Privacy Policy

Version 3 · Verksam 2026-10-09

Vad ändrades i denna version

Navigation and traffic (3, 4C.1, 4C.4): "Help improve traffic" is offered in every Calisto navigator — Calisto Local and the directions inside other Calisto apps such as Dispatch — always as the person's own choice on their own account; a business never sees or sets it.

This Privacy Policy explains how Calisto collects, uses, stores, and protects personal data on the Calisto Pro website at pro.calistoco.com and the Calisto Pro applications (together, the "Site").

1. Who We Are

1.1. Calisto LLC is the controller of personal data about visitors and account holders.

1.2. North Coast Vacations, Inc., RNC 132-08055-6, Pedro Clisante 73, Sosúa, Puerto Plata, Dominican Republic, is the controller of personal data about subscribers. When you activate Calisto Pay and subscribe, your account data is transferred from Calisto LLC to North Coast Vacations, Inc.

1.3. "Calisto" means the controller of your data under this section.

2. Scope

2.1. This policy applies to personal data Calisto collects about you through the Site.

2.2. When a subscriber uses the Site to handle personal data about its own customers, staff, or contacts, the subscriber is the controller of that data and Calisto processes it under the Data Processing Agreement. Questions about that data go to the subscriber.

3. What Personal Data We Collect

Identification and contact information: name, email address, phone number
Account information: login credentials, account settings, workspace membership
Identity verification data (subscribers): government-issued identity document and a liveness check, collected when you activate Calisto Pay
Compliance screening results (subscribers): results of screening against sanctions lists, politically exposed persons databases, and adverse media
Transaction and billing data (subscribers): Calisto Pay funding transactions, balance, charges, billing statements, and the tax details you enter
Support data: the content of support tickets and related correspondence
Technical and usage data: IP address, device type, operating system, browser, log files, session identifiers, and page performance measurements
Referral data: the referral code of the link you arrived through
Marketing preferences: whether you opted out of marketing emails or in-app marketing messages
Navigation positions (only if you turn on "Help improve traffic"): while you navigate with a Calisto navigator (Calisto Local, or the directions inside another Calisto app such as Calisto Dispatch), your device's positions and the times they were taken, under a random trip identifier

4. How We Use Your Data

To provide and manage your account and the Site
To verify your identity and screen your account before activating Calisto Pay
To process Calisto Pay funding, charges, and billing
To provide customer support and resolve disputes
To secure the Site and prevent fraud and unauthorized access
To measure and improve the performance of the Site
To credit referrals
To work out road speeds and traffic for Calisto's own directions, when you turn on "Help improve traffic"
To tell subscribers about Calisto products related to the ones they use
To comply with legal and regulatory obligations

4A. Automated Decisions

Calisto decides automatically whether to activate Calisto Pay, based on whether your identity document and liveness check are verified and whether compliance screening returns a match. You can request that a person review the decision by opening a ticket at https://pro.calistoco.com/support/tickets.

4B. Marketing

4B.1. Calisto sends marketing emails only to subscribers, and only about Calisto products related to the ones they use. You can opt out when you subscribe and through the unsubscribe link in each marketing email.

4B.2. Calisto shows messages about Calisto products inside the Site. You can switch them off in your account.

4C. Navigation and Traffic

4C.1. When you navigate with a Calisto navigator — Calisto Local, or the directions inside another Calisto app such as Calisto Dispatch — Calisto works out your route on its own servers. If you turn on "Help improve traffic", your device also sends Calisto its positions during the trip, so Calisto can measure how fast traffic moves on each road. This is off unless you turn it on, Calisto relies on your consent for it, and you can turn it off at any time with the same switch. Calisto records when you gave and withdrew your consent.

4C.2. What is sent carries no account: positions and their times under a random trip identifier that your device changes every 15 minutes. The first and last 500 metres of every trip are never sent, so the places your trips start and end stay on your device.

4C.3. Positions are deleted as soon as they are matched to roads. Calisto keeps only the speed of each trip on each road, for one hour, and anonymous averages per road and time of the week. A road's speed is used only when at least three separate trips drove it.

