Master Privacy Policy

Last updated: 2026-04-25

for the SOVIRO App and Related Digital Platform

1. Introduction

This Privacy Policy explains how Digital Supremacy B.V. (“Digital”, “we”, “our”, or “us”) collects, uses, stores, discloses and otherwise processes personal data in connection with:

the SOVIRO App mobile application (the “App”);
the related digital platform and internal order management and support systems operated by Digital;
account management, authentication, technical support, order routing, security, diagnostics and platform administration; and
related websites, support channels, account and data request channels made available by Digital.

This Privacy Policy is intended to provide a general, platform-level explanation of our processing activities. It should be read together with:

the Terms of Use for the App;
the country-specific seller and consumer information made available in the App and/or through the Legal Documents section on Digital’s website;
the applicable local seller’s Politicas page; and
the local sales, delivery, return, complaint and consumer terms applicable to the sale of products in the user’s country.

By creating an account, accessing, or using the App, you acknowledge this Privacy Policy.

Where consent is required by applicable law for a specific processing activity, such consent will be requested separately or as part of the relevant in-app process.

2. Who We Are

The App and the related software infrastructure and digital platform of which the App forms a part are owned and technically operated by Digital Supremacy B.V.

Digital acts as the owner and technical operator of the App and the related digital platform, including the underlying technology, infrastructure, hosting environment, account systems, support systems and internal order management systems.

The App is available to users in Chile, Peru and Colombia.

Important: Products displayed and offered through the App are sold by the local seller applicable to the user’s country, and not by Digital, unless expressly stated otherwise.

Country-specific seller details and local commercial information are made available:

in the App;
through the Legal Documents section on Digital’s website; and/or
through the applicable local seller’s Politicas page.

3. Scope of This Privacy Policy

This Privacy Policy applies to personal data processed by Digital in connection with:

registration and account management;
app access and authentication;
browsing products and interacting with the App interface;
creating and managing orders through the App;
delivery-related operational support;
customer service and support communications;
technical operation, security, diagnostics and platform administration;
marketing and promotional communications, where applicable; and
handling privacy requests, data requests, account deletion requests, complaints, incidents and legal obligations.

This Privacy Policy does not replace local consumer, tax, logistics, product-specific or seller-specific rules that apply to the local seller of goods in the user’s country.

Local sellers may provide additional local notices, terms or policies in relation to product sales, delivery, returns, complaints, local customer service and local legal obligations.

4. Roles and Responsibilities

Because the App operates across multiple countries and involves both platform-level and local commercial functions, different parties may play different roles in relation to personal data.

4.1 Digital

Digital acts as the owner and technical operator of the App and related digital platform. In this capacity, Digital may process personal data for purposes including:

user authentication and account administration;
hosting, support and platform operation;
information security and fraud prevention;
diagnostics, maintenance and technical support;
operation of internal systems used to route and manage orders;
privacy, account and data request handling; and
other platform-level, security-related, operational or legally required purposes.

4.2 Local Seller

The local seller applicable to the user’s country is the seller of goods offered through the App and may process personal data for purposes including:

sale of products;
order fulfillment;
delivery and logistics coordination;
returns and complaints handling;
customer service in relation to the purchase of goods;
local commercial communications, where applicable; and
compliance with local legal, tax, consumer, product and commercial obligations.

4.3 Service Providers and Other Recipients

Certain external service providers may process personal data to the extent necessary for the operation of the App, order handling, delivery, communications, security, infrastructure, diagnostics, support or legal compliance.

These may include, where applicable:

cloud hosting and infrastructure providers;
authentication, messaging and push notification providers;
analytics, diagnostics and crash reporting providers;
mapping, geocoding or address-validation providers;
logistics and delivery providers;
customer support or communications providers; and
other technical or operational service providers.

5. Categories of Personal Data We May Collect

Depending on the features you use, the country in which you use the App and the functionality enabled in your account, we may collect or otherwise process the following categories of personal data.

5.1 Registration and Account Data

mobile phone number;
first name and surname;
profile-related information you choose to provide;
profile photo, where available and voluntarily uploaded;
account identifiers;
authentication and session data; and
country or region associated with your account.

5.2 Order and Delivery Data

order details;
order history;
delivery addresses;
delivery notes or relevant instructions;
operational order status information;
customer support information related to an order; and
applicable local seller and service routing information.

5.3 Location and Address Data

GPS coordinates or map point selected by the user;
geocoded or normalized address data; and
location-derived delivery zone information.

Where location permission is requested, it is intended to support delivery-related functionality.

We do not state that the App performs background location tracking unless such functionality is actually implemented and separately disclosed.

If the App allows users to provide an address or select a delivery point manually, GPS permission may be optional, although delivery address or delivery point information may still be required to process an order.

