This document contains:

  1. Terms and Conditions of Use and Privacy Policies for the use of the Conciliac Website and Non-Disclosure Policies for the arrangement of a Demo
  2. Privacy Policy of the Site and of the Conciliac Technology.
  3. Commitment to comply with applicable regulations on prevention of corruption, terrorism, money laundering, human trafficking and/or smuggling of persons.

 

I. Terms and Conditions of Use and Privacy Policies for the use of the Conciliac Website and Non-Disclosure Policies for the arrangement of a Demo.
Last update: 14 December 2023

This document governs the use of the Website (as such term is defined below) of Conciliac S.A., CUIT (Individual Taxpayer Identification Number) 30-71230611-0, a company organized under the laws of Argentina, located at Mariscal Antonio José de Sucre 1530, Libérateur Tower, 9th Floor, Office 4 (C1428DUS), City of Buenos Aires, Argentina, (hereinafter, ¨Conciliac”)
Conciliac makes available to its users (the “Users”) these terms and conditions (¨Terms and Conditions¨) describing the rights and liabilities of the Users of Conciliac regarding Conciliac Web Site (the “Site” or “the Website”).
Conciliac, through its Technology (hereinafter also, the “Application”, “the Software”, “Conciliac EDM”, “Products”,” and/or “Services” and/or “the Application”, interchangeably), provides expert tools for the automation of data management, and offers a simple solution to a complex task, making data management processes of all kinds easier, faster and more straightforward.
In this regard, Conciliac creates, designs, develops and licenses products and services created to deal in a comprehensive manner with the problems of reconciliation of information of a company. Its main strength is that it allows you to solve from the simpler reconcilements to the most complex cases that are impracticable for a human being or that require unlimited working hours.
The Technology of Conciliac may be used for information reconciliation processes of any type, either financial or not. As an example, the most frequent reconcilements are: banks, credit and debit cards, payments to suppliers, withholdings and applicable taxes, clients´ collections, corporate cards, reconciliations of closing balance, current accounts, crossovers on databases, inventory control, and salaries, among others.
Users are herein informed that the acquisition and use of the Technology of Conciliac may be subject to the particular terms and conditions such as, for example, terms and conditions of contracting (the “Agreement”) and terms and conditions of use of the Technology (hereinafter, all of them together the ¨Particular Terms¨ or ¨PT¨) that, as the case may be, substitute, complement and/or modify these Terms and Conditions (hereinafter the ¨T&C¨ or ¨Terms and Conditions¨, interchangeably) and its Privacy Policies (¨PP¨).
By accessing, using and/or completing any form available on the Technology or theSite, Users acknowledge that they have read and understood the following T&Cs, or the applicable PTs or the PPs, and agree to be bound by them and, furthermore, to comply with all the applicable laws and regulations regarding the use of the Technology and theSite.
IF YOU DO NOT AGREE WITH THESE T&CS, OR THE APPLICABLE TPS OR THE PPS, DO NOT ACCESS, USE OR USE THE SITE OR THE TECHNOLOGY IN ANY WAY.
Both the T&C, the PTs and PPs may be amended from time to time, all of which will be notified to the Users, and, if applicable, request their consent for the continued use of the Technology and the Site, as appropriate.

1. Access to and Use of the Site

Notwithstanding the T&C or PTs to which the Products and/or Services offered by Conciliac are subject to, each User shall be responsible for itself and will make the entity and/or legal person for which it works or renders services responsible of all the activities that take place during the access and use of the Site by the User. Conciliac is not responsible for any loss or damage generated as a result of inaccurate, unreliable or incomplete information provided by the User to Conciliac.
You understand and accept that you and the entity and/or legal person for which you work or render services, are the only responsible for the content generated by yourself and for the information you entered in our digital environments, such as forms available in our Web Site. In this respect, you release Conciliacfrom any claim made by the user or by third parties related to the information entered.
As a User who accepts these T&Cs, when doing so, in the name and on behalf of an entity or legal person for which it works or provides services, declares under oath that it has sufficient authorization and/or powers to accept the T&Cs and the PPs; being responsible for the obligations set forth herein for itself and for such entity or legal person and for any damage caused by the falsehood and/or inaccuracy contained in this statement and being obliged to hold Conciliac harmless for such damages.

In particular, Users undertake to:

  • Not to use the Web Site or the resources available in the Web Site for illicit purposes or for purposes not authorized by Conciliac;
  • Not to use any technology, process or access method that allows the recovery, indexingand/or removal any information from the Web Site in a non-authorized manner.
  • Not to interfere or interrupt the operation of the Web Site or the servers or networks that host the Web Site, and not to infringe the laws or regulations or requirements, proceedings, policies or regulations of said servers or networks.
  • Not to create, charge, validate, transmit, distribute, show or make available through or in connection with Conciliac, any content, text, or information that may be considered abusive, threatening, obscene, defamatory, slanderous or discriminatory for race, sexual, age or gender reasons, or for politic or religious matters or information of any type that may be considered unpleasant, harmful, improper or offensive to third parties.
  • Not to create, charge, validate, transmit, distribute, show or make available through or in connection with Conciliac any content, including content generated by the User, that may adversely affect a right of a third party, including intellectual property, privacy or confidentiality rights, or that can include any illegal content.
  • Not to pretend to be someone else or another entity and not to provide misinformation in the forms completed in the Web Site, either directly or indirectly. Not to misrepresent or distort its affiliation with any person or affiliation to an entity, not to express or publish false or inaccurate information of yourself, of third parties or of Conciliac.
  • Not to carry out actions that force or may force, at our discretion, an elevated charge in our infrastructure of digital platforms.
  • Not to avoid physical and computer security measures that Conciliac arranges in order to prevent or restrict the access to the Web Site.
  • Not to copy, amend, alter, adapt, make available, translate, make reverse engineer, decompile or disassemble, any part of the Web Site, its source code, not to create a browser, frame (framing) without express written authorization of Conciliac.
  • Not to reproduce, duplicate, copy, sale, resale, distribute, or explore, in whole or in part, the Web Site, tools or contents of Conciliac without the express and written consent of Conciliac.
  • Not to infringe or fail to comply with the Term and Conditions and/or Particular Terms, if any, and/or Privacy Policies; or other agreements with Conciliac.
  • Use the Web Site according to these T&C, the PTs and their PPs.

