Privacy Policy

Last updated: August 16, 2026

This Privacy Policy explains how DAISSACA E.I.R.L., under its commercial name Habla Pue (hereinafter, “Habla Pue”, “the Platform”, “we”, “us”, or “our”), collects, uses, retains, protects, and, where applicable, shares information related to people who use the Platform.

This Policy applies to all persons who use Habla Pue, regardless of whether they use the Platform exclusively to consume services, participate as providers, or carry out both activities.

Use of the Platform implies that the user has had the opportunity to become aware of this Privacy Policy and the other documents applicable to the use of Habla Pue.

This Policy must be interpreted together with the Terms and Conditions and the Habla Pue Cookie Policy.

1. What information we collect

Habla Pue collects only the information necessary to operate the Platform, provide its features, protect its users, process transactions, and comply with applicable legal obligations.

Depending on how the user uses the Platform, we may collect the following categories of information.

1.1. Registration information

We may collect:

• name or username;
• email address;
• phone number;
• country of residence;
• date of birth or information necessary to verify age;
• password or equivalent authentication mechanisms;
• internal account identifiers.

Not all of this information will necessarily be required in every case.

1.2. Identity information

When certain features require user identity verification, Habla Pue may request additional information, which may include:

• identity document;
• information contained in that document;
• photograph or image necessary for verification processes;
• biometric information where strictly necessary and legally permitted;
• information related to ownership of certain withdrawal methods;
• additional information necessary to prevent fraud or abuse.

Verification may be carried out directly by Habla Pue or through specialized providers engaged for this purpose.

2. Information related to use of the Platform

Habla Pue may record information generated through use of its services, including:

• date and time of access;
• IP address;
• device used;
• operating system;
• technical device information;
• technical identifiers;
• session logs;
• actions performed within the application;
• call-related information;
• call duration;
• completed transactions;
• coin consumption;
• coins purchased or received;
• rewards;
• withdrawals;
• support requests;
• reports and complaints;
• information related to suspensions or security measures.

This information allows the Platform to operate and maintain traceability of completed transactions.

3. Transaction information

Habla Pue records information related to economic transactions carried out within the Platform.

This may include:

• coin purchases;
• payment method used;
• transaction amount;
• currency used in payment;
• date and time;
• transaction status;
• coins credited;
• coin consumption;
• coin distribution;
• generated earnings;
• rewards;
• withdrawal requests;
• payments made;
• reversals or adjustments;
• transaction identifiers.

Habla Pue does not need to directly store all sensitive financial data used by payment gateways when that data is processed directly by the corresponding provider.

For example, when a transaction is processed by a specialized third party, Habla Pue may receive only the information necessary to identify, reconcile, and verify the transaction.

4. Call and communication information

Habla Pue provides communication features between users.

To provide these features, technical and operational data related to communications may be generated, such as:

• identification of participants;
• date and time;
• duration;
• call status;
• technical information necessary to establish the communication;
• technical incidents.

4.1. Content of communications

Processing of the content of communications will depend on the specific features enabled by Habla Pue and on the security and moderation measures implemented.

When Habla Pue enables review, moderation, fraud-prevention, or security mechanisms that require analysis of certain content, that information may be processed exclusively for the corresponding purposes and within the limits established by applicable law.

5. Information used for verification and security

Habla Pue may use personal and technical information to:

• verify identity;
• verify age;
• prevent fake accounts;
• detect fraud;
• prevent abuse of promotions;
• detect self-referrals;
• detect suspicious activities;
• protect balances and transactions;
• prevent unauthorized access;
• investigate complaints;
• protect other users;
• comply with legal obligations.

When a transaction or account presents certain risk indicators, Habla Pue may conduct automated or manual review.

6. Purposes of processing

Habla Pue uses the information collected for the following purposes.

