Privacy Policy

cat /etc/underc0de/privacy.md

1. Purpose

This privacy policy (the “Policy”) governs the processing of users' personal data (the “Data”) in accordance with Personal Data Protection Law No. 25.326 and other applicable legislation of the Argentine Republic, and fully complies with European Union legislation. The Policy shall apply to all Users who accept it before providing their Data and to all Users who browse the Underc0de forum available through the app.

2. Definitions

Under Law No. 25.326, the following terms have the following meanings:

Personal data: information of any kind relating to identified or identifiable natural persons or legal entities.
Sensitive data: personal data revealing racial and ethnic origin, political opinions, religious, philosophical or moral beliefs, trade union membership, and information concerning health or sex life.
File, register, database or data bank: an organized set of personal data subject to processing, whether electronic or not, regardless of the manner in which it is created, stored, organized or accessed.
Data processing: systematic operations and procedures, whether electronic or not, that allow the collection, retention, sorting, storage, modification, cross-referencing, evaluation, blocking, destruction and, in general, the processing of personal data, as well as its transfer to third parties through communications, queries, interconnections or transfers.
Controller of a file, register, database or data bank: a public or private natural person or legal entity that owns a file, register, database or data bank.
Computerized data: personal data subject to electronic or automated processing.
Data subject: any natural person or legal entity with a legal domicile, offices or branches in the country whose data is subject to the processing referred to in Law 25.326.
Data user: any public or private person who, at their discretion, processes data, whether in their own files, registers or data banks or through a connection to them.
Data dissociation: any processing of personal data in such a way that the information obtained cannot be associated with an identified or identifiable person

3. Guiding Principles for Processing Your Data

Quality: this principle establishes that the Data collected shall be adequate, relevant and not excessive in relation to the scope and purpose for which it was collected; that collection may not be carried out by unfair or fraudulent means or in a manner contrary to the provisions of the law; that the Data must be accurate and capable of being updated; that it must be stored in a way that allows you to exercise your right of access; and that it must be destroyed once it is no longer necessary or relevant for the purposes for which it was collected.
Purpose: this principle establishes that your Data may not be used for purposes other than or incompatible with those that justified its collection.
Information: this principle establishes that, prior to the collection of your Data, you must be informed of the Data to be collected, the purpose for which it is collected, the existence of the database where your Data will be stored, the consequences of providing your Data or refusing to do so, and the possibility of exercising your rights of access, rectification and deletion.
Consent: the general principle is that the processing of your Data requires your informed consent, unless an exception is provided for in the regulations. Your consent must be free, express and informed, and must be given in writing or by an equivalent means; therefore, you must read and accept this policy in order to register as a User. Consent may be revoked at any time, without retroactive effect.
Sensitive Data: we inform you that no person may be compelled to provide sensitive data.
Transfer: we inform you that your data may only be transferred as set forth in this Policy, for purposes directly related to the legitimate interest of the transferor and the transferee.
Confidentiality: all persons involved in the processing of your Personal Data are bound by professional secrecy with respect to such Data. Your Data may only be disclosed to third parties in accordance with the provisions herein. Considering that employees may become aware of your Data in the performance of their duties, and in order to strengthen the legal protection of the data subject and ensure that those who must comply with this obligation are aware of it, it is advisable to enter into confidentiality agreements in which employees expressly undertake to keep confidential the personal data they access in the performance of their duties, and acknowledge that this duty of confidentiality continues even after the employment relationship has ended.
Security: Underc0de shall adopt the security measures necessary to ensure the security and confidentiality of your Data, in order to prevent its alteration, loss, or unauthorized access or processing, and to allow the detection of intentional or unintentional deviations of information, whether the risks arise from human action or from the technical means used; it is prohibited to record personal data in files, registers or data banks that do not meet technical conditions of integrity and security.

4. Data We Collect

By accepting this Policy, you consent to our processing of your Data in accordance with the provisions herein. The Data we may collect is as follows: (i) Underc0de collects personally identifiable information during the registration process or in response to certain requests. Underc0de may also collect your IP (Internet Protocol) address to help diagnose problems with our server and to administer the Site. An IP address is a number assigned to your computer when you use the internet. Your IP address is also used to help identify you within a particular session and to collect general demographic information; and (ii) to create a user account on the Site, the following Data will be required: (a) first and last name; (b) email address; (c) password; and (d) acceptance of this policy. Furthermore, Underc0de may change the required Data at any time in line with the evolution of the app. Likewise, if you do not accept this policy, you will be unable to use the Site.

