Privacy Policy

Cubillos Lama (the “Firm”) is the data controller for the personal data it processes through the website cubilloslama.com and its platform, in compliance with Article 19 No. 4 of the Political Constitution of the Republic of Chile and Law No. 19.628 on the Protection of Private Life.

This policy applies to the personal data that Cubillos Lama processes through its website and its platform, mainly by means of:

• the contact form;
• the legal self-assessment tool and requests for its detailed results;
• the prospect account the Firm may give you on its platform, and the scheduling of meetings from it;
• the newsletter and legal-updates subscription;
• your browsing of the site, through cookies and analytics tools (Cookie Policy, a separate document).

The processing of data in the context of the direct provision of professional services is governed by the respective contractual agreements and by lawyers’ professional secrecy obligation.

In the contact form: your name, your email address, your company or organization (if you provide it) and the content of your enquiry. If, in describing your request, you include sensitive personal data, by submitting the form you authorize its processing to handle your enquiry: we do not ask you for it.

In the legal self-assessment: the type of company, the industry and the employee-headcount range you declare, and your answers. While you do not request the detailed results, they are evaluated in your browser and are not sent to the Firm. To receive the detailed results we ask for your name, your email address and your company’s name — unless you state that you are an individual — and, optionally, your position and your phone number; with them we store your answers, the result you saw, the version of the questionnaire and the recommendations we send you. Before sending you the detailed results, we ask you to confirm your email, to make sure it is yours.

In your prospect account: your email address, the account’s access logs, the meetings you schedule and your newsletter preferences.

Data collected automatically. When you browse the site we may collect your IP address, your browser type and version, your operating system, the pages you visit, the date and duration of your visit and your approximate location. When you request the detailed results of the legal self-assessment, we additionally store an irreversible fingerprint of your IP address, used to limit abusive requests, and your browser type.

Universe of data subjects: those who contact the Firm, use the legal self-assessment, subscribe to its communications or hold a prospect account; the representatives of client or prospective-client companies; and those the Firm identifies as prospective clients from publicly available sources, such as a professional network.

We process your personal data to:

1. Respond to your enquiries and requests received through the website.
2. Manage the relationship with current and prospective clients, including the preliminary assessment of legal enquiries.
3. Deliver the detailed results of the legal self-assessment and its recommendations, and contact you about them.
4. Manage your prospect account, the meetings you schedule and the follow-up of your relationship with the Firm.
5. Send you the newsletter and legal updates, only if you authorized it separately.
6. Analyze the use of the website and prepare aggregated, anonymous statistics to improve its operation.
7. Comply with applicable legal obligations.
8. Manage job applications received through the website.

We do not process your data for purposes other than those indicated, unless we have your consent or the law authorizes it.

The processing is based on your consent, given in advance, freely, in an informed manner and specifically for each purpose, in accordance with Article 12 of Law No. 19.628. Consent to receive the detailed results of the legal self-assessment and consent to receive the newsletter are requested separately, neither comes pre-checked and neither is a condition of the other. The general result of the legal self-assessment is shown without asking you for any data: your data is requested only if you want to receive the detailed results by email. You may withdraw your consent at any time, without affecting the lawfulness of the processing carried out before your withdrawal.

Where applicable, the processing is additionally based on compliance with a legal obligation, on the assessment or performance of a professional services relationship, or on data from publicly available sources, in accordance with the same Article 12.

We share your data with providers that process it on the Firm’s behalf and in accordance with its instructions, under a data processing agreement:

• Supabase — the Firm’s database: it hosts your legal self-assessment request, your answers and your consents, as well as the Firm’s backoffice and client portal.
• Resend — the sending of the site’s emails: the confirmation and detailed results of the legal self-assessment, and the notices from the contact form and the subscription.
• Notion — the record of your contact-form enquiries. If the Firm moves it to its own database, this policy will be updated before the change.
• Vercel — the hosting of the website and the platform, and basic measurement of the site’s use.
• Google Workspace — the Firm’s institutional email (info@cubilloslama.com), where your enquiries, your subscriptions and the notices about your requests arrive.
• Google Calendar — the scheduling of meetings from the website: Google manages that form on its own domain, and the Firm does not receive that data in its systems.

The site’s measurement tools — Google Tag Manager, Google Analytics, Vercel Web Analytics and Speed Insights — are described in the Cookie Policy.

In addition, we may disclose your data when required by a judicial, administrative or regulatory authority in the legitimate exercise of its functions, or when you have expressly authorized it for a specific third party.

