privacy rights. Protecting DIVEO ARGENTINA S.A. systems, networks, and information.
Purpose: Improving and developing existing and new websites.
Examples of Processing Activities:
Performing data analysis, for example, monitoring and analyzing website usage and leveraging data analytics to improve efficiency; developing our websites; examining ways to improve, repair, maintain, or modify our existing websites; identifying usage trends, for example, understanding which parts of our website generate the most interest among users.
Categories of Personal Data:
Usage data; user-generated content; device data.
Legal Basis:
Legitimate interests, such as developing our website and ensuring it functions properly.
3.4 Conducting Corporate Activities
Such as managing our legal and compliance obligations, managing media and investor relations, overseeing our corporate structure, and engaging with shareholders.
Ensuring and monitoring compliance with our policies and procedures and with applicable laws in the Argentine Republic. Enforcing legal rights and remedies, and defending against claims. Fulfilling our legal and compliance obligations, such as responding to legal requests and demands from regulatory bodies or other authorities in the jurisdictions where we operate.
Fraud prevention.
Interacting with the media and industry analysts. Engaging with legislators and local and regional decision-makers, advocacy groups, and policy advisors. Interacting with industry and business associations and similar stakeholder groups. Conducting shareholders’ meetings. Managing relationships with institutional investors. Facilitating mergers, acquisitions, and corporate restructurings.
Legal Basis:
Legitimate interests, such as responding to customers’ and employees’ concerns.
Legal obligations*, for example, related to financial transactions, such as record-keeping requirements and obligations concerning the conduct of investigations.
4 How We Share Your Personal Data
Your personal data will only be handled by authorized employees of DIVEO ARGENTINA S.A. who have the appropriate training to carry out this task. In order to distribute our products, manage our supply chains, and conduct other business activities, we also work with certain third parties who may process your personal data. These third parties and the purposes for which we share personal data with them are listed below:
4.1 Third-Party Disclosures
Professional advisors, consultants, and other authorized personnel.
Service providers.
Web hosting service providers.
Information technology and related infrastructure service providers.
Email delivery service providers.
Advertising networks.
Brand-authorized individuals.
Analytics providers.
Other companies and partners.
Regulatory bodies, law enforcement agencies, public, regulatory, and governmental authorities, courts or tribunals.
Purpose: All purposes described in this Privacy Notice.
4.2 Disclosures for Legal or Restructuring Reasons
We also disclose your personal data as required or appropriate, especially when we have a legal obligation or a legitimate interest to do so, as further explained below.
Compliance with applicable laws and regulations in the territory of the Argentine Republic.
More Information: This may include laws outside your country of residence, which could give rise to a legal obligation requiring us to process your personal data, including matters of civil and commercial law; criminal law; consumer law; corporate and tax law; regulatory matters; national, provincial, and municipal authorities; health and safety regulations; and incidents involving individuals on our premises.
5 Cookies and Similar Technologies
Our websites and other web-based applications store cookies in the visitor’s browser for various purposes:
Session Management:
Session cookies are used to maintain continuity of the user’s browsing within DIVEO ARGENTINA S.A. websites. These cookies are temporary and are deleted when the browser is closed. Their purpose is technical, allowing the user’s session to be remembered to avoid repeated authentication during the same visit.
User Preferences:
Persistent cookies are used to remember the user’s preferences for the display of our website and web applications. These cookies remain in the browser for a set period or until the user manually deletes them. Their purpose is to improve the user’s experience by customizing the website’s display on future visits.
The information collected via cookies is used exclusively for the technical purposes described above.
The websites of DIVEO ARGENTINA S.A. do not use third-party cookies for advertising or invasive tracking purposes without the user’s explicit consent.
6 How We Keep Protected Data Secure
We use reasonable organizational, technical, and administrative measures to protect personal data within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please notify us immediately.
7 How Long We Retain Your Data
We will retain your personal data for as long as is necessary to fulfill the purposes described in this Privacy Notice, unless a longer retention period is required or permitted by law, for example, to meet legal, regulatory, tax, accounting, or reporting requirements.
The criteria used to determine our retention periods are outlined in our retention policy and will vary depending on factors such as (i) the length of time we have an ongoing relationship with you and provide you with goods or services (for example, as long as you have an account with us); (ii) if there is a legal obligation (for example, we must retain transaction records for a certain period before we can delete them); or (iii) if retention is advisable in light of our legal position (such as applicable statutes of limitations, litigation, or regulatory investigations).
Retention Periods Based on Legal Obligations
Where we have a legal obligation or it is recommended under our legal position, in some circumstances we will retain certain personal data even after your account has been deleted and/or we no longer provide you with goods or services.
8 Third-Party Services
This Privacy Notice does not cover, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating a website or service to which our products or services link. The inclusion of a link to any such service through our services does not imply that we or our affiliates endorse the linked site or service.