Privacy Policy

1. Introduction and Commitment to Privacy

Batelco quick pay Financial Services S.A. ("Batelco quick pay," "we," "us," or "our") is deeply committed to protecting the privacy and security of our customers' personal and financial information. This Privacy Policy explains how we collect, use, disclose, and safeguard information obtained through our digital banking platform, mobile applications, and related services (collectively, the "Services").

This Privacy Policy applies to all individuals who access or use Batelco quick pay Services, including account holders, authorized users, and visitors to our website. By using Batelco quick pay Services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your information as described herein.

Batelco quick pay complies with the Argentine Personal Data Protection Law (Law No. 25,326), the General Data Protection Regulation (GDPR) for European users, and all applicable international data protection regulations. Our data protection practices have been independently audited and certified under ISO 27001 standards.

2. Information We Collect

2.1 Information You Provide Directly

When you register for a Batelco quick pay account or use our Services, you voluntarily provide us with the following categories of information:

• Identity Information: Full legal name, date of birth, nationality, government-issued identification numbers (DNI, passport, CUIL/CUIT), photographs for identity verification, and digital signatures.
• Contact Information: Email addresses, mobile and telephone numbers, physical mailing addresses, and preferred communication methods.
• Financial Information: Bank account details, credit and debit card information, transaction history, income sources, employment information, tax identification numbers, and financial statements.
• Business Information: For business accounts: company registration documents, tax certificates, beneficial ownership information, authorized signatories, and business financial records.
• Authentication Information: Username, password (stored in encrypted form), security questions and answers, and two-factor authentication settings.

2.2 Information Collected Automatically

When you access Batelco quick pay Services, we automatically collect certain technical and usage information:

• Device Information: IP address, browser type and version, operating system, device identifiers, screen resolution, and language preferences.
• Usage Data: Pages visited, time spent on each page, clickstream data, features accessed, search queries, and interaction patterns.
• Location Data: Geographic location derived from IP address or, with your consent, precise geolocation from mobile devices.
• Log Data: Access times, error logs, referring/exit pages, and system activity.
• Cookies and Tracking Technologies: Session identifiers, analytics cookies, preference cookies, and security tokens.

2.3 Information from Third-Party Sources

We may receive information about you from third-party sources including:

• Credit Bureaus: Credit reports, credit scores, and creditworthiness assessments from authorized credit reporting agencies.
• Identity Verification Services: Document authentication, address verification, and sanctions screening from specialized verification providers.
• Financial Institutions: Account verification and transaction data from banks where you hold external accounts.
• Public Databases: Publicly available information from government registries, corporate registries, and regulatory filings.

3. How We Use Your Information

Batelco quick pay processes your personal information for the following legitimate business purposes:

3.1 Account Management and Service Provision

• Creating, maintaining, and administering your Batelco quick pay account
• Processing transactions, transfers, and payment instructions
• Providing customer support and responding to inquiries
• Sending transactional communications including confirmations, alerts, and statements
• Managing account authentication and security

3.2 Regulatory Compliance and Legal Obligations

• Verifying your identity in accordance with Know Your Customer (KYC) requirements
• Conducting Anti-Money Laundering (AML) screening and monitoring
• Detecting and preventing fraud, financial crimes, and unauthorized transactions
• Complying with court orders, subpoenas, and regulatory investigations
• Maintaining records as required by banking regulations
• Reporting suspicious activity to appropriate authorities

3.3 Risk Management and Security

• Assessing creditworthiness and managing credit risk
• Detecting unusual account activity and potential security threats
• Preventing unauthorized access and cyber attacks
• Monitoring system integrity and investigating security incidents
• Conducting internal audits and compliance reviews

3.4 Service Improvement and Development

• Analyzing usage patterns to enhance user experience
• Developing new features and services based on customer needs
• Conducting market research and customer satisfaction surveys
• Troubleshooting technical issues and optimizing platform performance

3.5 Marketing and Communications (with your consent)

• Sending promotional materials about Batelco quick pay products and services
• Providing personalized product recommendations
• Notifying you of special offers, updates, and new features
• Conducting targeted advertising campaigns

You may opt out of marketing communications at any time by clicking "unsubscribe" in promotional emails or adjusting your communication preferences in account settings.

4. Information Sharing and Disclosure

Batelco quick pay does not sell, rent, or trade your personal information to third parties for their marketing purposes. We share your information only in the following limited circumstances:

4.1 Service Providers

We engage trusted third-party service providers to perform functions on our behalf, including payment processing, fraud detection, identity verification, data analytics, cloud hosting, customer support, and marketing services. These providers have access to your information only to perform specific tasks and are contractually obligated to maintain confidentiality and security.

4.2 Financial Institution Partners

To facilitate transactions, we share necessary information with correspondent banks, payment networks (SWIFT, ACH), and card associations (Visa, Mastercard). Information shared is limited to what is required to complete the requested transaction.

4.3 Regulatory and Legal Requirements

We disclose information when required by law, including responses to court orders, subpoenas, regulatory inquiries, and law enforcement requests. We may also disclose information to prevent fraud, protect Batelco quick pay's rights and property, or protect public safety.

