Privacy Policy

 I. General

This document is part of the Agreements and Terms of Use of Pagadito. The User consents from the time of registration on the website, to the use of his/her information in accordance with these Policies.

Pagadito business model requires the collection and disclosure of Users’ information in some cases. Pagadito acknowledges that the privacy of the Users’ information is very important and because of this, precautions are taken to safeguard the information through effective computer security systems.

This section explains in detail, what Pagadito may do with that information so the User knows in advance of such circumstances.

II. Information collected

The User can enjoy Pagadito services by being a Registered User, for this, the User must provide complete and accurate personal and financial data, as detailed in section "Personal Information". The information that might be required and stored is: full name, User’s nickname to log in the website, domicile, date of birth, email, telephone number, credit or debit card number, billing address, card expiry date, card type, etc.

Pagadito reserves the right to confirm the personal data provided through public or specialized companies, for which, the User expressly authorizes Pagadito to confirm the information it deems necessary. The information obtained will be treated as confidential.

Pagadito automatically collects and stores some information about the activities of the Users within Pagadito. Such information may include the URL it comes from (whether or not they are in the website), which URL they access afterwards (whether or not they are in the website), what browser they are using and their IP addresses. Furthermore it shall also collect and store information about pages visited, searches, publications, purchases or sales, ratings and responses entered, messages in forums, etc. At the same time, Pagadito shall collect and store information from correspondence such as emails or letters sent by the User, or correspondence on the activities or messages from other Users on the site by other Users or third parties.

User’s nickname

To operate the site, registered Users should use a nickname to identify themselves. No User may have information about other Users unless: a) The Selling User is a Pagadito Comercio, b) Where goods sold are vehicles or real state property and c) When transactions are international.

Users’ Password

Users duly registered shall have a Personal Password that will assist the User –among other activities– in paying and collecting. The User shall keep the password in confidence and shall not share it with others. Furthermore, the User will be responsible for all actions requiring the use of his/her User’s Nickname and Password, which means that he/she will be responsible for paying all fees accrued resulting from the use of that User’s Nickname and Password. If the User has evidence that a third party knows his/her Password, he/she must change it by selecting “my Personal Data” from the Pagadito menu.

III. Confidentiality of information

Pagadito shall take all measures within its power to protect the privacy of the Users’ information. Therefore, Pagadito shall not share Personal Information either in an onerous or free manner, except in the ways set out in this document. In addition, the User authorizes Pagadito to provide Personal Information totally or partially to companies controlled, controlling or associated with Pagadito.

Particularly, in relation to Pagadito Comercios, Pagadito handles confidentially all Pagadito Comercios Purchasing Users’ information, so that Pagadito Comercio only knows the necessary information about the Purchaser and not the Purchasing User’s relevant financial or economic data.

In the case of court orders or before any public authority in which Pagadito finds itself under obligation to provide information, Pagadito does not hold itself responsible for such information. Also in case third parties unlawfully gain access to some information, Pagadito does not take responsibility for the use of the information.

IV. Security and storage of information

Pagadito believes the information of its Users is an asset that must be protected from any loss or unauthorized access. Therefore, it uses different security techniques to protect such data from unauthorized access by Users inside or outside the company. Pagadito binds itself to comply with all applicable laws relating to security measures that apply to Personal Information to reduce such risk. Pagadito is certified by VeriSign and PCI DSS.

Pagadito has hardware, software and encryption from companies that provide quality protection tailored to the type of information stored.

Despite this, it is necessary to consider that perfect security does not exist on the Internet; therefore Pagadito is not responsible for any unlawful appropriation and violation of its systems and databases and the use of such information by any unauthorized person.

All Users’ personal data will be stored in an automated database located in Panama and/or El Salvador. When the User joins Pagadito, he/she confirms that he/she has been informed of the residence is of this database and authorizes the international transfer of his/her data in those cases where his/her  country of domicile is different from the residence of the database.

V. How does Pagadito use information?

Collecting information makes it possible to provide Users more convenient functions and services and personalized services for their own benefit. Personal information collected has the following purposes:

1. Disclose information regarding the buying behavior and account profile related to the Card to the acquiring banks and Credit Card Associations in order to reduce or eliminate fraud and illicit behavior.

2. Pagadito will provide the interested parties, through email or the website, only the User’s Nickname data to facilitate transactions between them. For personal data such as name, phone, e-mail and address it will require the express permission of Pagadito. This information may only be used by stakeholders to complete the operation originated from Pagadito.  This information can only be used by the interested parties to end the operation originated by Pagadito.

3. Carry out internal studies on the interests, location and behavior of the Users to offer the best services and provide them with information of their interest according to their needs.

4. Develop marketing and advertising initiatives of the offers, contents and services through the analysis of web pages visited and Users’ searches to enhance their presentation.

5. Send information about new services, news about Pagadito, and advertising about products or services of interest to the User. The User hereby expressly authorizes Pagadito to send information about its services, but the User may request not to be included in the lists for sending this information. To do this, go to "Change Notification Preferences" shown in Section IX.

6. If the User is a winner of a Pagadito promotion, he/she consents to the disclosure of/her name, personal information and photographs of him/her or his/her family, in advertisements or promotional material without any compensation.

