Privacy Policy

Last updated: October 19, 2026

Data controller: Jorge Leonardo Romero Medina, C.C. 1118827474, with registered address at Cra 23 No. 13 – 56, Riohacha, La Guajira, Colombia, hereinafter THE WEBSITE MANAGER, whose contact email is info@en360grados.online.

Data requested on the website and purpose of the processing

• Name, surname and email address in the contact forms: to allow any direct contact with THE WEBSITE MANAGER, whether to raise questions, comments, suggestions, request a service or product, or any other information. Failure to provide the minimum personal data required will make it impossible for THE WEBSITE MANAGER to respond to the request.
• Name and email address: to post comments on the website blog.
• Name, surname, address, telephone, email address, tax identification number: this information will be requested at the time of payment for the service, in order to process everything related to the customer.
• Name, telephone and email address for the newsletter: with the due express and voluntary consent of the data subject, the minimum information necessary to send an automated commercial newsletter will be requested on the website, informing about advertising, promotions and other information on the services and/or products offered by THE WEBSITE MANAGER.
• Email address: the email address will be requested in order to access the customer area, in accordance with the data provided at the time of creating the account.

If the user is under 16 years of age, they must have the authorisation of their parents or legal guardians to provide their personal data. THE WEBSITE MANAGER has no way of effectively verifying the age of users, and is therefore exempt from any liability if the user does not comply with what is stated here.

THE WEBSITE MANAGER will at all times ensure that the use made of the website and its contents, and the processing of the user’s personal data, are carried out in the most correct way possible. To this end, the user may always exercise their rights of access, rectification, erasure, portability, oblivion or objection, in faithful compliance with the guidelines of the laws governing the matter, by writing to the email address info@en360grados.online.

At no time will THE WEBSITE MANAGER share the data it holds with third parties. Should it do so in order to fulfil the services contracted by a participant, send the newsletter, comply with legal requirements or for the administration of the website, the appropriate confidentiality agreements will be provided between the parties.

The links to third parties that may be found on the website have privacy policies unrelated to THE WEBSITE MANAGER. Access to these sites shall be the responsibility of the user, and it is their responsibility to know them and their decision to accept them or not.

Forms

The website has 4 types of forms:

Contact: the user, customer or participant may find forms that facilitate communication with THE WEBSITE MANAGER, in order to raise questions, comments, request a quote, book any of the services offered on the website or demand any right they hold. Failure to provide the minimum personal data required will make it impossible for THE WEBSITE MANAGER to respond to the request. This processing will be considered legitimate as it is part of a pre-contractual step. The website server and the email server of THE WEBSITE MANAGER will be the data processors.

Advertising: users, buyers or participants will be asked for their express and voluntary consent to provide THE WEBSITE MANAGER with the minimum data necessary to send advertising and commercial information related to the services and/or products offered by THE WEBSITE MANAGER, so that it may be added to an automated email marketing file managed by the data processor indicated below. The processing of the personal data in this section is carried out with the consent of the data subject.

Blog comments: in order to prevent spam and inappropriate messages, and to keep proper track, the user will be asked for their name, email and website to identify them in the comments they wish to make on blog posts. This data will be visible to other users of the website. If you do not want your data to be visible to other people, you should contact THE WEBSITE MANAGER at the email address info@en360grados.online.

The website server will be the data processor, and the processing will be carried out with the consent of the data subject.

Processing the service request: users, customers or participants will be asked for their data so that THE WEBSITE MANAGER can process the services requested by the customer. Legitimate processing of personal data due to the contractual relationship existing with the customer or participant. The data will be stored on the website server.

Data processors

THE WEBSITE MANAGER needs the support of third parties to properly offer its services and products, with whom it enters into the appropriate confidentiality agreements and verifies compliance with personal data protection regulations.

The data provided to these third parties may not be used for purposes other than those authorised by the data subject.

