Privacy Policy

1. Personal Data Subject to Processing
To carry out the purposes described in this Privacy Policy, Tomos Expenses will collect and process the following personal data, of which you are the owner: (i) full name, (ii) email, (iii) phone/mobile number, (iv) address, (v) date and place of birth, (vi) nationality, (vii) tax ID, (viii) marital status, (ix) identification and contact details, (x) geolocation, (xi) academic data, (xii) migration data (if applicable), (xiii) [if authorized, data verification through social networks], (xiv) financial data, (xv) outstanding debts; and for the company you represent: (i) full name, (ii) address, (iii) tax ID, (iv) identification and contact details, (v) data verification through social networks, (vi) financial data, (vii) outstanding debts, (viii) income and expenses via tax authority account, (ix) purpose of credit, (x) business type. All this information will hereafter be referred to as “Personal Data.”

Personal Data may be collected in person, through our site Tomos.io (“Website”), our software application (“App”), or by any electronic, telephone, video, or technological means (“Electronic Means”), and, where applicable, through agents, promoters, contractors, suppliers, or business partners. This is required to follow up on your user account request, provide our services (including financial services), or enforce compliance with agreements or contracts signed with Tomos Expenses.

Tomos Expenses may perform analyses, reports, video calls, photographs, in-person or remote interviews, as well as other actions, directly or through third parties, to verify the accuracy of the data you provided.

2. Essential Purposes
Tomos Expenses processes your Personal Data only for legitimate and specific purposes permitted by applicable privacy law, including:

• Fulfilling contractual obligations derived from the request and/or contracting of our Services.

• Verifying and confirming your identity and that of the legal entity you represent, as well as the accuracy of the information you provide.

• Managing and monitoring services and products requested or contracted with Tomos Expenses.

• Analyzing the information provided to determine risk level, payment capacity, transactional profile, and other required assessments.

• Formalizing contractual relationships with Tomos Expenses, maintaining databases, and integrating records.

• Processing requests made via our Electronic Means.

• Creating your profile in our App, verifying credit capacity, and conducting credit investigations.

• Consulting and checking your credit record with authorized credit bureaus.

3. Non-Essential Purposes
Your data may also be used for:

• Sending offers, promotions, marketing, or special events that may interest you.

• Sending financial education content.

• Offering upgrades or improvements to contracted services.

• Informing you about updates to Services.

• Conducting market research, customer experience analysis, and newsletters.

• Maintaining communication with you about our Services.

You may refuse processing of your data for these purposes by sending an email to marketing@tomos.io. If no request is received, your consent will be assumed.

4. Sensitive Data
Tomos Expenses may share your Personal Data with: (i) affiliates or subsidiaries, (ii) competent authorities as required by law, (iii) fraud investigation or debt collection companies, (iv) other companies in case of mergers or acquisitions, (v) financial institutions for credit portfolio operations, (vi) business partners for joint services, and (vii) other cases permitted by law.

5. ARCO Rights
As the data subject, you have the right to:

• Access and request a copy of your data.

• Request corrections.

• Request cancellation.

• Request restriction of processing.

• Object to processing.

To exercise these rights, send an email to marketing@tomos.io with proof of identity and a clear description of the request. Requests will be answered within 2 business days, and if accepted, implemented within 15 business days.

6. Limiting Use or Disclosure
You may limit the use or disclosure of your Personal Data by following the same procedure described in Section 5.

7. Cookies and Technologies
Tomos Expenses uses cookies and similar technologies to collect information about your activity on our Website and App. Cookies help us recognize you and improve functionality. You may disable them in your browser, though some features may not work properly. Our Website may contain links to third-party sites beyond our responsibility.

8. Consent
By accepting this Privacy Policy, you authorize Tomos Expenses to process your Personal Data for the purposes described. If you have questions, contact marketing@tomos.io. We may request consent through online forms, pop-ups, banners, or other methods.

9. Changes to the Privacy Policy
Tomos Expenses may update this Privacy Policy to reflect legal or operational changes. Updates will be published on our Website and App.

10. Declaration
By registering on our Website or App, you acknowledge having read, understood, and accepted this Privacy Policy. An electronic copy will be stored in our database and accessible through your user profile.