SwitchRay is a brand of Nexaswitch Global, LLC. 

This Privacy Policy (the “Policy”) is issued by Nexaswitch Global, LLC (“Nexaswitch”), which operates under the SwitchRay brand (“SwitchRay”), and establishes SwitchRay’s approach to compliance with personal data protection regulations when it carries out the processing of such information as a data controller and/or data processor. This Policy does not replace any specific data protection requirement that may apply under a specific mandate of local laws and regulations corresponding to the additional requirements or restrictions that may exist under them for the collection, use, disclosure, and circulation of personal data. Accordingly, where applicable, local laws and regulations shall prevail. 

Likewise, the Policy describes the processing of personal data in order to meet the required data protection standards, as well as compliance with privacy laws and regulations. These guidelines are given to both SwitchRay’s employees and contractors, who assume the duty of ensuring compliance with these Policies and with applicable regulations in this respect. 

This document sets out the privacy rules applicable to the services offered by SwitchRay through its technology platforms (the “Platforms”), which are available on this website, as well as the website itself and the other activities carried out by SwitchRay with the personal information it collects. Visitors to this website and users of the Platforms, by providing their personal data, expressly, previously, and knowingly state that they have read and understood this Policy, as well as the Platforms’ Terms and Conditions of Acceptable Use. 

Under this Policy, SwitchRay undertakes to protect the privacy of its users and to protect them against the misuse of their personal information. This Policy, which is incorporated into the Platforms’ Terms and Conditions of Acceptable Use, explains the practices applicable to the information that the user creates, enters, or asks SwitchRay to collect and process as a processor, as applicable, through SwitchRay’s Platforms, as well as the privacy settings the user may choose in order to protect and share the information provided and/or collected through the Platforms. 

SwitchRay is a brand of Nexaswitch, which is part of the portfolio of companies held by Identidad Group. Notwithstanding that portfolio relationship, Nexaswitch is an independent legal entity, maintains its own corporate documentation, and acts autonomously in providing its services and in processing the personal information described in this Policy. Accordingly, all references in this document to “SwitchRay” refer exclusively to SwitchRay, that is, to Nexaswitch acting under the SwitchRay brand, in its capacity as data controller and/or processor, and not to Identidad Group or to any other company in its portfolio. 

1. Registration, Collection of Personal Information, Processing, and Sharing

When registering an account on SwitchRay’s Platforms, the user will be asked to voluntarily provide certain personal information, specifically identifying data, the name of the representative or user, email address, phone numbers, country of origin, time zone, company name and address where applicable, company phone number, account credentials (for example, login credentials for PayPal or other third-party sites), and any other information the Platforms require to provide the services. By entering such information, the user accepts and understands that this personal and corporate identifying information is thereby voluntarily provided to SwitchRay when registering on the Platforms. The user accepts and acknowledges that it is their responsibility to customize their account using the privacy settings provided by SwitchRay’s Platforms. 

To ensure the security of personally identifiable information, SwitchRay recommends that Platform users periodically change their passwords and update their privacy settings within the Platforms in order to maintain the recommended security standards. If a user forgets their password, SwitchRay may notify them by email of the procedure to reset it, sending a temporary access key to the registered email address associated with their username. The user’s personal password is confidential and will be encrypted to ensure its confidentiality. 

By using our Platforms, the user agrees to the collection, transfer, transmission, circulation, processing, storage, and disclosure of their information as described in this Policy. Regardless of the country in which the user resides or from which they provide their information, by using the Platforms the user accepts and acknowledges that such data may be transferred or transmitted by SwitchRay to other countries such as the United States or any other country where SwitchRay operates. SwitchRay has access to and collects all information voluntarily provided by the user by email, through forms contained on the Platforms, its online interfaces, or other direct contact mechanisms the user has with SwitchRay. 