6.1. Operation of the Platform

To:

• create and manage accounts;
• allow access;
• provide features;
• connect users;
• enable provision of services by users acting as providers;
• process calls;
• manage coins;
• administer balances;
• process withdrawals;
• manage rewards.

6.2. Processing of transactions

To:

• process purchases;
• credit coins;
• record consumption;
• calculate distributions;
• calculate earnings;
• manage settlements;
• perform reconciliations;
• maintain transaction records.

6.3. Security and fraud prevention

To:

• detect fraudulent behavior;
• investigate transactions;
• prevent abuse;
• protect accounts;
• prevent unauthorized access;
• detect activities incompatible with the Terms and Conditions.

6.4. Legal compliance

To comply with:

• tax obligations;
• data protection obligations;
• requests from competent authorities;
• information retention obligations;
• fraud-prevention and security obligations.

6.5. User support

To:

• respond to inquiries;
• manage complaints;
• resolve technical issues;
• investigate reports;
• manage account-related requests.

6.6. Improvement of the Platform

To:

• detect errors;
• analyze operation;
• improve features;
• improve security;
• develop new features;
• analyze Platform performance.

7. Basis and lawfulness of processing

Habla Pue will process personal data based on the circumstances applicable to each processing activity, including:

• performance of the contractual relationship with the user;
• compliance with legal obligations;
• protection of Platform security;
• fraud prevention and detection;
• consent, where legally required;
• legitimate interests, where applicable and permitted by the relevant legislation.

Not all processing activities necessarily require separate consent.

Where applicable law requires consent for a specific purpose, Habla Pue will request it in the appropriate manner.

8. Technology providers

Habla Pue uses external providers for certain components of its technological infrastructure.

These providers may provide services related to:

• infrastructure and servers;
• storage;
• image processing;
• phone verification;
• email;
• authentication;
• notifications;
• payment processing;
• fraud prevention;
• technical analysis;
• communication services.

These providers’ access to personal information will be limited to what is necessary to provide the contracted services.

9. Payment processors

Payment transactions may be processed through specialized third parties.

Where applicable, the payment provider may directly collect the financial information necessary to process the transaction.

Habla Pue may receive information related to:

• transaction identification;
• amount;
• status;
• date;
• method used;
• transaction result;
• information necessary for reconciliation and support.

Sensitive financial data not necessary for Habla Pue will not be stored directly by the Platform when processing corresponds to the specialized provider.

10. International transfers and processing

Habla Pue may use providers located outside Peru.

Consequently, certain personal data may be stored, processed, or otherwise handled in other countries.

This may occur, for example, when Habla Pue uses international technological infrastructure or global providers.

Habla Pue will adopt the contractual, technical, and organizational measures that correspond to protect personal information and comply with applicable regulations.

11. Information related to users acting as providers

A person may use Habla Pue as a user and, additionally, as a provider.

When a person uses features that allow them to act as a provider, Habla Pue may process additional information necessary to:

• verify identity;
• determine eligibility;
• manage profile;
• calculate earnings;
• manage levels;
• process settlements;
• process withdrawals;
• prevent fraud;
• comply with legal obligations.

This information does not imply that Habla Pue establishes an employment relationship with the user.

The nature of the relationship between Habla Pue and persons acting as providers is governed by the Terms and Conditions.

12. Tax information and transaction records

Habla Pue will retain certain information related to transactions carried out within the Platform where necessary to:

• comply with tax obligations;
• justify transactions;
• perform reconciliations;
• issue receipts;
• respond to requests from authorities;
• maintain evidence of transactions;
• conduct audits.

The information may include records of:

• purchases;
• consumption;
• distributions;
• commissions;
• rewards;
• settlements;
• withdrawals;
• adjustments;
• transactions carried out by the Platform.

13. Retention of information

Habla Pue will retain personal information for the period necessary to fulfill the purposes for which it was collected.

