Política de Privacidad

2. Scope and Roles

Depending on the context:

• Pailon acts as a data controller for account administration, platform security, analytics, and business operations.
• Pailon acts as a data processor when processing Personal Data on behalf of customers in connection with regulated actions, evidence generation, or reporting.

Customers remain responsible for determining the lawful basis for processing Personal Data in their systems and for content they submit to Pailon.

3. Information We Collect

3.1 Personal Data You Provide

We collect Personal Data you choose to provide when you create an account, use the Pailon Services, or communicate with us.

A. Identity and Account Information

• Full name
• Email address
• Phone number
• Organization and role
• Authentication credentials (hashed or tokenized)
• API keys and access scopes

B. Compliance and Governance Information

• Authorization requests and approvals
• Policy evaluation inputs and outcomes
• Delegation and revocation records
• Risk classifications and decision metadata

C. Evidence and Audit Metadata

• Event timestamps and identifiers
• Cryptographic hashes
• Attestation references
• Artifact metadata (hashes, size, type)
• Custody and access records

Note: Pailon records metadata and proof. We do not require customers to upload raw domain records (e.g., medical files, legal documents, or financial account data) unless explicitly configured for evidence purposes.

D. Communications

• Support inquiries
• Emails and other correspondence
• Recorded communications where permitted by law

E. Location Information

• Approximate location inferred from IP address
• Location information you voluntarily provide

3.2 Information Collected Automatically

When you access the Pailon Services, we automatically collect limited technical data:

• IP address
• Device type and operating system
• Browser type and version
• Language and regional settings
• Usage logs, error logs, and performance metrics

This data is used for security, reliability, and operational integrity—not advertising.

4. Cookies and Similar Technologies

We use cookies and similar technologies only to:

• Enable core platform functionality
• Maintain secure sessions
• Prevent abuse and fraud
• Monitor system performance

We do not use cookies for behavioral advertising and do not track users across unrelated third-party websites.

You can manage cookies through your browser settings, but disabling them may limit certain features.

5. How We Use Personal Data

We use Personal Data solely for legitimate business and compliance purposes, including to:

• Provide and operate the Pailon Services
• Authenticate users and secure accounts
• Evaluate policies and governance rules
• Produce attestations and verifiable evidence
• Generate regulatory, audit, or court-ready reports
• Detect, prevent, and investigate fraud or security incidents
• Comply with legal and regulatory obligations
• Improve platform reliability and features
• Respond to support requests and operational communications

We do not sell Personal Data or use it for interest-based advertising.

6. How We Share Personal Data

6.1 Service Providers

We may share Personal Data with vetted service providers that support our operations, including:

• Cloud infrastructure providers
• Security, monitoring, and logging services
• Identity and access management tools
• Audit and compliance vendors

Service providers are contractually bound to use Personal Data only as instructed and to protect it appropriately.

6.2 Customer-Directed Integrations

If you connect Pailon to third-party platforms (e.g., banks, payment providers, case management systems, or agent frameworks), we may share data as directed by you.

Those third parties process data under their own terms and privacy notices.

6.3 Legal and Regulatory Disclosures

We may disclose Personal Data if required to:

• Comply with applicable laws or regulations
• Respond to lawful requests from regulators, courts, or law enforcement
• Enforce our agreements
• Protect the rights, safety, or integrity of Pailon, our users, or others

6.4 Business Transfers

If Pailon is involved in a merger, acquisition, reorganization, or sale of assets, Personal Data may be transferred as part of that transaction, subject to this Privacy Policy.

7. Data Retention

We retain Personal Data only as long as necessary to:

• Provide the Pailon Services
• Maintain verifiable audit and evidence trails
• Comply with legal, regulatory, and contractual obligations

Retention periods may vary by data category, jurisdiction, and regulatory requirements. Legal holds may suspend deletion where required.

When data is deleted, Pailon records provable deletion evidence as part of its audit trail.

8. Security Safeguards

We maintain administrative, technical, and organizational safeguards designed to protect Personal Data, including:

• Access controls and least-privilege enforcement
• Encryption in transit and at rest
• Audit logging and monitoring
• Key management and rotation
• Secure development and deployment practices

Access to Personal Data is limited to authorized personnel with a legitimate business need.

9. International Data Transfers

Pailon operates globally. Personal Data may be processed in jurisdictions other than your own.

Where required, we implement appropriate safeguards (such as contractual protections) to ensure lawful international data transfers.

10. Your Rights

Depending on your jurisdiction, you may have the right to:

• Access your Personal Data
• Correct inaccurate or incomplete data
• Request deletion (subject to legal retention obligations)
• Restrict or object to certain processing
• Receive a copy of your data in a portable format
• Withdraw consent where processing is based on consent

Requests can be submitted by contacting privacy@pailon.cc. We may require identity verification before responding.

11. Children's Data

The Pailon Services are not directed to individuals under 13 years of age, and we do not knowingly collect Personal Data from children.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Material changes will be communicated through the platform or by other appropriate means. The "Last updated" date reflects the most recent revision.

13. California and U.S. State Privacy Rights

Where applicable, residents of certain U.S. states (including California) have rights under state privacy laws, such as the CCPA.

Pailon does not sell Personal Data and does not discriminate against users for exercising privacy rights.

14. Third-Party Services and Notices

Pailon enables governance and evidence for services provided by third parties. Those providers' privacy notices govern their handling of Personal Data processed outside the Pailon platform.

15. Contact Us

For questions or concerns about this Privacy Policy or our data practices, contact:

Email: privacy@pailon.cc