Privacy Policy
1. Who we are
Kairos (“we”) is the trade name under which its founder, Jacobo Llanos Leyton, operates while the incorporation of Kairos Group, S.A. (in formation) in the Republic of Panama is completed. Once the company is registered it will assume the role of controller and we will update this policy. Location: Panama City. We are the data controller for the personal data collected through this website and our business relationships, in accordance with Law 81 of March 26, 2019 on Personal Data Protection and its regulations.
2. Scope
This policy applies to the Kairos website, forms, commercial communications and the relationship with clients, prospects, suppliers and candidates. The processing of data we carry out on behalf of our clients within the contracted services is governed by the services contract and the corresponding Data Processing Agreement (DPA) (see section 5).
3. Data we collect
| Category | Examples | Source |
|---|---|---|
| Identification and contact | Name, company, job title, email, phone | Forms, meetings, email |
| Business information | Described needs, proposals, contracts, invoicing | Business relationship |
| Technical data | IP, browser, pages visited, date and time | Automatic (cookie-free measurement) |
| Candidates | Résumé, experience | Applications |
We do not request sensitive data (health, origin, beliefs, biometrics) through this site. Please do not include third parties’ personal data in the forms.
4. Purposes and legal basis
| Purpose | Legal basis |
|---|---|
| Answer requests and schedule assessments | Consent / pre-contractual measures |
| Perform contracts, invoice and provide support | Performance of a contract |
| Comply with legal, tax and accounting obligations | Legal obligation |
| Send Kairos commercial information | Consent (revocable at any time) |
| Site security and fraud prevention | Legitimate interest |
| Improve the site (aggregate analytics) | Legitimate interest; no cookies or profiles |
5. Our clients’ data within the services
- When we automate processes, the client is the controller and Kairos acts as processor, only under their documented instructions.
- By default, bots run on the client’s equipment or cloud. Our code repositories contain no personal data: they are published through allow-lists and pass automatic privacy reviewers.
- Kairos staff access only what is strictly necessary, under signed confidentiality. The reports we use for support contain counts, statuses and technical identifiers, not personal data.
- In healthcare we also apply the patient confidentiality rules in force in Panama and the instructions of the healthcare facility.
- When the service ends, we return or delete the data as the contract provides and deliver written confirmation.
6. Use of artificial intelligence
- We do not use client data to train our own or third-party AI models.
- We only send information to external AI services with the client’s express authorization, to providers that do not retain or train on that data and, where possible, after anonymizing it.
- Automated decisions that affect people always have human review available. See our Responsible AI Policy.
7. Who we share data with
We do not sell personal data. We may share it with:
- Providers that deliver services to us (email, web hosting, electronic invoicing, accounting), under confidentiality contracts.
- Google (Google Calendar and Google Meet), when you book a conversation in our online calendar: it receives your name, email and whatever you write in the booking form.
- Meta (WhatsApp), when you write to us on WhatsApp or submit the contact form, which opens WhatsApp with your message.
- Legal advisors and auditors.
- Competent authorities, when the law requires it.
8. International transfers
Some technology providers (for example, email or hosting) may be located outside Panama. In those cases we require equivalent protection safeguards, in accordance with Law 81 of 2019.
9. Retention
| Data | Period |
|---|---|
| Prospects without a contract | Up to 24 months from last contact |
| Clients (contracts, invoices) | For the duration of the relationship + the legal accounting/tax period |
| Site technical data | Up to 12 months |
| Candidates | 12 months, unless you ask for deletion sooner |
10. Security
We apply technical and organizational measures: encryption in transit, least-privilege access control, multi-factor authentication, credentials in secure managers, audit logs, automatic privacy reviews of code and an incident response plan. If a breach affecting your data occurs, we will notify it as the law requires. More details in Security.
11. Your rights
You may exercise at any time your rights of Access, Rectification, Cancellation, Opposition and Portability, and withdraw your consent. Write to privacidad@kairosgrouppanama.com stating your name, the right you are exercising and a way to contact you. We respond within the legal deadline. If you are not satisfied, you may go to the National Authority for Transparency and Access to Information (ANTAI).
12. Cookies
This site does not use cookies. Typefaces are hosted on the site itself, so your browser does not connect to third parties to display them. We measure visits with Cloudflare Web Analytics, which uses no cookies and does not identify anyone: it only gives aggregate figures (for example, how many people viewed a page). If you arrive from one of our posts or ads, the link indicates its origin (for example, “linkedin”); we keep it only in that tab of your browser, without cookies, and it is sent to us only if you decide to write to us on WhatsApp or submit the form. To do this your browser loads a small script from static.cloudflareinsights.com, which receives technical data about the visit (page, browser, approximate country); Cloudflare does not use it to build profiles or for advertising. External services you choose to visit (online calendar, WhatsApp, LinkedIn, Instagram) have their own policies.
13. Minors
Our services are aimed at companies. We do not knowingly collect data from minors.
14. Changes to this policy
We will publish any change here and indicate the effective date. If the changes are significant, we will notify our clients by email.
15. Contact
Data protection officer · Kairos · privacidad@kairosgrouppanama.com · Panama City.