Legal
Privacy
What data we collect, why, and how to exercise your rights, whether you are in Panama, the United States or Europe. Draft pending legal review.
Translation notice: this is an English translation of our política de privacidad. If the two versions differ, the Spanish version prevails.
In short: if you only read Comentamos, we don't ask for any data or set any cookies. We only keep your email if you subscribe to the newsletter, we don't sell data to anyone, and we don't do targeted advertising.
1. Who is responsible
The data controller is Comentamos, a digital outlet operated from Panama by an individual domiciled in the Republic of Panama. For any privacy matter, write to hola@comentamos.com.
2. What data we process and for how long
| What | Data | Purpose | Retention |
|---|---|---|---|
| Newsletter email | Your email address, the sign-up date, the consent text you accepted, and which part of the site and language you signed up from. | Sending you the newsletter and being able to prove you gave consent. | While you remain subscribed. We delete it if you unsubscribe or ask us to. |
| Ad measurement | Which ad was seen or clicked, on which page and when, together with a pseudonymous identifier that changes every day. We do not store your IP address or use cookies. | Counting impressions and clicks for campaign reports, without counting the same visit twice and filtering out bots. | For as long as it is needed for campaign reports. |
| Abuse prevention | The same daily pseudonymous identifier and the number of recent sign-up attempts. | Preventing mass or automated form submissions. | Only as long as needed to count recent attempts. |
| Emails you send us | Your address and whatever you tell us when you write to our contact email. | Replying to you. | As long as needed to handle your message. |
| Editorial team | Email and encrypted password of the people who publish. | Secure access to the editorial dashboard. | While they are part of the team. |
The pseudonymous identifier is computed on our server from your connection, your browser, the date and a secret key. It changes every day and does not let us know who you are. We do not use it to follow you across days or across websites.
We use the measurement figures to produce aggregated reports per ad and per page for advertisers. Those reports contain no data about any individual.
3. What we don't do
- We don't sell or rent personal data.
- We don't share data with advertisers: they only receive aggregated figures.
- We don't do behavioral advertising, profiling, or automated decisions that affect you.
- We don't use third-party analytics, advertising pixels, or tracking social buttons.
- We don't ask for sensitive data. Please don't send it to us.
If we ever change anything on this list, for example by adding third-party advertising, we will update this page and ask for your consent beforehand where the law requires it.
4. Service providers and transfers
To run the site we use providers that process data on our behalf and under our instructions:
| Provider | Purpose | Location |
|---|---|---|
| Supabase | Database, files and dashboard sign-in | United States |
| Vercel | Website hosting | United States and global network |
| Cloudflare | Domain (DNS) and forwarding of our contact email | Global network |
| Google (Gmail) | Mailbox where we receive contact emails | United States and other countries |
Your data may therefore be processed outside Panama, mainly in the United States. We rely on the safeguards these providers offer in their data processing agreements, such as the standard contractual clauses approved by the European Commission. We may also disclose data when a competent authority lawfully requires it.
5. Your rights and how to exercise them
Wherever you are, you can ask us to access your data, correct it, delete it, object to its use, receive a portable copy, and withdraw your consent. To unsubscribe from the newsletter, just ask; once we start sending it, every email will include an unsubscribe link.
- How: write to hola@comentamos.com from the email address concerned and tell us what you need.
- Verification: we may ask you to confirm that the email address is yours before handing over or deleting data. We will never ask for documents that aren't necessary.
- Timing: we reply within 10 business days at the latest.
- Free and without retaliation: exercising your rights costs nothing and doesn't change how we treat you.
- Authorized agents: someone else can make the request for you if they show that you authorized them.
- If you disagree with our answer, you can ask us to review it and contact the relevant authority (see below).
6. Panama
We process your data under Law 81 of 2019 on personal data protection and its regulation, Executive Decree 285 of 2021.
- Basis: your consent for the newsletter; for ad measurement and abuse prevention, pseudonymous data that doesn't identify you.
- ARCO rights and portability: access, rectification, cancellation, objection and portability, as explained in section 5.
- Authority: if you believe we didn't handle your request properly, you can file a complaint with the National Authority for Transparency and Access to Information (ANTAI).
7. United States
Several states (including California, Virginia, Colorado, Connecticut, Utah and Texas) give their residents privacy rights. Although some of those laws only apply above a certain business size, we offer these rights to every reader in the United States:
- Know and access: the categories of data we hold, where they come from, why we use them and who we share them with. They are described in sections 2 and 4.
- Correct and delete your data.
- Do not sell or share: we don't sell personal data or share it for cross-context behavioral advertising, and we don't process sensitive data to infer characteristics about you. We honor the Global Privacy Control signal, although today there is nothing to opt out of.
- Appeal: if we deny your request, you can ask us to review it and, if you still disagree, contact your state attorney general.
- No discrimination for exercising your rights.
- California (Shine the Light): we don't share data with third parties for their own direct marketing.
- Children (COPPA): the site is not directed at children under 13 and we don't knowingly collect their data. We don't sell or share data of anyone under 16.
- Email (CAN-SPAM): the newsletter only goes to people who subscribe, identifies itself as Comentamos, and every issue will include a postal address and an unsubscribe link that we will honor promptly.
Browsers with a "Do Not Track" setting change nothing here, because we don't track your activity.
8. Europe (European Economic Area and United Kingdom)
If you read us from Europe, the General Data Protection Regulation (GDPR) also gives you these guarantees:
| Use | Legal basis |
|---|---|
| Newsletter | Your consent, which you can withdraw at any time. |
| Ad measurement | Legitimate interest in reporting to advertisers, using pseudonymous data, no cookies and no profiling. |
| Abuse prevention and security | Legitimate interest in keeping the site secure. |
| Replying to your messages | Legitimate interest in responding to you. |
| Team dashboard | Performance of our relationship with team members. |
- Additional rights: restrict processing and object to processing based on legitimate interest.
- Transfers: your data is processed outside Europe (section 4) with the safeguards described there.
- Complaints: you can complain to the data protection authority in your country of residence (in the UK, the ICO).
- No automated decisions with legal or similarly significant effects on you.
9. Security, children and changes
Security. We use encrypted connections (HTTPS), restricted database access, hashed passwords and as little data as possible. No system is infallible; if an incident affects your data, we will notify affected people and the authority when the law requires it.
Children. Comentamos is intended for adults. If you are a parent or guardian and believe a child has given us data, write to us and we will delete it.
Links to other sites. Articles and ads may link to third-party sites with their own policies; we are not responsible for them.
Changes. If we change this policy in a meaningful way, we will say so here with the new date and, if we have your email and the change affects you, we will let you know. For cookies, see our cookie policy, and for using the site, our terms of use.