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PRIVACY POLICY

Effective Date: June 30, 2026

Welcome to the Privacy Policy of Tower Elite LLC, a U.S. limited liability company doing business as "Recarga Rapido" and "Rapid Recharge" (collectively, "we," "us," "our," "the Company," or "Tower Elite").

This Privacy Policy outlines our policies and procedures regarding the collection, use, disclosure, retention, and protection of your information when you use our services through our Websites (including but not limited to www.RecargaRapido.com and www.RapidRecharge.com) (collectively, the "Websites"), as well as through our mobile applications (including but not limited to Recarga Rapido and Rapid Recharge) (collectively, the "Apps"). By using our services, you agree to the collection and use of your information in accordance with this Privacy Policy.

This policy describes how we use your personal data to provide and improve our services, and it informs you about your privacy rights and how the law protects you.

1. INTERPRETATION AND DEFINITIONS

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Account

  means a unique account created for You to access our Service or parts of our Service.

• Business

  , for the purpose of the CCPA (California Consumer Privacy Act), refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California.

• Company

  (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Tower Elite LLC, 8 The Green Suite A, Dover, Delaware 19901.

For the purpose of the GDPR, the Company is the Data Controller.

• Consumer

  , for the purpose of the CCPA (California Consumer Privacy Act), means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.

• Cookies

  are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

• Country

  refers to: United States

• Data Controller

  , for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

• Device

  means any device that can access the Service such as a computer, a cellphone or a digital tablet.

• Do Not Track

  (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.

• Facebook Fan Page

  are public profiles specifically created by the Company on the Facebook social network. These include:

Recarga Rapido, accessible from https://www.facebook.com/recargarapido

Rapid Recharge, accessible from https://www.facebook.com/rapidrechargeapp

• Personal Data

  is any information that relates to an identified or identifiable individual.

For the purposes for GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.

• Sale

  , for the purpose of the CCPA (California Consumer Privacy Act), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information to another business or a third party for monetary or other valuable consideration.

• Service

  refers to the Websites and Apps.

• Service Provider

  means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.

• Third-party Social Media Service

  refers to any website, app or any social network website through which a User can log in or create an account to use the Service.

• Usage Data

  refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

• Website

  refers to Recarga Rapido, accessible from https://www.recargarapido.com/, and Rapid Recharge, accessible from https://www.rapidrecharge.com/.

• You

  means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service.

2. COLLECTING AND USING YOUR PERSONAL DATA

2.1 Types of Data Collected

(a) Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Usage Data

(b) Usage Data

Usage Data is collected automatically when using the Service. It may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

(c) Information from Third-Party Social Media Services

The Company allows You to create an account and log in to use the Service through the following Third-party Social Media Services:

• Google
• Facebook

If You decide to register through or otherwise grant us access to a Third-Party Social Media Service, We may collect Personal data that is already associated with Your Third-Party Social Media Service's account, such as Your name, Your email address, Your activities or Your contact list associated with that account.

You may also have the option of sharing additional information with the Company through Your Third-Party Social Media Service's account. If You choose to provide such information and Personal Data, during registration or otherwise, You are giving the Company permission to use, share, and store it in a manner consistent with this Privacy Policy.

(d)Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. We also use other techniques such as web beacons which are small, clear picture files used to follow your movements on our website. (For more details on this and how to opt out of these, please see the 'Cookies Policy.') Other tracking technologies we use include tags and scripts to collect and track information and to improve and analyze Our Service. Ultimately, the technologies We use may include:

• Cookies or Browser Cookies.

  A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.

• Flash Cookies.

  Certain features of our Service may use local stored objects (or Flash Cookies) to collect and store information about Your preferences or Your activity on our Service. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies. For more information on how You can delete Flash Cookies, please read "Where can I change the settings for disabling, or deleting local shared objects?" available at

• Web Beacons.

  Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

We use both Session and Persistent Cookies for the purposes set out below:

• Necessary / Essential Cookies

Type: Session Cookies

Administered by: Us

Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

• Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

• Functionality Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

• Tracking and Performance Cookies

Type: Persistent Cookies

Administered by: Third-Parties

Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new pages, features or new functionality of the Website to see how our users react to them.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.

3. USE OF YOUR PERSONAL DATA

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service,

  including to monitor the usage of our Service.

• To manage Your Account:

  to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.

• For the performance of a contract:

  the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.

• To contact You:

  To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.

• To provide You

  with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.

• To manage Your requests:

  To attend and manage Your requests to Us.

• To deliver targeted advertising to You:

  We may use Your information to develop and display content and advertising (and work with third-party vendors who do so) tailored to Your interests and/or location and to measure its effectiveness.

• For business transfers:

  We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.

• For other purposes:

  We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We may share Your personal information in the following situations:

• With Service Providers:

  We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to advertise on third party websites to You after You visited our Service, for payment processing, to contact You.

• For business transfers:

  We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.

• With Affiliates:

  We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.

• With business partners:

  We may share Your information with Our business partners to offer You certain products, services or promotions.

• With other users (Third-Party Social Media Services only):

  if You register or sign in through a Third-Party Social Media Service such as Google or Facebook, Your contacts on that Third-Party Social Media Service may see information that Service makes available about Your activity in accordance with that Service's own privacy settings and policies. The Service itself is not a user-generated-content platform and does not currently provide public-area features through which Users interact with or view each other.

• With Your consent:

  We may disclose Your personal information for any other purpose with Your consent.

3.1 Marketing Communications and Channel-by-Channel Opt-Out

Where the User has consented (or has not opted out, depending on applicable law), the Company may send marketing and promotional communications about products, offers, and Services that may be of interest to the User. The User may opt out of marketing communications through the channels below at any time, without affecting the User's right to receive transactional, account-management, security, or regulatory communications.

