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Privacy Policy

This policy explains which personal data we process when you visit this site or talk to us, what we use it for, who it is shared with, how long it is kept, and what you can require of us in that regard.

Last updated:

1. Who is responsible for your data

The data controller is Basis Network, domiciled at Ruta N, Medellín, Colombia. This policy is governed by Ley 1581 de 2012 (Colombian Law 1581 of 2012) and Decreto 1377 de 2013 (Decree 1377 of 2013) of the Republic of Colombia, which regulate the protection of personal data. If you write to us from the European Union, we also uphold the rights granted to you by the General Data Protection Regulation.

Any matter relating to your data is handled at: [email protected]

2. What data we process and where it comes from

This site has no user registration, sells nothing online and does not have a single form of its own. We only process personal data in three situations, and in all three it is you who decides to hand it over:

  • When you book a meeting. The calendar on the booking page is provided by HubSpot and collects your name, your email address, the time slot you choose and whatever you want to tell us in the text field. That data reaches our calendar so that we can hold the meeting.
  • When you write to us. If you send us an email, we process your address, your name if you include it and the content of the message, for as long as is needed to reply to you and to keep a record of the conversation.
  • When you browse, and only if you accept it. The analytics tool described in the Cookie Policy collects usage data tied to a pseudonymous identifier: pages viewed, clicks, scrolling and the replay of your interaction with the page. We do not know who you are, and we do not cross-reference that information with what you give us when you book a meeting. If you do not accept analytics cookies, none of this is collected.

What we do not collect

It is worth stating this in the negative too, because that marks out the real scope of everything above:

  • We do not ask for or store identity documents, bank details or payment methods.
  • We do not process sensitive data: health, ethnic origin, political opinions, religious beliefs, trade union membership, biometric data or sexual orientation. If you send them to us on your own initiative in an email, we will not use them for anything other than replying to you.
  • We do not buy databases and we do not enrich your profile with third-party information.
  • We do not run personalized advertising and we do not pass your data on to advertisers.
  • We do not engage in automated decision-making that produces legal effects concerning you.

3. What we use it for

Each piece of data has a specific purpose, and we do not use it for anything else without telling you first:

  • Handling your request: booking, preparing and holding the meeting you asked for, or replying to your email.
  • Continuing the commercial conversation: if we talked about a project, writing to you to pick it up again, sending you the proposal or answering later questions. You can ask us to stop doing so at any time.
  • Understanding how the site is used: spotting the parts where people get stuck and fixing them. This purpose, and only this one, depends on you accepting analytics cookies.
  • Complying with legal obligations: keeping proof of your authorization and responding to requests from the competent authorities when the law obliges us to.

4. On what authorization

In Colombia, processing personal data requires your prior, express and informed authorization. This is how we obtain it: by submitting the calendar form or writing to us, you authorize us to process your data in order to handle that request; and analytics cookies are enabled only when you press Accept in the notice, never before. Silence, inactivity or the mere fact of browsing do not count as authorization, and we do not treat them as such. For visitors from the European Union, the equivalent legal bases are your consent and the taking of steps at your request prior to entering into a contract.

5. Who it is shared with

We do not sell your data. We share it only with the providers we need in order to run the service, each one with a clearly bounded role:

HubSpot, Inc.

United States

Processor

Provides the booking calendar and stores the meeting details. It processes the data on our instructions and does not use it for its own purposes.

HubSpot Privacy Policy

Microsoft Corporation

United States

Independent controller

Provides Microsoft Clarity, the analytics tool. Microsoft also uses that data for its own purposes, advertising among them, and that is why it is only enabled with your consent. The details are in the Cookie Policy.

Microsoft Privacy Statement

5.1. International transfer

Both providers process the data in the United States, a country included by the Superintendencia de Industria y Comercio (the Colombian data protection authority) among those with an adequate level of data protection, so the transfer does not require any additional authorization under Colombian law. For visitors from the European Economic Area, both companies are certified under the EU-U.S. Data Privacy Framework and maintain standard contractual clauses with their European entities.

Beyond that, we would hand your data over only to a judicial or administrative authority that lawfully requires it from us, and only to the extent that the law obliges us to.

6. How long we keep it

The principle is simple: for as long as it serves the purpose you gave it to us for, and after that, for as long as the law requires us to be able to show that we acted properly.

6. How long we keep it
Data How long Why that period
Booking data and emails For as long as the relationship or the conversation lasts, and up to 5 years afterwards General limitation period for civil and commercial obligations in Colombia.
Proof of your authorization For as long as we process your data, plus 5 more years Article 8 of Decreto 1377 de 2013 obliges us to be able to prove that you authorized us.
Session recordings 30 days, or up to 9 months for a sample The periods are set by Microsoft and are not configurable. They are detailed in the Cookie Policy.
Heatmaps and analytics tags 9 months The periods are set by Microsoft and are not configurable.

Once the period is over, the data is deleted or anonymized in such a way that it can no longer be linked to you.

7. Your rights

As the data subject you can exercise the following, free of charge and with no requirement other than identifying yourself:

  • Know: find out what data of yours we hold and how we process it.
  • Update and rectify: correct any that is incomplete, inaccurate or out of date.
  • Delete: ask us to erase it, except where a legal or contractual duty obliges us to keep it.
  • Revoke the authorization: withdraw your consent at any time, without that affecting the lawfulness of the processing carried out before.
  • Request proof of the authorization: except in the cases where the law does not require it.
  • Lodge complaints: go to the Superintendencia de Industria y Comercio (the Colombian data protection authority) if you believe we have failed to comply. If you are in the European Union, you can also go to the supervisory authority in your country.

7.1. How to exercise them

Write to us stating which right you want to exercise and over which data. You do not need any special format and you do not have to justify your reasons. These are the deadlines Colombian law sets for us, and we meet them:

  • Queries: 10 business days from the moment we receive the request, extendable by a further 5 business days if we cannot manage it in time, telling you the reason beforehand.
  • Claims: 15 business days from the moment we receive the claim, extendable by a further 8 business days, telling you beforehand the reason and the date on which we will reply.

To revoke only your consent for analytics cookies you do not need to write to us: you can do it yourself from the Cookie preferences link in the footer, at any time.

8. Minors

This site is aimed at companies and at professionals evaluating technology infrastructure, not at minors, and we do not knowingly collect data from minors. If you believe a minor has given us data, write to us and we will delete it. This warning also matters for one specific reason: the analytics tool we use must not be deployed on sites aimed at people under 18, under the provider's own terms.

9. Security

The site is served entirely over an encrypted connection and is static: there is no database with your information behind these pages. The data you give us when you book a meeting or write to us lives in the systems of the providers described in section 5, and access from our side is limited to the people on the team who need it to handle your request. No security measure is foolproof, and we are not going to tell you otherwise; if an incident affecting your data occurs, we will tell you about it and report it to the competent authority where appropriate.

10. Changes to this Policy

We may update this policy if the data we process, the providers involved or the applicable legislation change. The version in force will always be available on this page, with the date of last update at the top. If the change substantially affects the purposes for which you authorized us, we will tell you before applying it and, where appropriate, we will ask you for authorization again instead of treating the previous one as still valid.

11. Contact

The data controller is Basis Network, domiciled at Ruta N, Medellín, Colombia. To exercise your rights, or for any query about this policy, write to us at:

[email protected]

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