Privacy Policy
This document contains our complete privacy-related policies, including the Privacy Policy (Part A), Data Processing Agreement (Part B), and Cookie Policy (Part C).
- Part A — Privacy Policy
- Introduction & Scope
- Data Controller vs. Data Processor
- Information We Collect
- How We Use Information
- Legal Bases for Processing (GDPR)
- How We Share Information
- International Data Transfers
- Data Retention
- Data Security
- Your Rights
- California Privacy Rights (CCPA/CPRA)
- Brazilian Privacy Rights (LGPD)
- Children's Privacy
- Cookies & Tracking (Summary)
- Third-Party Links & Services
- Do Not Track
- Data Breach Notification
- Changes to This Policy
- Contact & Data Protection Officer Part B — Data Processing Agreement
- DPA Scope & Definitions
- Nature & Purpose of Processing
- Obligations of the Processor
- Obligations of the Controller
- Sub-processors
- International Transfers (DPA)
- Data Retention & Deletion (DPA)
- Audits
- Data Breach Response (DPA) Part C — Cookie Policy
- What Are Cookies
- Cookies We Use
- Third-Party Cookies
- How to Manage Cookies
- Local Storage
NoMasFilas LLC ("NoMásFilas", "Company", "we", "us", or "our") respects your privacy and is committed to protecting personal data. This Privacy Policy ("Policy") explains how we collect, use, share, store, and protect information when you visit our website, use our platform, or interact with our services.
This Policy applies to:
- Clients: Businesses, organizations, and institutions that use NoMásFilas to manage their queues and appointments.
- Authorized Users: Staff members who access the NoMásFilas backend dashboard on behalf of a Client (administrators, managers, operators).
- End Users / Guests: Individuals who take a queue number, schedule an appointment, or interact with the Service as a customer at a Client's location.
- Website Visitors: Individuals who visit nomasfilas.io or related websites without creating an account.
1. Introduction & Scope
NoMásFilas provides a cloud-based queue management and appointment scheduling platform. In providing this Service, we process personal data in various capacities. This Policy describes our practices regarding all personal data we collect or process, regardless of where you are located.
We process personal data in accordance with applicable data protection laws, including the EU General Data Protection Regulation (GDPR), the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA), the Brazilian General Data Protection Law (LGPD), and other applicable national and regional legislation.
2. Data Controller vs. Data Processor
Understanding who controls your data is important for exercising your rights.
2.1 NoMásFilas as Data Controller
We act as the Data Controller when we determine the purposes and means of processing. This applies to:
- Client account registration and management data
- Billing and payment information
- Website visitor data (analytics, cookies)
- Marketing communications with Clients
- Authorized User account data
- Support and communication records
2.2 NoMásFilas as Data Processor
We act as the Data Processor when processing personal data on behalf of a Client. This applies to:
- End User personal data collected through queue interactions (names, IDs, phone numbers, emails — as configured by the Client)
- Appointment and scheduling data for End Users
- Queue history and interaction records attributable to End Users
2.3 Implications
If you are an End User and wish to exercise data rights regarding data collected at a Client's location, you should first contact the Client (the business whose queue you joined). NoMásFilas will cooperate with Clients to fulfill data subject requests. You may also contact us directly at privacy@nomasfilas.io and we will direct your request appropriately.
3. Information We Collect
3.1 Information Provided by Clients
| Data Category | Examples | Purpose |
|---|---|---|
| Account Registration | Business name, country, admin email, phone, password | Create and manage account |
| Business Identification | Tax ID (RUT, EIN, etc.), business address | Billing, compliance, invoicing |
| Payment Information | Credit/debit card details (processed by Stripe) | Process subscription payments |
| Authorized User Data | Names, emails, roles of staff members | Account access and permissions |
| Branch Configuration | Branch names, addresses, service types, schedules | Service configuration |
| Support Communications | Emails, chat messages, call records | Provide customer support |
3.2 End User Data (Collected on Behalf of Clients)
End User data collection is determined and controlled by the Client. Clients configure what data their queue system requests from End Users. This may include:
| Data | Collected When | Required? |
|---|---|---|
| Name | Client enables "Request Name" setting | Optional — Client configures |
| National ID (RUT, DNI, etc.) | Client enables "Request ID" setting | Optional — Client configures |
| Phone number | Client enables notifications or requests phone | Optional — Client configures |
| Email address | Client enables email notifications or requests email | Optional — Client configures |
| Service type selected | Always (part of queue function) | Functional requirement |
| Queue number and timestamp | Always (part of queue function) | Functional requirement |
| Wait time and service time | Always (measured automatically) | Functional requirement |
Important: Some Clients may operate their queues without collecting any personal End User data (anonymous queuing). The queue system functions with just a number and service type selection.