• Email: Click the "unsubscribe" link at the bottom of any marketing email, or contact soporte@recargarapido.com with the subject line "Unsubscribe."
• SMS / MMS: Reply STOP (or any equivalent keyword required by applicable mobile-carrier rules, such as CANCEL, END, QUIT, UNSUBSCRIBE) to any promotional message, or contact soporte@recargarapido.com.
• Push Notifications: Disable notifications for the Recarga Rapido or Rapid Recharge App via Your device's Settings > Notifications, or within the App's notification preferences where available.
• In-App Marketing: Adjust marketing preferences in the User's account settings on the Websites or Apps.
• Voice Calls (Telemarketing): Inform the agent that You wish to be added to the Company's internal "Do Not Call" list, or contact soporte@recargarapido.com. The Company honors the U.S. National Do Not Call Registry (donotcall.gov) for telephone solicitations.
• Postal Mail: Email soporte@recargarapido.com with the subject line "No Postal Mail" and the User's full name, postal address, and ZIP/postal code.
• Interest-Based Advertising: Use the third-party opt-out platforms listed in Section 8(d) and the cookie-management settings described in Section 13.

Opt-out of marketing communications does not prevent the Company from contacting the User regarding active Transactions, account-security alerts, identity-verification challenges, fraud-prevention notices, regulatory disclosures, or other non-marketing matters required or permitted by law.

3.2 Automated Decision-Making and Profiling

The Company uses automated processing in connection with fraud prevention, identity verification, risk scoring, sanctions screening, transaction routing, and credit-card authorization. These automated processes may involve profiling within the meaning of Article 4(4) of the GDPR and of the U.S. state consumer-privacy laws referenced in Section 11. Automated decisions that produce legal effects or similarly significant effects (such as declining a Transaction, suspending an account for suspected fraud, or imposing a verification challenge) are subject to human review at the User's request, except where the automated decision is necessary for the entry or performance of a contract with the User, is authorized by applicable law, or is based on the User's explicit consent. EEA, UK, Colorado, Connecticut, Virginia, Texas, Florida, and Oregon residents may exercise applicable rights to opt out of profiling and request human review as described in Sections 9.2 and 11.

4. RETENTION OF YOUR PERSONAL DATA

The Company retains Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy, to comply with our legal obligations, to resolve disputes, and to enforce our legal agreements and policies. The applicable retention period depends on the category of Personal Data, the purpose of processing, and any specific minimum retention required by law. The following retention periods apply as a general matter, in each case subject to extensions where required to defend a legal claim, comply with a legal hold, satisfy a regulatory or tax obligation, prevent fraud, or protect the security of the Services.

• Account information (name, email, phone number, password hash, KYC documents): for the duration of the User's active account, plus a reasonable period thereafter not exceeding seven (7) years to comply with anti-money-laundering recordkeeping, tax recordkeeping, and dispute-resolution obligations.
• Transaction records (top-ups, calls, SMS, gift cards, market orders, experiences, receipts, vouchers, refund records, chargeback records): retained for a minimum of five (5) years and up to seven (7) years from the date of the Transaction, as required by U.S. federal tax law (26 U.S.C. § 6001) and applicable state recordkeeping laws.
• Customer Proprietary Network Information (CPNI): retained for the period required by 47 C.F.R. § 42.6 (toll records, generally eighteen (18) months) and as otherwise required by FCC rules.
• Payment-card data: not retained by the Company; tokenized and stored by our PCI-DSS-compliant payment processors in accordance with their data-retention policies.
• Usage Data, server logs, device identifiers, IP addresses: retained in identifiable form for a period of up to twenty-four (24) months for security, fraud-prevention, debugging, and analytics purposes, and thereafter only in aggregated or anonymized form.
• Marketing preferences and cookie-consent records: retained until the consent is withdrawn or for a reasonable period thereafter to evidence prior consent.
• Customer-support communications: retained for up to three (3) years from the date of last contact, except where retained longer for ongoing disputes, fraud investigations, or legal holds.
• Sanctions and AML screening records: retained for at least five (5) years from the date of the underlying Transaction or screening event, as required by FinCEN regulations at 31 C.F.R. § 1010.430.

Where the User exercises a right to deletion under Section 11 or applicable foreign law, the Company will delete the User's Personal Data within the timeframe required by the applicable law, except to the extent the Company is required or permitted to retain the data under one of the exceptions described in Sections 11.5 and 11.13. After the applicable retention period expires, the Company will delete or de-identify the Personal Data such that it can no longer reasonably be associated with the User.

5. TRANSFER OF YOUR PERSONAL DATA

Your information, including Personal Data, is processed at the Company's operating offices in the United States and at the offices of our Service Providers and Third-Party Providers, which may be located outside Your state, province, country, or other governmental jurisdiction where the data-protection laws may differ from those of Your jurisdiction. By using the Services, You acknowledge that information collected from You may be transferred to, and processed in, the United States and other countries.

5.1 International Transfer Mechanisms

Where the Company transfers Personal Data of residents of the European Economic Area ("EEA"), the United Kingdom, or Switzerland to a third country that has not been recognized by the European Commission, the UK Information Commissioner's Office, or the Swiss Federal Data Protection and Information Commissioner as providing an adequate level of data protection, the Company implements one or more of the following safeguards: (i) Standard Contractual Clauses ("SCCs") approved by the European Commission (Commission Implementing Decision (EU) 2021/914) and, where applicable, the UK International Data Transfer Addendum and the Swiss equivalent; (ii) Binding Corporate Rules where applicable; (iii) reliance on a permitted derogation under Article 49 of the GDPR (such as the transfer being necessary for the performance of a contract with the User); or (iv) any other lawful transfer mechanism. A copy of the SCCs or other safeguard applicable to a given transfer may be requested by contacting us at soporte@recargarapido.com.

5.2 Country of Operation

The Company is established in the United States. Personal Data is primarily processed in the United States. Where Personal Data is transferred to a Mobile Carrier, Issuer, Processor, Experience Provider, Fulfillment Partner, or other Third-Party Provider located in a foreign Recipient Country (including, without limitation, Cuba, Venezuela, the Dominican Republic, Mexico, and other countries in Latin America), such transfer is necessary for the performance of the Transaction initiated by the User and is subject to the destination country's law.

