Last modified: Dec 14th, 2023

This privacy policy (hereinafter referred to as “privacy policy”, the “policy”, equally) describes how Crombie.dev (“Crombie”, “us”, or “our”) gathers, uses, and divulges certain information, included your personal data and the options you can exert with regard to said information.

Crombie is a software development company specialized in the fields of Design and Prototyping, Code Development, Project Management, and Consulting. Some of the services provided by Crombie are: UX/UI Design, Custom Web and Mobile Development (Corporate Intranets and Extranets / Loyalty & Wellness Platforms/ e-Learning Platforms/ Corporate Apps), e-Commerce Platforms (B2B, B2C), Integrations (ERPs / CRM / HRM), Staffing, QA testing, DevOps, data migration, among others (‘Services’).

This privacy policy governs data processing and transferring directly or indirectly gathered when hiring our Services, by simply engaging with our website: https://crombie.dev/en (“web site”) or through any means of communication (“Visitors” and “Clients” both referred to as “you”).

POLICY CHANGES:

We reserve the right to make any changes to this privacy policy whenever we deem necessary, at our sole discretion. The most recent version of the privacy policy will always be published on our website, and the update date will be reflected on the header “last modified”. Each time you access Crombie’s website, please make sure you have checked this policy’s content.

CONTACT AND REGISTER RESPONSIBLE INFORMATION:

4R Soluciones S.R.L is the entity responsible for the register, formed under Argentine law, with address in San Gerónimo 2542, Piso P.B, Departamento ‘2’, Santa Fe city, Santa Fe province. You may communicate with us and our privacy team as follows:

• Contact information of our Responsible for the Personal Data Protection Program: privacy@crombie.dev

HOW IS THE GATHERED DATA CATEGORIZED AND FOR WHAT PURPOSE?

We can gather your data according to your engagement with us:

Individually identifiable information: meaning, information that identifies a person or that could identify a person by means of reasonable effort (“Personal Data”).

Next are details the types of personal data processed, the purpose, and our process operations:

Visitors / Clients:

• Data set: if you get in touch with us voluntarily through any form available in our website or e-mail, it is possible you will be requested to provide certain information, such as your full name, your e-mail address, and any other additional information you choose to share with us (“contact information”). Said information will be processed to provide a reply to your enquiry.
• Purpose and Operation: All e-mails and other instances of communication we have with you may be processed and filed to improve our customer service.
• Legal Basis: In case we deem it necessary, we may continue keeping the information, for example, in case of complaints or to provide you with assistance (if applicable). We will process the contact information subjected to our legitimate interest.

• Job Offers:

• Data Set: When a visitor applies to a job offer posted by Crombie, we will process the received resume, included any information associated with their full name, e-mail address, phone number, education, skills, work history, and picture (provided it was procured by said applicant). Additionally, we may gather more information from public and online sources, and previous employers, and then combine said information with the data provided by the applicant (“recruiting information”, as a whole).

• Purpose and Operation: we will gather recruiting information to process the application, for hiring management purposes, for additional hiring steps (for example, an interview) and to enable us to comply with corporate governance, and legal and regulatory requirements. If you are hired by Crombie, your recruiting information may be filed in the Human Resources Department as part of your employment record and will be subjected to our corporate management. With the purpose of managing all jobs applications, we make use of an external service provider, which is, at the moment, People Force. Said providers are contractually bound to keep their data confidential and safe, and not to use the recruiting data for any purpose that is not detailed in this policy.

• Legal Basis: we will process the recruiting information subjected to your consent. Whenever we request you provide health related information, we will process said data based on your consent, which you can withdraw at any time. We will retain your recruitment information for record keeping and defense in case of future legal claims. We will process said information subjected to our legitimate interest, or if you have given your consent to contact you in the future.

Management of building access control and other functions related to surveillance and security:

• Data sets: identification data.
• Purpose and operation: we will process your data with the purpose of preserving the safety of goods, people, and facilities under their management.
• Legal Basis: we will process your information subjected to our legitimate interest.

Advertisement purposes and commercial prospection:

• Data sets: identification data.
• Purpose and Operation: To send commercial communication about our own products and/or services, whether similar o not to the ones hired or requested by you through the means in place for this purpose, provided you have not opposed to receive said instance of communication at the moment of data gathering or after receiving any instance of commercial communication, and whenever it is required, provided we have your consent.
• Legal Basis: we will process your information subjected to our legitimate interest regarding the instances of commercial communication sent through electronic means. If applicable, we will request your consent.

