Effective date: May 18, 2026

Privacy Policy

A transparent privacy notice for clients, website visitors, users, enterprise customers, and authorized data portability participants.

This Privacy Policy explains how NeuronaX S.A.S, a company officially registered and operating under the laws of the Republic of Colombia as a sociedad por acciones simplificada, collects, uses, stores, shares, transfers, deletes, and protects personal data when people visit our website, request services, contact us, use our digital products, or authorize third-party account connections and data portability integrations.

NeuronaX S.A.S is physically established in Colombia and is subject to the Colombian constitutional and statutory personal data protection regime, including Article 15 of the Colombian Constitution, Law 1581 of 2012, Decree 1377 of 2013, Decree 1074 of 2015, and guidance issued by the Colombian Superintendence of Industry and Commerce. Colombian law requires lawful, transparent, secure, purpose-limited and accountable processing of personal data. For international digital services, NeuronaX S.A.S also adopts GDPR-grade safeguards as an organizational, contractual, and technical compliance baseline.

This policy is drafted as a production privacy notice for clients, users, enterprise customers, visitors, integration partners, and people who authorize data portability or third-party account connections. It explains the territorial scope of our obligations, the purposes for which we process personal data, the rights available to data subjects, and the security controls we apply before, during, and after processing.

1. Controller and Contact Details

The data controller is NeuronaX S.A.S, a Colombian legal entity registered and operating under Colombian law. For privacy requests, data subject rights, portability questions, security notices, or complaints, contact us through the website contact form or by email at privacy@neuronax.com. If a different official privacy address is later published by NeuronaX S.A.S, that address will replace this contact point.

NeuronaX S.A.S designates its legal and administrative management function as the internal area responsible for receiving and coordinating personal data requests, including access, correction, deletion, revocation of authorization, complaints, and data portability-related requests.

2. Territorial Scope and Applicable Law

Colombian data protection law applies to personal data recorded in databases or files that are processed in Colombian territory by public or private entities. It also applies where a controller or processor not established in Colombia is subject to Colombian law by virtue of applicable rules, contracts, treaties, or international law. Because NeuronaX S.A.S is incorporated, physically present, and operationally managed in Colombia, Colombian law is our primary privacy and data governance framework.

Colombian law is not a copy of the GDPR, but it protects the same core legal interests: privacy, habeas data, transparency, authorization, security, restricted circulation, purpose limitation, data quality, data subject rights, and accountability before the competent authority. For that reason, NeuronaX S.A.S has chosen to operate with GDPR-grade safeguards as a matter of corporate policy for international services, cross-border digital products, cloud processing, and third-party API integrations.

GDPR may apply directly where a specific processing activity falls within its territorial scope, including where goods or services are offered to people in the European Economic Area or where behavior in the EEA is monitored. Where GDPR applies, NeuronaX S.A.S will apply the required GDPR legal basis, transparency, rights, transfer, security, processor, and accountability obligations. Where GDPR does not apply directly, we still use GDPR-aligned controls as a professional standard unless Colombian law, mandatory local law, or a stricter contractual obligation requires a different approach.

3. Personal Data We Process

  • Identity and contact data, such as name, company, role, email address, phone number, country, city, and language preference.
  • Commercial and service data, such as requested services, project requirements, quotations, support messages, meeting notes, contract information, billing references, and communications with NeuronaX S.A.S.
  • Website and technical data, such as IP address, browser, device identifiers, pages visited, timestamps, referral source, approximate location derived from network data, and security logs.
  • Marketing preference data, such as newsletter subscription status, consent records, campaign interactions, and opt-out choices.
  • Third-party account or portability data, only when a user authorizes a NeuronaX S.A.S application to connect with a third-party platform or API. This may include the categories made available by the platform within the approved scope and the user's authorization.

4. Third-Party Integrations and Data Portability

Some NeuronaX S.A.S services may allow a user to connect a third-party account, authorize a data portability request, or permit an API integration so that our application can receive data from an external platform. We request this access only for a clear user-facing purpose, only through the platform's authorized consent flow, and only within the scope approved by the user and the platform.

