Privacy Statement

An open and honest statement about your privacy with us

Privacy

Cartera Privacy Policy

Welcome to the Cartera Privacy Policy, This explains how we collect, store, protect, and share your information, and with whom we share it. We suggest you read this in conjunction with our brilliant T&C’s. Whilst you’re enjoying the Cartera mobile application (“App”), we collect some information about you.

Cartera is a service based in the Philippines although once installed the app can be accesses all over the world, and your information will be sent to and used in the Philippines regardless of the country you reside in. This Policy explains how we protect your personal data when we transfer it overseas, so please read very carefully!

If you have any questions or comments about this Policy, please feel free to contact us at sales@cartera.com.pm

COLLECTION OF INFORMATION.

REGISTRATION INFORMATION

When you download the App and create an account (“Account”), we may collect certain information (“Registration Information”) about you, such as:

Name;
Username;
Email address;
Mobile number;
Gender identity;
Date of birth;
Location; and
Login information

You will also be required to create a password in connection with the registration of your Account. Once you register, you will be able to review and change this information at any time by accessing your “Settings” page! You control your user profile and are able to correct or update (other than your email address, date of birth, gender) your information at any time by just logging in to the Cartera App.

The information we collect helps to enhance the Cartera service and verify our Users (Machines are not welcome!!).

ADDITIONAL INFORMATION

We may ask you to provide your full name, address and email address. Such details may be shared with third parties for purposes relating to, for example, any of our loyalty programs, sending gifts or delivery.

We may also collect additional information in connection with your use of Cartera, for example if you use our electronic messaging function.

If you contact our Customer Support team, we will receive your email address, and may track your IP address as well as the information you send to us to help resolve your query. We will keep records of our communications with you, including any complaints that we receive from you.

For safety and security and to ensure you have the best possible user experience, we require users to verify their accounts and might ask for your phone number. We want to make sure you are not a robot! And we also want to avoid fake Cartera accounts being created which can be used for malicious activities and cybercrime – they threaten the Cartera network and ruin things for everyone.

To prevent abuse of the app/site, Cartera uses manual decisions to block accounts as part of its anti-spam procedures. In order to do this, our systems check accounts and messages for content that indicates breaches of our Terms and Conditions of Use. If an account or activity meets certain criteria that demonstrate that the Terms and Conditions of Use are likely to have been breached, the relevant account will automatically be blocked. All users of accounts that have been blocked will be notified that their account has been blocked and affected users can contact Cartera to contest the decision.

Finally, we want to keep in touch with you to make sure you know about the great promotions and offers we have available. If you’ve told us it’s OK, we will use your email address or number to send you information on these. You can withdraw this consent at any time by contacting us via email.

DATA STORAGE

By using the Cartera service, you acknowledge that Cartera is a global app operating through servers located in a number of countries around the world, including the Singapore. If you live in a country with data protection laws, the storage of your personal data may not provide you with the same protections as you enjoy in your country of residence.

GEOLOCATION INFORMATION

If you turn these features on, when you use your mobile, we will collect information about WiFi access points as well as other location information about your longitude and latitude and may save your device’s coordinates to offer certain features to you. This information helps us identify your physical location and we may use it to personalize and protect the service and make it easier for you to interact with other providers.

If you have enabled location services, but wish to turn them off, you can do so by the following methods:

iPhone app — settings, privacy, location services, Cartera
Android — settings, location, Cartera, permissions, location

LOG AND USAGE DATA

We keep your personal information only as long as we need it for legitimate business purposes (as set out in Section 11 below) and as permitted by applicable law.

In practice, we delete or anonymize your information upon deletion of your account (following the safety retention window), unless:

we must keep it to comply with applicable law (for instance, some “traffic data” is kept for one year to comply with statutory data retention obligations);
we must keep it to evidence our compliance with applicable law (for instance, records of consents to our Terms, Privacy Policy and other similar consents are kept for five years);
there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users’ safety and security. For example, information may need to be kept to prevent a user who was banned for unsafe behavior or security incidents from opening a new account.

DEVICE INFORMATION

We may collect information about your device when you use the App including the unique device identifier, device model, operating system, and MAC address. In addition, if you permit us to do so, the App may access your device’s address book solely in order to add someone to your payment contacts.

