Pasillo Privacy Policy

1. Who we are and what this policy covers

In short: Pasillo is operated by Zentoko AI, LLC. This policy covers the website, the app, our emails and our WhatsApp notices.

Pasillo is operated by Zentoko AI, LLC, a Georgia (United States) limited liability company based in Atlanta ("Pasillo", "we"). We are the controller of the data this policy describes. Section 10 explains what each mall is responsible for.

This policy covers:

• the pasillomall.com website, built and hosted on Zentoko, a platform our company also runs (section 9);
• the app at app.pasillomall.com: the shopper guide, each store's page, the store portal, the mall portal, the sales agent portal and the Pasillo staff tools;
• the emails we send;
• the WhatsApp notices we send to stores.

If you write to us through the website's form, we receive your name, your email address, your message and what you tell us about your company, with the page you sent it from, your browser type and a one-way scrambled (hashed) version of your IP address. We use them only to answer you.

Pasillo is an independent product. Each mall that uses Pasillo is a separate company, with its own privacy rules. Pasillo is not affiliated with any mall, Albrook Mall included, except a mall that has signed a contract with Pasillo.

We follow Law 81 of March 26, 2019, on personal data protection, and its regulation, Executive Decree 285 of May 28, 2021, of the Republic of Panama.

2. If you use the guide as a shopper

In short: you need no account. We count what happens in the app without knowing who you are, and almost everything else stays on your phone.

What we don't ask for. You need no account. We don't ask for your name, email or phone number to use the guide. Pasillo doesn't use GPS or follow your movements. You tell it where you are: you scan one of the mall's QR codes, tap your zone and floor, or tap a spot on the floor plan.

Activity without names. So the mall and the stores know what works, the app sends us these facts:

• that you opened a store's listing and, if you got there from a search, the words you searched;
• that you tapped "Getting there", WhatsApp or a store's phone number;
• that a deal's code was shown;
• that you tapped a restaurant's sponsored craving or mealtime card on the 3D map ("Antojo");
• that you ran a search, the words you used and whether it found anything;
• that you opened the app from a QR code or chose your zone by hand, with that zone and floor;
• that you scanned the QR code at a store's register, and which store.

Each fact carries the mall, the time and a random code that the app creates and keeps in your browser. That code lets us count how many different phones use the app and avoid repeated reports. It carries neither your name, email, number nor IP address. We never link it to the email you give us for deal alerts. It isn't fully anonymous: the same code links everything done from your browser, at any mall, until you delete it or the app replaces it with a new one, which it does every year. "Don't count my visits" in the Info tab stops the counting from your browser and deletes the code. We don't keep your exact spot on the plan, only the zone and floor. When someone shows the app in demo mode, we count nothing.

Your searches. We keep the words you search. The mall and the stores only see words searched from at least 3 different phones, and never who searched them. Even so, don't type personal information into the search box.

What is kept on your phone. The app keeps in your browser:

• where you are (zone, floor and spot on the plan);
• the stores you save;
• your last 5 searches, which you can clear in the app;
• the key to your deal alerts, if you asked for them;
• the bags you earned at stores' registers, your Mall passport (the zones, floors and stores whose QR codes you scanned, and the days you scanned one), the badges and accessories you unlocked, and the character you chose with its look and personality;
• how many tips you left today at each mall, at which stores and which ones you reported, for the daily limit.

The stores you save, your list of recent searches, your bags, your passport, your badges, your character and the count of your tips never reach us. Of the rest, only what this section explains reaches us: your zone and floor when you scan a QR code or pick your zone, your spot on the plan when you ask for a route, the words of each search, your alerts key when you open or change your alerts, and the tip you leave or report.

Photos with your character. If you make a photo with your character, the app uses your phone's camera, or a photo you pick, only on your phone, and only while that screen is open; nothing is recorded. The photo and the picture made from it never reach us: we don't receive, keep or count them, and the app doesn't keep them after you close that screen. Making the picture removes the photo's hidden data, such as where it was taken. If you share it, the app you share it with receives it, and its rules apply.

