Privacy Notice
This Privacy Notice describes how ADN SOFT S.A.S. ("ADN Soft", "we", "our" or "us") collects, stores, uses, transfers and deletes personal data, acting as controller and, where applicable, as processor.
By browsing this site, contacting us or engaging our services, you acknowledge that you have read this notice. It is written to comply with Law 1581 of 2012 and Decree 1074 of 2015 of the Republic of Colombia, and with Regulation (EU) 2016/679 (GDPR) where we process data of individuals in the European Economic Area.
1. Controller
ADN SOFT S.A.S., a company incorporated under the laws of Colombia, tax ID 902094914-1, with registered office at Calle 64 G # 90 A - 95, Bogotá D.C., and a second office at Calle 49 # 8-06, Soacha, Cundinamarca, Colombia.
Privacy contact: privacy@adnsoftsas.com. Data Protection Officer: dpo@adnsoftsas.com.
2. Scope
This notice covers: (i) client data processed on behalf of and under the instructions of our corporate clients during a project; (ii) visitor data from this website; (iii) candidate data from people applying to our roles; and (iv) business contact data of prospects and suppliers.
When we build or operate software for a client and access personal data of that client's users, we act as processor. In that case the client is the controller and we process the information only according to their documented instructions and the data processing agreement in force.
3. Data we process
- Identification and contact: name, job title, company, email, phone and country.
- Commercial relationship data: proposals, contracts, service orders, invoicing and communication records.
- Technical browsing data: IP address, device and browser type, pages visited and visit duration.
- Candidate data: CV, education, experience, technical assessment results and references you provide.
- Client data under processing agreements: as defined in each contract and its data processing annex.
We do not deliberately collect sensitive data. Where a process requires it, we will request your prior, express and informed consent, and make clear that you are not obliged to provide it.
4. Purposes and lawful basis
| Purpose | Lawful basis |
|---|---|
| Respond to enquiries and prepare commercial proposals | Consent / pre-contractual steps |
| Perform the services agreement and provide support | Contract performance |
| Invoicing and tax and accounting compliance | Legal obligation |
| Manage recruitment processes | Consent |
| Improve the website and measure its use | Legitimate interest / consent for non-essential cookies |
| Send communications about our services | Consent, withdrawable at any time |
| Prevent fraud and protect information security | Legitimate interest |
We do not make automated decisions producing legal effects on you, nor do we carry out profiling with that reach.
5. Processors and third parties
We share personal data only with: cloud infrastructure providers and working tools needed to operate; legal, accounting and audit advisers bound by confidentiality; and competent authorities where a legal obligation or court order applies.
All our suppliers are bound by contracts imposing confidentiality and security obligations equivalent to our own. We do not sell personal data and we do not transfer it for third-party advertising purposes.
6. International transfers
Part of our infrastructure is hosted outside Colombia. Where we transfer data to countries without an adequate level of protection, we rely on the Standard Contractual Clauses approved by the European Commission, on the data subject's authorisation, or on the other safeguards set out in Law 1581 of 2012 and External Circular 005 of 2017 of the Colombian Superintendence of Industry and Commerce.
7. Retention
We keep data for the duration of the relationship and thereafter for the periods required by Colombian commercial, tax and employment law. CVs of candidates who are not hired are kept for up to twelve months unless you ask us to delete them sooner. Data processed on a client's behalf is returned or deleted at the end of the contract, as the client instructs.
8. Your rights
At any time and free of charge you may: access the data we hold about you; update or correct it; request proof of the authorisation given; be informed of how your data has been used; withdraw authorisation or request deletion where no legal duty to retain applies; and lodge a complaint with the Colombian Superintendence of Industry and Commerce.
Where the GDPR applies to you, you also have the rights to restriction of processing, objection and portability, and you may complain to the supervisory authority of your country of residence.
To exercise them, write to privacy@adnsoftsas.com stating your name, the right you wish to exercise and a contact method. We answer queries within ten business days and complaints within fifteen business days, extendable as permitted by law.
9. Information security
We apply technical and organisational controls proportionate to risk: encryption in transit and at rest, least-privilege access control, two-factor authentication, activity logging, regular backups, code review and vulnerability management. No system is infallible; should an incident compromise your data, we will notify you and report it to the competent authority within the legal deadlines.
10. Cookies
This site uses first-party cookies necessary for it to work and, subject to your consent, usage measurement cookies. You can configure your browser to reject them, in which case some features may be unavailable.
11. Minors
Our services are aimed at businesses and are not directed at minors. We do not knowingly collect data from minors. If we find we have done so without the authorisation of their legal guardian, we will delete it.
12. Changes to this notice
We may update this notice to reflect regulatory or operational changes. The current version is published on this page with its update date. If a change is material, we will inform you through the contact details we hold.
13. Contact
For any question about this notice or about the processing of your personal data, write to privacy@adnsoftsas.com or to our Data Protection Officer at dpo@adnsoftsas.com.
