Privacy Policy

I. OBJECTIVE.
The objective of this policy is to guarantee the comprehensive protection of the personal data of all those who are registered (the " User " or the " Users ", as appropriate) in the application called Kampo (the " Application "), which is located available to be downloaded to mobile phones, tablets and other smart devices, and which is the property of KAMPO SpA (hereinafter, “ KAMPO ”), under the terms applicable to local legislation and the policies established by KAMPO.KAMPO recognizes the importance of access to Users' personal data, which is why this Privacy Policy is established so that all KAMPO members promote and preserve trust, fostering the organization's commitment to a adequate protection of the personal data you access.By accepting the processing of your Personal Data and this Privacy Policy, you expressly consent to KAMPO , responsible for the Personal Data, processing them in the manner and for the purposes indicated here.

II. PRIVACY.

1. ​DEFINITIONS
For the purposes of this policy, and without prejudice to the particular definitions that may be given in the following pages, it will be understood as:
Yo. DATA STORAGE : The conservation or custody of data in a registry or data bank.
i . FILE, REGISTRY, DATABASE : Indistinctly, they designate the organized set of personal data, whether automated or not and whatever the form or modality of its creation or organization, which allows the data to be related to each other, as well as carry out all types of treatment. of data.
iii . COMMUNICATION OR TRANSMISSION OF DATA : It is the action of disclosing personal data in any way to people other than the owner, whether determined or undetermined.
iv . STATISTICAL DATA : It is the data that, in its origin, or as a result of its treatment, cannot be associated with an identified or identifiable owner.
v. PERSONAL DATA : Refers to information of any kind, related to natural persons, identified or identifiable.
saw. SENSITIVE DATA : Are those personal data that refer to the physical or moral characteristics of people or facts or circumstances of their private life or intimacy, such as personal habits, racial origin, ideologies and political opinions, beliefs or convictions. religions, physical or mental health conditions and sexual life.
vii . DELETION OR CANCELLATION OF DATA : Destruction of data stored in registers or data banks, whatever the procedure used for it.
viii . DATA MODIFICATION : Any change in the content of the data stored in registers or data banks.
ix . DATA DISSOCIATION PROCEDURE : All processing of personal data in such a way that the information obtained cannot be associated with a specific or determinable person.
x. RESPONSIBLE FOR DATA PROCESSING : That entity responsible for the correct compliance with data protection.
xi. DATA HOLDER : The natural person who enters the Application as a User, to whom the personal data refers.
xii . TREATMENT OR PROCESSING OF DATA : any operation and/or technical procedure, automated or not, that allows collecting, storing, recording, organizing, elaborating, selecting, extracting, confronting, interconnecting, dissociating, communicating, assigning, transferring, transmitting or cancel personal data, or use them in any other way.

​2. ​PRINCIPLES FOR DATA PROTECTION
a. ​Processing of data with a legal basis : Any member of KAMPO must have a legal basis that enables them to process personal data, whether they are authorized under Law 19,628 and/or already have the express consent of the owner of the data.
b. ​Communication : Every holder of personal data will be informed, among others, of the following:- What personal data we will treat.- The purpose/purpose of data processing.- What rights do you have?
c. ​Responsibility : Any activity carried out by KAMPO that involves data processing must adhere to current legal regulations and the policy of the latter, and must be able to demonstrate said compliance.
d. ​Limitation on data collection : KAMPO only collects personal data that is necessary or useful for the purposes that have been foreseen and correctly communicated to the owner of said data. Consequently, the personal data collected cannot be used for another purpose, without a specific legal reason.
and. ​Expiration of the data : The personal data collected may not be stored for longer than necessary to achieve the purposes for which said Data is processed.
F. ​Accuracy of the data : The personal data collected must be exact, taking all the necessary safeguards to comply with said maxim. Likewise, in the event that the inaccuracy of the personal data collected is detected, they must be modified, while if there is personal data whose accuracy cannot be established, they must be eliminated.g. ​Right to access, correct, delete and object to data processing : Any person whose data has been collected will have the right to demand information about the data relating to their person, their origin and recipient, and the purpose of storage.At the request of the owner, KAMPO undertakes to eliminate the data collected, unless we are legally authorized or obliged to retain said data. Interested parties may also demand the deletion of their data when they have been voluntarily provided and are being used for commercial communications (direct marketing) and do not wish to continue appearing in the respective registry, either permanently or temporarily.h. ​Data Security and Incident Reporting : KAMPO is committed to maintaining and implementing appropriate security measures to protect Personal Data against accidental or intentional destruction, loss, alteration, unauthorized or unlawful disclosure or access, as well as against all other illegal forms of processing.In the event that any member of the organization detects any possible violation of data security, they must immediately notify the respective manager, through an email addressed to the following contact email: kampo@kampo.io.

