Privacy Policy

Effective Date: December 29, 2025 Legal Entity: Grupo Gedeon S.A. ("Neurona")

1. About this Privacy Policy and Legal Framework Your privacy is a priority for Neurona (Grupo Gedeon S.A.). This Privacy Policy sets out the basis on which we collect, use, process, and store your Personal Information in strict adherence to Law 81 of 2019 and Executive Decree 285 of 2021 of the Republic of Panama.

2. Data Controller Grupo Gedeon S.A. is the data controller of your Personal Information.

3. Personal Information We collect data necessary to provide our digital services (Web/App Development, E-commerce, Infrastructure, and Brand Design).

  • Identifiers: Name, company name, email, phone number, and IP address.
  • Commercial Information: Services purchased or considered, such as SaaS development, hosting plans, or UI/UX audits.
  • Internet Activity: Browser type, device identifiers, and interaction with our portals.
  • Geolocation Data: City and state related to your IP address.

4. How We Use Your Personal Information (Purposes) We process data to fulfill the following business purposes:

  • Service Fulfillment: To develop custom software, manage e-commerce stores, and execute brand strategies.
  • Infrastructure Support: To manage DevOps, cloud hosting, and provide 24/7 technical assistance.
  • Communication: To respond to inquiries regarding MVP development or digital transformation.
  • Security: To protect our technical property and comply with legal obligations.

5. Legal Basis for Processing Under Panamanian Law, we rely on:

  • Consent: Your unequivocal authorization for marketing or newsletters.
  • Performance of a Contract: Necessary to deliver the technical services contracted.
  • Legal Obligation: To comply with fiscal or regulatory requirements in Panama.
  • Legitimate Interest: To ensure the security and performance of our infrastructure.

6. International Data Transfers We share your Personal Information globally with affiliates and service providers (including AWS, Google, Microsoft, Cloudflare, DigitalOcean, and OVH) to support our infrastructure. We ensure these transfers maintain a level of protection equivalent to Panamanian law through technical measures like encryption.

7. Your Rights (ARCO Rights) Under Law 81, you have inalienable rights. We will satisfy your requests within the following legal timelines:

  • Access: Right to know what data we hold. (Response: 10 business days).
  • Rectification: Right to correct inaccurate data. (Response: 5 business days) .
  • Cancellation: Right to request deletion of data, subject to legal retention. (Response: 5 business days).
  • Opposition: Right to refuse processing for specific purposes like marketing. (Response: 5 business days).
  • Portability: Right to receive your data in a structured, electronic format.

8. Use of Services by Children (Minors) Our services are strictly directed to individuals 18 years of age or older. We do not knowingly collect Personal Information from minors under 18 in the Republic of Panama. If we become aware that we have collected data from a minor without verifiable parental or guardian consent, such information will be deleted immediately. Parents or legal guardians may exercise ARCO rights on behalf of the minor.

9. Data Security and Retention We implement technical and administrative measures, including encryption and pseudonymization, to protect your data. We retain Personal Information only as long as necessary to fulfill the service or as required by Panamanian fiscal law.

10. Oversight Authority The National Authority for Transparency and Access to Information (ANTAI) oversees data protection in Panama. You may file a claim with them if your rights are infringed.