CUENTAS CLARAS PRIVACY POLICY
1. Purpose and scope
This Privacy Policy describes how Cuentas Claras, a digital service developed and marketed under the Merabo Group brand, collects, uses, stores, protects, and, where applicable, deletes information relating to its users.
This Policy complements the Cuentas Claras Terms and Conditions and must be read together with them.
By registering for and using the service, the user represents that they have had access to this Policy and to the corresponding information regarding the processing of their personal data.
2. Privacy and data-minimization principle
Cuentas Claras seeks to limit the collection, use, storage, and disclosure of personal data to that which is reasonably necessary to create and administer the user's account, authenticate their identity, provide the service's features, maintain its security, manage subscriptions, provide support, comply with legal obligations, and ensure the application operates correctly.
Cuentas Claras does not intend to collect personal information that is unnecessary for the provision of the service.
Where it is necessary to use external providers for the operation of Cuentas Claras, efforts will be made to limit the information processed to that reasonably necessary for such providers to perform the corresponding functions.
3. Registration and profile information
To create, administer, and maintain an account, Cuentas Claras may request information such as:
name;
email address;
date of birth;
city;
province, state, or region;
country;
credentials or technical identifiers necessary for authentication and the operation of the account.
Cuentas Claras does not require, as an ordinary part of the user's profile, their home address or precise geographic location.
The date of birth may be used to verify, based on the information declared by the user, compliance with the age requirements established for the account holder, and to provide certain profile-related features.
4. Financial information entered by the user
To provide its management features, Cuentas Claras allows the user to voluntarily record information relating to their personal or family finances.
This information may include, among other data, income, expenses, savings, investments, debts, budgets, due dates, categories, payment methods identified by the user themselves, transactions, and other information necessary to use the available management tools.
This information is processed for the purpose of allowing the user to record, organize, review, calculate, and analyze their own finances through the features of Cuentas Claras.
Information entered into the application does not imply that Cuentas Claras or Merabo Group receive, hold, manage, or have control over the user's money, accounts, cards, or assets.
5. Protection of financial content
The personal financial information entered by the user will be used to provide the features of Cuentas Claras and the operations that the user themselves requests within the service.
Cuentas Claras and Merabo Group will not sell to third parties the personal financial history recorded by users.
Nor will they use the amounts, transactions, income, expenses, debts, savings, or other personal financial content recorded by a user to build advertising or commercial profiles based on their particular financial situation.
The content and values of personal financial records will also not be used for the purpose of analyzing the general use of Cuentas Claras's tools in order to improve the product.
6. Demographic and profile information
Cuentas Claras may use general profile information, such as age and the approximate geographic location declared by the user — for example, city, province, state, region, or country — to obtain general statistics on the composition and use of the service, understand the general characteristics of its user base, and make decisions relating to the development, operation, and promotion of Cuentas Claras.
Where reasonably possible, this analysis will be carried out using aggregated information or in a manner that reduces the individual identification of users.
This purpose does not involve using the personal financial content recorded within Cuentas Claras to build individual commercial profiles.
7. Usage metrics and service improvement
Cuentas Claras may collect and analyze metrics relating to the use of its tools and features in order to assess the operation, performance, stability, and user experience of the service and to develop improvements.
These metrics may make it possible to know, for example, which features are used, how frequently certain tools are used, whether technical errors occur, or whether certain processes require improvement.
Analysis carried out for these purposes will focus on the use and operation of the tools, and not on the analysis of the amounts, items, or other personal financial content entered by the user.
8. Subscriptions and payments
Contracting and processing of payments, renewals, and certain subscription-related functions may be carried out through external providers.
Cuentas Claras may receive from such providers limited information necessary to manage the contractual relationship and determine access to the service, such as:
subscription status, plan type, confirmation or rejection of a payment, billing- or renewal-related dates, transaction identifiers, and other necessary operational information.
The processing of payment data carried out directly by such providers will also be subject to their own terms and privacy policies.
9. Cards, bank accounts and financial credentials
Cuentas Claras and Merabo Group will not directly request full credit or debit card numbers, CVV/CVC security codes, banking passwords, access credentials for financial institutions, or other credentials intended to access or authorize transactions on the user's financial accounts.