We do not obtain third-party platform data by scraping, password collection, impersonation, hidden automation, circumvention of access controls, or any method that bypasses the platform's technical and contractual rules. We do not claim that a platform sponsors, endorses, verifies, or guarantees NeuronaX S.A.S unless that platform expressly states so in writing.

Data received from a portability or third-party API integration is used only for the purpose presented to the user at authorization and in the corresponding product experience. We do not sell portability data, use it for unlawful profiling, make legal or similarly significant decisions without appropriate safeguards, or combine it with unrelated datasets in a way that conflicts with the user's authorization, platform terms, or applicable law.

5. Portability and API Data Controls

  • Authorization: we access portability or third-party API data only after the platform confirms user authorization and only within the approved scope.
  • Purpose limitation: we use portability data only to provide the specific feature, service, analysis, export, or workflow disclosed to the user.
  • No resale: we do not sell, rent, broker, or trade portability data.
  • No unauthorized enrichment: we do not use portability data to create unauthorized datasets, hidden profiles, or unrelated marketing audiences.
  • Security: OAuth access tokens, member tokens, API credentials, and exported data are handled as confidential security-sensitive data.
  • Deletion: when authorization is withdrawn, the service ends, data is no longer necessary, or a valid deletion request is received, we delete or anonymize portability data unless a narrow legal retention duty applies.
  • Human accountability: requests, incidents, and exceptional uses involving portability data are reviewed by responsible personnel rather than treated as unmanaged automated processing.
  • Platform-specific compliance: where an integration involves LinkedIn Member Data Portability APIs, NeuronaX S.A.S respects LinkedIn's eligibility rules, user consent flow, approved scopes, deletion expectations, API Terms of Use, additional portability terms, and developer documentation.

6. Legal Bases and Lawful Purposes

  • Consent, when you submit a form, subscribe to communications, authorize an API integration, or allow optional processing.
  • Contract performance or pre-contractual measures, when we prepare proposals, provide services, manage accounts, or respond to service requests.
  • Legitimate interests, when we secure our systems, prevent abuse, improve products, manage business records, or communicate with business contacts, provided those interests do not override individual rights.
  • Legal obligations, when we must retain accounting, tax, corporate, regulatory, or compliance records.
  • Vital or public-interest bases only if required by exceptional circumstances and permitted by applicable law.

7. How We Use Personal Data

  • To respond to inquiries, prepare quotations, provide consulting, software, marketing, legal-administrative, and technology services.
  • To operate, personalize, secure, debug, and improve our website, portals, applications, and business workflows.
  • To manage consent, authentication, authorization, audit trails, user preferences, and data subject requests.
  • To integrate authorized third-party services, account connections, portability workflows, or API-based services when requested by the user or required for the service.
  • To send service messages, administrative notices, security notices, and marketing communications where permitted by law and user preference.
  • To comply with Colombian law, international data protection obligations, contractual duties, and lawful requests from competent authorities.

8. Sensitive Data and Children

NeuronaX S.A.S does not intentionally request sensitive data unless it is strictly necessary, clearly identified, legally permitted, and subject to explicit authorization or another valid legal basis. Sensitive data may include biometric data, health data, political opinions, religious beliefs, union membership, sex life, or data that may create discrimination risks.

Our services are intended for business users and adults. We do not knowingly collect personal data from children through this website. If we learn that a child's data has been provided without proper authorization, we will delete it or apply the safeguards required by law.

9. Sharing and Processors

We share personal data only when necessary for the purposes described in this policy, when the data subject authorizes it, when a contract requires it, or when law permits or requires it. Recipients may include hosting providers, cloud infrastructure providers, analytics and security vendors, email and communications providers, payment or accounting providers, professional advisers, public authorities, and approved integration partners.

Where service providers process personal data for NeuronaX S.A.S, we require confidentiality, security, purpose limitation, and appropriate contractual safeguards. We do not sell personal data.

