Data Treatment Policy
Last updated: July 31, 2026
This personal data treatment policy (the "Policy") governs the collection, storage, use, administration, transfer, transmission, and protection of the information that ACCENDO S.A.S. receives across its five platforms:
- accendo.com.co, the company's public commercial website (contact form, partner form, diagnostic questionnaire, and WhatsApp contact).
- hub.accendo.com.co (Accendo Hub), the company's internal platform, used only by the Accendo team, where customer and prospect contact details, submissions made on accendo.com.co, and the content of WhatsApp messages are stored in order to attend requests and measure service quality.
- trackvy.com, the commercial website for the Trackvy product.
- cloud.trackvy.com, the main Trackvy application, the SaaS platform clients log into.
- The Trackvy applications distributed through app stores and installed on devices: Trackvy Mobile, Trackvy Edge, and Trackvy Desktop.
Where a provision applies to only some of these platforms, the Policy says so explicitly, so that anyone reviewing a specific app or site can find its own clauses. This Policy has been drafted in accordance with Ley Estatutaria 1581 de 2012, Decreto 1377 de 2013, and other applicable Colombian regulations.
Identification of the Data Controller
Accendo S.A.S is the data controller for the personal data collected across the five platforms described in the scope of this Policy: the responsible entity is the same across all of them. The legal entity responsible for the data voluntarily obtained from and provided by data subjects, and for the databases in which that information is held, is ACCENDO S.A.S. (the "Company"), identified with NIT 900834127-9.
Address: Barranquilla, Calle 69 # 50 - 07 (080002)
Contact email: [email protected].
Information Collected
The information collected varies depending on which platform the data subject interacts with.
Within the commercial and contractual relationship of clients with the main Trackvy application (cloud.trackvy.com) and with the Trackvy Mobile, Trackvy Edge, and Trackvy Desktop applications, the information collected from data subjects is limited to what is necessary to carry out that relationship:
- First and last names of the legal representative, employees, and/or account managers.
- Email address.
- Bank account of the data subjects.
When you interact with accendo.com.co or Accendo Hub, for example by filling out a form or writing to us on WhatsApp, the information collected is:
- Name.
- Company.
- Email address.
- Phone number.
- Role.
- The content of the message or of the diagnostic wizard's answers.
The Company does not store the personal data held in the databases that data subjects themselves administer, and only uses the information hosted there according to the instructions they provide.
Trackvy applications: device permissions, third-party services, and children's privacy
This section applies only to cloud.trackvy.com and to the Trackvy Mobile, Trackvy Edge, and Trackvy Desktop applications.
The Trackvy applications may request device permissions, such as camera, location, or storage, necessary for the asset identification and tracking features they offer. These permissions are only activated when the user expressly authorizes them through the operating system, and their scope is limited to the app's functionality.
Trackvy Mobile uses Google Play Services and may use other third-party services necessary for its operation, such as push notifications. You can review Google Play Services' privacy policy at https://www.google.com/policies/privacy/.
The Trackvy applications are intended exclusively for enterprise customers with a valid Trackvy subscription, and are not authorized for use by anyone under 13 years of age. The Company does not knowingly collect personal information from individuals under 13. If you become aware that a child under 13 has provided us with personal information, please contact us at [email protected] so we can delete it.
Forms and messages
This section applies to accendo.com.co and Accendo Hub.
When you fill out a form on this site or write to us on WhatsApp, Accendo S.A.S receives and stores the content of your message, the contact details you provide, and the date and time it arrived. We use that information to handle your request and to measure our response times. We keep it on our internal platform, we do not share it with third parties for advertising purposes, and we do not use it for mass mailings. You may request access to, correction of, or deletion of your information through the channels indicated in this policy.
Purpose and Treatment of the Personal Data Collected
The purpose of storing personal data and the other information mentioned above is to support the relationship between data subjects and the Company, as well as the services provided under that relationship. The personal data collected serves the following purposes:
- Carrying out the Company's corporate purpose.
