PERSONAL DATA PROCESSING AND PROTECTION POLICY

  1. GENERAL PROVISIONS

1.1. This Personal Data Processing and Protection Policy (hereinafter – the "Policy") defines the procedure for the processing of personal data by the Operator and the organizational and technical measures for their protection. The Policy is developed to ensure the rights and freedoms of individuals, including the right to privacy, personal and family secrets.

1.2. The Policy defines the procedure for the processing of personal data by the Operator and the organizational and technical measures for their protection. The Policy is developed to ensure the rights and freedoms of individuals, including the right to privacy, personal and family secrets.

1.3. Key Concepts

Personal data – any information allowing to directly or indirectly identify a specific individual. Processing of personal data – any action performed with or without the use of automation tools (collection, recording, systematization, storage, updating, use, transfer, blocking, destruction, etc.).

Site – an information resource available on the Internet at https://bothub.chat/ (including domains).

Cookies – small text files saved on the user's device via the browser.

Operator – BotHub S.R.L. (Republic of Costa Rica; Cedula: 3-102-137531), the copyright holder of the Site.

Subject – an individual who has visited the Site or used the services of the Operator.

1.4. The purpose of the Policy is to establish the procedure for the collection, storage, use, transfer, and destruction of personal data within the framework of the Operator's activities.

1.5. A person who has visited the Site or used the services of the Operator consents to the provision of their data to the Operator's software systems and third parties for the purposes specified in this Policy. In the absence of consent, it is necessary to stop using the Site.

1.6. Legal grounds for processing personal data:

  • consent of the Subject, given in written or electronic form;

  • civil law contracts concluded between the Operator and the Subject;

  • fulfillment of the Operator's obligations related to the provision of Site services.

  1. PROCEDURE AND CONDITIONS FOR PERSONAL DATA PROCESSING

2.1. Processing of personal data is carried out in accordance with this Policy and the User Agreement (offer).

2.2. Consent is given by checking the checkbox "I agree to the processing of my personal data" in a special form on the Site. Separate written consent is not required unless otherwise provided by mandatory regulations.

2.3. The Operator carries out mixed processing (automated and manual).

2.4. Third parties to whom data may be transferred:

Yandex.Cloud LLC (location – RF). Purpose – web analytics (Yandex.Metrica). The transfer is carried out in the volume necessary for the specified purposes, in compliance with this Policy.

2.5. The Operator transfers personal data to authorized government bodies in cases and in the manner provided for by applicable law and/or the requirements of such bodies that have entered into force.

2.6. After the purpose of collection is achieved or upon withdrawal of consent by the Subject, the data is destroyed. Destruction is documented by an act.

  1. COMPOSITION OF PROCESSED PERSONAL DATA

3.1. The Operator processes data of the following persons: Platform clients, site visitors, contractual counterparties, and their representatives.

3.2. Main purposes, list of data, and storage periods:

3.2.1. Compliance with tax and accounting requirements:

– Full name, identification/registration data, residential address, phone number, e-mail, bank details, etc.;

– contract duration period + 5 years.

3.2.2. HR and accounting (if necessary) – data specified above.

3.2.3. Conclusion and execution of the contract – data specified above.

3.2.4. Technical support – Full name, e-mail, phone number, IP.

3.2.5. User experience analysis – cookie, IP, metric data (12–24 months).

3.2.6. Registration on the Site and personal account – Full name, e-mail, IP, cookie.

3.2.7. Marketing and information messages – Full name, e-mail (until consent is withdrawn).

3.3. Biometric and special categories of data (ethnicity, religion, political views, health, etc.) are not processed.

3.4. Cookies can be blocked in the Subject's browser, which may limit the operation of some functions.

3.5. The Operator does not intentionally collect data of minors. Persons under 18 years of age should not provide data without the permission of legal representatives.

  1. ENSURING PERSONAL DATA SECURITY

4.1. The Operator applies a complex of legal, organizational, and technical measures:

  • access regulations established by internal documents;

  • training employees on data confidentiality;

  • logging access to information systems;

  • detection and elimination of unauthorized access;

  • protection means in accordance with ISO/IEC 27001.

4.2. After the purpose of processing is achieved, the data is destroyed within 30 days (or upon the Subject's request – within 10 working days, if necessary +5 days).

  1. RIGHTS OF THE SUBJECT

5.1. The Subject has the right to:

  • access their data;

  • supplement, update, block, destroy it;

  • withdraw consent;

  • defend their rights in court;

  • appeal the actions of the Operator to the Agencia de Protección de Datos de los Habitantes (Prodhab) and other authorized bodies of the Republic of Costa Rica.

5.2. The request is sent in writing or electronically to the address support@bothub.chat.

  1. LIABILITY OF THE PARTIES

6.1. The Operator compensates for losses caused to the Subject in accordance with the legislation of the Republic of Costa Rica.

6.2. Liability for the disclosure of information does not arise in cases where it:

  • was made public by the Subject themselves;

  • was received from a third party in a lawful manner;

  • was disclosed with the written consent of the Subject.

  1. DISPUTE RESOLUTION

7.1. Disputes are resolved through a claim procedure (10 days).

7.2. If an agreement is not reached, disputes are considered in the competent court at the location of the Operator, unless otherwise provided by mandatory consumer protection regulations.

  1. ADDITIONAL PROVISIONS

8.1. The Operator has the right to unilaterally change the Policy. The new version enters into force from the moment of publication on the site bothub.chat.

8.2. If individual provisions are found to be invalid, the Policy as a whole remains in force.

  1. OPERATOR DETAILS

Name (brand): BotHub Legal form: S.R.L. (Sociedad de Responsabilidad Limitada) Jurisdiction: Republic of Costa Rica Cedula: 3-102-137531 Address: San Jose, Central, Mata Redonda, Sabana Oeste, Avenida 12 Calle 90, oficinas del Bufete ERP Lawyers

PERSONAL DATA PROCESSING AND PROTECTION POLICY :: BotHub