Comprehensive Privacy Notice

Last updated: September 2026 (v2026-09d)

DESARROLLO Y SOLUCIONES DE SOFTWARE ("Fidelip", "we", "us"), with its address at Av. Lateral Vía Atlixcáyotl 5210, Col. Emiliano Zapata, San Andrés Cholula, Puebla, C.P. 72810, Mexico, operates the Fidelip platform (fidelip.com and its subdomains, and the app for business staff). Fidelip lets businesses in Mexico, the United States, Canada and Spain run digital loyalty cards, customer satisfaction surveys, vouchers and emails to their customers.

This notice explains what personal data we process, why, who we share it with and how you can exercise your rights. It supplements our Terms and Conditions and our Cookie Policy.

1. Who We Are and in What Capacity We Process Your Data

Depending on your relationship with Fidelip, we process your data in one of two capacities:

1.1 Fidelip as controller

We decide why and how the data of these people is processed, and we answer to them directly:

• Holders of a business account (owners) and the users they create (admins and staff).
• Visitors to fidelip.com and to the business sign-up pages.
• Businesses and their representatives whom we contact to offer Fidelip (prospects).
• People who contact our support by email or WhatsApp.
• Visitors to the pages Fidelip hosts for businesses, only as regards the measurement of the use of the service that Fidelip carries out on them (section 9.2).

1.2 Fidelip as processor

When you are a customer of a business that uses Fidelip (for example, you keep its loyalty card in Apple Wallet or Google Wallet, answered one of its surveys, or received a voucher or an email from it), that business is the controller of your data. The business decides what data it asks you for, what it uses it for and what messages it sends you. Fidelip processes that data on the business's behalf, only to provide the service and in accordance with its instructions and our Terms and Conditions. We do not use that data for our own purposes (except to produce aggregated statistics, which identify no one, to improve the platform), we do not sell it, and we do not use it to advertise Fidelip.

Separately from that data, and only outside Europe (the European Economic Area, the United Kingdom and Switzerland), Fidelip measures, for its own purposes, with Google Analytics and without advertising features, how the pages it hosts for businesses are used. Section 9.2 explains how it does so and when it does not.

To exercise your rights over that data, contact the business first. You can also write to us at [email protected]: we will tell you which business your request concerns, forward it to them and help them handle it. You can also, on your own:

• Delete your data from the customer portal (cliente.fidelip.com), which you can also reach from the back of your Apple Wallet or Google Wallet pass.
• Stop receiving a business's emails using the unsubscribe link included in every email.

1.3 Which parts of this notice apply to you

2. Personal Data We Process

2.1 Account holders and business users

• Name, email address and phone number
• Password (stored only converted into an irreversible code (hash), never in plain text)
• Role in the business and assigned locations
• Two-step verification secret, if you turn it on, and the 4-digit kiosk-mode PIN
• Language preference
• Date, time and IP address of sign-ins and other security events, in our security logs
• Identifiers of the devices where you use the staff app, to send you notifications

2.2 Business data

• Trade name, logo and brand images
• Addresses and time zones of its locations
• Country, currency and language of the account
• Tax data: in Mexico, RFC, legal name, tax regime, CFDI use and tax address; elsewhere, the applicable tax identifier (for example, an EIN or NIF)
• Stripe customer and subscription identifiers. Your card details are received and processed only by Stripe; Fidelip never sees or stores them.

