Privacy Policy

Date of Update: October 2025

1. Introduction

This privacy policy is intended to inform you about the processing of your personal data within the scope of our digital offering. We are committed to protecting your data in accordance with current Chilean legislation (Law No. 21,719), as well as, where applicable, the European Union’s General Data Protection Regulation (GDPR) and US privacy laws (such as CCPA/CPRA).

2. Data Controller

DG Smart Solutions SPA
Aldunate 1525, Departamento 506
Santiago de Chile
Chile
Teléfono: +56 9 8419 2538
Correo electrónico: contacto[a]dg-smart-solutions.cl
https://dg-smart-solutions.com

3. Scope

This policy applies to all data processing related to:

• our website and digital services
• mobile applications
• social media presence
• communication with customers and interested parties

It also applies to users outside of Chile, especially in the EU and US, when our services are expressly directed to them.

4. Types of data processed

• Identification data (name, address)
• Contact data (email, telephone)
• Usage data (IP address, access times)
• Content data (forms, comments)
• Contractual data (business relationships, billing)
• Location data (mobile access)
• Technical metadata (browser, device type)

5. Purposes of processing

• Provision and optimization of our web services
• Communication and customer service
• Contractual fulfillment and business management
• Security and abuse prevention
• Marketing and analytics (only with consent)
• Compliance with legal obligations

6. Legal bases for processing

Chile (Ley 21.719):

• Informed, free, and specific consent
• Contractual necessity
• Legal obligation
• Legitimate interest

European Union (GDPR):

• Art. 6.1 a–f GDPR

United States (CCPA/CPRA):

• Transparency in Data collection
• Right to opt-out
• Right to deletion and correction
• Restriction of the use of sensitive data

7. Data Subject Rights

You have the right to:

• Access your data
• Rectify inaccurate data
• Delete your data
• Restrict processing
• Data portability
• Object to processing
• Revoke your consent
• Exercise the right to opt-out (“Do Not Sell or Share My Personal Information” (USA))

Contact to exercise your rights: contacto@dg-smart-solutions.cl

8. Data Security

We implement technical and organizational measures to protect your data:

• TLS/SSL encryption
• Access control
• Logging and monitoring
• Privacy-friendly default settings

9. Data transfer and disclosure

Data is only shared when:

• there is a legal obligation
• it is necessary to perform a contract
• consent has been given
• there is a legitimate interest

International transfers are only made if::

• there is an adequacy decision (e.g., EU)
• Standard Contractual Clauses apply
• Explicit consent is obtained
• Privacy Framework is complied with (US)

10. Cookies and Tracking

We use cookies to improve user experience. Non-essential cookies (e.g., for marketing) are only activated with your consent. You can change your preferences at any time.

11. Cloud Services and Web Hosting

We use cloud services and hosting providers to offer our website. These are contractually obligated to comply with data protection regulations.

12. Social Media

We maintain profiles on social media (e.g., Facebook, Instagram). Data processing is carried out by the respective platforms. Please refer to their privacy policies.

13. US-Specific Provisions (CCPA/CPRA and FTC)

If you reside in the US, specifically in California, you have additional rights:

• Know what data is collected
• Request data deletion
• Request data correction
• Restrict the use of sensitive data
• Exercise the right to opt out
• Not be discriminated against for exercising your rights
• We comply with the FTC’s guidelines for international providers.

14. Changes to this Policy

This policy may be updated. We recommend that you periodically review the current version.

15. Definitions

Personal Data: Information about an identified or identifiable individual.
Processing: Any operation involving personal data.
Controller: The entity that decides on the purposes and means of processing.