Where it is necessary to provide information relating to a payment method in order to contract for or maintain a subscription, that information will be requested and processed directly by the corresponding external provider.
Cuentas Claras and Merabo Group will never ask the user to disclose banking passwords, card security codes, or credentials for access to financial accounts by email, messaging, technical support, or another communication channel.
10. External providers
Cuentas Claras may rely on external providers to perform functions necessary for the operation of the service, including technology infrastructure, hosting, storage, databases, authentication, communications, security, technical analysis, payment processing, and other functions related to the provision of the application.
Where such providers need to process information relating to users, Cuentas Claras will seek to limit it to that reasonably necessary for the provision of the corresponding function.
The use of external providers does not authorize Cuentas Claras to collect additional personal information that is not reasonably necessary to provide, administer, protect, or fulfil the legal obligations related to the service.
11. Shared accounts and family groups
Cuentas Claras may allow certain spaces or information to be shared among members of a household or authorized group.
Users who take part in a shared space may view or manage certain information in accordance with the available permissions and features.
The account holder and other members are responsible for properly using the invitation features and for sharing only information for which they have sufficient authorization.
The deletion of a member's account will not necessarily result in the deletion of shared information that legitimately belongs to other members or that is necessary to maintain the integrity of their records.
12. Communications and support
When the user contacts Cuentas Claras to make inquiries, request support, file complaints, or exercise rights relating to their account or personal information, the data necessary to identify the request, respond to it, and keep a reasonable record of the handling may be processed.
Cuentas Claras may send necessary communications relating to security, account operation, subscription, payments, material changes to the service, or legal documents.
Promotional communications will be subject to the user's preferences and applicable law.
13. Security and confidentiality
Cuentas Claras will adopt reasonable technical and organizational measures aimed at protecting information against unauthorized access, loss, alteration, disclosure, or improper destruction.
Access to information must be limited to the persons, systems, and providers that reasonably need it to perform the corresponding functions.
However, no computer system or Internet-connected service can guarantee absolute security.
The user is also responsible for keeping their credentials and devices secure and for reporting any incident of which they become aware.
14. Data retention
Information may be retained while the account remains active and for the time reasonably necessary to provide the contracted features and fulfil the purposes described in this Policy.
Where a subscription ends voluntarily, the user may retain access until the end of the contracted or paid period, where applicable.
After that period ends, the account may remain inactive for thirty (30) days, in order to allow the user to reactivate the service or export their information.
In the event of a failed payment that prevents the subscription from renewing, the information may be retained for thirty (30) days from the failed payment, in order to allow it to be resolved, reactivated, or exported.
Once those periods have elapsed without reactivation or resolution, data that is no longer necessary to retain may be deleted or anonymized.
15. Account and data deletion
The user may request deletion of their account using the mechanisms enabled by Cuentas Claras.
Where deletion is requested, Cuentas Claras will delete or anonymize the personal and financial information that is no longer necessary for the legitimate purposes of the service.
Cuentas Claras does not intend to indefinitely retain the financial history of persons who have deleted their accounts.
Only the minimal information whose retention is necessary to comply with legal, tax, regulatory, or contractual obligations; to exercise or defend rights; to manage claims; to prevent or investigate fraud or security incidents; to evidence transactions or consents; to respond to valid requests from competent authorities; or where another legitimate legal basis exists, may be retained.
Where information must be retained for any of these reasons, efforts will be made to limit it to what is strictly necessary and to the corresponding period.
16. Backups
For reasons of security, continuity, and service recovery, certain information may temporarily remain in backup copies after having been deleted from active systems.
Deletion of an account does not necessarily mean the instantaneous disappearance of every existing technical copy.
Residual information contained in backups will be deleted, overwritten, or will cease to be available in accordance with the reasonable retention and renewal cycles of such systems, and must not be used to restore a deleted account unless there is a legitimate legal or technical reason that justifies it.
17. Data export
Before permanently deleting an account, Cuentas Claras will seek to offer the user a mechanism to export the information they have recorded.