1.2. Price of the Products and Services.
The use of the Web Site is completely free for the User. Both filling out forms to arrange a Demo of the Application (as defined below), and the virtual Demo in itself shall be free for the User.
The acquisition of the Application and/or of the products and services associated thereto by the Users, shall be subject to the respective T&C or PT and to the prices informed by Conciliac to the client in due course.

2. Liability for the Contents

2.1. Liability for the Information included in the Site.
Conciliac shall not be liable for any damages that the use of the information provided in the Web Site may cause. Conciliac does not warrant the truthfulness or validity of that information, or that said information has not been altered after its incorporation in the Web Site. In case the User feels aggrieved or adversely affected by this information, it shall direct its attention exclusively against the information provider. Besides, Conciliac shall not be liable for the inviolability of the data transmission sent through the public telecommunications network or any other telematics media.
2.2. Liability for links included in the Web Site.
Conciliac may provide links, websites or third-party services through the Web Site. The User agrees and acknowledges that Conciliac does not control and is not liablefor third-partywebsites which links are included in the Web Site, or for the related products and services. The User agrees and acknowledges that Conciliac does not control, guarantee, monitor or take the responsibility for the quality, availability, security, characteristics or other elements of the information, contents, advertisements, services, products, files or materials available in third-party websites. The User agrees and acknowledges that Conciliac will not be responsible or liable, directly or indirectly, for the damages or losses that the User may suffer in relation to the websites of third parties.If the User decides to access any of the independent third-party websites which links are included in the Web Site, it will be at his own risk. Conciliac advises the User to take due care when operating third-party websites and to pay special attention to the terms and conditions and privacy policies of said third parties before starting any download, giving personal information or conducting any transaction with third parties.
2.3. Liability for downloads.
The User is solely liable for the verification of the non-existence of any type of virus, malware or corrupted files in the programs and materials that the User downloads from the Web Site. In no event shall Conciliac be liable for the damages caused by destructive elements that may have been introduced by third parties to the downloadable files provided by Conciliac on the Site. The files are provided without express or implied warranties of any kind, including warranties of merchantability, property, non-infringement of intellectual property or fitness for a certain purpose. In no event shall Conciliac be held liable for the damages (including without limitation, loss of profit, business interruption or loss of information) arising out of the use or inability to use the files, even if Conciliac had been previously advised of the possibility of such damages. Conciliac does not warrant the accuracy or completeness of the information, including texts, graphics, links and related elements included in the files. The files described can be modified at any time by Conciliac, but makes not commitment to update them.

3. Ownership of the Site

3.1. The Web Site, downloadable contents and files, the Technology, and the products and services associated therewith, the trademarks and the logo of Conciliac and all the Intellectual Property rights related thereto, are the property and/or license of Conciliac and are subject to the applicable copyrights and other rights of intellectual property by virtue of the applicable laws and the international agreements.
3.2. Intellectual Property of third parties
Further to what has been stated in this section, Conciliac states that in the Web Site, the user may display software, information and other contents owned by third parties, being these third parties the authors thereof and the exclusive owners of all these material. The names, trademarks and/or logos that may be exhibited are the property of those individuals and/or legal persons that would have registered them on their behalf in the corresponding registrations.
3.3. License of Use of the Web Site.
Conciliac grants to the Usersa non-transferable, free, non-exclusive and revocable use license to use the Web Site and download the files made available to them on the Web Site; unless there are other T&C or PT establishing a license with a different scope. The retransmission, amendment or publication of any content or material of the Web Site is prohibited without the prior written consent of Conciliac.

4. Updates of the Site

4.1. Updates of the Site
Conciliac reserves the right, at its sole discretion, to implement new elements as part or complement of the Web Site and/or the products and services it offers, including changes that may affect the prior mode of operation of the Web Site.

