Privacy Policy

Privacy Policy

This CUX Privacy Policy (the "Privacy Policy") describes the information that CUX collects and processes about you and what it may do with that information. At CUX, we understand the protection of personal data as a priority and as an opportunity to create value for our Users. By responsibly using personal information, we not only protect the privacy of those who have entrusted us with their data, but we also allow them to operate securely and confidently on our Site. 

This Privacy Policy is an integral part of the Terms and Conditions of CUX (link). Providing your voluntary, express, and informed consent to this Privacy Policy is an essential requirement for entering into any type of relationship with CUX, depending on the applicable legislation in each country. To make it a more user-friendly reading for you, we will ask several questions and their answers. If your question is not included, you can reach us at info@cux.ai, and we will respond within 48 hours. 

To begin, YOU MUST PROVIDE YOUR EXPRESS AND INFORMED CONSENT for CUX to assign, transmit, or transfer your Personal Information to the recipients detailed in this Privacy Policy. (NOTE: pages must incorporate relevant functionalities that allow the Platform user to give consent or not to consent ("I Accept" or "I Do Not Accept") in any relevant transaction instance between the user and the mentioned pages). 

NOW WE WILL SHOW YOU HOW we work with your personal data at CUX: 

What is the purpose of CUX and how does this Privacy Policy apply?

 The goal of CUX is to provide accessible and affordable virtual support through a self-help digital platform, without mediation or human interaction with the User through pre-designed and conditioned conversations using algorithms (chatbot), and with the strength of a community that offers support in a safe environment. Therefore, your privacy is very important to us, and we strive to protect it and work every day to make sure that's the case. To provide you with our services, CUX processes, collects, and in some cases discloses information about individuals who, like you, are users and visitors of the Site. For this reason, it is important for you to know that when you register at CUX, you are generating a user account along with a personal password that will allow you to operate in the system. 

Who is responsible for processing Personal Information?

 CUX is responsible for processing the data of users through its subsidiary or affiliated companies. To find out which company or companies are responsible for processing in your country of residence, please refer to the corresponding Annex for that country. To elaborate further, the data controller is the one who decides on the processing of personal data. They determine the purposes or uses for which personal information will be used and the means that will be employed for that processing.

 What information do we collect and process at CUX? 

CUX collects your personal information so that you can access humanized and personalized virtual assistance and/or enjoy our services and continuously improve them. In some cases, the personal data is provided by you when you register. In others, we process it automatically because a third party authorized by you has shared it with us. The inaccuracy or falsity of the personal data you provide could lead to the suspension and/or cancellation of services. Likewise, CUX may suspend or permanently disable those users who violate this Privacy Policy. These are some of the personal data we can collect and process with your consent: Information you provide directly by creating a user: Full name, Email address, Phone number, Language preference, Personal image (selfie), Information when completing your user profile, Nationality, Country of residence, Nickname, Date of birth, Pronoun/gender with which you prefer your virtual assistant to refer to you, Data collected automatically when using the platform, Information from devices or computers from which you access the CUX platform, and other automatically captured data (such as browser type or version, operating system, settings, and parameters) Internet Protocol (IP) address used when connecting to our services or browsing our websites. Additionally, certain information about user and visitor activity on our website may be included. Such information may include the URL from which they came (whether or not they are on our website), what URL they access next (whether or not they are on our website), the pages visited, interactions with those pages, searches performed, among other stored, retained, and processed information.

 Does CUX collect sensitive personal data?

 In addition to the personal data mentioned above, CUX may request, collect, process, and/or use the following sensitive personal data, which as such require special protection. Sensitive data includes those revealing your racial and ethnic origin, political opinions, religious, philosophical, or moral beliefs, union affiliation, and information regarding your health or sexual life. However, regarding sensitive personal data, these will only be processed and used by CUX after an Anonymization process. 

What is the Anonymization of personal data, and in what cases is it used?