SwitchRay may also collect information about the services used within and from the Platforms, how they are used, and other analytical metrics in order to provide better services or to explore offering new products with enhanced functionality. Such information may include IP address information, device identification, “cookie” information, and the type of browser used to access our Platforms. SwitchRay also automatically receives information about the communications service sent or received using the Platforms’ services. This may include delivery receipt information, uploaded phone numbers, size of the content transmitted, transmission time, and descriptive information about the messages transmitted. As part of this processing, SwitchRay informs you, as a user of the Platforms, of the following: 

• What personally identifiable information is collected through SwitchRay’s Platform websites, how it is used, and with whom it may be shared. 

• What options are available to you regarding the use of your data. 

• The security procedures established to prevent misuse of your personal information. 

• How you can correct any inaccuracy in the information. 

SwitchRay will not share your information with any third party outside our organization that has no relationship with us, and undertakes to share collected personal data with third parties only when necessary to provide the services requested by the user, to comply with legal requirements, and to provide any cooperation required in legal proceedings, investigations, subpoenas, and requests from competent authorities. 

Internal Use of LinkedIn and Meta Integrations 

SwitchRay uses an internal tool that connects, through the official LinkedIn and Meta (Facebook and Instagram) APIs, exclusively to social media accounts and pages owned by SwitchRay. This tool is not a product or platform that SwitchRay markets, licenses, sells, or makes available to third parties, clients, or external users; its sole purpose is to manage SwitchRay’s own presence on those social networks. 

These accounts are connected under the express authorization that SwitchRay, as the account holder, grants through the authentication and authorization mechanisms provided by each platform. SwitchRay may revoke that authorization at any time from the settings of the corresponding account or from the tool’s own settings. 

2. Financial and Payment Information Collected by SwitchRay for the Purchase of Services

To use the services provided through the Platforms, the user must voluntarily provide and disclose accurate and correct payment information, including, among others, contact information, email addresses, and financial information (credit card number, expiration date, or ACH information), as well as the transactional information necessary to make the corresponding payment for the services SwitchRay provides through its Platforms. SwitchRay uses that information for billing and payment purposes in connection with the services you contract as a user of the Platforms. 

SwitchRay may contact the user if it needs to obtain information regarding any payment transaction for the contracted services. SwitchRay will use trusted third-party services, payment processors, or commercial service providers to process online payments. It may likewise share the user’s information with such third parties for online payment processing purposes. Any fraudulent financial information provided by the user to SwitchRay will be governed and handled in accordance with our Terms and Conditions of Acceptable Use. In such a case, the user accepts and acknowledges that they will hold SwitchRay harmless from any claim or damages arising against it as a result of providing false information or information provided for fraudulent purposes. 

3. Other Information Collected by SwitchRay

SwitchRay may request, through some of the forms available on the Platforms, the information necessary to provide the user with a better service. Such information may include, in addition to that already described, academic information, gender, date of birth, personal interests, and information about how the user learned of SwitchRay’s services, among other information. Depending on the form the user accesses on the Platforms, this information may or may not be required. 

4. Cookies

SwitchRay uses “cookies” or similar technologies to collect this type of personal data. SwitchRay notes that cookies are a small amount of data that generally includes an anonymous unique identifier, which is sent to the user’s computer through a website and stored on their hard drive in order to safeguard their browsing preferences. This data, stored on the Platform user’s hard drive, helps us improve their access to the Platforms and identify visitors. Platform users can configure their browser to accept all cookies, reject them, or receive a notification when a cookie is sent. 

We note that if the user chooses to reject all cookies in their browser, they may not be able to effectively use some of the resources and services offered by SwitchRay on its Platforms. If the user decides to reject all of SwitchRay’s cookies in their browser, they should contact us in advance to make sure that the right to reject cookies does not limit the Platforms’ own functionalities. The user may direct such inquiries to the following email address: contact@switchray.com. The use of cookies to identify the user saves them from having to provide their username and password each time they log in, which we apply under strict security standards. This procedure will save them time. Cookies may also allow us to track and target our users’ interests in order to improve the experience on our Platforms. In general, SwitchRay uses this information to improve the user experience, as well as the quality of our services. 