Routes. To draw a route, the app sends us the spot where you are and the place you are going. We work out the route and don't keep it in our database or in the server log, and your phone keeps a copy of the route for use without signal. Section 9 explains how to delete what is on your phone.

Reporting a problem. If you report a problem on a store's listing, we keep the reason you pick and your browser's random code. The code lets us accept only one report per store and reason a day. The mall team sees the reason, not the code.

Tips for other shoppers. If you leave a tip about a store (Terms, section 4), you make it with a phrase from a list, without your own text. We keep only the phrase, the store, the mall and the day, and whether the store hid it. The tip carries neither your browser's random code, your IP address, the time nor anything else that says who left it, and it isn't counted in the activity without names. The request is noted in the server logs and their in-memory counts, like any other ("Server logs", below); the phrase and the store go inside the request, not in the address, so the log doesn't show which tip you left. For the daily limit, your phone counts how many tips you left today at that mall (section 9). The tip shows to everyone who uses that mall's guide, on the store's card and on the 3D map, where one of the decoration shoppers says it. Nobody sees who left it, and Pasillo never shows where another shopper is or whether they are in the mall. If you report a tip, we keep the tip, the reason you pick and the day, without your browser's code.

Treasure hunts. A mall can run a treasure hunt in the app: clues that lead you to scan a store's sign or find a star on the 3D map. Which steps you have done stays on your phone. When you finish a hunt, the app tells us only that the hunt was finished: we add one to that hunt's count for the day. That count carries no random code, no time and nothing else about you, so it can't tell who finished or when. Like any request, the message is noted in the server logs below, which are kept up to 30 days. Everyone looking at the mall's map sees that shoppers finished the hunt, with a number only when at least 3 did. When someone shows the app in demo mode, or you turned on "Don't count my visits", the app doesn't tell us. If the hunt has a prize (Terms, section 4), when you finish it you can tap "Get my code": the app asks us for a random one-time code and keeps it on your phone. We keep the code with its hunt, the day it was given and the day it was used, and which register account recorded it, for the store's records; never who got it. The code carries neither your browser's random code nor your IP address; the request is noted in the server logs like any other, up to 30 days. Asking for the code is a tap and isn't counted in the activity without names. At a mall that isn't published yet, the code is a sample and we don't keep it.

Crowds on the 3D map. The shoppers walking the 3D map's halls are drawings. Outside each store, more of them gather the more phones showed interest in it over the last 7 days: they opened its listing, asked for directions, showed a deal's code, or tapped WhatsApp or its phone. We work it out from the activity without names explained above, in three levels, only for stores looked up from at least 3 different phones, and a day late, so it shows how popular a store has been, never who was there or who is there now. Nothing new is collected for it.

WhatsApp, calls and other sites. If you message a store on WhatsApp, call it, or open its website or Instagram, you leave Pasillo. That conversation is between you and the store, and those services' rules apply. Pasillo only counts taps on WhatsApp or the phone number; it doesn't count taps on the store's website or Instagram.

Server logs. Like any website, our server notes each request: the IP address, the browser, the referring page, the address requested (for example, the QR sign you scanned) and the time. We use them for security, to fix problems and to stop abuse. To stop abuse, the server also counts in its memory the requests from each IP address and the sign-in attempts for each email. It doesn't store them in the database, and it forgets them within a minute of their time window ending (an hour at most).

3. Deal alerts by email

In short: we keep your email and the stores you follow only to send you the alerts. When you unsubscribe, it is all deleted.

You can follow a store's deals or ask for every new deal at a mall. For that we keep:

• your email;
• the mall and the language of your emails;
• the stores you follow, or that you asked for every deal, and since when;
• which deals we already sent you, so we don't repeat them;
• when you confirmed and when we sent you the last email;
• a secret key that goes in the links of your emails.

Double confirmation. We send no alert until you confirm from the email you receive. That way nobody can sign up someone else's email. If you don't confirm within 7 days, we delete your email.

What you get. The alerts are the stores' advertising, and each email's subject says so. You get at most one email a day, with the new deals of the stores you follow. The email doesn't include the deal's code: that stays in the app.

Images and tracking. When you open an email, your email program downloads our logo. It is the same image for everyone and we don't use it to tell who opened the email. Our emails don't track whether you open them or which links you tap.