Export may be performed in structured and reasonably accessible formats, such as XLSX, CSV, or other technically suitable formats.
It is the user's responsibility to securely keep the exported copies.
18. Technical and security data
Cuentas Claras may process technical information reasonably necessary to operate, protect, and diagnose the service.
This information may include technical identifiers, browser or device information, sessions, error logs, security information, and other technical data necessary to detect problems, prevent unauthorized access, maintain the stability of the service, and protect accounts.
Technical information must be used in a manner consistent with the purposes described in this Policy.
19. Cookies, local storage and similar technologies
Cuentas Claras may use cookies, local storage, or other technologies that are technically necessary to maintain sessions, remember certain preferences, provide features, improve security, and enable the application to function correctly.
Cuentas Claras may also incorporate, in the future, measurement or analytics technologies, usage metrics, or other similar tools that are not strictly necessary for the application's basic operation, in order to understand how the service is used and improve its operation.
Where technologies are incorporated that require additional information or consent under applicable law —including, where applicable, those mentioned in the preceding paragraph— the corresponding mechanisms will be provided.
20. International processing of information
Due to the nature of digital services and the technological infrastructure used, certain external providers may process or store information in countries other than the user's country of residence.
Where applicable, Cuentas Claras will seek to ensure that such processing is carried out in accordance with the safeguards and requirements demanded by applicable law.
21. Disclosure of information to third parties
Cuentas Claras does not commercialize the personal financial history entered by users.
Information may be disclosed to or processed by third parties only where reasonably necessary to provide the service, fulfil a contractual obligation, protect the security of Cuentas Claras or its users, comply with a legal obligation, respond to a valid request from a competent authority, or where another legal basis permits it.
In such circumstances, efforts will be made to limit the information to what is necessary for the corresponding purpose.
22. Requests from authorities
Cuentas Claras does not aim to monitor its users' economic decisions or to determine on its own initiative the lawfulness of their financial activities.
Where there is a court order, a valid request from a competent authority, a legal obligation, or another legally enabling circumstance, Cuentas Claras may preserve and provide the information that is legally required.
The information provided will be limited, as far as possible, to the legitimate scope of the request.
23. User rights
The user may exercise the rights available to them over their personal data under applicable law, including, where applicable, access, updating, rectification, and erasure.
Cuentas Claras will provide reasonable mechanisms for requesting the exercise of such rights and may require information necessary to reasonably verify the identity of the requester before addressing a request relating to personal data.
Requests may be directed to the contact channel indicated in this Policy.
24. Minors
The person who subscribes to a plan or acts as the primary holder of an account must be at least eighteen (18) years of age and have sufficient legal capacity to contract, in accordance with the Terms and Conditions.
Any participation of other members in family or shared spaces will be subject to the available features, permissions, and conditions.
Cuentas Claras is not designed to deliberately collect personal information from minors acting as the contracting holders of the service.
25. Amendments to this Policy
This Policy may be updated as a result of legal, regulatory, technological, or operational changes, or changes relating to the features of Cuentas Claras.
Each version will be identified by a date or version number.
Where an amendment is substantial and necessary under applicable law, Cuentas Claras will notify the user and may require a new acceptance.
26. Responsible party and relationship with the Terms and Conditions
Cuentas Claras is a digital service developed and marketed under the Merabo Group brand.
The full identification of the party legally responsible for the service, its tax identification number, and address are available in the "Identification of the party responsible for the service" section of the Cuentas Claras Terms and Conditions, which form part of the legal documentation available to the user.
Use of the Merabo Group brand does not modify the responsibilities that legally correspond to the party responsible for the service.
27. Privacy contact
For inquiries relating to this Policy, the processing of personal data, requests for access, rectification, erasure, or other privacy matters, the user may get in touch through:
Email: merabogroup@gmail.com
28. Governing law
This Policy will be interpreted principally in accordance with the laws of the Argentine Republic, including applicable rules on personal data protection and consumer protection.
The foregoing is without prejudice to the rights and mandatory rules that may apply to users located in other jurisdictions.