Version 2.3 – May 2025.
This End User License Agreement (“EULA”) constitutes a legally binding contract between the User (hereinafter “you”) and Arbeláez Carvajal Tec S.A.S., a company legally incorporated in Colombia, identified with NIT 901576942 and DUNS 987069851, exclusive owner of the registered trademark CASTIERO®.
This agreement governs the access, installation, and use of the Castiero software (hereinafter, the “Software”) by the User. By using the Software, you agree to all the terms set forth below.
For the purposes of this End User License Agreement (EULA), the following terms shall have the meanings as set forth herein. These definitions are an integral part of the contract and condition its interpretation and application:
Castiero: Refers to the software developed and licensed by Arbeláez Carvajal Tec S.A.S., including its interface, features, educational resources, experience system, content modules, gamified logic, and all digital components related to its purpose of financial education.
User: A natural person who accesses, uses, or interacts with the Castiero platform, either as a visitor, participant, subscriber, or holder of an active account, according to the access levels defined by the platform.
Company: Refers to Arbeláez Carvajal Tec S.A.S., identified with NIT 901.576.942-3, holder of Castiero’s proprietary rights and responsible for the processing of personal data in accordance with applicable legislation.
License: A limited, revocable, non-exclusive, and non-transferable right granted to the User to access and use Castiero under the terms and conditions set forth herein, without implying any transfer of ownership or authorization for commercial exploitation.
Content: Digital material accessible within Castiero, including texts, images, sounds, videos, interactive activities, challenges, simulators, graphics, tips, and educational resources, which are owned by the Company or by authorized third parties.
Personal data: All information linked or that can be associated with a determined or determinable natural person, collected through the use of Castiero and processed in accordance with Law 1581 of 2012, Regulatory Decree 1377 of 2013, and other relevant laws.
Support: Channels provided by the Company for technical support, institutional contact, or submission of petitions, complaints, or suggestions, available through the means indicated on the official website.
Authorized third parties: Partners, providers, or external entities with whom the Company maintains contractual or institutional relations that allow, under control and confidentiality, the processing of data, provision of services, or integration of functionalities.
Through this agreement, Arbeláez Carvajal Tec S.A.S. grants the User a non-exclusive, limited, non-transferable, revocable, and personal license to install, access, and use the Castiero® Software in accordance with the terms set forth in this document.
This license allows the User to:
The license does not grant any ownership rights over the Software or its components. All rights NOT expressly granted to the User under this EULA are reserved by Arbeláez Carvajal Tec S.A.S.
This license:
Use of this license is strictly conditional on compliance with the terms set forth in this EULA, as well as any complementary policies related to account management, privacy, and responsible usage.
Castiero may revoke this license immediately and without prior notice if the User commits contractual breaches, engages in misuse, fraud, or violates intellectual property rights or those of third parties.
The license remains valid as long as:
Any use of the Software outside these parameters shall be considered unauthorized and may give rise to legal actions under applicable law.
This EULA grants the User the right to use the Software solely under the terms expressly stated herein. Any unauthorized use shall be considered an infringement of the intellectual property rights of Arbeláez Carvajal Tec S.A.S. and will result in immediate termination of the license, without prejudice to legal actions.
The User expressly agrees to refrain from:
Castiero reserves the right to suspend or restrict the User’s access if inappropriate or risky usage is detected.
The Software, including all its modules, features, interfaces, database structures, educational guides, illustrations, sounds, and documentation, is the exclusive property of Arbeláez Carvajal Tec S.A.S., protected under copyright laws (Law 23 of 1982, Law 44 of 1993) and international treaties such as:
The trademark CASTIERO® is registered with the Superintendence of Industry and Commerce (SIC) of Colombia, and its use is prohibited without formal authorization.
The User acknowledges and agrees that:
Any unauthorized use of Castiero’s intellectual rights constitutes a serious violation punishable under criminal, civil, and administrative law.
This agreement does not imply a transfer of economic rights, know-how, trade secrets, or any license over components not expressly granted herein.
