Privacy Policy
Last updated: [[PENDING]]
Reference boilerplate only — this is NOT legal advice and must be reviewed by a qualified attorney before production. [[PENDING: legal review]]
This Privacy Policy explains how [[RAZÓN SOCIAL]] ("SOMA9", "we"), a limited liability company organized in the United States, collects, uses and protects personal information across our website and services for a global audience.
Who we are
Data controller: [[RAZÓN SOCIAL]], [[DIRECCIÓN]], United States. Privacy contact: [[EMAIL DE CONTACTO/PRIVACIDAD]].
Data we collect
Information you provide (e.g. contact and project details), information collected automatically (e.g. device, log and usage data, IP address), and information from cookies and similar technologies. [[PENDING: exact data categories]]
How we use data
To provide and operate our services, respond to enquiries, secure and improve the platform, and comply with legal obligations. We do not sell your personal information. [[PENDING: confirm purposes]]
Legal bases (GDPR)
Where the GDPR applies, we process personal data on the bases of consent, performance of a contract, legitimate interests, and compliance with a legal obligation, as applicable. [[PENDING: map bases to purposes]]
Data retention
We retain personal data only as long as needed for the purposes described or as required by law, then delete or anonymize it. [[PENDING: retention periods]]
Cookies
We use necessary cookies and, with your consent, analytics/marketing cookies. See our Cookie Policy and the consent banner to manage your choices.
Your California rights (CCPA/CPRA)
California residents may request to know, access, correct and delete personal information, and to opt out of the sale or sharing of personal information, without discrimination. To exercise these rights contact [[EMAIL DE CONTACTO/PRIVACIDAD]]. [[PENDING: verification process]]
Your EU/EEA rights (GDPR)
If you are in the EU/EEA/UK, you have rights of access, rectification, erasure, restriction, portability and objection, and the right to withdraw consent and to lodge a complaint with a supervisory authority. [[PENDING: representative/DPO if required]]
International transfers
We may process data in the United States and other countries. Where required, we rely on appropriate safeguards (e.g. Standard Contractual Clauses) for international transfers. [[PENDING: transfer mechanism]]
Changes to this policy
We may update this policy; material changes will be reflected by the "last updated" date above. [[PENDING: notification method]]
Contact
Questions or requests: [[EMAIL DE CONTACTO/PRIVACIDAD]] — [[RAZÓN SOCIAL]], [[DIRECCIÓN]], United States.
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