5.3 Acknowledgment

Your consent to this Privacy Policy followed by Your submission of Personal Data represents Your agreement to the transfers described in this Section 5. The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy. No transfer of Your Personal Data will take place to an organization or a country unless there are adequate safeguards in place.

6. DISCLOSURE OF YOUR PERSONAL DATA

(a) Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

(b) Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

(c) Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

(d) Sanctions, Export Controls, and OFAC Compliance

The Company may disclose Personal Data to the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC"), to the U.S. Department of Commerce, to the U.S. Department of State, and to other competent governmental authorities, as well as to our Mobile Carriers, Processors, Issuers, Experience Aggregators, payment networks, and other Third-Party Providers, where such disclosure is necessary or appropriate to (i) screen Users, Recipients, beneficiaries, and Transactions against sanctions and prohibited-parties lists; (ii) comply with the Cuban Assets Control Regulations, 31 C.F.R. Part 515, including the prohibited-officials provisions of 31 C.F.R. §§ 515.337-338 referenced in our Terms of Use; (iii) block, reverse, or report any Transaction the Company reasonably believes may violate U.S. sanctions, export-control, or anti-money-laundering law; or (iv) satisfy any reporting obligation under 31 C.F.R. Chapter X (FinCEN regulations) or other applicable financial-crimes law.

7. SECURITY OF YOUR PERSONAL DATA

7.1 Security Measures

The security of Your Personal Data is important to Us. The Company maintains administrative, technical, organizational, and physical safeguards that are reasonably designed to protect Personal Data against unauthorized access, alteration, disclosure, loss, or destruction. These measures include Transport Layer Security (TLS) encryption for data in transit, encryption of sensitive data at rest where appropriate, role-based access controls, employee training, vendor due diligence, network segmentation, intrusion-detection monitoring, and PCI-DSS compliance for payment data handled by our payment processors. The Company does not store complete card numbers, CVVs, or other sensitive authentication data on its servers; such information is collected and tokenized by PCI-DSS-compliant payment processors. The Company also uses automated fraud-prevention controls, including Cloudflare Turnstile, device fingerprinting, IP-reputation signals, and 3-D Secure authentication, as described in Section 6 of our Terms of Use. No method of transmission over the Internet or method of electronic storage is 100% secure; while We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

7.2 Data Breach Notification

In the event of a personal-data breach involving Your Personal Data, the Company will notify You and, where required, the relevant data-protection or other regulatory authorities, in accordance with the timing and content requirements of applicable law, including the GDPR (within 72 hours of becoming aware of a breach where feasible, per Article 33), the California breach-notification statute (California Civil Code §§ 1798.29 and 1798.82), and analogous breach-notification laws of other U.S. states and foreign jurisdictions. Notice will be provided by email to the address You have on file with the Company, by SMS, by in-app notification, by postal mail, or by a substitute notice as permitted by the applicable law. The notice will describe, to the extent then known and as permitted by law-enforcement instructions, the nature of the breach, the categories of Personal Data affected, the measures being taken to address the breach, and any steps You can take to protect Yourself.

8. DETAILED INFORMATION ON THE PROCESSING OF YOUR PERSONAL DATA

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.

(a)Analytics

We may use third-party Service providers to monitor and analyze the use of our Service.

• Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page.

• Firebase

Firebase is an analytics service provided by Google Inc.

You may opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy.

We also encourage you to review Google's policy for safeguarding your data.

For more information on what type of information Firebase collects, please visit the How Google uses data when you use our partners' sites or apps webpage.

(b) Email Marketing

We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.

We may use Email Marketing Service Providers to manage and send emails to You.

• Mailchimp

Mailchimp is an email marketing and automation service provided by The Rocket Science Group LLC.

For more information on the privacy practices of Mailchimp, please visit their Privacy policy: https://mailchimp.com/legal/privacy/

• Omnisend

Omnisend is an email marketing and automation service provided by Omnisend UAB.

For more information on the privacy practices of Omnisend, please visit their Privacy policy: https://www.omnisend.com/privacy/

(c) Payments

We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors). We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

• Elavon / Converge

Their Privacy Policy can be viewed at https://www.elavon.com/privacy-policy.html

• PayPal

Their Privacy Policy can be viewed at https://www.paypal.com/us/legalhub/privacy-full.

(d) Behavioral Remarketing

The Company uses remarketing services to advertise to You after You accessed or visited our Service. We and Our third-party vendors use cookies and non-cookie technologies to help Us recognize Your Device and understand how You use our Service so that We can improve our Service to reflect Your interests and serve You advertisements that are likely to be of more interest to You.

These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies and to enable Us to:

• Measure and analyze traffic and browsing activity on Our Service
• Show advertisements for our products and/or services to You on third-party websites or apps
• Measure and analyze the performance of Our advertising campaigns

Some of these third-party vendors may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit You to block such technologies. You can use the following third-party tools to decline the collection and use of information for the purpose of serving You interest-based advertising:

• The NAI's opt-out platform: https://thenai.org/opt-out/
• The EDAA's opt-out platform: https://www.youronlinechoices.eu/
• The DAA's opt-out platform: https://optout.aboutads.info/

You may opt-out of all personalized advertising by enabling privacy features on Your mobile device such as Limit Ad Tracking (iOS) and Opt Out of Ads Personalization (Android). See Your mobile device Help system for more information.

We may share information, such as hashed email addresses (if available) or other online identifiers collected on Our Service with these third-party vendors. This allows Our third-party vendors to recognize and deliver You ads across devices and browsers. To read more about the technologies used by these third-party vendors and their cross-device capabilities please refer to the Privacy Policy of each vendor listed below.

The third-party vendors We use are:

• Google Ads (AdWords)

Google Ads (AdWords) remarketing service is provided by Google Inc.

You can opt-out of Google Analytics for Display Advertising and customise the Google Display Network ads by visiting the Google Ads Settings page.

Google also recommends installing the Google Analytics Opt-out Browser Add-on for your web browser. The add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page.

