Data Processing Policy

Last updated: 9/6/2026

This Policy sets out how Capital M Intellectual Property S.A.S. ("Capital M", "we"), as Data Controller, processes personal data in Colombia, in accordance with Law 1581 of 2012, Decree 1377 of 2013, and guidance from the Superintendence of Industry and Commerce (SIC).

1. Identification of the Data Controller

2. Scope

This Policy applies to personal data collected through our website, forms, communications, contracting and service execution, billing, and any other lawful sources.

3. Purposes of Processing

4. Categories of Data

5. Lawful Bases

Authorization by the data subject, performance of a contract, and compliance with legal duties under Colombian law.

6. Rights of the Data Subject (ARCO)

You may exercise the rights of Access, Rectification, Update, Deletion and Revocation of authorization.

7. Processors and Transfers

We may use service providers (hosting, communications, storage) under confidentiality and data processing agreements. International transfers will observe adequate safeguards.

8. Data Retention

We retain personal data for the time necessary to fulfill the purposes or as required by law and professional duties. Once the purposes are met, data will be deleted or anonymized, unless there is a legal or contractual duty to retain it.

9. Security Measures

We implement technical, administrative, and organizational measures to protect personal data against unauthorized or unlawful processing, loss, alteration, or disclosure.

10. Minors

Our services are directed to adults. We do not intentionally process personal data of minors without proper authorization and legal basis.

11. Policy Updates

We may update this Policy at any time. The current version and effective date will be published on this page.

12. Contact

To exercise your rights or ask questions about this Policy, contact: info@capitaleme.com.