This Privacy Policy explains how Activar Insurtech SAS ("Activar", "we" or "us"), the company that operates the Quore platform (the "Service"), handles personal data in accordance with Argentine Personal Data Protection Law No. 25,326 ("Law 25,326"), its regulations and other applicable rules.
1. Who we are
Activar Insurtech SAS (CUIT 30-71678699-0) is a company organized under the laws of the Argentine Republic with its registered address at Av. Ricardo Balbín 3251, Ciudad Autónoma de Buenos Aires. Quore is the product Activar operates: a B2B platform that insurers, brokers and other distributors (our "Customers" or "tenants") use to design, quote, issue and distribute insurance products.
You can contact us about privacy matters at hola@activar.app.
2. Our role: controller or processor
Our role depends on whose data it is:
- Data of our Customers' clients (applicants, policyholders, insured persons and beneficiaries). Each Customer is the data controller: it decides which data to collect, for what purpose and under which legal basis. Activar acts as data processor and processes that data only on the Customer's instructions to provide the Service.
- Data of our own Customers' account users and business contacts, and of visitors to our website. Activar is the data controller.
If you are a client of an insurer or broker that uses Quore, please contact that company to exercise your rights; its privacy notice governs the use of your data. If you contact us, we will forward your request to the corresponding Customer.
3. Data we process
As controller, we process:
- account data: name, work email, phone, company, role and credentials of the users who access the Service;
- billing data: company name, tax identification, billing address and payment details handled by our payment providers;
- usage and technical data: IP address, browser, device, access logs and activity within the Service, used for security and support;
- communications: messages you send us, demo requests and support conversations.
As processor, on behalf of each Customer, we process the data that Customer configures in its products, which may include identification and contact data, date of birth, data about the insured risk (such as vehicles or property), policy and payment information, and attachments uploaded by its clients.
4. Purposes and legal basis
We use the data we control to provide and secure the Service, manage accounts and subscriptions, bill and collect fees, provide support, communicate changes to the Service, improve the product and comply with legal obligations. We process it based on the contract with the Customer, the consent of the data subject when required, and our legal obligations.
We use Customer Data exclusively to provide the Service to that Customer. We do not sell personal data or use our Customers' client data for our own marketing.
5. Payment card data
Quore never stores full card numbers. We keep only the last four digits, the card brand and the cardholder name, to identify the payment method. The card security code (CVV) is never stored. Full card data is entered into and processed by the payment providers (such as Stripe, Mercado Pago or Rebill), which are responsible for handling it under their own security standards (PCI DSS).
6. Service providers and subprocessors
We rely on trusted providers that process personal data on our behalf, under contracts that require confidentiality and adequate security:
- Amazon Web Services (AWS): cloud hosting, databases and file storage;
- Stripe, Mercado Pago and Rebill: payment processing and subscription billing;
- Resend: delivery of transactional email.
We may update this list as the Service evolves. We do not share personal data with third parties for their own purposes, except when required by law or by a competent authority.
7. International transfers
Some of our providers store or process data outside Argentina, including in the United States. When we transfer personal data to countries that the AAIP does not consider to provide an adequate level of protection, we do so in accordance with Section 12 of Law 25,326 and its regulations, using contractual safeguards such as the model clauses approved by the AAIP, or relying on another legal basis permitted by law.
8. Security
We apply technical and organizational measures appropriate to the risk, including encryption in transit (TLS), logical isolation of each tenant's data, role-based access controls, scoped API keys, logging of relevant activity, backups and restricted access for our staff on a need-to-know basis. No system is completely secure; if we become aware of a security incident affecting personal data, we will notify the affected Customers without undue delay and cooperate with them.
9. Data retention
We keep account and billing data while the account is active and afterwards for the periods required by tax, accounting and legal obligations, or to exercise or defend legal claims. Customer Data is kept for the duration of the subscription, then made available for export for thirty (30) days and later deleted or anonymized, unless the Customer instructs otherwise or the law requires us to keep it. Security logs are kept for limited periods.
10. Your rights
Under Law 25,326 you have the right to access, rectify, update and delete your personal data, and to object to its processing in the cases provided by law. To exercise these rights over data we control, write to hola@activar.app from the email associated with your account or with proof of identity. We will answer access requests within ten (10) calendar days and rectification, update or deletion requests within five (5) business days, as provided by the law.
THE DATA SUBJECT HAS THE RIGHT TO ACCESS THEIR PERSONAL DATA FREE OF CHARGE AT INTERVALS OF NO LESS THAN SIX MONTHS, UNLESS A LEGITIMATE INTEREST IS SHOWN, AS PROVIDED IN SECTION 14, SUBSECTION 3 OF LAW No. 25,326. THE AGENCIA DE ACCESO A LA INFORMACIÓN PÚBLICA (AAIP), AS THE CONTROL AUTHORITY OF LAW No. 25,326, HAS THE POWER TO HANDLE THE COMPLAINTS AND CLAIMS FILED BY THOSE WHOSE RIGHTS ARE AFFECTED BY NON-COMPLIANCE WITH THE RULES IN FORCE ON PERSONAL DATA PROTECTION.
12. Minors
The Service is intended for businesses and is not directed at minors. Customers that collect data of minors through their insurance products are responsible for obtaining the authorizations required by law.
13. Changes to this policy
We may update this Privacy Policy. We will publish the new version on this page with its update date and, for material changes, notify account administrators in advance.
14. Contact
For any question or request about this policy or your personal data, write to hola@activar.app.