5. Information Required for User-Requested Analytics

In order for SwitchRay to provide analytical reports through the Platforms, we may collect and use certain special information required to carry out such activities (see the scope in the Terms and Conditions of Acceptable Use). Such information may include data about the user’s devices, phone numbers and mobile network information, browser information, country and city location, as well as online behavior and subscription preferences on the Platforms. We note that by using SwitchRay’s Platforms and providing SwitchRay with information about the final recipients of messages sent through the Platforms, the user represents to SwitchRay that such final recipients have authorized them to share their information with SwitchRay for the purposes set out in our Privacy Policy. 

5A. Integration with the LinkedIn and Meta APIs 

SwitchRay has developed an internal tool that integrates with the LinkedIn and Meta (Facebook and Instagram) APIs for the sole purpose of managing social media accounts and pages owned by SwitchRay. This tool is used to publish content, view engagement metrics (analytics), and manage SwitchRay’s presence on those social networks. 

This functionality is for SwitchRay’s internal use only. SwitchRay does not offer, sell, license, or distribute this tool to third parties, clients, or external users, and does not use it to manage social media accounts owned by third parties. 

Access to SwitchRay’s LinkedIn and Meta accounts occurs solely through the official authentication and authorization (OAuth) mechanisms provided by each platform, and under the permissions (“scopes”) expressly granted by SwitchRay as the holder of those accounts. 

Information obtained through these APIs — including profile information for the managed pages, analytics metrics, publications, and engagement statistics — will be used by SwitchRay exclusively to manage its own social media presence, in accordance with the policies, terms, and conditions of each platform and applicable data protection regulations. 

SwitchRay does not sell, redistribute, or share with unauthorized third parties any information obtained through the LinkedIn or Meta APIs. 

Information obtained through those APIs will not be used for unauthorized profiling, advertising directed at third parties, or any purpose other than managing SwitchRay’s own accounts as expressly authorized by each platform. 

6. Processing of Information by SwitchRay in Connection with Services Contracted by Users

The user accepts and acknowledges that any processing of information carried out by SwitchRay will be performed under an engagement granted by the user in accordance with this Policy and the Platforms’ Terms and Conditions of Acceptable Use. SwitchRay will process the personal information provided as a data processor, such that the user accepts and acknowledges that they act as the data controller under applicable law. Accordingly, SwitchRay will process the personal information provided on the user’s behalf and in accordance with the instructions and purposes indicated in each case. 

This Policy applies to the information SwitchRay collects about Platform users, with the caveat that if a user provides personal data belonging to third parties, they do so because they hold the express authorization of those data subjects to process their personal information through the Platforms, and because they have granted SwitchRay, with sufficient scope, the engagement to carry out the contracted activities based on the information provided. The information the user provides as a user of SwitchRay’s services will be used in accordance with the purposes described here. Accordingly, the user guarantees that the data (including, but not limited to, personal data and sensitive data) provided through the solutions offered by the Platforms and/or shared with SwitchRay in connection with the performance of the contracted services has been collected legitimately and, in all cases, in compliance with the rules applicable to personal data protection, providing only that data for which they hold the data subject’s express authorization for the processing to which it will be subject under the service provided by each Platform, and stating that the delivery and/or collection of such information, whether directly to SwitchRay or through the solutions provided by the Platforms, has the authorization of the data subjects and is consistent with the purposes authorized by them. 

By using the Platforms, the user undertakes to apply the necessary prior filters to ensure that any access by SwitchRay and/or the solutions provided by the Platforms to information contained in the user’s systems and files is directly related to the purpose for which the services provided by the Platforms were contracted, as set out in the Terms and Conditions of Acceptable Use of each of them, and that such information will be transmitted in compliance with applicable data protection regulations and, in every case, giving special effect to the regime applicable to the transmission and collection of sensitive data, where applicable. Access to the data and/or information provided by the user for the purposes of each Platform will not be considered a transfer of personal data but rather a transmission of personal data from the user to SwitchRay, it being understood that SwitchRay thereby acquires the status of processor and not controller, since that status is attributed to the user. By using the Platforms, the user expressly states and acknowledges that they have obtained the express consent of all recipients of the mechanisms used to collect information so that SwitchRay may provide the services offered through each of the Platforms, as described in this document and in the Terms and Conditions of Acceptable Use of each Platform, releasing SwitchRay from any administrative or judicial liability for failure to comply with this obligation. 