5. Non-Disclosure Policies for the arrangement of Demos

5.1 Proceeding to schedule a Demo.In order to arrange a test of the operation of the Technology with Conciliac (hereinafter, the ¨Demo¨), the User shall complete the corresponding contact form (hereinafter the ¨Form¨) with the information required. The User shall be responsible for the truthfulness, accuracy and update of said information, releasing Conciliac from any liability for the damages that the misrepresentation, inaccuracy and/or outdating of the information offered may cause. The User completing the form in the name and on behalf of an entity and/or legal person, when doing so, declares under oath that he is authorized and/or has sufficient powers to complete it; taking responsibility for the duty of non-disclosure established herein for himself and for his represented party and for any damage that the misrepresentation and/or inaccuracy included in this statement may cause and committing himself to hold Conciliac harmless for said damages.
5.2. After completing the Form, Conciliac shall contact the User through any of the means of contact that the User has provided in the Form to coordinate the arrangement of the Demo.
5.3. Non-disclosure Policies The User declares and acknowledges for himself and his representative, that by virtue of the Demo, Conciliac may disclose ¨Confidential Information¨, this being deemed to be any information in any way related with the Technology, Software, products and services of Conciliac, including but not limited to: (i) technical expertise (know-how), formulas, statistics, algorithms, processes, systems, devices, designs, products design, products solutions, solution criteria, prototypes, information regarding the development of solutions, concepts, implementation methodologies, industrial solutions, the Demo in itself, samples, forms, testing methods, technical data or specifications, techniques, methods, drafts, compilations, data bases, clients lists, business methods, marketing methods, marketing, promotion and merchandising reports, business, production, development and services plans, promotional and advertising strategies, information regarding prices, financial models and plans, inventions, long-term plans, data and activities regarding research and development, data and profiles of users or consumers, ideas, computer programs, graphics, drawings, sketches, photographs, models and other information of Conciliac which is by nature confidential; (ii) industrial secrets, commercial secrets, transactions, analysis, studies, projections, financial projections, business, technical or financial information, intermediary information, information regarding investors and members of the equipment of Conciliac, the contract negotiation and the financial agreements of Conciliac; and (iii) information typical of the activity of Conciliac that is not readily available to a competitor of Conciliac in the ordinary course of business, legal documents, contracts, terms and conditions, licenses, correspondence, any form of analytical capacity, process model, business model and/or modeling that, directly or indirectly, results from, relates to, or in any manner involves or uses any part of the Technology, Products and solutions of Conciliac.
The User undertakes, for himself and his representative, to maintain the Confidential Information in the strictest confidentiality possible and to take all the proper and necessary security measures to keep the confidentiality of the Confidential Information.
Furthermore, the User, for himself and his representative, understands that it may only use the Demo, Technology and Confidential Information of Conciliac for the sole purpose of its own internal evaluation and will only be allowed to share the Confidential Information with those dependents or people related to the User, or his representative, that need to know the information in relation to their activities and provided that they are bound by secrecy. In connection with this point, the User, for himself and his representative, understands that it is expressly prohibitedto conduct activities of reverse engineering, decompile or disassemble said Demo, Technology and/or any other software or Know-how that is transmitted pursuant to the Demo as well to use the Confidential Information for the benefit of a third party and/or for a different purpose than that agreed upon.
The User, for himself and his representative, may not: (a) disclose, directly or indirectly, in whole or in part, to any third party, any Confidential Information received from Conciliacin the context of the arrangement of the Demo; (b) use any Confidential Information for the own use of the User, or his representative or for any purpose different to its internal evaluation; (c) sell, make available, allow the use of, use or disclose the Confidential Information to benefit any third party or in any form that grants the User, or his representative, the ability to obtain in any way business advantages or any other type of benefits; (d) take all or part of the Confidential Information with it; € transmit the Confidential Information to other entities or individuals, without the prior written consent of Conciliac.
The User, and the represented party, must: (a) immediately notify Conciliac in case of having grounds for suspicion or becoming aware that the security of the Confidential Information has been or may be put at risk in any manner and fully cooperate in any defense of the Ownership Rights over the Confidential Information of Conciliac.
5.4. The User that accesses the Demo recognizes and accepts, for himself and his representative, that the disclosure or delivery of Confidential Information does not grant, neither expressed or implied, authorization, permission or license (express or implied) regarding trade secrets, trademarks, patents, copyrights or any other right of industrial or intellectual property of Conciliac. Furthermore, the User recognizes that any information (confidential or not) received from Conciliac, shall remain as exclusive property of Conciliac.
5.6. The infringement to the onfidentiality duty stated herein on the part of the User, by the the represented party and/or any of his dependents, shall empower Conciliac to exercise the legal actions that may legally correspond.
5.7. The User accepts and recognizes, for himself and his representative, that it is expressly prohibited to copy, photograph, film, or record the Demo or the Technology.
5.8. The User represents and warrants that any dependent and/or any other person related to himself and/or his representative, that accesses to the Confidential Information of Conciliac by virtue of the arrangement of the Demo:

  1. shall be notified of the confidential nature of the Confidential Information, together with the copying, photographing, filming or recording restrictions of the Demo, as well as of the use and disclosure restrictions; and
  2. shall be bound to comply with all the confidentiality duties and security measures regarding the Confidential Information stated in the Terms and Conditions as well as with all the applicable provisions of this agreement.

6. Limitation of liability with relation to the functioning of the Site.

The Web Site, including hereinafter its contents, downloadable files, contact forms and information disclosed therein, are available as they are (¨as is¨) and subject to availability, without guarantees of any type, express or implied.
The availability and operation of the Web Site may depend on third parties such as communication networks, software, hardware, servers and service providers of the Users of Conciliac. Conciliac neither guarantees not assures that the Web Site will operate all the time and without interruption, or that is free of mistakes. Conciliac is not responsible for any damage, injury, loss of profit, consequential damage or loss in the equipment or business of the User, not in the person of the User and/or its authorized persons and/or third parties, resulting from failures in the system, the technology, the Web Site, the servers or the Internet.
You expressly recognize and accept that the access and use of the Web Site are at your sole risk. Conciliac does not guarantee that
(i) the Web Site will comply with all your requirements,
(ii) the access to the Web Site will be uninterrupted, timely, safe or free from mistakes, or
(iii) that all the mistakes in the Web Site will be corrected or will be in a timely manner, even when Conciliac has been notified thereof.
Conciliac informs to the User that any material downloaded or obtained through the Web Site is at its own expense and risk and that the User will be the sole responsible for any damage to the equipment or loss of data resulting from the download and/or use of said material; and furthermore, that no advice or information, oral or written, that the User obtains from Conciliac or through the Web Site shall create any guarantee different from the ones set forth in these Terms and Conditions.
Consequently, Conciliac shall not be responsible for any type of damages or losses for the User or third parties, resulting from:

  1. the use or inability to use the Web Site;
  2. the acquisition cost of the goods and services resulting from any good, product, data, information or service acquired or obtained, or messages received or transactions made through or from the Web Site; and
  3. thenon-authorized access to, or the loss, corruption or alteration of your transmissions, content, or data.

7. Security and Confidentiality

Protecting the security and confidentiality of the information of the Users is fundamental for Conciliac. Consequently, Conciliac has adopted reasonable security measures within technological and economical reach and availability to protect the information and privacy of our Users and to prevent the non-authorized access to their data or any non-authorized amendment, disclosure or destruction thereof. The security measures taken by Conciliac comply with all the legal standards with regards to the Security and Confidentiality contents in the applicable regulations.
With the only limit of the technological, human and economic resources available to Conciliac, Conciliac contracts suitable and trustworthyservices to take care that the information that travels from your computer and/or any other device to the servers we use and vice versa, is transmitted in Conciliac´s monitoring safest possible manner.
Conciliac requires from its suppliers the same standards of confidentiality.
Conciliac may also disclose personal information of the Users in situations such that it jeopardizes the security of Conciliac before an attempt to breach or a physical hazard or threat against it or other Users, Conciliac and/or third parties.
Notwithstanding the foregoing, even if Conciliac makes its best effort to protect the information and privacy, Conciliac reminds the Users that the care of their privacy and security in digital environments also depends on each and every one and on how they use their own information, as well as on the manner they use the devices and/or programs and/or networks when conducting activities and/or transactions. In this sense, Conciliac suggests to always use devices and Internet connections that are safe at the moment of entering personal or financial data and/or other required data, as a way to duly protect you security.
The User assumes that, despite of all the efforts and technological, economic and human recourses used by Conciliac to ensure the Safety and Confidentiality of the User, the measures taken are not infallible. Consequently, Conciliac cannot guarantee the confidentiality and absolute safety, which may be eventually affected by the actions of third parties. The User waives any claim against Conciliac in such an eventuality, understanding that Conciliac has made the maximum possible effort to prevent it with the available technological, economic and human recourses. In case of such an eventuality, Conciliac undertakes to notify the users concerned.

