READ THIS PRIVACY POLICY CAREFULLY BEFORE ACCESSING AND/OR USING THE PLATFORM AND/OR THE SERVICE.
This document (hereinafter, the "Privacy Policy") aims to inform the Users of KEYNUA INC. (hereinafter, "KEYNUA"), a company located at 929 SW 122nd Ave, Miami, FL 33184, United States, about the use and processing of personal information (hereinafter, "Personal Data") collected or generated through visits to the KEYNUA website and/or platform (hereinafter, the "Platform") as well as the Personal Data that the User voluntarily provides and/or supplies to KEYNUA.
KEYNUA reserves the right to modify this Privacy Policy in order to adapt it to the applicable legislative and jurisprudential novelties.
KEYNUA declares that it respects the principles of legality, consent, purpose, proportionality, quality, security, resource availability, and an appropriate level of protection provided for in the Personal Data Protection Regulations.
KEYNUA is the legal entity responsible for the Personal Data provided by Users or collected from other sources permitted by applicable laws. This Personal Data will be stored in KEYNUA's Personal Data Bank.
Users may provide their Personal Data to KEYNUA in various ways, including by providing Personal Data through registration on the KEYNUA Platform, or redirection from third-party platforms with which KEYNUA has a commercial relationship.
In any case, if the User agrees to contract any of the services offered by KEYNUA or uses the Platform in accordance with the Terms and Conditions, the provided Personal Data will be stored in KEYNUA's Personal Data Bank, with KEYNUA being the owner of this bank, according to the definition established in the Personal Data Protection Law.
KEYNUA collects Personal Data from various public and private sources, in accordance with what is allowed by the Personal Data Protection Regulations. In this way, KEYNUA collects Personal Data from various sources of information, including but not limited to:
Registo Nacional de Identificación y Estatus Ciivil (RENIEC), Registraduria Nacional de Estado Civil de Colombia (REGISTRADURIA), Dirección General de Registro Civil de Mexico, and Secretaria Nacional de Transito (SENATRAN):
Information collected through the use of the platform/website. Information voluntarily provided by the User through any means, physical or electronic (e.g., emails, mobile applications, phone calls, video calls, photographs, text messages (SMS) or instant messages, etc.).
Information voluntarily provided by the User through redirection from third-party platforms with which KEYNUA has a commercial relationship. Credit Bureaus such as Infocorp, Equifax, Sentinel, SBS, Experian (Datacrédito), Xchange, among others. Social networks (Facebook, Instagram, Twitter, among others). Files with information about visited websites, as well as the search engines used. Publicly accessible information.
KEYNUA will collect, store, and process Personal Data for the preparation, conclusion, and execution of the contractual relationship to which the User and KEYNUA are parties. That is, for the provision of the services referred to in the KEYNUA Terms and Conditions, which include the Identity Registration service and others, as accepted by the User (hereinafter, the "KEYNUA Services").
According to the Personal Data Protection Regulations, the collection, storage, and processing of Personal Data for these purposes do not require the User's consent.
Likewise, KEYNUA will collect Personal Data contained or intended to be contained in publicly accessible sources, which do not require the User's consent, in accordance with the Personal Data Protection Regulations.
The Personal Data mentioned in the paragraphs above are important and necessary for KEYNUA to provide the KEYNUA Services to the User. Therefore, if the User refuses to provide the information requested by KEYNUA, as applicable, KEYNUA reserves the right not to initiate the contractual relationship and/or terminate the contractual relationship in accordance with its Terms and Conditions and applicable laws.
On the other hand, KEYNUA may also collect, store, and process Personal Data for purposes other than the preparation, conclusion, and execution of the contractual relationship or the Services provided by KEYNUA, without the participation of third parties, including:
For the offering of additional services and/or products of Keynua within the Keynua platform. In all these cases, KEYNUA must obtain the prior consent of the respective User. KEYNUA undertakes to inform and request the User's consent in a timely manner and in compliance with the provisions of the Personal Data Protection Regulations.