COOKIES

Our cookies are small data files that are transferred to your computer’s hard disk and are basically a tool that stores information about website visits, recognizes you, and ensures site functionality and enables us to provide the services our members request.

The cookies we collect enable us to learn how people interact with Cartera, which in turn helps us make a better product for you! Cookies store information about your website visits and can recognize you and your preferences each time you visit the Cartera site. They help us to provide a better service to you!

Cartera’s use of cookies and local storage devices is basically related to the performance of Cartera’s site, such as analytics that help us determine how our site is performing and ensuring a smooth and trouble-free experience for our members.

Below is a table to explain Cartera’s cookie functions and why they’re used.

If for any reason you decide that you do not want all of your Cartera activities to be stored you may set your browser and mobile settings to block cookies and local storage devices, but please remember that if you do so, you may not be able to access all of the features Cartera!

We use the following types of cookies:

Cookie Functions

Cookie Purposes

Analytics and research

We use Google Analytics to collect information about how visitors use the site. The cookies collect information in an anonymous form, including the number of visitors to the App, where visitors have come from and the pages they visited. For more information about Google’s Privacy Policy, please visit http://www.google.com/intl/en/policies/.

Performance

We need to use certain cookies and save data to your local storage devices to ensure our members have the best possible experience. They assist with your navigation of our site, ensuring pages load quickly and respond promptly to your requests – no one likes slow pace technology!

Our use of cookies and local storage devices, including the specific cookie names, may change over time, but will generally fall into the above categories. We will notify you of any important changes to our use of cookies and local storage devices. Please visit this page regularly so that you are aware of any changes.

If you would like to know more about these clever and inedible cookies, including flash cookies/local storage devices, the following websites provide useful information:

USE OF INFORMATION.

Our main goal is to ensure your experience on Cartera is an enjoyable one. In order to deliver an enjoyable experience to you, we may use your Registration and other information to:

offer you our services and features;
contact you with information about the App (e.g., updates and new offerings);
personalize the App and the content we deliver to you;
conduct research and analytics about how you use and interact with the App;
resolve disputes; and
investigate fraud, protect our legal rights, and to enforce our Terms & Conditions.

DISCLOSURE OF INFORMATION.

Our policy is to not disclose your Registration Information, except in the limited circumstances described here:

Service Providers – We engage certain trusted partners to perform functions and provide services to us. We may share your Registration Information with these partners, but only for the purposes of performing these functions and providing such services e.g. information technology companies (hardware and software) which provide services to support our products.

Moderators – To monitor activity on the apps and approve content.

Payment Processing and Telecommunications Companies – To facilitate payments for services.

Law and Harm – We think it is very important that all Cartera behave whilst using the App. We will cooperate with all third parties to enforce their intellectual property or other rights. We will also cooperate with law enforcement enquiries from within or outside your country of residence where we are required to by law or to protect the vital interests of a person or entity. This may include preserving or disclosing any of your information, including your Registration Information, if we believe in good faith that it is necessary to comply with a law or regulation, or when we believe that disclosure is necessary to comply with a judicial proceeding, court order, or legal request; to protect the safety of any person; to address fraud, security or technical issues e.g. through anti-spam providers to protect the service from criminal activity or to protect our rights or property or those of third parties. In such cases we may raise or waive any legal objection or right available to us.

Business Transfers -In the event that Cartera or any of our affiliates undergoes a business transition or change of ownership, such as a merger, acquisition by another company, re-organization, or sale of all or a portion of its assets, or in the event of insolvency or administration, we may be required to disclose your personal data.

Aggregated Information – We may share aggregated information with third parties that includes your personal data (but which doesn’t identify you directly) together with other information including log data for industry analysis and demographic profiling. You may opt-out of receiving marketing messages by using the opt-out mechanisms and links provided in each email.

We ensure these parties must adhere to strict data protection and confidentiality provisions that are consistent with this Policy. Measures are taken to ensure that the data shared is non-attributable to the greatest extent possible.

WHAT OTHERS MAY SEE ABOUT YOU.

We think our users are awesome, Our App is designed to make it easier for you to connect with services and people where needed to meet your request but we do not share any information that isn’t required for the transaction to take place.

MODIFYING YOUR REGISTRATION INFORMATION.

