> ## Documentation Index
> Fetch the complete documentation index at: https://internal.softcrum.com/llms.txt
> Use this file to discover all available pages before exploring further.

# Softcrum Privacy Policy — DRAFT v0.1

> 1. 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.

> ⚠️ **INFORMATIVE TRANSLATION — NOT BINDING.** The Spanish version at
> [`../../legal/`](/legal/overview) 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.

1. **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.
2. **Data we process as controller.** Account and profile (name, email, role), billing, platform
   usage (logs, telemetry), communications and support.
3. **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).
4. **Rights.** Access, rectification, erasure, objection, portability and restriction under Ley
   21.719. Channel: \[[privacidad@softcrum.com](mailto:privacidad@softcrum.com)] — response within ≤30 days. Complaints may be filed
   with the Personal Data Protection Agency.
5. **Retention.** Account: term + \[24] months; billing: tax periods; security logs: \[12] months.
6. **Recipients and transfers.** Sub-processors and providers listed at \[URL]; international
   transfers with guarantees as required by law.
7. **Security.** Measures of the Security Annex (public summary in the trust center).
8. **DPO / contact:** \[Daniel \_\_], \[email].
9. **Changes:** versioned, with notice.