• Facebook

Facebook remarketing service is provided by Meta Platforms, Inc.

You can learn more about interest-based advertising from Facebook by visiting this page.

To opt-out from Facebook's interest-based ads, follow these instructions from Facebook.

Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA, the Digital Advertising Alliance of Canada, or the European Interactive Digital Advertising Alliance in Europe, or opt-out using your mobile device settings.

For more information on the privacy practices of Facebook, please visit Facebook's Data Policy.

(e) Infrastructure, Security, and Bot Mitigation

The Company uses third-party infrastructure providers to host, deliver, and protect the Websites and Apps. These providers may process IP addresses, device identifiers, request headers, and other technical signals as necessary to deliver and secure the Services.

• Cloudflare, Inc.

  Edge delivery, DDoS protection, and bot-mitigation services, including the Cloudflare Turnstile challenge described in Section 6 of our Terms of Use. Cloudflare's Privacy Policy: https://www.cloudflare.com/privacypolicy/.

• Amazon Web Services, Inc. (AWS)

  Cloud hosting, storage, and computing services. AWS Privacy Notice: https://aws.amazon.com/privacy/.

(f) Customer Support

The Company uses third-party customer-support tools to communicate with Users. These tools may process the User's name, email address, support inquiry, transcripts of chat conversations, and other information voluntarily provided by the User.

• Tawk.to

  Live-chat and customer-support widget integrated in the Websites and Apps. Tawk.to Privacy Policy: https://www.tawk.to/privacy-policy/.

(g) Gift Cards and E-Gift Service

To process gift-card Transactions described in Section 34 of our Terms of Use, the Company shares Sender and Recipient information with the applicable Processors and Issuers as required to issue, deliver, and validate the Gift Card.

• Zendit

  Gift-card aggregation and delivery platform. Privacy Policy: https://www.zendit.io/privacy.

• Reloadly

  Gift-card and airtime distribution platform. Privacy Policy: https://www.reloadly.com/privacy-policy/.

(h) Experiences and Tours

To process Experience bookings described in Section 33 of our Terms of Use, the Company shares traveler information with the applicable Experience Aggregator and Experience Provider as required to confirm the booking, deliver the voucher, and operate the activity.

• Viator (Tripadvisor)

  Experience-booking aggregator. Privacy Policy: https://www.viator.com/support/privacy.jsp.

(i) Telecommunications Carriers and Messaging Providers

To deliver Mobile Top-Ups, International Calls, and SMS Services described in Sections 3.1, 3.2, and 3.3 of our Terms of Use, the Company shares the destination phone number, the User's account identifier where necessary for fraud screening, and the requested service parameters with one or more upstream wholesale aggregators (which may include, without limitation, DT One, TransferTo, and other industry providers) and with the destination Mobile Carrier in the Recipient Country. The destination Mobile Carrier is solely responsible to the User and the destination subscriber for the underlying telecommunications service, as further described in Section 3.1 of the Terms of Use.

(j) Marketing-Tracking Pixels and Conversion APIs

The Company may use the Meta (Facebook) Conversions API ("CAPI"), the Google Ads Conversion API, and similar server-side measurement tools to attribute web Conversions in a privacy-preserving manner. Where required by applicable law, the Company hashes Personal Data (such as email addresses or phone numbers) prior to transmission. The User may opt out as described in Section 8(d) and in the cookies management settings.

9. GDPR PRIVACY

9.1 Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

• Consent:

  You have given Your consent for processing Personal Data for one or more specific purposes.

• Performance of a contract:

  Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.

• Legal obligations:

  Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.

• Vital interests:

  Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.

• Public interests:

  Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.

• Legitimate interests:

  Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

9.2 Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the EU, to:

• Request access to Your Personal Data.

  The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.

• Request correction of the Personal Data that We hold about You.

  You have the right to have any incomplete or inaccurate information We hold about You corrected.

• Object to processing of Your Personal Data.

  This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.

• Request erasure of Your Personal Data.

  You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.

• Request the transfer of Your Personal Data.

  We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.

• Withdraw Your consent.

  You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

9.3 Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

10. FACEBOOK FAN PAGE

10.1 Data Controller for the Facebook Fan Page

The Company is the Data Controller of Your Personal Data collected while using the Service. As operator of the Facebook Fan Page and https://www.facebook.com/rapidrechargeapp, the Company and the operator of the social network Facebook are Joint Controllers.

The Company has entered into agreements with Facebook that define the terms for use of the Facebook Fan Page, among other things. These terms are mostly based on the Facebook Terms of Service.

Visit the Facebook Privacy Policy for more information about how Facebook manages Personal data, or contact Facebook online, or by mail: Meta Platforms, Inc., ATTN: Privacy Operations, 1601 Willow Road, Menlo Park, CA 94025, United States.

10.2 Facebook Insights

We use the Facebook Insights function in connection with the operation of the Facebook Fan Page and on the basis of the GDPR, in order to obtain anonymized statistical data about Our users.

For this purpose, Facebook places a Cookie on the device of the user visiting Our Facebook Fan Page. Each Cookie contains a unique identifier code and remains active for a period of two years, except when it is deleted before the end of this period.

Facebook receives, records and processes the information stored in the Cookie, especially when the user visits the Facebook services, services that are provided by other members of the Facebook Fan Page and services by other companies that use Facebook services.

For more information on the privacy practices of Facebook, please visit the Facebook Privacy Policy.

11. U.S. STATE PRIVACY RIGHTS

This Section 11 supplements the information contained elsewhere in this Privacy Policy and applies to residents of the U.S. states identified below. To the extent applicable law of a particular state confers a right that is not expressly enumerated below, the Company will honor that right in accordance with the law of that state.

11.0 California (CCPA/CPRA)

The provisions of Sections 11.1 through 11.10 apply to residents of the State of California pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, "CCPA/CPRA"), and supplement the rights granted under the California Civil Code.

11.1 Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact collected by Us, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if You provided such personal information directly to Us.

