Privacy Policy

1. Data Controller

LogiVAs ("we," "our," or "us") is the entity responsible for the processing of your personal data. For data processing performed on behalf of our clients (as described in Section 7), LogiVAs acts as a Data Processor.

• Company: LogiVAs
• Location: Colombia (principal place of business)
• Email: contact@logivas.com
• WhatsApp: +57 333 275 5711

The registered business address will be updated on this page once incorporation and registered-office details are finalized.

2. Information We Collect

2.1 Information You Provide

• Account Information: Name, email address, company name, industry, and role when you register.
• Contact Form Data: Name, email, company, and message content when you submit inquiries.
• Service Data: Operational data you enter into the Platform (shipments, contacts, invoices, inventory, etc.).
• Payment Information: Billing details processed through Stripe. We do not store credit card numbers on our servers.
• VA Contractor Data: Identification, contact details, banking information, and professional qualifications for VAs.

2.2 Information Collected Automatically

• Usage Data: Pages visited, features used, time spent, and interaction patterns within the Platform.
• Device Information: Browser type, operating system, IP address, and device identifiers.
• Cookies: Essential cookies for authentication and session management. See Section 10 for details.

3. How We Use Your Information

We use personal data for the following purposes (finalidades del tratamiento):

• Providing and maintaining the Services (VA staffing and Platform).
• Account creation and authentication.
• Processing payments and generating invoices.
• Assigning and managing Virtual Assistants for your account.
• AI Agent processing to provide operational insights from your data.
• Communicating about your account, services, and support.
• Improving our Services, including analytics and performance monitoring.
• Complying with legal obligations (tax, regulatory, anti-money laundering).
• Security monitoring and fraud prevention.

4. Legal Basis for Processing

4.1 Colombian Law (Ley 1581 de 2012)

Under Colombian data protection law, we process your personal data based on:

• Consent (Autorización): Your explicit consent provided during registration or through our consent forms.
• Contractual Necessity: Processing necessary for the performance of our Master Service Agreement or Freelancer Agreement.
• Legal Obligation: Compliance with Colombian tax, labor, and regulatory requirements.
• Legitimate Interest: Improving our Services and ensuring security, balanced against your privacy rights.

4.2 US Law

For users in the United States, we comply with applicable state privacy laws, including:

• California (CCPA/CPRA): California residents have the right to know, delete, and opt-out. LogiVAs does NOT sell personal information.
• Other States: We comply with applicable privacy laws in Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), and other states with enacted privacy legislation.

5. Data Sharing

We do NOT sell your personal data. We share data only with:

• Virtual Assistants: VAs assigned to your account access your operational data as needed to perform their duties, under strict NDAs.
• Service Providers (Subprocessors):

• Legal Requirements: We may disclose data when required by law, court order, or governmental authority.
• Business Transfers: In the event of a merger, acquisition, or sale of assets, your data may be transferred, subject to the same protections.

6. International Transfers

Your data may be transferred between Colombia and the United States. In accordance with Ley 1581 de 2012 (Articles 25-26), we ensure that international transfers are made only to countries with adequate data protection levels or with appropriate contractual safeguards in place. The United States is recognized under Decreto 1377 de 2013 as providing adequate data protection for the purposes of international transfers.

7. Client Data Processing

When LogiVAs processes data on behalf of a client (Data Controller), the processing is governed by a separate Data Processing Agreement (DPA). In such cases:

• LogiVAs acts as Data Processor (Encargado del Tratamiento).
• Data is processed solely according to the client's instructions.
• The client is responsible for obtaining necessary consents from their data subjects.
• Data subject requests should be directed to the client (Data Controller).

8. Your Rights

8.1 Rights under Colombian Law

As a data subject under Ley 1581 de 2012, you have the right to:

• Access: Know what personal data we hold about you.
• Rectification: Update or correct inaccurate data.
• Deletion: Request deletion of your data when no longer necessary (subject to legal retention requirements).
• Revoke Consent: Withdraw your consent for data processing.
• Proof of Consent: Request evidence that you provided consent.
• Complaint: File a complaint with the Superintendencia de Industria y Comercio (SIC) if you believe your rights have been violated.

8.2 Rights under US Law (CCPA and State Laws)

• Right to Know: Request disclosure of what personal information we collect and how it is used.
• Right to Delete: Request deletion of your personal information.
• Right to Opt-Out: We do NOT sell personal information. If this changes, we will provide an opt-out mechanism.
• Non-Discrimination: We will not discriminate against you for exercising your privacy rights.

8.3 Exercising Your Rights

To exercise any of these rights, contact us at contact@logivas.com. We will respond within fifteen (15) business days for Colombian law requests and within forty-five (45) days for US law requests.

9. AI Agent and Automated Processing

Our AI Agent feature processes your operational data to provide insights and answer queries. Important information about AI processing:

• AI processes data in real-time and does not permanently store conversation context beyond your Platform session logs.
• AI-generated responses are not used for automated decision-making that produces legal effects.
• Query data is transmitted to OpenAI for processing under their data processing terms, which prohibit using your data to train their models.
• You can disable the AI Agent feature at any time without affecting other services.

10. Cookies

We use the following types of cookies:

• Essential Cookies: Required for authentication, session management, and security. These cannot be disabled.
• Analytics Cookies: Help us understand how you use the Platform to improve our Services. These are optional and can be declined.

We do NOT use advertising or third-party tracking cookies.

11. Data Security

We implement appropriate technical and organizational measures to protect your data:

• Encryption in transit (TLS 1.2+) and at rest (AES-256).
• Role-based access control (RBAC).
• Two-factor authentication.
• Regular security assessments.
• All VAs sign NDAs and complete cybersecurity training.
• SOC 2-compliant infrastructure providers (Supabase, Vercel).

12. Data Retention

• Account Data: Retained for the duration of your account plus 30 days after closure for data export.
• Operational Data: Retained for the duration of your service agreement.
• Financial Records: Retained for five (5) years as required by Colombian tax law (Estatuto Tributario) and applicable US regulations.
• Communication Logs: Retained for one (1) year after the last interaction.
• VA Contractor Data: Retained for five (5) years after the end of the contractor relationship, as required by Colombian labor and tax regulations.

13. Children's Privacy

Our Services are not directed to individuals under 18 years of age. We do not knowingly collect personal data from minors. If we learn that we have collected data from a minor, we will delete it promptly.

14. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated to registered users via email at least fifteen (15) days before taking effect. The "Last updated" date at the top reflects the most recent revision.

15. Contact and Complaints

For privacy inquiries, data subject requests, or complaints:

• Email: contact@logivas.com
• WhatsApp: +57 333 275 5711
• Address: Colombia (registered address to be published upon incorporation)

If you are unsatisfied with our response, you may file a complaint with:

• Colombia: Superintendencia de Industria y Comercio (SIC) — www.sic.gov.co
• California, USA: California Attorney General — oag.ca.gov/privacy