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.
For relationships governed by Guatemalan law, the Spanish version serves as the reference, unless otherwise validly agreed.
1. Identification of the controller
| Trade name | ADIONC INTEGRATED SOLUTIONS |
|---|---|
| Legal form | Sole proprietorship |
| Owner | Angel Danilo Patzal Crúz |
| Commercial Registry | Registration 1251026 · Folio 144 · Book 1289 of Commercial Enterprises |
| Registration date | September 7, 2026 |
| Business address | Escuintla, Guatemala |
| Privacy contact | legal@adioncsolutions.com |
2. Privacy overview
UA Control uses data to create and protect your account, identify your vehicles, locate and coordinate assistance, manage incidents and evidence, send notifications, operate Memberships and payments when enabled, prevent fraud, provide support and meet legal obligations. ADIONC does not sell Users’ personal data or use precise location for location-based advertising.
3. Scope
This Policy applies to UA Control, web resources specifically linked to the UA Control account, and processing carried out by ADIONC to operate the service for end users.
It does not replace the corporate Privacy Policy for adioncsolutions.com, future UA Operación policies, or data processing agreements that may be entered into with business customers, insurers or other organizations. Where a specific B2B relationship exists, roles and responsibilities may be supplemented by contract.
4. Information we collect and how we use it
UA Control may collect or process the following categories when the relevant feature is enabled or the User provides the information. Not all categories are collected in every interaction.
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| Category | What it may include | How we use it |
|---|---|---|
| Account and identity | First and last name, email address, telephone number, internal user identifier, account status and data needed for authentication. | Create the account, identify the User, authenticate access, protect the account, provide support and maintain traceability of relevant actions. |
| Profile and preferences | A profile photograph if the User chooses to add one, language, settings and preferences. | Personalize the experience and display the selected settings. |
| Vehicles | License plate, make, model, type, color or other characteristics registered by the User. | Identify the vehicle associated with a request, determine the type of resource required, manage history and facilitate assistance. |
| Insurance policies and coverage | Insurer, policy number or reference, coverage or equivalent data when registered by the User or provided through an authorized integration. | Verify or coordinate benefits and coverage where an enabled relationship or integration exists. Recording this information does not mean that ADIONC guarantees validity or coverage. |
| Location and geolocation | GPS coordinates, confirmed location, assistance point, origin, destination, route or geographic context. | Display maps, locate an event, coordinate assistance, assign resources, calculate routes and enable tracking when required by the feature. |
| Assistance requests | Service type, event description, date and time, location, vehicle, status, assigned resource and traceability. | Receive, assess, coordinate, assign, perform and follow up on assistance. |
| Incident reports | Accident, delay, construction, closure, object on the road or other categories; description, location and evidence. | Record incidents, support operational context and display relevant information where applicable. |
| Photographs and evidence | Images, files or descriptions voluntarily attached by the User. | Assess the event, prepare the appropriate resource, document assistance, handle claims, prevent fraud and maintain traceability. |
| Memberships | Plan, validity, benefits, usage, limits, renewals and Membership status. | Manage eligibility, benefits, limits, renewals and use of included services. |
| Payments and invoicing | Amount, currency, transaction status, processor reference or token, billing information and receipts. | Process charges, reconcile payments, manage refunds, issue tax documents, handle disputes and prevent fraud. |
| Device and security | IP address, operating system, UA Control version, device model where technically necessary, logs, authentication events, technical identifiers and notification token. | Security, fraud prevention, diagnostics, compatibility, support, incident investigation and notification delivery. |
| Communications | Support messages, emails, requests for help, service-related communications and operational records where the channel exists. | Respond to inquiries, resolve incidents, document decisions, provide support and maintain evidence of the relationship. |
| Usage and performance | Technical events, errors, screens or features used when technical instrumentation is enabled. | Improve stability, detect errors and assess performance, security and the product experience. This Policy must be updated where appropriate before third-party analytics are used. |
5. How we obtain information
5.1 Information provided directly by the User
Account and contact details, profile photograph, vehicles, insurance policies, requests, descriptions, evidence, billing information and any information the User chooses to register voluntarily.
