PRIVACY POLICY

Privacy Policy — comup.com

Version 1.0 · Effective November 8, 2026

This document also serves as the comprehensive privacy notice (Aviso de Privacidad Integral) under Mexican personal data protection law.

1. Data controller

The controller of your personal data is COMUP IT INC., operator of this website, with a presence in:

For any privacy matter, including exercising your rights, write to us at monica@comup.com.

2. What data we collect

Data you provide in the "Talk to an expert" form: first name, last name, business email, company, phone number, job role, country or region and, optionally, the message you write to us.

Data you provide through other channels: if you write to us by email or through our official channels, we process the data included in your communication.

Browsing data: through analytics cookies, and only with your consent, we collect information about your use of the Site (pages visited, time on page, device and browser type, approximate country). This processing is detailed in the Cookie Policy.

We do not collect data from minors: the Site is directed at companies and professionals. We do not request sensitive personal data through the Site.

3. How we use your data

Primary purposes (necessary to serve you):

Secondary purposes (only with your consent):

We do not use your data to send you advertising or marketing campaigns without your separate, express consent, which you may withdraw at any time. We do not sell or transfer your personal data to third parties for their own commercial purposes.

4. Legal basis for processing

We process your data on the basis of: your consent (form and analytics cookies), pre-contractual measures taken at your request (when you ask us for a proposal) and our legitimate interest in operating and protecting the Site, in accordance with the legislation applicable to you (including the European Union's General Data Protection Regulation, Canadian federal privacy law and Mexican data protection law).

5. Who we share your data with

We share data only with providers that supply us with infrastructure services, acting on our behalf and under confidentiality and data protection obligations, including:

If a business relationship moves forward, data processing within the platforms we implement (for example, Freshworks) will also be governed by the agreements and notices corresponding to that service.

6. International transfers

Our team and providers operate in Canada, Mexico, Spain and the United States, so your data may be processed in countries other than your own. Where this occurs, we apply the safeguards required by applicable law so that your data maintains an adequate level of protection.

7. How long we keep your data

Once the period ends, data is deleted or anonymized.

8. Your rights

You may at any time exercise your rights of access, rectification, erasure, objection, portability and restriction of processing, and withdraw your consent without affecting the lawfulness of prior processing. (In Mexico, these are known as ARCO rights.)

To exercise them, write to monica@comup.com stating your name, the right you wish to exercise and the email associated with your request. We will respond within the deadlines established by the legislation applicable to you.

You also have the right to lodge a complaint with the data protection authority of your country if you believe the processing does not comply with the law.

9. Security

We apply reasonable technical and organizational measures to protect your data against unauthorized access, loss or alteration. No system is completely infallible, but we review our measures periodically.

10. Changes to this Policy

We may update this Policy. Each version is identified by number and date, and the current version will always be the one published on this page. If a change is substantial, we will communicate it through appropriate means. Your acceptance is recorded and associated with the version in force at the time you accepted it.

11. Contact

monica@comup.com · Vancouver +1 778 218 3997 · Madrid +34 919 944 574.