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PRIVACY POLICY

At Celebrain, we take your privacy very seriously. We strive to be transparent about the information we collect and how we use, share, and store it. We understand the importance of protecting your privacy and ensuring efficient and reliable service for our customers in Costa Rica.

This Privacy Policy explains our practices for GoCelebrain.com (the “Site”), Celebrain mobile applications (the “Apps”), and other services provided by Celebrain and its affiliates (collectively referred to as “Celebrain,” “we,” “us,” and “our”). We use the term “Services” to refer collectively to the Site, the Apps, and any other services we provide.

By using Celebrain’s Services, you consent to the practices described in this Privacy Policy.

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1. What Information Do We Collect and Receive?

We collect your personal information to provide and continually improve our products and services. These are the types of personal information we collect:

Information You Provide to Us

We receive and store any information you provide to us in connection with the Celebrain Services. You may choose not to provide certain information; however, if you do, you may not be able to enjoy many of the features we offer. This information includes, but is not limited to:

  • Information required to set up your account: Your name, email address, date of birth, gender, phone number, and store name (if applicable).

  • Billing and payment information: When you make a purchase, we process your payment information, including credit or debit card details. At Celebrain, we apply the Payment Card Industry Data Security Standards (PCI DSS).

  • Information you submit for Celebrain Services: Uploaded content (such as profile photos, listing images), store information, listing descriptions, financial information (for sellers).

  • Communication information: If you contact us for support or any inquiry, we collect the content of those communications.

  • Promotion or survey participation: Information you provide when participating in contests, promotions, or surveys.

  • Authentication information: Passwords and security questions, if applicable.

 

Automatic Information

We collect information automatically when you use our Services, even if you have not created an account or are not logged in. This includes:

  • Usage information: Activity on the Site and Apps (pages viewed, listings, clicks), searches, interactions with content.

  • Device information: IP address, device type, operating system, unique device identifiers, language settings, and privacy settings.

  • Log information: Date and time of access, features used, app crashes, etc.

  • Location information: Precise or approximate location from your mobile device or browser if you grant us permission.

  • Cookies and similar technologies: We use cookies, web beacons, pixels, and similar technologies to collect information about how you use our Services and to improve your experience. You can manage your cookie preferences through your browser settings. Our web server automatically recognizes and stores information such as visitors’ IP address/domain name combination to analyze traffic patterns and improve usability.

 

Information from Third-Party Sources

We may receive information about you from other sources, such as marketing partners, payment service providers, and publicly available sources, to complement the information we already have. For example, if you choose to connect your Celebrain account with a third-party service, that service may send us information. This also includes updated delivery or address information from shipping carriers, which we use to correct our records and facilitate future deliveries.

Sensitive Data (Under Costa Rican Law 8968)

Law 8968 of Costa Rica defines sensitive data as information that “reveals racial or ethnic origin, political opinions, religious, spiritual or philosophical beliefs, as well as information related to health, life, and sexual orientation.” At Celebrain, we generally do not collect this type of information unless it is strictly necessary to provide a specific service requested by you and always with your express consent. If at any time the nature of a service requires processing sensitive data, we will clearly inform you and obtain your explicit consent, as required by Costa Rican law.

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2. How Do We Use Your Information and What Is Our Legal Basis?

We use your personal information for the following purposes and legal bases, in accordance with Costa Rican Law No. 8968:

To Provide and Improve Our Services (Legal Basis: Contract Performance and Legitimate Interest)

  • To operate, maintain, and improve the functionality of the Site and Apps.

  • To process your transactions and deliver requested products or services.

  • To personalize your experience by showing relevant content, products, or services.

  • To develop new products and services.

  • To enable communication between buyers and sellers.

To Ensure Safety and Security (Legal Basis: Legal Obligation and Legitimate Interest)

  • To detect and prevent fraud, abuse, spam, and other harmful or illegal activities.

  • To enforce our policies and terms of use.

  • To protect the safety and integrity of our Services and users.

To Communicate With You (Legal Basis: Consent and Legitimate Interest)

  • To send notifications about your transactions, orders, and account.

  • To respond to your inquiries and provide customer support.

  • To send marketing and promotional communications about Celebrain products and services, if you have consented to receive them. You may opt out at any time.

  • To inform you about changes to our policies or services.

For Advertising and Marketing (Legal Basis: Consent and Legitimate Interest)

  • To show personalized advertisements on and off our Services.

  • To measure advertising effectiveness.

  • To analyze the performance of our marketing campaigns.

For Analytics and Research (Legal Basis: Legitimate Interest)

  • To understand how users interact with our Services and improve design and functionality.

  • To conduct market and trend research.

  • To generate aggregated and anonymized statistics that do not personally identify you.

To Comply With Legal Obligations (Legal Basis: Legal Obligation)

  • To comply with applicable Costa Rican laws, regulations, legal processes, or government requests.

  • To respond to subpoenas, court orders, or valid legal processes.

