Privacy Policy & Personal Data Treatment

1. Identification of the Data Controller

The data controller responsible for the processing of your personal data is CINNDEV S.A.S., a commercial entity legally established under the laws of the Republic of Colombia, Tax ID (NIT) 900899232-5, with principal domicile in Bogotá D.C., Colombia.

• Corporate Name: CINNDEV S.A.S.
• Tax ID (NIT): 900899232-5
• Registered Address & Headquarters: Calle 93 #11-13, El Chicó, Bogotá D.C., Colombia.
• Official Data Protection Email: [email protected]
• Official Phone & WhatsApp Channel: (+57) 302 459 9073
• Web Platform: https://cinndev.co/

2. Regulatory Framework & Geographic Scope

This Privacy and Data Protection Policy is governed by:

• In Colombia: Article 15 of the Political Constitution of Colombia, Statutory Law 1581 of 2012, Regulatory Decree 1377 of 2013, and external circulars issued by the Superintendence of Industry and Commerce (SIC).
• International Standards: For clients, prospective partners, and users located in the European Union, the United States, Mexico, and global markets, we voluntarily adopt the principles of lawfulness, fairness, transparency, data minimization, and accountability established under the General Data Protection Regulation (GDPR - EU 2016/679) and the California Consumer Privacy Act (CCPA).

3. Categories of Personal Data Collected

CINNDEV S.A.S. collects only strictly necessary and relevant information required to fulfill our engineering, contractual, and communication objectives:

• Business Contact & Representation Data: Full name, corporate email address, direct phone/mobile number, company name, managerial role, country, city, and industry vertical.
• Project & Technical Scoping Data: Target architecture requirements, e-commerce scale, marketplace features, or mobile app specifications voluntarily provided during discovery calls, quotation requests, or contact forms.
• Telemetry & Anonymous Navigation Data: Masked IP address, browser type, operating system, pages visited, dwell time, and performance analytics gathered via Google Analytics 4 with IP anonymization enabled.

4. Purposes of Data Processing

Personal data collected by CINNDEV S.A.S. is utilized to:

1. Structure, estimate, and present software engineering proposals, architectural blueprints, delivery schedules, and budgets.
2. Coordinate and conduct technical discovery sessions, scoping workshops, and consultations via Google Meet or WhatsApp.
3. Execute, manage, and conclude engineering contracts, Non-Disclosure Agreements (NDAs), and Service Level Agreements (SLAs).
4. Issue legal electronic tax invoices complying with applicable tax legislation (DIAN Colombia or international invoicing protocols).
5. Send mission-critical security advisories, infrastructure incident updates, or specialized engineering insights from Cinndev Radar (with a direct opt-out mechanism in each email).
6. Ensure cyber defense of our infrastructure, prevent DDoS attacks, mitigate fraud, and safeguard network perimeters.

5. Data Subject Rights (Habeas Data & GDPR)

In accordance with Statutory Law 1581 of 2012 and international GDPR guidelines, data subjects possess the right to:

• Access & Consultation: Request free confirmation of what personal data resides in CINNDEV S.A.S. systems.
• Rectification & Updating: Request immediate correction of inaccurate, incomplete, or outdated data.
• Erasure (Right to Be Forgotten): Request deletion of personal records when legal grounds or contractual necessity have elapsed.
• Revocation of Consent: Withdraw authorization for data processing at any point without retroactive penalties.
• Regulatory Complaints: Submit formal complaints to the competent Data Protection Authority (SIC Colombia or corresponding local supervisory bodies).

6. Procedure for Exercising Data Rights

Data subjects or their verified legal representatives may exercise access, modification, or erasure rights by sending a communication to our official email:

7. Information Security, Encryption & Cloud Infrastructure

CINNDEV S.A.S. implements stringent technical, organizational, and physical security measures to prevent data tampering, loss, or unauthorized access:

• End-to-End Encryption: All traffic across our platforms is secured using modern TLS 1.3 / HTTPS encryption with high-assurance certificates.
• Enterprise Cloud Datacenters: Cloud infrastructure and databases are hosted in audited datacenters holding international SOC 2 Type II, ISO/IEC 27001, and PCI-DSS certifications (Amazon Web Services, Google Cloud Platform, and Cloudflare).
• Principle of Least Privilege: Only engineers assigned under strict Non-Disclosure Agreements (NDAs) possess access, safeguarded by two-factor authentication (2FA) and audit trails.

8. Cross-Border Data Transmission

Due to the international architecture of modern cloud computing, data subjects acknowledge and consent to the transmission of technical information across secure cloud nodes located in North America and Europe, each maintaining rigorous data protection adequacy. CINNDEV S.A.S. NEVER sells, rents, or commercializes personal client records to any third party for marketing or advertising purposes.

9. Policy Validity & Data Retention

This policy is effective as of its official publication at https://cinndev.co/. Personal data will be retained solely for the period necessary to deliver contracted services, maintain ongoing business relationships, or satisfy statutory tax and commercial retention obligations.

Questions regarding your data protection or Non-Disclosure Agreements (NDA)?

Our legal and security engineering team is available to execute bilateral Non-Disclosure Agreements (NDAs) prior to scoping any project.