Privacy Policy and Personal Data Processing

1. Identification of the Data Controller

• Legal name: Fluxora Studio
• Tax ID (NIT): 901488208-8
• Registered address: Carrera 42 # 10-44, Medellín, Colombia
• Contact email (Habeas Data channel): hello@fluxora.tech

2. Regulatory Framework and Artificial Intelligence Governance

This policy is governed by Statutory Law 1581 of 2012 and Decree 1074 of 2015, and is aligned with the principles of ethics, transparency and algorithmic risk mitigation set out in SIC External Circular 002 of 2024 and CONPES Document 4144 of 2025 on Artificial Intelligence.

3. Processing and Purposes

Fluxora Studio collects, stores, uses and transmits personal data (including private and commercial data) for the following exclusive purposes:

• Interacting with the user through the Artificial Intelligence assistant "ADA".
• Qualifying commercial enquiries, profiling business needs and scheduling consultations.
• Briefing the assigned human consultant through AI-generated contextual summaries.
• Complying with the legal, accounting and tax obligations arising from the commercial relationship, under Colombian law.

Algorithmic Transparency

ADA uses natural language processing models. Nevertheless, Fluxora Studio guarantees that no automated decisions producing adverse legal effects on the data subject are taken without the possibility of review by a human advisor.

4. Processing of Sensitive Data (Voice Biometrics)

Using the ADA assistant requires the temporary capture of the user's voice, which is considered sensitive biometric data under Colombian law.

Optional Nature

The data subject has the inalienable right not to authorise the processing of their voice. Fluxora Studio guarantees alternative channels (email) without such refusal conditioning access to consulting services.

Privacy by Design

The captured voice is processed in real time for transcription into text. Fluxora Studio has implemented "Zero Retention" configurations with its AI providers, ensuring that raw audio files are neither permanently stored nor used for training third-party models.

5. International Data Transmission

For the operation of its cloud (SaaS) infrastructure, Fluxora Studio transmits data to technology providers (Data Processors) located in the United States of America (a jurisdiction with an adequate level of protection under SIC Circular 005 of 2017). This transmission is governed by Data Processing Agreements (DPAs) requiring providers to maintain the confidentiality and security of the information and prohibiting its use for purposes other than those instructed by Fluxora Studio.

6. Data Subject Rights (Habeas Data)

As the owner of the information, you have the right to:

• Access, update and rectify your personal data.
• Request proof of the authorisation granted (cryptographic evidence of consent).
• Be informed about the use given to your data.
• Revoke the authorisation and/or request deletion of the data (Right to be Forgotten), provided no legal or contractual duty prevents such deletion.

7. Procedure for Exercising Rights

Enquiries and claims must be sent to hello@fluxora.tech.

• Enquiries: answered within a maximum of ten (10) business days.
• Claims (deletion/revocation): answered within a maximum of fifteen (15) business days, pursuant to Article 15 of Law 1581 of 2012.

8. Effective Date and Information Retention Policy

This Privacy and Personal Data Processing Policy takes effect as of 5 August 2026.

In strict compliance with the principles of temporality and necessity, Fluxora Studio applies the following retention periods:

• Commercial prospects (leads): the personal data and interaction summaries of users who engage with ADA but do not enter into a commercial relationship with Fluxora Studio will undergo automatic and definitive purging and deletion within a maximum of six (6) months from their last interaction.
• Active clients: the data of users who acquire our services will be retained throughout the contractual relationship and, thereafter, for a period of ten (10) years in order to comply with legal, accounting and tax obligations under Colombian law.