3.3 Automatically Collected Data
| Data | Method | Purpose |
|---|---|---|
| IP address | Server logs | Security, fraud prevention, approximate geolocation |
| Browser type & version | HTTP headers | Compatibility, debugging |
| Operating system & device type | HTTP headers | Compatibility, analytics |
| Pages visited & time spent | Analytics tools | Service improvement |
| Referral source | HTTP headers | Marketing analytics |
| Feature usage patterns | Application telemetry | Product improvement |
| Error logs | Application monitoring | Debugging, stability |
3.4 Information from Third Parties
We may receive information from third parties including: (a) payment status and transaction information from Stripe; (b) authentication information if you sign in using a third-party service; (c) publicly available business information for account verification.
4. How We Use Information
| Purpose | Data Used | Legal Basis (GDPR) |
|---|---|---|
| Provide and operate the Service | Account data, configuration data, End User data | Contract performance (Art. 6(1)(b)) |
| Process payments and billing | Payment and account information | Contract performance (Art. 6(1)(b)) |
| Send transactional communications | Email, phone number | Contract performance (Art. 6(1)(b)) |
| Send queue notifications to End Users | Phone, email (as configured by Client) | Legitimate interest / Client's legal basis |
| Generate analytics and reports | Queue data, service times, usage patterns | Contract performance (Art. 6(1)(b)) |
| Improve and develop the Service | Aggregated usage data, feedback | Legitimate interest (Art. 6(1)(f)) |
| Ensure security and prevent fraud | IP address, activity logs, account data | Legitimate interest (Art. 6(1)(f)) |
| Provide technical support | Account data, communication records, logs | Contract performance (Art. 6(1)(b)) |
| Comply with legal obligations | As required by law | Legal obligation (Art. 6(1)(c)) |
| Marketing to Clients (opt-in only) | Business email | Consent (Art. 6(1)(a)) |
| Create anonymized benchmarks | Aggregated, de-identified data | Legitimate interest (Art. 6(1)(f)) |
4.1 What We Do NOT Do
- We do not sell personal data to third parties.
- We do not use End User data for our own marketing purposes.
- We do not share End User data with other Clients.
- We do not use personal data for automated decision-making that produces legal effects.
- We do not profile End Users for advertising or marketing purposes.
5. Legal Bases for Processing (GDPR)
For individuals in the European Economic Area (EEA) and United Kingdom, we process personal data based on one or more of the following legal bases:
- Contract Performance (Art. 6(1)(b)): Processing necessary to perform our contractual obligations to you (e.g., providing the Service, processing payments).
- Legitimate Interest (Art. 6(1)(f)): Processing necessary for our legitimate business interests, balanced against your rights (e.g., security, fraud prevention, service improvement). You may object to processing based on legitimate interest — see Section 10.
- Legal Obligation (Art. 6(1)(c)): Processing necessary to comply with applicable laws (e.g., tax records, responding to legal requests).
- Consent (Art. 6(1)(a)): Processing based on your specific, informed, freely given consent (e.g., marketing communications). You may withdraw consent at any time.
