Privacy Policy

Introduction

This Privacy Policy covers how Puntilla LLC collects, uses, discloses, and stores information about you (“personal information”) when you use our website or forms or attend in-person events or live demonstrations.
Puntilla acts as a data controller when collecting customer data to provide its services. 

What Information We Collect and How We Collect It

To provide our services to you and to ensure that our software and platform operate correctly, we collect various types of information, including personal information. When you use our website, sign up for our services, and use our company or platform, we collect the following categories of information:

Information you provide to us: 

  • Identifiers and Contact Information. If you use the contact information provided on the puntilla.us website to contact us directly, you agree to allow Puntilla to store and process your contact information. We’ll get your contact information, which could include, depending on how you contact us, your email address, phone number, SMS Opt-in consent, name, company name, job title, reason for contacting us, and postal address.
  • We collect and store customer contact and account information that you provide when signing up for and using our services and completing a Puntilla form. This information may include your name, email address, mailing address, phone number, job title, payment and billing details, and any other information you choose to provide (such as a user-submitted photograph for our data subject access request feature).

When you use our website or complete a company form, we automatically collect the following information: 

  • Internet Protocol Address (“IP address”). IP addresses are assigned by your Internet service provider (e.g., Comcast/Xfinity, AT&T, Time Warner, Verizon, Charter, etc.) to the modem used to access the Internet for connected devices in your home and/or workplace. Any devices using the modem to access the Internet may broadcast the same IP address. At home, connected devices could include one or more laptop/desktop computers, tablets, mobile phones, smart/connected TVs, and gaming consoles. At work, connected devices could include one (or all) floor(s) in an office building. Our website receives your IP address from your Internet browser whenever you request a file or web page.
  • User-Agent. Due to the nature of how the Internet works, we may receive information (known as “User-Agent”) automatically sent by your web browser, such as data associated with the source device’s Internet browser/content delivery software (e.g., Microsoft Explorer, Mozilla Firefox or Google Chrome). The User-Agent information we receive may also include device type (e.g., computer, tablet, mobile device) and/or date/time of visit. Similar to the collection of IP addresses, our website also receives User-Agent information associated with your browser and type of device.
  • Cookies and similar technologies collect information. We use various technologies to collect information, including saving cookies on users’ computers. These tools help us understand and improve the performance of the Puntilla website and platform.

We do not collect sensitive personal information other than necessary to collect payment from our customers for our products and services. Unless we specifically request such sensitive information from you, we ask that you not send it to us or disclose any sensitive personal information.

Finally, we may also receive personal information about you from third parties, such as social networks, that help us identify prospective businesses or customers interested in our products and services.

How We Use the Information We Collect

We use personal information associated with our general business operations for the following purposes:

  • We may use the personal information we collect concerning the services we provide. We may use the personal information we collect to set up user accounts; provide, operate, and maintain services; process and complete transactions; provide customer service and support and respond to inquiries; send communications; prevent fraudulent activity; for any other purpose based on our legitimate interest.
  • Website. We may use the personal information we collect to administer and improve the Puntilla website and platform.
  • SMS opt-in or phone numbers for the purpose of SMS are not being shared with any third parties under any circumstances.
  • Analytics. We may use analytics information collected to understand general information and trends related to our website, such as how many users have visited our website during a given period and the types of devices the visitors use. We use the information to help improve consumers’ solutions.
  • IP addresses—Fraud Prevention. Our use of IP addresses is limited to helping identify and combat potentially fraudulent activity. IP addresses are stored in our log files and deleted after 30 days.
  • Respond to Inquiries. You can contact us directly (by email, form, or postal mail) using the contact information on the Puntilla website. We will use your contact information to respond to your inquiry.

Legal Basis for Collecting and Using Information

Suppose you use the Puntilla website or platform located in the US. In that case, we rely on several processing purposes, such as legitimate interest, as the legal basis for processing the personal data we collect via the website and platform. For instance, we may collect, process, or disclose your personal information based on the following bases:

  1. Necessary for Service Provision: We collect, process, or disclose your personal information as necessary to provide a service or perform a transaction, such as responding to your requests.
  2. Consent: Where applicable law requires, such as for direct marketing or certain cookies, we obtain your consent before processing your personal information.
  3. Legitimate Interests: We may process your personal information to pursue our legitimate interests, such as maintaining the safety and security of the site and conducting our global business operations.
  4. Compliance with Legal Obligations: We may process your personal information to comply with legal obligations, including those related to labor and employment law, social security and protection law, data protection law, tax law, and corporate compliance laws.

The provision of your data is partly a statutory requirement and a contractual obligation.

