Privacy Policy

§ 1Who we are

Peregrino is a digital transformation and agentic services consultancy. We design the architecture, build or integrate the solution, and operate customer journeys end to end. We work through two companies.

The company answerable to you is the one that signed the agreement with the relevant client. These pages refer to both as Peregrino. Write to info@peregrino.co if you need to know which applies to a particular case.

§ 2Our role: processor, not controller

In most cases Peregrino decides nothing about the personal data it handles. Our clients, which are businesses, decide what data they collect from their own customers and why. Peregrino handles it on their documented instructions and nothing else.

Under Colombia's Ley 1581 de 2012, our client is the Controller and Peregrino is the Processor.

If you messaged a company on WhatsApp and landed here, the policy governing that conversation is that company's, not ours. Write to us and we will point you to them.

Peregrino acts as Controller only for what we collect on our own account: contact and demo requests on peregrino.co, commercial contact details, and our own team's data.

§ 3What we handle on behalf of clients

When we operate the WhatsApp Business Platform or other channels for a client, we may handle:

We do not ask for sensitive data. If someone volunteers it in a message, it falls under the same restricted-access and deletion rules set out here.

§ 4What we use it for

• Sending and receiving messages on the client's WhatsApp Business Account, so their customers get an answer.
• Carrying out the actions the client authorised inside the conversation: checking availability, creating or changing a booking, handing over to a person.
• Creating and managing message templates on the client's behalf.
• Keeping the account operationally healthy and reporting metrics such as response times and resolution rates back to the client.
• Technical support, error detection and security.

What we do not do. We do not sell personal data. We do not use it for our own advertising. We do not combine one client's data with another's. We do not use a client's conversation content to train general purpose models or to benefit a third party.

§ 5Meta and the WhatsApp Business Platform

Peregrino is registered with Meta as a Tech Provider for the WhatsApp Business Platform. To deliver the service we access, through Meta's APIs and with the client's authorisation, the WhatsApp Business Account the client owns and controls.

• The client keeps ownership of its account and phone numbers, and can revoke our access at any time from its Meta business portfolio.
• Meta's own handling of messages is governed by Meta's policies. See the WhatsApp Privacy Policy.
• We use data obtained from Meta's APIs solely to provide the service to the client that owns that data, in line with the Meta Platform Terms.

§ 6Sub-processors and vendors

We rely on vendors that may handle data on our behalf, always under contractual confidentiality and security obligations equivalent to our own: cloud and database providers, language model providers used to generate replies, observability and support tooling, and whichever CRM or messaging platform the client itself specifies. We give the current list to any client who asks.

Some vendors sit outside Colombia. Where that means an international transfer, we make it with the safeguards Ley 1581 de 2012 requires and on the client's instructions.

§ 7Retention and deletion

We keep data handled for a client for as long as the contract runs and for whatever period the client instructs. When the relationship ends, and absent a legal obligation to the contrary, we delete or return the data within 90 days.

Individual requests follow the data deletion procedure.

§ 8Security

We apply encryption in transit and at rest, least-privilege access control, logical separation of each client's data, access logging and periodic credential review. No system is infallible. If an incident affects personal data we notify the client without undue delay, so they can meet their reporting duties to the Superintendencia de Industria y Comercio and to the people affected.

§ 9Your rights

Ley 1581 de 2012 gives you the right to know, update, correct and delete your data, to ask for proof of the authorisation you gave, to be told how your data has been used, to complain to the Superintendencia de Industria y Comercio, and to withdraw your authorisation.

If Peregrino handled your data as Processor, go first to the company you were talking to, which is the Controller. Write to us directly and we will tell you who to approach and pass your request along within 5 business days.

If you live in California and Peregrino Digital Inc. handled your data, you can exercise the CCPA rights to know, to delete and to opt out of sale. Peregrino does not sell personal data.

§ 10What we collect on peregrino.co

For this site Peregrino is the Controller. We collect what you submit in the contact or demo form: name, company, email, industry and your message. We use it to reply and to manage the commercial relationship. We use HubSpot as our CRM. We use no advertising or third-party profiling cookies.

§ 11Changes

We publish any material change on this page with a new effective date. Where a change materially affects processing carried out for a client, we tell that client directly.

§ 12Contact

Write to info@peregrino.co or to Calle 104 13 A 46, Bogotá D.C., Colombia. WhatsApp: +57 316 289 26 94. We answer in Spanish and English.