6. How We Share Information
We share personal data only as necessary and with appropriate safeguards:
| Recipient | Purpose | Data Shared | Safeguards |
|---|---|---|---|
| Stripe, Inc. | Payment processing | Payment card details, billing info | PCI-DSS Level 1; Privacy Policy |
| Google Cloud / Firebase | Cloud hosting & infrastructure | All Service data (encrypted) | SOC 2, ISO 27001; DPA in place |
| MongoDB Atlas | Database storage | Service data (encrypted) | SOC 2, ISO 27001; DPA in place |
| Cloudflare | DNS, CDN, security | IP addresses, traffic data | ISO 27001; DPA in place |
| SMS/Email providers | Deliver notifications | Phone/email of End Users | Contractual obligations |
| WhatsApp (Meta) | WhatsApp notifications | Phone numbers of End Users | WhatsApp Business Terms |
| Google Analytics | Website analytics | Anonymized usage data | IP anonymization enabled |
| Legal authorities | Legal compliance | As required by law | Court order or legal obligation |
| Business successors | Merger/acquisition | All data (with notice) | Contractual protections; prior notice |
We require all third-party recipients to maintain confidentiality and security of personal data through appropriate contractual provisions.
7. International Data Transfers
NoMásFilas operates globally. Personal data may be transferred to and processed in the United States and other countries where our service providers operate. These countries may have data protection laws different from your country of residence.
When transferring data from the EEA, UK, Switzerland, or other jurisdictions with data transfer restrictions, we rely on:
- Standard Contractual Clauses (SCCs) approved by the European Commission
- Adequacy decisions where applicable
- Binding Corporate Rules of our service providers where applicable
- Your explicit consent to the transfer when you use the Service
- Necessity for contract performance (processing required to deliver the Service you requested)
You may request a copy of the applicable transfer mechanisms by contacting privacy@nomasfilas.io.
8. Data Retention
| Data Category | Retention Period | Basis |
|---|---|---|
| Client account data | Duration of account + 30 days post-termination | Contract + data export period |
| Authorized User data | Duration of account + 30 days | Contract |
| End User queue data | Up to 24 months (configurable by Client) | Analytics and reporting |
| End User personal identifiers | As configured by Client, max 24 months | Client's data retention policy |
| Payment and billing records | 7 years | Tax and accounting laws |
| Support communications | 3 years after resolution | Quality and dispute resolution |
| Website analytics | 26 months (aggregated) | Service improvement |
| Server logs | 90 days | Security and debugging |
| Aggregated/anonymized data | Indefinitely | No personal data involved |
Clients may request earlier deletion of End User data at any time by contacting support@nomasfilas.io. We will process deletion requests within 30 days.
9. Data Security
We implement and maintain appropriate technical and organizational security measures, including:
- Encryption in transit: All data transmitted between your device and our servers is encrypted using TLS 1.2 or higher (HTTPS).
- Encryption at rest: All stored data is encrypted using AES-256 encryption on our cloud infrastructure.
- Access controls: Role-based access control for all administrative functions. Principle of least privilege applied.
- Authentication: Secure password hashing. Session management with automatic timeout.
- Infrastructure security: Hosted on enterprise-grade cloud infrastructure (Google Cloud Platform / Firebase) with SOC 2 and ISO 27001 certifications.
- Payment security: All payment data handled exclusively by Stripe, which is PCI-DSS Level 1 certified. We never store full card numbers on our systems.
- Monitoring: Continuous monitoring for unauthorized access attempts and anomalous activity.
- Employee access: Staff access to production data is limited, logged, and subject to confidentiality agreements.
- Incident response: Documented incident response procedures for detecting, investigating, and mitigating security incidents.
While we take reasonable measures to protect data, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security against all possible threats.
10. Your Rights
10.1 Rights for All Users
Regardless of your location, you may:
- Access: Request a copy of the personal data we hold about you.
- Correction: Request correction of inaccurate or incomplete data.
- Deletion: Request deletion of your data, subject to legal retention requirements.
- Data Portability: Request a machine-readable copy of your data (JSON or CSV format).
- Withdraw Consent: Where we rely on consent, withdraw it at any time without affecting the lawfulness of prior processing.
- Opt-out of Marketing: Unsubscribe from marketing communications at any time using the unsubscribe link or by contacting us.
10.2 Additional Rights for EEA/UK Residents (GDPR)
- Restriction of Processing: Request that we limit how we use your data in certain circumstances.