 Anonymization is understood as the process by which all information enabling the identification of the owner is dissociated, meaning the information cannot be linked to a specific or determinable person. CUX commits that, if personal data is used to generate statistical data, it will undergo disassociation processes so that it cannot be associated with its owner.

 What do we do at CUX with your Personal Information?

 The collection and processing of your personal data allow us to provide you with excellent service so that you can have continuous, humanized, and personalized assistance and offer you functionalities that better adapt to your needs. Except in cases where applicable regulation specifically prohibits it, CUX will use your personal data for the following purposes: 

-Register you in our systems.

-Identify and contact you. 

-Provide you with the services and/or benefits that you use, request or contract with us. -Address your comments, complaints, and suggestions, as well as provide you with support.

-Attend to the exercise of your rights according to the existing regulations; 

-Improve our services, develop new ones, and offer you a better experience with CUX platforms. 

-Comply with legal obligations and requests from competent authorities.

-Comply with applicable regulations for CUX in general. 

-Compliance with informational regimes in general, as applicable in each country. -Compliance with informational requests from competent administrative or judicial authorities.

-Supply user information to government entities with collaboration agreements for compliance with their competencies.

-Detect and prevent fraud, abuse, and related crimes to protect the security of our users and the sustainability of the platforms.

-Protect the rights of users, third parties, or CUX's own.

-Defend the rights, tangible, and intangible assets of CUX.

-Enforce the rights of CUX regarding breaches of its Terms and Conditions and this Privacy Policy; 

-Allow other users or third parties to enforce their rights.

-Contact you through different channels (via email, short text messages (SMS), push notifications, phone calls, or any other means) for advertising and/or promotional purposes for products and services of CUX and/or third parties.

-Carry out all kinds of marketing, advertising, commercial prospecting, and/or market research activities. 

We consider it important to indicate that CUX will generate statistics based on non-individualized and non-personalized information regarding various aspects of mental health. Some of the purposes described may not be applicable in that: a) you do not use the service associated with those purposes, or b) the services linked to those purposes are not offered in your country of residence. The use of your data for any other purposes that are not compatible with those detailed will be communicated to you before we proceed to their processing so that you can freely express your consent.

 Finally, it is important for you to know that CUX will maintain your personal data for as long as necessary to fulfill the purposes for which they were collected. 

How do we share your Personal Information?

Your privacy protection is very important to CUX. Therefore, it is important for you to know that at CUX, we do not sell or commercialize information that identifies our users. We also do not share or transfer your Personal Information to third parties in any other way, except as indicated below: CUX may assign, transmit, and/or transfer your Personal Information to: 

(i) "Service Providers": service providers or outsourcing companies are third parties we contract to act on behalf of CUX to provide a service following our instructions and in accordance with this Privacy Policy, to help improve or facilitate operations through our platform, such as (a) interface and artificial intelligence providers, information systems providers, cloud service providers, database providers, and technology service providers in general, (b) companies or institutions dedicated to payment management and means, (c) advertising or marketing agencies, (d) data analysis. These Service Providers only access the strictly necessary information to provide the agreed services and may not use it for purposes other than those entrusted by CUX. 

(ii) “Business Partners”: companies with which CUX has a collaborative relationship or alliance, aimed at offering you new services. In these cases, CUX always ensures that confidentiality and security standards are met through the signing of agreements whose object is the privacy of our users' personal data and compliance with applicable legislation. 

(iii) "CUX Group": companies belonging to our corporate group that operate under our same internal processes and policies, whether controlled, controlling, or affiliated companies with CUX, to comply with our internal policies and facilitate the management of CUX services. 

(iv) “Public Authorities”: administrative and judicial authorities that, in the exercise of their powers, require information for the purposes of: (a) collaborating in the investigation and reporting fraud as well as any activity or circumstance that could result in legal liability for CUX and/or its users; (b) safeguarding a public interest, ensuring or administering justice, the recognition, exercise or defense of a right in judicial or administrative proceedings, and/or resolving disputes; and (c) complying with any applicable law, regulation, or legal disposition, or any mandamus from a competent authority properly grounded and motivated. Additionally, CUX may disclose your Personal Information at its discretion to public entities, and/or authorities when there are sufficient grounds to believe that your activity is suspicious of attempting or committing a crime or attempting to harm others.

