In the event of an interpretative discrepancy, the Spanish version shall prevail for relationships governed by Guatemalan law, except where a specific valid agreement provides otherwise.
No provision is intended to exclude non-waivable rights or limit liability where the law does not permit such limitation.
Identification of the responsible entity
| Trade name | ADIONC INTEGRATED SOLUTIONS |
|---|---|
| Legal nature | Individually owned commercial enterprise (empresa mercantil individual) |
| Owner | Angel Danilo Patzal Crúz |
| Commercial Registry | Registration 1251026 · Folio 144 · Book 1289 of Commercial Enterprises |
| Registration date | September 7, 2026 |
| Business location | Escuintla, Guatemala |
| Corporate contact | legal@adioncsolutions.com |
This policy covers the corporate website and institutional contacts. It does not replace future specific policies for UA Control, UA Operación, Payments/Billing, FEL or other products that process additional categories of data.
Privacy principles adopted by ADIONC
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| Principle | Commitment |
|---|---|
| Necessity and proportionality | Request only information reasonably connected with the stated purpose. |
| Transparency | Clearly explain what information is processed, why and with whom it may be shared. |
| Purpose | Avoid uses incompatible with the original purpose unless there is authorisation or a sufficient legal basis. |
| Security | Apply reasonable technical and organisational measures according to the risk. |
| Limited retention | Keep information for the time necessary or legally required, rather than indefinitely by default. |
| Control and traceability | Provide mechanisms for enquiries, correction and deletion where appropriate. |
| Third-party responsibility | Select suitable technology providers and limit access to what is necessary. |
1. Purpose
This Policy describes how ADIONC receives, uses, retains, protects and shares personal information associated with its corporate website adioncsolutions.com and institutional or commercial communications received through official channels.
ADIONC adopts these commitments as a corporate privacy standard, without prejudice to additional obligations that may arise from laws, contracts, regulated sectors, international relationships or specific products.
2. Scope and exclusions
The Policy applies to Website visitors, people who contact ADIONC, representatives of customers or prospective customers, providers, partners and other people who interact with general corporate channels.
It does not fully cover processing carried out by UA Control, UA Operación, platforms with authentication, payments, billing, operational services, continuous geolocation data, insurance policies, photographic evidence or other specialised features. Such processing must be governed by specific policies before launch.
3. Entity responsible for processing
The entity responsible for information processed by the corporate Website is ADIONC INTEGRATED SOLUTIONS, an individually owned commercial enterprise in Guatemala, owned by Angel Danilo Patzal Crúz.
Privacy contact: legal@adioncsolutions.com. This is the designated corporate channel for requests relating to privacy and the processing of personal information within the scope of this Policy.
4. Categories of information we may process
Depending on the interaction, ADIONC may receive identification and contact information, professional or business information, communication content, voluntarily submitted documentation and technical information generated by the infrastructure.
- Identification and contact: first name, surnames, email address, telephone number or other contact details voluntarily provided.
- Professional information: company, position, department, country, industry or relationship with an organisation.
- Enquiry information: messages, requests for proposals, technical needs, meetings, documents or attachments provided by the sender.
- Contractual or commercial information: where a discussion progresses to a proposal or contract, information needed to prepare documents, verify the counterparty, issue quotations or manage the relationship.
- Technical information: IP address, date/time, requested resource, user agent, HTTP status, security events, access logs and server errors.
- Technical preferences: language selected through the first-party adionc_lang cookie.
- Third-party information: only where the sender is authorised to provide it and it is relevant to the purpose of the interaction.
5. Information we do not request through the corporate website
The corporate Website is not designed to receive full payment card numbers, CVVs, passwords, private keys, medical records, biometric data, system credentials, critical trade secrets or highly sensitive information that is unnecessary for a general enquiry.
Users must avoid sending such information through public email unless ADIONC has established a secure channel and there is a legitimate need. If ADIONC receives unsolicited information, it may restrict access to it, request that it be resent through an appropriate channel, return it or delete it where reasonable and legally permitted.
6. Sources of information
ADIONC obtains information directly from the person making contact, from their organisation, from technical records generated by use of the Website, from technology providers necessary for communication or security and, where relevant, from legitimate public or professional sources used to verify a commercial relationship.
ADIONC does not state that it purchases personal databases or markets contact lists obtained from third parties.
7. Purposes of processing
- Responding to enquiries, requests for information, meetings and communications.
