Data Treatment Policy

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 six 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.
• rfid.com.co, an informational site about RFID. It has no forms and receives no personal data; contact happens on accendo.com.co.

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

The data controller for the personal data collected across the six platforms described in this Policy is ACCENDO S.A.S. (the "Company"), identified with NIT 900834127-9. It is the same entity on all of them, and it is also responsible for the databases holding the information data subjects provide voluntarily.

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.

On accendo.com.co and Accendo Hub, for example when a form is completed or a message arrives 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 campaign parameters (utm_source, utm_medium, utm_campaign, gclid), the landing page, and the referring site. The browser holds them for the session and they travel with the form.
• The consent record: the date and time, the exact text of the notice that was accepted and its fingerprint, the language, the form, the site, the method, and the submission identifier.

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. Google Play Services' privacy policy is 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 anyone finds that a child under 13 has provided us with personal information, an email to [email protected] is enough and we delete it.

Forms and messages

This section applies to accendo.com.co and Accendo Hub.

When a form arrives from this site or a message arrives on WhatsApp, the Company receives and stores the content of the message, the contact details provided, the date and time it arrived, and the record of the consent that was accepted. That information is kept on our internal platform, is used to handle the request and to measure our response times, and is not used for mass mailings. We do not sell it and we do not hand it to third parties for their own advertising. What goes to Google Ads is only the signal that a form was submitted successfully, with no name, email address, phone number, or message content, so we can tell which ad produced the contact. Access, correction, and deletion are requested through the channels indicated in this Policy.

The forms use Google reCAPTCHA Enterprise to tell a person from an automated submission. Google receives browser and form-interaction data for that purpose and uses it under its own privacy policy.

Analytics and advertising

This section applies to accendo.com.co, trackvy.com, and rfid.com.co.

The three sites use Google Analytics 4, with a separate property for each, to measure page views and a few form and contact events. accendo.com.co also records a Google Ads conversion when a form is submitted successfully. The measurement never receives the name, email address, phone number, or message content.

We measure the minimum that tells us what works. Anyone who prefers not to be measured can block analytics in the browser or with an ad blocker, and the sites work the same. The detail is in the Privacy 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.
• Measuring website usage and advertising effectiveness, in aggregate.

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 Policy

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. They can be submitted 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 rights

The Company has the mechanisms needed to receive, process, and answer requests from data subjects effectively, regardless of which of the six platforms described in this Policy the relationship began on.

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 September 9, 2026.

Previous PDF version.