You may access or modify the Registration Information you provided at any time or permanently delete your Account (we hope you don’t!)

When your Account is deactivated, we take reasonable efforts to make sure it is no longer viewable on the App to partners. For up to 30 days it maybe still possible to restore your Account if it was accidentally or wrongfully deactivated. After 30 days, we begin the process of deleting your Account from our systems. We are not responsible for any information, transactions, money, points, or other content that is deleted from our systems resulting from the deactivation of your Account.

To prevent abuse and/or misuse of KAP by a User following termination or deletion of a profile/Account we shall retain such information as we deem in our sole discretion may be necessary to ensure that User does not open a new Account and profile in breach of our insert our T&C’s and to ensure compliance with all laws and regulations.

Warning: Even after you remove information from your profile or delete your Account, copies of that information may still be viewable and/or accessed to the extent such information has been previously shared with others, or copied or stored by other Users or to the extent such information has been shared with search engines. We cannot control this, nor do we accept any liability for this. If you have given third party applications or websites access to your personal information they may retain such information to the extent permitted under their terms of service or privacy policies.

Removed and deleted information may persist in backup copies for up to 30 days to enable restoration, but will not be available to others in the meantime.

OUR POLICY TOWARDS AGE.

Although we want as many people as possible to enjoy our platform, you have to be at least 18 years old to use the App, mobile web app and web version.

KAP does not knowingly collect any information about or market to children, minors or anyone under the age of 18. If you are less than 18 years old, we request that you do not submit information to us. If we become aware that a child, minor or anyone under the age of 18 has registered with us and provided us with personal information, we will take steps to terminate that person’s registration and delete their Registration Information from KAP. If we do delete a profile because you violated our no children rules, we may retain your email and IP address to ensure that you do not try to get around our rules by creating a new profile.

CHANGES TO THIS POLICY.

As Cartera evolves, we may revise this Privacy Policy from time to time. The most current version of the policy will govern our use of your information and will always be at Cartera.com.ph/privacy-terms/. If we make a change to this policy that, in our sole discretion, is material, we will notify you, for example, via an email to the email associated with your Account or by posting a notice within Cartera. By continuing to access or use the App after those changes become effective, you agree to be bound by the revised Privacy Policy.

SECURITY.

Here at Cartera we pride ourselves on taking commercially reasonable security measures to help protect your information against loss, misuse and unauthorised access, or disclosure. We use reasonable security measures to safeguard the confidentiality of your personal information such as secured servers using firewalls.

Unfortunately no website or Internet transmission is ever completely 100% secure and even we cannot guarantee that unauthorised access, hacking, data loss or other breaches will never occur, but here are some handy tips to help keep your data secure:

Please make sure you log out of your Account after use as you never know who may stumble onto your device.
Please don’t share your password with anyone else.
We recommend you change your password periodically.

If you ever think someone has had access to your passwords, please report it to the relevant platform and change your password immediately. We cannot guarantee the security of your personal data while it is being transmitted to our site and any transmission is at your own risk.

WE EXPRESSLY DISCLAIM ANY REPRESENTATION OR WARRANTY, WHETHER EXPRESS OR IMPLIED, WITH RESPECT TO ANY BREACHES OF SECURITY, DAMAGE TO YOUR DEVICE, OR ANY LOSS OR UNAUTHORISED USE OF YOUR REGISTRATION INFORMATION OR OTHER DATA.

YOUR UK AND EU RIGHTS.

Under law, users have the right to lodge a complaint with data protection regulators. You can find out how to raise a concern you may get in touch with your local Data Protection Regulator who may liaise on your behalf.

You have a number of rights under European Data Protection law if you are an EU citizen.

Right to be informed: what personal data an organization is processing and why (this notice).
Right of access: you can request a copy of your data.
Right of rectification: if the data held is inaccurate, you have the right to have it corrected.
Right to erasure: you have the right to have your data deleted in certain circumstances.
Right to restrict processing: in limited circumstances, you have the right to request that processing is stopped but the data retained.
Right to data portability: you can request a copy of your data in a machine-readable form that can be transferred to another provider.
Right to object: in certain circumstances (including where data is processed on the basis of legitimate interests or for the purposes of marketing) you may object to that processing.
Rights related to automated decision making including profiling: there are several rights in this area where processing carried out on a solely automated basis results in a decision which has legal or significant effects for the individual. In these circumstances your rights include the right to ensure that there is human intervention in the decision-making process.