If CUX decides to share your Personal Information with third parties other than those mentioned, we will ask for your prior and express consent, unless there is a legal authorization or obligation that allows doing so without that consent. Finally, CUX will not be responsible for the improper use of your Personal Information by any third party when these third parties directly collect and/or process your Personal Information. 

International data transfers:

The services provided by CUX require a technological infrastructure, like servers and cloud services, which can be either own or provided by third parties. Part of that infrastructure may be located in a country different from yours. It may also occur that the recipients of the data mentioned earlier in the section "How do we share Personal Information?" are located in a different country. Countries receiving the data we transfer may not offer adequate levels of protection for personal data, according to applicable regulations. In these cases, CUX adopts measures to safeguard your data through contractual clauses or binding corporate rules imposing the same protective measures as those described in this Privacy Statement.

For how long will we store Personal Information at CUX?

We will only store personal information for as long as necessary to fulfill the purpose for which it was collected, to comply with regulatory or legal requirements, or during the statutory limitation period for possible legal or contractual liabilities. Once that period has ended, the data will be deleted or anonymized in such a way that no person can be individualized, according to the legal regulations.

Automated decisions and profiling:

At CUX, we are committed to providing you with more and better services and increasingly personalized and humanized assistance. To achieve this, we rely on tools that help us be more efficient using techniques known as "artificial intelligence", "machine learning", or "Big Data". Automated decisions are those made based on the use of algorithms and software programs, without any human intervention in the decision-making process. According to current regulations, you have the right to request a review of a decision based on automated data processing with negative impact. For this purpose, you can request it at: info@cux.ai CUX reminds you that the use of Artificial Intelligence helps us provide you with a better experience; however, the responses generated may not be crafted or reviewed by humans. If you have any issue, discomfort, doubt, comment, or suggestion regarding this, please contact us immediately at info@cux.ai While all the information you share while chatting with CUX is anonymous, for your safety, we ask you not to include information related to bank accounts, keys, passwords, or similar information, which even if anonymous, could pose a risk. 

Confidentiality of Personal Information and Users' Responsibilities:

At CUX, we do everything within our power to protect the privacy of your Personal Information. However, it is crucial for you to know that the user will be responsible for all actions that take place through the use of their personal information and password. If in doubt, you can contact: info@cux.ai 

Minors: 

CUX Services are only available to individuals over 18 years old who have the legal capacity to contract according to applicable law. Therefore, if you do not meet this requirement, you should not provide your Personal Information. 

Links to Other Websites:

CUX may include links to third-party websites, which does not indicate that they are owned or operated by CUX. Thus, the processing of Personal Information conducted by the third parties responsible for those mentioned websites is not covered by this Privacy Policy. Furthermore, you acknowledge and accept that CUX has no control over such websites and is not and will not be responsible for the content or the services provided by those sites, nor for the way in which they process your Personal Information. Therefore, if you enter these websites, you do so at your own risk.

How can you exercise your rights to control your Personal Information?

Applicable regulations grant you certain rights regarding your Personal Information, such as: (i) access; (ii) updating; (iii) rectification; (iv) cessation of advertising, offers, and promotions; (v) deletion; (vi) revocation of consent; and (vii) confidentiality. You can make any inquiries, claims, and/or requests related to your Personal Information by contacting CUX at this email: info@cux.ai. In certain cases, we will keep your Personal Information that you requested to delete in our files to fulfill the purposes described in this Privacy Policy or when there is a contractual or legal obligation to maintain your Personal Information. Once that purpose is fulfilled or the contractual or legal obligation has expired, we will proceed to delete your Personal Information.