Additionally, the KEYNUA platform collects information through the use of cookies in order to improve the User's experience, as well as to better understand how the User interacts with the platform and the KEYNUA Services. Since the information collected through cookies may be considered as Personal Data, KEYNUA will also request Users' consent for the use of cookies.
In case the User refuses to provide information or consent for the processing of Personal Data for the aforementioned external purposes referred to in the paragraphs above, the User may still use the Platform and/or access the services offered by KEYNUA.
KEYNUA may assign a portion or all of the processing of your personal data to other natural and/or legal persons, referred to as "Data Processors," in accordance with the Personal Data Protection Regulations. Currently, there are no Data Processors for KEYNUA.
KEYNUA may carry out national or international transfer of Personal Data to natural and/or legal persons other than the Data Processors. In these cases, the transfer of Personal Data does not arise for specific assignment reasons, and there is no contract or agreement for the processing of Personal Data (e.g., to affiliated companies). The possible recipients of the Personal Data are as follows:
| Recipient Name | Location | Purpose |
|---|---|---|
| AWS | USA | Processing and storage of Personal Data necessary to provide KEYNUA Services |
| AZURE | USA | Processing of Personal Data necessary to provide KEYNUA Services |
As the owner of your Personal Data, the User has the right to access their Personal Data located in the Personal Data Bank owned by KEYNUA. Likewise, the User has the right to know the characteristics of the processing of their data, rectify them if they are inaccurate or incomplete, request their deletion or cancellation when the Personal Data collected are no longer necessary or relevant for the purposes previously informed, or object to their processing for specific purposes.
To exercise these rights and others recognized to the User by the Personal Data Protection Regulations, the User must request it by sending a communication to the email address misdatos@keynua.com.
This request must contain the following information: names and surnames; address or another address, which may be electronic, to receive the response; specific request and supporting documents, if applicable; date and signature of the applicant.
Once KEYNUA receives the request, a receipt will be issued to the User, which will be attached to their file.
The exercise of the rights is free, and KEYNUA must respond to the request within the established legal period with the justification of its decision. In this regard, the maximum periods for sending the response to the request are as follows:
In said response, KEYNUA will inform the User of the maximum implementation period of the measure, considering the nature of the request. If the User believes that they have not been adequately served or because their request has been denied, they can file a complaint with the National Authority for Personal Data Protection.
The User has the right to revoke their consent for the processing of Personal Data. To do this, they can revoke their consent at any time and without the need for prior justification, using any physical or electronic means available. KEYNUA guarantees the adequacy of the processing of Personal Data due to the revocation of consent within a reasonable time, not exceeding five (5) business days.
The provided Personal Data will be kept for the duration of the contractual relationship or until the User requests cancellation. In any case, after the mentioned contractual relationship ends, KEYNUA will delete the Personal Data within a maximum period of ten (10) years, and this period may be extended at KEYNUA's discretion if it foresees that it may be held liable in any way due to the contractual relationship or other obligations of legal document and information retention, as well as for historical, statistical, or scientific reasons, and when a disassociation or anonymization procedure is used.
KEYNUA confirms that it has adopted appropriate security levels for the protection of information, respecting the measures applicable to each category and type of processing of the Personal Data Bank, following what is established in the Information Security Directive managed by the Personal Data Banks.
The Platform uses generally accepted information security techniques in the industry, such as firewalls, access control procedures, and cryptographic mechanisms, all for the purpose of preventing unauthorized access to the data. To achieve these purposes, the User agrees that the provider obtains data for the authentication of access controls.
Any hiring process or that involves the introduction of sensitive Personal Data will always be transmitted through a secure communication protocol, in such a way that no third party has access to the information transmitted electronically.
When it is strictly necessary to process Personal Data through human means, KEYNUA undertakes to use appropriate segmentation to avoid unnecessary exposure of such data.
Any total or partial change and/or modification to this Privacy Policy will be announced through any of the following means: published on the website (at www.keynua.com or applications), Platform, a message sent to your email or mobile phone, a message disclosed through any electronic means used to conduct operations with KEYNUA, or through a written communication sent to the User's address."