Privacy Policy
Complete Privacy Policy of Roxom Markets S.A. de C.V. covering data collection, processing, user rights, and artificial intelligence usage.
Privacy Policies
1. INTRODUCTION
This Privacy Policy explains what we do with your personal data to provide the services offered on our website, applications and other electronic platforms (“Site”) such as sending complaints, subscription to mailings, communications, etc. (the “Services”). Our policy also explains the data we may collect when you visit the Site, as well as how we may use and share it. Please read this policy carefully to understand our way of processing data and if you have any doubts, feel free to contact us. In the event that you do not provide the information indicated as mandatory, we may not be able to process your user registration or provide you with the use of some Services on our Site. This is because some benefits of our Services require personal information to be shared. Among the personal data we may collect are: name, email address, IP address, device identifier, among others. You are solely responsible for ensuring the accuracy of the data you share with us, since if you maintain untruthful or outdated information within your user account, this may affect your use of the site, the information you receive from it and our ability to contact you.2. LEGAL BASIS FOR PERSONAL DATA PROCESSING
The collection and processing of your personal data is based mainly on the contractual and non-contractual relationship you have with us. When we send you newsletters and you use our Services, or when we use the email address you have provided to contact you individually or to recognize you when you return to visit our website, it is done under informed consent. The way we process the information collected by our cookies is based on the informed consent you have given us, in accordance with current legislation. Within ROXOM MARKETS, S.A. DE C.V., we adhere to the regulatory compliance of the country of domicile of the company (El Salvador “Personal Data Protection Law”, legislative decree No. 144/2024, published in the official gazette No. 219 on November 15, 2024) that ROXOM MARKETS, S.A. DE C.V. possesses, as well as internationally, to the norms of the European General Data Protection Regulation (“RGPD”, normally known as “GDPR”). In general, we follow all current legal guidelines to ensure respect and protection of your data.3. PERSONAL INFORMATION WE COLLECT
To create a user on our Site, it will be necessary for you to provide personal information, such as, but not limited to: email address, date of birth, country or city where you reside, your name, your surnames, among other mandatory and optional ones. When you visit or use our Services, we record data that is also related to frequency of use, date and time of access, when you view or click on specific content. We may also collect information from the URLs from which you were redirected to our site (Referral ID). We use that information when you log in and when you read our emails, and we use internet protocol (“IP”) addresses to identify you and record your use of the Site.4. ABOUT DATA PROCESSING
ROXOM MARKETS, S.A. DE C.V. will process your personal data based on the following:- Manage your registration as a user of the Site, to identify you and give access to the Services available for registered users.
- The development, compliance and execution of the contract for the provision of our Services.
- Contact you by email to update and inform you about resources, products or services offered, including Platform security updates, whenever necessary and reasonable.
- Respond to requests or inquiries you make through the customer service channels available on our Platform.
- We also use your information to generate non-identifiable global data. For example, to generate statistics about our users, their jobs or areas of experience, the number of hits or clicks on a specific course or project, or their demographics.
- For legitimate interests of ROXOM MARKETS, S.A. DE C.V., such as:
- Manage, develop and grow our business
- Operate our Site and provide our Services
- Appropriately select providers
- Research and statistical analysis
- Marketing development
- Administration and internal audit purposes
- To comply with the regulations emanating from the Bitcoin Law and the Digital Asset Issuance Law, their complementary norms and the resolutions that complete them.
- To comply with the AML/CFT/FPADM obligations emanating from the Anti-Money Laundering and Asset Law and its regulation, the Special Law Against Acts of Terrorism, the Instructions of the Financial Investigation Unit for the Prevention of Money and Asset Laundering (Agreements No. 085 of 2013 and No. 380 of 2021), the United Nations Convention against Illicit Traffic in Narcotic Drugs and Psychotropic Substances and the Central American Convention for the Prevention and Suppression of Money and Asset Laundering Crimes.
5. USE OF COOKIES
Cookies are small text files that sites and apps you use send to your device (through the browser) to identify it. They allow you to remember certain information about your visit and make subsequent ones easier. They serve, for example, to remember your language, your time zone and the products you have consulted, among other issues. In fact, sometimes cookies could also serve so that you don’t have to enter your password so frequently during a session. For us, these technologies are very important. They allow us to recognize you as a user, know your habits and behaviors and even improve our services. Although the site is accessible without cookies being activated, you should keep in mind that their deactivation could limit the use of certain services or prevent their proper functioning as certain functions cannot be executed. The following list are the cookies we use:- x-session-data: stores “session Id”, “user”, “email”, “username”
- refreshTokens: stores to validate authenticity of requests
- NEXT_LOCALE: stores preferred language
- ga: stores information available for Google Analytics
- intercom-device-id- and intercom-session: Intercom cookies, used to facilitate communication with users and provide customer support
- devrev_plug_user_ref: DevRev cookie, also used in customer support to identify and track users during their interactions with support services
- _ga: Google Analytics cookie, used to track user behavior on the website
- CLID: Clarity cookie, which helps collect information about how users interact with the website
6. DATA RETENTION PERIOD
Your personal data will be retained for the time necessary according to the objectives for which we have collected and processed said data, and in no case will exceed said period. The exact time will depend on the purposes for which we have collected and used the information, always taking into account applicable laws and respecting your right to data protection.7. DATA RECIPIENTS
ROXOM MARKETS, S.A. DE C.V. does not and will not commercialize your personal data in any way. Therefore, we detail below the companies and entities with which we could share your data to offer you our services correctly:- COMPANIES THAT ARE PART OF THE CORPORATE GROUP: that operate under the same policies, are controlled, controlling and/or affiliated with ROXOM MARKETS, S.A. DE C.V.