- Fulfilling the duties and obligations arising from the contractual relationship entered into between data subjects and the Company.
- Auditing, controlling, and tracking payments made for the services provided to data subjects.
- Establishing a communication channel to share news, procedures, policies, and steps in delivering the services offered to data subjects.
- Auditing, controlling, and processing the accounting record of the obligations and transactions entered into with data subjects.
- Complying with the duties and obligations of the tax and legal system, in accordance with the directives, laws, and instructions of the national government and its regulatory bodies.
- Providing data subjects' personal data to entities involved in resolving disputes between the parties, such as insurance companies or competent courts, and responding to requests made by authorities through the corresponding legal procedures.
- Providing competent administrative authorities with the information requested through the corresponding mechanisms.
- Handling requests received through accendo.com.co and WhatsApp, and measuring our response times, through Accendo Hub.
- Any other activity necessary for the effective performance of the commercial relationship between data subjects and the Company.
Confidentiality of the Information Collected
Personal data provided to the Company will be handled solely and exclusively as described in this Policy. The Company will take the measures within its reach to protect the confidentiality and privacy of the information provided. Notwithstanding the foregoing, such information may be requested by order of any competent administrative or judicial authority, through the legal procedures designed for that purpose. The Company will not be liable for information disclosed, intercepted, or accessed by third parties as a result of such procedures.
Protection and Security of the Information
The information provided by data subjects is of great importance to the Company. For this reason, we maintain information security standards whose primary objective is to safeguard and preserve its integrity, confidentiality, and availability, regardless of the medium or format in which it is stored, its temporary or permanent location, or the way in which it is transmitted.
The Company applies security practices recognized in the industry, including: transmission and storage of sensitive information through secure mechanisms such as encryption and secure protocols; hardening of technology components; restricting access to information to authorized personnel only; information backups; and secure software development practices, among others.
Changes to the Privacy Policies
The Company reserves the right to modify this Policy at any time. Data subjects may request a copy of the policies mentioned here at any time.
Assignment and Transfer Under Special Circumstances
Through this document, data subjects authorize the Company to assign or transfer the databases in which their information is recorded.
In the event of a sale, merger, spin-off, change of corporate control, transfer of assets, reorganization, or liquidation of the Company, it will retain the authority for the personal data that is part of its databases to be transferred, sold, assigned, or reassigned to whomever it considers relevant for that purpose.
Petitions, Complaints, and Claims
Petitions, complaints, and claims are handled by our Customer Service area. You may submit them by email to [email protected], or in person Monday through Friday from 8:00 a.m. to 12:00 p.m. and from 2:00 p.m. to 6:00 p.m., at the following address:
Address: Barranquilla, Calle 69 # 50 - 07 (080002)
These petitions will be governed by the terms and conditions described in the following section (Procedure for Exercising Your Rights).
Procedure for Exercising Your Rights
The Company has the mechanisms necessary to effectively receive, process, and respond to requests submitted by data subjects, regardless of which of the five platforms described in this Policy your relationship with the Company originated on. This procedure seeks above all to guarantee the rights of data subjects, so responding to the requests submitted is of great importance to the Company.
Requests may be submitted digitally to [email protected], or filed in person Monday through Friday from 8:00 a.m. to 12:00 p.m. and from 2:00 p.m. to 6:00 p.m., at the following address:
Address: Barranquilla, Calle 69 # 50 - 07 (080002)
When submitting any type of request, whether to delete, update, rectify, or correct the personal data provided, data subjects must verify their identity by attaching a copy of their identity document to the request. The same applies to anyone processing such a request on behalf of a data subject, who must provide a copy of the power of attorney or authorization for doing so, as well as a copy of the identity document of both the data subject and their representative. These conditions also apply to requests for a copy of the authorization granted to the Company to store the data subject's personal data, or requests to revoke that authorization.
The Company commits to providing a timely response within ten (10) business days, counted from the day following the filing of the request.
Final Provisions
This Policy replaces the previous version, in effect since May 1, 2018, and takes effect as of July 31, 2026.