3. ​OBTAINING PERSONAL DATA
KAMPO obtains different types of data from Users through the information that they voluntarily provide through the use of the Application or the services it provides.Within the data that KAMPO may process, are the following personal data:
a. ​Minimum data referring to the User :Yo. ​Full name.i . ​Email and password .The information contained in our databases is intended to efficiently comply with the services offered through the Application, in strict compliance with current local regulations and KAMPO policy.
Consistent with the foregoing, the information provided by the Users is necessary to :a. Comply with legal requirements, including those provided for in consumer protection laws. b. Protect the legitimate interests of KAMPO. c. Efficiently provide the contracted services. d. Improvement of the content and navigability of the Application. e. Statistical analysis, including its anonymization .The information will be kept by KAMPO as long as said information is useful for the fulfillment of any of the objectives indicated above, and must be eliminated at the moment it loses said utility, the data expires or the owner of the same requests its elimination and there is no basis legal any for its maintenance.KAMPO declares that under no circumstances will Users be required to reveal personal data associated with their ethnic or racial origin, political opinions, religious or philosophical convictions, or with respect to union affiliation, genetic data, biometric data, data related to health or data related to the sexual visa or sexual orientation of the Users.

4. ​DATA PROCESSING a. ​NATIONAL TRANSFER OF PERSONAL DATA :
By accepting this Privacy Policy, the User expressly authorizes KAMPO so that, within the framework of the provision of services offered through the Application, fully subject to the provisions of this document and the current regulations applicable to the matter, may transfer personal data to entities or organizations existing in Chile, in order for the latter to use the information collected for any of the purposes indicated in the previous clause.b. ​INTERNATIONAL TRANSFER OF PERSONAL DATA : KAMPO does not transfer personal data to any entity or body outside of Chile. However, in the event that it is necessary to share the data with an entity related to KAMPO in another country, two points must first be met: (i) the owner of the data must have given their written consent; ( ii ) the country receiving the data must have legislation with protection standards similar to those of the regulations of the Republic of Chile, or there must be an international transfer contract with the receiving entity of the data in which said data is ensured. standards.c. ​ACCESS TO PERSONAL INFORMATION : KAMPO limits access to personal information only to those people who require the information to carry out their tasks.Notwithstanding the foregoing, KAMPO guarantees personal data holders access to their personal data, and also guarantees their right to delete them, as indicated in this policy.d. ​DISCLOSURE OF PERSONAL DATA : KAMPO does not disclose or transfer to third parties the personal data it collects, except in those cases in which a law determines it, or that is required by competent public authorities (trials, lawsuits, etc.) to do so in the case concrete.

5. ​SURVEY OF INCIDENTS KAMPO
undertakes to maintain and implement adequate security measures to protect the personal data of its Users that it has collected.In the event of a security breach, KAMPO must apply the procedures established for this purpose. Any KAMPO worker who detects a security breach must notify their direct manager and the local data protection officer, as well as report any suspicious activity that could involve a possible security breach.Some examples of security breaches that should be reported are:
1. ​Loss of documentation containing personal data,
2. ​The disclosure of personal data to unauthorized persons (for example , if a KAMPO employee accidentally sends such information to an unauthorized third party).
3. ​In the event that KAMPO is the target of a cyberattack.In the event that a supplier, client or interested party makes any type of request regarding their personal data stored by KAMPO, it must be treated in accordance with local law.

6.​ RIGHTS OF PERSONAL DATA HOLDERS
You can revoke at any time the consent that you grant in this act, or present queries or objections in relation to the treatment that we make of your Personal Data. To the extent possible, we will apply your preferences going forward. In addition, and according to current legislation, you can also request, at any time, access and information about the Personal Data that we keep about you and its treatment; update and correct errors in that data and request that the data we hold about you be blocked or deleted as appropriate.All these rights can be made effective by contacting the email kampo@kampo.io.

7 . ​QUESTIONS
Any questions arising from this Policy, the way it should be implemented or data protection in general, should be directed to the KAMPO data protection officer at the following email: kampo@kampo.io.

8. ​APPLICABLE REGULATION
This Privacy Policy is in harmony with the legal regulations applicable in the Republic of Chile and the internal policies of KAMPO. KAMPO is not adjusted to the regulations of the General Data Protection Regulation (Regulation (EU) 2016/679 in consideration of the fact that KAMPO :
(a) You do not offer your Services to natural persons residing in the European Union; me
(b) It does not process data for the purpose of controlling the behavior of natural persons residing in the European Union.