2.3 Customers of businesses (as processor)

What data is collected depends on how each business sets up its card, its surveys and its campaigns. It may include:

• Name, email address, phone number, date of birth, gender, age range, address or state and postal code
• Your card's QR code or unique identifier
• Points, stamps or membership balances and transaction history, including the location and the staff member who recorded each transaction, the receipt number, the purchase amount and, if the business uses it, the items purchased
• Tier (for example, Bronze, Silver or Gold) and a customer segment calculated automatically from how recently, how often and how much you buy. The business uses this segmentation to send its promotions; it has no legal effects on you and does not similarly significantly affect you.
• Your code for inviting other people, and who invited you
• Tags the business assigns to you
• Survey answers: ratings, likelihood to recommend (NPS), free-text comments, photos you choose to upload and table number
• Your consent to receive marketing and, where applicable, your email unsubscribe
• The language of the page on which you signed up
• Apple Wallet or Google Wallet pass identifiers and, for Apple, the push token and device identifier Apple uses to update the pass
• Email delivery events: whether a campaign email was opened or clicked, and whether an email bounced

2.4 Visitors to the website and sign-up pages

• Identifiers of the ad through which you arrived (for example, Google's gclid and Meta's fbclid) and campaign parameters (UTM), stored in a first-party cookie
• The page you entered on, the referring page and the date of the visit
• Approximate country, which our network provider derives from your IP address, to show you the right language and prices and to know whether the European rules apply to you
• Preference cookies with the country and language you choose
• Google and Meta analytics and advertising cookies: in Europe, only if you accept them in the cookie notice; elsewhere, from your first visit, unless you reject them (section 9)

2.5 Prospects

To offer Fidelip to other businesses, we collect business contact data from public sources (for example, websites and business listings): business name, contact person's name, work email and phone number, and premises address. We also keep a record of our contacts with you, including whether you open or reply to our emails and visits to the personalized page we send you. If you do not want us to contact you, reply to any of our messages or write to [email protected] and we will stop; we will keep only what is needed to honor your choice.

2.6 Support

If you write to [email protected] or message us on WhatsApp, we process your name, your email address or phone number and the content of the conversation to help you.

2.7 Sensitive data

We do not request sensitive personal data (ethnic origin, health status, religious beliefs, sexual preferences, etc.). Each business designs its own surveys, and free-text comments and photos contain whatever each person chooses to write or upload.

3. Purposes of Processing

3.1 Primary purposes (necessary for the service)

• Creating and managing business and user accounts
• Providing the service to businesses: loyalty cards and digital passes, recording points and stamps, redemptions, tiers, surveys, vouchers, customer referrals, emails and notifications the business decides to send, and reports and statistics for the business
• Charging the subscription, issuing invoices and keeping accounting records
• Providing technical support
• Protecting the platform: verifying identities, preventing fraud and abuse (for example, per-customer transaction limits and blocking email addresses that bounce or mark our emails as spam), and keeping security logs
• Complying with legal and tax obligations

3.2 Secondary purposes (not necessary)

• Sending businesses information about new Fidelip features and offers
• Contacting businesses that are not yet customers to offer them Fidelip
• Producing aggregated statistics on platform use to improve it, including measuring with Google Analytics how our sites and the pages we host for businesses are used (section 9)
• Measuring and improving our advertising on Google and Meta (Facebook and Instagram), learning which ad led to a sign-up, and showing Fidelip ads on those platforms (remarketing)

You may object to the secondary purposes at any time by writing to [email protected], by rejecting analytics and advertising cookies in the cookie notice (section 9), or by using the unsubscribe link in our emails. Doing so does not affect the service.

3.3 Sign-up measurement

When advertising cookies are active (section 9), Google's and Meta's tags load in your browser; when you create a business account, Google's tag sends your email address, converted into an irreversible code (hash), to count the sign-up. In addition, outside Europe (the European Economic Area, the United Kingdom and Switzerland), when a business account is created we send Meta, from our servers, two events (the sign-up and the start of the trial) with: the email address, the phone number and the account identifier, converted into an irreversible code (hash); the IP address and browser used to sign up; the ad click identifier and Meta's browser identifier, when there are any; and the chosen plan and its price. We do so solely to count the sign-up as a result of the campaign. This server-side report does not depend on your answer to the cookie notice. We do not send it when the business or the visitor is in Europe, or when your browser sends the Global Privacy Control (GPC) signal.