Personal Information Categories

Under CCPA, personal information does not include:

• Publicly available information from government records
• Deidentified or aggregated consumer information
• Information excluded from the CCPA's scope, such as:

- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data

- Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994

11.2 Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from You.

  For example, from the forms You complete on our Service, preferences You express or provide through our Service, or from Your purchases on our Service.

• Indirectly from You.

  For example, from observing Your activity on our Service.

• Automatically from You.

  For example, through cookies We or our Service Providers set on Your Device as You navigate through our Service.

• From Service Providers.

  For example, third-party vendors to monitor and analyze the use of our Service, third-party vendors to deliver targeted advertising to You, third-party vendors for payment processing, or other third-party vendors that We use to provide the Service to You.

11.3 Use of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose personal information We collect for "business purposes" or "commercial purposes" (as defined under the CCPA), which may include the following examples:

• To operate our Service and provide You with our Service.
• To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve our Service.
• To fulfill or meet the reason You provided the information. For example, if You share Your contact information to ask a question about our Service, We will use that personal information to respond to Your inquiry. If You provide Your personal information to purchase a product or service, We will use that information to process Your payment and facilitate delivery.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to You when collecting Your personal information or as otherwise set forth in the CCPA.
• For internal administrative and auditing purposes.
• To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.

Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the "Use of Your Personal Data" section.

If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes We will update this Privacy Policy.

11.4 Disclosure of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:

• Category A: Identifiers
• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
• Category D: Commercial information
• Category F: Internet or other similar network activity

Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.

When We disclose personal information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

11.5 Your Rights under the CCPA

The CCPA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:

• The right to notice.

  You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.

• The right to request.

  Under CCPA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and share of personal information. Once We receive and confirm Your request, We will disclose to You:

- The categories of personal information We collected about You

- The categories of sources for the personal information We collected about You

- Our business or commercial purpose for collecting or selling that personal information

- The categories of third parties with whom We share that personal information

- The specific pieces of personal information We collected about You

- If we sold Your personal information or disclosed Your personal information for a business purpose, We will disclose to You:

* The categories of personal information categories sold

* The categories of personal information categories disclosed

• The right to say no to the sale of Personal Data (opt-out).

  You have the right to direct Us to not sell Your personal information. To submit an opt-out request please contact Us.

• The right to delete Personal Data.

  You have the right to request the deletion of Your Personal Data, subject to certain exceptions. Once We receive and confirm Your request, We will delete (and direct Our Service Providers to delete) Your personal information from our records, unless an exception applies. We may deny Your deletion request if retaining the information is necessary for Us or Our Service Providers to:

- Complete the transaction for which We collected the personal information, provide a good or service that You requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or otherwise perform our contract with You.

- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

- Debug products to identify and repair errors that impair existing intended functionality.

- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if You previously provided informed consent.

- Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us.

- Comply with a legal obligation.

- Make other internal and lawful uses of that information that are compatible with the context in which You provided it.

• The right to correct inaccurate Personal Data.

  Under the CPRA, You have the right to request that We correct any inaccurate Personal Data the Company maintains about You, taking into account the nature of the Personal Data and the purposes of processing.

• The right not to be discriminated against.

  You have the right not to be discriminated against for exercising any of Your consumer's rights, including by:

- Denying goods or services to You

- Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties

- Providing a different level or quality of goods or services to You

- Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services

11.5.1 Sensitive Personal Information and Right to Limit

Under the CPRA, certain categories of Personal Data are designated as "Sensitive Personal Information," which the Company may collect or process in connection with the Services. These include, without limitation: (i) account log-in credentials, financial-account numbers, debit-card or credit-card numbers in combination with any required security code, access code, or password permitting access to the account; (ii) precise geolocation (where the User enables location features on a Device); and (iii) any Personal Data collected as part of identity verification or anti-fraud checks (such as a government-issued identification document submitted under Section 6 of the Terms of Use).

The Company uses Sensitive Personal Information only for the purposes permitted by CPRA § 1798.121(a) and the corresponding regulations, including to perform the Service requested by the User, to authenticate Users, to maintain the quality and safety of the Services, to detect and resist fraud, unauthorized or illegal activity, and security incidents, and to ensure physical safety. The Company does not use or disclose Sensitive Personal Information for the purpose of inferring characteristics about the User.

California residents may direct the Company to limit the use and disclosure of Sensitive Personal Information to the purposes described above by submitting a request as described in Section 11.6.

11.6 Exercising Your CCPA Data Protection Rights

In order to exercise any of Your rights under the CCPA, and if You are a California resident, You can contact Us:

• By email: soporte@recargarapido.com

Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.

Your request to Us must:

• Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative
• Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it

We cannot respond to Your request or provide You with the required information if we cannot:

• Verify Your identity or authority to make the request
• And confirm that the personal information relates to You

We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonable necessary and with prior notice.

Any disclosures We provide will only cover the 12-month period preceding the verifiable request's receipt.

For data portability requests, We will select a format to provide Your personal information that is readily useable and should allow You to transmit the information from one entity to another entity without hindrance.

11.7 Sale of Personal Information

As defined in the CCPA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.

Please note that the categories listed below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact sold, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been shared for value in return.

We may sell and may have sold in the last twelve (12) months the following categories of personal information:

• Category A: Identifiers
• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
• Category D: Commercial information
• Category F: Internet or other similar network activity

11.8 Share of Personal Information

We may share Your personal information identified in the above categories with the following categories of third parties:

• Service Providers
• Payment processors
• Our affiliates
• Our business partners
• Third party vendors to whom You or Your agents authorize Us to disclose Your personal information in connection with products or services We provide to You

11.9 Sale of Personal Information of Minors Under 16 Years of Age

We do not sell the personal information of Consumers We actually know are less than 16 years of age, unless We receive affirmative authorization (the "right to opt-in") from either the Consumer who is between 13 and 16 years of age, or the parent or guardian of a Consumer less than 13 years of age. Consumers who opt-in to the sale of personal information may opt-out of future sales at any time. To exercise the right to opt-out, You (or Your authorized representative) may submit a request to Us by contacting Us.

