1. Introduction
Margintv (hereinafter, "we", "us", "our", or "the Company") is committed to protecting and respecting your privacy. This Privacy Policy sets out the basis on which we process any personal data we collect from you or that you provide to us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
This policy applies to information we collect when you use our website, when you communicate with us or request information about our services, and when you participate in real estate investment projects through our platform.
We comply with all applicable data protection laws in Bolivia, including Law No. 1360 on the Protection of Personal Data and other relevant regulations that protect the privacy of individuals.
2. Data we collect
We may collect and process the following data about you:
2.1 Information you provide to us:
- Identification data: full name, identity document number, nationality.
- Contact data: postal address, email address, telephone numbers.
- Professional data: occupation, company, position, academic background.
- Financial data: information about your financial capacity and investment interests (without collecting bank account or credit card numbers through the website).
- Communications: when you communicate with us, we keep records of that correspondence.
2.2 Information we collect automatically:
- Technical data: IP address, browser type and version, time zone setting, browser plugin types and versions, operating system and platform.
- Usage data: information about your visit, including the full URL clickstream to, through, and from our website, pages you viewed, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
2.3 Information from third parties:
We may receive information about you if you use other websites operated by us or services we provide. We also work closely with third parties (including, for example, business partners, subcontractors in technical, payment, and delivery services, advertising networks, analytics providers, search information providers) and may receive information about you from them.
3. Purposes of processing
We use the information we hold about you in the following ways:
- Service provision: To provide you with information, products, or services that you request from us or that we feel may interest you.
- Project management: To manage your participation in real estate investment projects, including communications about project progress, meetings, document distribution, and financial management.
- Service improvement: To improve our website, products, and services.
- Communications: To communicate with you, including notifications about changes to our services or policies.
- Security: To protect our website, our business, and your interests.
- Legal compliance: To comply with legal and regulatory obligations, including the prevention of fraud and money laundering.
4. Legal basis for processing
We process your personal data based on the following legal bases:
- Consent: When you have given your explicit consent to the processing of your personal data for one or more specific purposes.
- Contract performance: When processing is necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering into a contract.
- Legal obligation: When processing is necessary to comply with a legal obligation to which we are subject.
- Legitimate interests: When processing is necessary for the purposes of legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms that require personal data protection.
5. Retention period
We will retain your personal data only for as long as necessary for the purposes for which it was collected, including to satisfy any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Specific retention periods:
- Contact data for general inquiries: 2 years since the last communication.
- Customer and investor data: During the contractual relationship and 10 years after its termination (according to Bolivian tax and legal requirements).
- Browsing and analysis data: 26 months.
7. Your rights
Under Bolivian data protection law, you have several rights regarding your personal data:
- Right of access: You have the right to request a copy of the personal information we hold about you.
- Right of rectification: You have the right to correct data we hold about you that is inaccurate or incomplete.
- Right to be forgotten: In certain circumstances, you can request that your personal data be deleted from our records.
- Right to restriction of processing: Under certain conditions, you have the right to restrict the processing of your personal data.
- Right to data portability: You have the right to have the information we hold about you transferred to another organization in certain cases.
- Right to object: You have the right to object to certain types of processing, such as direct marketing.
- Right to withdraw consent: When the processing of your personal data is based on your consent, you have the right to withdraw that consent at any time.
If you wish to exercise any of these rights, please contact us using the details provided in the "Contact" section of this policy.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
We try to respond to all legitimate requests within one month. Occasionally, it may take us longer than a month if your request is particularly complex or if you have made several requests. In this case, we will notify you and keep you updated.
8. Data security
We have implemented appropriate security measures to prevent your personal data from being lost, used or accessed in an unauthorized way, altered or disclosed. Some of these measures include:
- Encryption of sensitive data
- Firewalls and intrusion detection systems
- Role-based access controls
- Security incident response procedures
- Regular security training for employees
- Periodic security audits
In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data according to our instructions and are subject to a duty of confidentiality.
We have implemented procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. International transfers
Since we operate in an international context facilitating global real estate investments, it is possible that your personal data may be transferred to and stored in destinations outside Bolivia. It is also possible that personnel operating outside Bolivia may access and process your personal data. This includes personnel working for us or for our suppliers.
Whenever we transfer your personal data outside Bolivia, we ensure a similar level of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will transfer your personal data only to countries that have been recognized by Bolivian authorities as providing an adequate level of protection for personal data.
- Where we use certain service providers, we may use specific contracts approved by relevant authorities that give personal data the same protection it has in Bolivia.
- Where we use providers based in the US, we may transfer data to them if they participate in the Privacy Shield, which requires them to provide similar protection to personal data shared between Europe and the US.
If you want further information on our specific practices regarding international data transfers, please contact us using the details provided in the "Contact" section of this policy.
10. Minors
Our website and services are not intended for children under 18 and we do not knowingly collect data relating to children. If we discover that we have collected personal data from a child without verification of parental consent, we will take steps to remove that information from our servers.
11. Policy changes
We may update this privacy policy from time to time. When we do, we will update the "last updated" date at the top of this privacy policy. In case of material changes, we will provide prominent notice on our website or send you a direct notification.
We encourage you to periodically review this privacy policy to be informed about how we are protecting your information.
12. Contact
If you have any questions about this privacy policy or our privacy practices, please contact us at:
Margintv
Av. Tumusla N°592 - Galeria Habana "1st Floor
La Paz, Bolivia
Email: privacy@margintv.com
Phone: +591 70543619
If you are not satisfied with our response to your inquiry or complaint, you have the right to lodge a complaint with the Bolivian data protection authority.