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Come Together Privacy Policy

Notice about personal information handled through Come Together.

Privacy PolicyLegal Center
Table of contents

Platform Operator: Bitopia LLC Website: https://cometogether.ar Privacy Contact: [email protected]

1. Introduction

At Come Together, we recognize the importance of protecting the privacy and personal data of individuals who use our Platform.

This Privacy Policy explains how Bitopia LLC ("Bitopia", "we") collects, uses, stores, shares, and protects personal information in connection with Come Together.

Come Together is a technology platform that enables organizations to manage communities, events, activities, bookings, content, communications, and other digital or in-person functionalities.

This Policy applies to Come Together's websites, mobile applications, and services, to the extent that Bitopia is involved in the processing of personal data.

It also explains the distribution of responsibilities between Bitopia and the Organizations that use the Platform.

2. Identity and Contact

Come Together is provided by:

Bitopia LLC 20900 NE 30th Ave, Fl 8 Aventura, FL 33180 United States

Privacy Inquiries: [email protected]

General Inquiries: [email protected]

Trust Center: https://trust.bitopia.digital/

3. Scope of this Policy

This Policy covers the processing of information related to:

  • Visitors to Come Together websites.
  • Administrators and operators of Organizations.
  • Community members.
  • Event and activity participants.
  • Individuals who request or make bookings.
  • Mobile application users.
  • Parents, mothers, tutors, and representatives, where applicable.
  • Individuals who receive communications through the Platform.
  • Business contacts and Client representatives.

Available functionalities may vary depending on the Organization, the contracted product, and the service configuration.

This Policy may also apply to new functionalities incorporated into Come Together, without prejudice to certain activities requiring additional privacy notices.

4. Roles and Responsibilities in Data Processing

4.1. Organizations as Data Controllers

When an Organization uses Come Together to manage its members, participants, bookings, activities, or services, it generally determines what information needs to be collected and for what purposes.

Under those circumstances, the Organization acts as the data controller for the corresponding data, in accordance with applicable legislation.

Its responsibilities may include:

  • Determining the purposes of information collection.
  • Establishing the data required for each activity.
  • Informing users about the processing of their data.
  • Obtaining consents or authorizations when necessary.
  • Establishing access and retention criteria.
  • Addressing requests related to the data it manages.
  • Complying with special requirements applicable to minors.

4.2. Bitopia as Data Processor

When Bitopia processes information on behalf of an Organization, it acts as a technology provider and data processor, as applicable.

In this context, Bitopia processes information to provide the contracted services, following the authorized instructions of the Organization and applicable legal obligations.

4.3. Bitopia as Controller for Certain Processing Activities

Bitopia may also determine the purposes and means of certain processing activities necessary for its own operations, including:

  • Account administration and business relationships.
  • Billing and contractual management.
  • Platform security.
  • Prevention of fraud and abuse.
  • Handling of requests and support.
  • Compliance with legal obligations.
  • Operational analysis and service improvement, in accordance with applicable terms.

In such cases, Bitopia assumes the obligations corresponding to it as a data controller.

The status of controller or processor depends on each specific activity and not exclusively on who stores the information.

5. Personal Information We May Process

Depending on the product, configuration, and purpose, Come Together may process different categories of information.

5.1. Identification and Contact Information

May include:

  • First and last name.
  • Email address.
  • Telephone number.
  • Date of birth or age.
  • Country, region, or administrative location.
  • Account identifiers.
  • Personally identifiable information, when required by the Organization.

5.2. Account and Profile Information

May include:

  • Registration data.
  • Authentication identifiers.
  • Organization or community to which the user belongs.
  • Roles, permissions, and responsibilities.
  • Language preferences.
  • Profile information.
  • Activation and access statuses.

When external identity providers are used, Come Together may receive the authorized attributes necessary to authenticate or identify the user.

5.3. Community Information

May include:

  • Memberships and community associations.
  • Profile information.
  • Posts and content.
  • Participation in activities.
  • Permissions and roles.
  • Community-related interactions and communications.