4.4 Business Transfers

In the event of a merger, acquisition, bankruptcy, or sale of assets, your information may be transferred to the successor entity. You will be notified of any such change and your continued use of Services constitutes consent to the transfer.

4.5 With Your Consent

We may share information with third parties when you explicitly provide consent, such as authorizing account aggregation services or linking external financial applications.

5. Data Security Measures

Batelco quick pay employs comprehensive technical and organizational measures to protect your information against unauthorized access, alteration, disclosure, or destruction:

• Encryption: All data in transit is protected using TLS 1.3 with 256-bit encryption. Sensitive data at rest is encrypted using AES-256 encryption algorithms.
• Access Controls: Role-based access controls limit employee access to personal information on a need-to-know basis. All access is logged and monitored.
• Network Security: Multi-layered firewalls, intrusion detection systems, and DDoS protection safeguard our infrastructure.
• Physical Security: Data centers employ 24/7 security, biometric access controls, and environmental monitoring.
• Security Audits: Regular penetration testing, vulnerability assessments, and third-party security audits validate our security posture.
• Incident Response: Comprehensive incident response procedures enable rapid detection and remediation of security events.
• Employee Training: All employees undergo mandatory security and privacy training and sign confidentiality agreements.

While we implement industry-leading security measures, no system is completely impenetrable. You play a critical role in protecting your account by maintaining secure passwords, enabling two-factor authentication, and promptly reporting suspicious activity.

6. Data Retention

Batelco quick pay retains your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy and to comply with legal obligations:

• Active Accounts: Information is retained throughout the duration of your account relationship.
• Closed Accounts: After account closure, we retain information for a minimum of 10 years to comply with banking regulations, tax laws, and potential legal claims.
• Transaction Records: Financial transaction records are retained for 10 years in accordance with Argentine banking law.
• Communications: Customer service interactions and correspondence are retained for 5 years for quality assurance and dispute resolution.
• Marketing Data: If you opt out of marketing communications, we retain minimal information to honor your opt-out preference.

Data no longer required for legitimate business or legal purposes is securely deleted or anonymized in accordance with our data retention schedule.

7. Your Privacy Rights

You have the following rights regarding your personal information:

• Right to Access: Request a copy of the personal information we hold about you.
• Right to Rectification: Request correction of inaccurate or incomplete information.
• Right to Erasure: Request deletion of your information, subject to legal retention requirements.
• Right to Restriction: Request limitation of processing under certain circumstances.
• Right to Data Portability: Receive your information in a structured, machine-readable format.
• Right to Object: Object to processing based on legitimate interests or for direct marketing purposes.
• Right to Withdraw Consent: Withdraw previously given consent at any time.

To exercise these rights, contact our Data Protection Officer at:

Email: privacy@baetlco.com
Phone: +54 11 4567-8902
Mail: Data Protection Officer, Batelco quick pay Financial Services S.A., Av. Corrientes 1234, Piso 15, Buenos Aires, C1043, Argentina

We will respond to your request within 30 days. If we cannot honor your request, we will explain the reason in accordance with applicable law.

8. Cookies and Tracking Technologies

Batelco quick pay uses cookies and similar technologies to enhance user experience, analyze usage patterns, and deliver personalized content:

• Essential Cookies: Required for platform functionality including authentication and security. These cannot be disabled.
• Analytics Cookies: Help us understand how visitors interact with our website to improve performance.
• Preference Cookies: Remember your settings and preferences for future visits.
• Marketing Cookies: Track your activity across websites to deliver relevant advertisements.

You can manage cookie preferences through your browser settings. Disabling certain cookies may impact functionality. For detailed information, see our Cookie Policy.

9. Third-Party Links

Batelco quick pay Services may contain links to third-party websites and services not operated by us. This Privacy Policy applies only to information collected by Batelco quick pay. We are not responsible for the privacy practices of external sites and encourage you to review their privacy policies before providing any personal information.

10. Children's Privacy

Batelco quick pay Services are intended for individuals 18 years of age and older. We do not knowingly collect information from minors. If we become aware that we have inadvertently collected information from a child, we will take steps to delete such information promptly. Parents or guardians who believe their child has provided information to Batelco quick pay should contact privacy@baetlco.com immediately.

11. Changes to This Privacy Policy

Batelco quick pay reserves the right to modify this Privacy Policy at any time to reflect changes in our practices, technology, legal requirements, or other factors. Material changes will be communicated via email and prominent notice on the Batelco quick pay platform at least 30 days before the effective date. Your continued use of Services after changes take effect constitutes acceptance of the updated Privacy Policy.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information. The "Effective Date" at the top of this policy indicates when it was last updated.

12. Contact Information

For questions, concerns, or requests regarding this Privacy Policy or Batelco quick pay's data practices, please contact:

Data Protection Officer
Batelco quick pay Financial Services S.A.
Av. Corrientes 1234, Piso 15
Buenos Aires, C1043, Argentina
Email: privacy@baetlco.com
Phone: +54 11 4567-8902

Regulatory Authority: If you believe your data protection rights have been violated, you may file a complaint with the Argentine Data Protection Authority (Agencia de Acceso a la Información Pública) at www.argentina.gob.ar/aaip