- Object to Processing: Object to processing based on legitimate interest. We will cease processing unless we demonstrate compelling legitimate grounds.
- Automated Decision-Making: Right not to be subject to decisions based solely on automated processing that produce legal or significant effects. (Note: We do not currently engage in such processing.)
- Lodge a Complaint: File a complaint with your local supervisory authority (data protection authority).
10.3 How to Exercise Your Rights
To exercise any of these rights, contact us at privacy@nomasfilas.io. We will verify your identity and respond within 30 days (or 45 days for complex requests, with notice). We will not charge a fee for reasonable requests. Manifestly unfounded or excessive requests may be subject to a reasonable administrative fee or refused.
11. California Privacy Rights (CCPA/CPRA)
If you are a California resident, you have additional rights under the CCPA/CPRA:
- Right to Know: Request disclosure of the categories and specific pieces of personal information we have collected, the sources, the business purposes, and the third parties with whom we share it.
- Right to Delete: Request deletion of personal information, subject to certain exceptions.
- Right to Correct: Request correction of inaccurate personal information.
- Right to Opt-Out of Sale/Sharing: We do not sell personal information and do not share personal information for cross-context behavioral advertising.
- Right to Limit Use of Sensitive Personal Information: We limit our use of sensitive information to purposes necessary to provide the Service.
- Non-Discrimination: We will not discriminate against you for exercising your CCPA rights.
To exercise these rights, contact privacy@nomasfilas.io or call us (contact details in Section 19). We will verify your identity using at least two pieces of personal information before fulfilling requests.
11.1 Categories of Personal Information Collected
| CCPA Category | Examples | Sold? | Shared for Ads? |
|---|---|---|---|
| Identifiers | Name, email, phone, IP address | No | No |
| Commercial Information | Subscription plan, payment history | No | No |
| Internet/Network Activity | Browsing history, usage data | No | No |
| Geolocation | Approximate location from IP | No | No |
| Professional Information | Business name, role | No | No |
12. Brazilian Privacy Rights (LGPD)
If you are located in Brazil, you have rights under the Lei Geral de Proteção de Dados (LGPD), including the right to: (a) confirmation of processing; (b) access; (c) correction; (d) anonymization, blocking, or deletion of unnecessary data; (e) portability; (f) information about sharing with third parties; (g) information about the possibility of denying consent and its consequences; (h) revocation of consent. To exercise these rights, contact privacy@nomasfilas.io.
13. Children's Privacy
The Service is not intended for use by children under 16 years of age. We do not knowingly collect personal data from children under 16. If you are a parent or guardian and believe your child has provided personal data through the Service, contact us at privacy@nomasfilas.io and we will promptly delete it.
14. Cookies & Tracking
- Essential cookies: Required for the Service to function (session management, authentication). Cannot be disabled.
- Analytics cookies: Help us understand how the Service is used (Google Analytics with IP anonymization). Can be declined.
- Preference cookies: Remember your settings and choices. Can be declined.
We do not use advertising or tracking cookies. We do not participate in third-party advertising networks.
15. Third-Party Links & Services
The Service may contain links to third-party websites, applications, or services. We are not responsible for the privacy practices, content, or security of third parties. We encourage you to review the privacy policies of any third-party services you interact with.
16. Do Not Track
Some browsers transmit "Do Not Track" (DNT) signals. There is currently no industry standard for interpreting DNT signals. We do not currently respond to DNT signals, but we do not engage in cross-site tracking of individual users.
17. Data Breach Notification
In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of individuals, we will:
- Notify the relevant supervisory authority within 72 hours of becoming aware of the breach (where required by GDPR).
- Notify affected Clients without undue delay so they can fulfill their own notification obligations to End Users.
- Notify affected individuals directly if the breach is likely to result in a high risk to their rights and freedoms (where we are the Data Controller).
- Document the breach, its effects, and the remedial actions taken.
18. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. If we make material changes:
- We will notify Clients by email at least 15 days before the changes take effect.
- We will post a prominent notice on the Service.
- We will update the "Last updated" date at the top of this Policy.