4. Legal Bases (European Economic Area)

Where the GDPR applies, we process the data for which we are controller on these bases:

For the data of a business's customers, the legal basis is determined by the business as controller. For example, the platform only lets a business in the European Economic Area send marketing emails to customers who gave their consent.

5. Recipients and Sub-processors

We do not sell personal data. We share it only with the providers we need to deliver the service. Most of them process it on our behalf; Google and Meta, for analytics and advertising, also under their own policies:

Infrastructure providers are listed by category. When a provider processes data outside the European Economic Area, it does so with the safeguards the law requires, such as the European Commission's standard contractual clauses or an adequacy decision (section 6). We send the detailed list of providers to businesses and to anyone who requests it at [email protected].

Each business's customer data is seen by that business (its owners, admins and staff, according to their role) and, when needed to provide support or maintain the platform, by authorized Fidelip personnel; never by other businesses.

AI assistants. A business may connect an AI assistant of its choice (for example, Anthropic's Claude) to its account through our MCP feature. In that case, the data that assistant reads is sent to the provider the business chose, under the business's own account and terms. For its part, Fidelip uses third-party AI assistants to manage its sales contacts with prospects (section 2.5); it never sends them data of the businesses' customers.

Under Mexican law, disclosing data to these providers (communications to processors, known as remisiones) and transfers necessary to provide the service do not require your consent. Advertising measurement is a secondary purpose you may object to (section 3).

6. International Transfers

Our servers and databases are in the United States; we do not host data in the European Union. Data of users in every country is therefore transferred to the United States and, depending on the provider, to the other countries in the table above.

• European Economic Area: transfers rely on the Standard Contractual Clauses approved by the European Commission and, where the recipient is certified, on the EU-U.S. Data Privacy Framework.
• Mexico: the LFPDPPP allows transfers necessary to provide the contracted service.
• Canada: sending data to a provider that processes it on our behalf is a use of the data for the same purpose, not a disclosure to a third party. Section 14 explains what it means for the data to be processed outside Canada.
• Latin America: we rely on each local law's equivalent provisions on transfers necessary to perform a contract.

7. Retention

Deleting a customer from the portal also erases their survey demographics and photos and the email addresses vouchers were sent to, and their Apple Wallet or Google Wallet card stops being valid. Deleted data may remain in backups until they are overwritten; if we ever restored one, we would apply the deletion again.

A business can close its account from Settings in its dashboard; more details at Delete account.

8. Security

We apply reasonable technical, administrative and physical measures to protect data, including encryption in transit, role-based access, two-step verification (mandatory for Fidelip's administration access and available for business accounts), lockout after failed sign-in attempts, audit logs and backups.

9. Cookies

We use necessary and preference cookies in every country. Analytics cookies (Google Analytics) and advertising cookies (Google Ads and the Meta Pixel) depend on where you are. In this notice, "Europe" means the European Economic Area, the United Kingdom and Switzerland; we know it from the country our network provider derives from your IP address or, if we do not know it, from your browser's time zone. The details are in the Cookie Policy.

9.1 Our sites

• In Europe, analytics and advertising cookies only load if you accept them in the cookie notice.
• In every other country, including Mexico and the United States, they are active from your first visit. On fidelip.com, id.fidelip.com, pos.fidelip.com and the app.fidelip.com dashboard a notice tells you so and lets you reject them; if you do not reject them, we take it that you consent to their use. If you reject them, we switch them off on the spot and delete their cookies. On pos.fidelip.com we only use Google Analytics.
• With your browser's Global Privacy Control (GPC) signal, in any country, advertising tags do not load and Google Analytics runs without Google Signals or ad personalization.
• To change or withdraw your choice, use the "Cookie settings" link on fidelip.com, id.fidelip.com or the app.fidelip.com dashboard, or delete the cookies and site data for fidelip.com in your browser: the notice will appear again.