8. Indemnity

You accept that Conciliac shall not be responsible, in any case, for any damage, inconvenience, impact or infringement of rights through the Web Site, its contents or tools provided by Conciliac, or the ones that provide other digital technologies therein, or through the digital media of Conciliac, regardless of its entity, that may suffer the User in person or in its goods or in the person or goods of its dependents, partners, contractors, close relatives, relatives and/or any other third party related in any manner with the User.
You accept and recognize that neither Conciliac nor its subsidiaries, controlling or controlled companies or companies subject to common control, related companies, affiliates, officers, agents, employees, directors, dependents, advertisers, partners, distributors, contractors and/or subcontractors (hereinafter, the “Related Parties”) shall be responsible for the damages, loss of profit or any other direct or indirect consequential damage, due to the use made by the Users of the Web Site, its contents or tools provided by Conciliac or the ones provided by other digital technologies therein or through the digital environment of Conciliac and that Conciliac places at the disposition of the Users.
The User is committed to indemnify and hold Conciliac and its Related Parties, harmless of any liability by and/or against any claim, liability, damages, loss of profit or any other direct or indirect consequential damage, for losses and expenditures (including legal and professional fees) that may arise from or are associated with third parties´ claims in connection with the use of the Technology and/or the Web Site, any infringement of this T&C or any other action related to the above-mentioned use . In the event of a claim, Conciliac shall inform it to the contact that the User has provided in its User account, provided that it is legally and factually possible. Nevertheless, Conciliac states that the lack of notification regarding any claim will not eliminate or reduce its obligation to compensate hereunder.
Furthermore, the User accepts and acknowledges that they shall be entirely responsible for the actions, omissions and use of the Technology and/or the Site by third party Users authorised by the Client. They shall in no way exempt and/or limit their liability towards Conciliac.

9. Cookies Policy

Conciliac uses ¨cookies¨ in order to improve the experience of the User in the Web Site. In that regard, in order to make a full use of the features and services of the Web Site, the User shall accept certain cookies. When using or browsing the Web Site, the User accepts the use of Conciliac’s cookies according to the features described below. The ¨cookies¨ are small text fragments, usually consisting of letters and/or numbers, which are sent by the visited website and stored by the software (e.g. a web browser) installed on the device used by the User to navigate on that website. Cookies are transmitted back to the mentioned website the next time the User visits it.
You can access more information about the cookies we use and how to manage your preferences in our Cookie Policy, which is included in our Privacy Policy, which is an integral part of these T&Cs.

10. Privacy policy

In Conciliac we give a great importance to the protection of personal data of all our users so we focus on complying with current regulations on the Protection of Personal Data in order to provide the best experience.
We know that it is important for our Users to know how we use their personal information, with whom we share it and what security measures we adopt to protect it. Therefore, in the Privacy Policies, which are an integral part of these Terms and Conditions, we explain, as clearly as possible, what data we collect, how we process it, for what purposes, with whom we share it and what are the rights of Users when they access, browse or use the services.
To know all the information related to the Privacy Policy of the Site and Conciliac Technology, you can verify it at the bottom of this document.

11. General Provisions

11.1. Entire Agreement
The T&Cs, the PTs and PPs, and any other contract or agreement that can be executed between the User and Conciliac, express all the terms agreed between said User and Conciliac, and supersedes any prior agreement, commitments or proposals in relation to the Site, the Technology and/or the products and/or services contracted.
It is established that the Particular Terms, if any, shall prevail over the Terms and Conditions and its Privacy Policy.11.2. Severability Clause
If any disposition of the present Terms and Conditions of Use is declared invalid, said invalidity shall not affect the remainder of the agreement, which shall continue in full force and effect. The parties shall negotiate in good faith a replacement disposition to replicate the intention of said disposition to the maximum extent permitted by the applicable laws.
11.3. Law and jurisdiction.
The present Terms and Conditions of Use and their Privacy Policies are governed by the applicable laws of Argentina being subject to the Jurisdiction of the courts of the City of Buenos Aires.
11.4. How to contact us.
In order to contact us, you may send us an electronic mail to soporte@conciliac.com.

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II. Privacy Policy of the Site and of the Conciliac Technology.
Last update: 14 December 2023

At Conciliac S.A. (hereinafter, ¨Conciliac¨), we give great importance to the protection of the personal data of all our Users (as defined in the Terms and Conditions of Use of Conciliac and also called, for the purposes of these Privacy Policies, the ¨Data Subjects¨), thereby focusing on the compliance of the current regulations regarding the Protection of Personal Data in order to offer the best experience.
We know that it is important for our Users to know which is the use we make of their personal information, with whom we share it and which security measures we adopt for its protection. Therefore, in this document (hereinafter the ¨Privacy Policies¨) we will explain, as clearly as possible, which data we gather, how we process it, for what purposes, with whom we share the data and which are the rights of the Data Subjects when they access and use the services.
The Privacy Policy is complementary to the Terms and Conditions of Use of the Concliac Technology, Terms and Conditions of the Site, Particular Terms and Agreements entered into between Conciliac and its Clients, if any.

Application of the Privacy Policy

These Privacy Policies shall be applied to:

  1. all web sites owned or operated by Conciliac, its applications, platforms, forms used for the collection of data, accounts in social networks or third parties´ platforms or related web sites (hereinafter, as a whole, the ¨Site¨);
  2. the Technology, Products and Services of Conciliac, as defined in the Terms and Conditions of Use of the Conciliac Technology.

