Last modification: July 08, 2026

This privacy policy (hereinafter the “privacy policy”, the “policy”, interchangeably) describes how Crombie (“Crombie”, “we”, or “our”) collect, use and disclose certain information, including your personal information, and the choices you can exercise regarding such information.

Crombie is a software production company specializing in the areas of Design and Prototyping, Code Development, Project Management, and Consulting. Some of the services developed by Crombie are: UX/UI Design, Custom Web and Mobile Development (Corporate Intranets and Extranets / Loyalty & Wellness Platforms / e-Learning Platforms / Corporate Apps), e-Commerce Platforms (B2B, B2C), Integrations (ERPs / CRM / HRM), Staffing, QA testing, DevOps and data migration, among others (“Services”).

This privacy policy governs the processing and transfer of data collected directly or indirectly when hiring our Services, simply by interacting with our website: https://crombie.dev/es (“website”) or through any means of communication (“Visitors” and “Clients” will be collectively referred to as “you”).

This policy has been developed in strict compliance with current regulatory frameworks, including Law No. 25,326 on the Protection of Personal Data of the Argentine Republic and its regulatory framework, as well as the international standards established by the GDPR (General Data Protection Regulation). In any event, interested parties may exercise their rights or file claims before the competent control authorities, such as the Agency of Access to Public Information (AAIP) in the Argentine Republic or the corresponding supervisory authority in their jurisdiction of residence.

MODIFICATIONS TO THE POLICY:
We reserve the right to modify this privacy policy when necessary, at our sole discretion. The most recent version of the privacy policy will always be published on our website and the date of the policy update will be reflected in the “Last modification” header. Each time you access the Crombie website you must ensure that you have reviewed the content of this policy.

CONTACT INFORMATION AND INFORMATION OF THE CONTROLLER:
Crombie S.R.L. is the entity responsible for the file, incorporated under the laws of Argentina, with address at San Jeronimo 2542, Ground Floor, Department “2”, in the city of Santa Fe, province of Santa Fe. You can contact us and our privacy team as follows:

• Contact information of the Responsible for the Personal Data Protection Program: privacy@crombie.dev

WHAT CATEGORIES OF DATA DO WE COLLECT AND FOR WHAT PURPOSES?
We may collect data from you, depending on your interaction with us:

Individually identifiable information: that is, information that identifies an individual or that could identify an individual with reasonable effort (“Personal Data”).

The types of personal data we process, the purpose, and our processing operations are detailed below:

Visitors / Clients:

• Data set: if you contact us voluntarily through any form available on our website or by email, you may be asked to provide us with certain information, such as your full name, email address, and any additional information you choose to share with us (“contact information”). We will process such information to provide you with a response to your inquiry.
• Purpose and operation: The emails and communications we have with you may be processed and stored by us to improve our customer service.
• Legal basis: In the event that we consider it necessary, we may continue to store it, for example, in case of claims or to provide assistance (if applicable). We will process contact information subject to our legitimate interest.

• Job offers:
  • Data set: When a visitor applies for a job position offered by Crombie, we will process the CV you provided, including any associated information, such as your full name, email address, telephone number, education and skills, work history, and your photo (provided it is provided by you). Additionally, we may collect more information from public and online sources and former employers and combine such data with the data provided by you (collectively “recruitment information”).
  • Purpose and operation: we will collect recruitment information to process your application, for hiring management purposes, for additional hiring steps (e.g., interview), and to enable us to comply with corporate governance and legal and regulatory requirements. If you are hired by Crombie, your recruitment information may be stored in the Human Resources department as part of your employment file, and it will be subject to our corporate management. We use a third-party service provider for the purpose of managing job applications; we are currently using People Force. Such providers are contractually obligated to maintain your information confidential and secure and will not use the Recruitment Information for any purpose other than those detailed here.
  • Legal basis: we process Recruitment Information subject to your consent. Whenever we ask you to provide health-related information, we will process such data based on your consent, which you can withdraw at any time. We will retain your Recruitment Information for record-keeping and defense in the event of future legal claims. We will process such information under our legitimate interest, or if you have given your consent to contact you in the future.

Management of building access control and other functions related to surveillance and security:

• Data set: identifying data.
• Purpose and operation: we will process your information in order to preserve the security of the property, people, and facilities under its management.
• Legal basis: we will process your information based on our legitimate interest.

Advertising and commercial prospecting purposes:

• Data set: identifying data.
• Purpose and operation: Sending commercial communications of own products and/or services, similar or not to those contracted or requested by you through the medium enabled for that purpose, as long as you have not opposed receiving such communications at the time of data collection or after receiving any subsequent commercial communication and, when required, provided we have your consent.

