Privacy Policy

Privacy Policy

This privacy policy applies to the apps (hereby referred to as “Application”) for mobile devices, created by ELCSoftware SpA (hereby referred to as “Service Provider”) as Ad Supported services. This service is intended for use “AS IS”.

What information does the Application obtain and how is it used?


To provide and improve our services, the Application collects certain categories of personal information from you:

- Location Information (Stored Locally): The Application obtains real-time location information from your device to display relevant information based on your current location. This data is stored exclusively on your device and is not transmitted to our servers.

- Device Identifiers (Transmitted): We may collect a unique identifier for your device (such as a Device ID or Advertising ID). This information helps us understand usage patterns, troubleshoot issues, and support our services. Registration is not required to use the Application.

Legal Basis for Processing Data


We process your personal information based on the following legal grounds:

- Consent: By using the Application and granting necessary permissions (such as location access), you consent to the processing of your data as described in this policy. This is the primary basis for collecting location information.

- Legitimate Interest: We process data like Device Identifiers based on our legitimate interest in maintaining, securing, and improving our services, understanding usage trends, and troubleshooting issues. We ensure that our legitimate interests do not override your rights and freedoms.

Data Retention


We retain personal data for as long as it is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations.

- Location Information stored on your device is retained until you uninstall the Application.
- Device Identifiers transmitted to our servers are retained for a period necessary to provide and improve our services, after which they may be anonymized or deleted.

Do third parties see and/or have access to information obtained by the Application?


We do not sell, trade, or otherwise transfer your personally identifiable information to outside parties. As described in this policy, location data remains on your device and is not shared. Device Identifiers may be processed by trusted third-party service providers who assist us in operating our Application, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We do not "sell" or "share" your personal data as those terms are defined under the California Consumer Privacy Act (CCPA) or the Virginia Consumer Data Protection Act (VCDPA).

Your Data Privacy Rights


You have certain rights regarding the personal data we hold about you. To exercise any of these rights, please contact us at contacto@elcsoft.cl.

- Right to Access: You have the right to request access to the personal data we hold about you (such as your Device ID). Location data can be accessed directly by you within the Application, as it is stored on your device.

- Right to Correction: You have the right to request the correction of inaccurate personal data we hold about you.

- Right to Deletion: You have the right to request the deletion of your personal data. For data stored on our servers (like Device ID), you can submit a request to us. For data stored locally (location data), you can delete it by uninstalling the Application. We will process your request in accordance with applicable privacy laws, subject to certain legal exceptions.

- Right to Lodge a Complaint: You have the right to lodge a complaint with a competent supervisory authority or data protection agency in your country of residence if you believe that our processing of your personal data infringes applicable data protection laws.

Your U.S. Privacy Rights (California & Virginia)


This section supplements the information contained in our Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California or the Commonwealth of Virginia. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and the Virginia Consumer Data Protection Act (VCDPA).

Right to Know About Sale or Sharing: You have the right to know whether your personal data is sold or shared. We do not "sell" or "share" your personal information as those terms are broadly defined in the CCPA and VCDPA.

Right to Opt-Out: Since we do not sell or share your personal information, there is no need to offer an opt-out mechanism.

Your Rights for Users in the European Economic Area (EEA)


If you are a resident of the European Economic Area (EEA), you have certain data protection rights under the General Data Protection Regulation (GDPR). We aim to take reasonable steps to allow you to exercise your rights. In addition to the rights listed in the "Your Data Privacy Rights" section, your rights under the GDPR include:

- The right to restrict processing: You have the right to request that we restrict the processing of your personal information.

- The right to data portability: You have the right to be provided with a copy of the information we have on you in a structured, machine-readable, and commonly used format.

- The right to object: You have the right to object to our processing of your personal data when it is based on our legitimate interests.

We do not engage in automated decision-making or profiling that would have a legal or similarly significant effect on you. To exercise any of these rights, please contact us at contacto@elcsoft.cl.

Your Rights for Users in Brazil


If you are a resident of Brazil, you have certain rights under the Lei Geral de Proteção de Dados (LGPD). These rights include:

- Confirmation of the existence of the processing;
- Access to the data;
- Correction of incomplete, inaccurate, or out-of-date data;
- Anonymization, blocking, or deletion of unnecessary or excessive data or data processed in noncompliance with the provisions of the LGPD;
- Portability of the data to another service or product provider, by means of an express request;
- Deletion of personal data processed with the consent of the data subject;
- Information about the possibility of denying consent and the consequences of such denial;
- Revocation of consent.

To exercise any of these rights, please contact us at contacto@elcsoft.cl.

Children


The Application is not used to knowingly solicit data from or market to children under the age of 13. The Service Provider does not knowingly collect personally identifiable information from children. If you have reason to believe that a child has provided personally identifiable information to us, please contact us at contacto@elcsoft.cl.

Security


We are committed to safeguarding the confidentiality of your information. We take reasonable measures to protect the information we collect from loss, theft, misuse, and unauthorized access.

Changes


This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by updating this page with the new Privacy Policy. You are advised to consult this Privacy Policy regularly for any changes, as continued use is deemed approval of all changes.

This privacy policy is effective as of 2025-07-30.

Your Consent


By using the Application, you consent to our processing of your information as set forth in this Privacy Policy now and as amended by us.

Contact Us


If you have any questions regarding privacy while using the Application, or have questions about our practices, please contact us via email at contacto@elcsoft.cl.

Data Controller:
The data controller for the information you provide is ELCSoftware SpA.

Data Protection Officer (DPO):
To contact our Data Protection Officer regarding any privacy concerns, please email contacto@elcsoft.cl with the subject line "DPO Inquiry".