The tools available and the activities for the processing of personal data that Conciliac carries out through its accounts in social networks or third-party platforms (hereinafter, the ¨Third-Party Platforms¨) can be subject to the privacy policies of those Third-Party Platforms.. We recommend that you undertake a thorough review of the privacy policies of said Third-Party Platforms when using them to understand the processing they make of the Personal Data of their users.
When accessing and using the Technology and Site of Conciliac, or when using the products and services available through these channels, the Users gives consent to include the personal data offered in the databases owned by and under the responsibility of Conciliac S.A., as well as to the processing of their personal data for the purposes described in the following pages herein.
BY ACCESSING, CONNECTING OR, IN ANY OTHER MANNER, USING THE TECHNOLOGY AND SITE OF CONCILIAC OR THE SERVICES OR TECHNOLOGIES AVAILABLE THROUGH THESE CHANNELS, YOU WILL HAVE TO CONFIRM THAT YOU HAVE READ, UNDERSTOOD, AGREED, ACCEPTED AND EXPRESSLY CONSENTED TO THESE PRIVACY POLICIES. IF YOU DO NOT AGREE WITH THESE POLICIES, WE RECOMMEND NOT TO USE THE TECHNOLOGY AND SITE OF CONCILIAC OR THE SERVICES AND TECHNOLOGIES AVAILABLE THROUGH THESE CHANNELS.

Data Controller – Contact

CONCILIAC S.A., CUIT (Individual Taxpayer Identification Number) 30-71230611-0, located at Mariscal Antonio José de Sucre 1530, Torre Libérateur, 9 floor, Office 4 (C1428DUS) City of Buenos Aires, Argentina (hereinafter, “Conciliac”), is the controller of the personal data collected through the Technology and Site of Conciliac.
The databases of Conciliac are duly registered before the National Registry of Databases of the Public Information Access Agency (Agencia de Acceso a la Información Pública) .
In case of enquiry or complain, the User may contact us through the electronic mail soporte@conciliac.com

Definitions

The following definitions will be used:

  1. ¨Personal Data¨: Any type of information referred to individuals or certain or ascertainable legal entities. In simple terms, any information related to a person that allows its identification (name, surname, National Identity Number, electronic mail, etc.).
  2. ¨Processing of personal data¨: Operation and systematic processes, electronic or not, that allow the collection, preservation, arrangement, storage, modification, relation, evaluation, blocking, destruction, and in general, the processing of personal data, as well as its assignment to third parties through communications, enquiries, interconnections or transfers.
  3. ¨ Data Subject¨: Any natural or legal person with legal domicile or branches or subsidiaries in the country, which data is subject to the processing. In this case, the User of the service is the owner of its persona data.
  4. ¨Data Controller¨: Conciliac S.A. is the controller of all the data of the Users collected through the Technology and Site of Conciliac or through other channels available to the Users in the future.

Categories of Users:

  • General User: Those Users that enter and use the Site without registration, whether they complete any form or not.
  • Client User: Those Users that have purchased the products and/or services of Conciliac and, in accordance with this, access to the Technology.
  • Client Collaborator User: Those Users that are employees or collaborators of the Client User and that have access to the Technology of Conciliac through an account generated as member of the team of the Client User.

Data Processing

Through the Technology or the Site of Conciliac, and the access to the services available through these channels, Conciliac may collect and request certain data from Users data, including personal data, meaning information that may identify the User.

The User understands that they will be solely liable for the veracity, accuracy, completeness, validity, authenticity and certainty of the information provided, having to notify of any update or modification that may apply immediately. Notwithstanding the foregoing, Conciliac may verify the Personal Data and/or information provided – either by itself or through third parties – by resorting to public entities, specialized companies, among others, what the User expressly consents.
The User acknowledges and accepts that Conciliac may collect and store the information regarding the different types of Users that operate in the Technology and Site.
The data collected and requested by Conciliac regarding a General User when they complete the form to request a demo are as follows:

  • Name and surname of the User that completes de Form.
  • Company and/or legal person in the name and on behalf of which the form is completed.
  • Country where the Technology will be used.
  • Amount of employees of the company and/or legal person in the name and on behalf of which the Form is completed.
  • Contact information (electronic mail and telephone) of the User.
  • Other information that may be provided by the User that completes the form in the section ¨Add Message¨.

The data collected and requested by Conciliac regarding a Client User to access to the Technology and/or Site and/or products and/or services available through these channels, is the following:

  • Corporate name of the Client User
  • Tax Identification Number
  • Country of the Client User
  • Data of the bank accounts through which collection to the Client User will be done.
  • Contact information (as electronic mail and telephone) of the Client.
  • Other information that Conciliac may have obtained directly from a General User that subsequently hires a product and/or service of Conciliac and thereby becomes a Client User.

The data collected and requested by Conciliac, regarding a Client Collaborator User to access to the Sites and/or the Technology and/or the products and/or services available through these channels, is the following:

  • Name of the user (corporate electronic mail of the Client Collaborator User).
  • Password

Furthermore, Conciliac may collect, use and combine anonymous information passively collected from the products, services and technologies of Conciliac, to render better services to Users and compile and statistically analyze the trends to manage and improve the products, services and technologies of Conciliac for the benefit of the Users. The information passively collected may include information regarding the use of the Product, such as the amount of registrations reconciled, functions of the Product used, modules, frequency of use, etc.
THE LICENSES OF THE PRODUCTS AND SERVICES OF CONCILIAC CORRESPOND TO LICENSES OF SOFTWARE ¨ON-PREMISE¨. THEREFORE, THE INFORMATION (INCLUDING PERSONAL DATA OF THE CLIENT USER OR OF THIRD PARTIES) THAT THE CLIENT USER PROCESSES THROUGH SAID LICENSES OF SOFTWARE SHALL BE PLACED IN THE SERVERS AND/OR LOCAL EQUIPMENT OF THE CLIENT USER AND NOT OF CONCILIAC. THAT IS TO SAY THAT THE CONFIDENTIAL INFORMATION OR NON-CONFIDENTIAL INFORMAITON OF THE CLIENT USER OR OF THIRD PARTIES PROCESSED USING THE TECHNOLOGY AND/OR THE PRODUCTS, SERVICES AND TECHNOLOGIES OF CONCILIAC IS INACCESSIBLE FOR CONCILIAC AND IS KEPT WITHIN THE INFRASTRUCTURE OF THE ORGANIZATION OR COMPANY OF THE CLIENT USER, AND NOT OF CONCILIAC.
Furthermore, regarding all Users:

  • If the User contacts Conciliac requesting information or for any other remark through our Sites and/or available contact channels, we will request to the User its name and surname, electronic mail, cell phone number, company and country or residence.
  • We will also collect information of the devices through which the User accesses to the Sites and/or Technology of Conciliac and to the services available through these channels. Among other data, we gather data regarding the browser used, the mobile operator, trademark, model and operating system of the device, IP address and geolocation of the device from which the User accesses. We may also monitor the traffic, displays, interactions and any other activity in the Sites. These data may be collected through the use of cookies, web beacons, pixels, canvas, fingerprints and/or the like.
  • With the purposes of knowing and analyzing the use that the Users make of the Site and/or Technology of Conciliac and of the Services available through these channels, Conciliac uses analytic services of third parties. These suppliers use technologies such as cookies, network server registrations and web beacons that collect information (including the IP address and geolocation) that may be informed to suppliers of said analytical services, as well as to other third parties that can use the information collected to, among other things, evaluate the use of the Sites and/or Technology of Conciliac. More information can be found in the section Cookies Policies at the end of this document.

Purposes of the Processing

You expressly consent that Conciliac may use de Personal Data offered by the User for the following purposes:

  • Identification of the Users and their devices;
  • Management and storage of Conciliac’s Users Accounts and related services, own or outsourced, such as technical, support, customer service, call centers services, among others;
  • Processing of the collection of the Technologies of Conciliac hired by the User;
  • Analyses, storage and processing of said information, including its grouping according to certain profiles for the purposes of quality control, marketing and research, promotion, commercial or publicity;
  • Coordination of Demos of the Technology with Users;
  • Offer of useful information to the User and/or other Users that are cooperating in the environment, easing a better operation;
  • Sending promotional information of products and/or services of Conciliac, through the sending of newsletters or other type of presentations, always with the option for the User to unsubscribe;
  • Analyses and follow-up of the use of Conciliac and its functionalities with business, statistical or promotional purposes;
  • Use of different tools created by Conciliac in order to render the services more efficiently;
  • Disclosure of the information to third parties as component of set of data keeping the anonymity of Users;
  • Offer access to the use licenses of the Technology hired and/or to the services associated thereto.

How do we Share the Data of the Users

The Data Subject gives their express and informed consent so that Conciliac can share the Personal Data with third parties with which Conciliac has a business relationship (including, but not limited to, marketers of Conciliac´s Technologies) or that operate the Sites and/or Technology of Conciliac, this serving as explicit consent for such sharing.
In this regard, Conciliac may disclose or broadcast the Personal Data to third parties for the purposes of and/or within the frame of processes related to the assignment, merge, consolidation, corporate restructuring, investment, sale of all or of a significant part of its assets or shares, acquisition of credits and/or within the frame of any process of own internal audit of Conciliac and/or of third parties.Conciliac may also share the collected data with:

  1. Suppliers of Services: Considering the complexity of our services, there are some companies or entities that supply us with services that imply the processing of personal data. In this way, the data of the Users will be shared with our suppliers of hosting services, cloud storage, suppliers of technology, suppliers of security information, suppliers of audit, account or legal services, marketers, among others. Our suppliers render services according to our instructions and with the purposes detailed in these Privacy Policies. We do not authorize them to disclose or reveal the personal data of our Users except for those uses that are strictly necessary for the rendering of the services on our behalf, or to comply with legal obligations.
  2. Public Authorities: We share information with administrative and judicial authorities that, in the exercise of their responsibility, require information of Conciliac, of our suppliers of services and/or of our commercial partners, even though there is no order or executive or judicial summons in this regard, for the purposes of: (a) cooperating in the research and reporting frauds, hacking, infringements to industrial or intellectual property or any other illegal act, as well as any activity or circumstance that may generate legal responsibility to Conciliac and/or its users; (b) safeguarding a public interest, the procurement or administration of justice, the recognition, exercise or defense of a right in a judicial or administrative proceeding, and/or the settlement of disputes; and (c) complying with any applicable law, regulation or legal provision, or any commission of a competent authority duly founded and justified.
  3. Officers: It refers to judicial, administrative, governmental officers and those responsible of the settlement of disputes. We share information with authorities, courts, conciliation officers, mediators or entities that intervene in the settlement of disputes for the purposes of settling the disputes that may arise in which we may have any kind of intervention or participation.

Finally, we also share information to: (a) protect and defend our rights and property; (b) protect the personal safety of our employees, agents, representatives or Users; and/or (c) protect the integrity of the on-line community of our services.
At all times the Data Subject shall have the right to revoke its consent for the assignment of the Personal Data, which shall result in the immediate suspension of the Service, any time that the assignment is essential so that Conciliac can comply with the purposes of the collection of data.

International Data Transfer.

When our service providers or their servers are outside the Argentine Republic, we ensure that they are located in countries which legal framework provides an adequate level of data protection, so that user’s personal data is processed in a safe manner and with the same guarantees as we treat them in Argentina.
Otherwise, we monitor that these international data transfers are carried out through appropriate legal mechanisms, implementing safeguards that guarantee a proper level of protection of the data under the terms of the regulations in force regarding Personal Data Protection and the regulation ordered by the Public Information Access Agency (Agencia de Acceso a la Información Pública).
In all cases, the Data Subjects gives their free, express and informed consent that their personal data can be internationally transferred to Conciliac, Inc., located in the State of Florida, United States of America, always within the frame of what is set forth in these Privacy Policies.

