Personal data processing policy

Law 21.719 · version 1.4 · September 15, 2026

Version 1.4 · adopted on September 15, 2026

NeumaDiesel Servicios Industriales SpA (“NeumaDiesel”, “we”) is the data controller for the personal data processed through this website, the careers section and the intranet used by our staff.

This policy is published under Article 14 ter of Law No. 19.628, as amended by Law No. 21.719. It covers these digital channels. Treatments linked to the employment relationship (contracts, payroll, occupational health) are governed by a separate internal notice and are not published on this site.

1. Controller

Controller: NeumaDiesel Servicios Industriales SpA, Chilean tax ID (RUT) 76.676.209-3, doing business as NeumaDiesel.

Representante legal: Mayerlyng Aguilera Sanchez. Gerente general: Cristóbal Oyarzun Gonzalez.

Postal address: Ruta D43 #701 Block 3 Oficina 2, Centro Empresarial Coquimbo, Región de Coquimbo, Chile.

Email for data-subject requests: contacto@neumadiesel.com. Phone: +56 2 3263 7480. You may also use the form in the “Exercise your rights” section of this page. Incoming messages are identified, routed and logged internally so we can answer within the legal time limit.

No data-protection officer has been appointed. Law 21.719 does not require every company to designate one. If we adopt a voluntary infringement-prevention model (Article 49), this policy will be updated.

2. What we process and why

We only collect data that is needed for the purpose you requested: answering an inquiry, assessing a job application, or letting authorized staff use the intranet. We do not sell personal data and we do not use contact or application data for marketing.

The table below is our record of processing activities for these digital channels.

Record of processing activities

Digital channels of the website and intranet. Source: current systems · policy version 1.4.

Website inquiries and quotations

Data subjects
People who write through the contact form.
Data
First name, last name, email, phone (optional), company (optional), subject and message.
Purpose and legal basis
To answer the inquiry or quotation requested by the data subject. Not used for marketing. Art. 13 (c) of Law 19.628 (pre-contractual steps at the data subject’s request).
Recipients
NeumaDiesel commercial staff. Email transits through Amazon SES (processor).
Retention
For as long as needed to complete that inquiry or quotation and at most 12 months after the last contact on that request. It must then be deleted from the mailbox. Not used for marketing. Not stored in our own database.
Transfers
Email is sent via Amazon SES. The processor’s servers may be outside Chile (United States).

Job applications

Data subjects
People who apply to a vacancy published on the site.
Data
Name, email, phone (optional), expected salary, cover letter (optional) and CV (PDF or Word). The CV may contain other data the applicant includes in the file.
Purpose and legal basis
To assess the application for the specific vacancy and contact the applicant if the profile matches. Art. 13 (c) to identify and assess the application for that vacancy. Expected salary is optional and is used only for that process, with a specific checkbox; it is not used to infer socioeconomic situation. The CV is processed insofar as it is needed for the role; there is no generic authorization for sensitive data.
Recipients
HR staff with ADMIN or RECRUITER role. Processors: file storage (Amazon S3) and email (Amazon SES).
Retention
For that vacancy’s process and up to 12 months after closure, to finish that same search (replacement if the selected person does not take the role, questions about the process) and, where needed, to establish or defend a claim (Art. 13 (e)). Not a talent pool. Unsuccessful applications are then deleted automatically. If hired, the selection file is not kept indefinitely: only what is needed moves to the personnel file.
Transfers
CVs are stored in Amazon S3 (intended region: United States, us-east-1). Notifications are sent via Amazon SES.

Staff access to the intranet

Data subjects
Employees and contractors enabled by an administrator.
Data
Corporate email, name, role, account status and last login date.
Purpose and legal basis
To authenticate and authorize access to the internal panel (job offers and applications). Art. 13 (c) (performance of an employment or service contract) and Art. 13 (b) when access control is required by law.
Recipients
Intranet administrators. Identity processor: Microsoft Entra ID.
Retention
While the person is enabled and, after deactivation, for as long as labor, tax or security duties require.
Transfers
Authentication runs through Microsoft. Account data is stored in Chile or in the infrastructure hired for the intranet.

Site security and session

Data subjects
Contact-form visitors, intranet users and anyone who chooses to show the map on the contact page.
Data
Intranet session cookie (httpOnly JWT), Cloudflare Turnstile anti-bot token and technical data Google Maps may process to show the map.
Purpose and legal basis
To protect the form against automated submissions, keep the HR session and show the office location. Art. 13 (d) (legitimate interest in site security) for Turnstile and the session. The map loads only if the user chooses to show it; it is not used for advertising.
Recipients
Cloudflare (Turnstile) and Google (Maps). We do not automatically classify them as processors. The session cookie is not shared with marketing third parties.
Retention
The intranet session lasts 8 hours. Turnstile does not keep an account of the visitor on our side. We do not use analytics or marketing cookies.
Transfers
Cloudflare and Google may process data outside Chile. The current site does not use Google Analytics or advertising pixels.

3. Legal bases

Answering a contact or quotation request and assessing a job application are based on Article 13 (c): pre-contractual steps at your request. You do not have to “accept privacy” as a condition to send a message whose only purpose is that we reply.

Expected salary is optional. It is personal data and is used only to assess this vacancy, not to infer your socioeconomic situation. A specific, unticked checkbox records that use. We do not treat every salary expectation as sensitive data under Article 2 (g). You may withdraw that authorization without preventing assessment of the rest of your file (Article 13 (c)).