- Preparing proposals, estimates, demonstrations, scopes of work and precontractual discussions.
- Managing customers, providers, partners, integrations and B2B relationships.
- Operating, maintaining, diagnosing and protecting the Website and associated infrastructure.
- Detecting abuse, fraud, unauthorised access attempts, malware or security incidents.
- Retaining evidence of communications, decisions and obligations where a commercial or legal relationship exists.
- Complying with commercial, tax, administrative or regulatory obligations or valid requests from authorities.
- Defending rights, addressing complaints, bringing legal actions or responding to proceedings.
- Improving internal processes and developing solutions, using aggregated or non-identifiable information where possible.
- Sending communications directly related to a relationship or request; any additional marketing must respect applicable preferences and rules.
8. Grounds for processing and privacy expectations
ADIONC shall process information where necessary to address a request made by the person concerned, prepare or perform a contractual relationship, comply with legal obligations, protect systems and legitimate rights, or where consent or another valid authorisation exists.
This Policy is not intended to automatically import legal categories from foreign legislation that does not apply; however, ADIONC may voluntarily adopt more protective privacy standards as a corporate practice.
9. Technical logs and security
Servers and security mechanisms may record technical access data. These logs are used for operations, diagnosis, abuse prevention, forensic analysis and security.
ADIONC shall endeavour to restrict access to logs to personnel or providers who need them and retain them only for the period reasonably necessary, except in the event of incidents, investigations, legal requirements or evidentiary needs.
10. Email and corporate communications
Emails addressed to ADIONC may be processed through corporate email providers and stored according to account settings and the needs of the relationship. Senders should assume that ordinary email is not an appropriate channel for secrets of the highest sensitivity, unless encryption or an agreed mechanism is in place.
ADIONC may retain communications relevant to demonstrating agreements, requests, authorisations, support or commercial decisions.
11. Cookies and similar technologies
The Website currently uses a first-party cookie named adionc_lang to remember the language preference. Its operation is described in the Cookies Policy.
According to the architecture currently verified, the Website does not integrate advertising networks, advertising pixels, external fonts or third-party analytics tools. If non-essential technologies are introduced, this Policy and the Cookies Policy must be updated before or when they are activated.
12. Service providers and processors
ADIONC may rely on providers of infrastructure, email, domain/DNS, security, storage, communications, development, support, professional services and other necessary functions.
Those providers may access or process information only to the extent necessary to provide the corresponding service, subject to their terms, security measures and, where appropriate, contractual confidentiality obligations.
13. Categories of recipients
- Technology providers necessary for hosting, email, infrastructure, DNS, security and operations.
- Legal, accounting or tax advisers, auditors or consultants subject to confidentiality duties.
- Counterparties or providers where necessary to evaluate or fulfil a request and where there is a basis for sharing the information.
- Administrative, judicial, tax or regulatory authorities where a valid request or legal duty exists.
- Acquirers, successors or participants in a business reorganisation, to the extent legally permitted and with appropriate safeguards.
14. No sale of personal information
ADIONC does not sell personal information collected through the corporate Website or market visitor databases as a standalone product.
Sharing information as necessary to provide a service, use infrastructure or fulfil a request is not considered a sale of personal data.
15. International transfers and processing
Some technology providers may operate servers, personnel or infrastructure outside Guatemala. Consequently, certain data may be processed or stored in other countries.
ADIONC shall endeavour to select reasonable providers, limit data to what is necessary and use appropriate contractual or technical mechanisms where warranted by the nature of the information. A specific international commercial relationship may incorporate additional data protection provisions.
16. Retention and deletion
ADIONC does not intend to retain personal information indefinitely. The period shall be determined according to the purpose, the existence of a commercial relationship, the need for support, security or defence of rights, commercial or tax obligations and any applicable legal requirement.
Enquiries that do not lead to a subsequent relationship may be deleted or archived when they are no longer reasonably necessary. Technical logs shall be retained for operational and security periods unless they must be preserved because of an incident or investigation. Commercial and contractual documents may be retained for the periods necessary for legal, accounting, evidentiary or defence obligations.
When a person requests deletion, ADIONC shall evaluate the request and may retain information that must be kept due to a legal obligation, fraud prevention, security, the exercise or defence of rights, contractual compliance or equivalent legitimate reasons.