Your key. The link in your emails carries a key that lets you see and change your alerts without an account. Your alerts page shows your email and the stores you follow. The app keeps the key on your phone so that "Follow deals" works with one tap. Don't share that link.

Unsubscribing. You can stop the alerts at any time, free and with one tap. Every email has a link to unsubscribe, and many email programs show a button to do it. When you unsubscribe we delete your email, the stores you followed and the record of what we sent.

Who sees it. Stores and the mall only see how many people follow their deals, never who they are.

4. Scanning a store's sign

In short: the photo goes to Anthropic only to recognize the store. Pasillo doesn't keep it or log it.

Scanning is optional. You can set your location without it. When you tap "Scan a sign" and take a photo:

1. the app shrinks the photo on your phone, to about 1000 pixels, and turns it into a new image; this removes the photo's hidden data, such as where it was taken;
2. the app sends us that photo, and we pass it to Anthropic, PBC, together with the mall's store list;
3. Claude, Anthropic's artificial intelligence model, answers which store it is, or that it isn't sure;
4. we show you the result and put your location on the plan.

Pasillo doesn't keep the photo and doesn't write it to any log. Anthropic handles it as our provider. Under its commercial terms, Anthropic doesn't use the photo to train its models and deletes it within 30 days. If its safety systems flag it, it may keep it for up to 2 years. Anthropic stores data in the United States and may process it in other countries.

Aim only at the sign and keep people out of the photo. Scanning may not be available and has a daily limit.

5. If you work at a store

In short: we keep your account, what you publish and what you do in the portal. Your store's managers, the mall and the Pasillo team can see it.

How your data reaches us. You are invited by the mall team, the Pasillo team or a manager of your store, who gives us your name, email and role. If the mall invites you from a list, it sometimes also gives us your WhatsApp number. The mall may send you the invitation by email or from its own WhatsApp.

Roles. A manager has the whole store portal. A cashier only has the register screen: they check and record promotion codes, and only see their own redemptions of the day.

Your account. We keep:

• your email, which is your username;
• your name;
• your password, only as a one-way code; nobody can read it;
• the language of your emails and whether you want the monthly report;
• the stores where you work and your role at each;
• when your account was created, when you joined each store and when you last signed in.

What you publish. We keep your store's listing (description, hours, WhatsApp, phone, website, Instagram and up to 6 photos), the promotions (title, conditions, code and dates) and the changes you ask the mall for, with your note. The listing and published deals are public: anyone can see them, they appear on the store's page and search engines such as Google may show them. Use a business WhatsApp and phone number, not a personal one. When you upload a photo, our server removes its hidden data, such as where it was taken.

What you do in the portal. We note who creates a promotion, who records each redemption, who changes the plan, who confirms the listing's details, who invites someone, and when you last looked at some sections of the portal.

Who sees it. Your store's managers see your name, email, role, when you joined and when you last signed in. The mall team and the Pasillo team do too, to provide support.

Emails. Managers get invitations, links to create or change a password, the mall's decisions on promotions and changes, reminders to check the listing, and the store's monthly report, which can be turned off in Account. Cashiers only get their invitation and their account's security emails. Everyone gets security emails when their password changes or they are signed out on every device.

WhatsApp. We only send WhatsApp notices to the store's number if the store agreed to get them. A manager agrees in the portal, or the mall marks it when the store told them so. From October 2026 we keep who ticked the box and when. They are short messages: approvals, rejections and reminders. They are sent through Meta's WhatsApp Cloud API. You can stop them by unticking the box in the portal.

Billing. The store's plan, its changes and each month's charges make up the statement that the mall downloads and bills the store for. Pasillo doesn't receive or keep card details.

6. If you are on a mall's team

In short: we keep your account and what you do in the mall portal.

Your account holds the same data as a store's (section 5). We also keep what you do in the mall portal:

• the mall's settings: plan prices, hours, holidays, sponsorship and the approval rule;
• the floor plans, map points and walkways you draw;
• the invitations you send, with the name, email, role and, if you give it, the WhatsApp number of each person invited;
• your decisions on promotions and changes, with the reason, how you resolved shopper reports and the stores you deleted.