4C.4. "Help improve traffic" is always your own choice, on your own account, wherever you navigate. If you navigate inside an app a business uses (for example to reach a job in Calisto Dispatch), the business does not see whether you turned it on and cannot turn it on for you. Locations a business shares about its own staff or vehicles (for example in Calisto Dispatch) are that business's data, processed under the Data Processing Agreement. They are never used for traffic.

5. How We Collect Your Data

From you: when you create an account, complete identity verification, fund Calisto Pay, or contact support
Automatically: through cookies and similar technologies, as described in the Cookie Policy
From service providers: identity verification results and compliance screening results

6. Sharing Personal Data

Calisto shares personal data with:

Calisto group companies: between Calisto LLC and North Coast Vacations, Inc. as described in §1.2, and with Calisto Philippines for back-office and help-desk services
Service providers: hosting, identity verification, compliance screening, payment processing, and communication services, each bound by a written contract
Authorities: where the law requires it
A successor: if Calisto undergoes a merger or asset sale

7. Where Your Data Is Stored

Personal data is stored in the European Union, primarily in Germany, France, and Sweden, and is accessed from the Dominican Republic and the Philippines.

8. Data Security

Calisto protects personal data with:

TLS encryption in transit and encryption at rest
Firewalls and network segmentation
Role-based access, least-privilege principles, and multi-factor authentication for staff and contractor access
Staff and contractor confidentiality agreements
Regular vulnerability scanning and patching

9. Data Retention

Calisto keeps personal data for as long as your account is active and, after that, for as long as the law requires it to be kept. After that period, the data is deleted or anonymized.

10. Cookies

The Cookie Policy explains how the Site uses cookies and similar technologies.

11. Children's Privacy

The Site is not directed to individuals under the age of 16.

12. Your Rights

12.1. Your rights depend on the data protection law that applies to you. Section 15 sets out those rights by jurisdiction.

12.2. To exercise your rights, send your request by mail to North Coast Vacations, Inc., Pedro Clisante 73, Sosúa, Puerto Plata, Dominican Republic, or open a ticket at https://pro.calistoco.com/support/tickets (sign-in required).

13. Policy Updates

Calisto publishes changes to this policy on this page with an updated "Last Updated" date.

14. Contact

Support: https://pro.calistoco.com/support/tickets

15. Jurisdiction-Specific Terms

15.1. European Union, European Economic Area, United Kingdom, and Switzerland

This section applies where the GDPR, the UK GDPR, or the Swiss Federal Act on Data Protection applies to your personal data.

EU representative: LUNA LIMPIEZAS NORTH COAST SL, registration number B72574890, C/ Zurbano 45 1º, 28010 Madrid, Spain.
Legal bases:
- Account, Site, Calisto Pay, billing, and support — performance of a contract
- Identity verification (identity document and liveness check) — your explicit consent
- Compliance screening, tax, and accounting records — compliance with legal obligations and Calisto's legitimate interests in preventing fraud and financial crime
- Security, fraud prevention, performance measurement, and referrals — Calisto's legitimate interests
- Marketing emails to subscribers and in-app marketing messages — Calisto's legitimate interests
Your rights: access, rectification, erasure, restriction of processing, data portability, objection to processing based on legitimate interests, and withdrawal of consent at any time without affecting processing before withdrawal.
Complaints: you can lodge a complaint with the data protection authority of your country of residence.
Transfers: personal data accessed from the Dominican Republic and the Philippines is transferred under the standard contractual clauses adopted by the European Commission (Decision (EU) 2021/914) and, for the United Kingdom, the UK International Data Transfer Addendum.
Required data: the data in §3 is required to provide the Site and Calisto Pay. Without it, Calisto cannot open your account or activate Calisto Pay.

15.2. Brazil

This section applies where the LGPD applies to your personal data.

Your rights: confirmation of processing, access, correction, anonymization, blocking or deletion of unnecessary or excessive data, portability, information about the entities your data is shared with, and revocation of consent.
Complaints: you can lodge a complaint with the Autoridade Nacional de Proteção de Dados (ANPD).

15.3. United States

This section applies where the law of a US state applies to your personal data.

Reviewing and correcting your data: request it as described in §12.2.
Do Not Track: the Site does not respond to browser Do Not Track signals.

15.4. Dominican Republic

This section applies where Law 172-13 applies to your personal data.

Your rights: access, rectification, updating, and deletion of your personal data.