- For material changes affecting End User data processing, we will also notify Clients so they can inform their End Users as appropriate.
Continued use of the Service after the effective date constitutes acceptance of the revised Policy.
19. Contact & Data Protection Officer
For privacy-related inquiries, data subject requests, or concerns:
| Purpose | Contact |
|---|---|
| Privacy & Data Protection Inquiries | privacy@nomasfilas.io |
| General Support | support@nomasfilas.io |
| Legal | legal@nomasfilas.io |
| Security Incidents | security@nomasfilas.io |
| Entity | NoMasFilas LLC, Wyoming, United States |
| Website | nomasfilas.io |
If you are not satisfied with our response to a privacy concern, you have the right to lodge a complaint with the relevant data protection authority in your jurisdiction.
Part B — Data Processing Agreement: Scope & Definitions
This Data Processing Agreement ("DPA") forms an integral part of this Privacy Policy and the Terms of Service. It governs the processing of personal data by NoMasFilas LLC ("Processor") on behalf of the Client ("Controller") in connection with the Service. This DPA meets the requirements of Article 28 GDPR, UK GDPR, CCPA/CPRA, and LGPD.
By using the Service, you accept this DPA. For a separately signed copy (e.g., institutional compliance), contact legal@nomasfilas.io.
- "Personal Data" — information relating to an identified or identifiable person, processed by the Processor on behalf of the Controller.
- "Processing" — any operation on Personal Data: collection, recording, storage, retrieval, use, disclosure, erasure, destruction.
- "Data Subject" — the person to whom the Personal Data relates (typically End Users).
- "Sub-processor" — any third party engaged by the Processor to process Personal Data on the Controller's behalf.
- "Personal Data Breach" — a security breach leading to accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data.
21. Nature & Purpose of Processing
| Aspect | Details |
|---|---|
| Nature | Collection, storage, organization, retrieval, consultation, use, transmission (for notifications), and erasure of End User data |
| Purpose | Queue management, virtual ticketing, appointment scheduling, notifications, analytics, and reporting |
| Duration | Duration of the Terms of Service + 30 days post-termination |
| Data Subjects | End Users / Guests of the Controller's locations; Authorized Users (staff) |
| Data Types | As configured by Controller: names, national IDs, phone numbers, emails, queue interaction data, appointment details, IP addresses |
Special categories: The Service is not designed for special category data (health, biometric, religious). If the Controller's use involves such data (e.g., medical queues), the Controller is solely responsible for lawful basis and additional safeguards.
22. Obligations of the Processor
NoMásFilas shall:
- Process on instructions only: Process Personal Data solely on documented Controller instructions (Terms + DPA), unless required by law (with prior notice, unless legally prohibited).
- Confidentiality: Ensure all personnel authorized to process Personal Data are bound by confidentiality obligations.
- Security: Implement appropriate technical and organizational measures (see Section 9 above).
- Sub-processors: Not engage Sub-processors without Controller authorization (see Section 24).
- Data subject assistance: Assist Controller in responding to data subject rights requests.
- Breach notification: Notify Controller within 72 hours of becoming aware of a Personal Data Breach.
- Deletion/return: Delete or return all Personal Data upon termination, per Section 26.
- Audit cooperation: Make information available to demonstrate compliance and allow audits (Section 27).
- DPIA assistance: Assist with data protection impact assessments and prior consultations where required.
- Cross-border safeguards: Implement transfer mechanisms (SCCs, etc.) for international data transfers.
23. Obligations of the Controller
The Client (Controller) shall:
- Determine the lawful basis for processing End User Personal Data.
- Provide appropriate privacy notices to Data Subjects.
- Obtain necessary consents where required.
- Respond to Data Subject requests (with Processor assistance).
- Ensure data collection scope is necessary and proportionate.
- Provide documented processing instructions.
- Comply with all Applicable Data Protection Law.