If you give us other people's data, such as the people you invite, you must have permission to do so.

Your mall colleagues see your name, your email and when you last signed in. The Pasillo team does too.

7. If you are on the Pasillo team or are one of its sales agents

In short: we keep your account, what you do and the codes to sign in. If a sales agent talks to you at a mall, we keep your work contact details.

We keep your account, as in section 5, and what you do with the Pasillo staff tools, for example adding or deleting a mall or inviting someone.

To sign in, after your password we email you a 6-digit code. We keep it only as a one-way code and delete it once used; unused ones are deleted within a day. The team's owners get an email when someone joins or leaves the Pasillo team.

Sales agents. Pasillo's sales agents are independent people or companies who present Pasillo to malls. We keep an agent's account, as in section 5, with the same 6-digit sign-in code, the terms of their agreement (commission, goals and territory), the malls they signed and what they earn. In their portal an agent sees, for the malls they signed, the same statistics without names that the mall sees, the list of its stores and whether each one has a manager, but never the names, emails or phones of the people at the mall or its stores. An agent can also open a view-only copy of the mall portal of a mall they signed, to help it get set up and to see its results. It shows what the mall's team sees, without anything that identifies a person: no names, emails or phones of the mall's team, of store staff or of the people they invited, and no notes or reasons anyone wrote about a request. The agent can't change anything in it.

If you work at a mall a sales agent talks to. The agent registers your mall with us before it signs. We keep the mall's name and address, the name, title, work email and work phone of the people the agent talks to there, and the agent's notes of those talks (calls, meetings, demonstrations and emails, with their dates). We get them from the agent, who is asked to use work contact details only. Only that agent and the Pasillo team see them; other agents never do. We use them only to manage our relationship with your mall, and you can ask us to access, correct or delete them, or object to their use (section 15). If an agent asks us to remind your mall's team of the steps left to set up Pasillo, we send that email ourselves, in the agent's name; the agent doesn't get your email address.

8. What we use data for and on what legal basis

In short: we use each piece of data for one thing, and we tell you why we may do so.

• Showing you the guide, routes and deals. Data: the spot where you are, only to work out the route. Basis: providing the service you ask for. We keep no personal data for this.
• Statistics for the mall and the stores, and improving Pasillo. Data: the activity without names, with the random code. Basis: our legitimate interest in knowing what works in the guide and giving the mall and stores numbers without names.
• Handling problem reports. Data: reason and random code. Basis: our legitimate interest in keeping the guide correct.
• Shopper tips. Data: none that says who you are; the phrase, the store, the mall and the day, and reports with their reason. The request's IP address stays only in the server logs and their in-memory counts. Basis: our legitimate interest in letting shoppers share useful tips and in stopping abuse.
• Deal alerts. Data: email, language and stores you follow. Basis: your consent, confirmed from your email.
• Sign scanning. Data: the photo. Basis: your consent when you take the photo, after reading the app's notice.
• Store and mall accounts and portals. Data: your account details and what you publish. Basis: the relationship with your store or mall, which uses the service in your interest, and our legitimate interest in managing its accounts.
• Sales agents and the malls they talk to. Data: the agent's account, terms and earnings; the work contact details of mall staff and the agent's notes. Basis: the agreement with the agent, and our legitimate interest in offering Pasillo to malls and managing those relationships.
• WhatsApp notices to stores. Data: the store's WhatsApp number and the notice. Basis: the store's consent.
• The mall's monthly statement. Data: each store's plans and plan changes. Basis: the relationship with the mall and the stores, and the duty to keep records.
• Security and abuse prevention, including security emails and sign-in codes. Data: server logs, IP addresses and emails. Basis: our legitimate interest in protecting Pasillo and your data, and our duty of security.
• Complying with the law and defending rights. Data: whatever is necessary. Basis: legal obligation.

We rely on our legitimate interest only when your right to privacy doesn't outweigh it, and you can object by writing to us (section 15).

We don't sell data. We use no advertising networks. We don't make automated decisions that have legal effects on you.