If You have reason to believe that a child under the age of 13 (or 16) has provided Us with personal information, please contact Us with sufficient detail to enable Us to delete that information.

11.10 Do Not Sell or Share My Personal Information

You have the right to opt-out of the sale or sharing of Your personal information. Once We receive and confirm a verifiable consumer request from You, we will stop selling or sharing Your personal information. To exercise Your right to opt-out, please contact Us at soporte@recargarapido.com.

The Service Providers we partner with (for example, our analytics or advertising partners) may use technology on the Service that constitutes a "sale" or "sharing" of personal information as defined by the CCPA/CPRA. If you wish to opt out of the use of Your personal information for interest-based advertising purposes and these potential sales or sharing as defined under the CCPA/CPRA, you may do so by following the instructions below.

Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that You use.

11.11 Global Privacy Control (GPC) Signal

The Company recognizes and honors the Global Privacy Control ("GPC") browser signal as a valid opt-out preference signal from California residents to opt out of the sale and sharing of Personal Information, as required by CCPA/CPRA and its implementing regulations. When the Company detects a GPC signal sent through a browser, the Company treats the signal as an opt-out request for that browser and Device. Because GPC operates at the browser/Device level, the User must enable GPC on every browser and Device the User wishes to opt out from. Authenticated User-level opt-out preferences expressed by submitting a request as described in Section 11.6 will take precedence over conflicting browser-level signals.

11.12 Verification, Authorized Agents, and Response Timeframes

To process any verifiable consumer request under Section 11, the Company will verify the requestor's identity using information already in our possession or by requesting additional information sufficient to authenticate the requestor as the consumer about whom we hold Personal Data, in a manner proportionate to the sensitivity of the data and the risk of harm from unauthorized disclosure. A California resident may designate an authorized agent to submit a request on the resident's behalf; the Company may require the authorized agent to provide written, signed permission from the resident and may require the resident to verify the agent's authority and the resident's identity directly with the Company. The Company will confirm receipt of a verifiable request within ten (10) business days and will substantively respond within forty-five (45) calendar days, which may be extended once by an additional forty-five (45) calendar days where reasonably necessary, with notice to the requestor of the extension.

11.13 Right to Appeal

If the Company denies a request submitted under this Section 11, the requestor may appeal the denial by replying to the response email or by submitting a new email to soporte@recargarapido.com with the subject line "Privacy Request Appeal" and a description of the basis for the appeal. The Company will respond to a properly submitted appeal within sixty (60) calendar days (or such shorter period as required by applicable state law) and will inform the requestor in writing of the outcome and, where the appeal is denied, of the requestor's right to contact the applicable state Attorney General or state-specific privacy regulator.

11.14 Colorado Residents (Colorado Privacy Act)

If You are a resident of Colorado, You have the rights described in the Colorado Privacy Act, including the right to confirm whether the Company processes Your Personal Data and to access that data; the right to correct inaccuracies; the right to delete Personal Data; the right to data portability in a portable, readily usable format; and the right to opt out of targeted advertising, sale of Personal Data, and profiling in furtherance of decisions that produce legal or similarly significant effects. To exercise these rights, please contact us at soporte@recargarapido.com. Appeals of denied requests may be submitted as described in Section 11.13; if Your appeal is denied, You may contact the Colorado Attorney General at https://coag.gov/.

11.15 Connecticut Residents (Connecticut Data Privacy Act)

If You are a resident of Connecticut, You have the rights described in the Connecticut Data Privacy Act, including the right to confirm whether the Company processes Your Personal Data and to access it, the right to correct inaccuracies, the right to delete, the right to data portability, and the right to opt out of targeted advertising, sale of Personal Data, and profiling in furtherance of decisions producing legal or similarly significant effects. Requests and appeals may be submitted as described above; appeal denials may be referred to the Connecticut Attorney General at https://portal.ct.gov/ag.

11.16 Virginia Residents (Virginia Consumer Data Protection Act)

If You are a resident of Virginia, You have the rights described in the Virginia Consumer Data Protection Act (Va. Code § 59.1-575 et seq.), including the right to confirm processing and access Your Personal Data, the right to correct, the right to delete, the right to data portability, and the right to opt out of targeted advertising, sale of Personal Data, and profiling producing legal or similarly significant effects. The Company does not process Sensitive Data of a Virginia resident without that resident's consent.

11.17 Utah Residents (Utah Consumer Privacy Act)

If You are a resident of Utah, You have the rights described in the Utah Consumer Privacy Act (Utah Code § 13-61-101 et seq.), including the right to confirm and access Your Personal Data, the right to delete, the right to data portability, and the right to opt out of targeted advertising and sale of Personal Data. Utah does not currently provide a stand-alone right to correct or a right to opt out of profiling, and the appeal procedure of Section 11.13 is provided voluntarily.

11.18 Texas Residents (Texas Data Privacy and Security Act)

If You are a resident of Texas, You have the rights described in the Texas Data Privacy and Security Act (Tex. Bus. & Com. Code § 541.001 et seq.), including the right to confirm processing and access Your Personal Data, the right to correct, the right to delete, the right to data portability, and the right to opt out of targeted advertising, sale of Personal Data, and profiling producing legal or similarly significant effects. The Company does not knowingly process Sensitive Data of a Texas resident without that resident's consent.

11.19 Florida Residents (Florida Digital Bill of Rights)

If You are a resident of Florida, You have the rights described in the Florida Digital Bill of Rights (Fla. Stat. § 501.701 et seq.) to the extent that statute applies to the Company. These rights include the right to confirm processing and access, the right to correct, the right to delete, the right to data portability, and the right to opt out of sale of Personal Data, targeted advertising, and profiling producing legal or similarly significant effects. The Florida Digital Bill of Rights also provides certain rights related to voice and facial recognition data and to the collection of precise geolocation; the Company does not engage in these activities except as described in Section 11.5.1.