• Legal basis: we will process your information based on our legitimate interest in relation to commercial communications sent by electronic means. If applicable, we will request your consent.

Newsletter registration:
In the event that you register to receive our newsletter, you will be asked to provide your contact details, such as your email address. We will use your email to send you our newsletter and other marketing materials. We process this contact information subject to your consent. You can withdraw your consent at any time via the “unsubscribe” link within the email or by contacting us directly.

Payment information:

To use our services, you may be asked to provide standard billing information, such as name, e-mail, company you belong to, tax data, address, position within the company, cell phone number, LinkedIn account. We will process this information to be able to provide our services, execute the contract, and process your payment.

Please note that the actual processing operation for each purpose of use and legal basis detailed above may vary. We may collect different categories of personal data and non-personal data from you, depending on the nature of your interaction with the services provided by our company.

HOW LONG WILL WE RETAIN THE DATA?
Personal data of interested parties will be kept for the period necessary to comply with the aforementioned purposes for which they were collected.

WHAT SECURITY MEASURES DO WE IMPLEMENT AT CROMBIE?

At Crombie we work to protect the personal data we collect and process. We have implemented physical, technical, and organizational security measures to comply with applicable laws and regulations. We minimize the amount of data we store on our servers, restrict access to personal data only to employees (and where necessary for the performance of their duties), contractors and, among other measures.

Please note that we cannot be held responsible for unauthorized or unwanted access that is beyond our control, and we offer no warranty, express, implied, or otherwise, that we will always be able to prevent such access.

If you consider that your privacy has not been handled appropriately, please contact us at: privacy@crombie.dev. We will make a reasonable effort to notify you and the relevant authorities (if required by law) in the event that we discover a security incident related to your personal data.

TO WHICH RECIPIENTS WILL YOUR DATA BE COMMUNICATED?

Recipients of Personal Data: the disclosure of personal information stored in our files will only be carried out in the following circumstances:

1. Public Entities: Crombie may share your personal data when established by a law, regulation, or provision, complying with the relevant legal requirements and ensuring adequate data protection at the time of sharing.
2. Subcontracted Third Parties: Within the framework of the execution of the service provision contract, Crombie reserves the right to assign personal data to subcontracted third parties participating in the implementation and development of the contracted services. These third parties are contractually obligated to guarantee a level of security and confidentiality equivalent to that offered by Crombie, and to use the data exclusively for the purposes agreed upon in the contract.

WHAT ARE YOUR RIGHTS RELATED TO YOUR PERSONAL DATA?

Our goal is to be transparent about the information we collect so that you can make the decisions you consider regarding how your personal data is used. For this reason, you can make certain choices, rights, and controls in relation to your information. Depending on your relationship with us, your jurisdiction, and the applicable data protection laws that affect you, you have the right to control and request certain limitations or that certain rights be executed.

Below you can review the rights according to the interaction you have with us. You can also find how you can exercise these rights.

1. RIGHT TO INFORMATION: you have the right to confirm if we collect personal data from you. If you want to know if we collect personal data about you, please review this Privacy Policy.

1. ACCESS RIGHTS: you have the right to know what specific personal data we have about you and to receive a copy of it or access it. If you wish to receive a copy of the personal data, please submit a “Right of Access Request” form available here.

1. RIGHT OF RECTIFICATION: you have the right to correct inaccurate personal data that we store in our databases, taking into account the nature and purposes of each processing activity. If you wish to correct your personal data, please submit a “Request for Right of Rectification, Update, or Deletion of Personal Data” form available here.

1. RIGHT TO BE FORGOTTEN, RIGHT TO DELETION: in certain circumstances, you have the right to have us delete the personal data we have in our databases about you. In the event that you wish to exercise your right to be forgotten, please submit a “Request for Right of Rectification, Update, or Deletion of Personal Data” form available here.

1. RIGHT TO APPEAL OR FILE A COMPLAINT: in the event that we refuse to take action regarding your request, we will inform you of this without undue delay, as required by applicable laws. The notification will include a justification for refusing to take action and instructions on how you can appeal, if applicable. In the EU, you have the right to file a complaint with the supervisory authority.

1. NON-DISCRIMINATION: discrimination may include denial of a service, providing a different level or quality of service, or charging different prices. We do not discriminate against our clients or users.

CHILDREN’S PRIVACY:

The services provided by Crombie are not intended for use by children (“child”: an individual who is under the age defined by applicable law, which in the case of the EEA is under 16 years of age and in the Argentine case is up to 18 years of age), and we do not knowingly process information from children. We will immediately discard any information we receive from a user considered a “child” as soon as we discover that such user shared information with us. Please contact us at: privacy@crombie.dev if you have reason to believe that a child has shared information with us.