If you gave us your consent, you can withdraw it at any time: unsubscribe from alerts, untick WhatsApp in the portal or stop using the scan. Withdrawing it doesn't affect what we did before.

9. Cookies and what is kept on your phone

In short: we use our own cookies only, and keep a few things in your browser. There are no advertising cookies.

• pasillo_lang cookie: the language you chose (Spanish or English). Lasts 1 year.
• pasillo_session cookie: your session, only if you sign in to a portal. The page can't read it. Lasts 30 days, or until you sign out.
• pasillo_preview cookie: only if you open a preview link the Pasillo team gave you for a mall that isn't published yet; it lets your browser see that mall. The page can't read it. Lasts 30 days, and stops working if the link is turned off.
• pasillo-session: the random code for the activity without names. Lasts a year at most (then the app makes a new one), or until you clear the site's data or turn on "Don't count my visits".
• pasillo-session-at: when that code was made, so the app knows when to replace it. Lasts as long as the code.
• pasillo-no-count: your "Don't count my visits" switch. Lasts until you turn it off or clear the site's data.
• pasillo-here-<mall>: where you are. Lasts until you change it or clear it.
• pasillo-saved-<mall>: the stores you save (up to 200). Lasts until you remove them or clear them.
• pasillo-recent-<mall>: your last 5 searches. Lasts until you clear them.
• pasillo-alerts-<mall>: the key to your deal alerts. Lasts until you unsubscribe or clear it.
• pasillo-tips-<mall>: how many tips you left today at that mall, at which stores and which ones you reported, for the daily limit. It never reaches us. Replaced the next day, or lasts until you clear the site's data.
• pasillo-hunts-<mall>: the treasure hunt steps you have done, the hunts you finished and the prize codes you got. Lasts until you clear the site's data.
• pasillo-bags-<mall>: the stores whose register QR code you scanned (their bags). Lasts until you clear the site's data.
• pasillo-passport-<mall>: your Mall passport: the zones, floors and stores whose QR codes you scanned, the days you scanned one (the last 60) and whether you met the mall's mascot. Lasts until you clear the site's data.
• pasillo-unlocked: the accessories your badges unlocked. Lasts until you clear the site's data.
• pasillo-character: the character you chose, its shirt color, accessory and personality. Lasts until you change it or clear the site's data.
• Copies for use without signal: the mall's pages, its public data, the routes you asked for, the floor plans, the photos, the app's code and the fonts. They are refreshed each time you open Pasillo with signal and last until you clear the site's data or we reset the copies.

The copies for use without signal never include the portals, the sign-in page or your deal alerts. In the portals we also keep in your browser the mall or store you picked, the paper size of the QR signs and the filters of the store list.

We use no advertising cookies and no third-party analytics tools. The fonts come from our own server.

On the pasillomall.com website. The website counts visits with Zentoko's own analytics. While you browse it, it keeps a random session ID and any campaign tags from the link you followed in your browser, only until you close the tab. It records the pages you view, the links and buttons you tap (their label and destination, never what you type), when a form is submitted, the website that sent you, your browser type and a one-way scrambled (hashed) version of your IP address. This data stays with our company; we don't share it with advertisers or analytics companies.

To delete everything, use your browser's option to clear the site data for app.pasillomall.com. If you delete the random code, the app creates a new one.

10. Who we share data with

In short: with the mall and the stores, only what is needed, and with the providers that help us run.

The mall and the stores. They see statistics from the activity without names: how many times a listing was opened, how many times shoppers scanned a store's register QR code, how many searches, which words were searched from at least 3 different phones and how many phones used the app. They see how many people follow deals, not who. For treasure hunt prizes, the store that gives the prize and the mall see how many codes were given and how many were used, never who got them. The mall sees problem reports and the account details of its mall, as explained above.

Each mall decides on its own what it does with what it downloads or sees in Pasillo, such as the statement and its stores' contacts, and is responsible for that use. Pasillo is responsible for everything else this policy describes.

Shopper tips. Published tips are seen by anyone who uses that mall's guide. A store's managers see the tips about it, and the mall team and the Pasillo team see all the mall's tips and their reports. Nobody sees who left or reported a tip, because we don't keep it.