Arbeláez Carvajal Tec S.A.S., as the data controller, is committed to ensuring the privacy, integrity, and availability of the User’s personal data, in accordance with international standards and applicable local laws.
Data processing is governed by principles of legality, purpose, transparency, veracity, restricted access and circulation, security, and confidentiality.
Castiero adheres to the following regulations:
🇨🇴 Law 1581 of 2012 (Colombia): Regulates personal data protection through prior authorization, specific purpose, and data subject rights including access, rectification, update, and deletion. Requires implementation of proper security measures.
🇲🇽 Federal Law on Protection of Personal Data Held by Private Parties (Mexico): Requires data subject consent, defines ARCO rights (Access, Rectification, Cancellation, and Opposition), and mandates internal policies and security mechanisms.
🇦🇷 Law 25.326 (Argentina): Recognized as GDPR-equivalent by the EU. Requires database registration, informed consent, and guarantees rights of access, confidentiality, update, and deletion.
🇧🇷 General Data Protection Law (LGPD, Brazil): Requires consent for processing, and establishes principles such as necessity, transparency, and accountability. Grants rights including portability, anonymization, review of automated decisions, and data deletion.
🇺🇸 CCPA (California Consumer Privacy Act): Grants California consumers rights to access collected data, request deletion, and opt out of data sales. Applies to companies meeting certain thresholds.
🇺🇸 COPPA (Children’s Online Privacy Protection Act): For data involving minors in the U.S., requires verified parental consent before collecting information from children under 13.
Additionally, Castiero implements technical and organizational controls based on the ISO/IEC 27001:2022 standard, including access policies, encryption, anonymization, incident monitoring, and regular audits.
Users may, at any time:
Minors’ data processing:
Castiero is not intended for minors without the express supervision of their legal representatives. If the User is a minor, consent will be understood as granted by their parent or guardian, who assumes responsibility for supervision and authorizes data processing in accordance with applicable law.
To exercise these rights, contact info@arbelaezcarvajal.com or use the in-app mechanisms provided.
Arbeláez Carvajal Tec S.A.S. is committed to protecting the confidentiality of all personal, financial, technical, or behavioral information recorded by the User during their use of the Software. Such information shall be considered confidential and handled accordingly, in compliance with the highest international legal and technical standards.
For the purposes of this agreement, “confidential information” means any non-public data submitted by the User through forms, accounts, usage patterns, financial records, or any other means provided by the Software.
Confidentiality is governed by the following principles and standards:
Law 1581 of 2012 (Colombia) and Decree 1377 establish the obligation to ensure restricted access, integrity, and prevent unauthorized disclosure of personal data.
ISO/IEC 27001:2022, the international standard for information security management, requires implementation of confidentiality controls such as access policies, data encryption, traceability, and incident management.
General Data Protection Regulation (GDPR) of the EU, although not binding, serves as a reference for data minimization, confidentiality by design, and granular consent.
Under this EULA, Castiero agrees to:
The User acknowledges that unauthorized access or misuse of their account or device may compromise confidentiality. Therefore, they agree to protect their credentials and report any irregularities.
This confidentiality obligation shall survive the termination of the contractual relationship, as long as the information remains confidential.
Castiero is designed as an ad-free environment, focused exclusively on the User’s financial education. Arbeláez Carvajal Tec S.A.S. guarantees that the User experience will not be subject to commercial stimuli, disguised suggestions, or profit-driven interruptions.
Specifically, the company declares that:
Financial partner directory Castiero may optionally enable a directory of financial partners that the User can access voluntarily. This resource:
Castiero is an educational software designed to provide the User with tools for personal financial management, economic skill development, and informed decision-making. Its content includes:
However:
Sources and methodology. The content is based on:
Limitation of liability. Arbeláez Carvajal Tec S.A.S. shall not be liable for:
The User acknowledges that using the Software involves active learning and self-management, and that their financial progress will depend on commitment, consistency, and critical thinking.
