Privacy and Cookies Policy

PRIVACY POLICY

This Privacy Policy governs the processing of personal data collected through the Platform, a digital product operating under the domain ISITAB.com, previously identified as a digital self-management system for administrative and accounting purposes.

The purpose of this Policy is to inform users about the nature of the data collected, the purposes for which such data is processed, the protection mechanisms implemented, and the rights available to users in their capacity as data subjects.

The Company respects the privacy of its users and of the data collected through the Platform and is committed to protecting their personal information.

Introduction

This Privacy and Cookies Policy describes how the Company, acting as the Data Controller, collects, uses, stores, and protects personal information through the Platform. The Company is committed to safeguarding users’ privacy and to processing personal data in a lawful, transparent, and responsible manner, in accordance with applicable data protection laws.

Information collection

The Platform collects and processes personal and non-personal information from its users through various means and at different stages, including, without limitation, when users:

(i) register and create an account;
(ii) complete or update their profile;
(iii) use Platform features and services; (iv) interact with other Users; and/or
(v) provide information through digital forms or communications.

Collected information may include identification and contact data, account credentials, billing-related information, property and condominium administration data, and any other information strictly necessary for the provision of the services.

The Platform may also collect technical and usage-related data associated with User interaction, in compliance with applicable privacy regulations.

Information storage

The information collected by the Platform is stored on secure servers and protected through technical and organizational security measures designed to prevent unauthorized access, loss, destruction, alteration, or misuse.

Use of information

The information collected through the Platform is used to provide a personalized user experience, improve services, communicate with users for administrative and/or marketing purposes, and comply with applicable laws and regulations. The Platform may also use such information for internal purposes, including data analysis, audits, and service optimization.

Security

The Platform implements reasonable technical, organizational, and administrative security measures, consistent with industry standards, to protect users’ personal information against loss, theft, unauthorized access, alteration, disclosure, or misuse.

Such measures include, without limitation, access controls, information security protocols, internal data management procedures, and safeguards aimed at preserving the confidentiality, integrity, and availability of personal data.

Notwithstanding the foregoing, the User acknowledges that no data transmission or storage system is completely secure. Accordingly, the Platform does not guarantee absolute security and commits only to applying reasonable efforts to protect personal information in accordance with applicable regulations.

Changes to this policy

The Platform may update this Privacy and Cookies Policy at any time. By using the Platform, the User expressly accepts the processing of information as described herein and acknowledges the possibility of refusing the processing of such data by disabling cookies through the appropriate browser settings.

However, the User is informed that blocking cookies may limit or prevent the full use of certain functionalities of the Platform.

Specific Scope

COOKIE POLICY

This Cookie Policy forms an integral part of the Platform’s Terms and Conditions of Use. Its purpose is to provide transparent information regarding the use of cookies and similar technologies that interact with Users’ devices when accessing ISITAB.com, mobile applications, or any derivative modules thereof.

Concept and scope of cookies

Cookies are small data files stored on the User’s browser or device for the purpose of enabling the proper functioning of the Platform, remembering preferences, improving performance, facilitating navigation, and optimizing the overall User experience.

For these purposes, the Platform may use both first-party and third-party cookies, whether session-based or persistent, depending on their nature and function within the Platform’s digital ecosystem.

Purposes of cookie usage

Non-Intrusive nature and data processing

Cookies used by the Platform do not directly identify Users unless the User voluntarily provides personal data through account creation or data submission.

Any data derived from cookie usage is processed in accordance with the following principles:

• Data minimization
• Anonymization, where applicable
• Technological security and safeguards
• Exclusively functional or statistical use

The Company does not use cookies to create individual commercial profiles, nor to track User activity outside the Platform environment.

Cookie management, deactivation, and configuration

Users may manage, block, or delete cookies through their browser settings. Users may also configure alerts to be notified when cookies are being installed.

Users are hereby advised that:

• Disabling necessary cookies may affect or prevent the normal operation of the Platform.
• Limiting functional or performance cookies may degrade the User experience.

The Company shall not be liable for malfunctions or service disruptions resulting from cookie blocking configurations performed by the User.

Third-Party cookies and associated responsibility

The Platform may incorporate technological components or integrations whose operation partially depends on third-party services. Such cookies are not directly managed by the Company but are used solely for indispensable technical functions. All third parties involved are subject to contractual confidentiality obligations and are strictly limited to processing information under the conditions authorized by the Company.

