Version 1.0 · Effective from: October 12, 2026 The Spanish version is the legally binding text in Colombia; this translation is provided for convenience.

• Legal name: UBIHPC S.A.S
• Tax ID (NIT): 901076538-5
• Registered address: Carrera 17 # 13 - 50, Edificio Smart 17, Torre 2, Apartamento 701, Bucaramanga, Colombia
• Email: contact@ubihpc.com
• Phone: +57 311 290 2902
• Website: https://www.ubihpc.com

UBIHPC S.A.S ("UbiHPC") is the controller of the personal data described in this policy, under Colombian Law 1581 of 2012, Decree 1377 of 2013 (compiled in Decree 1074 of 2015) and the instructions of the Superintendence of Industry and Commerce (SIC).

People whose personal data UbiHPC processes: website visitors, people who write to us, customers and prospective customers, suppliers, partners, job candidates, and users of our products and services.

• Contact and identification data: name, email, phone, company and role.
• Business relationship data: requests, proposals, contracts, invoicing and payments.
• Communications: messages you send us by form, email, WhatsApp or other channels.
• Usage data from the site and our products: IP address, device and browser type, pages visited and activity logs.
• Data about companies from public sources: trade name, website and corporate contact details published by the company itself, with the source and date recorded.

UbiHPC does not ask for sensitive data or data about children or adolescents. If you send it on your own initiative, we use it only to handle your request and delete it when it is no longer needed.

We process personal data to:

1. Answer questions and requests.
2. Prepare proposals, enter into and perform contracts, invoice and collect payment.
3. Provide, operate, maintain and improve our products and services, including those that use artificial intelligence.
4. Send communications about our products and services to people who have authorized them, or to corporate contact details, always with a simple way to stop receiving them.
5. Meet legal, accounting and tax obligations and respond to authorities.
6. Protect the security of our systems and prevent fraud.
7. Manage recruitment and our relationships with suppliers and partners.

We do not sell personal data. We do not make decisions with legal effects on a person based solely on automated processing.

UbiHPC processes personal data with the data subject's prior, express and informed authorization, except where the law does not require it (for example, public data or compliance with a legal duty). We keep proof of the authorization. You may withdraw it at any time, unless a legal or contractual duty requires us to keep the data.

Some of our products use artificial intelligence models to analyze information and draft text. In those cases:

• We process only the data needed for the stated purpose.
• Actions with consequences for third parties (for example, sending a message) go through defined rules and, where appropriate, human approval.
• We do not use one customer's data to serve another customer.
• We follow the criteria of suitability, necessity, reasonableness and proportionality set by the SIC in External Circular 002 of 2024.

When UbiHPC provides services to a client company and, to do so, processes personal data of that company's customers or contacts, the client company is the controller and UbiHPC acts as a processor. In that case we process the data only on the client's instructions and under the data transmission agreement signed with it, and data subjects should address their requests to that company first. UbiHPC will assist it in responding.

• Suppliers acting as processors: cloud hosting, email, messaging, payment processing and artificial intelligence model providers. They receive only the data needed to provide their service and are required to protect it.
• Companies affiliated with UbiHPC: Stellar Mesh Ltd (United Kingdom) and Hackingverse Inc. (United States), when they take part in providing the service.
• Authorities, when the law requires it.

Some suppliers and affiliated companies are outside Colombia, mainly in the United States, the United Kingdom and the European Union. UbiHPC carries out these transmissions and transfers under Article 26 of Law 1581 of 2012 and the SIC's instructions, through contracts that require an adequate level of protection.

You have the right to:

1. Know, update and correct your personal data.
2. Request proof of the authorization you gave.
3. Be informed of how your data has been used.
4. Withdraw your authorization and request deletion of your data, where no legal or contractual duty requires us to keep it.
5. Access your personal data free of charge.
6. File a complaint with the Superintendence of Industry and Commerce after completing the process with UbiHPC.

• Responsible area: Data Protection — UbiHPC
• Channel: privacy@ubihpc.com

Send your request with your full name, a way to reply to you, a clear description of what you are asking for and, if you act on behalf of someone else, the document that proves it.

• Inquiries are answered within ten (10) business days of receipt. If that is not possible, we will tell you why and when we will answer, which will be no more than five (5) additional business days.
• Claims (correction, update, deletion or non-compliance) are answered within fifteen (15) business days of receipt. If that is not possible, we will tell you why and when we will answer, which will be no more than eight (8) additional business days. If a claim is incomplete, we will ask you to complete it within five (5) days of receiving it.

To stop receiving commercial communications, use the link or instruction in each message, or write to the channel above. The request takes effect immediately.

We apply reasonable technical, human and administrative measures to prevent alteration, loss, and unauthorized consultation, use or access: access control, encryption in transit, activity logging, backups and supplier management. If a security incident affects personal data, we will report it to the SIC and to the affected people as the regulations require.

Our site uses cookies needed for it to work and, with your acceptance, measurement cookies. You can decline them in the site notice or in your browser settings.

We keep data for as long as the purpose it was collected for lasts and, after that, for the time required by applicable accounting, tax and contractual rules. After that time we delete or anonymize it.

This policy applies from the date shown at the top. The databases remain in effect while the purposes described continue. We will publish any substantial change on this site before applying it.