In compliance with the principles of information and transparency, it is made known that these third parties are:

• Mailchimp: used to automate commercial information newsletters and to send advertising for the products and/or services offered on the website to the data subject’s email address. Service provided by the company The Rocket Science Group LLC, located in the United States of America. It has a security agreement called the Privacy Shield, in accordance with the requirements of the European Data Protection Committee, which can be consulted here https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG&status=Active. For more information on its privacy policy you can visit https://mailchimp.com/legal/privacy/
• Asana: Application used to organise and manage work activities. This service is provided by the company Asana, Inc., which is located at 1550 Bryant Street, Suite 200, San Francisco, CA 94103 and can be contacted by email at privacy@asana.com. If you would like more information about its privacy policy you can consult: https://asana.com/terms
• Active campaign: Used for email marketing and customer management. This service is provided by the company ActiveCampaign, LLC, whose office is located in Chicago, USA. They have signed the Privacy Shield, which can be verified at this link https://www.privacyshield.gov/participant?id=a2zt0000000GnH6AAK&status=Active. You can see more information about their privacy policy here https://www.activecampaign.com/privacy-policy/
• Zapier: It is a tool used to automate tasks. The company, Zapier Inc., is located at Zapier, Inc., 548 Market St. # 62411, San Francisco, CA 94104 – 5401 and can be contacted by email at contact@zapier.com. Its privacy policy can be viewed at the link https://zapier.com/privacy/
• Google: Tool used for the purposes described on this site. This service is provided by the company Google LLC, located in Mountain View, California, United States of America. It holds the EU-US Privacy Shield subscription, which can be consulted at https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active. If you would like more information about its privacy policy you can consult: https://policies.google.com/privacy
• Lead Pages: Tool used to create websites, landing pages and pop-ups, among others. This service is provided by the company Avenue 81, Inc., which is located at 107 Cheapside, London and can be contacted by email at legal@ave81.com. Its privacy policy can be viewed at the link https://www.leadpages.net/privacy
• Apple: Tool used for the purposes described on this site. This service is provided by the company Apple Inc., which can be contacted through the link https://www.apple.com/la/contact/ and whose privacy policy can be viewed at https://www.apple.com/legal/privacy/en-ww/
• Siteground: Provides the web hosting service through the company SiteGround Spain SL. Its European headquarters are located in Spain, C/ Serrano 1, 28001 Madrid, and its privacy policy can be viewed at https://www.siteground.com/privacy.htm
• Calendly: Tool used to schedule meetings; the company is located at 1315 Peachtree St NE, Atlanta, GA 30309 and can be contacted by email at support@calendly.com. It holds the EU-US Privacy Shield and the Swiss-US Privacy Shield subscriptions, which can be consulted at https://calendly.com/pages/privacy, and its privacy policy can be viewed at https://calendly.com/pages/privacy
• Typeform: Tool used to create online forms and online surveys. This service is provided by the company Typeform SL, which is located at Carrer Bac de Roda, 163, local, 08018 – Barcelona (Spain). They can be contacted by email at support@typeform.com and their privacy policy can be viewed at https://admin.typeform.com/to/yFvrNI/
• Facebook pixel: analytics tool for advertising, used to learn about the actions of data subjects on this website. This service is provided by Facebook, Inc., which is located at 1601 Willow Road Menlo Park, CA 94025, United States of America. If you are outside the United States of America or Canada, the data controller responsible for the information is
• Facebook Ireland Ltd., which is located at 4 Grand Canal Square Grand Canal Harbour, Dublin 2, Ireland. It holds certification under the European Union-United States Privacy Shield framework and the Switzerland-United States Privacy Shield framework, as can be evidenced at https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active. For more information on the privacy policy visit https://www.facebook.com/privacy/explanation
• Google Analytics: Web analytics service, to see statistics on the use of the website. This service is provided by the company Google LLC, located in Mountain View, California, United States of America. It holds the EU-US Privacy Shield subscription, which can be consulted at https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active. If you would like more information about its privacy policy you can consult: https://policies.google.com/privacy
• Zoom: tool used for videoconferences. This service is provided by the company Zoom Video Communications, Inc., located in San Jose, California, United States of America. It holds the EU-US Privacy Shield subscription, which can be consulted at https://www.privacyshield.gov/participant?id=a2zt0000000TNkCAAW&status=Active. If you would like more information about its privacy policy you can consult: https://zoom.us/privacy
• Evernote: tool to better manage the services offered. Service offered by Evernote Corporation, located in the United States of America, which has signed the privacy shield as can be evidenced at https://www.privacyshield.gov/participant?id=a2zt0000000PCFCAA4&status=Active, an agreement signed between the EU and the US and approved by the European Data Protection Committee. For more information on its privacy policy visit https://evernote.com/intl/es/privacy/policy
• Skype: tool used for videoconferences. This service is provided by the company Microsoft Corporation, located in Redmond, Washington, United States of America. It holds the EU-US Privacy Shield subscription, which can be consulted at https://www.privacyshield.gov/participant?id=a2zt0000000KzNaAAK&status=Active. If you would like more information about its privacy policy you can consult: https://privacy.microsoft.com/es-mx/privacystatement
• Coda.io: Tool used for document editing. This service is provided by the company Coda, which is located at 444 Castro St, Suite 1200, Mountain View, CA 94041. It can be contacted by email at help@coda.io and its privacy policy can be viewed at https://coda.io/trust/privacy
• Manychat: Tool used to create bots on Facebook pages. This service is provided by the company ManyChat, INC. It can be contacted by email at support@ManyChat.com and its privacy policy can be viewed at https://manychat.com/privacy.html
• Pay U Latin America: Company used to manage payments on the website. It can be contacted by email at protecciondedatos@payulatam.com and its privacy policy can be viewed at https://legal.payulatam.com/ES/politica_de_privacidad.HTML
• PayPal (Europe) S.à r.l. et Cie, S.C.A.: company used to manage payments by debit and credit card on the website. Located at 22-24 Boulevard Royal L-2449, Luxembourg. For more information you can visit https://www.paypal.com/es/webapps/mpp/ua/privacy-full?locale.x=es_ES
• Stripe Inc: used to manage payments by debit and credit card on the website. This company is located in the United States and has a security agreement called the Privacy Shield, in accordance with the requirements of the European Data Protection Committee, which can be consulted here https://www.privacyshield.gov/participant?id=a2zt0000000TQOUAA4&status=Active. For more information at https://stripe.com/us/privacy
• Mailtrack: It is a tool used to send emails and verify that they have been read by the recipient. The company THE MAIL TRACK COMPANY, S.L. is located at calle Córcega, number 301, attic 2ª, 08008 – Barcelona (Spain) and can be contacted by email at hi@mailtrack.io. Its privacy policy can be viewed at the link https://mailtrack.io/es/privacy-policy
• Dropbox: Used for virtual hosting of documents related to the products or services offered on the website. Service provided by Dropbox, Inc, located in California, United States. It has a security agreement called the Privacy Shield, in accordance with the requirements of the European Data Protection Committee, which can be consulted at https://www.privacyshield.gov/participant?id=a2zt0000000GnCLAA0&status=Active. For more information about its privacy policy you can visit https://www.dropbox.com/privacy
• WhatsApp: Tool used for communication with users, buyers, customers and participants through the company WhatsApp Ireland Limited (for those located in Europe). It can be contacted through the link https://www.whatsapp.com/contact/?subject=messenger and its privacy policy can be viewed at https://www.whatsapp.com/legal?eea=1#privacy-policy