5.4. Event and Activity Information

May include:

  • Registrations.
  • Forms and responses.
  • Participation requirements.
  • Approval and confirmation statuses.
  • Group assignments.
  • Accreditations and QR codes.
  • Attendance logs.
  • Documents and authorizations.
  • Photographs and content associated with activities.

5.5. Booking Information

When the corresponding functionalities are enabled, may include:

  • Identification of the requester.
  • Requested space, resource, activity, or service.
  • Date and time.
  • Availability and confirmation.
  • Booking status.
  • Modification and cancellation history.
  • Additional information required by the Organization.

5.6. Information on Minors and Representatives

When an Organization manages activities involving minors, the Platform may process information related to:

  • Identification and age of the minor.
  • Data of parents, mothers, or tutors.
  • Representation relationships.
  • Authorizations.
  • Emergency contacts.
  • Specific participation requirements.

The collection of this data depends on the enabled functionalities and the decisions of the responsible Organization.

5.7. Particularly Sensitive Information

Certain Organizations may configure forms that request additional information, such as accessibility needs, allergies, conditions relevant to an activity, or other data that, according to applicable legislation, may be considered sensitive.

Such data must be requested only when there is a legitimate purpose, an adequate legal basis, and the corresponding safeguards.

Bitopia does not require all Organizations to collect these categories of information.

5.8. Technical and Usage Information

We may process technical information necessary to operate, protect, and improve the Platform, such as:

  • IP address.
  • Device and browser type.
  • Operating system.
  • Technical identifiers.
  • Access logs.
  • Date and time of certain operations.
  • Error and performance information.
  • Interactions with functionalities.
  • Security and audit logs.

The scope of the information collected depends on the technologies actually used.

5.9. Communication Information

When messaging functionalities are used, we may process information necessary to manage communications, including:

  • Recipient contact data.
  • Message content.
  • Channel used.
  • Send or delivery status, when available.
  • Technical and operational logs.
  • Communication preferences and opt-out requests.

6. Origin of Information

We may obtain personal information:

  1. Directly from users, through forms, registrations, or interactions.
  2. From Organizations that manage activities or communities.
  3. From authorized administrators or representatives.
  4. From parents, mothers, or tutors, where applicable.
  5. From identity providers used for authentication.
  6. From enabled integrations and external services.
  7. Automatically, through technical logs and technologies necessary for the operation of the Platform.

The information obtained will depend on the permissions granted and the functionalities actually used.

7. Purposes of Processing

Personal information may be used for:

Provision of services: providing the contracted or enabled functionalities.

User administration: managing accounts, authentication, profiles, roles, and permissions.

Community management: managing memberships, posts, content, and activities.

Event management: processing registrations, approvals, accreditations, and attendance.

Booking management: managing availability, requests, confirmations, and cancellations.

Communications: sending messages related to activities, services, accounts, and operations.

Support: responding to inquiries and resolving issues.

Security: detecting unauthorized access, preventing abuse, and protecting systems.

Commercial administration: managing contractual relationships, billing, and communications with Clients.

Service improvement: analyzing the operation, performance, and use of the Platform in accordance with applicable contractual and legal terms.

Legal compliance: responding to regulatory obligations, valid requests from authorities, and legal claims.

Data processed on behalf of an Organization will not be used freely for purposes unrelated to the provision of services or applicable authorizations and obligations.

Use of Data and Artificial Intelligence

Come Together may incorporate functionalities based on artificial intelligence, machine learning, and other technologies aimed at improving user experience, optimizing processes, and developing new Platform capabilities.

Currently, Come Together does not use personal data or information provided by Organizations to train artificial intelligence models.

In the future, Bitopia may use anonymized or aggregated information for the development, training, and improvement of technological models, provided that such information has been transformed in a manner that does not reasonably allow for the identification of natural persons, and that the processing is permitted by applicable legislation and contractual agreements.

The use of personal data or identifiable information for additional purposes will require a specific evaluation and, where applicable, a valid legal basis, the necessary authorizations, and the updating of this Policy.

