Draft: this document is a starting template pending legal review.
Privacy policy
Last updated: [A COMPLETAR POR EL ABOGADO: publication date].
This policy explains what personal data SMRTRACE processes on this website and on the ACTIVE platform, why, who it is shared with and how you can exercise your rights under Argentine Personal Data Protection Law 25,326.
Who is responsible
SMRTRACE ([A COMPLETAR POR EL ABOGADO: legal name, tax ID and address]) is responsible for the data collected on this website, such as the "Request a demo" form.
For the data our customers upload or sync into ACTIVE (purchase orders, suppliers and their contacts, communications), the customer is the controller and SMRTRACE processes it on the customer's behalf. [A COMPLETAR POR EL ABOGADO: confirm roles and the data processing agreement].
What data we collect
"Request a demo" form: name, company, email, phone (optional) and your message. It is sent by email to our sales team; it is not stored in the platform.
ACTIVE user accounts: name, email, password (stored as a hash, never in plain text), two-step verification settings (encrypted) and session data (IP address, browser and usage dates).
Activity log: actions inside ACTIVE are recorded in an audit log (who did what and when).
Customer operational data: purchase orders read from the customer's SAP, suppliers and their representatives' contact details (name, email, phone and position), and the emails exchanged with them about each order.
Preferences: the language and theme you choose are stored in your own browser.
Why we use it
To answer demo requests and contact you; to provide the service (purchase order tracking, alerts, delivery performance indicators and supplier evaluation); to keep accounts secure (authentication, two-step verification, abuse prevention and auditing); and to understand how the website is used through analytics, only if you accept it.
[A COMPLETAR POR EL ABOGADO: legal basis for each purpose].
Who we share it with
Microsoft (Entra ID and Microsoft Graph): to sign in with the corporate account and to send emails to suppliers from the user's mailbox, when the customer enables it.
OpenAI: to interpret supplier replies (confirmed dates and updates), when the feature is enabled.
Hosting and infrastructure provider: [A COMPLETAR POR EL ABOGADO: name and server location].
System email provider (invitations, password recovery): [A COMPLETAR POR EL ABOGADO: name].
Google Analytics: website usage statistics, only if you accept analytics cookies.
Other services used only when enabled: Meta (WhatsApp Business) and an error monitoring service. [A COMPLETAR POR EL ABOGADO: confirm the final list of subprocessors].
Some of these providers process data outside Argentina. [A COMPLETAR POR EL ABOGADO: international transfers (section 12 of Law 25,326) and applicable safeguards].
Cookies and browser storage
We use a technical cookie to keep you signed in to ACTIVE; the platform cannot be used without it. Language and theme are remembered in your browser storage.
Google Analytics cookies are only enabled if you accept them in the cookie notice. You can change your choice at any time from "Cookie preferences" at the bottom of the site.
How long we keep it
[A COMPLETAR POR EL ABOGADO: retention periods per data type].
The audit log is designed so it cannot be altered. [A COMPLETAR POR EL ABOGADO: how this is reconciled with deletion requests].
How we protect it
Passwords stored as hashes, encrypted secrets, mandatory two-step verification, database-level isolation of each company's data and an audit log of actions.
Your rights
You can request access to, correction, update or deletion of your personal data by writing to [A COMPLETAR POR EL ABOGADO: privacy contact email]. If your data was uploaded by your employer, an ACTIVE customer, we may forward the request to them. [A COMPLETAR POR EL ABOGADO: timelines and procedure].
Argentina's Agency for Access to Public Information (AGENCIA DE ACCESO A LA INFORMACIÓN PÚBLICA), as the supervisory authority under Law 25,326, is empowered to handle complaints and claims from anyone whose rights are affected by non-compliance with data protection rules.
Changes to this policy
If we change this policy, we update the date above. [A COMPLETAR POR EL ABOGADO: how customers and users are notified].