9.2 Pages Fidelip hosts for businesses

On the loyalty card sign-up, survey and voucher pages that Fidelip hosts for businesses on app.fidelip.com, Fidelip uses Google Analytics for its own purposes, as controller, only to measure and improve the use of the service. Google Analytics receives the page visited and the referring page, technical data about your browser and device, the approximate location Google derives from your IP address, and a random identifier stored in the _ga cookie. We do so:

• Only when neither you nor the business is in Europe, and never if you rejected analytics cookies on any of our sites.
• Without advertising features: no Google Signals, no ad personalization, no Google Ads and no Meta Pixel.
• With no codes, tokens or contact details in the addresses we send to Google (9.3).
• Never in kiosk mode, the business's counter tablet.

Until you answer, a short notice in the page's language tells you so and lets you reject it; closing it only hides it and does not count as an answer. The customer portal (cliente.fidelip.com) uses no analytics or advertising cookies.

9.3 Addresses we send to Google

In every country, the page addresses we send to Google carry no codes, tokens or contact details: we remove their parameters (except the utm_* campaign parameters and the gclid and fbclid click identifiers) and everything after the # sign, and we replace a survey's token and a voucher's or personalized page's code with a generic placeholder. We do not use the Meta Pixel when the page's address or the referring page's address carries any of that data.

9.4 "Do Not Track" and tracking across sites

Some browsers can send a "Do Not Track" signal. Because there is no common standard for interpreting it, our sites do not respond to it. We do honor the Global Privacy Control (GPC) signal, as explained in section 9.1.

When analytics or advertising cookies are active on fidelip.com, id.fidelip.com, pos.fidelip.com or the app.fidelip.com dashboard (in Europe, only if you accept them; elsewhere, unless you reject them), the providers of those services may collect information about your online activities over time and across different websites, under their own policies. We load no advertising tags on the pages we host for businesses (section 9.2).

10. Your Rights and How to Exercise Them

Depending on the law that applies to you, you may request access to your data, its correction or its deletion, object to certain uses and withdraw your consent. Sections 11 to 15 set out the rights for each country.

• If Fidelip is the controller (section 1.1), write to [email protected] from your registered email address, stating which right you wish to exercise and over which data.
• If you are a customer of a business (section 1.2), contact the business. If you write to us, we will forward your request to the business and help them handle it. You can delete your data yourself from the customer portal and unsubscribe from emails with the link in each email.
• If you are a prospect, simply reply to our message or write to [email protected] and we will stop contacting you.

To protect your data, we may ask for information that lets us confirm your identity before handling the request. We will not charge you for exercising your rights or treat you differently for doing so.

Automated decisions: customer tiers and segments are calculated automatically, but they only serve to let the business offer promotions and benefits; we make no automated decisions that produce legal effects concerning you or similarly significantly affect you.

11. Mexico (LFPDPPP)

This notice is issued under the Federal Law on the Protection of Personal Data Held by Private Parties (Ley Federal de Protección de Datos Personales en Posesión de los Particulares, "LFPDPPP") published in the Official Gazette (Diario Oficial de la Federación) on March 20, 2025, which replaced the 2010 law. The team that handles your personal data requests is Fidelip's support team, at [email protected].

11.1 ARCO rights

You may Access your data, Rectify it, Cancel it or Oppose its processing (ARCO rights). Send your request to [email protected] with:

• Your name and a way to send you the response
• A document proving your identity or, where applicable, the authority of the person acting on your behalf
• A clear description of the data and of the right you wish to exercise
• Anything that helps locate your data (for example, the business or the registered email address)

We will respond within a maximum of 20 business days. If the request is granted, we will give effect to it within the following 15 business days. If you are a customer of a business, the request is decided by the business as controller; we will help it do so within those same periods.

11.2 Withdrawal of consent

You may withdraw your consent by writing to [email protected]. If the withdrawal affects a primary purpose, we may be unable to keep providing the service to you.