The CV is processed under Article 13 (c) insofar as it is needed to assess the role. We ask you not to include unnecessary sensitive data (Article 2 (g)). There is no generic authorization to process sensitive data in the CV. If you include any, HR will not use it for the hiring decision and may remove it from the selection file.

Staff intranet accounts are based on the employment or service relationship (Article 13 (c)). Turnstile and the session cookie are based on our legitimate interest in security (Article 13 (d)).

4. Recipients and processors

Inside the company, only people who need the data for the stated purpose can access it (sales for contact messages; HR for applications).

Providers that process data on our instructions (processors, Article 15 bis): Amazon Web Services (email via SES and CV storage in S3) and Microsoft (Entra ID for staff login). The applicable contracts and data-processing addenda are under review so they meet Articles 15 bis, 27 and 28.

Cloudflare Turnstile and Google Maps are third-party services that may process technical data when you use those features. They are not automatically classified as our processors; they may act as independent controllers of some technical data under their own terms.

5. International transfers

CVs are stored in Amazon S3 in region us-east-1 (United States). Email via SES and authentication via Microsoft may also involve processing outside Chile. Cloudflare may process Turnstile data outside Chile.

The United States is not listed as providing an adequate level of protection equivalent to Chilean law. Ongoing storage of CVs in that infrastructure is not based on your consent or on Article 13 (c) alone. We rely on the provider’s security measures and on contractual safeguards (Articles 27 and 28), which we are documenting with each provider. If those guarantees change, we will update this policy.

6. Retention

Contact messages: they are not stored in our own database; they transit through the mailbox. They are kept only to complete the commercial follow-up of that inquiry or quotation (clarifications, sending the quote, closing that request), for up to 12 months after the last contact on that request. They are not used for marketing or for other matters. After that period the message must be deleted from the mailbox, unless a legal duty or the establishment or defence of a claim (Article 13 (e)) requires a longer, documented and minimized retention.

Job applications: kept during the selection process for that vacancy. Closing the vacancy stops new applications and does not delete the file at once. Unsuccessful applications and CVs are deleted automatically 12 months after closure. That period was adopted by Recruitment so we can still contact remaining candidates for the same vacancy if the selected person does not take the role, answer questions about that process, and establish or defend a claim related to the selection (Article 13 (e)), using only the data already collected. It is not a talent pool and is not used for other vacancies (Article 14 (d)).

If you are hired, the purpose and legal bases change. Only data needed to perform the employment relationship or to meet legal duties of the employer are moved to the personnel file. Information that belongs only to the selection process is deleted from the recruitment system when it is no longer needed.

7. Security

We apply technical and organizational measures according to the type of data: HTTPS, access limited by role, httpOnly session cookie, private S3 bucket with SSE-AES256 encryption, CV downloads through short-lived signed URLs, file type and size limits, and Turnstile on the contact and rights forms.

If a security incident causes accidental or unlawful destruction, leak, loss, alteration, disclosure or unauthorized access, and there is a reasonable risk to your rights, we will report it to the Agency by the most expeditious means and without undue delay (Article 14 sexies). We keep an internal record of the nature of the incident, its effects, the categories and approximate number of people affected, and the measures taken.

The law does not set a general 72-hour deadline. Seventy-two hours is only an internal maximum for escalation. We will notify the Agency sooner if we already have enough information. We will also notify each affected person, in clear language, when the incident involves sensitive data, data of children under 14, or economic, financial, banking or commercial data. If individual notice is not possible, we will publish a notice in a nationwide mass medium.

Exercise your rights

You may request access, rectification, erasure, objection, portability and temporary blocking of your personal data, and you may withdraw consent where processing is based on consent. These rights are personal and cannot be waived.

How to submit a request: send it to contacto@neumadiesel.com or use the form below. Include your identification, an email to receive the answer, which right you exercise and which data or processing it concerns. For rectification, erasure, objection or blocking, please state the change or ground. We do not automatically require a copy of your identity card; we verify identity in a way that is proportionate to the request.

We will acknowledge receipt and decide within 30 calendar days. That period may be extended once by another 30 calendar days. We will answer in writing to the email you give us and keep proof of the reply.

Temporary blocking: if you request it with grounds, we will decide within 2 business days. While the request is pending we will not further process the data involved, other than storing it.

If we refuse or do not answer on time, you may lodge a complaint with the Agencia de Protección de Datos Personales within 30 business days.

This form is the electronic channel under Article 11. You can also write to contacto@neumadiesel.com. The request is free of charge.

Also by email: contacto@neumadiesel.com

Only if you act on behalf of the data subject.

For example: a job application, a contact message, or the email you used.

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9. Automated decisions

We do not make decisions with legal or similarly significant effects based solely on automated processing. Job applications are reviewed by people in HR.

10. Cookies

The public site does not use analytics or advertising cookies. The intranet sets a strictly necessary session cookie (intranet_session, 8 hours, httpOnly). Cloudflare Turnstile may set its own cookies when you submit a form. The Google Maps embed loads only if you choose to show the map. Details are in the processing table under “Site security and session”.

11. Updates

This is version 1.4, dated September 15, 2026. Material changes will be published on this page with a new version number. The date and version of the policy shown when you send a form will be the reference for that processing.

This policy describes the processing that NeumaDiesel has adopted for its digital channels. Counsel reviewed the wording in September 2026. Contractual review of providers (Articles 15 bis, 27 and 28) remains pending.

Personal data processing policy | NeumaDiesel