VISAGERD S.L. — responsible for the QR NOW app — and PrimexPath Technologies LLC — responsible for the website — (each referred to hereinafter as "the Company", "We", "Us" and the like, depending on the Platform you are accessing) are each firmly committed to regulatory compliance and the privacy and protection of personal data; accordingly, in the present Privacy Policy, the User (hereinafter "the User", "you", "your") of our Platforms will find all the relevant information to better understand what We do with his/her personal data. If you do not agree with this Policy, please discontinue using our Platforms. We may update this Privacy Policy according to new legislative or jurisprudential requirements and/or business needs, among other reasons. The new version of this Privacy Policy will be applicable from the moment of its publication on the Platform. Therefore, the User is recommended to review this Privacy Policy regularly. This Privacy Policy will always be available on the Platform so that the data subjects can consult it at all times.
What does this Policy apply to?
This Privacy Policy applies to the personal data that We collect and process from you as a User of our App and our Website as well as the services offered within it. Please bear in mind that this Platform is for adults in accordance with the laws and regulations of his/her birth or residence country.
What does personal data mean and which data do We collect and process?
For the purposes of this Policy, "Personal data" refers to all data that identifies you or that could be used to identify an individual, such as:
- Your Store Provider Identifier (e.g. Apple/Google user ID) when you download the App and your IP address or browser identifiers when accessing via website.
- E-mail address if you contact us or register through the Platform
- The Platform may collect information about how you interact with it, to enhance your user experience.
- Information about the location (GPS) of your device (that is, your IP address) by using RevenueCat. For further information, please consult RevenueCat’s privacy policy;
- Advertisements while using the Platform when applicable by means of AdMob from Firebase (Google Inc.). For further information, please consult Google’s partner privacy policy.
In all cases, We only process personal data which is strictly necessary for the fulfillment of the purposes below. That is, if you provide Us with more information than the one expressly required, you consent to its processing for the informed purpose(s). In view of the foregoing, the Company shall not be liable if:
- The User is not an adult in accordance with the laws and regulations of their birth or residence country. In this sense, it is the sole responsibility of the parents and/or legal guardians to exercise adequate control over their minor children’s/wards’ online activity and to prevent their access to Platforms whose content is not suitable or recommended for minors. Therefore, the communication of a minor's personal data without the prior authorization of their parents/legal guardians is under the exclusive responsibility of the latter. If We become aware that We have collected personal data about a User under the aforementioned age, We will delete that data as soon as it is possible from a technical standpoint.
- The Company has received an adult’s personal data and/or private information to provide the services offered in the Platform by a third party who has not requested the adult’s consent to communicate his/her personal data to us. In such case, the Company reserves the right to inform the interested person of how his/her personal data and/or private information has been collected and, where appropriate, We will ask the individual who provided the personal data to the Company to confirm that he/she requested the consent of the data subject and/or to amend this circumstance, as well as, if appropriate, to suspend the services and/or the User account.
- For circumstances that are beyond our reasonable control, such as being provided with erroneous, incomplete, and/or fraudulent information from you as a User and/or Customer, you will be solely responsible for the inaccuracy or lack of veracity of the information provided. In this regard, the Company will not be held responsible for the impossibility of providing the Services or for the Services not being correct or complete because the User has not complied with this requirement.
Who is the personal data controller?
Depending on the Platform you are using, the controller of your personal data is:
- For the app: VISAGERD S.L.
- For the website: PRIMEXPATH TECHNOLOGIES LLC
Each entity acts as an independent data controller in respect of the personal data collected through their respective Platform and is solely responsible for its processing.
What do We use your personal data for?
Please be informed that you only are required to provide personal data and information that is strictly necessary to fulfill the purposes explained below. In this regard, if you provide Us with more information than is expressly required, you consent to its processing for the purpose(s) for which it was granted. Having said that, We use your personal data for the following purposes:
- To personalize your experience and improve our Service and/or Platform functionalities.
