Legal
Privacy Policy
Version 1.0
Effective
Privacy Policy
Effective from: November 10, 2026 · Version: 1.0
*This is an English translation of the Spanish text. If the two versions differ, the Spanish version prevails.*
1
Controller and contact
Divergente SAS, tax ID (NIT) 901.481.736-3, registered address Transversal 120 A 129 D 27, Bogotá D.C., email for privacy and Habeas Data (data subject rights under Colombian law): admin@customy.ai. It is the controller of your account data (section 2). Regarding the data of the people who click on our customers' links, the customer is the controller and Divergente SAS is the processor (section 3).
2
Account data (we are the controller)
| Data | Purpose | Basis |
|---|---|---|
| Email, name, organisation, password or access credential (never in the clear) | Create and protect your account, authenticate you, security notices | Performance of the contract |
| Payment and billing data: handled by Wompi and, if enabled, Polar; we receive the payment reference, amount, status and tax data in order to invoice | Charge, issue electronic invoices, prevent fraud | Contract and legal obligation |
| Use of the service: links created, API calls, volume against your plan | Apply plan limits, support, security | Contract and legitimate interest |
| Anti-abuse signals: irreversible hash of the IP, email of the reporter, evidence | Handle reports, protect third parties and the service | Legitimate interest and legal obligation |
| Transactional and security communications | Verify your email, notify you of usage, suspensions, payments | Contract |
| Commercial communications (e.g. about other Customy products) | Only if you authorise them; you can unsubscribe | Consent |
3
Data of people who click your links (we are the processor)
When someone visits a Forklink link, we record for the link owner, depending on their plan: approximate country, region and city, device type, operating system, browser and user agent, referring page, UTM and URL parameters, whether it looks like a robot, the A/B test variant served, and, if the owner configures it, contact or campaign identifiers. We do not store the visitor's IP address in the click record; we use it transiently to limit abuse and estimate location. Technical server logs may include the IP address and are kept for up to 14 days (section 7).
The link owner decides what to do with that information and is the one who must inform people and obtain authorisations where applicable (e.g. if they add third-party pixels such as Meta or TikTok on the intermediate page). We process that data only to provide the service to them, under their instructions and with adequate security measures.
Cookies that may be created when visiting a link: a technical cookie to keep the same variant in A/B tests and a technical cookie to remember that you entered the password of a protected link. They are strictly necessary for those functions.
4
Forklink site and application
We use technical session cookies. To measure the site we use analytics with consent and we respect the Global Privacy Control signal; the data is aggregated and is not used to profile people. You can change your choice at any time from the cookie notice.
5
Who we share data with (processors and providers)
- Infrastructure and platform: Customy (the platform on which Forklink operates) and the cloud infrastructure provider that hosts the servers, engaged by Divergente SAS.
- Payments: Wompi (Colombia) and, if enabled, Polar (merchant of record).
- Security: Cloudflare Turnstile (anti-automation check at sign-up) and Google Safe Browsing: to protect third parties we check destination URLs against Google's lists, which means sending those URLs to Google.
- Email: our sending service (Customy Send), which operates its own mail server.
- Electronic invoicing: DIAN (Colombia's tax authority) and the invoicing software.
- Authorities, when the law requires it. We do not sell your data.
6
International transfers
Some providers are outside Colombia. We transfer data only when an adequate level of protection exists, or with your authorisation, or with the safeguards required by article 26 of Ley 1581 de 2012 (Colombia's personal data protection law).
7
How long we keep data
- Account: while it is active and for up to 12 months after closure; billing data and its supporting documents are kept for as long as tax and commercial rules require (up to 10 years).
- Clicks and analytics: according to your plan: 30 days on the free plan, 1 year on Pro, 2 on Team and 3 on Business.
- Abuse reports and their evidence: up to 24 months.
- Technical server logs: up to 14 days.
8
Your rights (Habeas Data)
As a data subject you may know, update and rectify your data, request proof of the authorisation, be informed of the use we make of it, file complaints with the Superintendencia de Industria y Comercio (SIC, Colombia's data protection and consumer authority), revoke the authorisation and/or request deletion when the principles and guarantees are not respected, and access your data free of charge. Write to admin@customy.ai; we will answer queries within a maximum of 10 business days and claims within a maximum of 15 business days, in accordance with Ley 1581 de 2012. If you are a visitor to a customer's link, you can also contact that customer. If you are in the European Union, the United Kingdom or California, you also have the rights granted to you by the GDPR, the UK GDPR or the CCPA/CPRA.
9
Minors
The service is not directed at people under 18 and we do not knowingly collect data from minors. If you believe a minor has given us data, write to us and we will delete it.
10
Security
We apply reasonable technical and organisational measures: encryption in transit, per-customer data isolation, access control, audit logging, encrypted backups and security reviews. No system is infallible; if an incident affects your data we will notify you as required by law.
11
Changes
If we change this policy in a significant way we will notify you by email or in the application before it takes effect.
12
Language
This policy is provided in Spanish and English. If there is any discrepancy between the two versions, the Spanish version prevails.