1. Data controller
Just is a brand of SOFTWARE TECNOLOGIA E INNOVACION S.A.S. (hereinafter, “Just” or “we”), a Colombian company with tax ID (NIT) 901.836.959, domiciled in Cali, Colombia.
- Address: Calle 46 # 11-33, Cali, Colombia
- Email: hola@trackva.com.co
2. Legal framework
This policy complies with Colombian Statutory Law 1581 of 2012, Decree 1377 of 2013 (compiled in Decree 1074 of 2015) and the instructions of the Superintendence of Industry and Commerce.
3. Definitions
Under article 3 of Law 1581 of 2012:
- Personal data: any information linked or that can be associated with an identified or identifiable natural person.
- Data subject: the natural person whose personal data is processed. In this policy, you.
- Processing: any operation on personal data, such as collection, storage, use, circulation or deletion.
- Data controller: whoever decides on the database and the processing of the data. In this policy, Just.
- Data processor: whoever processes personal data on behalf of the controller.
- Authorization: the data subject’s prior, express and informed consent to the processing of their data.
4. Data we process and why
| When | Data | Purpose |
|---|---|---|
| Waitlist | Email, platform (iPhone or Android), language, sign-up date, source form, invite code and who invited you | Tell you about the launch and the presale, manage your spot and invitations |
| Website | In your browser (local storage, not cookies): your spot, your invite code and the code of whoever invited you | Show you your spot and your link when you come back to the site. We don’t use advertising or analytics cookies |
| Presale | Email, platform, purchase identifier on Google Play or the App Store, amount and date of payment (the store receives your card details, not us) | Activate your founder price, issue invoices and handle withdrawals and refunds |
| Account | Name, email, sign-in provider (email, Google or Apple) | Create and protect your account |
| App use | Transactions (amount, date, merchant, category, note), accounts, cards (name, last 4 digits, credit limit, statement and payment dates), loans, budgets, categories, households and their members | Provide the Service: record, classify, calculate the card of the day, budgets, reminders and reports |
| Automatic capture | Text of notifications or messages from the banks you authorize, Apple Pay purchase data (merchant, amount, card) | Create transactions automatically. The text is read on your phone; only the data of the detected transaction is sent to our servers |
| Voice and chat | Text of what you type or dictate | Turn it into transactions and answer your questions. Dictation is transcribed by your phone’s system; we don’t keep audio recordings |
| Technical | Device model and system, app version, notification identifier, error logs | Send notifications, fix bugs and maintain security |
We don’t use your data for third-party advertising, we don’t sell it and we don’t use it to assess your creditworthiness.
5. Data we don’t process
- We don’t ask for or store full card numbers, bank passwords, one-time codes or account numbers.
- Biometrics: fingerprint or Face ID unlock is handled by your phone; the app doesn’t receive your biometric data.
- Sensitive data: we don’t request sensitive data as defined in article 5 of Law 1581 of 2012, and no feature depends on you providing it. If you write any in a note or in the chat, we only use it to provide the Service.
6. Authorization
We ask for your prior, express and informed authorization before processing your data. On the waitlist, you give it by submitting the form, next to which we tell you what we’ll do with your email and where to read this policy. When you buy and when you create your account, you give it by expressly accepting this policy and the terms. You request automatic capture permissions yourself from your phone, and you can withdraw them at any time.
7. Your rights
Under article 8 of Law 1581 of 2012, you can:
- Access, update and correct your data.
- Request proof of the authorization you gave us.
- Know how we have used your data.
- File complaints with the Superintendence of Industry and Commerce, after completing the inquiry or claim process with us.
- Revoke your authorization and ask us to delete your data, except when the law requires us to keep it.
- Access your data free of charge.
You can also export your transactions and delete your account from Settings.
8. How to exercise your rights
Write to hola@trackva.com.co from your account email, with your name, what you are requesting and, if it’s a claim, the facts and any documents you want to provide.
- Inquiries: we reply within ten (10) business days of receiving them. If that’s not possible, we explain why and reply within the following five (5) business days.
- Claims (correction, update, deletion or revocation): we reply within fifteen (15) business days from the day after we receive them. If that’s not possible, we let you know and reply within the following eight (8) business days. If the claim is incomplete, we ask you for what’s missing within the following five (5) business days; if two (2) months pass without a reply from you, the claim is considered withdrawn.
Requests are handled by the Just team, at hola@trackva.com.co.
9. Providers and international transfers
To provide the Service we use technology providers that process data on our behalf (data processors), such as hosting, database, notifications, email, payments and artificial intelligence services, under contracts that require them to protect your data and use it only according to our instructions. Some have their servers outside Colombia, mainly in the United States, a country that the Superintendence of Industry and Commerce recognizes as having an adequate level of data protection (External Circular 005 of 2017).
Household members see the data you mark as “household”. Beyond that, we only hand over your data to authorities that request it in the exercise of their legal duties.
10. Security
We encrypt data in transit and at rest, limit each user’s access to their own data and that of their households, restrict internal access to what is essential and log access. If an incident affects your data, we report it to the Superintendence of Industry and Commerce and notify you.
11. Retention
- Waitlist: up to 90 days after launch, or earlier if you leave.
- Account and use: while your account is active. When you delete it, we remove your data from active systems within 30 days and from backups within 90 days.
- Purchases and invoicing: for the time required by tax and commercial regulations.
12. Minors
The Service is only for people over 18. We don’t knowingly collect data from minors; if we detect any, we delete it.
13. Data protection authority
If you believe we didn’t properly handle an inquiry or a claim, you can go to Colombia’s Superintendence of Industry and Commerce, Office for the Protection of Personal Data: Carrera 13 # 27-00, Bogotá D.C., national toll-free line 01 8000 910165, www.sic.gov.co.
14. Changes and validity
If we make substantial changes to this policy, we’ll notify you before applying them and, when the purposes change, we’ll ask for a new authorization. The databases will remain in force as long as the purposes described are being fulfilled.