Table of contents
Provider: Bitopia LLC Platform: Come Together Website: https://cometogether.ar Privacy Contact: [email protected]
1. Introduction
This Data Deletion Policy (hereinafter, the "Policy") describes how requests for the deletion of personal data related to Come Together, a technology platform provided by Bitopia LLC ("Bitopia"), are received, evaluated, and managed.
Its purpose is to provide clear information regarding the mechanisms available to request data deletion, response timeframes, and the circumstances under which certain information may need to be retained.
This Policy supplements the Privacy Policy, Terms and Conditions, and applicable contractual agreements.
2. Scope
This Policy applies to requests for the deletion of personal data processed through Come Together products, applications, and services.
It may encompass information related to:
- User accounts and profiles.
- Event participants and registrations.
- Community members.
- Bookings and activities.
- Contact data.
- Documents and files provided through the Platform.
- Communication logs.
- Administrative information associated with the services.
- Other personal data processed through current or future features.
The deletion of information will depend on the nature of the data, the purpose of its processing, the responsibilities of the parties, and applicable legal or contractual obligations.
3. Responsibilities of Bitopia and Organizations
Come Together allows various Organizations to manage information regarding their participants, members, and users.
In many of these operations, the Organization determines what information to collect, for what purposes to use it, and for how long it needs to be retained, acting as the data controller in accordance with applicable legislation.
Bitopia provides the infrastructure and technological services necessary to process such information on behalf of the Organization, in accordance with the corresponding agreements.
In other contexts, Bitopia may act as the data controller for certain data related to its own operations, accounts, security, support, or commercial administration.
When a request refers to information controlled by an Organization, Bitopia may require its intervention, authorization, or instructions before proceeding with the deletion, as appropriate.
Bitopia will not indiscriminately delete information managed by an Organization when doing so would imply breaching applicable contractual or legal obligations or legitimate instructions.
4. Right to Request Data Deletion
Individuals may request the deletion of their personal data when appropriate under applicable law.
Requests may be related to:
- Personal information that is no longer necessary for the corresponding purposes.
- Data processed without a valid legal basis.
- Information for which there is a legal right to deletion.
- Data associated with accounts that the user wishes to stop using.
- Information whose retention is no longer necessary or justified.
The submission of a request does not imply that all data must be deleted automatically.
Each request will be evaluated considering the legislation, applicable agreements, and the circumstances of the processing.
5. How to Request Data Deletion
Requests for the deletion of personal data may be sent to:
To facilitate processing, it is recommended to include:
- First and last name of the requester.
- Email address associated with the account or registration.
- Related product, event, community, or Organization.
- Description of the information whose deletion is requested.
- Additional information necessary to locate the corresponding records.
It is not necessary to provide additional personal information that is not relevant to processing the request.
Bitopia may request supplementary data when reasonably necessary to verify identity or identify the information involved.
Passwords, authentication codes, or other access credentials must not be sent.
6. Deletion from Applications
Certain Come Together applications or features may offer mechanisms to deactivate an account, request its deletion, or manage personal information directly.
The availability of these options may vary depending on the product and the type of user.
The deactivation of an account does not necessarily imply the immediate or complete deletion of all associated data.
Part of the information may remain linked to event records, bookings, communities, administrative operations, or other legitimate purposes.
When a feature does not allow requesting deletion directly, or when the user wishes to request the deletion of additional information, they may contact [email protected].
This email constitutes the general channel for requests for the deletion of personal data related to Come Together.
7. Receipt and Evaluation of Requests
Bitopia will review requests for the deletion of personal data within a period of five (5) business days from their receipt.
During this stage, it may:
- Verify the identity of the requester when necessary.
- Identify the data involved.
- Determine the role of Bitopia and the corresponding Organization.
- Evaluate the existence of legal or contractual retention obligations.
- Request additional reasonably necessary information.
- Determine whether to approve total or partial deletion.
When the request refers to information managed by an Organization, Bitopia may coordinate necessary actions for its processing with said Organization.
The review period does not constitute a guarantee of automatic approval.
8. Deletion Period
Approved requests will be processed within a period of thirty (30) business days, in accordance with Bitopia's corporate data deletion policy.
The deletion may encompass all or part of the requested information, depending on the data involved and applicable exceptions.
When circumstances exist that prevent completing the deletion within the stipulated period, Bitopia will inform the requester as appropriate, indicating the relevant circumstances and applicable steps.
The foregoing periods shall be interpreted without prejudice to shorter or specific periods that may be required by applicable legislation.
9. Identity Verification
To protect personal information and prevent fraudulent requests, Bitopia may perform reasonable verifications before proceeding with deletion.
These verifications may include confirmation of control over an account or email address, or the request of strictly necessary additional information.
The measures used must be proportional to the type of information involved and the associated risk.
Bitopia will not request passwords or authentication codes to verify a deletion request.
When it is not possible to reasonably verify the identity or legitimacy of the request, its processing may remain pending until the necessary information is obtained.
10. Information That May Be Retained
The deletion of personal data does not always imply the suppression of all related records.
Bitopia or the corresponding Organization may need to retain certain information when a valid legal or contractual justification exists.
This may include:
- Compliance with legal obligations.
- Retention of accounting or tax records.
- Handling requests from competent authorities.
- Prevention and investigation of fraud.
- Security and protection of systems.
- Dispute resolution.
- Exercise or defense of legal claims.
- Compliance with current contractual obligations.
- Other retention circumstances permitted or required by applicable legislation.
Retained information must be limited to what is necessary for the purposes justifying its retention.
The existence of an exception does not authorize the indefinite retention of information without a legitimate foundation.
