Privacy Policy

and Personal Data Protection

Version 1.0 · Last updated: July 7, 2026

At Corporate TIC Latam S. de R.L. (“Corporate TIC,” “we,” “us”) we protect the privacy of our customers and users. This Policy describes how we collect, use, store, share, and protect the personal data processed through tic.com.pa and our services.

We comply with Law 81 of March 26, 2019 on Personal Data Protection of the Republic of Panama and its Executive Decree 285 of May 28, 2021, as well as the European Union’s General Data Protection Regulation (GDPR), where applicable to data subjects in that territory.

1. Data Controller

Corporate TIC Latam S. de R.L., a Panamanian company. For privacy matters, please use the contact form on the website, selecting the subject “Data Protection.”

2. Personal Data We Collect

2.1 Identification and contact

Name or company name, national ID or RUC (tax ID), address, email address, and phone number.
Details of the contact person and legal representative, for business customers.

2.2 Billing and payment

Billing data and purchase history. We do not store full card numbers; card payments are processed through secure gateways (PCI-DSS).

2.3 Technical and usage data

IP address, browser and device, access logs, service configuration (domains, mailboxes, servers), and cookies.

2.4 Data you host on our services

Email content (WorkMail), files on hosting/servers, and backups. We act as data processors and do not access them except to operate or support the service, or when legally required.

3. Purposes of Processing

Register the account and activate, provide, and manage the contracted services.
Process payments, issue invoices, and manage renewals (including the month 11 notice for annual plans).
Provide technical support and customer service.
Send operational communications, security notices, and renewal notifications.
Send commercial communications where consent exists; you may opt out at any time.
Comply with legal, accounting, tax, and regulatory obligations.
Prevent fraud and ensure information security.

4. Legal Basis

Performance of a contract: to provide the services you purchase.
Consent: for commercial communications and non-essential uses of cookies.
Legal obligation: to comply with tax, accounting, and data protection regulations.
Legitimate interest: for security, fraud prevention, and improvement of the services.

5. Principles We Apply

In accordance with Law 81 and its regulations, we process data under the principles of fairness, purpose limitation, proportionality, accuracy, security, transparency, confidentiality, lawfulness, and portability.

6. Data Subject Rights

Access: to know what data we process, and its purpose and origin.
Rectification: to correct inaccurate, incomplete, or outdated data.
Cancellation / Erasure: to have your data deleted when it is no longer necessary or you withdraw your consent.
Objection: to object to certain processing, such as commercial communications.
Portability: to receive your data in a structured, commonly used format.
Restriction: to restrict processing in the cases provided by law.

To exercise these rights, use the contact form with the subject “Data Protection,” verifying your identity. We will respond within the applicable legal deadlines.

7. Data Retention

We retain data for as long as a contractual relationship exists and for the periods required by legal, accounting, and tax obligations.
Once those periods have elapsed, data is securely deleted or anonymized.
Content hosted on canceled or unpaid services may be deleted after the applicable retention period.

8. Transfers and Data Processors

To provide our services, we may share data with processors and providers that act under instructions and confidentiality agreements:

Cloud infrastructure: Amazon Web Services (AWS) and Microsoft Azure.
Databases and deployment: Supabase and Vercel.
License manufacturers: Microsoft, BlackBerry, Acronis, Lookout, and RPost.
Payment gateways and electronic invoicing providers.

For international transfers, we verify that the destination offers standards comparable to those of Law 81, or we adopt the necessary safeguards (contractual clauses, consent, or other legal exceptions), in accordance with Law 81, its regulations and, where applicable, the GDPR.

9. Information Security

Encryption in transit (TLS/HTTPS) and role-based access controls.
Backups, monitoring, segmentation, and infrastructure hardening.
Internal confidentiality policies and least-privilege access.
Providers with recognized security certifications.

In the event of a security breach affecting personal data, we will notify the competent authority and the affected data subjects within the deadlines and under the conditions required by applicable regulations.

10. Cookies

We use first-party and third-party cookies for the operation of the site, analytics and, with your consent, marketing.
You can manage or reject non-essential cookies through the consent banner or your browser.

11. Minors

Our services are intended for adults and businesses. We do not intentionally collect data from minors; if we detect data from a minor without authorization, we will delete it.

12. GDPR (European Union)

When we process data of data subjects in the European Union, we will additionally comply with the GDPR: lawful bases for processing, enhanced data subject rights, breach notification and, where applicable, the appointment of a representative or processor with the required safeguards.

13. Supervisory Authority

In Panama, the competent authority is the National Authority for Transparency and Access to Information (ANTAI). If you believe your rights have not been properly addressed, you may file a complaint with that authority, without prejudice to first contacting us to resolve your request.

14. Changes to this Policy

We may update this Policy to reflect legal or operational changes. The current version, with its update date, will always be available at tic.com.pa/en/privacidad.