Privacy Notice

1. Identity of the Data Controller

Cuentas Claras LATAM, with address in Jalisco, Mexico, is responsible for the processing of your personal data in accordance with the Federal Law on Protection of Personal Data Held by Private Parties (LFPDPPP, DOF March 20, 2025) and its Regulations.

Privacy contact email: privacy@cuentasclaraslatam.com

2. Personal Data We Collect

• Identification data: name, email address, date of birth, and optionally, username (@username). Date of birth is required to verify age eligibility in accordance with applicable law.
• Contact data: phone number, voluntarily provided by the user.
• Usage data: registered expenses, groups created, activity history within the Application.
• Financial and asset data (optional): payment method information voluntarily provided, which may include banking data (such as account numbers), electronic payment platform identifiers (such as PayPal, Mercado Pago, RappiPay), and cryptocurrency wallet addresses (such as Bitcoin, Ethereum, USDT). Processing of this data requires the user's express consent.
• Technical data: device type, operating system, session identifiers, and push notification tokens.
• Files: images or receipts voluntarily uploaded by the user.
• Internal identifiers: unique invitation code automatically assigned to each user to facilitate connections between users.

Sensitive data: We do not collect sensitive data relating to racial origin, health status, religious beliefs, sexual orientation, or biometric data. Financial and asset data you optionally provide receives the enhanced treatment established by applicable law for this type of information.

3. Purposes of Processing

Primary purposes (necessary for the service):

• Creating and managing your user account, including age eligibility verification through the provided date of birth.
• Enabling the registration and organization of shared expenses.
• Facilitating interaction between users (friendships, groups, shared expenses).
• Allowing other users to find you through your username or invitation code.
• Sending notifications related to your expenses, groups, and requests.

Primary purposes requiring express consent:

• Securely storing and sharing the payment method information you voluntarily provide, including banking data, payment platform identifiers, and cryptocurrency wallet addresses. This consent is granted expressly at the time of registering each payment method within the Application, through a checkbox that must be actively checked. Registration of payment methods other than cash and the "Other" field is restricted to users over 18 years of age.

Secondary purposes (optional — may be revoked):

• Improving the Application's functionality and user experience through aggregated usage analysis.
• Generating internal usage statistics in aggregated and anonymous form.

If you do not wish your data to be used for secondary purposes, you may communicate this to privacy@cuentasclaraslatam.com.

4. Service Providers and Data Transfers

To operate the Application, your data may be processed by the following service providers, whose servers are located in the United States:

• Amazon Web Services (AWS): authentication via Amazon Cognito and email delivery via Amazon SES.
• Supabase: database and file storage.
• Firebase (Google): aggregated usage analytics, technical error reporting, and push notification delivery.
• Cloudflare: network protection, DNS management, and website content delivery.
• RevenueCat: premium subscription management.
• Apple (App Store) and Google (Google Play): subscription payment processing.

These providers are contractually bound to protect your personal data in accordance with their respective privacy policies and not to use it for purposes other than those described herein.

We do not sell, trade, or share your personal data with third parties for advertising or marketing purposes. The Application does not display third-party advertising.

Within the Application, certain data is shared with other users:

• Your name and username (@username), if configured, are visible to users who search for you to add as a friend.
• Expenses you register are visible to the participants of that expense.
• Your registered payment method information is only visible to users with whom you share expenses, if you configure it that way.

5. Your Rights Over Your Personal Data

You have the right to Access, Rectify, Cancel, or Object to the processing of your personal data (ARCO Rights). To exercise these rights, send a request to privacy@cuentasclaraslatam.com including:

• Your full name and email address registered in the Application.
• The right you wish to exercise and a clear description of what you request.
• Any document verifying your identity.

We will respond within a maximum of 20 business days. The parent or legal guardian of a minor may exercise these rights on behalf of the minor.

Data portability format: When you request portability of your personal data, we will deliver it in JSON or CSV format — structured, machine-readable formats that allow transfer to other systems.

6. Consent Withdrawal

You may withdraw your consent to data processing at any time by sending a request to privacy@cuentasclaraslatam.com. Please be aware that withdrawal may result in inability to continue using the Application. The mechanisms for withdrawing consent will be at least as easy as those used to grant it.

7. Account and Data Deletion

You may request deletion of your account and personal data at any time from the Application settings or by sending a request to privacy@cuentasclaraslatam.com. Upon deleting your account:

• Your account will be deactivated and your access credentials deleted.
• Your name will remain visible in shared expenses with other users, accompanied by the label "deleted account", so other participants can identify the expense history.
• Files you uploaded (receipts, proof of payment, avatar) will be deleted.
• All your payment method information (banking data, cryptocurrency wallets, platform identifiers) will be deleted.
• Deletion is executed after a 7-day grace period during which you may cancel the request.

8. Data Retention

Your personal data is retained while your account remains active. Upon account deletion, only your name associated with existing shared expenses will be retained to preserve the integrity of other users' records. The rest of your personal data will be deleted once the grace period ends.

9. Minors

The Application is available to persons over 13 years of age. Processing of personal data of users under 18 requires the express consent of their parent or legal guardian.

Cuentas Claras LATAM has no obligation or technical capacity to independently verify the age of users or the existence of parental consent. Responsibility rests exclusively with parents or legal guardians.

10. Security Measures

We implement administrative, technical, and physical security measures to protect your data, including:

• Encrypted connections via SSL/TLS.
• Access control through secure authentication with cryptographically signed tokens.
• Encryption of financial and asset data in the database, including banking data and cryptocurrency wallet addresses.
• Database-level security policies (Row Level Security).
• Access and activity monitoring.
• Controls and mechanisms to ensure the confidentiality of data by all persons involved in its processing.

Although we implement reasonable security measures, no computer system is completely secure. Cuentas Claras LATAM cannot guarantee the absolute security of information transmitted or stored in the Application.

11. Analytics Technologies

The Application uses Firebase Analytics and Firebase Crashlytics to collect usage data in aggregated form to improve the service and detect technical errors. This data is not used to identify individual users for advertising purposes.

12. Advertising and Tracking

The Application does not display third-party advertising or use tracking technologies for advertising purposes. No personal data is shared with advertising networks, and user activity is not tracked outside the Application. The only usage data collected is through Firebase Analytics and Firebase Crashlytics for the purposes described in the previous section.

13. Changes to This Privacy Notice

We reserve the right to modify this Privacy Notice. Any changes will be notified through the Application. The current version will always be available within the Application and on our website: cuentasclaraslatam.com

14. Contact and Competent Authority

For any questions or requests related to your personal data:

privacy@cuentasclaraslatam.com

If you believe your data protection rights have been violated, you may file a complaint with the Secretaría Anticorrupción y Buen Gobierno (SABG), the authority responsible for personal data protection in Mexico, at: www.gob.mx/buengobierno