Rights of the Users

  1. Right to Access: In order to know if we are processing or not the personal data. If we are processing it, we shall provide all the information in this respect. Regarding the right of Access, we herein inform the User that, complying with Regulation 10/2008, as the Data Subject, the User has de authority to exercise the right of access to them free of charge at intervals of no less than six months, unless a legitimate interest is proven according to what is set forth in article 14, section 3 of Law No. 25.326.
  2. Right to Rectification: The Data Subject may request the rectification of the personal data that concerns to the user and is inaccurate.
  3. Right to Update: The Data Subject may request the update of the personal data that concerns to the user and is inaccurate.
  4. Right to Eliminate: The Data Subject may request the elimination of the personal data that concerns to the user upon the occurrence of any of the following situations: (i) if the personal data is not necessary with reference to the purposes for which it had been collected or processed; (ii) if the processing of the personal data has been based on the consent and it had been withdrawn, provided that the mentioned processing is not based on any other ground that legitimates it; (iii) if there had been oppositions to the processing; (iv) if the personal data had been illegally processed; (v) if the personal data shall be eliminated for the compliance of a legal obligation. As it is necessary that we have certain personal data of your ownership to grant access to the services of Conciliac, the elimination of certain personal data may imply that the User loses total or partial access to the services of Conciliac. However, Conciliac may withhold certain data necessary for the invoicing of its services for a term of 5 years to allow audits.

How to exercise your rights as User before Conciliac?

The User may exercise these rights before Conciliac sending an electronic mail to soporte@conciliac.com from the mail initially registered and stating the means through which the user wants to be granted access (mail, zip code, personal delivery, telephone).
When we cannot verify the identity of the User, we shall request users to enclose reliable documents that allow the identification.
In case the User exercised the right to access, in compliance with the applicable regulations, we shall reply to its request within a term of ten (10) consecutive days counted from the reception, prior verification of the identity of the User. When the User request the rectification, update or elimination of information, we shall reply within a term of five (5) working days counted from reception of the inquiry, prior verification of its identity and, if applicable, of the documents proving the applicability of the rectification or update of information.
Finally, the User has the right to withdraw the consent to treat the data at any time sending a message for these purposes through the mail soporte@conciliac.com.

Links with other Sites

The Technology and Site of Conciliac may include links to other web sites for your convenience and information. These web sites may be operated by entities not related to Conciliac. Usually, these linked wed sites have their own privacy policies and or warnings, so we recommend Users to read them when visiting said sites.
Conciliac assumes no liability regarding the links to web sites of third parties or regarding the content of web sites different from ours. Conciliac assumes no liability regarding the use of said web sites or privacy practices thereof, beyond what has been expressly stated in the privacy policies.

Security Measures

In Conciliac we comply with the applicable regulations regarding protection of personal data.
When the Users give us their personal information, we keep it in strict confidentiality and secret. Conciliac shall only use your data to the extent that your relationship with Conciliac is in full force and effect and shall use it strictly for the compliance of the above-detailed purposes. In this respect, all data shall be stored in a database owned by Conciliac, registered before the National Registry of Personal Data Protection.
To guarantee the safety of the personal data, we adopt administrative, organizational, technical and physical safety measures specially designed to protect the personal data given against its destruction, loss, alteration, access, communication or accidental, illegal or non-authorized use. We apply the same criteria and the same degree of care that Conciliac applies to protect its own information. We consider the safety standards and proceedings set forth by the regulations in the matter and permanently evaluate new technologies to protect this information.
However, as is generally known, existing technical means that provide security are not impenetrable and even when we adopt all reasonable safety precautions it is possible that we may experience tampering, destruction and/or loss of information.
For this reason, whenever the User considers that its interaction with Conciliac is no longer safe (for example, if the User believes that safety of its account has been jeopardized), we request to send immediate notice of said circumstance using the communication channels we offer in section ¨ Data Controller – Contact¨.

Storage Limitation

We shall preserve the personal data of our Users while their relationship with us is in full force and effect. Once the relationship with the User is terminated, we shall preserve the personal information for 10 (ten) years and/or for the additional time required by the applicable legislation for accounting and/or legal purposes.

Complaints

At all times, the User may communicate with us through our contact channels to file a claim concerning any infringement to his rights with regard to the processing of personal data. In such a circumstance, we shall take care of the situation and amend it as early as possible.
However, if the User considers that fully satisfaction in the exercise of his rights has not been accomplished, the User may file a claim before the Public Information Access Agency (Agencia de Acceso a la Información Pública) located at Av. Pre. Gral. Julio A. Roca 710, 5th floor, City of Buenos Aires, that is the supervisory body of Law No. 25.326 and who has the assignment of attending claims and complaints filed in relation with the non-fulfillment of the regulations on protection of personal data.

Updates of these Privacy Policies

Conciliac may modify or update these Privacy Policies, to reflect the changes introduced in our practices with regard to personal data, and according to what is required by the Regulations on Personal Data Protection.
If applicable, Conciliac shall place at the disposal of the User the information regarding the changes made and Users will have to accept the new policies again, offering a new consent for the processing of Personal Data. If the User does not want to give consent in case of an amendment of this policy, User may not continue using the technology and/or Site of Conciliac.
For further inquiries regarding these policies, we provide the following means of contact: soporte@conciliac.com.

Competent Jurisdiction and Applicable Law

Any dispute arising between Conciliac and the User shall be governed by the laws of the Argentine Republic, with the exception of any regulation that refers to the application of a foreign law. Any dispute shall be submitted to the Ordinary Courts of the City of Buenos Aires.