The providers listed in the previous section process data outside Chile:

Supabase

Country of processingBrazil (São Paulo)

SafeguardData processing agreement with EU standard contractual clauses; SOC 2 Type II

Resend

Country of processingUnited States

SafeguardData processing agreement with EU standard contractual clauses and adherence to the EU-U.S. Data Privacy Framework; SOC 2 Type II

Notion

Country of processingUnited States

SafeguardData processing agreement with EU standard contractual clauses; SOC 2 Type II, ISO 27001, ISO 27017, ISO 27018 and ISO 27701

Vercel

Country of processingUnited States

SafeguardData processing agreement with EU standard contractual clauses and the UK transfer addendum; certification under the EU-U.S. Data Privacy Framework; SOC 2 Type II and ISO 27001

Google Workspace and Google Calendar

Country of processingNo fixed country: Google’s global infrastructure

SafeguardGoogle Cloud and Workspace data processing agreement, with EU standard contractual clauses

None of these countries currently has an adequacy decision issued by the Chilean authority, so each transfer relies on the safeguard in its row.

You have the right to request from Cubillos Lama the access, rectification, erasure, objection, portability and blocking of the processing of your personal data, in accordance with Articles 4 to 9 of Law No. 19.628. In particular, you may object at any time to the processing of your data for direct-marketing purposes.

To exercise them, write to us at info@cubilloslama.com stating your identification, an email address or postal address for our reply, the data your request refers to and, as applicable, the changes you request, the ground for erasure or the basis for your objection. Cubillos Lama will acknowledge receipt and issue a decision within 30 calendar days, a period that may be extended once for an equal period. If your request is rejected or is not answered in time, you may file a complaint with the Data Protection Agency.

We keep your data only for as long as necessary for the purposes of this policy:

• Legal self-assessment and prospect account: while the relationship is active, and for up to 24 months after your last interaction — a request for the detailed results, a login, or a scheduled meeting — if you do not become a client of the Firm. Once that period expires, we erase or anonymize the record.
• Newsletter and legal updates: until you withdraw your consent.
• Contact-form enquiries: for up to 24 months from your enquiry, unless it gives rise to a professional engagement; in that case it becomes part of the corresponding file and is kept for as long as that relationship lasts and for up to five years after it ends.

Your data comes from you, through the forms on the website and the platform. When the Firm registers a prospective client who did not arrive through the website — from a professional contact, an event, a referral or a publicly available source such as a professional network — your data comes from that source, and before creating your account the Firm informs you of this policy and asks for your consent by email.

The legal self-assessment applies fixed rules to your profile — type of company, industry and employee-headcount range — and to your answers, to indicate which legal obligations may apply to you and which ones you should review. The result is informational: it does not produce legal effects for you and does not replace the advice of a lawyer, and the Firm does not make automated decisions about you.

We have adopted technical and organizational measures to protect your personal data against unauthorized access, loss, alteration or misuse, including encrypted communications (HTTPS/TLS), access restricted by role, and periodic encrypted backups.

No system can guarantee absolute security. We make our best efforts to protect your information, but we are not responsible for events that reasonably escape our control, such as third-party cyberattacks or force majeure.

In addition, the Firm’s lawyers are subject to the professional secrecy obligation established by Chilean law, an additional layer of protection for the information you entrust to us in a consultation or professional relationship.

Cubillos Lama’s website is not directed at minors, and the Firm does not knowingly collect data from persons under 18 years of age. If we become aware that we have collected data from a minor without their legal representative’s authorization, we will delete it promptly.

The site may contain links to sites operated by third parties. Cubillos Lama does not control and is not responsible for their content, their privacy policies or their data-processing practices. We recommend that you review the privacy policy of each site you visit.

We may amend this Privacy Policy to adapt it to legislative, regulatory, technological or operational changes. We will publish any amendment on the site with its date and version, and a change to the text of a consent will be requested again before it applies.

If you have any questions about this policy or about the processing of your personal data, write to us:

• Email: info@cubilloslama.com
• Address: San Sebastián 2807, Of. 513, Las Condes, Santiago, Chile

This is the exact text shown next to each checkbox, with a link to this policy. Each consent is stored with that text, the version of the policy and the moment you gave it. No checkbox comes pre-checked.

Legal self-assessment — the detailed results

TextI agree that Cubillos Lama may keep my details and answers to send me the full results of this assessment and contact me about them, as set out in the Privacy Policy.

Mandatory?Yes, to receive the detailed results

Legal self-assessment — the newsletter

TextI'd like to receive the Cubillos Lama newsletter. I can unsubscribe at any time.

Mandatory?No

Contact form

TextI agree that Cubillos Lama may process my details to answer my enquiry, as set out in the Privacy Policy.

Mandatory?Yes, to send the enquiry

Newsletter and legal-updates subscription

TextI'd like to receive the Cubillos Lama newsletter and legal updates. I can unsubscribe at any time, as set out in the Privacy Policy.

Mandatory?Yes, to subscribe

The binding version of this policy is the Spanish one; the English and Chinese versions are courtesy translations.