Legal bases depend on the purpose, context, and applicable legislation.

Where applicable, processing may be based on:

  • Performance of a contract or adoption of pre-contractual measures.
  • Compliance with legal obligations.
  • Valid consent of the data subject.
  • Legitimate interests, when permitted by applicable legislation and the rights of affected individuals have been evaluated.
  • Other bases recognized by applicable legislation.

When an Organization acts as a data controller, it is responsible for determining and communicating the appropriate legal bases for the processing activities it decides to perform.

The use of Come Together does not replace that obligation.

9. Communications and Messaging

Come Together may facilitate the sending of communications via email, application notifications, WhatsApp, SMS, or other enabled channels.

These communications may include:

  • Registration confirmations.
  • Community information.
  • Activity reminders.
  • Booking updates.
  • Schedule changes.
  • Operational notifications.
  • Administrative communications.
  • Promotional messages, when permitted.

WhatsApp messages may be sent through accounts or numbers managed by Bitopia or through WhatsApp Business accounts connected by the Organizations.

Organizations are responsible for having the necessary authorizations for the messages they configure and for respecting recipient preferences.

Promotional messages will be subject to the corresponding consent and opt-out conditions.

Operational communications necessary to provide a service may be handled differently than commercial communications, in accordance with applicable legislation.

The use of these channels may also involve the processing of information by third-party providers.

10. Service Providers and Subprocessors

Bitopia may use third-party providers to provide infrastructure, hosting, authentication, communications, support, security, and other functionalities.

When such providers process personal data on behalf of Bitopia, the corresponding contractual and legal obligations apply.

Corporate information regarding subprocessors is available at:

https://trust.bitopia.digital/subprocessors

Not all providers included in the corporate list necessarily intervene in each implementation of Come Together.

Organizations may also connect external services under their own decisions and responsibilities.

11. Storage and International Transfers

Come Together uses technological infrastructure and service providers that may be involved in the storage, processing, and transmission of information.

Depending on the contracted service, configuration, and providers used, personal data may be processed or accessible from different jurisdictions.

Bitopia adopts the technical, organizational, and contractual measures corresponding to its obligations and the characteristics of each processing activity.

When specific requirements for international data transfers apply, their compliance must be evaluated according to the corresponding legislation, contractual agreements, and the characteristics of the implementation.

Organizations requiring specific data residency conditions or international transfers may contact Bitopia to evaluate feasibility.

12. Information Security

Bitopia applies technical and organizational measures designed to protect the confidentiality, integrity, and availability of information processed through its services.

These measures may include access controls, authentication, permission management, security logs, incident response procedures, and other appropriate safeguards.

Security also depends on the configuration performed by Organizations, the administration of their users, and the protection of their credentials.

No technological system can guarantee the absolute elimination of all risks.

Additional information on corporate security practices can be consulted at:

https://trust.bitopia.digital/

13. Data Retention

Come Together retains personal information for as long as necessary to provide its services, fulfill the corresponding purposes, and meet applicable contractual and legal obligations.

Retention periods may vary depending on the type of information, each Organization's configuration, commercial terms, and corresponding legal requirements.

Account deactivation, the completion of an activity, or the termination of a contractual relationship do not necessarily imply the immediate deletion of all associated data.

Requests for the deletion of personal data may be submitted via [email protected] and are handled in accordance with Bitopia LLC's Data Deletion Policy.

Deletion may be subject to identity verifications, legal retention obligations, and other exceptions permitted by applicable legislation.

Backups and technical logs are managed in accordance with applicable security, retention, and deletion procedures, without prejudice to corresponding legal and contractual obligations.

14. Data Deletion Requests

Individuals may request the deletion of their personal data via:

[email protected]

To process a request, Bitopia may require information reasonably necessary to locate the data and verify the identity of the requester.

