1. Objective
The purpose of this personal data privacy policy (hereinafter, the “Privacy Policy“) is to inform how REAL APP USA LLC, domiciled at 6355 NW 36 St. Ste 407 Virginia Gardens, FL 33166, processes the personal data it collects through its REAL APP USA LLC Application (hereinafter, the “Application“). This data is collected through the registration and use of the Application, the filling out of virtual forms and through the different spaces that the Application in which must provide personal data virtually.
To this end, we will refer to the “Data Subject” as the person whose data will be collected and processed in accordance with the terms set forth in the Privacy Policy. Only personal data for which due consent has been obtained are processed, unless the exceptions set forth in the Organic Law on the Protection of Personal Data (the “Law“) are applicable.
The processing of personal data derived from this Privacy Policy is legitimate and lawful by virtue of obtaining the consent of the Data Subject and its origin comes directly from him/her.
2. Legal Grounds
This Privacy Policy is governed by and construed in accordance with the laws of the State of Florida, USA.
3. Conservation period
The personal data provided by the Data Subject will be kept as long as it is necessary to fulfill the purpose for which it was collected and/or as long as the Data Subject does not revoke his/her consent, as regulated by the Law and applicable regulations.
4. Personal Data Bases
The personal data provided by the Data Subject will be stored in the personal database called “USUARIOS REAL APP USA LLC “, duly registered in the National Registry of Personal Data Protection.
5. Purpose of data processing
Through the registration and use of the Application, REAL APP USA LLC collects personal data, such as names, surnames, telephone numbers, emails and geolocation data.
These personal data provided by the Data Subject will be necessary to provide the Real App USA LLC application’s own authorizations.
REAL APP USA LLC may perform systematic evaluations of the personal aspects and behaviors of its users within the Application, such as profiling, trends and consumption habits, seeking a properly dissociated or at least anonymized treatment of these data, always taking into account the security measures, principles and limitations for this purpose, provided by law.
If the Data Subject does not provide this data, or provides erroneous or inaccurate information, REAL APP USA LLC will not be able to perform the purpose described above and the quality and form of execution of the services provided by REAL APP USA LLC is compromised.
Additionally, with the valid consent of the Data Subject, REAL APP USA LLC may contact you by [phone calls, SMS, emails, or other equivalent means], to send you advertisements, promotions, discount opportunities, general information. If you do not accept the additional processing of your personal data, this will not affect the access and use of the Application and the products and services provided therein.
6. Transfer and recipients
The Data Subject is informed that his or her personal data is not shared with third parties.
7. Security Measures
REAL APP USA LLC adopts the necessary security measures to ensure the protection of the Data Subject’s information to avoid its alteration, loss, treatment and/or unauthorized access, taking into consideration the nature of the information and the risks to which they are exposed. In order to protect the personal data of the Data Subject, REAL APP USA LLC strictly complies with the provisions of the Law and its Regulations.
8. Communications and further processing
REAL APP USA LLC undertakes not to disclose or share the personal data provided by the Data Subject without his/her valid consent, except for the following cases:
- Requests for information from administrative or judicial authorities by virtue of requests and orders in the exercise of their functions and the scope of their powers under the Law.
- Requests from administrative authorities for the purpose of further processing data for historical, statistical or scientific purposes, provided that such data is duly disassociated or at least anonymized.
- In general requests for information pursuant to relevant legal provisions.
The Data Subject may revoke his/her consent to this type of communications at any time, without the need for any justification.
9. Use of cookies in the Application
The Application does not use cookies and therefore no personal data is processed in this way.
10. Exercise of rights
The Data Subject may exercise the rights of access, deletion, rectification and updating, opposition, cancellation, limitation of processing and not to be subject to a decision based solely on automated assessments and other rights enshrined in the regulation, by means of a written request that may be sent to: [email protected] and including, at least, the following information:
- The name and email address of the Data Subject or any other means to receive responses.
- A document proving the identity of the applicant and, if applicable, that of his/her representative with the respective authorization.
- The telephone number registered in the application.
- The clear and precise description of the personal data with respect to which the Data Subject seeks to exercise any of the rights and the specific request.
Notwithstanding the foregoing, REAL APP USA LLC may retain certain information of the Data Subject requesting the cancellation, to serve as evidence in the event of a claim against REAL APP USA LLC, as well as to protect the security or functionality of its operations or to service your account.
The duration of such retention shall not exceed the statutory limitation period of such liabilities. If the information on logical interactions of the user with the Application cannot be eliminated by technical limitations, these data will be anonymized so that they cannot serve to identify or make identifiable the Data Subject.
If the Data Subject considers that his/her claims have not been addressed in the exercise of his/her rights, the Data Subject may file a claim before the National Authority for the Protection of Personal Data through the channels that this institution has enabled.
11. Portability of personal data
At the express request of the Data Subject, REAL APP USA LLC may return the personal data collected from the Data Subject in a compatible, updated, structured, common, interoperable and machine-readable format, preserving its characteristics, or deliver it to another data controller defined by the Data Subject.
REAL APP USA LLC will carry out this transfer or communication in an economically and financially efficient, expeditious and unhindered manner.
There will be no portability of the Data Subject’s data in the case of inferred, derived, created, generated information or information obtained from the analysis or processing carried out by REAL APP USA LLC.
12. Revocation of consent
The Data Subject may revoke the authorization and consent granted to REAL APP USA LLC for the processing of his/her personal data by submitting a written request to the above-mentioned e-mail address.
13. Modifications to the Privacy Policy
REAL APP USA LLC expressly reserves the right to modify, update or supplement this Privacy Policy at any time. Any modification, update or addition to this policy will be immediately communicated through the Application.
14. Applicable law and dispute resolution
These Terms and Conditions are governed by and construed in accordance with the laws of the State of Florida, USA.