5.2 Information obtained from the device or app
Location when permission is granted and the feature requires it, IP address, logs, app version, notification token, errors and security events.
5.3 Information received from third parties
Data returned by payment processors, map providers, operational providers and, where a formal and authorized integration exists, insurers, banks, assistance networks or other organizations.
ADIONC does not obtain information from an insurer, bank or other organization merely because the User is that entity’s customer. Exchanges must occur only where an applicable integration, contractual relationship, authorization, instruction or other basis exists.
6. General purposes of processing
- Create, verify, manage and protect the UA Control account.
- Identify the User and associated vehicles.
- Display maps, location, routes and geographic context when required by the feature.
- Receive, assess, coordinate, assign, perform and follow up on assistance requests.
- Manage incident reports, photographs and other evidence.
- Manage Memberships, benefits, eligibility and limits when enabled.
- Process, reconcile and document payments, refunds and invoicing when enabled.
- Send necessary notifications about the account, security, requests and service status.
- Handle support, claims, chargebacks, investigations and disputes.
- Detect and prevent fraud, abuse, impersonation, unauthorized access and security incidents.
- Comply with legal, tax and regulatory obligations and valid requests from authorities.
- Improve the product through technical metrics, aggregated analysis or minimized data where possible.
7. Location and geolocation
UA Control may request location access while the User uses features that depend on it, such as maps, event location, roadside assistance, routes, geolocation and operational coordination.
Precise location will not be used for location-based advertising. The app must request only the level of permission necessary for the specific feature.
If ADIONC needs background location in the future, it must update this Policy, establish the technical need for the feature, obtain the relevant permissions and meet applicable Google Play, Apple and legal requirements before enabling it.
8. Vehicles, insurance policies and coverage
Vehicle data is used to identify the vehicle involved, determine the appropriate resource and facilitate assistance. Users must provide reasonably accurate information and be authorized to register the vehicle.
Policy or coverage information will be used only for the disclosed purposes, such as validation or coordination of benefits where an applicable integration or agreement exists. Merely registering a policy in UA Control does not confirm its validity, coverage, eligibility or the insurer’s authorization.
9. Assistance requests, incidents and evidence
Assistance requests and incident reports may contain operational information, location, event type, vehicle details, photographs and traceability records. ADIONC uses this data to assess the need, coordinate resources, document assistance and resolve claims.
Users must avoid attaching photographs or third-party information that is unnecessary for the purpose of the event. Where an image contains third-party data, ADIONC will limit its use to handling the request, security, claims, fraud or compliance where applicable.
10. Device permissions
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| Permission | When it may be requested | Purpose |
|---|---|---|
| Location | When using maps, assistance or geographic features. | Locate the event, display context and coordinate services and routes. |
| Camera / photos | When the User wishes to attach evidence. | Capture or select evidence related to the request or incident. |
| Notifications | When the User enables app notifications. | Service status, security, account and transactional communications. |
| Other permissions | Only if a future feature needs them. | The purpose must be explained before requesting permission. |
UA Control must not request access to contacts, microphone, general files, continuous location or other permissions unless a clear and necessary feature justifies them.
11. Memberships, payments and financial data
When Memberships or individual payments are enabled, ADIONC will use the information needed to manage the plan, record benefits, process charges, reconcile transactions, issue receipts, manage refunds and handle disputes.
The planned architecture aims to use tokenization or processor references so that ADIONC does not store full card numbers or CVV codes. This model is subject to technical validation of the final integration with NeoNet or another provider; it does not represent confirmation of the final processor or of an implementation already in operation.
ADIONC may retain transaction references, amounts, statuses, receipts and other information required for reconciliation, support, fraud prevention, accounting and tax obligations.
