Privacy policy and personal data processing

At Clouwe we look after the data of people who write to us and visit this site. This policy explains what data we collect, what we use it for, who we share it with, how we use cookies and measurement tools, and how you can exercise your rights. It is issued under Colombian Law 1581 of 2012, Decree 1377 of 2013 (compiled in Decree 1074 of 2015) and other Colombian data protection rules, and also addresses the EU General Data Protection Regulation (GDPR) for visitors from there.

1. Data controller

• Controller:Clouwe
• Address: Bucaramanga, Santander, Colombia
• Email for personal data matters: [email protected]
• Phone / WhatsApp: +57 316 734 8868
• Website: https://clouwe.com

2. What data we collect

What you give us:

• In the contact and plan sign-up forms: name, email, company, phone or WhatsApp and country, preferred contact method, chosen plan and billing option, and the answers you write about your business and project.
• If you do not finish a plan form, we keep what you entered up to the point you moved to the second step, and we may contact you to help you finish.
• Whatever you tell us over WhatsApp, email or phone when we talk to you.

What is collected as you browse:

• Where your visit came from (UTM parameters, ad click ID, referring page and first page viewed) and your time zone. We store it in your browser to attach it to your message if you write to us.
• IP address, browser and device type, and pages viewed, recorded for security, to limit abusive submissions and, with your consent where required, to measure site usage.

We do not ask for sensitive data (health, racial origin, political or religious views, biometric data) or data of children or teenagers. If you send it on your own, we will delete it. This site is aimed at businesses and adults.

3. What we use it for (purposes)

• Answer your inquiries and prepare a quote or proposal.
• Contract, deliver and bill the services you request, and provide support.
• Follow up commercially on what you asked for (including a form you left unfinished) and inform you of news related to your project.
• Keep the site secure and prevent fraud and automated submissions.
• Measure how the site is used and which channels bring visits, to improve it, and measure the performance of our advertising (see section 6).
• Meet legal, accounting and tax obligations.

We do not sell your data or use it for purposes other than those described here.

4. Authorization and legal basis

We process your data with your prior, express and informed authorization, which you give by submitting a form or writing to us, and when it is necessary to perform a contract or handle your request. For cookies and measurement and advertising tools, the basis is your consent (where the law requires it) or our legitimate interest in understanding and improving the site. For visitors from the European Economic Area, the United Kingdom and Switzerland, the bases in Article 6 GDPR also apply. You can withdraw your authorization at any time by writing to us.

5. Who we share it with

We share data only with providers that help us operate, under agreements that require them to protect it, and with authorities when the law requires it:

• Transactional email service (how your messages reach us).
• Hosting, network and security providers.
• Google (Google Tag Manager and Google Analytics) and Meta (Meta Pixel), for measurement and advertising, as described in section 6.
• Customer management and messaging tools we use to serve you.
• Accounting, legal and financial advisers, when necessary.

Some of these providers are outside Colombia, for example in the United States. In those cases the international transfer or transmission is made to providers that offer adequate levels of protection or with the safeguards required by law.

6. Cookies, tags and measurement tools

A cookie is a small file the site stores in your browser. We also use similar technologies (local storage and pixels). These are the categories:

Google Tag Manager is a tag manager: it loads the other tools without changing the site. Google Analytics 4 measures traffic and events (for example, a form submission) with pseudonymous identifiers; retention periods are set in the Analytics account. TheMeta Pixel sends browsing and conversion events to Meta to measure and optimize campaigns on Facebook and Instagram. Google and Meta may act as independent controllers of the data they receive; see their policies atpolicies.google.com/privacyandfacebook.com/privacy/policy.

Your consent. For visitors from the European Economic Area, the United Kingdom and Switzerland, analytics and advertising cookies stay off until you accept them. For everyone else, we use them with the information and notice in this policy, and you can refuse them at any time. To control cookies:

• Change your browser's cookie settings (block or delete cookies).
• Install theGoogle Analytics opt-out add-on.
• Manage the ads you see inMeta's ad preferences.
• Write to us and we will stop using your data for those purposes.

If you block necessary cookies, some parts of the site may not work well. When we add or remove tools, we will update this section.

7. How long we keep it

• Inquiries and quotes that did not become a contract: up to 24 months from last contact.
• Clients: for the length of the relationship and afterwards for as long as accounting and tax rules require and legal claims can still be brought.
• Unfinished forms: up to 6 months.
• Measurement data: according to the retention set in each tool (by default, up to 14 months in Google Analytics).

After that, we delete or anonymize it.

8. Your rights as a data subject

Under Article 8 of Colombian Law 1581 of 2012, you may:

• Know, update and correct your data.
• Request proof of the authorization you gave us.
• Be told how we have used your data.
• File complaints with the Superintendence of Industry and Commerce (SIC) for violations of the law.
• Revoke your authorization and request deletion of your data when legal principles and safeguards are not respected and there is no legal or contractual duty to keep it.
• Access your personal data free of charge.

If you visit from the European Economic Area, the United Kingdom or Switzerland, you also have the right to portability, restriction and objection to processing, and to complain to your data protection authority.

9. How to exercise your rights

Write to [email protected] with your name, a way to reach you, what you want to do and, if applicable, the data you want corrected or deleted. We may ask you to confirm your identity. We answer inquiries within 10 business days; complaints to correct, update or delete data within 15business days (extendable as the law allows, and we will tell you). If you are not satisfied with the answer, you can go to the Superintendence of Industry and Commerce (www.sic.gov.co).

10. Security

We apply reasonable technical and organizational measures to protect your data: encrypted connections (HTTPS), restricted access for those who need it, and vendor review. No system is infallible; if an incident affects you, we will tell you and the authority when the law requires it.

11. Data we process on behalf of our clients

When we provide services such as Agentia (AI assistant), automations or custom software, we may process data of our clients' customers. In that case our client is the controller and Clouwe acts as processor: we use that data only to provide the service and under their instructions, under the terms of the contract.

12. Links to other sites

The site may link to third-party pages (for example, social networks or WhatsApp). We do not control their policies; we recommend reading them.

13. Changes to this policy

We may update this policy, for example when adding a new measurement tool. We will publish the current version on this page with its update date; if the change is significant, we will tell you through an effective channel.