7. Share Personal Information with service providers or outsourcers such as transport, media or intermediaries in the management of payments, insurance, call centers, loyalty programs in order to improve or facilitate services and operations. Pagadito will take care that certain standards are met through the signing of privacy agreements of Users’ information. However, Pagadito does not take any responsibility for the misuse of the information by these providers. Sometimes, providers will collect information directly from Users and in these cases, the User may be notified of this activity, and it is at the discretion of the User what information he/she wants to provide and the uses that will be made of this information. In case the User supplies additional information on its own initiative, providers will use this information according to their own policies; therefore, Pagadito will not take any responsibility for such use. If it is decided to disclose information to third parties other than the suppliers referred to, the consent of the User will be required.

8. In case of disputes between Users and Pagadito, the latter may provide Personal Information to entities such as insurance companies, conciliators, arbitration courts or any other competent court.

VI. Use of information by other Users

Pagadito has a policy of restricted access of a User's Personal Information to other Users. Users may only use Personal Information of other Users obtained from the site for: a) communications relating to Pagadito constituting requested and authorized commercial communications, b) using services offered on Pagadito such as deposits, insurance, shipping or transportation and fraud claims c) any other purpose for which the corresponding User expressly consents once he/she has been notified in advance of legally required information. Furthermore, the information accessible to the User in the method stated above cannot be disclosed to other Users or third parties without proper authorization from Pagadito or the User who owns the account. In addition, Users are forbidden to add any other email or in any other means, another Pagadito User’s notification address or any other information.

VII. Legal Requirements

Pagadito will cooperate with the judicial or administrative authorities to ensure full compliance with the law and in order to safeguard the integrity and security of the company and their Users. Therefore, upon request from any authority, for investigation purposes, Pagadito may provide Users' personal information in cases such as: Protection of industrial and intellectual property rights, fraud prevention and other matters, and on the other hand, the User authorizes Pagadito Comercios to provide – at its own discretion– the information it deems appropriate for faithful compliance with the law.

Pagadito at its own discretion and when deemed necessary on the grounds that a User’s activity is suspicious or there is evidence of attempts to commit a crime or harm a person, may provide a User's Personal Information to other Users or third parties to enforce the Agreements and Conditions of Use of Pagadito and other policies of the Site and for the purpose of cooperating with the enforcement of the law. This power shall be exercised by Pagadito regardless of whether or not there is a court or administrative order to the effect.

 VIII. Pagadito Information tools

Cookies

Pagadito may use a tracking system through the use of cookies. Cookies are files that are installed on a hard drive and have a limited life while helping to personalize services. Cookies are important because there are some applications that can only be provided under this system, moreover, these are used in order to understand the interests, needs, location and behavior of Users and thus provide a better service; Cookies may also be used to promote and enforce the security rules of the site.

Some of the uses Pagadito may do with the Cookies may include: a) avoid the User having to enter his/her password too often during a browsing session, b) to account for and verify registrations, User activity and others. The purpose of the installation of cookies is always for the benefit of the User who receives it, and will not be used for any other purposes other than Pagadito’s.

Therefore, the Users and / or visitors to the site acknowledge and accept that Pagadito may use this system. The installation and retention of cookies in the User's computer may be deleted whenever the User so desires. To find out how to remove cookies from the system it is necessary to review the Help section (Help) on the browser used by the User. It is clarified that these policies cover the use of cookies by this site, so it is established that Pagadito does not control the use of cookies by any third parties.

Web Beacons

Pagadito may also use Web beacons. A web beacon is an electronic image, also called single-pixel (1 x 1) or transparent pixel that is placed on a Web page code. A web beacon has similar purposes but in addition to cookies, a Web beacon is used to measure traffic patterns of Users from one page to another in order to maximize traffic as it flows through the Web. The Users and visitors of Pagadito Web site know and accept that Pagadito shall use a tracking system by means of Web beacons.

IX. Change in notification preferences

If the User does not want to receive emails containing advertisements, promotions or news from Pagadito he/she can change notification preferences in the Mi Pagadito Section. In this section the User may choose his/her preferences to be taken into account by Pagadito in promotions, advertising and news.

X. Rights to access, rectify and cancel personal information

The User has the right to access, modify and cancel his/her Personal Information. On the other hand, he/she undertakes and is responsible for the truthfulness, accuracy and validity of the information provided and agrees to keep it updated. Once registered with Pagadito, the User may review and modify the information submitted such as:

1.     The User nickname and email address, however, for security purposes Pagadito retains the previous information.

2. The information provided at the time of registering, such as: company, domicile, zip code, country, telephone number, fax number, email, etc.

3. Personal security Code.

The purpose of keeping some information the User has requested to be removed is so that it may be used in cases of disputes or claims or to identify problems and solve them. Also, for security reasons, technical and legal purposes, the User should not expect his/her Personal Information is definitely and automatically removed from the databases.

Users are required to update their information as the data must be modified. The updating of information will be made through Mi Pagadito Section.

Pagadito may change at any time the terms and conditions of the Privacy Policy. If it decides to make any material changes to the Privacy Policy, Users will be notified by posting an updated version of the Policies in this section, by sending a notice or posting it on the home page or other sections of the site to keep changes updated.

If any material changes are made to the way Personal Information is administered, the User will be notified to allow the User to make an informed decision as to whether to accept his/her Personal Information is used as proposed. If he/she does not accept these terms, then the contractual relationship will be dissolved and his/her Personal Information will not be used in another way other than the one it was reported when collected. The User’s silence will be taken as an acceptance of the changes.

XI. Final Considerations

About Minors

To access the services, the User must be a person with legal capacity to enter into a contract, so, people who do not meet this requirement must abstain from registering on the site unless they do so through their legal representative.

Validity

The privacy policies described here are effective upon acceptance by the new Users and are valid from March 1, 2011.