Terms & conditions and personal-data processing policy
Last updated: September 24, 2026
These terms and this personal-data processing policy (the “Policy”) govern the collection and processing of the data you provide to request your participation in the ApoloFX program as a cardholder. ApoloFX is operated by Piensa IT. By ticking the authorization box and submitting the form, you confirm you have read and accepted this Policy.
1. Definitions
Data Subject: the natural person whose data is processed. Controller: ApoloFX (Piensa IT). Processor: a party that processes data on the Controller’s behalf. Personal Data: any information linked to or that can be associated with an identified or identifiable person. Processing: collection, storage, use, circulation or deletion. Program: the ApoloFX card waitlist and application process.
2. Data controller
The controller is ApoloFX, operated by Piensa IT. Contact and channel for data-rights requests: [email protected].
3. Legal framework and scope (multi-country)
We process your data in accordance with the data-protection law applicable to your country of residence, including, among others: in Colombia, Law 1581 of 2012 and Decree 1074 of 2015; in the European Union/EEA, Regulation (EU) 2016/679 (GDPR); in the United Kingdom, the UK GDPR and Data Protection Act 2018; in México, the Federal Law on Protection of Personal Data Held by Private Parties; and equivalent laws in other countries. Where these conflict, we apply the standard most protective of the Data Subject.
4. Data we collect
The data you enter in the form: full name, email and location (city and country). If you arrive from an invitation, the associated referral code. Minimal technical data needed to operate and protect the service (e.g. browser language, approximate IP and analytics usage data). We do not collect sensitive data or financial information at this stage.
5. Purpose of processing
We process your data to: (a) validate and manage your request to participate in the ApoloFX program as a cardholder; (b) inform you about the status of your request, your spot and the launch; (c) run the referral program (generate your code, attribute invitations and apply benefits); (d) send you communications related to the program. We will not use your data for different purposes without your prior authorization.
6. Authorization and legal basis (habeas data)
By ticking the authorization box and submitting the form, you give your free, prior, express and informed consent to process your data for the purposes described. In jurisdictions such as the EU/EEA and UK, the legal basis is your consent and the taking of pre-contractual steps at your request. You may withdraw your authorization at any time.
7. No disclosure to third parties
We do not sell, rent or disclose your personal data to third parties for commercial or advertising purposes. Your data is only processed by our processors (technology providers acting on the Controller’s behalf and instructions, under confidentiality and security obligations), solely to operate the program. We will only disclose data where a competent authority requires it under the law, or to protect legal rights in response to a legal request.
8. Processors
To provide the service we use, among others, Supabase (data storage) and Netlify (hosting and infrastructure). These processors handle the data only under our instructions and with adequate security measures.
9. International transfers
Given the nature of the service, your data may be stored or processed on servers located outside your country of residence. When this happens, we adopt appropriate safeguards so that your data keeps a level of protection equivalent to that required by applicable law.
10. Your rights
You may exercise, free of charge, your rights to: know/access, update, rectify and delete your data; request proof of the authorization; object to processing; withdraw consent; and, where applicable (e.g. GDPR), data portability and restriction of processing. You may also lodge a complaint with the data-protection authority of your country (e.g. the Superintendencia de Industria y Comercio in Colombia; your national authority in the EU/EEA; the ICO in the UK; the INAI in México).
11. How to exercise your rights
Write to [email protected] stating your request. We will respond within the timeframes required by applicable law. We may ask for information to verify your identity before processing the request.
12. Information security
We adopt reasonable technical, human and administrative measures to protect your data against loss, unauthorized access, alteration or improper disclosure (e.g. encryption in transit, access control and data minimization).
13. Retention
We keep your data for as long as the program and your request are active, or until you withdraw the authorization or request its deletion, unless the law requires us to keep it for a longer period.
14. Minors
The program is intended for adults (18+). We do not knowingly collect data from minors; if we detect a minor’s registration, we will delete it.
15. Cookies and analytics
We use web analytics (Google Analytics) for statistics and improvement, with the minimum collection necessary. You can manage cookies from your browser.
16. Referral program
If you take part in the referral program, your invitation code and referral count are part of the processing. Anyone who signs up through your invitation accepts this same Policy.
17. Changes to this Policy
We may update this Policy; the current version will always be published on this page, with its update date.
18. Governing law, jurisdiction and contact
This Policy is governed by the law applicable to your country of residence and, where relevant, by the laws of Colombia, where the Controller operates. For any question or request about your data: [email protected].