 

3. How Do We Share Your Information?

We share your personal information only under the circumstances described below and with the appropriate safeguards, in compliance with Costa Rican Law 8968, which requires unequivocal consent for the transfer of personal data unless otherwise provided by law.

With Other Celebrain Users (Buyers and Sellers)

When you make a purchase or sale, we share necessary information with the other party, such as your shipping address and order details for sellers, and sellers’ usernames and location for buyers.

Any information you post in public forums, reviews, or product listings will be publicly accessible.

With Third-Party Service Providers

We collaborate with companies and service providers that help us operate, provide, improve, integrate, optimize, and market our Services. We may share your information with them so they can perform services such as:

  • Payment processing

  • Shipping and logistics

  • Marketing and advertising

  • Data analytics

  • Hosting and infrastructure services

  • Customer support

These providers only have access to the personal information necessary to perform their tasks and are contractually required to protect your information and use it solely for the agreed purposes, in compliance with Costa Rican Law 8968.

With Celebrain Affiliates

We may share your information with other companies within the Celebrain corporate group for purposes described in this policy and for internal business operations. All affiliates will be bound by this Privacy Policy or equivalent protections.

Business Transfers

In the event of a sale, merger, acquisition, bankruptcy, reorganization, or transfer of all or part of our assets, your personal information may be transferred as part of that transaction. In such cases, we will notify you, and your information will remain protected under the same or equivalent terms.

Legal Compliance and Law Enforcement

We may disclose your information if we believe in good faith that it is necessary to:

  • Comply with a legal obligation, judicial process, or valid governmental request (e.g., PRODHAB or judicial authorities).

  • Protect our rights, property, or safety, or that of our users or the public.

  • Detect, prevent, or address fraud, security issues, or technical problems.

  • Enforce our Terms of Service.

With Your Consent

We will share your personal information with third parties when you explicitly consent.

 

4. How Do We Transfer Your Information (International Transfers)?

Because Celebrain operates globally and uses service providers that may be located outside of Costa Rica, your information may be transferred, stored, and processed in other countries, including the United States.

We ensure that all international data transfers comply with Law No. 8968 by implementing safeguards such as standard contractual clauses requiring recipients to protect personal data in accordance with Costa Rican law and international standards.

 

5. How Do We Protect Your Information?

We implement robust security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. These measures include:

  • Encryption: We use TLS and SSL technologies to protect data during transmission.

  • PCI DSS Compliance: For credit card data handling.

  • Access Controls: Only authorized employees, contractors, and agents can access your personal information, and they are bound by confidentiality obligations.

  • Physical and electronic security measures.

  • Identity verification procedures.

  • Password protection requirements: You must protect your password and devices; log out when using shared devices.

 

6. How Long Do We Store Your Information?

We retain your personal information only for as long as necessary for the purposes for which it was collected and to comply with legal obligations.

  • Account information is retained while your account is active.

  • After account closure, some information is retained for backup, auditing, legal, or dispute-resolution purposes.

  • Information will be deleted or anonymized when no longer necessary unless a longer retention period is legally required or permitted.

 

7. Your Rights and Choices (ARCO Rights and More)

In accordance with Costa Rican Law No. 8968, you have the following rights:

  • Access: To know whether we process your data and for what purposes.

  • Rectification: To correct inaccurate or incomplete data.

  • Deletion: To request deletion of your personal data unless a legal reason requires retention.

  • Objection: To object to processing for specific purposes, such as direct marketing.

  • Withdrawal of consent: At any time, without affecting the legality of prior processing.

  • Restriction of processing: Under certain circumstances.

  • Data portability: To receive your data in a structured, commonly used, machine-readable format.

  • File a complaint: With the Costa Rican Data Protection Agency (PRODHAB).

To exercise your rights, contact us at info@gocelebrain.com. We commit to responding within the timeframes established by Costa Rican law.

Marketing Choices

You may opt out of promotional communications by following “unsubscribe” instructions in our emails or adjusting your Celebrain account settings.

 

8. Your Responsibilities

As a Celebrain user, you agree to:

  • Provide accurate and updated information.

  • Protect the confidentiality of your password and credentials.

  • Be responsible for all activity under your account.

  • Respect other users’ privacy and not process their personal data without consent.

  • Handle third-party personal data obtained through our Services (e.g., as a seller) confidentially and lawfully.

 

9. Changes to This Privacy Policy

We reserve the right to update this Privacy Policy at any time. Changes will be posted on this page and will take effect as indicated. We will notify you of any substantial changes via a prominent notice on our Site, Apps, or by email.

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10. Our Relationship With You (Data Controller)

Depending on the Services you use, Celebrain, as a Costa Rican entity, is the data controller of your personal information.

 

11. Minors

We do not intentionally collect information from individuals under 18 without parental consent. If you believe a minor has provided us with personal data, please contact us so we can delete it. Parents and guardians should supervise minors’ online activities.

12. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, you may contact us:

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