11.20 Oregon Residents (Oregon Consumer Privacy Act)

If You are a resident of Oregon, You have the rights described in the Oregon Consumer Privacy Act (ORS 646A.570 et seq.), including the right to confirm processing and access Your Personal Data, the right to a list of specific third parties to whom the Company has disclosed Personal Data, the right to correct, the right to delete, the right to data portability, and the right to opt out of targeted advertising, sale of Personal Data, and profiling producing legal or similarly significant effects.

11.21 Other U.S. States

Residents of Delaware (Delaware Personal Data Privacy Act, effective January 1, 2025), Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, and Tennessee may have additional or different rights with respect to their Personal Data, including rights of confirmation and access, correction, deletion, portability, and opt-out of sale, targeted advertising, and profiling, as set forth in the consumer-privacy law of the User's state of residence. The Company will honor such rights to the extent applicable law requires. Requests and appeals may be submitted as described in Sections 11.6 and 11.13.

12. CUSTOMER PROPRIETARY NETWORK INFORMATION (CPNI)

Tower Elite LLC is authorized by the Federal Communications Commission ("FCC") to provide telecommunications services under Section 214 of the Communications Act of 1934. As a provider of telecommunications services, the Company is required by Section 222 of the Communications Act (47 U.S.C. § 222) and by the FCC's implementing rules (47 C.F.R. §§ 64.2001-64.2011) to protect Customer Proprietary Network Information ("CPNI").

"CPNI" includes information that relates to the type, technical configuration, quantity, destination, technical destination, and amount of use of a telecommunications service to which You subscribe, and that is made available to the Company solely by virtue of the customer-carrier relationship. Examples include the phone numbers You call, the duration and time of those calls, and the calling features and rate plan associated with Your account.

The Company uses CPNI to provide and bill for the telecommunications services You purchase, to perform fraud prevention and account security, to comply with applicable law and regulatory requirements, and to provide customer service. The Company will not use CPNI to market services to You that are outside the category of service to which You already subscribe, to share CPNI with affiliates for that purpose, or to disclose CPNI to third parties for marketing purposes, unless required or permitted by law or unless You provide express opt-in consent.

You have the right, at any time, to deny or withdraw any consent You have given to the use, disclosure, or access to Your CPNI. To exercise this right, please contact us at soporte@recargarapido.com with the subject line "CPNI Opt-Out." Denying or withdrawing CPNI consent will not affect Your existing telecommunications service.

The Company authenticates each customer before disclosing CPNI in response to a customer-initiated call, online request, or in-store request, in accordance with 47 C.F.R. § 64.2010. The Company also follows the breach-notification procedures required by 47 C.F.R. § 64.2011.

13. COOKIES POLICY.

By continuing to use our Websites or Apps, you consent to our use of cookies as outlined in this policy. If you do not agree with our use of cookies, you may manage your preferences or disable cookies through your browser settings (explained below).

13.1. WHAT ARE COOKIES?

Cookies are small text files which are stored on your device (computer, tablet, or smartphone) when you visit a website or app. They help websites and apps remember your actions and preferences, improving your browsing experience. Cookies are created to keep track of your movements online, help you resume where you left off, remember your registered username, preferences, and other customizations.

Cookies can be categorized as follows:

• First-party cookies

  – Set by the website or app you are visiting.

• Third-party cookies

  – Set by other domains, such as analytics or advertising providers.

• Session cookies

  – Expire when you close your browser.

• Persistent cookies

  – Remain on your device for a set period.

13.2. TYPES OF COOKIES WE USE

We use the following types of cookies on our Websites and Apps:

A. Essential (Strictly Necessary) Cookies

These cookies are required for our Websites and Apps to function properly. They allow you to navigate and use essential features. Without them, certain services cannot be provided. They are used for remembering your login details, enabling secure transactions and ensuring functionality.

B. Performance & Analytics Cookies

Performance and analytics cookies help Websites and Apps track user behavior, measure performance, and optimize functionality without storing personally identifiable information. They monitor navigation patterns, page load times, and interactions to improve user experience and identify technical issues. Additionally, these cookies provide valuable insights for refining Websites and Apps design and supporting marketing strategies by analyzing audience demographics and preferences. Common examples include Google Analytics, Hotjar, and Meta. While they enhance Websites and Apps efficiency, many sites offer users the option to manage their cookie preferences for greater privacy control.

C. Functional Cookies

These cookies remember your preferences and choices, such as language settings, to provide a personalized experience. These may include saving preferred currency settings and remembering location preferences.

D. Advertising & Targeting Cookies

We use data from cookies for marketing, including displaying ads based on your preferences and interests. You can opt out of this, but it won't stop ads from appearing. Instead, the ads you see won't be personalized to your interests. These cookies appear through services like Google Ads and Facebook Pixel (for remarketing) and are used to display relevant promotions based on your activity.

E. Third-Party Cookies

Some services on our Websites and Apps, such as social media sharing features or payment gateways, may use third-party cookies. These cookies are managed by external providers, and we do not have control over them. Examples may include Elavon and Converge (payment processing) and social media integrations (Facebook, Twitter, Instagram).

13.3. HOW WE USE COOKIES

We use cookies to:

• Enhance user experience.
• Provide secure login and transaction processing.
• Analyze Websites and Apps traffic and improve functionality.
• Personalize content and recommendations.
• Display targeted advertisements.

We do not store sensitive personal data (such as passwords or payment details) in cookies.

13.4. HOW TO MANAGE YOUR COOKIE PREFERENCES

You can control and manage cookies through the following methods:

A. Browser Settings

Most web browsers allow you to block, delete, or disable cookies. The steps to manage cookies vary by browser:

• Google Chrome: https://support.google.com/accounts/answer/32050
• Mozilla Firefox: https://support.mozilla.org/en-US/kb/clear-cookies-and-site-data-firefox
• Safari: https://support.apple.com/guide/safari/manage-cookies-sfri11471/mac
• Microsoft Edge: https://support.microsoft.com/en-us/microsoft-edge/delete-cookies-in-microsoft-edge

Note: Disabling essential cookies may impact Websites and Apps functionality.