- To provide the service;
- To manage scanning of QR codes provided through our Platform and/or created through the Platform;
- To collect the fees of the subscription plans to the services offered through the Platform;
- To manage your information queries regarding our Platform and/or the Service offered through it;
- To comply with our legal obligations, legal requirements, laws, and regulations and/or to respond to judicial, police or the corresponding authorities’ requirements;
- To protect, investigate, and deter fraudulent, unauthorized, or illegal activity on/through our Platform;
- When applicable, to improve our Platform's functionalities and the Service offered by analyzing disaggregated data not associated with a particular user’s personal information.
- When applicable, to show you advertisements related to our Platform while you are browsing your social media or third-party websites.
- To send you commercial communications, newsletters, and promotional updates about our services, provided that you have given your explicit and separate consent for such marketing communications.
What is the legal basis for processing your personal data?
We only process your personal data when there is a legal basis for doing so. The legal basis will depend on the reason(s) why We collect and process your personal data. In almost all cases the legal basis will be:
- The consent that you provided Us with for the processing of your personal data in order to be able to provide you with the Services offered through the Platform and other purposes informed at the time of collection of your data.
- The consent you have granted to your Store Provider to install cookies and/or similar technologies on your device(s) for the purpose of tracking your activity in these platforms, for example, what applications you have installed or which information you share with third party partners about your browser or device for advertising purposes.
- To comply with our legal obligations and/or to attend administrative, judicial, police, or the corresponding authorities’ official requirements.
- Our legitimate interests in (i) offering an enhanced user experience when you access and use the Platform and operating it efficiently, (ii) monitoring fraudulent activity in order to preserve the security and integrity of our Platform; (iii) providing advertisements to users according to their interests; (iv) defending and addressing our rights in the event that a claim regarding our Platform and/or Service may arise.
Regarding cookies and/or similar technologies used by the Store Provider to collect and store the information on your device that is later shared with the partners of the services offered by these platforms, we recommend that you consult the Privacy and Cookie Policies of these platforms for information on how to revoke the consent that you have given for the installation of similar technologies.
How long do We keep your personal data for?
For Non-subscribed Users: We will keep your personal data for six (6) months. For Subscribed Users: For as long as you are subscribed. Beyond that, your personal data will be retained, and securely blocked, for the necessary retention period to meet our legal obligations and/or for our legitimate reasons (i.e. to address claims in connection with the services offered through the Platform; to finish the investigation of detected fraudulent or illicit activity.) Once the necessary retention period has ended, your personal data will be securely deleted from our information systems.
Who do We share the User’s personal data with?
We may communicate your personal data to the following third parties, including but not limited to:
- (i) our main service providers, such as Store Providers, where appropriate;
- (ii) outsourced service providers for the Service provision, such as Documo Inc. (Documo's Privacy Policy)
- (iii) other providers such as RevenueCat, Google Inc, Amplitude, Firebase, among others;
- (iv) administrative, police or judicial authorities as long as the data is required in accordance with the applicable law and regulations;
- (v) law firms to respond to claims regarding our Platforms or services offered through it;
The third parties mentioned above may have their headquarters outside the European Economic Area (EEA), therefore, your personal data will be object of international transfers. In any event, if a personal data international transfer is deemed appropriate, We inform you that We will only transfer personal data to recipients located in countries that ensure an adequate level of data protection according to the Decisions of adequacy of the European Commission or, failing that, offer the appropriate safeguards required by the current applicable law and regulations on the protection of personal data, in order to ensure that your personal data is properly protected and that your individual rights and freedoms are guaranteed. In this regard, please be informed that the third parties mentioned above are committed to using standard contractual clauses approved by the EU Commission for transfers to the USA. In the event of any type of international data transfer we guarantee an adequate level of protection by means of:
- Agreements with standard contractual clauses approved by the European Commission
- Certification mechanisms or adequacy decisions. For users located in Latin American countries (LATAM), international transfers of personal data are carried out in accordance with the mechanisms and conditions legally established in the local legislation applicable in each country. This may include, among others, the requirement to have the express consent of the data subject, the existence of adequacy decisions by the local authority, or the implementation of contractual clauses or other legally valid instruments that ensure an adequate level of protection of the personal data transferred.
How do We protect your personal data?
Your trust is very important to Us. For this reason, your personal data is stored confidentially and securely in our information systems. We have established the appropriate technical and organizational measures to safeguard and protect your personal data against illegal or unauthorized access, loss or accidental destruction, damage, use, and illegal or unauthorized disclosure.
