Privacy notice

Version 3.1 · Last updated: September 29, 2026 (date of the Spanish version)

Short-form notice (in brief)

• Who: Edsi Fabián Pérez Jaramillo, under the trade name AduanaClic (aduanaclic.com), Manzanillo, Colima. Address: Calle Neptuno 229, Valle Esmeralda, Barrio 4, C.P. 28219, Manzanillo, Colima, Mexico. Contact: [email protected].
• What data: if you open an account, your name and your email or WhatsApp. If you ask a customs brokerage to give you a quote, or if you advertise your brokerage, the contact details you type in. On the free page we do not ask for your name or email. We do not ask for sensitive data or card data.
• What for: to provide the service you request (queries, entry review [glosa], pre-review, pre-inspection [previo], audit, classified catalogs, pre-shipment inspection at origin, the free page), to keep your balance and to prevent abuse. Separately, and only if you do not object, to tell you about courses and news.
• What you upload (photos, invoices, pedimentos) is read to answer you and is not stored, except in Classified catalogs and Pre-shipment inspection at origin: there it is kept in a living file [expediente vivo] so you can complete the open questions, and it is deleted automatically after 180 days. We do not sell your data. It only goes to a customs brokerage if you tick the box asking it to give you a quote.
• How to limit the use: write to [email protected] (for example, «No quiero avisos» [I do not want notices] or «Borren mis datos» [Delete my data]).

The comprehensive notice, with all the details, is below. It is governed by the Ley Federal de Protección de Datos Personales en Posesión de los Particulares (Federal Law on the Protection of Personal Data Held by Private Parties, DOF 20-03-2025).

Contents:

1. Who is responsible
2. What data we use, depending on what you do
3. What we use it for
4. Documents of your operations
5. Entry review files
6. Providers that help us (processors)
7. When data goes to another party
8. How long we keep it
9. Cookies and browser storage
10. How to limit the use
11. Your ARCO rights and how to exercise them
12. Consent and how to withdraw it
13. Security
14. Changes to this notice
15. Authority

Comprehensive privacy notice

1. Who is responsible

Edsi Fabián Pérez Jaramillo, an individual who operates the service under the trade name AduanaClic (aduanaclic.com), in Manzanillo, Colima, Mexico, is the data controller of your personal data under the Ley Federal de Protección de Datos Personales en Posesión de los Particulares (hereinafter, «the Law»).

Address for notices: Calle Neptuno 229, Valle Esmeralda, Barrio 4, C.P. 28219, Manzanillo, Colima, Mexico.

Contact for anything related to your data, including your ARCO rights: [email protected]. The person who handles these requests is the data controller himself.

AduanaClic is not a customs broker (agente aduanal) or a customs brokerage, and does not act on behalf of the authorities.

2. What data we use, depending on what you do

a) If you open an account or request your trial query (Edsi IA / bot)

• Name, email address or WhatsApp number, and the access key we assign to you.
• Your balance: how many queries you use, when, and your top-up requests.
• The IP address from which you request the trial, only to prevent abuse (it is used per hour and per day, and discarded within 24 hours at the latest).
• If you pay by bank transfer: the proof of payment you send us (name, bank, amount and date), only to load your balance and keep the accounts. This is financial data; we process it because it is necessary to fulfil your relationship with us (art. 7 and art. 9 fr. IV of the Law). We do not ask for or store card data.

b) If you use the free page «Pega el link» [Paste a link] (aduanaclic.com/importar)

• We do not ask for your name, email or WhatsApp.
• For the limit of 2 free queries a day: the page stores a random number in your browser (it does not say who you are). With that number and the IP of your connection we derive an encrypted «fingerprint» (SHA-256 with a salt that changes every month); we never store the IP or the number as such. Fingerprints are deleted after 2 days.
• What you ask about (the link, the text or the photos of the product) is sent to the artificial intelligence to answer you and is not stored.
• What we do keep, without personal data: the product data (what it is, material, use, country, price, quantity), the tariff item and the requirements that came out, the link without whatever follows the «?» or the «#» (trackers travel there) and a single word about where you came from (for example, «facebook»). We use it to review and improve the answers.
• Only if you ask for it: if you want a customs brokerage to give you a quote, you type your name and your WhatsApp or email and tick the consent box. See point 7.

