1. Status and scope
This is a preliminary draft subject to legal review. It references Colombia’s Law 1581 of 2012 and Decree 1074 of 2015 and does not replace legal advice. The English text is a convenience translation; the legally reviewed Spanish version will govern.
2. Controller identification
Controller: Zaxon SAS. Provisional email: zaxon@outlook.com. Phone: +57 321 810 0456.
Pending before production: tax identification number, place of business, physical address, and the area responsible for data protection.
3. Applicable principles
Processing must follow legality, purpose limitation, freedom, accuracy or quality, transparency, restricted access and circulation, security, and confidentiality.
4. Data categories
Identification, contact, role, organization, communication, commercial, contractual, supplier or candidate information, and technical interaction data may be processed once approved infrastructure exists.
Zaxon will not request sensitive data or children’s data through the general website. If an exceptional process requires such information, special rules and authorizations will apply.
5. Processing purposes
Handling inquiries; coordinating meetings; assessing PPA, SAP, or technology opportunities; preparing proposals; performing contractual relationships; managing suppliers and talent; providing support; meeting legal, accounting, and security duties; and sending commercial information only when applicable authorization exists.
6. Individual rights
Knowing, updating, and correcting data; requesting proof of authorization; learning how data is used; filing inquiries and claims; requesting deletion or withdrawing authorization when allowed; accessing data free of charge; and contacting Colombia’s Superintendence of Industry and Commerce after the applicable internal process.
7. Inquiries and claims
Requests may be sent to the provisional email, identifying the individual, describing the request, and providing the information needed to respond.
As a legal reference, inquiries should be answered within ten business days, extendable by five; claims within fifteen business days, extendable by eight. The final policy must define the operating procedure and responsible person.
8. Processors, transmission, and transfer
Zaxon may rely on hosting, email, messaging, collaboration, and technology providers acting as processors or independent controllers. The final policy must identify categories, locations, contracts, and safeguards before forms or analytics are enabled.
9. Security and retention
Reasonable access, confidentiality, backup, incident management, and deletion controls will apply. Data will be retained for the authorized purpose and applicable legal or contractual periods.
10. Term and changes
Draft date: August 8, 2026. The final version must state its effective date, database retention period, and the mechanism for communicating material changes.