11.3 Limiting use or disclosure

You may limit the use of your data for secondary purposes by writing to [email protected], by using the unsubscribe link in our emails, by rejecting analytics and advertising cookies in the cookie notice (section 9), or by registering with the Public Registry to Avoid Advertising (Registro Público para Evitar Publicidad, REPEP) of PROFECO, Mexico's consumer protection agency.

11.4 Authority

If you believe your right to the protection of your personal data has been violated, you may turn to the Ministry of Anti-Corruption and Good Governance (Secretaría Anticorrupción y Buen Gobierno), which under the 2025 law supervises the processing of personal data by private parties in place of the former INAI.

12. European Economic Area and Spain (GDPR and LOPDGDD)

Where the General Data Protection Regulation (GDPR) and, in Spain, Organic Law 3/2018 on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD) apply to you, Fidelip is the controller of the data listed in section 1.1, on the legal bases in section 4. For a business's customers, the business is the controller and Fidelip acts as processor.

You have the right to:

• Access: know whether we process your data and obtain a copy.
• Rectification: correct inaccurate or incomplete data.
• Erasure: ask us to delete your data where applicable.
• Restriction: ask us to restrict processing in certain cases.
• Portability: receive the data you gave us in a structured, commonly used and machine-readable format, and transmit it to another controller.
• Objection: object to processing based on legitimate interests and, in every case, to direct marketing.
• Not to be subject to solely automated decisions with legal or similarly significant effects. We make no such decisions.
• Withdraw your consent at any time, without affecting the lawfulness of prior processing.

Write to [email protected]. We will respond within one month, which may be extended by two further months where the complexity or number of requests requires it; in that case we will tell you within the first month.

You may lodge a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos, AEPD) at www.aepd.es or with the supervisory authority of the EEA country where you live or work.

13. United States

This section supplements the notice for residents of the United States, under state privacy laws where applicable.

13.1 Categories, sources and purposes

Sources: you; the business you are a customer of; your browser or device; our providers (for example, the status of a payment in Stripe); and, for prospects, public sources.

Purposes: those in section 3: providing the service, billing, support, security and fraud prevention, legal compliance, improving the service and advertising Fidelip.

13.2 Sale and targeted advertising

We do not sell personal information for money. Some state laws may treat advertising cookies and the sign-up measurement in section 3.3 as "sharing" data or "targeted advertising". In the United States advertising cookies are active from your first visit; you can opt out of them by rejecting them in the cookie notice, which switches them off on the spot (section 9). We honor your browser's Global Privacy Control (GPC) signal as an opt-out of both: with it, advertising tags do not load and we do not send sign-up measurement. We do not use businesses' customer data to advertise Fidelip, and we load no advertising tags on the pages we host for businesses (section 9.2). Rejecting advertising cookies in the notice does not stop the server-side sign-up measurement (section 3.3); the GPC signal does.

13.3 Your rights

Even where your state's law does not require it, we handle these requests from anyone who lives in the United States:

• Know what personal information we process about you and receive a copy.
• Correct information that is inaccurate.
• Delete it, except what the law requires us to keep (section 7).
• Opt out of targeted advertising and of what some laws call the "sale" or "sharing" of data (section 13.2).

How. Write to [email protected] from your registered email address. If you use a business's dashboard, you can download your account data on the dashboard's "Account security" page. If you are a customer of a business, you can download or delete your data in the customer portal; other requests are decided by the business, and we will forward them (section 1.2).

We may ask for information to confirm your identity. You may act through an authorized agent, who must show that authorization. We will respond within 45 days; if we need more time, we will tell you before that period ends and will take no more than 45 more days. If we deny your request, we will explain why and you may appeal by replying to our decision; we will tell you the outcome in writing. We will not charge you or treat you differently for exercising these rights.

Sensitive data. We use your password and kiosk PIN only to verify your identity; we do not use sensitive data to infer characteristics about you.

Loyalty programs. Each business offers its own program and sets its terms and benefits; Fidelip offers consumers no incentives in exchange for their data.