5.4 Device, Technical and Security Data

device identifiers and app instance identifiers;
push token / FCM token;
operating system and device model;
app version and technical environment data;
IP address and associated technical logs;
security events and session metadata; and
technical data generated by SDKs, libraries or infrastructure services used for app operation, diagnostics, notifications, security or support.

5.5 Support and Communications Data

requests, messages or support tickets submitted by users;
service communication records;
delivery- or order-related notifications;
communication preference data; and
information related to complaints, returns or support interactions, where applicable.

5.6 Promotional, Loyalty or Referral Data

Where promotional, loyalty or referral features are available in the App and enabled in the relevant country, we may process:

promotional participation data;
loyalty-related balance or benefit information;
referral or invitation identifiers; and
eligibility-related data for campaigns or offers.

Where such features are not enabled, this section does not apply.

5.7 Error, Diagnostics and Security Data

crash reports;
application diagnostics;
error logs;
performance and reliability data; and
operational and security-related event records.

5.8 Health-Related Data

The standard account, browsing, ordering and delivery flow of the App is not intended to collect health data, medical records, symptom questionnaires or medical history.

If, in the future, the App enables specific health-related functionality, such as symptom questionnaires, medical profiles, AI-generated health-related recommendations or similar features, additional notices, consents and safeguards may apply before such functionality is made available.

6. Sources of Personal Data

We may obtain personal data:

directly from you;
automatically from your interaction with the App and related platform;
from internal digital systems operated by Digital;
from the applicable local seller;
from logistics or delivery service providers;
from communication providers, mapping or geocoding providers, infrastructure providers, diagnostics providers and similar service providers;
from support interactions, complaint-handling flows or order-related communications; and
from legally required or operationally necessary sources connected with your account, order or use of the App.

7. Purposes of Processing

We may process personal data for the following purposes:

to register and manage user accounts;
to authenticate access and protect account security;
to operate the App and related digital platform;
to route, process and support orders;
to enable local sellers and delivery providers to fulfill orders;
to provide technical support and customer assistance;
to communicate with users about orders, delivery, support or account security;
to personalize language, region, display settings or operational flows;
to administer campaign, referral, loyalty or promotional features, where available;
to prevent fraud, abuse, misuse and security incidents;
to maintain logs, monitor service quality and improve reliability;
to comply with legal, tax, accounting, consumer or regulatory obligations;
to establish, exercise or defend legal claims; and
to protect the rights, property, safety and legitimate interests of Digital, local sellers, users, service providers and third parties.

8. Legal Bases for Processing

Depending on the applicable law and the nature of the relevant processing activity, we may rely on one or more of the following legal bases:

performance of a contract or steps taken at your request prior to entering into a contract;
compliance with a legal obligation;
consent, where consent is required by law; and
legitimate interests, where permitted by applicable law and appropriately balanced against your rights and freedoms.

Where local law requires a more specific consent, authorization, disclosure or in-app acceptance mechanism, the relevant local requirements shall apply.

9. Data Sharing and Recipients

We do not sell personal data to unrelated third parties for their independent marketing or advertising purposes.

We may disclose personal data, where relevant and necessary, to:

the local seller applicable to your country;
logistics and delivery providers;
customer service or communications providers;
cloud hosting, infrastructure, security and support providers;
authentication, messaging, push notification or diagnostics providers;
mapping, geocoding or address-validation providers;
analytics, diagnostics, crash reporting or app performance providers;
legal advisers, auditors, insurers and professional service providers; and
public authorities, regulators, courts, law enforcement agencies or other third parties where disclosure is required by law or necessary to protect rights and legitimate interests.

For clarity, certain providers may process data as service providers acting on behalf of Digital or the applicable local seller. Other recipients, such as local sellers or logistics providers, may receive data as separate parties where necessary to fulfill orders, deliver products or handle consumer-related matters.

10. International Transfers

The App and the related digital platform rely on international technical infrastructure and service providers. As a result, personal data may be processed in jurisdictions other than the user’s country.

Where required by applicable law, we implement reasonable contractual, organizational and technical safeguards in connection with such transfers.

11. Data Security

We implement reasonable technical and organizational measures designed to protect personal data, including measures relating to:

encrypted transmission;
secure storage of authentication-related data where applicable;
access controls;
environment segregation;
logging and monitoring;
role-based access restrictions;
incident management procedures; and
technical and organizational safeguards intended to reduce the risk of unauthorized access, disclosure, alteration or loss.

No system can guarantee absolute security.

12. Data Retention

We retain personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy, including:

operation of the App and user accounts;
processing and support of orders;
customer service;
compliance with tax, accounting, legal and regulatory obligations;
fraud prevention and security;
dispute resolution and claims handling; and
auditing, backup and operational continuity requirements.

