Privacy

Privacy Policy

We take your privacy seriously. This policy explains what data we collect, why we collect it, and how we protect it.

Last revised: July 31, 2026 · Effective: July 31, 2026 · Version 2.0

Reference translation. The Spanish version of this Policy is the sole governing version. This English text is provided for convenience only; in the event of any discrepancy, the Spanish version prevails.

This Privacy Policy applies to all information collected through our website, our platform, and any related service, sales, marketing, or event activity. It supplements the Terms of Service and uses the same defined terms. By using the Services you agree to the collection and use of information in accordance with this Policy.

Encrypted

Data encrypted at rest and in transit.

Never sold

Your data is never sold to third parties.

Your control

Delete or export your data at any time.

01

Who We Are

The Services are operated by Victor Manuel Peña Jacquet, trading as Triple Impacto AI, a sole proprietorship registered in Paraguay under RUC 4867264-5, with domicile at Demetrio Ortiz Vargas [NUMBER — TBD], Asunción, Paraguay. References to "Triple Impacto AI", "we", "us", or "our" in this Policy refer to that entity. For any matter relating to this Policy, write to legal@tripleimpact.site.

02

Who This Policy Is About

The account holder

The account unit on our platform is the individual seller. A Customer is a natural or legal person lawfully engaged in vehicle sales, whether working independently or within a dealership. Where a seller operates inside a dealership, the account belongs to the person or entity identified as account holder under Section 03 of the Terms; the dealership does not obtain access to the account or to its data by reason of the employment or commercial relationship alone.

End customers

This Policy also describes how we handle data about the people the Customer contacts through the platform — its own prospects and buyers. Those people are not our customers. The Customer decides who to contact and why; we process that data on the Customer's instructions.

Minors

The Services are directed exclusively at persons aged 18 or over. We do not knowingly collect personal data of minors. If we become aware that we hold data of a minor collected through an account, we will delete it.

03

Information We Collect

Information you provide

When you create an account or use the Services we collect your name, email address, telephone number, the name of the dealership you operate from where applicable, tax identification where required for invoicing, and billing details. We also collect the data you upload to the platform, including vehicle inventory, contact details of your prospects, and conversation histories.

Information collected automatically

We automatically collect your IP address, browser type, operating system, pages visited, time spent on pages, and other usage data. We use cookies and similar technologies to collect part of this information, as described in Section 09.

WhatsApp and messaging data

To provide the messaging service we process the messages sent and received through the messaging line assigned to your account, including message content, timestamps, and associated contact details. This data is processed in order to generate replies and to maintain your conversation history, and is stored under the security measures described in Section 06.

Payment data

Billing and payment data is collected and processed by Paddle.com, our authorised reseller and merchant of record. We do not store full card details on our servers. Paddle's own privacy policy governs the processing of your payment data.

04

Data Processing Roles

Where you are the controller

In relation to the personal data of your prospects, buyers, and other contacts that you upload, import, or generate on the platform, you act as data controller and we act as data processor. We process that data solely on your instructions and for the purpose of providing the Services. You decide what data to load, on what lawful basis, for how long, and when to delete it.

Where we are the controller

In relation to your own registration, billing, support, and account usage data, we act as controller and process it for the purposes set out in Section 05.

Your responsibility for the data you upload

Under Section 05 of the Terms you represent that you hold a sufficient lawful basis and the consent of each person you contact through the platform. We do not verify the origin of the contacts you upload, and we cannot assess whether a given contact consented to be messaged. Responding to a request from one of your contacts — access, correction, deletion, or a request to stop being contacted — is your responsibility. If such a request reaches us directly, we will forward it to you and assist you in giving effect to it.

05

How We Use Your Information

Providing and improving the Services

We use your information to operate and maintain the platform, process transactions, send service communications, and respond to support requests. We also use aggregated and anonymised data, which does not permit identification of you or of your end customers, to improve platform features and quality. We do not use your identifiable business data to train general-purpose models without your express consent.

Communications

We may send you transactional email — account confirmations, invoices, security notices, changes to these documents — and, with your consent, marketing communications about new features and offers. You may opt out of marketing email at any time through the unsubscribe link. Transactional email cannot be opted out of while your account is active, because it forms part of the service.

Analytics and security

We use usage data to understand how the platform is used, identify faults, measure the effectiveness of features, and detect fraud, abuse, or attempts at unauthorised access.

Legal obligations

We process data where necessary to comply with accounting, tax, and other legal obligations applicable to us in Paraguay.