Pasillo's sales agents. An agent sees, for the malls they signed, the statistics without names described above and each store's name and whether it has a manager, never anyone's personal data. The same goes for the view-only copy of the mall portal an agent can open for those malls (section 7): it shows how many people a store has, never who they are. An agent sees the contact details of the mall staff they registered themselves, as section 7 explains. Agents act under an agreement with us that requires them to keep that information confidential and use it only to work with Pasillo.

Our providers. They handle data on our behalf and under contracts that limit what they can do:

• Amazon Web Services (AWS): servers, database and photos. Holds everything we keep. In the United States (Northern Virginia).
• Amazon SES, part of AWS: sends our emails and scans them to block spam and viruses. Receives the email address, name and content of each message. In the United States (Northern Virginia).
• Anthropic, PBC: recognizes the store in a sign's photo. Receives the shrunk photo and the mall's store list. Stores in the United States and may process in other countries.
• Meta (WhatsApp Cloud API): sends WhatsApp notices to stores that agreed. Receives the store's WhatsApp number, the store's and mall's names, and the notice's text. In the United States and other countries where Meta operates.

WhatsApp's privacy rules apply to your WhatsApp account.

Other cases. We may share data if the law or a competent authority requires it, to protect the safety of people or of Pasillo, or if Pasillo passes to another company through a merger or a sale. In that case, we'll let you know.

11. Transfers outside Panama

In short: your data leaves Panama and is kept in the United States.

Pasillo is operated by a United States company and its servers are in the United States, with AWS, so your data leaves Panama. Some providers may process it in other countries (section 10). We do this because it is needed to provide the service you ask for and to keep our relationship with you, and under contracts with each provider that include data protection clauses. If you want to know more about those safeguards, write to us.

12. How long we keep data

In short: we keep each piece of data only while it is useful, and then we delete it.

An automatic job checks these periods every hour.

• A sign's photo: Pasillo doesn't keep it. Anthropic deletes it within 30 days, or keeps it up to 2 years if its safety systems flag it.
• Unconfirmed deal-alert email: deleted after 7 days.
• Confirmed deal-alert email, stores you follow and deals sent: until you unsubscribe, and then it is all deleted. If we send you no alert for 24 months, or the mall is hidden from shoppers for 90 days or deleted, we delete it too.
• Activity without names: deleted 25 months after it happened.
• Treasure hunts, their finish counts and their prize codes: deleted 13 months after the hunt ended.
• Problem reports: deleted 12 months after they are resolved or dismissed. Open ones stay until the mall handles them.
• Shopper tips and their reports: deleted 90 days after the day the tip was left, including those the store hid. If the mall or Pasillo removes a tip, or the store is deleted or its unit becomes vacant, they are deleted at once.
• Active accounts: while you have access.
• Accounts without access: 12 months after access ends, we erase the name, the email and the password, unless an invitation for you is still waiting. What the account did stays without your name, for the stores' and the mall's history. You can ask us to do it sooner (section 15): we also sign you out everywhere and remove your access, invitations and links.
• Links to create or change a password: each works once. Links you ask for with "Forgot your password?" expire in 1 hour; links the mall team sends you, in 3 days; invitations, in 14 days.
• Invitations and password links already expired or used: deleted 90 days after they expire or are used.
• Sign-in codes of the Pasillo team and sales agents: deleted once used, and any code a day after it was created.
• Store listings: while the store is on Pasillo.
• Photos a store removes or replaces: deleted from the server at once.
• Vacant units: the listing is hidden. If the unit stays vacant for 6 months, its photos, description and contacts are deleted.
• Deleted store: its photos, description and contacts are deleted at once. We keep its name and plan history with the billing records, for the 5 years below.
• Deleted mall: everything about the mall is deleted, including its deal alerts, reports and activity.
• Promotions, redemptions, plan and price changes, statements and deleted stores: deleted 5 years after their month ended, as billing records.
• Sales leads (section 7): deleted 24 months after they were last updated. If the mall signed with Pasillo, the contact details and the agent's notes are deleted then, and the rest is kept with the commission records.
• Server logs: up to 30 days.
• Automatic database backups: up to 35 days.
• What is on your phone: until you delete it.