13.4 Marketing emails (CAN-SPAM)

Every marketing email sent through Fidelip, whether ours or a business's, includes a working unsubscribe link that is honored promptly, and the sender's postal address.

13.5 Children (COPPA)

The service is not directed to children under 13, and businesses must not enroll children under that age. See section 16.

14. Canada

This section supplements the notice for people who live in Canada, under the Personal Information Protection and Electronic Documents Act (PIPEDA) and, where they apply, equivalent provincial laws.

• Privacy Officer. We have designated a Privacy Officer who is accountable for compliance with this notice and handles questions and complaints: Privacy Officer, Av. Lateral Vía Atlixcáyotl 5210, Col. Emiliano Zapata, San Andrés Cholula, Puebla, C.P. 72810, Mexico, [email protected].
• Data processed outside Canada. Our servers are in the United States and some providers process data in other countries (sections 5 and 6). While there, the data is subject to those countries' laws and may be accessed by their courts, law enforcement and national security authorities. Except as section 5 states for analytics and advertising, our providers process the data on our behalf and only to provide their services to us.
• Cookies. Analytics and advertising cookies work as described in section 9: a notice tells you so from your first visit, you can reject them then or later in "Cookie settings", and your rejection takes effect immediately and is kept. Rejecting advertising does not stop the server-side sign-up measurement (section 3.3); the GPC signal does.
• Access and correction. You may request access to your data and its correction by writing to [email protected]. We will respond within 30 days; if we need more time, we will tell you within that period, with the reason, and will take no more than 30 more days. We do not charge for handling your request.
• Withdrawing consent. You may withdraw your consent at any time, on reasonable notice and subject to legal or contractual restrictions; we will explain the consequences (for example, that we can no longer provide the service to you).
• Complaints. If you are not satisfied with our response, you may file a complaint with the Office of the Privacy Commissioner of Canada (www.priv.gc.ca) or, where applicable, your provincial privacy commissioner.
• Customers of a business. If you are a customer of a business that uses Fidelip, that business is responsible for your data and Fidelip processes it on its behalf (section 1.2); we will forward any request you send us.

15. Other Latin American Countries

Fidelip does not yet open sign-up to businesses in these countries; the rules in this section apply from when it does. If you live in one of them, you can exercise your rights of access, rectification, updating, deletion and objection (and, where your law provides for it, withdraw your authorization) by writing to [email protected]. We will respond within the period your law sets and, if you are not satisfied, you can turn to your authority:

If you are a customer of a business, that business is the controller of your data and Fidelip processes it on its behalf (processor). In countries that require prior authorization, the business obtains it when it enrolls you, and you can withdraw it at any time.

Promotional emails: in Colombia, Peru, Panama, Costa Rica and the Dominican Republic (as in the European Economic Area) they are only sent to people who expressly agreed; the box is never pre-ticked. In Argentina, Chile and Uruguay you can unsubscribe at any time with the link in every email.

Transfer to the United States: data is hosted in the United States (section 6). For each country we use the mechanism its law provides: an adequate country where the authority recognizes it as such (for example, Colombia), or contractual clauses with our providers.

16. Children

Fidelip is aimed at businesses and does not knowingly collect data from children. Businesses must not enroll in their programs children under 13 in the United States, or children under the age their country requires: 14 in Spain, Peru and Chile, 15 in Ecuador; in Colombia and Panama, no minor without a parent's or guardian's authorization; in Canada, children under 13 (14 in Quebec) without a parent's or guardian's authorization. If you know we hold a child's data, write to [email protected] and we will delete it.

17. Changes to this Notice

We may update this notice. We will publish the new version on this page with its date, and we will notify account holders by email before any material change takes effect.

18. Contact

• Privacy Officer: [email protected]
• Other matters: [email protected]
• Address: Av. Lateral Vía Atlixcáyotl 5210, Col. Emiliano Zapata, San Andrés Cholula, Puebla, C.P. 72810, Mexico