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MELI PRIVACY STATEMENT FOR THE PURCHASE OF MUSD

Last updated: 6th of January, 2025

At Meli Dólar, we view the protection of personal data as an opportunity to generate value for our users and members. Your privacy is of utmost importance to us, and we take all necessary measures to protect it.

In order to provide you with the MUSD transaction service, it is necessary to process certain personal data. This Privacy Statement (“Statement”) clearly and thoroughly explains how Meli Dólar collects, uses, and protects your data, as well as your rights regarding the management and control of such information.

This Privacy Statement sets out our practices concerning the use, storage, and disclosure of the information we collect from you during the provision of the Services, as established in the Terms and Conditions. This Privacy Statement forms an integral part of our Terms and Conditions.

Who Is Responsible for the Processing of Personal Data?

Personal information is recorded in a database for which Meli ISAC Ltd. is the data controller, with its registered address at Third floor, 73 Front Street, Hamilton, Bermuda HM12.

What Personal Data Do We Collect and Process?

To fulfill the purposes described in this Privacy Statement, we collect certain categories of personal data from you.

The personal data we collect directly from you at the time of registration and when using our services are:

For Artificial Persons Operating in Argentina and Uruguay

  • Corporate name
  • Business name
  • Type of company
  • Type and number of company identification
  • Telephone number
  • Email address

For Representatives of Artificial Persons, Regardless of Their Place of Residence

  • First name(s) and last name(s)
  • Preferred language for communications
  • Identification document
  • Telephone number
  • Email address
  • Role or position

The personal data we collect automatically when you use our services are:

  • Information from the devices you use to access the MUSD service, as well as other automatically captured data such as browser type or version, operating system, settings, information about some of the applications downloaded, and parameters.
  • Internet IP address you use when connecting to our services or browsing our sites.
  • Data about your activity within our site and applications.

You are not obliged to provide us with the detailed personal data, but refusal to provide them or inaccuracy may prevent you from transacting with MUSD.

What do we do with personal data?

We process your personal data for the following purposes:

  • Identification and verification: To verify the identity of the company, the legal representative and/or the designated contact, as well as to validate the existence and legal nature of the company.
  • Contractual compliance: To manage the registration, onboarding, and participation of the company and its representative in services linked to MUSD, in accordance with the applicable Terms and Conditions.
  • Compliance with legal and regulatory obligations: To fulfill obligations imposed by competent authorities regarding anti-money laundering, terrorism financing, user identification and reporting, tax control, and any other applicable regulations in the relevant jurisdiction.
  • Provision and administration of services: To allow the provision of services related to MUSD, such as purchase, custody, and reimbursement operations, as well as management of loyalty and rewards programs.
  • Communication and user support: To contact the company or its representative to notify about any service-related matter, send relevant information, resolve queries, provide support, and handle requests or comments.
  • Personalization of the experience: To tailor communications and services offered according to the profile, preferences, and characteristics provided by the company and its representative.
  • Conduct any promotional and/or advertising communications of our services via different channels such as email, WhatsApp, SMS, phone.

Use of your data for any other purpose not compatible with those described in this Statement will be communicated to you in due course.

How do we share personal data?

In relation to the purposes described in the previous section (“What do we do with your personal data?”), your personal data may be accessed by or shared with the following categories of recipients:

  • Mercado Libre Group: Companies belonging to our group and operating under the same processes and internal policies, to comply with internal regulations, prevent fraud, manage risks, and facilitate the management of Melidolar services and products.
  • Business partners: Commercial partners with whom Melidolar has a collaborative relationship, to offer you their promotions, products, and services or co-branded services and/or in compliance with legal obligations. Additionally, we may share user information with business partners to prevent fraudulent actions and ensure a secure and sustainable environment on our platform. We always strive for confidentiality and security standards, through agreements or contracts.
  • Service providers: Providers who render services to us and process data on behalf of Melidolar, following our instructions.
  • Competent authorities: Administrative and judicial authorities that require Melidolar’s cooperation to carry out joint activities, in the exercise of their functions and powers. Also when, in the exercise of their powers, they need data or determine sharing with third parties, without the need for an executive or judicial citation, in order to: (a) Assist in the investigation and reporting of fraud, piracy, intellectual or industrial property violations, or any other offense, as well as any activity that may create legal liability for Melidolar and/or its users, (b) Protect a public interest, administer justice, exercise or defend determined rights in judicial or administrative proceedings, or resolve disputes, (c) Comply with applicable laws, regulations or legal provisions, or with a duly substantiated and motivated mandate from a competent authority.
  • Transaction counterparties: Other Meli Dólar Users or Members with whom you may interact in the context of transactions.

Whenever your personal data is shared with third parties, we shall enter into appropriate data transfer or assignment agreements in accordance with applicable legislation.

How Are International Transfers of Personal Data Managed?

The operation of MUSD relies on human, organizational, and technological infrastructure, such as servers and cloud-based services, which may be located in a country other than your own. It is also possible that the recipients of your data, as described in the section “How Do We Share Personal Data?”, are based in a different country. Some of the countries to which we may transfer your data may not provide an adequate level of personal data protection under the laws applicable in your country of residence. In such cases, Meli Dólar shall implement the necessary measures to transfer your data in accordance with applicable regulations, including the use of contractual clauses, binding corporate rules, or other legal mechanisms.

How Long Do We Store Personal Data?

We shall retain your personal data for as long as necessary to: (i) fulfill the purposes for which they were collected; (ii) protect our rights or the rights of third parties; and/or (iii) comply with our contractual obligations or regulatory requirements.

How Do We Protect and Secure Your Personal Data?

Meli Dólar complies with the requirements of applicable regulations and has implemented technical, organizational, and administrative security measures in accordance with industry standards to protect your personal data.

How Can You Exercise Your Rights Regarding Your Personal Data?

Depending on your country of residence, the applicable regulations may grant you certain rights concerning your personal data, including: (i) the right to information, confirmation of processing, and access; (ii) the right to update; (iii) the right to rectify or modify; (iv) the right to opt out of receiving advertisements, deals, and promotional messages; (v) the right of removal or cancellation; (vi) the right to object to or restrict processing; (vii) the right to withdraw consent; (viii) the right to confidentiality, (ix) the right to object to or request a review of automated decisions; and (x) the right to data portability.

You may submit any inquiry, complaint, or request regarding your personal data by email to: privacy@mercadolibre.com.

You also have the right to file a complaint with the data protection authority in your country of residence.

What Law and Jurisdiction Apply?

Any dispute or disagreement concerning the interpretation, validity, execution, or enforcement of this Privacy Statement shall be resolved by the competent courts of [----].

Changes to the Privacy Statement

If Meli Dólar makes changes to this Statement, you will be notified through individual communication using our usual channels (e.g., via email), as well as through our websites or applications (through banners, pop-up messages, or other forms of notification). Where your consent is required, we will inform you accordingly so that you may decide whether to grant it or not.