Cookies Policy

Conciliac shall use ¨cookies¨ to improve the experience of the User in the Site. Accordingly, in order to make a complete use of the characteristics and services of the Site, the User shall accept certain cookies. When using and browsing the Site, the user accepts the use of cookies from Conciliac according to the characteristics described below. Cookies are small pieces of text, usually formed by letters and/or numbers, that are sent by the visited web site and stored by the software (for example, the web browser) installed in the device used by the User for the browsing. Cookies are transmitted again to the mentioned web site the next time the User visits it.
¨Cookies¨ do not contain information that allows the identification of the User and, on their own, do not allow obtaining personal contact information of the User, such as its electronic mail address. If the User decides to provide personal information to the Site, for example through forms, said information can be related to the data stored in the cookie. The information we collect consists of information of the browser used, the type of computer, its operative systems, its internet service suppliers, the sections of the Site visited, the links made and any other information of similar characteristics. The ¨Cookies¨ are an essential part of how the web site works. The main purpose of using ¨cookies¨ is to improve the experience of the User during browsing. For example, the ¨cookies¨ help to remember user´s preferences (language, country, etc.) during browsing and during future visits. The information gathered in the ¨cookies¨ allows Conciliac, for example, to improve the Site, through estimates regarding numbers and use patterns, the adaptation of the Site to the individual interests of the User, the acceleration of searches. Conciliac does not use ¨cookies¨ to store sensitive information of personal identification such as address, passwords, etc. Conciliac neither uses ¨cookies¨ to direct advertisements to its Users according to their browsing nor for other advertising purposes, own or of third parties.
Conciliac in no way binds the User to maintain ¨cookies¨ active, but informs that some functions and sections of the Site may be disabled or may not work properly. The configuration of the management of cookies depends of the browser used.
Hereinafter, you will find instructions and links to guides to manage cookies of the main desk browsers:

  • Microsoft Edge: Click the icon with three points in the upper right margin and then in ¨Configuration¨. In the left menu, choose ¨Cookies and site permissions¨ and adjust the configuration of cookies. Hereinafter is the link to obtain more information: https: //support.microsoft.com/es/help/4027947/microsoft-edge-delete-cookies
  • Google Chrome: Click the icon with three points in the upper right margin and then ¨Configuration¨. Choose ¨Advance¨ and in ¨Privacy and safety¨ click ¨Configuration of the Site¨. After this adjust the configuration of cookies choosing ¨Cookies and data of the site¨. Hereinafter is the link to obtain more information: https://support.google.com/chrome/answer/95647?hl=it&p=cpn_cookies%20https://support.google.com/accounts/answer/61416?hl=it
  • Mozilla Firefox: Click the icon with the three horizontal bars in the upper right margin and choose ¨Options¨. In that window choose ¨Privacy and Safety¨ to adjust the configuration of cookies. Hereinafter is the link to obtain more information: https://support.mozilla.org/it/kb/Attivare%20e%20disattivare%20i%20cookie
  • Apple Safari: select “Preferences” and then “Privacy”, where you can adjust the configuration of the cookies. Hereinafter is the link to obtain more information: https://support.apple.com/it-it/guide/safari/sfri11471/mac

In case of browsers different from the mentioned ones, it will be necessary to consult the pertaining guide to know how to manage cookies.

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III. Commitment to comply with applicable regulations on prevention of corruption, terrorism, money laundering, human trafficking and/or smuggling of persons.

Conciliac rejects all forms of corruption, terrorism, money laundering, human trafficking and/or human smuggling, understanding that those activities are an obstacle to economic and social development. Therefore, we support the efforts of governments, international organizations and civil society to eradicate those activities, including this Commitment as an Annex to the Terms and Conditions of Use of the Technology of Conciliac and to the Particular Terms and Conditions (hereinafter, all of them, the “T&C”) with our clients (the “Clients”).
For the purposes hereof, the term “Clients” shall also include their subsidiaries, related companies, companies that control, are controlled or are subject to common control with the Client, shareholders, officers, directors, employees, dependents and contractors.

SECTION 1: REPRESENTATIONS AND WARRANTIES OF THE CLIENT

The Client declares and guarantees that:

  1. Complies with applicable regulations regarding the prevention of corruption, terrorism, money laundering, human trafficking and/or smuggling of persons (the “Prohibited Practices and Activities”)
  2. Will not use or link in any way the technology, software, applications, algorithms, products and/or services provided by Conciliac to engage in Prohibited Practices and Activities.
  3. Has internal policies and procedures for the prevention of Prohibited Practices and Activities.
  4. Is not included in international listings related to Prohibited Activities and Practices, including, but not limited to, listings published by the UN, OFAC or the U.S. Department of State.
  5. Was not subject to any sanction related to non-compliance with applicable regulations regarding the prevention of Prohibited Activities and Practices, and the normal course of its activities should not reasonably cause investigations of any kind related to such Prohibited Activities and Practices.
  6. Has not made and will not make any type of contribution, donation, gift or present in favor of political campaigns, candidates for office or political parties or officials of such parties, unless such contributions, donations or gifts: (i) are made in compliance with applicable regulations, (ii) are not made in exchange for advantages or benefits, (iii) are expressly recorded in the books and records of the Client, in accordance with applicable regulations.
  7. Has not and will not engage in: offering, promising, paying, giving or authorizing any payment or anything of value, directly or indirectly, to or for the benefit of any Authority, for the purpose of obtaining or retaining business or advantage and/or for the purpose of improperly inducing anyone to engage in activities that violate, even potentially, applicable anti-corruption regulations. For purposes of this document, “Authority” means any officer, agent or representative, or any other person acting officially or on behalf of any (i) government, including any entity owned or controlled by such entity, (ii) political party or political candidate, (iii) international organization, or (iv) person who knows or has reason to believe that any part of the payment given or offered to such person will be governed by any of the foregoing categories.

SECTION 2: EARLY TERMINATION BY CONCILIAC:

Conciliac may immediately terminate the contractual relationship with the Client in accordance with applicable provisions regarding for cause termination provided in the T&Cs, without any compensation for the Client, in the following cases:

  1. If at any time during the term of the contractual relationship the Client fails to comply with one or more representations and warranties contained in Section 1 of this document.
  2. If the Client is convicted for having committed a crime related to Prohibited Activities and Practices.
  3. When there are indications or circumstances which in the reasonable judgment of Conciliac represent a risk that the Client may have committed an offence in connection with Prohibited Activities and Practices.

SECTION 3: INDEMINITY:

The Client will hold harmless and indemnify, exonerating Conciliac and its subsidiaries, related companies, companies that control, are controlled or are subject to common control with Conciliac, affiliates, officers, agents, employees, managers, employees, dependents, advertisers, partners, distributors, contractors, and/or subcontractors as provided in the applicable T&Cs, for the applicable statute of limitations period, for any judicial or extrajudicial claim brought by any third party against Conciliac related to Prohibited Activities and Practices carried out by the Client or that the third party claims to have been carried out by the Client.