c) If you advertise your brokerage (aduanaclic.com/anunciate)

• Trade name of the brokerage, the customs offices where it works, one contact (WhatsApp or email), your comment if you write one, and the date on which you gave your consent.
• An encrypted fingerprint of the IP (not the IP), only to prevent repeated submissions; it is deleted after 7 days.
• To publish a brokerage we check in publicly available sources (for example, the DOF and the public registers of the customs authority) that it operates under a valid customs broker licence (patente de agente aduanal), and we note the licence number and where we verified it (art. 9 fr. II of the Law).

d) If you use the entry review, pre-review, pre-inspection, audit services or queries with documents

• The documents you upload (pedimento, invoice, packing list, bill of lading, certificates, pre-inspection photos, etc.). See point 4.

e) If you order a Classified catalog or a Pre-shipment inspection at origin

• Your contact details (name, email or WhatsApp) and, if you pay, what Stripe tells us (see point 6).
• Classified catalog: the catalog or list you upload (codes, descriptions, product photos and whatever the file contains) and your answers to the classification questions.
• Pre-shipment inspection at origin: photos of the goods, their labels and their packaging, and the documents you upload (invoice, packing list, certificates). If you give us your supplier's contact so that they upload the photos, we use that name and that WhatsApp or email only to send them the photo link for your order. We ask them to photograph the goods and that no people appear in the photos.
• These two services work with a living file [expediente vivo]: we keep your files and your answers so you can answer the questions and complete what is missing without starting over. See points 4, 5 and 8.

We do not ask for sensitive personal data. If a document you upload contains any, we use it for nothing other than answering you and it is not stored.

3. What we use it for

Necessary purposes (without them we cannot provide the service):

• Opening your account, giving you your trial query and answering your queries.
• Reviewing your documents and delivering the result (entry review, pre-review, pre-inspection, audit, classification, approximate costs).
• Keeping your balance, telling you when it runs out and handling your top-ups and payments.
• Preventing abuse: limits per device, per connection and per day, and the spending cap of the free page.
• On the free page: keeping, without personal data, what was asked, to review and improve the answers.
• If you ask for it: sending your contact to the brokerage you chose so it can give you a quote.
• If you advertise your brokerage: answering you, verifying the licence and, if an agreement is reached, publishing the brokerage with its label («Patrocinado» [Sponsored] or «Agencia aliada (piloto)» [Partner brokerage (pilot)]).
• Complying with legal obligations and responding to requests from the authorities.

Additional purpose (you can say no and the service stays the same):

• Telling you about AduanaClic courses, tools and news.

If you do not want the additional purpose, write to [email protected] with the subject «No quiero avisos». You can do so at any time.

The artificial intelligence analyses goods and documents, not people: we do not use it to assess your behaviour, your creditworthiness or any other personal aspect. The result is guidance; the decision is made by whoever signs.

4. Documents of your operations

• Exception: Classified catalogs and Pre-shipment inspection at origin. There we do keep your files, photos and answers, in private storage (see point 6), only to work on your order and its corrections. They are deleted automatically 180 days after being uploaded, or earlier if you ask us.
• In the other services, they are read to answer you and are not stored. Our systems are configured not to store the content of executions that succeed or of those that fail.
• If a review takes long, the result (without your files) is kept for 2 hours at most to deliver it to you, and it is deleted as soon as you receive it.
• When it finishes, we deliver the result for you to download: you keep your own copy.
• Other people's data: your documents may contain third-party data (for example, names, addresses and RFC [Mexican tax ID] of the importer, the supplier or a carrier). That data belongs to your operation or to your client: you (or your brokerage) are responsible for holding it lawfully and for being able to share it. AduanaClic processes it only on your behalf, only to give you the result you ask for, and does not use it for anything else. Upload only what is necessary.
• Anonymous learning: from classification queries we only keep technical knowledge (type of goods, tariff item and criterion), without names, RFC, values, document numbers or anything that identifies a person or company. From entry reviews, pre-inspections, audits and notices not even that is kept.

