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PRIVACY

Privacy Policy

Soluciones ComAura S.A.S.
Tax Identification Number (NIT): 902.105.209-6
Email: info@comaura.co
Product: ComAura DM Personalizados
Last updated: September 13th, 2026

1. Data Controller

This Privacy Policy establishes the criteria applicable to the processing of personal data in connection with the services offered by Soluciones ComAura S.A.S., identified by Tax Identification Number (NIT) 902.105.209-6, hereinafter referred to as “ComAura”, through its platform ComAura DM Personalizados.

ComAura develops and provides technology services aimed at managing and sending personalized communications through WhatsApp, using technological tools and third-party services when necessary for the operation of the platform.

For activities in which ComAura directly determines the purposes and means of processing personal data, ComAura will act as the Data Controller, in accordance with applicable law.

Contact: info@comaura.co

2. Personal Data That May Be Processed

Depending on the use of the platform and the services contracted, ComAura may process information such as:

  • Name or identification of the recipient of a communication.
  • Telephone number associated with the recipient.
  • Information related to communications sent.
  • Information necessary for the configuration and operation of the service.
  • Contact and identification information of ComAura customers.
  • Technical information necessary for the security, operation, and maintenance of the platform.

ComAura will seek to process only the data that is necessary for the purposes described in this Policy.

3. Purposes of Processing

Personal data may be processed for the following purposes:

  • To provide, operate, and maintain ComAura services.
  • To enable the generation and sending of personalized messages through WhatsApp.
  • To manage the configurations necessary for the use of the platform.
  • To process and record communications made through the service.
  • To provide customer support and service.
  • To maintain the security, integrity, and operation of the platform.
  • To prevent fraudulent, abusive, or unlawful use of the service.
  • To comply with legal obligations or requirements from competent authorities.
  • To manage administrative, commercial, and contractual matters related to the services.

ComAura will not use personal data for purposes incompatible with those informed to the data subject or with the legitimate instructions provided by its customers when acting on their behalf.

4. Processing of Data on Behalf of ComAura Customers

In certain circumstances, ComAura will provide its technology services by processing personal data on behalf of its customers.

For example, a ComAura customer may use the platform to upload information about their own contacts and generate personalized communications addressed to those contacts.

In these cases, the ComAura customer will determine the purposes for which the personal data is used and will be responsible for having the applicable authorization, legal basis, or other lawful basis for its processing, as well as for complying with the obligations applicable to such data.

In these circumstances, ComAura will act as a Data Processor, limiting the processing of data to the legitimate instructions and purposes related to the provision of the contracted service.

ComAura does not intend to acquire ownership of its customers' databases or to use recipients' data for its own purposes that are incompatible with the instructions received.

The customer will be responsible for verifying that the data incorporated into the platform may be lawfully used for the communications they intend to make.

5. WhatsApp Communications and Technology Providers

To provide its services, ComAura may use technological services provided by third parties, including the WhatsApp Business Platform and services associated with Meta.

The use of these services may involve certain data being processed directly by such providers in accordance with their own privacy policies, terms, and practices.

ComAura will seek to use appropriate technology providers for the operation of the service and will adopt reasonable measures to protect information under its control.

The operation of third-party services may be subject to their own technical conditions, policies, availability, and modifications.

6. International Transfers and Transmissions of Personal Data and Applicable Law

Due to the nature of the technological services used by ComAura, certain personal data may be stored, hosted, accessed, or processed in countries other than Colombia, either directly by ComAura or by technology providers used to provide the service.

Where international transfers or transmissions of personal data take place, ComAura will seek to ensure that they are carried out in accordance with applicable provisions and using the safeguards or protection mechanisms required under the laws applicable to the processing.

When ComAura acts as a Data Processor and uses other providers to carry out certain processing activities on behalf of a customer, data transmissions will take place within the authorized scope and in accordance with the applicable contractual and legal obligations.

The processing of personal data carried out by ComAura may be subject, depending on the circumstances and the applicable territorial scope, to different data protection laws.

In particular, where the European Union's General Data Protection Regulation (GDPR) is territorially applicable to a particular processing activity, ComAura will adopt the measures required to comply with the applicable obligations, including, where necessary, the safeguards required for international data transfers.

The reference to the GDPR in this Policy does not mean that such regulation applies universally to all ComAura activities. Its application will depend on the specific circumstances and its territorial scope.

Likewise, where applicable, ComAura will comply with Colombian laws governing the protection of personal data, as well as with any other provisions that may apply depending on the nature, location, and circumstances of the processing.

7. Data Retention

ComAura will retain personal data for as long as necessary to fulfill the purposes for which it was processed, provide the contracted services, comply with legal obligations, resolve potential disputes, and maintain the records necessary for the operation and security of the platform.

When data is no longer necessary for these purposes and there is no legal obligation to retain it, ComAura will proceed with its deletion, anonymization, or other appropriate processing in accordance with applicable measures.

When ComAura acts as a Data Processor, data retention will also be subject to the instructions and conditions agreed upon with the customer, within the limits established by applicable law.

8. Rights of Data Subjects

In accordance with applicable law, data subjects may exercise, among others, the rights applicable to:

  • Know the personal data subject to processing.
  • Request the updating or correction of information.
  • Request the deletion of data where applicable.
  • Obtain information regarding the use of their data.
  • Submit inquiries or complaints concerning the processing of their data.
  • Withdraw consent where legally applicable.

Requests concerning data processed by ComAura on behalf of one of its customers may be directed to the relevant customer, in its capacity as the party responsible for determining the purposes of the processing, without prejudice to the obligations that may directly apply to ComAura as Data Processor.

Requests may be sent to:

info@comaura.co

9. Information Security

ComAura will implement reasonable technical, administrative, and organizational measures aimed at protecting personal data against loss, unauthorized access, alteration, disclosure, or destruction.

However, no technological system can guarantee absolute security. For this reason, ComAura will maintain reasonable prevention, protection, and incident-management measures according to the nature of the data and the risks associated with the service.

10. Children's Data

ComAura services are not specifically designed to collect personal information from children.

Where a customer uses the platform to process children's data, the customer will be responsible for ensuring that it has the authorizations, legal bases, and other requirements established by applicable law.

ComAura will process such data only within the scope of the legitimate instructions received and the obligations applicable to it as a Data Processor.

11. Changes to This Privacy Policy

ComAura may update this Privacy Policy when necessary due to changes in the services offered, technological modifications, new providers, regulatory changes, or other relevant circumstances.

Where material changes are made, ComAura will seek to provide notice through the available means and will update the date indicated at the beginning of this Policy.

The version published on comaura.co will be the current version.

Contact

For questions, requests, or matters relating to this Privacy Policy:

Soluciones ComAura S.A.S.
Tax Identification Number (NIT): 902.105.209-6
Email: info@comaura.co
Website: comaura.co

Soluciones ComAura S.A.S.

Tax Identification Number (NIT): 902.105.209-6

info@comaura.co

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