With Whom We Disclose Information

We may disclose information (including personal information) in the following instances:

  • We may disclose your information to vendors and service providers who assist us in delivering our services, billing customers, and responding to support tickets
  • If Puntilla is acquired or merged with another company, collected information may be transferred to the acquiring company.
  • Applicable order. Under certain circumstances, we may be required to disclose personal information to comply with a subpoena or court order, establish or exercise our legal rights,or defend against legal claims, or cooperate with government and/or law enforcement officials.
  • We may also share de-identified information (i.e., information that cannot be used to identify an individual) for various reasons, including to improve our products, facilitate transparency, comply with legal requirements, or for any lawful basis.

Cookies

The Puntilla website and platform may place cookies on your browser to identify you when you return to our website or log in to our software. You can also manage your privacy preferences with us anytime by clicking the cookie icon on our website.

Security

We take security very seriously. Puntilla has implemented reasonable technical, administrative, and organizational security controls to protect data confidentiality, integrity, availability, and resilience. These measures include using encryption technologies, creating and maintaining policy, and overseeing the management of the security program, role-based access controls, password management, vulnerability management, and secure software development protocols.

Data Retention

The duration for which we retain your personal information depends on its purpose and applicable laws. Puntilla will keep your personal information for as long as you use our services or platform, or as long as we have a valid business purpose, and afterward, only as required or permitted by law.

  • If you provide information to request a service, we will retain it for up to twelve months after your last communication.
  • Information collected while using our website will be kept until you withdraw consent or it is no longer needed for marketing or analytics.

Personal information collected by our platform or provided by customers will be retained for up to three months after the end of our business relationship, in line with our agreement. Payment information will be deleted three months after processing unless required by law to be kept longer.

If you contact us directly via the contact information on the Puntilla website, we will retain your contact information for up to three months after responding to your inquiry. After that, communications will be deleted unless legally required to retain them longer.

Data Transfers from the US & Data Privacy Framework

For visitor-facing components of Puntilla, such as the Puntilla Consent Management platform, all personal data are stored exclusively by our servers in the US. Nevertheless, certain personal information may be stored or accessible outside these Areas. For such transfers of personal information and/or where required by law, Puntilla relies on the Standard Contractual Clauses as a valid transfer mechanism.

Puntilla complies with the U.S. Data Privacy Framework and has attached principles about processing personal data from customers and visitors. If there is any conflict between the terms in this privacy policy and the U.S. Principles, the Principles shall govern. Puntilla adheres to these principles for onward transfers of personal data to third parties and remains liable for damages caused by third parties.

Individuals with inquiries or complaints regarding our Data Privacy Framework policy should first contact Puntilla at:

Puntilla LLC
28 West Flagler St Suite 1200D, Miami, FL. 33130

Puntilla has further committed to solving the unresolved Data Privacy Framework. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please write to contact@puntilla.us

You may be entitled to binding arbitration under the Data Privacy Framework Principles if we do not address your concern. To enforce compliance with the Data Privacy Framework, Puntilla is subject to the investigatory and enforcement authority of the U.S. Federal Trade Commission.

Children’s Privacy

The Puntilla website and platform were not developed or intended for individuals under 18, and we do not knowingly collect information from children under 18. If you provide your information to us through a request form or any part of our platform, you represent that you are at least 18 years old. If you learn that your child has provided us with personal information without your consent, you may alert us at businessasffais@puntilla.us, and we will promptly take steps to delete such information.

“Do Not Track” and Global Privacy Control

Do Not Track (“DNT”) is a privacy preference that users can set in specific web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals.

Global Privacy Control is a browser setting that allows you to notify websites you visit about your privacy preferences. We honor website visitors’ Global Privacy Control signals.

Links to Other Websites

For your convenience, Puntilla’s website may contain links to external websites operated by companies not affiliated with us. These sites may have their own privacy policies, which we recommend reviewing. This Privacy Policy only applies to personal information collected on our website. We have no control over and are not responsible for the content, privacy practices, or use of any third-party websites.

