Privacy Policy

Gaucho Digital S.R.L. (CUIT 30-71756619-6), with registered address at Melián 2975, Planta Baja, Ciudad Autónoma de Buenos Aires, Argentina, is the controller of the personal data collected through the site https://gaucho.digital and in connection with the services we provide.

For any question related to data protection, you can contact us at administracion@gauchodigital.com.ar.

This policy applies to anyone whose data we process: site visitors, commercial contacts, clients, suppliers and applicants. We comply with Argentine regulations and, where applicable, with international standards — in particular:

• Argentina: Law 25.326 on Personal Data Protection and complementary rules of the Agency for Access to Public Information (AAIP).
• European Union / United Kingdom: Regulation (EU) 2016/679 (GDPR) and UK GDPR.
• California, USA: California Consumer Privacy Act (CCPA), as amended by the CPRA.
• Brazil: Lei Geral de Proteção de Dados (LGPD, Law 13.709/2018).

We collect only the data necessary for the purposes indicated below. The main categories are:

• Contact data: first name, last name, email, phone, company and role, when you provide them in forms or meetings.
• Commercial relationship data: project requirements, communications, billing and payment data.
• Browsing data: IP address, device and browser identifiers, pages visited, time on site and referrer, collected through cookies and similar technologies (see Cookie Policy).
• Candidate data: CV, professional background and references, when you apply for a position.

We do not request sensitive data (racial origin, health, political opinions, religion, etc.). If you voluntarily send us any, we will delete it unless strictly necessary to reply to you.

• Respond to inquiries and manage commercial opportunities.
• Provide our services and manage the contractual relationship with clients and suppliers.
• Issue billing and comply with tax and legal obligations.
• Improve the site, measure its use and prevent fraud (based on aggregated/pseudonymized data when possible).
• Send commercial communications about our services, only when we have consent or a compatible legitimate interest.
• Personnel selection processes.

The legal basis for processing your data depends on the purpose:

• Contract execution or pre-contractual steps (when you contact us as a potential client or supplier).
• Consent (newsletter subscription, non-essential cookies, spontaneous applications). You can withdraw it at any time without affecting the lawfulness of prior processing.
• Compliance with a legal obligation (accounting records, authority requirements).
• Legitimate interest of Gaucho Digital in operating the site, preventing fraud and communicating improvements to active clients, balanced against the data subject's rights.

We do not sell your personal data. We share it only when necessary, with:

• Technology providers acting as processors under contract (hosting, email, CRM, analytics, communication tools, ad platforms).
• Professional advisors (accountants, lawyers) subject to confidentiality duties.
• Authorities when there is a legal obligation or judicial requirement.
• Successors in case of corporate operations (merger, acquisition), informing you in advance when required.

Some of our providers are located outside Argentina (for example, in the USA or the European Union). When we transfer data to those countries, we do so guaranteeing an adequate level of protection through one of the mechanisms provided by applicable regulations:

• Countries considered adequate by the AAIP (Argentina), the European Commission (EU) or equivalent authorities.
• Approved standard contractual clauses (including the EU's "Standard Contractual Clauses") or AAIP model clauses.
• Additional contractual commitments and technical and organizational security measures.

You can request more information about the mechanisms applicable to your case by writing to administracion@gauchodigital.com.ar.

We keep data only for the time necessary to fulfill the purposes for which it was collected and, afterwards, for the periods required by applicable law (in particular, tax and commercial regulations). When there is no legal retention obligation, the data is deleted or anonymized.

We apply reasonable technical and organizational measures to protect data against unauthorized access, loss, alteration or disclosure: access control, encryption in transit, backups, supplier management and internal training. No system is infallible, but we continuously review our practices.

We do not make decisions that produce legal effects on you based solely on automated processing. Some analytical and advertising tools perform aggregated profiling to optimize campaigns, without affecting the data subject's substantial rights or interests. You can manage the cookies linked to these uses in our Cookie Policy.

The site and services are aimed at people over 18 years of age. We do not intentionally collect data from minors under 16 (or the threshold applicable in your jurisdiction). If you notice that a minor sent us data without parental authorization, please write to us so we can delete it.

Without prejudice to the specific rights by jurisdiction detailed below, every data subject can exercise:

• Access: know what data of yours we process and how.
• Rectification / update: correct inaccurate or outdated data.
• Erasure: request deletion of your data when it is no longer necessary or you withdraw consent.
• Objection and restriction: object to or restrict processing in the cases provided by law.
• Portability: receive your data in a structured and commonly used format, when applicable.
• Withdrawal of consent: at any time, without retroactive effect.

To exercise these rights, write to administracion@gauchodigital.com.ar stating your name, jurisdiction of residence and the right you wish to exercise. We may request additional information to verify your identity. We will respond within the timeframes provided by applicable regulations and, in any case, without undue delay.

In accordance with Law 25.326 and its complementary rules:

• The rights of access, rectification, update and erasure are guaranteed under the terms of arts. 14 and 16 of the Law.
• You have the right to file complaints before the Agency for Access to Public Information (AAIP), the control authority in Argentina (argentina.gob.ar/aaip).
• The data subject can exercise the right of access free of charge at intervals of no less than six months, except where a legitimate interest is proven.

If you reside in the European Economic Area, Switzerland or the United Kingdom, you additionally have the following rights:

• Right not to be subject to decisions based solely on automated processing.
• Right to lodge a complaint with the data protection authority of your country of residence (list of DPAs at edpb.europa.eu and, in the UK, ico.org.uk).
• Information about the safeguards applied to international transfers (European Commission Standard Contractual Clauses or other valid mechanisms).

Gaucho Digital is not required to appoint a Data Protection Officer (DPO) or an EU representative. If that changes in the future, we will inform in this policy.

If you reside in California, USA, the California Consumer Privacy Act (as amended by the CPRA) grants you specific rights:

• Right to Know: know the categories and specific pieces of personal information we collect, the sources, the purposes and with whom we share it.
• Right to Delete: request deletion of your personal information, subject to legal exceptions.
• Right to Correct: correct inaccurate information.
• Right to Opt-Out of Sale or Sharing: although we do not sell your personal information in the traditional sense, you can request to opt out of "sharing" for cross-context advertising. Preferences are reflected in the cookie banner and we respect Global Privacy Control (GPC) signals.
• Right to Limit Use of Sensitive Personal Information.
• Non-discrimination for exercising these rights.

To exercise them, write to administracion@gauchodigital.com.ar. You may authorize an agent to act on your behalf; we will verify their authorization.

For residents of Brazil, the Lei Geral de Proteção de Dados (LGPD) applies. You have the right to:

• Confirmation of the existence of processing and access to your data.
• Correction, anonymization, blocking or deletion of unnecessary or excessive data.
• Portability and revocation of consent.
• Information about with whom we share your data.
• File a complaint before the Autoridade Nacional de Proteção de Dados (ANPD) (gov.br/anpd).

We use first- and third-party cookies for different purposes (site operation, analytics and marketing). All the information, including the detail by category and how to manage your preferences, is in our Cookie Policy.

We may update this policy to reflect regulatory, technical or operational changes. We will publish the current version on this page, indicating the date of last update. When changes are substantial, we will communicate them through the usual channels.

For any privacy or data protection question: administracion@gauchodigital.com.ar · Melián 2975, Planta Baja, Ciudad Autónoma de Buenos Aires, Argentina.