5. Entry review files

Classified catalogs and Pre-shipment inspection at origin already work with a living file: your order, its files and your answers are kept so you can complete what is missing (including 2 rounds of corrections within 30 days) and are deleted automatically after 180 days. Only the data controller and the systems that process your order see them.

In the entry review and the other services, today we do not keep files. If we later offer to keep your review report so you can complete it later, we will do it only when you tick the box to keep it, and before that we will update this notice with what is kept, for how long, who sees it and how it is deleted.

AduanaClic does not replace the file that the Ley Aduanera (Customs Law) requires the customs broker or brokerage and the importer to prepare and keep.

6. Providers that help us (processors)

To provide the service we use providers that process the data only on our behalf and under their terms of service. The regulation calls this a remisión (communication to a processor): it does not require your consent, but we tell you so you know where your data is (Regulations of the Law, arts. 2 fr. IX, 49 to 53). Several are outside Mexico:

According to its published terms, OpenAI does not use the data it receives through its API to train its models and may keep it for up to 30 days to monitor abuse.

7. When data goes to another party (transfers)

• We do not sell or rent your data.
• To the customs brokerage you choose (only on the free page, only if you ask for it): we send it your name, your contact and the product data (product, tariff item, quantity and customs office) so it can give you a quote. This is a transfer (transferencia) and we make it only with your express consent, which you give by ticking the box next to that brokerage. The brokerage receives this notice and the purposes, and is bound to respect them (art. 35 of the Law): to use the data only to give you a quote, not to share or sell it, and to delete it if you ask or if there was no deal within 6 months. If you do not tick the box, we send nothing.
  How we get it to them: by message or email to the brokerage (with the support of Telegram and an email sending service, as processors). Your name and contact do not remain in our database; at most, an encrypted fingerprint of the contact for 12 months, so as not to send it twice and to be able to ask the brokerage to delete it if you request so.
• To authorities, only when a law, a treaty or a reasoned order of a competent authority requires it (arts. 9 fr. VII and 36 of the Law). These do not require your consent.

Transfer clause: by ticking the box «Acepto que AduanaClic comparta mi nombre, mi contacto y los datos de este producto con [la agencia]…» [I agree that AduanaClic shares my name, my contact and the data of this product with (the brokerage)…], you accept that transfer. If you do not tick it, you do not accept it.

8. How long we keep it

When data is no longer needed, it is deleted; if the law requires it to be kept, it is first blocked (kept without being used) and then deleted (arts. 10 and 24 of the Law).

9. Cookies and browser storage

• We do not use cookies, analytics tools or advertising pixels (for example, there is no Facebook pixel or Google Analytics).
• Some pages store data in your own browser (local storage), which does not reach us except when you send a query:
  • pin_consulta: your key, so it is not asked for every time (bot, home page, classroom, pre-inspection). It is deleted when you sign out.
  • aduanaclic_disp: the random number of the free page, for the limit of 2 a day.
  • sesion_abierta, modo_prueba, supuestos: screen preferences while you use it.
  • In the classroom: your progress and your game records (perfil_aula, candado.*, intro_*).
  • In the team's pre-inspection tool: photos are kept on the device until they are sent.
  • In Pre-shipment inspection at origin: the photos the supplier takes are kept on their own device until they are uploaded (in case the signal drops).
  • ac_idioma, ac_idioma_visto: the language you chose (Spanish, English or Chinese) and whether you already saw the notice to change it.
• All of this is technically necessary for the page to work. You can delete it whenever you want from your browser (Settings → Privacy → Clear site data, or in Chrome: the padlock next to the address → Site settings → Clear data). If you delete it, the page will ask for your key again.
• The «Pega el link» and «Anúnciate» pages load fonts from Google Fonts: when you open them, your browser connects to Google, which can see your IP.
• When you arrive from an ad, we only keep one word of origin (for example, «facebook»), never the ad identifier.