5. Purposes for Which We Use the Data

In order to provide an excellent service and so that you can use the Site and enjoy our Services as dynamically and securely as possible, Underc0de requires the use of your Data for the purposes set forth herein. Using your Data for these purposes allows Underc0de to offer services and features better suited to your needs. The Data collected may be used by Underc0de to verify a person's details and to create a digital credential that certifies them.

6. Rights of Access, Deletion and Rectification

Please be advised that the data subject has the right to access their Data free of charge at intervals of no less than six months, unless a legitimate interest in doing so is demonstrated, as set forth in Article 14, paragraph 3 of Law No. 25.326 (Resolution 14/2018). To do so, you may send an email to [email protected] requesting access to your Data and, where applicable, requesting that it be updated, modified or deleted. The Agencia de Acceso a la Información Pública (Agency for Access to Public Information), the Supervisory Authority for Law No. 25.326, has the power to handle complaints and claims filed in connection with non-compliance with personal data protection regulations. When exercising your right of access, you must prove your identity. Once your identity has been verified, Underc0de will respond through the same channel within five (5) business days, as appropriate according to the data subject's request.

7. Data Portability and Blocking

Portability: The data subject shall have the right to receive the Data concerning them that they have provided to Underc0de in a structured, commonly used and machine-readable format, and to transmit it to another controller without hindrance from Underc0de, where: a) the processing is based on consent given after having previously been informed of its purpose, and b) the processing is carried out by automated means. When exercising the right to Data portability, the data subject shall have the right to have the Data transmitted directly from one controller to another, where technically feasible. The exercise of this right shall be without prejudice to the right to deletion. This right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Blocking: The data subject shall have the right to object to or block, at any time and on grounds relating to their particular situation, the processing by Underc0de of Data concerning them, including profiling of that person. Underc0de shall cease processing the Data unless it demonstrates compelling legitimate grounds for the processing that override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defense of legal claims.

8. Storage

Underc0de shall be the sole owner of the aforementioned Database. The Data will be stored for as long as is useful to fulfill the purposes indicated above. Underc0de will protect the database in accordance with the standards imposed by current regulations and industry best practices that reasonably ensure the integrity and security of the personal data it contains. As stated, by accepting this Policy you consent to your data being stored in and/or transferred to the countries where the servers are located, even if such countries do not have personal data protection legislation equivalent to Argentine legislation.

9. User Representations

By providing your Data, you guarantee its truthfulness, accuracy, currency and authenticity, and you undertake to keep it duly updated. In accordance with applicable legal requirements, Underc0de may use a variety of technologies that collect and provide information about how digital media are used and accessed by Users.

10. Data Collected by the Underc0de App

Underc0de operates the Underc0de mobile application (the “App”), available for iOS and Android. In addition to what is stated in section 4, in connection with the App we may collect the following Data:

Account data: username, email address and password, required to access the forum and the App's services.
Profile data: your member credential information and your profile picture, if you choose to upload one.
PRO subscription: on iOS, Apple processes the payment and we receive only your subscription status in order to enable PRO benefits. On Android, we may ask for the email address associated with your Mercado Pago account in order to link your subscription.
Notifications: your device token, in order to send you notifications through Firebase.
App usage: anonymous usage events and crash reports, through Firebase Analytics and Crashlytics.
Camera and photos: these are accessed only when you choose to change your profile picture or scan a QR code.

11. How We Use App Data

We use the Data listed in the previous section to authenticate you, display your member credential, manage PRO subscription benefits, operate the integrated forum, send you notifications, and improve the stability and performance of the App.

12. Who We Share Data With

To provide the App's services, we share Data, only to the extent strictly necessary, with the following third parties:

Apple: in-app purchases on iOS.
Mercado Pago: subscription management on Android.
Google Firebase: notifications, analytics and crash reports.
Underc0de forum infrastructure: underc0de.org. We do not sell your personal Data.

13. Underc0de PRO Subscriptions

Underc0de PRO renews automatically until you cancel it. On iOS, you can cancel it from Settings → Apple ID → Subscriptions; billing is handled by Apple under its own terms and conditions. On Android, the subscription is managed through Mercado Pago under its terms.

14. Your Rights and Contact

You can request access to, correction of, or deletion of your account and your Data by writing to [email protected], under the terms set out in sections 6 and 7 of this Policy.

15. Changes to This Policy

We may update this Policy at any time. The date of the latest revision will be indicated at the bottom of this document.

Last updated: August 11, 2026.