Updates to the cookie policy

The Company may modify this Cookie Policy at any time to reflect technological, regulatory, operational changes, or new functionalities incorporated into the Platform. The version in force shall always be the one published on the Platform

Acceptance of cookie use

By continuing to browse the website or use any module of the Platform, the User acknowledges and consents to the installation and use of cookies in accordance with the purposes, scope, and limitations set forth herein

LIABILITY FOR BREACH OF CONFIDENTIALITY AND MISUSE OF THE PLATFORM

The Administrator User, whether acting as a natural person or a legal entity, undertakes to strictly comply with the provisions set forth in these Conditions of Use, the Privacy Policy, and the Platform’s Operations Manual.

Any improper use, unauthorized disclosure, unlawful access, manipulation, assignment, commercialization, or incorrect processing of personal data, condominium-related information, financial or administrative information, or any other protected content, in violation of the foregoing provisions, shall constitute a material breach.

In the event such breach is verified, the Administrator User shall be solely and exclusively liable vis-à-vis data subjects, the Condominium, and any affected third parties, and such breach may give rise to civil, administrative, and/or criminal legal actions in accordance with the laws of the applicable country of operation and any other relevant jurisdictions.

The Platform reserves the right to immediately suspend or terminate the offending Administrator User’s access, without prejudice to pursuing any legal actions necessary to protect its rights, reputation, operational continuity, and regulatory compliance.

This policy applies equally to members of the Condominium Association, Residents, and, in general, all Users of the Platform.

By registering on the Platform, the User declares that they have read, understood, accepted, and agreed without reservation to all terms, conditions, and policies governing its use, including those contained in official documentation, and undertakes to comply with them faithfully.

All provisions herein shall also apply to External Administrators, who, even if not members of a Condominium Association, shall be fully subject to compliance with the foregoing rules.

USE AND PRIVACY MANUAL FOR ADMINISTRATOR USERS

This document is intended exclusively for Administrator Users, condominium Association members, and authorized personnel.

Role of the Administrator User

The Administrator User acts as the data controller with respect to property owners and residents. The Administrator User determines which data is entered, modified, or maintained on the Platform.

Obligations of the Administrator User

The Administrator User shall:

• Maintain the confidentiality of all data entered into the Platform.
• Prevent unauthorized access by sharing credentials only with authorized personnel.
• Inform property owners of the basic use of their data.
• Rectify, update, or delete data when appropriate.
• Notify Platform support of any incident or data breach

Sensitive data

The Administrator User must exercise heightened caution with respect to information related to:

• Identification data: name, surname, identification number, User profile photo, address, email, telephone numbers of Residents and Condominium Association members.
• Images or photographs of invoices, receipts, or supporting documents.
• Property-related information: apartment number, ownership percentage, property data.
• Financial information necessary for condominium management: payment status, outstanding balances, proof of payment, and payment methods used.
• Personal contact information (telephone numbers, email addresses).
• Identification documents.
• Financial information.
• Medical or emergency information, where applicable.

Sensitive data and Administrator obligations

The Administrator User acknowledges that failure to comply with these obligations may result in civil, administrative, or criminal liability under applicable law.

Proper use of the Platform

The following actions are strictly prohibited:

• Exporting databases for personal use.
• Sharing information with third parties without consent.
• Storing data unrelated to the condominium.
• Using data for external commercial purposes.

Responsibility toward property owners

The Administrator User is responsible for:

• Transparency regarding the purpose of data collection.
• Addressing rectification or deletion requests.
• Maintaining control over access to the administrative panel.

Recommended best practices

• Enable two-factor authentication.
• Change passwords every ninety (90) days.
• Enforce secure device policies.
• Avoid public or unsecured Wi-Fi networks.

Cooperation with the Company

In the event of audits, incidents, or technical requests, the Administrator User agrees to:

• Cooperate with the support team.
• Provide required technical information.
• Allow the implementation of necessary security measures.

All provisions herein apply equally to External Administrators

DATA RETENTION POLICY

Purpose

This Data Retention Policy governs the criteria, timeframes, and procedures under which the Company stores, retains, anonymizes, and deletes data generated and processed through the Platform.

Governing principles

The Company adheres to the following principles when retaining data:

• Necessity: Only data strictly required for operational, legal, contractual, or regulatory purposes is retained.
• Proportionality: Retention periods are aligned with applicable accounting, legal, and contractual obligations.
• Security: Data deletion is performed through secure, controlled, and, where applicable, certified processes.

Categories of data and retention periods

The following retention periods apply, without limitation:

• Data relating to property owners and residential units: Retained for as long as the unit remains active within the Platform, plus an additional period of three (3) years following account closure.
• Residents’ payment history, fees, assessments, and account statements: Retained for the duration of the active account, plus three (3) years after closure.
• Invoices issued to the Condominium: Retained for the duration of the active account, plus ten (3) years following account closure.
• Contracts and financial documentation: Retained for the duration of the active account, plus three (3) years thereafter.
• System activity logs and audit trails: Retained for twenty-four (24) months.
• Support tickets and communications: Retained for twelve (12) months.
• Backup copies: Maintained under a rolling retention cycle ranging from thirty (30) to ninety (90) days, depending on infrastructure and security architecture.