The user accepts and acknowledges that SwitchRay will process the personal information the user provides and that is collected through the solutions provided by the Platforms for purposes of providing the contracted services, storing the information under strict security conditions and maintaining confidentiality and reserve regarding the databases in which it will be stored. Each party will hold the other harmless, under the parameters and limitations set out in this Policy, against any legal action, claim, sanction, and/or indemnification it may be required to assume as a result of a breach of the obligations contained in this Policy or of the rules governing the matter. In the event of a breach attributable to one of the parties, that party must defend the other against any request, inquiry, or investigation initiated by the competent authorities. 

In the event that, in the course of carrying out the engagements the user grants to SwitchRay under the services provided by each of the Platforms, sensitive data is collected, the applicable legal regulations governing the matter will be taken into account. SwitchRay, as a processor of data provided by the client or collected as a result of providing the services of each Platform, is subject to compliance with the following obligations: (i) process the data provided and/or collected in accordance with the user’s instructions, and it may not apply or use them for a purpose other than that set out in the Terms and Conditions of Acceptable Use of each Platform or one expressly and legitimately indicated by the user, nor transfer or transmit them (not even for retention) to other persons when doing so is not consistent with the purpose of the service provided by each Platform; (ii) access the data provided and/or collected only when necessary to provide the service offered by each Platform, in its capacity as processor; (iii) refrain from manipulating or transforming the data provided and/or collected, limiting itself, as processor, to using the data for the purpose of the service provided by each Platform; (iv) maintain confidentiality regarding the data provided and/or collected; (v) apply to the data provided and/or collected the technical, human, and administrative security measures necessary to secure the records, preventing their alteration, loss, unauthorized or fraudulent consultation, use, or access, according to the nature of the personal data processed in providing the service offered by each Platform; (vi) ensure that the data provided and/or collected are handled only by those persons whose involvement is necessary to provide the service offered by each Platform; (vii) generally, SwitchRay will observe all provisions and organizational and technical measures necessary to guarantee the security of the data provided and/or collected, carrying out all acts that are required or simply advisable in order to strictly comply with its obligations regarding the protection of personal data; and (viii) upon termination of the contractual relationship arising from the contracting of the services of each Platform, return all copies and media containing the data provided and/or collected, in accordance with the user’s instructions and those set out in any agreements executed for that purpose or in the Terms and Conditions of Acceptable Use of each Platform, so that it may thereafter destroy them and suspend their processing. 

This obligation may be satisfied through the anonymization or de-identification of the data provided by the user for the provision of the service offered by each Platform, or of data collected in that connection. The foregoing is without prejudice to the rules on document and/or information retention applicable to SwitchRay and/or to the software SwitchRay enables to provide the service offered by each Platform. 

6A. Retention, Storage, and Deletion of LinkedIn and Meta Credentials 

Authentication credentials and access tokens issued by LinkedIn and Meta for SwitchRay’s own accounts are stored securely, are protected using appropriate technical and organizational security measures, and are retained only for as long as the corresponding integration remains active. 

If SwitchRay deactivates or revokes an integration, or it is no longer needed, the associated credentials will be securely deleted in accordance with SwitchRay’s internal security procedures. 

Data obtained through these integrations will be retained only for as long as necessary to manage SwitchRay’s social media accounts, and will be deleted or anonymized once the integration is revoked or the data is no longer needed. 

SwitchRay implements reasonable technical and organizational procedures to ensure the secure deletion of information and to prevent unauthorized access during storage or destruction processes, limiting access to such credentials to authorized personnel and systems only.

 

7. Security

SwitchRay takes precautions to protect your personal information hosted on the Platforms, which is safeguarded both online and offline. Please note that whenever SwitchRay collects personal information – which will be treated as confidential within our systems – that information is delivered securely via SSL under network security protocols. This information is likewise encrypted. To protect the integrity of the information, only SwitchRay employees and/or collaborators who need it will have access to it, in connection with the specific work they must carry out. The computers and servers on which SwitchRay stores the information are kept in a secure, protected environment. Please note that SwitchRay may process personal information on a server located inside or outside the country where the data subject resides, or one other than the country from which they use the Platforms and the services contained therein. 

