# Actib Privacy Policy

**Version:** DRAFT v0.2 · updated 14 October 2026

This Policy describes how Actib handles Personal Data when a person visits actib.app, requests a demo, creates or manages a business account, contacts support or deals directly with Actib.

This is an English translation of the Spanish original, which is the reference text. It is a draft pending legal review.

## 1. Controller

- Legal name: `ACTIB TECHNOLOGIES, S.EP.`
- Trade name: Actib
- RUC: `155790094-2-2026`
- Domicile: Panama City, Republic of Panama
- Privacy email: `support@actib.app`

`[LEGAL REVIEW]` Confirm whether the law requires publishing the full domicile. The full address and the telephone number are not published on this site by decision of the owner.

## 2. Scope

This Policy applies to data that Actib handles on its own account about:

- visitors to its sites;
- prospects;
- restaurant representatives;
- dashboard users;
- support contacts;
- people who accept terms;
- billing and administration of the B2B relationship;
- Instagram professional accounts that a restaurant connects to Actib (see the [Instagram and Meta Annex](/en/legal/instagram-meta)).

Data of end consumers processed mainly on behalf of a restaurant is also governed by the restaurant's own notice and the applicable DPA.

## 3. Data we may collect

### Information provided directly

- name;
- email;
- phone;
- job title;
- restaurant or company;
- billing data;
- support messages;
- information included in demo or onboarding forms.

### Account and security information

- UID;
- tenant and branch identifiers;
- sign-in records;
- IP address;
- device and browser;
- security events;
- version of the terms accepted;
- date and time of acceptance.

### Information from connected Instagram accounts

When a restaurant connects its Instagram professional account, Actib processes the account's ID and username, an access token (stored encrypted), the direct messages and comments received, with the ID and username of whoever sent them, and post drafts. The detail, the roles and how to delete them are in the [Instagram and Meta Annex](/en/legal/instagram-meta).

### Technical information

- logs;
- errors;
- performance metrics;
- product events;
- cookies or similar technologies if used.

`[PENDING]` Audit the real analytics, pixels and cookies before publishing.

## 4. Purposes

Actib may use this data to:

- create and manage accounts;
- provide support;
- manage sales and demos;
- authenticate users;
- protect the platform;
- invoice and collect payment;
- send service notices;
- comply with legal obligations;
- keep contractual evidence;
- improve the product through reasonable analytics;
- prevent fraud or abuse;
- communicate commercial news where a valid legal basis exists.

## 5. Legal bases

Depending on the case, Actib may process data because:

- consent exists;
- it is necessary to perform a contractual relationship;
- there is a legal obligation;
- another applicable rule authorizes the processing.

Where processing depends on consent, Actib will try to keep traceable evidence of it and allow its withdrawal where applicable.

## 6. Marketing

Actib will not use contact data for promotions that are incompatible with the purpose communicated.

People may ask to stop receiving promotional communications through the mechanisms included in the message or by writing to `support@actib.app`.

Transactional, security or contractual messages needed to provide the Service are not promotions and may continue while they are necessary.

## 7. Who we share data with

Actib may share data with providers that support:

- cloud infrastructure;
- authentication;
- communications;
- payments;
- maps;
- support;
- analytics;
- AI;
- invoicing;
- security;
- messaging, including WhatsApp and Instagram (Meta Platforms).

Identifiable personal databases will not be sold to advertisers.

The list of main providers is kept at `[URL PENDING]`. Meanwhile see [Subprocessors](/en/legal/subprocessors).

## 8. International transfers

Some providers may process data from other countries. Actib will take reasonable measures so that these transfers comply with applicable law.

## 9. Security

Actib uses reasonable technical and organizational measures, which may include:

- access controls;
- authentication;
- encryption in transit;
- secrets management;
- logical isolation per customer;
- monitoring;
- restrictions on sensitive credentials;
- incident response.

No system can guarantee zero risk.

## 10. Retention

`[CRITICAL: PENDING]`

Actib will keep Personal Data for as long as needed for the purposes communicated, legal obligations, security, invoicing and defense of claims.

Before final publication there must be an internal table with periods per category.

## 11. Data subject rights

People may exercise the rights recognized by Panamanian law, including access, rectification, cancellation and objection where applicable.

Requests: `support@actib.app`. To request deletion of WhatsApp or Instagram data, see the [Data Deletion Instructions](/en/legal/actibot/data-deletion).

Actib may require reasonable information to verify identity and avoid handing data to an unauthorized person.

## 12. Restaurant consumers' data

When a person places an order with a restaurant that uses Actib:

- the restaurant normally determines the commercial purpose of the processing;
- Actib processes data to provide the technology infrastructure;
- requests about commercial history, promotions or the relationship with the restaurant may require coordination with that restaurant;
- the same applies to the messages and comments a person sends to the Instagram account of a restaurant connected to Actib.

## 13. Minors

Actib is a B2B platform for restaurants and is not designed to deliberately collect data of minors on its own account.

`[LEGAL REVIEW]` Orders by minor consumers or data of minors processed by restaurants must be assessed according to the real operation and the applicable rules.

## 14. Changes to this Policy

Actib may update this Policy. Material changes will be communicated reasonably and a version history will be kept.

## 15. Contact and complaints

- Privacy and support: `support@actib.app`

Data subjects may also go to the Autoridad Nacional de Transparencia y Acceso a la Información (ANTAI), in accordance with applicable law.