17. Security measures
ADIONC adopts an approach to security proportionate to risk. Measures may include HTTPS, access controls, minimum permissions, environment separation, backups, security logs, software updates, perimeter protection, monitoring and response procedures.
No system is invulnerable. Accordingly, ADIONC does not promise absolute security, but does commit to reasonable and ongoing efforts consistent with the nature of the information and available technology.
18. Security incidents
If ADIONC identifies an incident compromising personal information, it shall assess its scope, take containment and recovery measures, document what occurred and make any legally required communications or notifications.
The existence of a technical event does not necessarily mean that unauthorised access to personal data has occurred; each incident shall be assessed on the evidence.
19. Individuals' rights and requests
Without prejudice to rights recognised by applicable rules, ADIONC offers mechanisms for requesting information, updates, corrections, rectification or deletion of personal data associated with the corporate Website.
Requests may be sent to legal@adioncsolutions.com. ADIONC may ask for reasonable information to verify identity and prevent one person from obtaining or modifying another person's data.
20. Limits on requests
ADIONC may reject or limit a request where identity cannot be verified, it affects third-party rights, involves disclosure of trade secrets or security information, conflicts with a legal retention obligation, interferes with proceedings, is manifestly abusive or where another legitimate and legally permitted reason exists.
Where reasonable, the reason for the limitation shall be explained.
21. Minors
The corporate Website is primarily intended for businesses, institutions, professionals and people interested in technology solutions. It is not designed to deliberately collect information from minors.
Future products that may be used by minors must have specific assessments, controls and policies in place before launch.
22. Automated decisions and artificial intelligence
The current corporate website does not use automated decisions that produce legal effects for visitors. Commercial references to artificial intelligence do not mean that the Website automatically makes decisions concerning eligibility, credit, insurance, employment or individuals' rights.
If AI features that process personal data or produce significant effects are implemented in the future, ADIONC must update the documentation and apply specific controls.
23. Links and third parties
Third-party websites have their own privacy practices. ADIONC does not control data collection carried out by a third party once a visitor leaves the Website. Reviewing their policies before providing information is recommended.
24. B2B relationships and professional contact details
In business relationships, ADIONC may process data of an organisation's representatives, employees or professional contacts to manage the relationship. An organisation providing such data must have authorisation or an appropriate basis for doing so.
Where a business customer instructs ADIONC to process data on its behalf within a product, roles, instructions, security and responsibilities must be defined through the corresponding contract or processing agreement.
25. Changes to this Policy
ADIONC may update this Policy following changes to legislation, architecture, providers, purposes, products or practices. The date and version shall be updated in the document.
Material changes affecting products with accounts or specific processing may require additional notices or acceptance in accordance with applicable rules and the contract.
26. Contact and version control
Contact: legal@adioncsolutions.com. Version 1.0 — September 15, 2026 — Initial corporate policy for ADIONC WEB 1.0. Effective date: upon publication, once approved.
Summary data matrix for the corporate website
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| Context | Data | Purpose | Retention criterion |
|---|---|---|---|
| Email / enquiry | Name, email, company, message, voluntary attachments | Respond, assess needs, prepare a relationship | According to the needs of the relationship and legal obligations |
| Web access | IP, date/time, resource, browser, response codes | Operations, diagnosis, security | Reasonable operational period; longer if an incident occurs |
| Language preference | adionc_lang cookie | Remember ES/EN | 12 months from creation/renewal |
| B2B relationship | Professional contact, company, position, communications | Commercial and contractual management | For the duration of the relationship and the legally or evidentially necessary period |
Regulatory framework and official reference sources
Including a source does not mean that all of its rules apply to every interaction. Specific obligations depend on the service, the nature of the user, the territory and the applicable contract.
1. Commercial Enterprise Registration Certificate (Patente de Comercio de Empresa) — ADIONC INTEGRATED SOLUTIONS. Foundational corporate document identifying the responsible entity. Official source
2. Political Constitution of the Republic of Guatemala. Constitutional framework concerning correspondence, communications, privacy and records. Official source
3. Constitutional Court — case law on informational self-determination. Constitutional criteria relating to private life, dignity, honour, privacy and data processing. Official source
4. Decree 47-2008. Recognition of electronic communications and signatures. Official source
5. Decree 6-2003. Consumer and User Protection Law; transparency, information and user rights. Official source
6. Decree 2-70. Commercial Code of Guatemala; commercial obligations and documentation. Official source