Privacy Policy

Privacy Policy

PRIVACY POLICY

CAFETO SOFTWARE USA, LLC

Last updated: August 26, 2026

1. WHO WE ARE

This Privacy Policy is issued by Cafeto Software USA, LLC ("Cafeto", "we", "us", "our"), with offices at 825 Town & Country Ln, Houston, TX 77024, USA. Cafeto Software USA, LLC operates together with its affiliates Cafeto Software S.A.S. (Colombia, NIT 900.696.777-5) and Cafeto Software México, S.A. de C.V. (Mexico). References to "Cafeto," "we," "us," or "our" in this Policy refer to these three affiliated entities collectively, unless the context requires otherwise.

Contact for privacy matters: [email protected]

Website: https://cafetosoftware.com

For visitors located in Colombia, personal data is processed by our Colombian affiliate, Cafeto Software S.A.S. (NIT 900.696.777-5), under the terms described in our Spanish-language Aviso de Privacidad, available on this website.

2. SCOPE AND LEGAL FRAMEWORK

This Privacy Policy explains how Cafeto collects, uses, discloses, and protects personal data collected through cafetosoftware.com and related communications (the "Site").

Where you are located in the European Economic Area (EEA), the United Kingdom, or otherwise protected by the Regulation (EU) 2016/679 (the "GDPR") or the UK GDPR, this Policy is intended to comply with those frameworks, as described in Section 9 below.

Where you are located in Colombia, your personal data is processed under Law 1581 of 2012 and Decree 1377 of 2013, as described in our Spanish-language Aviso de Privacidad.

3. PERSONAL DATA WE COLLECT

Depending on how you interact with the Site, we may collect:

  • Identification and contact data: name, email address, phone number, job title, company name.
  • Information you submit through forms: project details, staffing needs, or messages you voluntarily provide when requesting a consultation or quote, including forms managed through our campaign landing pages, Google Ads, and social media advertising.
  • Job application data: if you apply through our careers page, we collect your resume/CV, work experience, and education through our applicant tracking system, Job Adder.
  • Technical and usage data: IP address, browser type, device information, pages visited, time on page, referring URLs, and data collected through cookies and similar technologies (see Section 8).
  • Business relationship data: billing and contact information for clients and vendors.
  • Chatbot interaction data: messages and contact details you voluntarily share when chatting with the Site's virtual assistant.

We do not intentionally collect special categories of personal data (such as data revealing racial or ethnic origin, political opinions, religious beliefs, health data, or sexual orientation) through the Site. If you voluntarily include such information in a free-text field, we will either seek your explicit consent to process it or delete it.

4. HOW WE USE YOUR PERSONAL DATA (PURPOSES)

We use personal data to:

1. Respond to inquiries, quote requests, and meeting bookings.

2. Manage our contractual relationship with clients and vendors.

3. Evaluate applications to job openings posted by Cafeto.

4. Send marketing communications, newsletters, or educational content (blogs, guides, event invitations), where you have opted in to receive them.

5. Analyze and improve the Site's performance and user experience (web analytics).

6. Comply with applicable legal, contractual, or regulatory obligations.

7. Detect, prevent, and address fraud, security, or technical issues.

5. LEGAL BASIS FOR PROCESSING (GDPR)

Where the GDPR applies, we rely on the following legal bases under Article 6(1):

  • Consent (Art. 6.1.a) — for marketing communications and non-essential cookies.
  • Performance of a contract or pre-contractual steps (Art. 6.1.b) — to respond to your inquiry or provide requested services.
  • Legal obligation (Art. 6.1.c) — to comply with tax, accounting, or other legal requirements.
  • Legitimate interests (Art. 6.1.f) — to operate, secure, and improve the Site, provided your interests or fundamental rights do not override those interests.

You may withdraw consent at any time by contacting us, without affecting the lawfulness of processing carried out before the withdrawal.

6. HOW WE SHARE PERSONAL DATA

We may share personal data with:

  • Service providers who process data on our behalf, including our website chatbot provider, Google Ads and social media advertising platforms, and Job Adder as our recruiting/applicant tracking system, under contractual terms that require them to protect your data.
  • Professional advisors (legal, accounting) where necessary.
  • Regulators or authorities, where required by law.
  • A successor entity in the event of a merger, acquisition, or sale of assets, subject to appropriate safeguards.

