01. Controller and definitions
Pailebote Digital, S.A.S. de C.V. (“Pailebote Digital”), with Mexican tax registration number (RFC) PDI260826M60 and its address at Hamburgo 182, Piso 4, Interior 400, Colonia Juárez, Alcaldía Cuauhtémoc, C.P. 06600, Ciudad de México, México, is the controller of the personal data it obtains through pailebote.com.mx and pailebote.digital (the “Site”) and the emails it receives concerning its services.
In this notice, “Data Subject” means the natural person to whom the personal data relate, whether they visit the Site, communicate with Pailebote Digital on their own behalf or on behalf of an organisation, or are part of a services relationship.
All communications concerning this notice must be addressed to contacto@pailebote.com.mx.
When Pailebote Digital provides services involving the processing of personal data on a client's behalf, the terms of that processing will be established in the relevant contract.
02. Personal data processed
Browsing. As with any web server, the infrastructure that delivers the Site receives technical data for each request, such as the IP address, date and time, requested page and information sent by the Data Subject's browser.
Communications. When the Data Subject writes to Pailebote Digital, it receives their email address, name, organisation name if included, message content, attachments and email metadata.
Services relationship. If a contract is entered into, Pailebote Digital also processes the identification, contact and billing data needed to formalise and perform it.
Pailebote Digital does not request sensitive personal data. Data Subjects are advised not to include passwords, identity documents or third-party information unnecessary for their enquiry in their messages.
03. Purposes
Pailebote Digital processes personal data to answer enquiries, prepare proposals, follow up on conversations and, where applicable, formalise, perform and invoice the services contract. Technical data are used to operate the Site and email and protect them against abuse.
All these purposes are necessary to handle the Data Subject's request or the services relationship. Contacting Pailebote Digital does not enrol anyone in advertising or marketing lists. Any different purpose will require the Data Subject's prior consent.
04. Use of artificial intelligence in email
To organise incoming emails, Pailebote Digital uses an artificial intelligence system that analyses the sender, subject, text and metadata of each message and generates a summary. The system does not open attachments or send replies.
A person authorised by Pailebote Digital reviews each request, has access to the original message and decides how to handle it. Pailebote Digital does not make decisions based solely on automated processing.
05. Cookies
The Site does not use first-party cookies, advertising, analytics tools or tracking pixels, and does not save information on the Data Subject's device. The Cookies and technology page provides more detail.
06. Processors and data locations
Pailebote Digital relies on hosting, email and artificial intelligence providers that process personal data on Pailebote Digital's behalf, under its instructions and contractual confidentiality and data-protection obligations. Data are processed in the locations set out below.
- Browsing. The Site is hosted on servers located in the United States, where browsing data are processed.
- Email. Messages are stored on servers located in Mexico.
- Artificial intelligence. The system described in section 04 operates on servers located in the United States, where the data it analyses and the summaries it generates are processed. The artificial intelligence provider does not use the messages to train its models and may retain them for up to thirty days for abuse prevention.
- Handling enquiries. Pailebote Digital personnel in Mexico are responsible for reading and replying to messages.
Pailebote Digital does not sell or rent personal data, and does not transfer them to third parties except where the law does not require the Data Subject's consent, such as complying with a request from a competent authority, performing a contract entered into in the Data Subject's interest or defending a right in proceedings.
07. Retention and security
Pailebote Digital retains conversations for as long as needed to handle the Data Subject's request. Those that do not result in a contract are retained for up to twelve months after the last communication, unless there is a legal obligation or a pending dispute. Contractual and tax information is retained for the periods established by law. Once those periods end, the data are deleted or blocked for the period required by law before their erasure.
The artificial intelligence system deletes its copy of the message when the analysis is complete and retains summaries for up to ninety days, unless they relate to a pending matter.
Providers may retain technical logs and backup copies for the periods provided for in their own terms.
Pailebote Digital applies administrative, technical and physical security measures proportionate to the data it processes.
08. Data Subject's rights
Data Subjects have the right to access, rectify or cancel their personal data or object to their processing (ARCO rights), as well as to withdraw consent and limit the use or disclosure of their data.
To exercise any of these rights, the Data Subject or their representative must email contacto@pailebote.com.mx with the subject “Privacidad”, stating the Data Subject's name, a means of receiving a reply, the right they wish to exercise and information that allows the data to be located. For rectification, they must specify the correction requested. If proof of the Data Subject's identity or the representative's authority is needed, Pailebote Digital will explain the procedure; an official identity document must not be sent in the first message.
Pailebote Digital will communicate its response within a maximum of twenty business days from receipt of the request and, if the request is granted, will implement it within the following fifteen business days. These periods may be extended once by an equal period when circumstances justify it. Exercising these rights is free of charge; only reproduction, copying or delivery costs may be charged.
If the Data Subject considers that their request was not handled in accordance with the Federal Law on the Protection of Personal Data Held by Private Parties (Opens in a new tab), they may contact the Secretaría Anticorrupción y Buen Gobierno (Ministry of Anti-Corruption and Good Governance).
09. Data Subjects outside Mexico
This notice applies to all Data Subjects, regardless of their country of residence. Pailebote Digital will also respect any additional rights granted to them by applicable law.
Legal bases. Processing is based on taking pre-contractual steps at the Data Subject's request and performing the services contract; on Pailebote Digital's legitimate interest in replying to those who write to it and in operating and protecting the Site; and on compliance with legal obligations, such as tax obligations.
Additional rights. Depending on applicable law, Data Subjects may request data portability or restriction of processing, and lodge a complaint with their country's data-protection authority. Pailebote Digital does not sell or share personal data for targeted advertising and will not treat Data Subjects differently for exercising their rights.
International transfers. When data are processed outside the Data Subject's country, Pailebote Digital uses providers that offer appropriate safeguards, such as standard contractual clauses.
10. Changes to this notice
Pailebote Digital will publish any changes to this notice on this page, with their update date. If a change requires the Data Subject's consent, it will be requested before the change is applied.