10. International Transfers and Transmissions

Because we use modern cloud, communication, and software providers, personal data may be processed outside Colombia. International transfers and transmissions are handled under Colombian law, applicable contractual obligations, and GDPR-style safeguards where relevant. These safeguards may include data processing agreements, confidentiality duties, vendor due diligence, transfer impact review when appropriate, access controls, encryption, audit logging, deletion commitments, and purpose limitation.

For portability or third-party API data, we will also follow the applicable platform terms, developer documentation, consent requirements, and any additional restrictions required by the platform or applicable data protection law.

11. Retention

We keep personal data only for as long as reasonably necessary for the purposes described in this policy, for the duration of the relationship with the user or client, for legal limitation periods, for accounting and tax obligations, for dispute resolution, and for security or audit needs.

Portability and third-party API data will be retained only while necessary for the authorized feature or service, unless a shorter retention period is required by the platform terms, the user withdraws authorization, the data is no longer needed, or deletion is legally required.

12. Security Measures

  • Access control, least-privilege permissions, authentication controls, and role-based administration.
  • Encryption in transit where supported, secure credential handling, secret management, and secure API authorization practices.
  • Logging, monitoring, backup procedures, vulnerability management, and incident response procedures appropriate to the risk.
  • Vendor review, contractual confidentiality obligations, and internal privacy-by-design practices.
  • Deletion, anonymization, or restriction procedures when data is no longer needed or when a valid request requires it.

13. Your Rights

Under Colombian law, data subjects may know, update, correct, and delete personal data; request proof of authorization; be informed about use; file complaints with the Colombian Superintendence of Industry and Commerce; revoke authorization; and request deletion when legally appropriate. Where GDPR or equivalent international standards apply, additional rights may include restriction, objection, portability, and rights relating to automated decision-making.

To exercise rights, contact NeuronaX S.A.S using the privacy contact above. We may need to verify your identity and request details needed to locate the relevant data. We will respond within the time periods required by applicable law. Withdrawal of consent does not affect processing performed lawfully before withdrawal and may limit our ability to provide certain services.

14. Cookies and Similar Technologies

Our website may use cookies, local storage, analytics, security tools, and similar technologies to operate the site, understand performance, protect against abuse, remember preferences, and improve services. Where required, optional cookies or marketing technologies will depend on consent or an equivalent lawful basis. Users can also manage cookies through browser settings.

15. Automated Processing and AI

NeuronaX S.A.S may use automation and artificial intelligence to support software development, analytics, client operations, security, marketing workflows, or service delivery. We do not use personal data to make automated decisions with legal or similarly significant effects without appropriate notice, human review, and safeguards required by applicable law.

Portability and third-party API data will not be used to train general-purpose AI models unless the user has been clearly informed, the use is lawful, compatible with the authorization, and permitted by applicable platform terms.

16. Regulatory Framework and Reference Standards

  • Republic of Colombia Constitution, Article 15, recognizing habeas data and the right to know, update, and rectify personal data.
  • Colombian Law 1581 of 2012, the general statutory personal data protection regime.
  • Colombian Decree 1377 of 2013 and Decree 1074 of 2015, including authorization, privacy notice, data subject rights, and controller or processor obligations.
  • Guidance and enforcement criteria of the Colombian Superintendence of Industry and Commerce as the Colombian data protection authority.
  • GDPR principles and safeguards where directly applicable or contractually adopted as an international best-practice baseline.
  • Applicable third-party API terms and developer documentation, including LinkedIn API Terms of Use, LinkedIn Additional Terms for the LinkedIn DMA Portability API Programs, LinkedIn developer documentation, LinkedIn Privacy Policy, and LinkedIn portability help resources when a LinkedIn integration is used.

17. Changes to This Policy

We may update this Privacy Policy to reflect changes in our services, legal obligations, security practices, API requirements, platform rules, or business operations. Material changes will be published on this website with a revised effective date and, where required, additional notice or consent.

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