Security of API Integration Credentials 

SwitchRay implements reasonable technical, administrative, and organizational measures to protect personal information and the credentials used in integrations with third-party APIs and platforms. 

Authentication credentials used to access third-party APIs are transmitted using secure communication protocols and are protected through appropriate technical and organizational safeguards. Access is limited to the authorized personnel and systems responsible for operating the Platforms. 

Such measures may include: 

• encryption of information in transit and at rest, 

• role-based access controls, 

• secure authentication mechanisms, 

• protection of API credentials and tokens, 

• access monitoring, and 

• security procedures designed to prevent unauthorized access, alteration, disclosure, or destruction of information. 

8. Contact Channels and Department Responsible for the Protection of Your Rights

You, as a user and/or final recipient of the Platforms’ services and as the data subject of the personal information provided, may submit any specific inquiry about the security of your information, or to exercise your data protection rights, through the following email address: contact@switchray.com. Likewise, the user and/or final recipient may use the Customer Service lines available on SwitchRay’s website, which can be reached at the following email address: contact@switchray.com. If the user and/or final recipient believes a violation of this Policy has occurred, they may notify SwitchRay through the email account mentioned above. In such a case, the user and/or final recipient should be sure to include any relevant information about why they believe a violation of the Policy has occurred, as well as any other information relevant to helping SwitchRay conduct the corresponding investigation and take measures to protect the rights involved. These contact channels are handled by the Customer Service department responsible for the protection of personal data within the organization. The entity responsible for addressing these requests is Nexaswitch, which operates under the SwitchRay brand. 

9. Rights You Hold as a Data Subject of Personal Information

As a user and/or final recipient of the Platforms’ services, you have the following rights regarding the personal data provided: 

• Access and review the data SwitchRay has collected about you, as well as your user account information, where applicable. 

• Change, modify, correct, or delete any information you have provided to SwitchRay or that has been stored in your session. 

• Opt out of or unsubscribe from receiving email communications from SwitchRay. 

• Unsubscribe from email communications via the link at the bottom of the messages SwitchRay sends you by email, where applicable. 

• Request proof of the authorization given for the processing of your personal information. 

• Be informed of the purposes for which the personal information provided is used. 

• Submit inquiries and complaints to SwitchRay regarding the processing of your personal information. 

• File complaints with the competent authorities regarding the use of your personal information. 

To exercise these rights, you, as a user and/or final recipient of the Platforms’ services, may use the contact channels provided by SwitchRay, which undertakes to address and substantively resolve the requests you submit. 

10. No Processing of Minors’ Data

By using the Platforms, the user accepts and acknowledges that, as a user of accounts created on the Platforms, they are at least 18 years of age in order to use the services offered by SwitchRay, since these may only be used by that population. They likewise accept and acknowledge that they must not allow persons under 18 years of age to access or use the Platforms or the contracted services. Please be sure to follow these guidelines. Failure to do so may subject you to a variety of actions, including limitations, immediate suspension, or cancellation of your account. Likewise, by using the Platforms, the user accepts and acknowledges that SwitchRay has no knowledge of the actual use of the services and Platforms, which is why the user certifies that the personal data they provide is their own, and that if such information belongs to third parties or to minors, they certify that they are providing it because they act as the representative or guardian of that individual and/or hold sufficient authorization to do so, as applicable. 

11. Changes to This Policy

SwitchRay may review the provisions contained in this Policy and make any modifications it deems appropriate. The most current version of the Policy will govern our use of the information. If we make a change that, in our sole discretion, is material, we will notify you at the email address associated with your account. 

12. Periodic Updates to the Policy or Updates to the Terms and Conditions of Acceptable Use

This Policy was last updated in September 2026 and may be reviewed or updated every 12 months. The most current version of the Policy will be in effect on SwitchRay’s website, www.switchray.com. All SwitchRay services will be subject to the Terms and Conditions of Acceptable Use of each Platform, which are published on the corresponding web