What rights do you have and how can you exercise them?
We inform you that the Users can withdraw their consent to processing their personal data at any time. Users may also exercise the following rights: access, verify and seek rectification, have their Personal Data deleted or otherwise removed, restrict the processing of their data, object to processing of their data, as well as the right to have the Personal Data transferred to another controller (portability), with a written request, addressed to us, via the following e-mail: support@qr-now.app. We also inform you of your right to lodge a complaint to the Supervisory Authority. As a general rule, We will respond to data protection rights requests within one (1) month. Occasionally, this period may be extended by two (2) further months where necessary, taking into account whether your request is particularly complex or you have made several requests. In this case, We will notify you of this event and explain the reasons for the delay to you. Finally, we inform you that should you consider it appropriate, you have the right to lodge a complaint before the corresponding Supervisory Authority, especially if you consider that your data protection rights have not been adequately addressed. We remain at your disposal for any doubts or questions you may have about this Policy, please contact Us by email at support@qr-now.app.
What are cookies, and what are they used for?
For the purposes of this Policy, the single term “cookies” refers to cookies and similar tracking technologies (such as SDKs, pixels, device identifiers, and local storage mechanisms) that collect information about how users access and interact with our Platforms (i.e., our website and/or app), for different purposes, such as:
- Facilitating information about the user's device;
- Recording the user's navigation through our Platforms;
- Remembering browsing and in-app preferences;
- Customizing the services offered on our Platforms;
- Storing the user's purchase and cancellation history; and
- Generating aggregate statistics based on user interaction, among others.
The data recorded by cookies takes up a small space on a device's memory and does not harm the device in any way.
When are cookies installed?
Interacting with our Platforms and purchasing the paid services offered on them implies the installation of cookies or equivalent tracking technologies, which may belong to us or belong to third parties. The use of third-party cookies is subject to the Cookies and Privacy Policies of those third parties. Therefore, We will not be responsible for the content or accuracy of such third-party policies. Please consult the website(s) and/or app(s) of said third parties to obtain more information, or to change your preferences regarding these cookies.
What type of cookies are installed?
Cookies that can be installed include the following:
By duration
| Type | Description |
|---|---|
| Session cookies | Used to identify the user during their session and prevent repetition of processes. Automatically deleted when the browser or app session is closed. |
| Persistent cookies | Used to identify the user across sessions and prevent repetition of processes. Remain installed for a defined period on the user's device. |
By origin
| Type | Description |
|---|---|
| First-party cookies | Sent from our own Platforms and equipment. Information is collected for our own purposes. |
| Third-party cookies | Sent from equipment or services managed by third parties (partners and/or service providers). Information may be collected for our own purposes (e.g., geolocation) and/or to manage the services those third parties provide (e.g., payment processing). |
By purpose
| Type | Description |
|---|---|
| Technical / Strictly necessary cookies | Enable the basic operation and functions of our Platforms, including carrying out the purchase process and managing payment. |
| Analytical cookies | Allow us to analyze use of our Platforms and identify which features are of most interest to users, in order to improve quality and user experience (e.g., interface design, usability). Data is collected in aggregated, non-personally identifiable form. |
| Preference / Functionality cookies | Remember user settings and preferences to personalize the experience across our Platforms (e.g., language, region, display settings). |
| Advertising / Marketing cookies (web only) | Used to deliver relevant advertising and track campaign performance across our website and third-party channels. |
To install cookies in your device's browser, we require your express consent, except for cookies that are exempt from such consent. The exempt cookies are strictly necessary technical cookies and user authentication or identification cookies (session cookies only). We have enabled appropriate mechanisms to obtain your consent for the installation of non-exempt cookies. Please be informed that, in accordance with the applicable laws and regulations, (i) it will be understood that your consent has been given if you modify the configuration of the browser by disabling the restrictions that prevent the installation of cookies and that, (ii) when the installation of cookies is necessary to provide a service that you have expressly requested, your consent will not be required. On our website, you may manage your cookie preferences at any time through our cookie consent banner or browser settings. On our mobile app, you may manage tracking and data collection preferences through your device's privacy settings (e.g., limiting ad tracking on iOS/Android) or within the app's settings menu, where available.