In accordance with Bitopia's corporate policy:

  • Requests are initially verified and reviewed within 5 business days.
  • Approved requests are processed within 30 business days, subject to applicable legal requirements and exceptions.
  • Confirmation and a deletion certificate are provided when the corresponding procedure is completed.
  • Logs of requests and actions are retained for 5 years, unless another legal period applies.

When data is managed by an Organization acting as a data controller, Bitopia may need to coordinate the request with said Organization.

Some applications may allow account cancellation or deactivation directly from their interface. These actions do not necessarily imply the deletion of all associated personal data.

15. Rights of Individuals

Depending on applicable legislation, individuals may have the right to:

  • Request information about the processing of their data.
  • Access their personal data.
  • Request the rectification of incorrect information.
  • Request the deletion of data.
  • Object to certain processing activities.
  • Request the restriction of processing.
  • Withdraw consent where applicable.
  • Request data portability when applicable.
  • Lodge complaints with competent authorities.

The scope and conditions for exercising these rights depend on applicable legislation.

Requests may be sent to [email protected].

When an Organization is the data controller, Bitopia may forward or coordinate the request with it, as appropriate.

16. Privacy of Minors

Come Together may provide functionalities intended for Organizations that carry out activities with minors.

The information collected and authorization mechanisms depend on the characteristics of each activity and the configurations made by the Organization.

Organizations are responsible for determining applicable legal requirements, including consents and authorizations from parents, mothers, or tutors when necessary.

Bitopia provides technological tools to facilitate certain processes without replacing the legal responsibilities of Organizations.

Requests related to minors' data may require additional identity and representation verifications.

17. Cookies, Analytics, and Similar Technologies

Come Together uses cookies and similar technologies to enable the operation of its websites, maintain sessions, remember preferences, and analyze Platform usage.

These technologies may include:

  • Necessary cookies: used for essential functions such as security, session management, and storage of consent preferences.
  • Preference cookies: allow remembering certain user configurations, such as the selected language.
  • Statistics cookies: allow obtaining information on website usage and understanding how visitors interact with its content and functionalities.

Come Together uses Google Analytics to obtain statistics on the use of its websites and help improve their operation and user experience.

Cookies that are not strictly necessary will be subject to available consent options and applicable legal requirements.

Users may accept, reject, or configure optional cookie categories through the preference manager available on the website. They may also review their choices subsequently via the "Manage cookies" option.

Detailed information on the cookies used, their providers, purposes, and duration periods is available in the Cookie Policy and the cookie preference manager.

Come Together may contain links or integrations with websites, applications, and services operated by third parties.

These providers may process information in accordance with their own privacy policies.

Bitopia does not necessarily determine the privacy practices of independent external services.

Organizations must evaluate the integrations they enable and provide corresponding notices when necessary.

19. Future Functionalities and External Payments

Come Together may incorporate functionalities that allow Organizations to manage payments for events, activities, bookings, or other services through third-party providers.

When these functionalities are available, payment providers may process information necessary to process transactions, prevent fraud, and comply with their own legal obligations.

Bitopia's involvement and the categories of shared information will depend on the implemented integration.

This section does not imply that Come Together currently processes payments or directly stores complete bank card information.

When payment functionalities are enabled, additional information regarding the corresponding processing activities will be provided.

20. Changes to this Policy

Bitopia may update this Policy to reflect modifications in its services, processing practices, or legal requirements.

The current version will be available on the Come Together website.

When changes are substantial, the notifications required by applicable legislation will be provided.

21. Inquiries Regarding Specific Data Protection Requirements

Organizations that need to evaluate specific privacy, data protection, or regulatory compliance requirements may contact Bitopia.

Do you need to comply with GDPR or other data protection requirements? Contact our team to analyze your organization's requirements and evaluate whether Come Together can adapt to your needs.

Contact: [email protected]

22. Contact

For inquiries regarding this Policy or the processing of personal data:

Bitopia LLC 20900 NE 30th Ave, Fl 8 Aventura, FL 33180 United States

Privacy: [email protected] General Inquiries: [email protected] Trust Center: https://trust.bitopia.digital/