1. Controller identity
The controller of personal data processing through the application is:
- Company name
- ADALMI SRL
- Tax ID (CUIT)
- 30-61560107-8
- Address
- Ruta 9 km 685, Toledo, Argentina
- Institutional website
- adalmi.com.ar
- Privacy email
- info@somosorbita.com
- Application
- «Gestión Contenedores» (com.gestioncontenedores.mobile)
2. Scope and audience
Gestión Contenedores is an internal, corporate application. It is not aimed at the general public nor offered to consumers as an open service. It is intended for:
- Administrative and logistics coordination staff of ADALMI SRL.
- Drivers assigned to container pickup, delivery, and replacement operations.
- Scrap dealers, suppliers, and destination holders formally invited by ADALMI SRL to operate on their containers.
Access is granted through accounts created and managed by the company. Credentials are personal, non-transferable, and must be protected by each user.
3. Personal data we collect
3.1. Account and authentication data
- First and last name.
- Email address (also used as the sign-in identifier).
- Assigned role: administrator, driver, or scrap dealer/supplier.
- Encrypted password and session tokens issued by the backend.
3.2. Operational data
- Internal identifiers of containers, trips, assignments, destinations, and movements.
- Addresses and coordinates of containers and destinations.
- Operational statuses (available, full, in transit, delivered, replacement requested, etc.).
- «Wants replacement» flag and full reports generated from the app.
3.3. Location data
- Precise device location during trips and dispatches.
- Background location while a trip is in progress, to record the route.
- Timestamp and operational reference associated with each location point.
3.4. Notifications
- Push notification tokens (Expo Push / FCM / APNs) for sending operational alerts.
- Notification content and reference to the event that triggered it.
3.5. Technical and usage data
- Access logs (API logs) with timestamp, endpoint, and outcome.
- Device identifiers required to deliver push notifications.
- App usage events required for support, auditing, and security.
We do not process financial data, health data, device contacts, photos, microphone, SMS, advertising, or social media account data. We do not profile for advertising purposes and we do not sell personal data.
4. Purposes of use
Data is used exclusively for the following purposes, all related to internal operations:
- Authentication and role-based access control.
- Management of containers, destinations, assignments, trips, and movements.
- Logistics coordination of pickups, deliveries, and replacements.
- Recording and validation of routes through location during trips.
- Sending operational and security notifications.
- Support, auditing, fraud prevention, and service improvement.
- Compliance with legal, accounting, tax, and rights-defense obligations.
5. Precise and background location
The application requests access to the device's precise location to record driver trip routes. The permission is used only during trips and is deactivated when the trip ends.
- Foreground (when-in-use): While the app is open and a trip is active.
- Background: During ongoing trips to keep the route trace, with no advertising uses.
Location data is not shared with third parties for advertising purposes and is not associated with advertising identifiers (Advertising ID / IDFA). It is only visible to authorized ADALMI SRL staff and stored in the proprietary backend.
Permission prompts shown by the operating system
You may revoke the location permission from your operating system settings at any time. Revocation may prevent trips from being completed.
6. Third-party services and SDKs
To operate, the app integrates the following services. Each one processes data according to its own policies.
| Provider | Data shared | Purpose |
|---|---|---|
| Google Maps Platform | Coordinates, addresses, geocoding queries, and routes. | Display maps, calculate routes, and resolve addresses. |
| Expo / EAS | Push tokens, device metadata. | Push notification delivery. |
| Apple Push Notification service (APNs) | Device push token. | Notification delivery on iOS. |
| Firebase Cloud Messaging (FCM) | Device push token. | Notification delivery on Android. |
| ADALMI SRL Backend | Operational data, account, location. | Service operation. |
ADALMI SRL does not sell personal data nor share it with third parties for advertising purposes. Any disclosure to third parties responds to an operational, technical, or legal need.
7. Data retention
Retention periods are as follows:
- Account data
- While the user is linked to the operation, and up to 2 additional years afterwards for auditing and rights-defense purposes.
- Trip, movement, and location history
- 5 years, in line with logistics auditing best practices.
- Technical and API logs
- Between 90 and 365 days, depending on their criticality.
- Push notification tokens
- Until revoked or replaced.
Once these periods have elapsed, the data is deleted or irreversibly anonymized, unless a legal rule or competent authority requires its retention for a longer period.
8. Information security
ADALMI SRL applies reasonable technical and organizational measures to protect data, including:
- Encrypted transmission via HTTPS/TLS.
- Passwords stored with robust hash algorithms on the backend.
- Role-based access control and non-transferable personal credentials.
- Secure token storage on the device (Secure Store / Keychain).
- Critical event logging and access monitoring.
Despite the measures adopted, no system is entirely infallible. In the event of a security incident affecting personal data, ADALMI SRL will assess the need to notify the affected individuals and, where appropriate, the enforcement authority.
9. International transfers
Some of the providers listed in section 6 may store or process data on servers located outside the Republic of Argentina (for example, in the United States or the European Union). These transfers are carried out based on the contractual clauses and guarantees offered by each provider, in line with Argentine Personal Data Protection Law 25.326 and its complementary regulations.
10. Rights of users
Users may exercise, to the extent permitted by applicable law, the following rights:
- Access: know what data we hold and how we process it.
- Rectification: correct inaccurate or outdated data.
- Update: keep the information provided up to date.
- Suppression / deletion: request account closure and removal of associated data (see section 11).
- Objection: object to processing that is not necessary for the labor or operational relationship.
- Consent revocation: when processing is based on consent.
Requests may be sent to info@somosorbita.com. If necessary, the user may file a complaint before the Agencia de Acceso a la Información Pública (AAIP), the enforcement authority of Law 25.326 in the Republic of Argentina.
11. Account and data deletion
Users may request the deletion of their account and associated data at any time, in two complementary ways:
- From the app: through the «Delete my account» option available within each user's profile (when applicable).
- From this website: by sending a request to info@somosorbita.com with the subject «Account deletion request», indicating the email associated with the account and, optionally, the company or plant they belong to.
Once the request is received, ADALMI SRL will:
- Verify the requester's identity.
- Deactivate the account within a maximum of 10 business days.
- Delete or anonymize the associated personal data, except for data that must be retained due to legal, accounting, tax, or rights-defense obligations.
- Issue a confirmation of the request handled.
Account deactivation does not equal definitive deletion: data will be retained only for the minimum period indispensable for the legitimate purposes indicated in section 7.
12. Use by minors
The application is intended exclusively for individuals over 18 years of age who are part of the ADALMI SRL operation or participate as invited suppliers. It is not designed for minors and does not intentionally collect data from minors.
13. Changes to this policy
ADALMI SRL may modify this policy to reflect operational, technical, or legal changes. Updated versions will be published at this same address, indicating the date of the last update. When changes are significant, users will be notified through the usual internal channels.
14. Contact and enforcement authority
For any inquiry related to this policy, write to:
- Privacy email
- info@somosorbita.com
- Controller
- ADALMI SRL — CUIT 30-61560107-8
- Address
- Ruta 9 km 685, Toledo, Argentina
- Institutional website
- adalmi.com.ar
Enforcement authority of Law 25.326 in the Republic of Argentina: Agencia de Acceso a la Información Pública (AAIP) — argentina.gob.ar/aaip.
This document is provided for informational purposes. The application of specific rules may vary by case. For complex situations, specialized legal advice is recommended.