10. How to limit the use or disclosure of your data

• Write to [email protected] and tell us what you want to limit (for example, «No quiero avisos»). We add you to our internal list of people who do not want notices and confirm it through the same channel.
• On the free page, do not type your name or contact if you do not want a brokerage to give you a quote: the analysis works the same.
• In your queries, upload only the necessary documents.

11. Your ARCO rights and how to exercise them

You have the right to Access your data, Rectify it, Cancel it (have us delete it) and Object to its use (arts. 21 to 26 of the Law).

How: send an email to [email protected] with (art. 28 of the Law):

• your name and an email, WhatsApp or address where we can answer you;
• a copy of your official ID or, if you act through another person, the document proving their representation and the ID of both;
• which right you want to exercise and over which data (for access it is enough to say you want to see your data);
• any information that helps us find it (for example, the email or WhatsApp with which you opened your account);
• if you ask for rectification: what must be corrected and the document that supports it.

Time limits (art. 31 of the Law, in business days): we answer within 20 days at most from receiving your request and, if it applies, we carry it out within the following 15 days. Only if the case justifies it, each period may be extended once for the same time, and we let you know.

How we give you access: by email, in a readable file (art. 32 of the Law). The procedure is free of charge; only the cost of copies or shipping could be charged (art. 34 of the Law).

We may deny the request, in whole or in part, only in the cases of art. 33 of the Law (for example, if identity is not proven or if we do not hold that data), and we will tell you why. We cannot cancel data that the law requires us to keep (art. 25 of the Law).

Note: the documents of your queries are not stored, so there is normally nothing of them to deliver or delete. Free-page data are encrypted fingerprints that we cannot link to you.

12. Consent and how to withdraw it

• By requesting your trial query, using your key or using the free page, you accept this notice for the necessary purposes (tacit consent, art. 7 of the Law).
• To send your contact to a brokerage and for «Anúnciate» we ask for your express consent with a box.
• You can withdraw your consent at any time, without retroactive effect, by writing to [email protected] with the same information as in point 11. We answer within the same time limits. If you withdraw consent for a necessary purpose, we will no longer be able to provide that service to you.

13. Security

We use an encrypted connection (HTTPS), access keys, databases closed to the public that can only be reached through functions that check a system key, encrypted fingerprints instead of IPs, and systems configured not to store the content of queries (art. 18 of the Law). If a security breach occurs that significantly affects your rights, we will notify you immediately through the contact details we have (art. 19 of the Law).

14. Changes to this notice

• We publish any change on this same page (aduanaclic.com/privacidad) with its new date and version number.
• If the change is important (a new purpose, keeping something we do not keep today or a new transfer), we also announce it on the page where you give your data and, if you have an account, by email or WhatsApp; and we ask for your consent again when the Law requires it (art. 11 of the Law).

15. Authority

If you believe your rights were not respected, you can go to the Secretaría Anticorrupción y Buen Gobierno (Ministry of Anti-Corruption and Good Government), the authority for personal data held by private parties since March 21, 2025 (previously the INAI). The request for protection of rights is filed within the 15 business days after we answer you or, if we do not answer, after our time limit expires (arts. 38 to 41 of the Law). More information: gob.mx/buengobierno.

Legal basis: Ley Federal de Protección de Datos Personales en Posesión de los Particulares (DOF 20-03-2025, last amended DOF 14-11-2025), in particular arts. 2, 7 to 16, 21 to 36 and 40; its Regulations (Reglamento, DOF 21-12-2011) and the Privacy Notice Guidelines (Lineamientos del Aviso de Privacidad, DOF 17-01-2013) insofar as they do not contradict the Law.