⚠️ INFORMATIVE TRANSLATION — NOT BINDING. The Spanish version at
../../legal/ is the authoritative text and the only one that may be signed,
published or presented to a third party. This English rendering exists so that non-Spanish readers
can review the content; where the two differ, Spanish governs. Like its original, it is an
unreviewed working draft — nothing here is legal advice, and nothing is final until a Chilean
data-protection lawyer has signed off.
- Who we are and our roles. Softcrum SpA, RUT [], domiciled at []. In respect of the data of our platform users, site visitors and prospects, we act as controller. In respect of the data our clients (companies) upload or generate about THEIR end customers, we act as processor — that processing is governed by the DPA and by the respective client’s privacy policy; rights requests over that data should be directed to the corresponding company, without prejudice to our assistance.
- Data we process as controller. Account and profile (name, email, role), billing, platform usage (logs, telemetry), communications and support.
- Purposes and lawfulness. Provision of the service (contract performance); security, fraud prevention and legal compliance (legal obligation / legitimate interest); our own commercial communications (consent, revocable).
- Rights. Access, rectification, erasure, objection, portability and restriction under Ley 21.719. Channel: [privacidad@softcrum.com] — response within ≤30 days. Complaints may be filed with the Personal Data Protection Agency.
- Retention. Account: term + [24] months; billing: tax periods; security logs: [12] months.
- Recipients and transfers. Sub-processors and providers listed at [URL]; international transfers with guarantees as required by law.
- Security. Measures of the Security Annex (public summary in the trust center).
- DPO / contact: [Daniel __], [email].
- Changes: versioned, with notice.