12. Technical information, logs and security
UA Control and its infrastructure may generate technical records to maintain the service, detect errors, authenticate sessions, investigate incidents, prevent fraud and protect the platform.
These records may include IP address, date and time, app version, operating system, authentication events, errors, notification token and other information strictly necessary for diagnostics and security.
13. Who we share information with
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| Type of third party | What it may receive | Why |
|---|---|---|
| Operational provider | Name or minimum identifier required, location, vehicle, service type, instructions and essential evidence. | Perform or coordinate the requested assistance. |
| Payment processor | Data needed to process the transaction under its integration. | Process charges, tokenization, reconciliation, fraud prevention and refunds. |
| Maps and geolocation | Coordinates, addresses or technical data required by the service. | Display maps, geocode, calculate routes or provide geographic context. |
| Integrated insurer or network | Data needed to validate or coordinate coverage where an agreement, authorization or applicable relationship exists. | Manage benefits or services linked to coverage. |
| Infrastructure and communications | Data hosted or technically processed. | Hosting, security, email, messaging, notifications and continuity. |
| Professional advisers | Strictly necessary information. | Legal, accounting, security or audit advice, or protection of rights. |
| Authorities | Information requested through a valid or legally enforceable request. | Compliance with legal obligations and proceedings. |
14. What we do not do with your data
- ADIONC does not sell UA Control Users’ personal information as a product or commercial database.
- ADIONC does not use the User’s precise location for location-based advertising.
- ADIONC does not request indiscriminate access to contacts, microphone, photographs or other device resources when a feature does not require them.
- ADIONC does not intend to store CVV codes or full card numbers under the planned tokenization model.
- ADIONC does not share data with insurers, banks or other entities merely because the User is their customer; there must be an applicable purpose, relationship or integration.
15. Artificial intelligence and automation
UA Control and ADIONC’s ecosystem may incorporate artificial intelligence tools for assistance, summarization, classification, analysis, support or process automation.
ADIONC will not use an AI feature as the sole basis for decisions with significant legal effects on the User without additional controls, appropriate information and review when needed. New AI features that use personal data must be reflected in this Policy.
16. Aggregated data, statistics and product improvement
ADIONC may produce metrics, statistics and aggregated or de-identified analyses to assess operations, performance, demand, security and design. Minimized or aggregated data will be used whenever reasonably possible, and no attempt will be made to re-identify information that has been effectively de-identified.
17. International transfers and providers
Some infrastructure, map, email, notification, payment or other service providers may process information outside Guatemala. ADIONC will seek to select suitable providers, limit information to what is necessary and apply contractual, technical and organizational measures proportionate to the risk.
18. Information retention
ADIONC will retain information only for as long as necessary for its purpose, the contractual relationship, security, support, tax or legal obligations, fraud prevention, claims and protection of rights. Definitive retention periods remain subject to validation against ADIONC Core and actual operations before launch.
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| Category | Retention criterion | Note |
|---|---|---|
| Account and profile | While the account is active plus the closure/deletion period. | Subject to data that must be retained by law. |
| Vehicles | While maintained by the User or needed for history or service. | Information may be de-identified where appropriate. |
| Location | Only for the period necessary for the feature, service, security or claim. | Avoid unnecessary retention of precise location. |
| Requests and evidence | Operational period plus the applicable legal, contractual or evidentiary period. | An archiving policy must be defined for each service type. |
| Payments and invoicing | In accordance with tax, accounting, anti-fraud and reconciliation obligations. | Do not retain CVV codes. |
| Security logs | A reasonable technical period; longer where an incident or investigation exists. | Restricted access. |
| Aggregated / de-identified data | For as long as useful for legitimate analysis. | Must not allow reasonable re-identification. |
19. Information security
ADIONC will apply technical and organizational measures proportionate to the nature of the information and the risk. These may include encryption in transit, access controls, least privilege, logical separation, secrets management, security logs, backups, software updates, perimeter protection and incident response procedures.