Newsletter Subscription:
In case you subscribe to our Newsletter, you will be requested to provide your contact details, as well as your e-mail address. We will make use of your e-mail address to send you our Newsletter and any other Marketing materials. We will process this contact information subjected to your consent. You may withdraw your consent at any time through the link “Unsubscribe” within the e-mail or contacting us directly.

Payment Information:
To make use of our services, it is possible you will be requested to provide usual billing information, such as name, e-mail, company name, fiscal data, address, job title within the company, mobile number, LinkedIn account. We will process this information in order to provide our services, perform the contract, and invoice you.

Please note that the real processing operation for each usage purpose and the previously detailed legal basis may suffer changes. We can gather different categories of your personal and non-personal data, depending on the nature of your engagement with the services provided by this company.

HOW LONG WILL WE KEEP THE DATA?
The personal data of the interested parties will be held for the period necessary for the fulfillment of the previously detailed purpose for which they were collected.

WHAT SECURITY MEASURES DO WE IMPLEMENT AT CROMBIE?
At Crombie, we work to protect all personal data we gather and process. We have implemented physical, technical and organizational safety measures to comply with applicable laws and regulations. We minimize the amount of date stored in our servers, restrict the access to personal data only to employees (and whenever necessary for their fulfillment of their activities), contractors, and another collaborators.

Please note that we cannot be held responsible for non-authorized nor unwanted access beyond our control, and we make no warranty, express, implied or otherwise, that we will always prevent such access.

If you consider that your privacy has not been correctly handled, please reach out to: privacy@crombie.dev We will make a reasonable effort to notify you and the relevant authorities (if required by law) in case we notice a safety incident related to your personal data.

TO WHOM WILL WE PASS ON YOUR DATA?

Recipients of personal data: the disclosure of personal data stored in our register will only take place under the following circumstances:

1. Public Entities: Crombie may share personal data when required to do so by law, regulations or order, while keeping to relevant legal requirements and ensuring the data’s proper protection when shared.
2. Outsourced third parties: In the context of the execution of the contracts for provision of services, Crombie reserves the right to disclose personal data to outsourced third parties that take part in the implementation and performance of the hired services. These third parties are contractually bound to guarantee a level of security and confidentiality equivalent to the one offered by Crombie, and to use the data only for the purposes defined in the contract.
3. Group: To other companies that are part of CROMBIE GROUP.

WHAT ARE YOUR RIGHTS RELATED TO YOUR PERSONAL DATA?

Our goal is to be transparent regarding the information we gather so you can make the decisions you deem appropriate regarding the usage of your personal data. Therefore, you can make certain choices, rights and controls regarding your information. Depending on the nature of your relationship with us, your jurisdiction and the applicable data protection laws subjected to it, you have the right to control and request certain limitations or that certain rights be enforced.

Next, you can review the rights according to your engagement with us. Also, you will find different ways of exercising said rights.

1. 1. RIGHT TO INFORMATION: you have the right to confirm if we have gathered your personal data. If you wish to know if we have gathered your personal data, please check this Privacy Policy.

1. 1. RIGHT TO ACCESS: you have the right to know which specific personal data we have about you, and to receive a copy of said information or access to it. If you wish to receive a copy of your personal data, please fill out the available form “Access Rights Request” here.

1. 1. RIGHT TO RECTIFICATION: you have the right to correct inaccurate personal date stored in our database, taking into account the nature and purpose of each processing activity. If you wish to correct your personal data, please fill out the available form “Personal Data Rectification, Updating, or Deletion Request” here.

1. 1. RIGHT TO OBLIVION, RIGHT TO DELETE: under certain circumstances, you have the right to request we delete the personal information we have in our database about you. In case you wish to exercise your right to oblivion, please fill out the available form “Personal Data Rectification, Updating, or Deletion Request” here.

1. 1. RIGHT TO APPEAL OR MAKE A COMPLAINT: in case we deny taking measures regarding your request, you will be informed about it without undue delay, as required by applicable laws. The notification will include a justification for refusing to take measures and instructions about how you can file an appeal, if applicable. In the EU, there is a right to lodge a complaint with the supervisory authority.

1. NON-DISCRIMINATION: discrimination may include refusal to provide service, to supply a different level or quality of service, or charge different prices. We do not discriminate our clients or users.

PRIVACY OF CHILDREN:

The services provided by Crombie are not meant to be used by children (“children”: an individual younger than the age defined by applicable law, which, in case of the EEA, is under 16 years), and we will not consciously process children information. We will immediately dismiss any information we perceive as belonging to a user regarded as a “child” as soon as we discover that said user shared that information with us. Please, contact us at: privacy@crombie.dev if you have reason to believe a child has shared information with us.