Information Reserve Policies

I. General Information

This document is an integral part of the Terms and Conditions of use of Subelotodo. The user consents from the moment of registration and/or navigation on the web site, for his information to be used in accordance with the present policy of Reservation of the Information.

The Subelotodo business model requires to collect and disclose information about users in some cases. Subelotodo recognizes that the privacy of the information of its users is very important and under this, precautions are taken to the shelter information through effective information security systems.

This section explains in detail, what Subelotodo can do with that information so that the user is aware in advance of such circumstances.

II. About the collected information

The first step to begin to enjoy the services of Subelotodo is to register, providing the personal data in a manner that is complete and accurate, on “Personal information". The Personal information that it may require and store is: pseudonym to identify on the website, name, address, email, among others.

Subelotodo saves the power to confirm the personal data provided through public entities or specialized companies, for which, the user and/or visitor expressly authorizes Subelotodo. The information obtained will be treated as confidential.

Subelotodo collects and stores, automatically, some information about the activity of users and visitors within Subelotodo. Such information may include the URL that they come from (whether or not they are on the Web site), what URL access afterwards (whether or not they are on the Web site), what browser they are are using, and their IP addresses. It can also collect and store information about pages visited, searches performed, publications, purchases or sales, ratings and entered replicas, messages in the Interactive Zone, among other information. At the same time, Subelotodo may collect and store information from correspondence, e-mails or canes sent by the user, or correspondence about the activities or messages from other users on the site by other users or by third parties.

The user registered in Subelotodo can at all times request closure of his account or his account and information from the database of Subelotodo. For more information see “clause XIII "rights of access, cancellation and rectification of information appear.

Pseudonym

To operate on the Subelotodo website, users should use a user ID that identifies them. No user can have information from other users except when: a) the transactions are international and b) when for national purchases the users have selected Agree Delivery, for the delivery of their products.

Personal Key

Registered users will have a Personal key that will serve the user to buy, bid and/or sell, among other activities. The user shall keep the password confidential and must not share it with other people. In addition, the user will be responsible for all actions that require the use of his user ID and Personal Key, which implies that it will be responsible for paying all fees accrued product of using this user ID and Personal Key. If the user has evidence that a third party knows their key staff, he should change this entering from your account.

III. Information confidentiality

Subelotodo must take measures that are within its reach to protect the privacy of the information of the users. Therefore, Subelotodo will not share Personal information either way onerous or free, with the exception of the ways set out in this document. In addition, the user authorises Subelotodo to provide total or partially Personal information to companies controlled by, controlling or linked to Subelotodo. In the case of court orders or any public authority in which Subelotodo is obliged to provide information, Subelotodo is not responsible for such information. Also, in the event that third parties can access any information illegitimately, Subelotodo is not responsible for the use of the information.

IV. Information Security

Subelotodo believes that its users information is an asset that must be protected from any loss or improper access. For this reason, various security techniques are used to protect such data from unauthorized access by users inside or outside the company. Subelotodo undertakes to comply with all applicable regulations in the field of security measures applicable to the Personal information to reduce the risk.

Pese a lo anterior, es necesario tener en cuenta que la seguridad perfecta no existe en Internet, por ello. Subelotodo no se hace responsable por apropiaciones ilegitimas y violación de sus sistemas o bases de datos por parte de personas no autorizadas y el respectivo uso de dicha información.

V. How does Subelotodo use the information?

Information gathering allows Subelotodo to provide its users the features and services that best suit them and customize them for the benefit of the same. The Personal information collected has the following purposes:

1. Helping users to contact directly and anonymously. Subelotodo will provide stakeholders through email or the web site, only pseudonym data for purposes of facilitating transactions among them. To know the personal data such as name, phone, email, and address will require the express permission of Subelotodo. This information may only be used by stakeholders to conclude the operation originated in Subelotodo.
2. Realize internal studies on interests, location, and behavior of users to offer the best services and providing information of interest to them according to their needs.
3. Develop commercial and advertising offers, content and services through the analysis of visited web pages and searches for users to improve their presentation.
4. Send information about new services, news about Subelotodo and advertising about products or services of interest to the user. However, the user can request not to include the sending of this information lists.
5. In case that the user wins a promotion of Subelotodo, they authorize to disseminate their names, personal data and photographs of him or his family by any means for advertising purposes without right for compensation therefore.
6. Share Personal information with service providers or to the outsourcing companies such as transportation services, media or intermediaries in the management of payments. insurance, call Centers, loyalty programs among others with the purpose of improving or facilitating services and operations. Subelotodo will take care that certain standards are met through the signing of agreements of the privacy of the information of its users. However, Subelotodo is not responsible for the misuse of the information these providers make. Sometimes providers collect information directly from users and in these cases, he will receive a notification about this activity, and will be at the discretion of the same information that he wants to provide and the uses that are made of the same. In the event that the user provides them with additional information, on its own initiative, providers will use that information according to their own policies, so, Subelotodo is not responsible for such use. If Subelotodo decides to disclose information to third parties different providers that are referenced, it will request the consent of the user.
7. In case of disputes between the users and Subelotodo, the latter may provide Personal information institutions such as insurance companies, conciliators, courts of arbitration or any Court of competent jurisdiction.

VI. The use of information by other Subelotodo users

Subelotodo has a policy of restricted access of Personal information of a user to other users. Users may only use the Personal information of other users obtained on the site to: a) Subelotodo-related communications which constitute commercial communications requested and authorized, b) use Subelotodo services such as shipping or transportation and complaints about fraud, among others and (c) any other purpose to which the corresponding user expressly consents once you have been notified previously information legally required.