When we delete data, it may remain in backups until they are replaced.

13. How we protect data

In short: we use encrypted connections and limit who sees what, but no system is perfect.

• Everything travels over encrypted connections (HTTPS).
• Passwords are kept only as a one-way code.
• After several failed sign-in attempts, you have to wait up to 15 minutes to try again.
• The Pasillo team signs in with a password of at least 12 characters and a code we email them.
• We email you if your password changes or you are signed out on every device.
• You can sign out on all your devices from Account. Changing your password ends your other sessions.
• Every request is checked against your account: a store only sees its own data, a cashier only the register screen and a mall only its own.
• Each email goes to one person only, so nobody sees who else got it.
• The data is on AWS servers in the United States, and only our technical team can reach it.

No system is completely secure. If a security breach puts your data at risk, we'll tell you and ANTAI within 72 hours of learning of it. We'll tell you what happened, which data was affected, what we did and what you can do. You can help: use a password you don't use on any other site and don't share your account.

14. Children and teenagers

In short: the guide and shopper tips ask for no personal data. Deal alerts and accounts are for adults.

Anyone can use the guide, because it asks for no personal data. That includes leaving a tip: it is picked from a list, without your own text, and we don't keep who left it, so teenagers can leave them too. Panamanian law requires a parent's or guardian's authorization to process minors' data. That is why email deal alerts and every account, including cashier accounts, are only for people aged 18 or over. If we learn that a minor gave us their email, we delete it. If you are a parent or guardian and believe your child gave us data, write to us.

15. Your rights and how to use them

In short: you can ask to see, correct or delete your data, or object to its use, and get a copy. Write to us.

Under Law 81 of 2019, you have the right to:

• Access: know what data of yours we have and how we use it.
• Rectification: correct wrong or incomplete data.
• Cancellation: ask us to delete your data.
• Opposition: ask us to stop using your data for a purpose, including where we rely on our legitimate interest.
• Portability: receive your data in a common format to take it to another service.

You can also withdraw your consent at any time, and object at any time to receiving advertising, such as deal alerts.

What you can do yourself.

• Unsubscribe from alerts from any email or from your alerts page, which shows your email and the stores you follow.
• Change your name, language and the monthly report in Account.
• Correct your store's listing in the portal, if you are a manager.
• Untick WhatsApp notices in the portal.
• Sign out on all your devices.
• Clear your recent searches in the app, or all the site's data in your browser.

How to ask for the rest. Write to info@pasillomall.com with the subject "Privacy". Tell us what you are asking for and the email of your account or alerts. To protect your data, we may ask you to confirm it's you, for example by replying from that email. We don't charge for handling these requests.

We'll answer within 10 business days of receiving your request. If you ask us to correct something, we'll correct it within 5 business days. If you ask us to delete your account, we delete it within 30 days, except what we must keep by law, such as billing records. If so, we'll tell you.

Activity without names carries neither your name nor your email, so we can't find it from them. You can delete the random code from your browser at any time, or stop the counting with "Don't count my visits" in the Info tab. We don't keep who left a tip either, so we can't find yours to show them to you or delete them: you can report them, and they are deleted on their own after 90 days.

If you are not satisfied. If we don't answer in time, or you disagree with our answer, you can go to Panama's National Authority for Transparency and Access to Information (ANTAI), at antai.gob.pa.

16. Changes to this policy

In short: we'll tell you before important changes.

We may change this policy as Pasillo changes. If a change is important, we'll notify people with an account or deal alerts by email, and in the app, at least 30 days before it takes effect. We won't use data we already have in a very different way without telling you first and, where the law requires it, asking for your consent. The change log is at the end of this page.

17. Contact

In short: write to info@pasillomall.com.

For privacy questions, requests or complaints, write to info@pasillomall.com. You can also write to us by post at Zentoko AI, LLC, 2625 Piedmont Road, Ste. 56-400, Atlanta, Georgia 30324, United States.

We haven't designated a data protection officer, which the law doesn't require of private companies. For anything about privacy, write to info@pasillomall.com.

18. Change log

In short: every version of this policy, newest first.