B. Opting Out of Targeted Advertising

You can opt out of personalized advertising by adjusting settings with:

• Google Ads: https://adssettings.google.com/
• Facebook Ads: https://www.facebook.com/ads/preferences/
• Network Advertising Initiative Opt-Out: https://thenai.org/opt-out/

13.5. UPDATES TO THIS COOKIES POLICY

We may update this Cookies Policy from time to time to reflect changes in regulations or technology. Any updates will be posted with a revised "Last Updated" date. We encourage you to review this policy periodically. Continued use of our Websites and Apps after changes are made constitutes your acceptance of the updated policy.

14. WEBSITE

You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:

• The NAI's opt-out platform: https://thenai.org/opt-out/
• The EDAA's opt-out platform: https://www.youronlinechoices.eu/
• The DAA's opt-out platform: https://optout.aboutads.info/

The opt out will place a cookie on Your computer that is unique to the browser You use to opt out. If you change browsers or delete the cookies saved by your browser, You will need to opt out again.

15. MOBILE DEVICES

Your mobile device may give You the ability to opt out of the use of information about the apps You use in order to serve You ads that are targeted to Your interests:

• "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android devices
• "Limit Ad Tracking" on iOS devices

You can also stop the collection of location information from Your mobile device by changing the preferences on Your mobile device.

16. "DO NOT TRACK" POLICY AS REQUIRED BY CALIFORNIA ONLINE PRIVACY PROTECTION ACT (CALOPPA)

Our Service does not respond to Do Not Track signals. However, some third party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.

17. CHILDREN'S PRIVACY

The Service may contain content appropriate for children under the age of 13. As a parent, you should know that through the Service children under the age of 13 may participate in activities that involve the collection or use of personal information. We use reasonable efforts to ensure that before we collect any personal information from a child, the child's parent receives notice of and consents to our personal information practices.

We also may limit how We collect, use, and store some of the information of Users between 13 and 18 years old. In some cases, this means We will be unable to provide certain functionality of the Service to these Users. If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

We may ask a User to verify its date of birth before collecting any personal information from them. If the User is under the age of 13, the Service will be either blocked or redirected to a parental consent process.

17.1 Information Collected from Children Under the Age of 13

The Company may collect and store persistent identifiers such as cookies or IP addresses from Children without parental consent for the purpose of supporting the internal operation of the Service.

We may collect and store other personal information about children if this information is submitted by a child with prior parent consent or by the parent or guardian of the child.

The Company may collect and store the following types of personal information about a child when submitted by a child with prior parental consent or by the parent or guardian of the child:

• First and/or last name
• Date of birth
• Gender
• Grade level
• Email address
• Telephone number
• Parent's or guardian's name
• Parent's or guardian's email address

For further details on the information We might collect, You can refer to the "Types of Data Collected" section of this Privacy Policy. We follow our standard Privacy Policy for the disclosure of personal information collected from and about children.

17.2 Parental Access

A parent who has already given the Company permission to collect and use his child personal information can, at any time:

Review, correct or delete the child's personal information

Discontinue further collection or use of the child's personal information

To make such a request, You can write to Us using the contact information provided in this Privacy Policy.

18. YOUR CALIFORNIA PRIVACY RIGHTS (CALIFORNIA'S SHINE THE LIGHT LAW)

Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes.

If you'd like to request more information under the California Shine the Light law, and if You are a California resident, You can contact Us using the contact information provided below.

19. CALIFORNIA PRIVACY RIGHTS FOR MINOR USERS (CALIFORNIA BUSINESS AND PROFESSIONS CODE SECTION 22581)

California Business and Professions Code section 22581 allow California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if You are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account. Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

20. LINKS TO OTHER WEBSITES

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

21. CLOSURE OR TERMINATION OF YOUR ACCOUNT

You may close your account at any time by contacting us through our Customer Service, via email at soporte@recargarapido.com. If there is no activity in your account for a period of two (2) years, we reserve the right to suspend your Account and to send you a notification email to the registered address. If you do not respond within thirty (30) days, we may, at our discretion, close your Account. YOU UNDERSTAND AND AGREE THAT CLOSING, ABANDONING, OR CANCELING YOUR ACCOUNT WILL RESULT IN THE FORFEITURE OF ALL AND EACH OF YOUR CREDITS AND GRATUITIES IN YOUR ACCOUNT (WHETHER CREDIT FOR PREPAID SERVICES SUCH AS CALLS, SMS, ETC., OR RECHARGE/TOP-UP SERVICES) PENDING EXECUTION AS DESCRIBED HEREIN) THAT YOU HAVE PURCHASED. ALL CREDIT PURCHASES ARE FINAL AND WILL NOT BE REFUNDABLE.

22. USER DATA DELETION REQUESTS

In accordance with the Meta Platform Policy and applicable global data protection standards, you have the right to request the permanent deletion of your account and associated personal data at any time.

22.1 How to Request Deletion

To exercise this right, please follow these steps:

Email Request: Send an email to soporte@recargarapido.com with the subject line "Data Deletion Request".

In-App: If you still have access to the app, you may also navigate to Profile > Settings > Delete Account to initiate the process automatically.

22.2 Processing and Data Retention

Upon receiving a verified request, we will:

Delete your account, login credentials (including Facebook Login data), and personal profile information within 30 days.

Retain only strictly necessary financial and transaction records (such as payment history and mobile top-up receipts) for a period of up to 5 years, solely to comply with tax obligations, audits, and applicable laws.

Once the retention period expires, this remaining data will be permanently deleted or anonymized.

23. CHANGES TO THIS PRIVACY POLICY

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy. You are therefore advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

24. CONTACT US

If you have any questions about this Privacy Policy or wish to exercise any of the rights described herein, You can contact us:

Tower Elite LLC
d/b/a Recarga Rapido and Rapid Recharge
8 The Green, Suite A
Dover, Delaware 19901
United States
Email: soporte@recargarapido.com