“Data beyond these periods may only be retained if legally required or for legitimate operational reasons”.

Anonymization

Anonymization refers to the irreversible transformation of personal data in such a manner that no individual may be identified, directly or indirectly.

Upon expiration of the applicable legal or operational retention period, data shall be:

• Securely deleted; or
• Converted into anonymized, non-personal data for statistical, analytical, or historical evaluation of the Platform’s overall performance.

Exceptions

Where a legal obligation, regulatory requirement, or judicial order exists, the Company may retain data beyond the standard retention period strictly to the extent required by such obligation.

Legal and best practice considerations

• The Platform issues invoices to Users in compliance with the technical and legal requirements applicable to digital invoicing.
• The Platform recognizes the Condominium Association as a legal entity and enables management either internally or through an External Administrator using the Platform.
• The Platform manages condominium expenses, receipts, and payments in a fully digital environment and respects the internal Condominium Regulations applicable to each property.
• Electronic documents generated through the Platform possess legal validity and are stored under appropriate security and backup conditions.
• The Platform protects the personal information of Condominium Association, Residents, and External Administrators, collecting and processing personal data solely upon explicit User consent granted at the time of registration.
• Data retention periods are limited to the minimum duration necessary to ensure proper service delivery and compliance with applicable economic, accounting, and tax regulations.

LIABILITY FOR BREACH OF CONFIDENTIALITY AND MISUSE OF THE PLATFORM

The Administrator User, whether acting as a natural person or legal entity, undertakes to strictly comply with the provisions set forth in these Terms of Use, the Privacy Policy, and the Platform’s Operations Manual.

Any improper use, unauthorized disclosure, unlawful access, manipulation, assignment, commercialization, or incorrect processing of personal data, condominium-related information, financial or administrative information, or any other protected content, in violation of the foregoing instruments, shall constitute a material breach.

In the event such breach is verified, the Administrator User shall be solely and exclusively liable vis-à-vis the data subjects, the Condominium, and any affected third parties, and may be subject to civil, administrative, and/or criminal actions, in accordance with the laws of the country of operation and any other applicable jurisdiction.

The Platform reserves the right to immediately suspend or terminate access of the offending Administrator User, without prejudice to pursuing any legal actions necessary to protect its rights, reputation, operational continuity, and regulatory compliance.

This policy applies equally to members of the Condominium Association, Residents, and, in general, to all Users of the Platform.

By registering on the Platform, the User declares having read, understood, and fully accepted all terms, conditions, and policies governing its use, including those contained in official documentation, and undertakes to comply with them faithfully.

All provisions herein shall also apply to External Administrators, who, even if not members of a Condominium Association, shall be fully bound by the same obligations.

ADMINISTRATOR USER PRIVACY AND USE MANUAL

This document is intended exclusively for Administrator Users, Condominium Association members, and authorized personnel.

Role of the Administrator User

The Administrator User acts as the data controller vis-à-vis property owners and residents.

Such User determines which data is entered, modified, maintained, or removed from the Platform.

Obligations of the Administrator User

The Administrator User shall:

• Maintain strict confidentiality of all data entered into the Platform.
• Prevent unauthorized access by sharing credentials solely with authorized personnel.
• Inform property owners of the basic use of their data.
• Rectify, update, or delete data when appropriate.
• Notify Platform support of any security incident or data breach.

Sensitive data

Special care must be exercised with respect to:

• Identification data (name, ID number, profile photo, address, email, phone numbers).
• Images of invoices, receipts, or supporting documents.
• Property-related data (apartment number, ownership percentage, property details).
• Financial data related to condominium management (payment status, outstanding balances, proofs of payment).
• Personal contact information.
• Identification documents.
• Financial information.
• Medical or emergency information (where applicable)

Proper use of the Platform

The following actions are strictly prohibited:

• Exporting databases for personal use.
• Sharing information with third parties without consent.
• Storing data unrelated to the condominium.
• Using data for external commercial purposes.

Responsibility toward property owners

The Administrator User is responsible for:

• Transparency regarding the purpose of data collection.
• Addressing rectification or deletion requests.
• Maintaining control over access to the administrative panel.

Recommended best practices

• Enable two-factor authentication.
• Change passwords every ninety (90) days.
• Enforce secure device policies.
• Avoid public or unsecured Wi-Fi networks.

Cooperation with the Company

In the event of audits, incidents, or technical requests, the Administrator User agrees to:

• Cooperate with the support team.
• Provide required technical information.
• Allow the implementation of necessary security measures.

All provisions herein apply equally to External Administrators