Retention periods may vary depending on the type of data, the country involved, legal obligations, platform architecture and operational necessity.

Where immediate permanent deletion is not technically possible, personal data may first be deactivated, restricted, anonymized, suppressed or otherwise removed from active operational use, and fully deleted later in accordance with applicable retention requirements and technical limitations.

13. Your Rights

Depending on the law applicable to your country and the context of processing, you may have the right to:

request access to your personal data;
request correction or updating of inaccurate data;
request deletion, blocking or restriction of processing;
object to certain processing activities;
withdraw consent where processing is based on consent;
request information about transfers or disclosures; and
lodge a complaint with a competent authority.

To exercise your rights, please contact us using the contact details set out below or through the dedicated account/data request channel made available in the App or through the Legal Documents section on Digital’s website.

Where your request relates to a product purchase, delivery, return, refund, local complaint, PQR, Libro de Reclamaciones or similar local seller matter, we may direct you to the applicable local seller or relevant local contact channel.

We may require reasonable proof of identity before processing a request.

14. Account Deletion

You may request the deletion of your account and associated personal data through:

the in-app account deletion flow, where implemented and available;
the dedicated account and data request section available through the Legal Documents page at dsupremacy.com/legal; and/or
the privacy contact details listed in this Privacy Policy.

Deleting the App from your device does not automatically delete your account or associated personal data.

Please note that certain data may need to be retained after an account deletion request in order to:

comply with legal, tax, accounting or regulatory obligations;
prevent fraud, misuse or security abuse;
maintain auditability or logs;
preserve evidence relevant to disputes, complaints or claims; and
comply with backup, security or system continuity requirements.

Where data has been shared with local sellers, logistics providers or other parties for order fulfillment, delivery, consumer support or legal compliance, deletion or restriction requests may need to be coordinated with such parties in accordance with applicable law.

15. Marketing and Service Communications

We may send:

service communications, including messages relating to account security, order status, delivery, support or operational matters; and
marketing communications, where permitted and where any required consent has been obtained.

Users may manage available marketing preferences in the App, where such settings are implemented, or by contacting us through the channels listed below.

Service communications necessary for account security, order processing, delivery or support may still be sent even if a user opts out of marketing communications.

16. Children and Minimum Age

The App is not intended for individuals who are not legally permitted to use the App or purchase products through it under applicable law.

Where the App includes an age confirmation step or minimum-age requirement, users must provide accurate information.

We do not knowingly seek to collect personal data from children in violation of applicable law.

17. Country-Specific Information

Additional country-specific information may apply depending on the user’s country, including information relating to:

the identity of the applicable local seller;
local contact details for customer support, complaints and privacy-related requests;
local sales, delivery, returns and complaint procedures; and
other country-specific legal disclosures relevant to the sale of products through the App.

Such country-specific information may be made available:

in the App;
through the Legal Documents section on Digital’s website; and
through the applicable local seller’s Politicas page.

Please refer to the country-specific documents and local legal materials applicable to your country of purchase.

17.1 Chile

For users in Chile, products made available through the App are sold by the local seller identified in the App and in the Chile-specific legal materials available through the applicable local seller’s Politicas page.

17.2 Peru

For users in Peru, products made available through the App are sold by the local seller identified in the App and in the Peru-specific legal materials available through the applicable local seller’s Politicas page.

17.3 Colombia

For users in Colombia, products made available through the App are sold by the local seller identified in the App and in the Colombia-specific legal materials available through the applicable local seller’s Politicas page.

18. App Store and Data Safety Disclosures

Where the App is made available through an app store, additional privacy, data safety, account deletion or similar disclosures may be provided through the relevant app store listing.

Such disclosures are intended to summarize certain data practices of the App and should be read together with this Privacy Policy and the information made available in the App.

If any app store disclosure requires updates due to changes in App functionality, data processing, SDKs, service providers, account deletion mechanisms or other relevant practices, we may update such disclosures accordingly.

19. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The updated version will be made available in the App and/or in the Legal Documents section on Digital’s website, and the “Last updated” date will be revised accordingly.

Where required by applicable law, additional notice or a renewed acceptance mechanism will be used.

20. Contact Details

Digital Supremacy B.V.

Korte Lijnbaanssteeg 1, office 4548,

1012SL Amsterdam,

The Netherlands.

Privacy contact: privacy@dsupremacy.com

Technical support: support@dsupremacy.com

Account and data requests: dsupremacy.com/legal

Website: dsupremacy.com

Country-Specific Local Seller Documents

Country-specific seller information and local commercial documents are made available through the applicable local seller’s Politicas page and/or through the Legal Documents section on Digital’s website.