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Privacy Policy

Last updated: July 4, 2025 Β· Version 3.0

πŸ‡ΊπŸ‡Έ English πŸ‡·πŸ‡Ί Русский πŸ‡ͺπŸ‡Έ EspaΓ±ol
This Privacy Policy describes what personal data JOYNATIVO S.A.S. ("JOYNATIVO") collects, how it is used, stored, and protected, and what rights users have regarding their data.

1. Data Controller

The data controller responsible for processing personal data is:

JOYNATIVO S.A.S., RUC 0691787377001, Riobamba, Ecuador.
Email: [email protected]

2. Data We Collect

  • Registration data: name, email, phone number, country of residence.
  • Profile data: photo, biography, languages, cultural interests (for Hosts: accommodation details and cultural programs; for Tutors: qualifications and teaching experience).
  • Payment and verification data: transaction tokens, payment method tokens (full card data is not stored), bank account or payment account details for Host/Tutor payouts, identity documents and additional KYC verification data.
  • Booking data: history, dates, statuses, communications with hosts and support.
  • Technical data: IP addresses, cookies, browser type, operating system, Platform activity.
  • Reviews and communications: reviews submitted or received, support messages.

3. Legal Bases for Processing

  • Performance of a contract: processing necessary to provide Platform services, manage bookings, and process payouts.
  • Legitimate interests: fraud prevention, Platform security, analytics, and service improvement.
  • Legal compliance: AML/KYC verification, tax reporting, and other regulatory requirements.
  • Consent: marketing communications, analytics cookies (where explicit consent is obtained).

4. Storage and Protection of Documents

Identity documents and other verification materials are stored encrypted on secure servers. Access is restricted to authorized personnel acting exclusively for verification and compliance purposes. Upon expiry of the applicable retention period, documents are permanently deleted in accordance with the Data Retention Policy (Section 7).

5. Data Transfers to Third Parties

JOYNATIVO does not sell or transfer personal data to third parties for their own marketing purposes without explicit consent. Data may be shared in the following cases:

  • Payment providers (PayPhone, PayPal, and similar services) β€” to process transactions.
  • Cloud and hosting service providers β€” to operate the Platform.
  • Analytics services β€” in anonymized or aggregated form.
  • Hosts and Tutors β€” limited to data necessary to fulfill the booking.
  • Public authorities and law enforcement β€” when required by law.

6. Your Rights

Users have the following rights regarding their personal data:

  • Access: request a copy of the data being processed.
  • Rectification: request correction of inaccurate or incomplete data.
  • Erasure ("right to be forgotten"): request deletion of data where there is no legal basis for continued processing.
  • Restriction of processing: request temporary suspension of processing in certain circumstances.
  • Data portability: receive data in a structured, machine-readable format.
  • Objection: object to processing based on legitimate interests.
  • Withdrawal of consent: withdraw consent at any time without affecting the lawfulness of prior processing.

To exercise these rights, contact: [email protected]. Requests will be processed within 30 days.

7. Data Retention Policy

JOYNATIVO retains personal data only for as long as necessary to fulfil the purposes for which it was collected, comply with legal obligations, and resolve disputes. The following retention periods apply:

  • Active account data: retained for the duration of the active account.
  • Closed account data: retained for 3 years after closure for dispute resolution and legal compliance, then deleted or anonymized.
  • Verification documents (KYC/AML): retained for 5 years from the last transaction, in accordance with applicable AML regulations.
  • Transaction data: retained for 7 years for tax and financial reporting purposes.
  • Marketing preferences: retained until consent is withdrawn; deleted within 30 days of withdrawal.
  • Technical data (logs, IP addresses): retained for a maximum of 12 months, unless a longer period is required by law.

Upon expiry of the applicable retention period, data is permanently deleted or securely anonymized. Users may request early deletion where a legal basis exists.

8. Data Security

JOYNATIVO applies technical and organizational measures to protect personal data from unauthorized access, loss, alteration, or disclosure, including:

  • Encryption of data in transit (TLS/HTTPS) and at rest.
  • Role-based access control for JOYNATIVO staff.
  • Regular security audits and penetration tests.
  • PCI DSS compliance for payment data processing.

In the event of a data breach affecting users' rights, JOYNATIVO will notify affected users and, where required, the supervisory authority within the timeframe required by applicable law.

9. Supervisory Authority

If a user believes their personal data is being processed in violation of applicable data protection law, they may lodge a complaint with the competent supervisory authority in their country of residence. Users may also contact JOYNATIVO directly at [email protected].

10. Payment Data and Identity Verification

Payments on the Platform are processed by licensed third-party payment providers, including PayPhone, PayPal, and similar services. JOYNATIVO does not store full payment card numbers or bank account details on its own servers; payment data processing is carried out exclusively through the secure systems of payment providers, which comply with the PCI DSS standard. JOYNATIVO stores transaction tokens and payment method tokens for the purposes of transaction confirmation, refund processing, and dispute resolution.

JOYNATIVO is required to comply with applicable anti-money laundering (AML) and know-your-customer (KYC) regulations. For this purpose, JOYNATIVO collects and processes identity documents and verification data from Hosts and Tutors. This data is not shared with third parties except where required by law or with the user's explicit consent.

11. Marketing Communications

JOYNATIVO may send marketing and promotional messages by email or in-app notification if the user has given consent or where permitted by applicable law. Users may opt out of marketing communications at any time via the unsubscribe link in any marketing email or by adjusting notification preferences in account settings. Opting out of marketing communications does not affect the receipt of transactional messages (booking confirmations, payout notifications, security alerts) that are necessary for the operation of the Platform. JOYNATIVO will not share users' personal data with third parties for their own marketing purposes without explicit consent.

12. Amendments to this Privacy Policy

JOYNATIVO reserves the right to modify this Privacy Policy at any time. For material changes, JOYNATIVO will notify users at least 14 days in advance by email or in-app notification. Continued use of the Platform after the effective date constitutes acceptance of the updated Policy.

13. Prevailing Language

This Privacy Policy is published in English, Spanish, and Russian. In the event of any discrepancy between language versions, the Spanish version shall prevail.

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