Privacy Policy

Last updated: March 18, 2026

Data Controller: Smallcap Market Systems LLC ("DelegaAI", "we", "us")

Address: 5830 E 2nd St, Ste 7000 #31660, Casper, WY 82609, United States

Contact: [email protected]

1. Personal Data We Collect

We collect the following personal data when you use our website or services:

  • Contact information: name, email address, phone/WhatsApp number, company name
  • Service usage data: type of process to automate, team size, urgency level
  • Browsing data: IP address, browser type, pages visited, time on site (collected by Google Analytics and Microsoft Clarity)
  • Communication data: messages sent via WhatsApp, contact forms, and website chat

We do not collect financial data, sensitive data, or data from minors.

2. Purpose of Data Processing

We use your personal data to:

  • Respond to inquiries and demo requests
  • Schedule and conduct demonstration calls
  • Send personalized quotes and proposals
  • Improve our website and services through usage analytics
  • Send communications about our services (only with your prior consent)

3. Legal Basis for Processing

  • Consent: when you submit a contact form or voluntarily provide your data
  • Legitimate interest: for website usage analytics and service improvement
  • Contractual performance: when necessary to deliver the contracted services

4. Data Transfers

Your data may be processed by the following third parties, strictly for the purposes described:

  • Google Analytics (Google LLC): web traffic analysis — Privacy Policy
  • Microsoft Clarity (Microsoft Corp): heatmaps and session recordings — Privacy Policy
  • WhatsApp / Meta Platforms: communication via WhatsApp Business API — Privacy Policy
  • Cloudflare Inc: hosting and form processing — Privacy Policy
  • OpenRouter / DeepSeek: natural language processing for the chatbot — your data is NOT used for model training

We do not sell, rent, or share your personal data with third parties for marketing purposes.

5. ARCO Rights (Mexico — LFPDPPP)

In accordance with the Federal Law on Protection of Personal Data Held by Private Parties (LFPDPPP), you have the right to:

  • Access: know what personal data we hold about you
  • Rectification: correct inaccurate or incomplete data
  • Cancellation: request the deletion of your data
  • Opposition: object to the processing of your data for specific purposes

To exercise these rights, send an email to [email protected] with the subject "ARCO Rights" including your full name and a description of your request. We will respond within a maximum of 20 business days.

6. CCPA Rights (California, USA)

If you are a California resident, you have the right to:

  • Know what personal data we collect, use, and share
  • Request deletion of your personal data
  • Opt out of the sale of your personal data (we do NOT sell personal data)
  • Not be discriminated against for exercising your privacy rights

To exercise these rights: [email protected]

7. GDPR Rights (European Union)

If you are a resident of the European Union or the European Economic Area, you have the right to:

  • Access, rectification, and erasure of your data
  • Data portability
  • Restriction of and objection to processing
  • Withdraw your consent at any time
  • Lodge a complaint with a data protection authority

8. Cookies

We use cookies and similar technologies. For more information, please see our Cookies Policy.

9. Data Retention

We retain your personal data for as long as necessary for the purposes described or while an active business relationship exists. Contact form data is retained for a maximum of 24 months. You may request deletion at any time.

10. Security

We implement technical and organizational security measures to protect your data:

  • AES-256 encryption at rest and TLS 1.3 in transit
  • Restricted access to personal data (principle of least privilege)
  • Servers on Cloudflare with SOC 2 and ISO 27001 certifications
  • Tokens and credentials stored securely (never in source code)

11. Changes to This Policy

We reserve the right to update this privacy policy. Any changes will be published on this page with the corresponding update date. We recommend reviewing it periodically.

12. Contact

For questions, requests, or complaints related to the privacy of your data:

  • Email: [email protected]
  • Data Controller: Smallcap Market Systems LLC
  • Address: 5830 E 2nd St, Ste 7000 #31660, Casper, WY 82609, USA