24. Sub-processors
24.1 Authorized Sub-processors
The Controller provides general authorization for the following Sub-processors:
| Sub-processor | Purpose | Location |
|---|---|---|
| Google Cloud / Firebase | Cloud hosting, database, authentication | United States |
| MongoDB Atlas | Database storage | United States |
| Cloudflare | DNS, CDN, DDoS protection | Global (US-based) |
| Stripe, Inc. | Payment processing | United States |
| Twilio / SMS providers | SMS notifications | United States |
| WhatsApp (Meta) | WhatsApp notifications | United States |
| Email service providers | Email notifications | United States |
24.2 Changes
Processor shall notify Controller of Sub-processor changes at least 15 days in advance. Controller may object on reasonable grounds within 15 days. If unresolved, either party may terminate the affected portion. Processor remains fully liable for Sub-processor acts.
25. International Transfers (DPA)
For transfers from EEA/UK/Switzerland, we rely on: (a) Standard Contractual Clauses (EU Commission Decision 2021/914); (b) UK International Data Transfer Agreement or Addendum; (c) Controller's consent as part of Service acceptance. Supplementary measures include encryption and access controls. Request transfer mechanism copies at privacy@nomasfilas.io.
26. Data Retention & Deletion (DPA)
- Upon termination: data retained 30 days for export.
- After 30 days: deletion or anonymization from active systems.
- Backups: purged per backup retention schedule.
- Controller may request specific End User deletion at any time.
- Legally mandated retention (e.g., tax records) overrides deletion requests.
27. Audits
Upon reasonable request and at Controller's expense, Processor shall provide: (a) written questionnaire responses; (b) certifications and audit reports; (c) on-site/remote audits with 30 days' notice, during business hours, under confidentiality, max once per 12 months. In case of conflict, this DPA prevails over the Terms regarding Personal Data processing.
28. Data Breach Response (DPA)
Upon a Personal Data Breach, Processor shall: (a) notify Controller within 72 hours; (b) provide: nature, categories/numbers affected, likely consequences, mitigation measures; (c) cooperate with investigation and remediation; (d) assist Controller in notifying authorities and Data Subjects; (e) document the breach and remedial actions.
Part C — Cookie Policy: What Are Cookies
Cookies are small text files placed on your device when you visit a website. They enable functionality, remember preferences, and help us understand usage. Similar technologies include web beacons, pixels, and local storage. "Cookies" in this section covers all such technologies.
30. Cookies We Use
30.1 Strictly Necessary (cannot be disabled)
| Cookie | Purpose | Duration |
|---|---|---|
| session_id | Maintains login session | Session |
| csrf_token | Prevents CSRF attacks | Session |
| auth_token | Authentication for logged-in users | 30 days |
| locale | Language preference | 1 year |
| cookie_consent | Remembers your cookie choice | 1 year |
30.2 Analytics (consent required)
| Cookie | Provider | Purpose | Duration |
|---|---|---|---|
| _ga | Google Analytics | Unique visitor ID (anonymized IP) | 2 years |
| _ga_* | Google Analytics | Session state | 2 years |
| _gid | Google Analytics | 24-hour visitor distinction | 24 hours |
| _gat | Google Analytics | Rate throttling | 1 minute |
30.3 Functional (preference-based)
| Cookie | Purpose | Duration |
|---|---|---|
| theme | Dark/light mode preference | 1 year |
| branch_last | Last selected branch (backend users) | 30 days |
| display_prefs | TV/display interface settings | 1 year |
30.4 What We Do NOT Use
We do not use: advertising cookies, social media tracking cookies, cross-site tracking, or behavioral advertising cookies.
31. Third-Party Cookies
- Google Analytics: Anonymized IP enabled. Opt out: Google Analytics Opt-out Add-on.
- Stripe: May set cookies during payment for fraud prevention. See Stripe's Cookie Policy.
32. How to Manage Cookies
Consent banner: On first visit, accept or decline non-essential cookies. Change preferences anytime via "Cookie Settings" in the footer.
Browser controls: Most browsers let you view, delete, block, or allow cookies. Instructions:
Disabling strictly necessary cookies may prevent core features from working.
33. Local Storage
The Service may use browser local/session storage for: caching queue data, storing UI preferences, and maintaining application state. This data stays on your device and is not transmitted to our servers. Clear it via browser settings.