Privacy Notice

Last updated: January 29, 2026 Version: 1.0

In accordance with Articles 13, 14, and 15 of Decree 1377 of 2013, which regulates Law 1581 of 2012 (Personal Data Protection Law), Cyclora provides this Privacy Notice to data subjects.

1. Data Controller

• Name: Cyclora
• Address: Bogotá, Colombia
• Contact email: [email protected]
• Data Protection Officer: [email protected]
• Website: https://www.cyclora.app

2. Processing Purposes

Cyclora collects and processes personal data for the following purposes:

2.1 Primary Purposes (Necessary for the service)

• Create and manage your user account
• Provide contracted bicycle management services
• Issue digital property cards with QR codes
• Process payments and issue electronic invoices
• Manage the component and spare parts inventory
• Provide technical support and customer service
• Comply with legal and regulatory obligations

2.2 Secondary Purposes (With your authorization)

• Send commercial and promotional communications
• Perform statistical analysis and service improvements
• Personalize your platform experience
• Share information with commercial partners for relevant offers

3. Personal Data Collected

3.1 Identification Data

• Full name
• Identity document number (CC, CE, Passport)
• Email address
• Phone number

3.2 Account Data

• Username
• Password (stored encrypted)
• Profile photo (optional)

3.3 Bicycle Data

• Brand, model, year
• Serial number
• Color and characteristics
• Photographs
• Maintenance history

3.4 Financial Data

• Payment information processed through MercadoPago
• Transaction and billing history
• Tax data (NIT, tax regime)

3.5 Technical Data

• IP address
• Device type and operating system
• Browsing and platform usage data
• Cookies and similar technologies

3.6 Location Data (Future)

• When GPS functionality is implemented, express and prior authorization will be requested for geolocation data collection

4. Data Subject Rights

As a personal data subject, you have the right to:

• Know the personal data we hold about you
• Update and rectify your personal data
• Request proof of the authorization granted
• Be informed about the use given to your data
• Revoke authorization and/or request data deletion, provided there is no legal or contractual duty preventing elimination
• Access processed personal data free of charge
• File complaints with the Superintendence of Industry and Commerce (SIC) for violations of the law

5. Mechanisms to Exercise Your Rights

To exercise any of your rights, you may:

1. Email: Send a request to [email protected]
2. Platform: From Settings > Privacy > My Data in the application
3. Physical mail: Bogotá, Colombia

Response Timeframes (Decree 1377 of 2013)

6. Persons or Companies with Data Access

Personal data may be shared with:

International data transfers are carried out in accordance with Article 26 of Law 1581 of 2012, to countries that meet adequate levels of protection according to the SIC list, or through standard contractual clauses.

7. Validity

Personal data will be processed while the contractual relationship exists or until the data subject revokes their authorization. Some data may be retained for additional periods in accordance with legal obligations (tax, accounting, fraud prevention).

8. Changes to This Privacy Notice

Any substantial changes to this Notice will be communicated through:

• Email to your registered address
• In-app notification
• Publication on our website

9. Full Privacy Policy

This Privacy Notice is an informational summary. For detailed information on how we process your personal data, see our full Privacy Policy.

10. Supervisory Authority

The data protection authority in Colombia is the Superintendence of Industry and Commerce (SIC):

• Web portal: www.sic.gov.co
• Helpline: 01 8000 910 165
• Address: Carrera 13 No. 27-00, Bogotá D.C.

This Privacy Notice was prepared in accordance with Law 1581 of 2012, Decree 1377 of 2013, and other concordant regulations.