In specific cases, THE WEBSITE MANAGER may use applications or tools that have not been included or named in this list, because they are a better option that contributes to carrying out a given task; if this should happen, THE WEBSITE MANAGER will notify its users, customers or participants, as the case may be, of this situation.

Policies related to the Newsletter

These policies shall be understood at all times as a complementary part of the terms and conditions set out on the website, both being equally applicable at the time of a dispute. The privacy and intellectual property policy applied shall be the same as that set out in the terms and conditions of the website.

“Newsletter” shall be understood as the digital bulletin that THE WEBSITE MANAGER produces periodically and sends to its subscribers through an external email service provider, to which the user has subscribed voluntarily.

THE WEBSITE MANAGER is not obliged to send the newsletter within defined periods of time, and is therefore entirely free to do so when it deems appropriate. The user may at all times exercise their rights of access, rectification, erasure or objection by following the instructions found in the footer of the newsletter.

The user must not share its content with third parties, as this would violate the copyright of THE WEBSITE MANAGER. The only possible distribution channel is the one managed and/or authorised by THE WEBSITE MANAGER.

THE WEBSITE MANAGER shall not be liable for third-party content shown in the newsletter; any dispute arising must be dealt with directly with the person or company mentioned.

All material shown in the newsletter is protected by copyright in favour of THE WEBSITE MANAGER, and where it belongs to third parties, it shall be understood that THE WEBSITE MANAGER has the due authorisation to use it as agreed with the author.

Retention period

In the case of personal data provided for invoicing and the purchase of products or services, it will be kept for the period legally applicable by the platform that carries out the invoicing.

In the case of personal data provided for electronic commercial newsletters and blog comments, it will be kept for as long as the data subject wishes to remain on the subscription list, and they may unsubscribe at any time they wish, automatically as indicated in each newsletter, or by writing to the email address info@en360grados.online.