Personal Data Processing Policy

Focus Bogotá, identified with NIT pendiente de confirmar and domiciled at Dirección legal pendiente de confirmar, acts as the Data Controller for personal data collected through the Focus founders registration form.

Requests related to this policy and to the exercise of habeas data rights are received at hola@focusboxgym.com.

Through the form we may collect name, email address, phone or WhatsApp number, location of interest, language, registration source, date and time of consent, and technical or campaign data needed to understand where the request came from.

We do not request sensitive data in the founders form. If a person voluntarily includes it in a message, we will process it only when needed to handle their request and under the applicable safeguards.

We use the data to manage interest in the founders campaign, contact the registered person, send confirmations or operational information, coordinate payments or memberships when applicable, respond to requests, and keep evidence of the authorization granted.

We may also use aggregated or statistical data to measure campaign performance and improve Focus operations, without identifying people when identification is not necessary.

The basis for processing is the prior, express, and informed authorization that the Data Subject gives by checking the consent box during registration.

The person may choose not to grant authorization, but in that case we will not be able to process the registration or contact them about the founders offer.

We keep the data while managing the founders campaign, during the commercial relationship if one is created, and for up to five (5) years after the last contact to meet administrative, accounting, legal, or legal-defense obligations.

When the Data Subject requests deletion or revokes authorization, we will delete or anonymize the data if there is no legal or contractual obligation requiring us to keep it.

We share data only with providers that support the service operation: Supabase, Inc. to host the database and form records; Vercel Inc. to host the application and process technical logs; and Resend to send transactional emails and notifications.

These providers act as processors or infrastructure providers under Focus Bogotá's instructions and only for the purposes described. We do not sell databases or share data for purposes unrelated to this policy.

Under Law 1581 of 2012, the Data Subject may know, update, and rectify their data; request proof of the authorization granted; be informed about the use of their data; revoke authorization; request deletion when applicable; access their data free of charge; and file complaints with the Superintendence of Industry and Commerce when appropriate.

Revocation or deletion will not apply when there is a legal or contractual duty to keep the information.

Consultations and claims are submitted by email to hola@focusboxgym.com and must include the name, contact details, a clear description of the request, and documents that allow verification of the Data Subject's identity or representation when applicable.

Consultations will be answered within a maximum of ten (10) business days, extendable by five (5) additional business days. Claims for correction, update, deletion, or revocation will be answered within a maximum of fifteen (15) business days, extendable by eight (8) additional business days, with the reason for the extension communicated before the original deadline expires.

If a claim is incomplete, we will request the missing information within the following five (5) business days. If no response is received within the following two (2) months, the claim will be understood as withdrawn.