No Internet-connected system can guarantee absolute security. ADIONC will review its controls as the platform evolves.
20. Security incidents
Where ADIONC identifies an incident affecting personal information, it will assess its scope, take containment and recovery measures, document the event and make any notifications or communications legally required or reasonably necessary according to the risk.
21. Account and data deletion
Users may initiate account deletion through UA Control and the external web resource provided by ADIONC. Deletion will cover associated data that need not be retained for a legitimate reason.
Account deletion does not necessarily mean immediate deletion of tax records, transactions, services, anti-fraud evidence or information that must be retained for legal obligations, security, claims or the protection of rights. These categories will be restricted to the purpose that justifies retention.
The UA Control Account and Data Deletion Policy explains this process in greater detail.
22. User rights and requests
- Request information about data associated with their account.
- Correct or update inaccurate information.
- Request account and data deletion where appropriate.
- Request clarification about the use or sharing of information.
- Manage device permissions through the operating system.
- Opt out of promotional communications where they exist, without affecting necessary transactional messages.
Requests may be sent to legal@adioncsolutions.com. ADIONC may verify the requester’s identity before providing, modifying or deleting information to protect the User and third parties.
23. Limitations on certain requests
ADIONC may retain or restrict information where required for a legal obligation, outstanding invoicing or tax documentation, fraud prevention, a security investigation, a dispute, the exercise or defense of rights, protection of third parties or another legitimate reason. Where reasonable, the reason for the limitation will be explained.
24. Minors
UA Control is initially intended for persons over eighteen years of age. If ADIONC detects an account created by a minor outside an authorized mechanism, it may suspend the account and take reasonable steps to delete the information or bring its handling into compliance. If features for minors are enabled in the future, specific controls and notices will be developed before launch.
25. Changes to this Policy
ADIONC may update this Policy following changes to features, data categories, providers, integrations, legislation, security or the operating model.
Where a change is material and significantly affects data processing or requires additional consent or acceptance, ADIONC will inform the User through the app, email or another appropriate mechanism before applying the new purpose where applicable.
26. Contact
Privacy and legal matters: legal@adioncsolutions.com
General contact: info@adioncsolutions.com
27. Version control
ADIONC-LEGAL-UA-PRIV-001 · Version 1.0 · Prepared on September 18, 2026 · Effective date pending approval and commercial launch.
Annex A. Data processing matrix
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| Data | Main purpose | Potential recipients | Retention |
|---|---|---|---|
| Account and identity | Account, authentication, support and security | Infrastructure, support, authorities where applicable | Account lifetime plus legitimate obligations |
| Vehicle | Assistance, identification and eligibility | Operational provider; integrated insurer where applicable | As long as needed plus legal/evidentiary history |
| Location | Maps, event location, coordination and routes | Maps/geolocation; operational provider | Minimum necessary for the feature, service or claim |
| Request / evidence | Assessment, coordination, performance, claims and traceability | Operational provider; integrated insurer; advisers where applicable | Operational plus legal/evidentiary period |
| Membership | Benefits, limits and renewal | Payment processor where applicable | Validity period plus legal/commercial obligations |
| Payment | Collection, reconciliation, refund and invoicing | Payment processor; accounting; authorities where applicable | Tax/accounting/anti-fraud period |
| Device / logs | Security, diagnostics, fraud prevention and support | Infrastructure and security | Reasonable technical period; longer if an incident occurs |
| Communications | Support, service status and contractual evidence | Communications providers and authorized personnel | According to the relationship and evidentiary need |
Official reference sources
1. DIACO — Consumer and User Protection Law. Official source
2. DIACO — Standard-form consumer contracts. Official source
3. Decree 47-2008 — Electronic Communications and Signatures. Official source
4. Google Play — User Data. Official source
5. Google Play — Account Deletion. Official source
6. Apple App Review Guidelines. Official source