- PROVIDERS: They are third parties that we hire to act on behalf of ROXOM MARKETS, S.A. DE C.V.
- COMMERCIAL ALLIES: They are third parties with whom we have some relationship to offer you services and promotions
- LINKED USERS: They are users registered on the platform, and the only purpose of the information exchange is the transaction they intend to carry out
- COMPETENT AUTHORITIES: Before formal requests in the exercise of their functions, we could share information with tax authorities, control bodies, national or local justice, etc.
8. DATA PROTECTION RIGHTS
At ROXOM MARKETS, S.A. DE C.V., we recognize the importance of privacy and commit to respecting the confidential nature of all personal data of our users. From the moment you entrust us with your information, you will have the following rights (Chapter III of the Personal Data Protection Law of El Salvador):- ACCESS: You have the right to request access to your personal data, as well as to know any information related to the conditions of its processing
- RECTIFICATION: You have the right to request the rectification of your personal data when it is inaccurate, incomplete, or not up to date
- CANCELLATION: You have the right to request the deletion of your personal data, so that it is not processed by Roxom, unless it could cause harm to legitimate rights or interests of Roxom or third parties
- OPPOSITION: You have the right to oppose the processing of your data, or to a specific purpose, when you have not given consent and/or its processing is not legitimate or justified according to current regulations
- PORTABILITY: You have the right to request the portability of your personal data, which means receiving the data you have provided to Roxom in a structured, commonly used, and machine-readable format
9. HOW TO MANAGE COOKIE CONSENT?
Users can manage their consent regarding cookies at any time by directly contacting dpo@roxom.com. However, please note that you can also block and/or delete cookies from your browser (desktop and/or mobile). In this regard, we suggest you visit www.aboutcookies.org/how-to-manage-and-delete-cookies, where you will find information on how to manage cookies in different web browsers.10. USE OF ARTIFICIAL INTELLIGENCE
In some cases, we may use artificial intelligence for data processing. At ROXOM MARKETS, S.A. DE C.V., we recognize the potential of artificial intelligence (AI) as a tool to optimize processes and improve user experience. In cases where AI is used for data processing, we will do so under strict standards of ethics, transparency, and regulatory compliance.10.1. Purpose of AI Use
Artificial intelligence may be used for the following purposes:- Process Optimization: Automation of tasks such as data analysis, report generation, or information classification
- Service Personalization: Improve user experience through personalized recommendations based on their preferences and behaviors
- Security Improvements: Identification of fraud patterns, prevention of suspicious activities, and protection of sensitive data
10.2. Commitment to Transparency
We commit to:- Clearly inform users when their data may be processed using AI tools
- Ensure that AI-generated results are understandable and do not generate automated decisions without human supervision when these may significantly affect users’ rights
10.3. Data Protection and Confidentiality
The use of AI tools will be aligned with our data protection policy, ensuring that:- Processed data is treated securely and complies with applicable privacy legislation
- The use of personal data is limited to what is strictly necessary for the established purpose
- The principle of anonymization is implemented when possible, minimizing the risk of sensitive data exposure
10.4. Ethics and Non-Discrimination
The AI used in our systems will be designed and supervised to avoid:- Discriminatory biases that could negatively impact groups or individuals
- Results that compromise fairness, justice, or ethical principles established by the company
10.5. Supervision and Control
We ensure that the development, implementation, and operation of AI systems are subject to:- Regular review by technical and legal experts
- Internal audits to ensure proper functioning and alignment with our privacy and ethics policies
- Human supervision in all critical decisions, ensuring that no automated decision can compromise users’ rights
10.6. Users’ Rights
As part of our commitment to transparency, users will have the right to:- Be informed about the use of AI in processing their data
- Request review of automated decisions that may directly affect them
- Opt for alternative channels that do not include the use of AI tools, when technically feasible
11. CHANGE CONTROL
This policy should be reviewed once a year to update its content and adapt it according to current conditions. The Compliance Officer will be responsible for the custody of the original document, as well as its administration, proposing changes, modifications, and updates. Such proposed changes or modifications must be authorized by the President of the Administrative Body before applying them to the document. Once the changes or modifications have been incorporated into this policy, its dissemination to staff will be the responsibility of the Compliance Office department. ROXOM MARKETS, S.A. DE C.V., reserves the use of this document for Committee members; therefore, it is the responsibility of the persons holding the positions to safeguard, preserve, disseminate, and update it.12. VERSION HISTORY
| Version | Date | Department | Approval |
|---|---|---|---|
| 1.0 | 15/11/2024 | Compliance | Compliance |
Contact Information
For any questions regarding this Privacy Policy or to exercise your data protection rights, please contact us at: Email: dpo@roxom.com Company: ROXOM MARKETS, S.A. DE C.V.Address: Cuscatlán 4312, Colonia Escalón, San Salvador, San Salvador Centro, San Salvador, El Salvador
Tax ID (NIT): 0623-210524-104-6
Commercial Registry: Number 196 of book 4894