Your Rights

You may be able to exercise specific privacy rights. The rights available to you depend on our reason for processing your personal information and the requirements of applicable law (i.e., your rights will vary depending on whether you are located In, for example, the European Union, the United Kingdom, Brazil, or California). Specifically, you may have the following rights:

  • The right to confirmation on the existence of processing and to access the data: You may have the right to obtain confirmation from us as to whether personal information has been processed and, where that is the case, to request access to the personal information. Depending on your location, you may also have the right to information about public and private entities with which the controller has disclosed personal data.
  • The right to correct incomplete, inaccurate, or out-of-date data: You may have the right to request that we correct any inaccurate personal information about you. Depending on the purpose of the processing, you also have the right to request that we complete the personal information we hold about you where you believe it is incomplete, including by providing a supplementary statement.
  • The right to data portability: Under certain conditions, you may have the right to request that we transfer the personal information we have collected about you to another organization or directly to you in a structured, commonly used, and machine-readable format.
  • The right to request anonymization, blocking, or deletion of personal information: You have the right to request the deletion of the personal information we have collected from you, subject to certain conditions and limitations under the law.
  • The right to revoke consent: Where we rely on your consent to process your personal information, you can withdraw that consent at any time with future effect. Depending on where you are located, you may also have the right to request deletion of personal data processed based on your consent or the right to know the consequences of revoking your consent. Such a withdrawal will not affect the lawfulness of the processing before the consent withdrawal.
  • The right to object to processing: You may have the right to object to our processing of your personal information under certain conditions, and we can be required to process your personal information no longer. Such right to object applies if we collect and process your personal information through automated decision-making, such as profiling, to understand better your interests in our products and services or for direct marketing. If you have a right to object and you exercise this right, your personal information will no longer be processed by us for such purposes. Such a right to object may not exist if processing your personal information is necessary to take steps before entering into a contract or to perform a contract already concluded.
  • The right to opt out of the sale or sharing of personal information: We do not sell your personal information in exchange for monetary consideration. If we disclose your personal information to third parties for their marketing purposes, you may have the right to opt out of that disclosure. You may also have the right to request further information about disclosing your personal information for those third parties’ marketing purposes, such as the contact information of those parties, once per calendar year.
  • The right to limit the use and disclosure of sensitive personal information: We will only use sensitive or special personal information as needed for the purposes for which it was collected or with your consent. We do not currently process sensitive personal information for purposes that may be limited under applicable law. If this changes, we will notify you, and you may have the right to restrict such additional uses.
  • The right to non-discrimination for exercising a privacy right: We will not discriminate against you for exercising any rights.

Exercising rights

To exercise any of your rights as set out above, please contact us by contact@puntilla.us or by contacting us at our office at 28 West Flagler St, Suite 1200D, Miami, FL. 33130. Please note that you must verify your identity before we can fulfill your request. Your request must (i) provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative of that person and (ii) describe the request with sufficient detail that allows us to understand, evaluate, and respond to it properly. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. We will respond to your verifiable request within any prescribed timelines. In some regions, there may be limitations on how often a request relating to personal information may be submitted.

Appointing an authorized agent

You can designate an authorized agent to submit a request on your behalf. To do so, you must provide written authorization or power of attorney signed by you so that the agent can act on your behalf. You will still need to verify your identity with us.

 

Appeals

In some locations, you can appeal any decision regarding a request for personal information. If you have any questions, you can contact businessasffais@puntilla.us

Unsubscribe from marketing

You can opt out of receiving specific marketing or promotional communications from Puntilla anytime by using the unsubscribe link in our email communications.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time based on changes to applicable laws and regulations or other requirements applicable to us, changes in technology, or changes to our business.

Any changes we make to the Privacy Policy in the future will be posted on this page, so you should review it periodically.

If our information practices significantly change, specifically how we process personal information, you will receive appropriate online notice. If our Privacy Policy changes, we will also post a notice on our home page.

How to Contact Us

If you have any questions about this Privacy Policy or its implementation. In that case, you may contact Puntillas’s Business Affairs team at businessasffais@puntilla.us, or you can send correspondence to the following address:

Puntilla LLC
28 West Flagler St Suite 1200D, Miami, FL. 33130

What information do we collect?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide us when you register on the Services, express an interest in obtaining information about us or our products and Services when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

  • names
  • email addresses
  • Phone Number
  • Usernames
  • SMS consent (only applicable to customers & employees)

SMS consent from customers & team members

  • This service is used to send you notifications about the use and protocol of our services, access verification, and other relevant announcements regarding your active status as a company partner.
  • You can cancel this service anytime by replying to our text message with “STOP.” After you send us the “STOP” message, we will reply to confirm that you have canceled your subscription. After this, you will stop receiving our messages. If you wish to join again, simply register as you did the first time, and we will send you messages again.
  • If you forget which keywords are supported, send us a text message with “HELP.” After you send us the “HELP” message, we will respond with instructions on how to use our service and how to unsubscribe.
  • As always, message and data rates may apply to any message we send to you and that you send to us. If you have any questions about your text messaging or data plan, it is best to contact your wireless carrier. If you have any questions about the services offered by this SMS program, you can email your company’s support email address.
  • If you have any questions about privacy, please review your security data company.