We do not sell personal data to third parties.

7. INTERNATIONAL DATA TRANSFERS

Cafeto operates through Cafeto Software USA, LLC (United States), Cafeto Software S.A.S. (Colombia), and Cafeto Software México, S.A. de C.V. (Mexico), and may use service providers located in other countries. Personal data may therefore be transferred among these affiliates and to such providers. Where personal data protected by the GDPR is transferred outside the EEA/UK, we will rely on an appropriate transfer mechanism, such as the European Commission's Standard Contractual Clauses (SCCs), an adequacy decision, or another mechanism recognized under Chapter V of the GDPR.

8. COOKIES AND SIMILAR TECHNOLOGIES

The Site uses first-party and third-party cookies to: (a) ensure the Site functions correctly, (b) remember preferences (e.g., language), and (c) analyze traffic. Cafeto uses a cookie consent banner allowing you to accept, reject, or configure non-essential cookies before they are set, in compliance with the GDPR/ePrivacy rules and Colombian Decree 1377/2013. For details on the specific cookie categories used, please see the cookie banner on the Site.

9. YOUR RIGHTS UNDER THE GDPR

If you are located in the EEA or UK, you have the right to:

  • Access the personal data we hold about you (Art. 15).
  • Request rectification of inaccurate data (Art. 16).
  • Request erasure of your data ("right to be forgotten") (Art. 17).
  • Request restriction of processing (Art. 18).
  • Receive your data in a portable format (Art. 20).
  • Object to processing based on legitimate interests or for direct marketing purposes (Art. 21).
  • Not be subject to a decision based solely on automated processing, including profiling, that produces legal or similarly significant effects (Art. 22).
  • Withdraw consent at any time (Art. 7.3).
  • Lodge a complaint with your local data protection supervisory authority.

To exercise any of these rights, contact us at [email protected]. We will respond within the timeframes required by the GDPR (generally one month, extendable by two further months for complex requests).

Cafeto has not appointed a representative in the European Union or the United Kingdom under Article 27 of the GDPR or the equivalent provision of the UK GDPR.

10. YOUR RIGHTS UNDER COLOMBIAN LAW

If you are located in Colombia, your rights are governed by Law 1581 of 2012 and Decree 1377 of 2013, and are described in detail in our Spanish-language Aviso de Privacidad, available on this website. In summary, you have the right to know, update, and rectify your data; request proof of your authorization; be informed about the use given to your data; file complaints with the Superintendencia de Industria y Comercio (SIC); revoke your authorization and/or request deletion of your data; and access your data free of charge.

11. DATA RETENTION

We retain personal data only for as long as necessary to fulfill the purposes described in this Policy, or as required by applicable tax, accounting, labor, or commercial regulations, after which it is deleted or anonymized.

12. SECURITY

We implement reasonable technical, administrative, and physical safeguards designed to protect personal data against unauthorized access, loss, misuse, alteration, or disclosure. No method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

13. YOUR CALIFORNIA PRIVACY RIGHTS

Shine the Light. Under California Civil Code Section 1798.83 ("Shine the Light" law), California residents with an established business relationship with us may request information once a year about our sharing of personal data with third parties for those third parties' direct marketing purposes. To make such a request, contact us using the details in Section 16.

Minors' content removal ("eraser button"). Under California Business and Professions Code Section 22581, California residents under the age of 18 who are registered users of the Site may request and obtain removal of content or information they have publicly posted. To request removal, contact us at [email protected], including the email address associated with your submission. This request does not guarantee complete or comprehensive removal, as applicable law may not require or permit removal in all circumstances.

To the extent the California Consumer Privacy Act (CCPA/CPRA) applies to Cafeto's processing of California residents' personal data, California residents also have the right to know, delete, correct, and limit the use of their personal information, and to not be discriminated against for exercising these rights.

14. CHILDREN'S PRIVACY

The Site is intended for business audiences and is not directed to individuals under the age of 16 (or the applicable age of digital consent in your jurisdiction). We do not knowingly collect personal data from children without appropriate parental or guardian consent.

15. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. Material changes will be reflected by updating the "Last updated" date at the top of this document.

16. CONTACT US

If you have questions about this Privacy Policy or wish to exercise your rights, contact us at: [email protected]