Cartera has designated a Data Protection Officer and they can be reached by emailing sales@cartera.com.ph

If you want to exercise any of your rights listed above please contact our DPO.

How does Cartera protect my personal data?

Cartera has implemented appropriate security measures to protect and prevent the loss, misuse, and alteration of the information under our control, including your personal data. Our technical experts at Cartera work hard to ensure your secure use of our site.

While we take reasonable precautions against possible security breaches of our website, member database and records no website or Internet transmission is completely secure and we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. We urge you to take steps to keep your personal data safe (including your password) and to log out of your account after use. If you lose your password or give it out, or another service provider that you use suffers a data breach and you have used the same credentials with that service provider as you have with Cartera, your personal data may be compromised. If that happens, please report it to Support via sales@cartera.com.ph.

Where is my personal data kept?

We want you to be able to access Cartera wherever you happen to be in the world. To enable us to provide that service, we currently store our data within a popular SOC compliant third party cloud provider in Singapore. We ensure that the data is adequately protected by ensuring that valid, legal mechanisms are in place such as: EU approved model clauses, US privacy shield certification (please note that Cartera is not Privacy Shield certified but implementing robust contractual standards. If you want more information relating to the nature of the safeguards we have in place, please email sales@cartera.com.ph

Does Cartera collect any other personal data about me?

If you contact our Customer Support team sales@cartera.com.ph we will receive your email address, and may track your IP address, as well as the information you send to us to help resolve your query. We will keep records of our communications with you, including any complaints that we receive from you about other users (and from other users about you) for 5 years after deletion of your account.

Does Cartera use my personal data for any other purpose?

If we intend to do this, we will contact you for your prior approval.

We use your personal data to resolve disputes, troubleshoot problems and enforce our Terms and Conditions of Use.

Under data protection laws, we are only permitted to use your data when we have a lawful basis to do so. The table below provides an overview of the legal bases that we rely on to use your data. Where the legal basis is consent, you can withdraw consent at any time. Where the legal basis is legitimate interests, you have a right to object to our use of your data. We explain in the relevant sections in this Policy how you can withdraw consent or opt-out of certain data uses (where applicable).

Purpose for which data is used

Data

Legal basis

To provide you with the Cartera services

Name, email address, date of birth, location

Contractual necessity

To facilitate money and points exchange services

Consent

To take payment for premium services

Payment card details

Contractual necessity and legitimate interests – we have a legitimate interest in receiving payment for our premium services or facilitating your transaction from accounts you hold with third-parties.

To serve targeted advertisements to Users of the App

Demographic and location information

Legitimate interests – it is in our legitimate interests to target advertisements so that users see relevant advertisements and to allow us to generate income from advertising revenue

To send you marketing information about our offers and services

Email address

Legitimate interests – it is in our legitimate interests to promote our products and services

Consent

To carry out research and analysis to help us improve the App

Log and usage data, including IP address, browser type, referring domain, pages accessed, mobile carrier and search terms

Legitimate interests – it is in our interests to analyse the way in which Users are accessing and using our services so that we can further develop the App and improve the service

To respond to correspondence and queries that you submit to us

Email address and IP address

Legitimate interests – it is in our legitimate interests to respond to your queries to ensure that we provide a good service to Users and troubleshoot problems

To block accounts as part of our anti-spam procedures

Email address, IP address and IP session information, social network ID, username, user agent string

Legitimate interests – it is in our legitimate interests to prevent unauthorized behavior and to maintain the safety and security of our services

ABOUT US.

Your access to the Cartera service, as well as this Privacy Policy are governed and interpreted by Philippine laws, other than such laws, rules, regulations and case law that would result in the application of the laws of Philippines government. By using the service, you are consenting to the exclusive jurisdiction of the laws of Philippines government. You agree that such courts shall have personal jurisdiction and venue to waive any objection based on inconvenient forum. You agree that you will not file or participate in a class action against us. In the event there is a discrepancy between this English language version and any translated copies of the Policy, the English version shall prevail.

EFFECTIVE DATE

This Privacy Policy was last updated on 12/12/2020