On the other hand, the information to which the user has access according to the previous procedures, may not be disclosed to other users or third parties without due authorization of Subelotodo or the user that owns it. In addition, it is prohibited for users to add the email or in any other medium, e-mail address or other information of another user of Subelotodo, even the data of those who have bought or sold an article featured in Subelotodo.

VII. Legal Requirements

Subelotodo will cooperate with the judicial or administrative authorities to ensure faithful compliance with the law and in order to safeguard the integrity and the security of society and its users. Therefore, Subelotodo can provide Personal information of its users at the request of any authority for the purposes of its investigations in cases such as: protection of industrial and intellectual property rights, prevention of fraud and other matters, and for his part, the user authorises Subelotodo to provide the information that in its discretion it deems appropriate for the faithful fulfillment of the law.

Subelotodo according to its discretion and when deems it necessary on grounds that the activity of a user is suspect or presents signs attempting to commit a crime or harm a person, it can provide Personal information of a user to other users or third parties to enforce the terms and conditions of use of Subelotodo and other policies of the site and in order to cooperate with the implementation and compliance with the law. This power shall be exercised by Subelotodo whether or not a judicial or administrative order exists to the effect.

VIII. Interactive Zone Information

Subelotodo offers users a space for questions, answers, comments, suggestions, to raise discussions and topics of interest in a friendly atmosphere subject to rules, through the interactive zone. It is important to clarify that the data and information that are published in this space are completely public, so it can be used by any user, whereupon, Subelotodo is not responsible for any misuse of such information. For more information see Interactive Zone rules.

IX. Information tools of Subelotodo

Cookies

Subelotodo may use a tracking system through the use of cookies. Cookies are files that are installed on a hard drive, which have a limited time duration and help to customize services. Cookies are important, because there are some applications that only they can provide under this system. In addition, these are used in order to meet the interests, needs, location and behavior of users and thus provide better service: Cookies may also be used to promote and enforce compliance with the rules and the site's security.

Some of the uses that Subelotodo can make of the Cookies include: a) so that the user does not have to enter your password as frequently during a browsing session, b) to account for and verify registration, activity of the user and others. The purpose of the installation of the Cookies will always be the benefit of the user who receives it, and will not be used with other purposes other than Subelotodo.

Subelotodo uses Google Analytics for demographics and interest information from the User, so if he wants to disable this monitoring, he can go to means of disqualification.

The user or visitor of the site knows and agrees that Subelotodo can use this system. Installation and permanence of Cookies on the user's computer can be eliminated when he so desires. To know how to remove Cookies from the system is necessary to check the help section (Help) of the browser used by the user. It is clarified that these policies cover the use of Cookies by this site, so it is established that Subelotodo does not control the use of Cookies by third parties.

Web Beacons

Subelotodo may also make use of a Web beacon. A web beacon is an electronic image, also called a single-pixel (1 x 1) or transparent pixel, that is placed on a Web page code. A Web beacon has purposes similar to Cookies but in addition, a Web beacon is used to measure patterns of traffic of users from one page to another in order to maximize as traffic flows through the Web. The user and the visitor of the Subelotodo website know and accept that Subelotodo may use a system for tracking through the use of Web beacons.

X. Share this product with a friend

Through this option, Subelotodo will send an email to a friend chosen by the user, inviting him to visit a product: so the user must provide the name and e-mail of his friend. This information will be only used for sending the invitation and to follow it up.

People who are not registered users on Subelotodo, such as children under age, can visit Subelotodo and use this tool.

Subelotodo warns that according to its policy of information reservation. It is prohibited to use this service for the massive sending of unwanted e-mail or "spamming" by which it prohibits users to send such messages.

Subelotodo may suspend or disable users that are using this service for the purposes of promoting his items for sale or any other purpose other than the intended for this service and that are denounced by those who receive such messages. Who does not want to receive these invitations must request it.

XII. E-mail preference changes

When registering on Subelotodo, the user provides consent for InterMall to send to his email messages containing advertising, promotions or news. If the user does not want to receive emails from Subelotodo he can change your preferences for e-mail in the section my Subelotodo. In that paragraph, the user can choose their preferences so that they are taken into account by Subelotodo in the promotions, advertising and news.

XIII. Access, modification and cancellation of the Personal Information rights

The user is entitled to access, modify and delete his Personal information. On the other hand, he undertakes and is responsible for the veracity, accuracy and validity of the information provided and undertakes to keep it updated. Once registered on Subelotodo, users may review and modify the information that has been sent as:

1. The email address. However, for purposes of security, Subelotodo will retain the above information.
2. The information provided on registration as: Enterprise, address, postal code, country, phone number, fax number, email and others.
3. Security Personal Key.

The purpose of retaining any information that the user has requested to be withdrawn is to be used in case of disputes or claims or to detect problems and solve them. Also for reasons of security, technical and legal, the user should not expect that his Personal information is automatically deleted from Subelotodo databases.

Users are required to update his information as data must be modified. The updating of information will be done through the my Subelotodo section > my data.

Subelotodo may modify at any time the terms and conditions of these policies.

If material changes are made in the way Personal information is managed, it will be notified by e-mail to allow the user to make an informed decision, regarding if he agrees or not that his Personal information be used as proposed.

XIV. Final considerations about children under age

On Minors

To access the services of Subelotodo the user must be a person with legal capacity to contract: so, persons who do not comply with this requirement should refrain to register on the site unless they do so through their legal representative.

However, minors of age can visit Subelotodo and suggest a product through the option "Share this product to a friend", as previously explained in these policies.

Validity

The present policies are valid from their acceptance by new users, and are valid from April 30, 2011.