Privacy Policy

At Litsight, operated by SWEBCOL SAS, we are committed to the privacy and security of our users' personal data. This Privacy Policy aims to transparently inform how we collect, use, protect, and share your personal information, in accordance with the General Data Protection Regulation (GDPR) and other applicable regulations.

1. Data Controller

The data controller for personal data is SWEBCOL SAS, with NIT 900436315-1, located in Bogotá, Colombia.

2. Personal Data Collected

We collect the following personal data for the indicated purposes:

• Identification data: Name, date of birth, gender, document number.
• Contact data: Email, phone.
• Location data: Country of residence.
• Payment data: Collected and stored directly by our payment processors (PayPal, Wompi, Stripe). We do not have access to banking information or credit card information from our users.
• Evaluation data: Results of competency or behavioral assessments.

We do not process sensitive data (health, religious beliefs, political orientation, etc.) according to GDPR Art. 9.

3. Processing Purposes

Your data is used to:

• Provide access to the platform (legal basis: contract).
• Manage payments and billing (legal basis: contract).
• Send commercial communications (legal basis: explicit consent).
• Comply with legal obligations (e.g., invoice retention).

4. Legal Basis

Each processing is linked to a GDPR legal basis:

• Contract: Platform access, payment management.
• Consent: Newsletter and direct marketing.
• Legal obligation: Tax data retention.

Right to withdraw consent: You can withdraw it at any time (see Section 9).

5. Third-Party Sharing

We share data with:

• Payment processors: PayPal, Stripe, Wompi (subject to GDPR agreements).
• Infrastructure providers: AWS (USA)
• Communication providers: Brevo (EU).

6. International Transfers

Transfers outside the EEA use safeguards such as Standard Contractual Clauses (SCCs).

7. Storage Duration

• Active account data: Retained while the user does not request deletion.
• Payment data: 5 years (legal obligations).
• Inactive data: Deletion after 2 years without activity.

8. Data Security

We implement:

• AES-256 encryption.
• Annual security audits.
• Breach notification: We will inform authorities and users within 72 hours if there is high risk.

9. User Rights (GDPR Art. 15-22)

You can exercise:

• Access, rectification, deletion.
• Portability (in CSV/JSON format).
• Objection to processing.
• Withdraw consent (marketing: "unsubscribe" link in emails).

Response time: 1 month (extendable to 2 in complex cases).

Supervisory authority: You can file a complaint with the Data Protection Agency of your country. E.g., AEPD in Spain.

10. Cookies

Litsight uses cookies and similar technologies to improve user experience, personalize services, and analyze platform usage. Cookies may be used to store preferences, perform traffic analysis, and improve website functionality. Users can manage their cookie preferences and accept them fully or partially through the options available on the platform.

• Essential cookies: Necessary for operation (do not require consent).
• Analytical/marketing cookies: Blocked until explicit consent.

11. Minors

Our platform is oriented to behavioral and competency assessment for adults. In accordance with our Terms and Conditions of use, every Litsight user affirms to be of legal age or to have authorization from their legal guardian to use the platform and provide the data mentioned in this policy.

12. Policy Changes

We will notify substantial changes by email.

13. Contact

For any questions or requests to exercise your rights as a user, please contact us at info@litsight.pro

14. Acceptance and Consent

Platform use is not conditional on marketing consent. During registration:

• I accept the Terms and Conditions (required).
• Consent to receive newsletters (optional).