THE OWNER OF PERSONAL DATA HAS THE RIGHT TO EXERCISE THE RIGHT OF ACCESS TO IT FREE OF CHARGE AT INTERVALS OF NO LESS THAN SIX MONTHS, UNLESS A LEGITIMATE INTEREST IS DEMONSTRATED FOR THIS PURPOSE AS PROVIDED IN ARTICLE 14, SECTION 3 OF LAW NO. 25,326 OF THE ARGENTINE REPUBLIC. THE ENFORCEMENT AUTHORITY (IN ARGENTINA, THE AGENCY FOR ACCESS TO PUBLIC INFORMATION, CONTROL BODY OF LAW NO. 25,326), HAS THE AUTHORITY TO HANDLE COMPLAINTS AND CLAIMS REGARDING NON-COMPLIANCE WITH PERSONAL DATA PROTECTION STANDARDS.

The User may contact the AGENCY FOR ACCESS TO PUBLIC INFORMATION at the following addresses:

Located at: Av. Pte. Julio A. Roca 710, 2nd Floor - Buenos Aires City

URL: www.argentina.gob.ar/aaip

Email: datospersonales@aaip.gob.ar

Tel.: + 54 11-2821-0047.

Advertising, Cookies, and Other Technologies: 

The User expressly recognizes and accepts that CUX may use a behavioral tracking system through "cookies" and/or other similar tracking technologies. These technologies are used to understand the interests and behaviors of those visiting or using our website and thus provide them with better service or relevant information. We also use the information obtained through cookies to analyze the pages visited by the visitor or user, the searches made, improve our commercial and promotional initiatives, display advertising or promotions, interest banners, news about CUX, enhance our content and service offerings, personalize such content, presentation, and services, as well as promote and enforce the rules and security of the site; we also use them so that the user does not have to enter their password as frequently during a browsing session, always aiming at the user's benefit from the cookie installation, which will not be used for purposes unrelated to CUX. Additionally, we store cookies to offer a more interactive experience on the site, based on user actions. Your personal data obtained through these technologies will not be transferred to third parties in a way other than indicated in this Privacy Policy. You should know that the installation, permanence, and existence of cookies on your computer or device depend solely on your will and can be deleted whenever you wish.

To know how to delete cookies from the system, it is necessary to review the Help section of the browser. In this regard, you can at any time delete the stored cookies, configure the browser to request approval before storing cookies, or directly prevent cookies from being stored. This procedure is carried out differently in different browsers, and it is necessary to do it in each browser you use on your devices. Below we provide access to the different procedures for handling this configuration in the most commonly used browsers:

-From Internet Explorer (on Windows) http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies -From Firefox https://support.mozilla.org/en/kb/enable-and-disable-cookies-websites

-From Google Chrome http://support.google.com/chrome/bin/answer.py?hl=en&answer=95647 

-From Safari (on Mac) http://www.apple.com/legal/privacy/en/cookies/ 

If you disable cookies, you should keep in mind that you may not be able to use and enjoy all the functionalities that CUX offers.

Security. Storage of Personal Information:

As required by the principle of proactive responsibility, CUX complies with regulations and industry standards regarding the security measures applicable to your Personal Information. However, CUX is not responsible for illegal interceptions or violations of its systems or databases, or for their use by unauthorized persons. CUX is not responsible for the improper use of information obtained through such means. In compliance with applicable regulations, CUX will make the relevant notifications in case of security incidents or privacy violations. 

Changes to the Privacy Policy: 

If CUX makes changes to how Personal Information is managed, we will notify you through our usual channels, such as email or messages through the Site, of those changes so that you can provide us with your consent. In the terms permitted by the regulations of each country, for users who do not accept those new terms, the contractual link with CUX will be dissolved, and the Personal Information of that user will not be used in any way other than that informed at the time of collection. 

Applicable Law and Jurisdiction: 

This Privacy Policy shall be governed in all its points by the laws in force in the countries where it operates. Any dispute arising from this agreement, its existence, validity, interpretation, scope, or compliance shall be submitted to the corresponding country's judiciary. Version: The general Terms and Conditions included herein correspond to version V1 published on 09-21-2023.