06

Sharing and Sub-Processors

We do not sell your data

We do not sell, rent, or trade your personal data or that of your contacts, and we do not share it with third parties for their own advertising purposes.

Sub-processors

We share data with providers who help us operate the platform, including hosting and infrastructure, the messaging interface, underlying technology providers, payment processing (Paddle), email delivery, and analytics. These providers act on our instructions, are bound to protect the data, and may only use it to provide services to us. The current list of sub-processors is available on request, as is a data processing agreement for customers subject to a regime that requires one. We will give reasonable notice of any change of sub-processor that materially affects the processing of your data.

WhatsApp Business API

The Services operate on messaging infrastructure owned by Meta Platforms. Conversation data processed through that integration is also subject to Meta's own policies, over which we have no control, in addition to this Policy. We recommend reviewing Meta's privacy policy.

Legal requirements

We may disclose information where required by law, in response to valid legal process, or where we consider disclosure necessary to protect the rights, property, or safety of Triple Impacto AI, its customers, or the public. Where we are permitted to do so, we will notify you before disclosing.

Business transfers

In the event of a merger, acquisition, or sale of all or part of our business, your information may be transferred as part of that transaction. We will notify you by email or by prominent notice on the platform.

International transfers

Your data may be processed by our providers in countries outside Paraguay. We take reasonable steps to ensure that such transfers comply with applicable data protection law and that the data continues to be protected to an adequate standard.

07

Data Security

How we protect data

We apply reasonable technical and organisational measures, including encryption at rest, TLS in transit, access controls, and periodic security reviews. Production infrastructure is hosted in certified data centres. No system is entirely immune from risk, and we do not warrant that a security incident can never occur.

Incident notification

In the event of a security incident affecting your personal data or that of your contacts, we will notify you without undue delay and no later than 72 hours after becoming actually aware of it, describing the nature of the incident, the categories of data affected, and the measures adopted. We will notify the competent authorities where applicable law so requires. Where you are the controller of the data affected, notifying the individuals concerned is your responsibility, and we will provide you with the information you need to do so.

08

Retention and Deletion

While your account is active

We retain your account data for as long as the account remains active or as long as necessary to provide the Services. Conversation histories are retained for 24 months by default and this period may be configured at account level.

After termination

Following termination you may request an export of your content within 30 calendar days. After that period we will delete the content from our active systems within 90 calendar days, and from backups in accordance with our ordinary retention cycles. We retain billing records for as long as tax and accounting law requires, and we may retain data necessary for the defence of a legal claim. Aggregated and anonymised data, which does not permit identification of you or of your end customers, may be retained indefinitely.

Deletion requests

You may request deletion of your personal data at any time by writing to legal@tripleimpact.site. We will process the request within 30 calendar days, subject to any legal obligation requiring us to retain particular records, and we will tell you what has been retained and why.

09

Your Rights

Access and control

You have the right to access, correct, delete, and export your personal data; to object to or restrict certain processing; and to withdraw a consent you have given, without that withdrawal affecting the lawfulness of processing carried out beforehand. To exercise any of these rights, write to legal@tripleimpact.site. We will respond within 30 calendar days. We may ask you to verify your identity before acting on a request.

Complaints

If you consider that we have not handled your data correctly, we ask you to contact us first so that we can resolve the matter. This does not prevent you from lodging a complaint with the competent authority in your jurisdiction or from bringing an action before the courts.

Do Not Track

The platform does not respond to Do Not Track browser signals at this time. You can manage cookie preferences through your browser settings.

10

Cookies

Types of cookies we use

We use strictly necessary cookies, required for the platform to function; performance cookies, to understand usage patterns; and functionality cookies, to remember your preferences. We do not use third-party advertising cookies.

Managing cookies

You can control cookie settings through your browser preferences. Disabling certain cookies may affect the functionality of the platform.

11

Changes to This Policy

We may update this Policy from time to time. We will notify you of material changes by posting the revised version on this page with an updated revision date and, where appropriate, by email at least 30 days before the changes take effect. Continued use of the Services after that date constitutes acceptance of the revised version.

12

Contact

For any question, concern, or request relating to this Policy or our data practices:

Triple Impacto AI — Victor Manuel Peña Jacquet (sole proprietorship)

Tax ID (RUC): 4867264-5

Address: Demetrio Ortiz Vargas [NUMBER — TBD], Asunción, Paraguay

Email: legal@tripleimpact.site

Questions about your privacy?

legal@tripleimpact.site

© 2026 Triple Impacto AI · Victor Manuel Peña Jacquet