PROAPCI

Bozza in attesa di revisione legale

Personal Data Processing Policy

DRAFT pending legal review. Written in accordance with Colombian Law 1581 of 2012 (Habeas Data), its regulatory Decree 1377 of 2013 (arts. 13 to 15), and Meta Platforms' requirements for apps in Live mode (WhatsApp Business Platform / Instagram Messaging). Validate with a lawyer before publishing. Last revised: 2026-07-17.

1. Data controller

Proapci (Deportecnología / Carbon Manufactory), based in Bogotá D.C., Colombia, and represented by its founder Nicolás Ocampo, is the controller of the personal data you provide through our website (proapci.com), WhatsApp, Instagram, and other channels handled by our team or by our virtual assistant Fibo.

  • Contact email and channel to exercise your rights: info@proapci.com (suggested
  • Registered address: Bogotá D.C., Colombia. [Exact street address and tax ID (NIT) — to

Proapci is a small business whose total assets are below 100,000 UVT, so it is exempt from registering its databases in the National Database Registry (RNBD) administered by the Superintendency of Industry and Commerce (SIC), under Decree 090 of 2018. This exemption does not exempt Proapci from the rest of the obligations under Law 1581 of 2012, its regulatory decree, or this policy.

2. Channels covered by this policy

This policy applies to personal data we collect and process through:

  • The website proapci.com: contact forms, checkout, measurement protocol, and chat with
  • WhatsApp, when you message us or receive messages from us through the WhatsApp
  • Instagram (@proapci), when you send us a direct message, reply to a story, or comment
  • Any other Meta Platforms, Inc. ("Meta") channel we use as a commercial communication

Across all these channels, your conversations may be handled in whole or in part by Fibo, our AI-powered virtual assistant. Fibo always identifies itself as an automated assistant and you may ask to speak with a human team member at any time.

3. Data we collect

  • Identification and contact: name, email, phone/WhatsApp number, shipping address,
  • Order technical data: your bike's brand, model, and year, groupset type, protocol
  • Conversations with Fibo and with the team: chats (web, WhatsApp, and Instagram) are
  • Payment data: processed directly by the payment gateways (Bold, PayPal); Proapci does
  • Basic website navigation data (cookies and basic analytics), to the extent the site

4. Data processors (third parties that process data on our behalf)

To operate the business and provide the service, Proapci relies on the following data processors, each under their own privacy policies and under Proapci's instructions:

  • Anthropic, PBC — provides the artificial-intelligence model that powers Fibo; it
  • Google LLC / Firebase — hosts the website and stores the database where your order and
  • Meta Platforms, Inc. — provides the WhatsApp and Instagram messaging infrastructure
  • Bold and PayPal — process order payments; Proapci only receives the transaction

Proapci requires its processors to implement reasonable security measures and shares only the data strictly necessary for each purpose.

5. Use of artificial intelligence

We expressly inform you that Fibo is a conversational assistant powered by artificial intelligence (Anthropic models). Fibo may read your conversation history to give it continuity, suggest products, and help you complete your purchase. You may ask to speak with a human member of the Proapci team at any time by writing "advisor" (or an equivalent request) in the chat.

6. Purposes of processing

Your personal data is processed to:

  1. Sales and customer service: advise you, verify product compatibility with your bike,
  2. Manufacturing and order management: build your order to your measurements and manage
  3. Customer service and after-sales: contact you about the status of your order,
  4. Compliance with legal, accounting, and tax obligations.
  5. Analytics and service improvement: analyze, in aggregate, the use of the site and
  6. **Marketing and commercial communications — ONLY with your prior, express, and informed

7. Your rights as a data subject

Under Law 1581 of 2012 and its regulatory decree, you have the right to:

  • Know, update, and rectify your personal data.
  • Request proof of the authorization granted to Proapci, except as legally exempted.
  • Be informed, upon request, about how your data has been used.
  • Revoke your authorization and/or request deletion of your data when there is no legal
  • Access your personal data, free of charge, as processed by Proapci.
  • File complaints with the Superintendency of Industry and Commerce (SIC) for violations

How to exercise your rights

Send your request (consultation, claim, update, rectification, deletion, or revocation) to info@proapci.com with the subject "Personal data", indicating your full name, a contact detail, the data concerned, and the specific request. Proapci resolves:

  • Consultations: within a maximum of 10 business days of receipt, extendable by 5
  • Claims: within a maximum of 15 business days of receipt; if the claim is

8. Authorization

The site's forms (fit protocol, checkout, contact, and chat) and your first contact via WhatsApp or Instagram request your express authorization before capturing personal data, and inform you of the purpose of processing. Photos you upload to the protocol or chat are used exclusively for the technical analysis of your order and to let Fibo advise you, unless you authorize an additional use (e.g., marketing or social media).

9. Retention and security

Data is stored with infrastructure providers (Google/Firebase) using encryption in transit and at rest, and is retained while a commercial relationship or legal retention obligation exists, or until you exercise your right to deletion and no legal impediment prevents it.

10. Effective date

This policy is effective as of the last-revised date indicated at the top of this document and may be updated by Proapci at any time by publishing a new version on this same page with its effective date. The databases remain active while the purposes described in section 6 subsist.

11. Privacy notice (short text for data-capture points)

The following notice summarizes this policy and is used wherever we capture data (forms, chat, checkout, and first contact via WhatsApp or Instagram), in accordance with articles 14 and 15 of Decree 1377 of 2013:

Privacy notice. Proapci (Deportecnología), Bogotá D.C., Colombia — info@proapci.com — is the controller of the personal data you provide through this channel. We will use it to advise you, quote, build and manage your order, and provide after-sales service. We will only send you commercial communications if you expressly authorize it, and you may revoke that authorization at any time. Your conversations may be handled by Fibo, our AI-powered assistant. As data subject you may know, update, rectify, and delete your data and revoke your authorization by writing to info@proapci.com. Full policy: proapci.com/legal/privacidad

Minimal version for chat and space-constrained surfaces:

By continuing you accept the processing of your data by Proapci to advise you and manage your order. You are served by Fibo, an AI assistant. Policy: proapci.com/legal/privacidad