|1. Identity and address of the data controller
DIEGO FRIAS NERIO, on his own behalf, with address at Calle Ramon García Chavarri, number 2780, interior D4, Colonia Lomas, Monterrey, Nuevo León, C.P. 64030, who operates the Chapter application (hereinafter, “Chapter,” “we,” or the “Controller”), is responsible for the processing of personal data collected from users of the application.
For any matter related to privacy and personal data protection, you can contact us at support@clubchapter.com.
2. Personal data we collect
We may collect and process the following categories of personal data, depending on how you use Chapter:
- Identification and account data: name, user identifier, email address, and profile photo, when you choose to provide it.
- Authentication data: information necessary to create and manage your account. If you register via email and password, credentials are stored securely. If you use Apple or Google login (OAuth), authentication is performed through the corresponding provider and Chapter does not store your password for that provider.
- Data obtained through login providers: name and email associated with your Apple or Google account. When using Apple and choosing the “Hide my email” feature, we may receive and store the private alias provided by Apple, which forwards communications to your real email address.
- Usage data: information about your activity and interactions within the application, used to understand feature usage, address incidents, and improve the service.
- Device data and identifiers: technical information and device identifiers that may be collected, among other purposes, for the measurement and personalization of advertising through Google Ads services.
Chapter does not intentionally collect sensitive personal data through the application. However, if you choose to voluntarily include sensitive personal information when posting reviews, comments, or other public content within Chapter, such processing will be under your strict and exclusive responsibility, and such information will be subject to the platform’s visibility conditions.
3. Purposes of processing
Your personal data will be processed for the following primary purposes, necessary to provide you with Chapter:
- Create, authenticate, and manage your account;
- Allow access to application features and synchronize your information across devices;
- Provide support, handle requests, and resolve technical issues;
- Maintain the security, continuity, and proper functioning of the application; and
- Perform strictly necessary operational and statistical analyses to detect errors, prevent failures, and improve overall service performance, provided that such analyses are not used to personalize advertising.
- Additionally, your data may be processed for the following secondary purposes:
- Advertising personalization; and
- Usage analysis linked to personal or device identifiers for advertising measurement or personalization purposes.
You may object to these secondary purposes in accordance with section 5 of this notice, without affecting access to the essential features of Chapter.
Chapter does not sell your personal data to third parties.
4. Use of providers and third parties
Chapter uses service providers for specific functions such as data storage and synchronization, authentication, analytics, and advertising. These may include services from Firebase, Apple, Google, and Google Ads, depending on the functionality used.
Depending on the relevant service, these providers may process categories such as user or device identifiers, email, authentication data, and usage data, exclusively to the extent necessary to provide the contracted service or enable the requested feature. When a provider operates under its own terms or policies—for example, in authentication or advertising services—this will be informed to the user through this notice, the relevant interface, or both.
When you disable analytics tracking from the application settings, Chapter may continue to collect anonymized usage information to improve the application; such information will not be associated with data that identifies you, such as your user identifier, name, or email address.
We inform you that the use of these providers for storage, analytics, and technical operation constitutes a data transfer, as they process the information exclusively on behalf of and for Chapter. Except for these transfers, Chapter does not transfer your
personal data to third parties for their own use, unless your prior and express consent is obtained, or one of the exceptions provided in Article 37 of the LFPDPPP applies.
5. Options, ARCO rights, and withdrawal of consent
You can manage certain preferences directly from Chapter:
- Analytics: you can disable analytics tracking in the application settings. Even if you disable it, Chapter may use anonymized usage data under the terms described in this notice.
- Personalized advertising: you can disable or limit the use of your data for personalized advertising from the Chapter settings, when such option is available, as well as through Google ad settings and your device’s privacy settings. Exercising this option with Chapter will apply to processing carried out by Chapter as the controller; third-party settings may also be governed by their own policies.
- Account deletion: you can delete your account from the application or request it by writing to support@clubchapter.com.
You may also request access, rectification, cancellation, or opposition to the processing of your personal data (ARCO rights), revoke the consent you may have granted, or limit the use or disclosure of your data.
To exercise these rights, send a request to support@clubchapter.com with: (i) your name and a means to communicate the response; (ii) documents proving your identity or, if applicable, legal representation; (iii) a clear description of the right you wish to exercise and the personal data involved; and (iv) any element that facilitates locating your information.
The Controller will inform you of the determination made regarding your request within a maximum period of 20 (twenty) business days from the date it was received. If the request is appropriate, it will be implemented within 15 (fifteen) business days following the date you are notified of the response.
If you believe that your right to the protection of your personal data has been violated by any act or omission on our part, or you suspect any violation of the provisions of the Federal Law on Protection of Personal Data Held by Private Parties (LFPDPPP), we inform you that you have the right to file the corresponding complaint or report with the National Institute of Transparency, Access to Information and Protection of Personal Data (INAI) (www.inai.org.mx).
6. Data retention and deletion
We retain personal data as long as necessary to fulfill the purposes described in this notice, maintain your account, comply with legal obligations, or resolve disputes.
When you delete your account, Chapter will delete from its systems your personal data associated with it, including, where applicable, your name, email, and profile photo, unless retention is necessary to comply with a legal obligation, address a dispute, or assert rights.
Public reviews you have posted may remain visible to other users, but will, within a reasonable period after account deletion, undergo an anonymization process intended to dissociate them from data that can directly identify you. This retention will only be carried out while such reviews remain part of the service’s functionality or there is a legitimate legal or operational need.
7. Security measures
Chapter employs reasonable administrative, technical, and physical measures to protect personal data against damage, loss, alteration, destruction, unauthorized use, access, or processing. Data is stored using Firebase infrastructure.
No system is completely infallible. Therefore, although Chapter seeks to protect your data through reasonable measures, it cannot guarantee the absolute security of information transmitted or stored electronically.
8. Data of children and adolescents
Chapter is only available to persons aged 13 or older. If the user is a minor under applicable law, they declare that they have authorization from their mother, father, or legal guardian when required. If the Operator reasonably detects that an account belongs to a person under the age of 13, it may suspend or cancel it and delete the associated information, unless it must be retained due to a legal obligation.
Persons under 13 years of age should not provide personal data through Chapter. If you believe that a minor has provided personal information without authorization, contact us at support@clubchapter.com.
9. Changes to the privacy notice
Chapter may modify or update this privacy notice. Any modification will be published in the application, on the website, or electronic medium where this notice is available, indicating the date of the last update and, where appropriate, the effective date.
10. Contact
If you have questions, comments, or requests related to this privacy notice or the processing of your personal data, contact us at:
Email: support@clubchapter.com