In addition, certain information may be retained for additional periods where necessary to:

• comply with legal obligations;
• respond to requests from authorities;
• resolve disputes;
• exercise or defend rights;
• prevent fraud;
• conduct audits;
• maintain evidence of transactions.

Deletion of an account does not necessarily imply immediate deletion of all information associated with it.

Certain records must be retained for the period necessary in accordance with applicable legal and operational obligations.

14. Account deletion

The user may request deletion of their account through the mechanisms enabled by Habla Pue.

Once deletion has been processed, Habla Pue may delete or anonymize information that is no longer necessary.

However, it may retain information where there is a legal obligation or a legitimate need to retain it, especially where it relates to:

• economic transactions;
• tax records;
• fraud evidence;
• complaints;
• regulatory obligations;
• information necessary to exercise or defend rights.

15. Security

Habla Pue will implement reasonable technical and organizational measures intended to protect personal information against:

• unauthorized access;
• loss;
• destruction;
• unauthorized modification;
• improper disclosure;
• fraudulent use.

These measures may include:

• access controls;
• authentication;
• encryption where appropriate;
• activity logs;
• segregation of duties;
• monitoring;
• fraud detection mechanisms;
• backups;
• controls over providers.

No system connected to the Internet can guarantee absolute security. For this reason, Habla Pue cannot guarantee that no security incident will occur.

16. Information shared with third parties

Habla Pue may share personal information only where there is a legitimate purpose and within the corresponding limits.

Recipients may include:

• technology providers;
• verification providers;
• communications providers;
• storage providers;
• payment processing providers;
• security providers;
• professional service providers;
• competent authorities;
• public entities where there is a legal obligation.

Habla Pue will not sell users’ personal data as an independent commercial activity.

17. Reports, moderation, and security

When a user reports another user or when Habla Pue detects a possible violation of the Terms and Conditions, the Platform may use available information to investigate the incident.

This may include:

• account information;
• transaction history;
• technical records;
• call information;
• reports;
• evidence provided by users;
• information related to security measures.

Processing will be aimed at protecting the community, investigating possible violations, and adopting corresponding measures.

18. Minors

Habla Pue will establish a minimum age for use of the Platform.

It is not permitted to use Habla Pue where the person does not meet the established minimum age.

Where Habla Pue reasonably detects that an account belongs to a person who does not meet the minimum age, it may suspend or cancel the account and adopt the necessary measures regarding the associated information.

19. Rights of the personal data subject

Users may exercise the rights available to them under applicable personal data protection legislation.

Depending on the case, these may include:

• access to their data;
• information about its processing;
• rectification;
• updating;
• cancellation or deletion;
• objection;
• withdrawal of consent where processing is based on consent;
• other rights recognized by applicable law.

Requests must be made through:

Email: administrador@hablapue.com

Habla Pue may request additional information to verify the identity of the person submitting the request.

20. Accuracy of information

The user is responsible for providing truthful, complete, and up-to-date information.

When the information provided changes, the user must update it through the available mechanisms.

The existence of incorrect information may affect certain features, including verification processes, withdrawals, or security.

21. Cookies and similar technologies

Habla Pue may use cookies and similar technologies to:

• maintain sessions;
• remember preferences;
• improve features;
• analyze operation of the Platform;
• detect problems;
• improve security.

Specific handling of cookies is developed in the Habla Pue Cookie Policy.

22. Changes to the Privacy Policy

Habla Pue may modify this Privacy Policy when necessary, for example, due to:

• changes in the Platform;
• new features;
• technological changes;
• regulatory changes;
• incorporation of new providers;
• changes in information processing practices.

The current version will be the one published through Habla Pue’s official channels.

Where a change is substantial and applicable law so requires, Habla Pue will adopt the corresponding communication measures.

23. Contact

For questions related to this Privacy Policy, personal data protection, or exercise of rights:

DAISSACA E.I.R.L.
Habla Pue
Email: administrador@hablapue.com
Website: https://hablapue.com/