11. Information Managed by Organizations
When personal data is managed by an Organization acting as a data controller, Bitopia will coordinate the evaluation and execution of deletion requests with said Organization, in accordance with authorized instructions, contractual agreements, and applicable legislation.
The data deletion process may be initiated bilaterally:
- By the data subject: when a user, participant, or member requests the deletion of their personal data, Bitopia may coordinate with the responsible Organization to evaluate and execute the request.
- By the Organization: when an Organization requests the deletion of personal information it manages through Come Together, Bitopia may process such request in accordance with authorized instructions and applicable contractual and legal obligations.
Bitopia will not unilaterally delete information controlled by an Organization, except when a legal obligation requires it or a valid authorization to do so exists.
When Bitopia acts as the data controller for certain personal data, it may evaluate and directly execute the corresponding deletion requests without requiring authorization from an Organization.
In all cases, requests will be subject to the procedures, periods, and exceptions established in this Policy and applicable legislation.
A deletion request submitted by an Organization does not substitute the rights recognized by legislation to data subjects, nor does it authorize the deletion of information whose retention is legally mandatory.
12. Deletion of Accounts and Associated Records
The deletion or deactivation of an account may affect access to certain Come Together products and services.
However, the deletion of the access account and the deletion of related personal records are different operations.
For example, a user may no longer have access to their profile while certain participation or transaction records remain legitimately retained by an Organization.
The deletion of information will be evaluated according to its nature and applicable obligations.
The suspension or termination of contracted accounts and services will be governed exclusively by the corresponding contractual conditions.
This Policy does not establish an independent procedure for the termination of commercial services.
13. Documents, Photographs, and Files
Deletion requests may also encompass documents, photographs, and other personal files uploaded through Come Together.
The deletion of these items will be subject to the same evaluation conditions and corresponding legal or contractual exceptions.
When files are managed by an Organization, Bitopia may need its instructions or authorization to delete them.
Organizations will be responsible for determining the authorizations necessary to retain, publish, or use personal files within their activities.
14. Backups and Technical Systems
Come Together may use backup and recovery mechanisms to protect the availability and integrity of its services.
The deletion of information in operating systems does not necessarily imply its immediate disappearance from all existing backups.
The management of data contained in backups will be carried out in accordance with applicable technical procedures, corresponding retention cycles, and legal and contractual obligations.
When technical restrictions exist that affect the immediate deletion of backed-up information, Bitopia will apply appropriate measures to protect such data and limit its use.
This Policy does not establish a uniform backup retention period for all products and services.
15. External Providers and Subprocessors
Come Together may use external providers to provide infrastructure, storage, communications, and other features.
When an approved deletion request involves information processed by external providers, Bitopia will manage the corresponding actions within the scope of its responsibilities and applicable agreements.
Certain providers may maintain information in accordance with their own legal obligations or service conditions.
Corporate information regarding Bitopia's subprocessors can be consulted at:
https://trust.bitopia.digital/subprocessors
The inclusion of a provider in the corporate list does not necessarily imply that it processes information for all Come Together products.
16. Records of Deletion Requests
Bitopia may retain records related to deletion requests to document their receipt, evaluation, resolution, and compliance.
In accordance with its corporate policy, these records will be retained for five (5) years, unless a legal obligation requires a different period.
Records may include information necessary to accredit the management of the request and the actions performed.
This retention does not imply maintaining integrally all personal data whose deletion has been approved.
17. Confirmation of Deletion
Once an approved request is processed, Bitopia will provide confirmation of the actions performed.
When appropriate, a data deletion certificate may be issued in accordance with its corporate procedures.
The confirmation may identify the categories of information deleted and, when appropriate, applicable exceptions or restrictions.
The issuance of a confirmation does not imply that records whose retention is legally mandatory or legitimately justified have been deleted.
18. Requests Regarding Minors
Requests regarding personal information of minors may be submitted by their parents, tutors, or legal representatives when appropriate.
Bitopia may request reasonable identity and representation verifications before processing these requests.
When data is managed by an Organization, its intervention may be necessary to determine applicable obligations.
The processing of these requests will take into account the minor protection requirements established by corresponding legislation.
19. Rejected or Partially Approved Requests
A request may be rejected or partially approved when valid legal or contractual grounds exist that prevent deleting all requested information.
When appropriate, Bitopia will inform the requester about the decision and the general reasons supporting it, to the extent permitted by applicable legislation.
Individuals may submit additional inquiries or exercise rights recognized by corresponding legislation.
20. Security and Confidentiality
Bitopia will apply reasonable security and confidentiality measures during the receipt, evaluation, and execution of deletion requests.
Access to information used to process these requests will be limited to persons and systems that need to intervene.
Verifications and communications will be conducted seeking to minimize unnecessary exposure of personal data.
21. Relationship with Other Documents
This Policy supplements:
- The Come Together Privacy Policy.
- The Terms and Conditions.
- The Acceptable Use Policy.
- Messaging Conditions, when applicable.
- Applicable commercial agreements.
When a Master Subscription Agreement (MSA), order form, or other written agreement is in effect, its provisions shall prevail in matters expressly regulated and in case of contradiction, in accordance with corresponding priority rules.
This Policy does not modify by itself the commercial obligations of retention, return, or deletion of information established in such agreements.
22. Updates
Bitopia may update this Policy to reflect changes in its services, internal procedures, legal obligations, or data protection practices.
The current version will be available on the Come Together website.
When appropriate, notifications required by legislation or applicable agreements will be provided.
23. Contact
Personal data deletion requests: [email protected]
General support form: https://cometogether.ar/support
Alternative support email: [email protected]
Provider: Bitopia LLC 20900 NE 30th Ave, Fl 8 Aventura, FL 33180 United States
Website: https://cometogether.ar