Educational content is not intended to be interpreted or applied by minors without adult supervision. Legal guardians must oversee their access, understanding, and application of financial content.
Arbeláez Carvajal Tec S.A.S. may, at its sole discretion, provide updates, enhancements, bug fixes, security patches, or new functionalities of the Software (hereinafter, “Updates”). These Updates may be automatic or may require User intervention depending on the platform used.
By accepting this EULA, the User authorizes the installation of Updates necessary to ensure the functionality, stability, and security of the Software. Updates are subject to the same license terms unless expressly stated otherwise.
Technical support:
The Company provides the User with technical support and institutional
assistance channels for inquiries, reports, suggestions, or issues related
to the use of Castiero.
Official contact channels are:
The technical support provided by the Company is limited to ensuring proper access and general operation of the Castiero software under normal usage conditions.
Personalized support, financial assistance, or resolution of incidents caused by improper, external, or incompatible use with the platform’s educational purpose is not guaranteed.
Response times and available channels may vary depending on demand, contracted service levels (if applicable), or the Company’s operational conditions.
The Castiero Software may include libraries, dependencies, or modules developed by third parties and licensed under open source schemes, such as:
The User acknowledges that:
Arbeláez Carvajal Tec S.A.S. guarantees that it has verified the legal compatibility between third-party component licenses and their integration into the Castiero® Software, complying with best practices for Free and Open Source Software (FOSS) compliance.
The User acknowledges that the Software is subject to export control laws, economic sanctions, and international regulations governing technology transfer. In particular:
Arbeláez Carvajal Tec S.A.S. does not guarantee compliance with local laws outside Latin America or the United States. The User is solely responsible for verifying the legality of use in their jurisdiction.
The User acknowledges and accepts that use of the Software is at their sole risk and responsibility.
Arbeláez Carvajal Tec S.A.S. makes no warranties that:
To the fullest extent permitted by applicable law, Arbeláez Carvajal Tec S.A.S. expressly limits its liability and excludes:
This limitation of liability shall remain in effect even after termination of this EULA.
If any provision of this clause is declared invalid or unenforceable by a competent authority, such declaration shall not affect the validity of the remaining provisions of this clause or of the EULA as a whole.
This EULA may be terminated by either party at any time, without the need for justification, by notifying the intention to end the contractual relationship.
The User may terminate this agreement at any time by:
Arbeláez Carvajal Tec S.A.S. may revoke this license without prior notice in the following cases:
Upon termination of this EULA:
Termination does not exempt the User from obligations acquired prior to the effective termination date.
Arbeláez Carvajal Tec S.A.S. reserves the right to modify, update, or replace this EULA, in whole or in part, at any time, for reasons including:
In the event of modification:
Continued use of the Software after notification constitutes tacit acceptance of the new terms.
If the User does not agree with the modifications:
It is the User’s responsibility to periodically review this EULA and remain informed of relevant changes or updates.
This EULA binds not only the User and Arbeláez Carvajal Tec S.A.S., but also their legal successors, assignees, merged entities, or acquiring parties.
In the event that Castiero or its owning company is subject to:
this agreement may be automatically transferred to the new holder, who shall assume all contractual obligations established herein, while respecting User rights—particularly regarding personal data processing.
The User will be informed of any significant assignment of rights through available channels and may exercise their right to withdraw consent if they so choose, in accordance with applicable law.
This agreement shall be interpreted and enforced according to the following provisions, depending on the User’s location:
Users located in Latin America: This EULA shall be governed by the laws of the User’s country of residence. Direct and amicable conflict resolution will be encouraged as a first option. In case of dispute, the parties shall submit to conciliation centers, arbitration tribunals, or the ordinary jurisdiction of said country.
Users located in the United States of America: This EULA shall be governed by the laws of the State of Delaware. Any dispute shall be resolved through binding arbitration under the rules of the American Arbitration Association (AAA), conducted in English. The User expressly waives the right to a jury trial.
Users in other countries: General principles of private international law may apply, as long as they do not contradict the User’s fundamental rights or mandatory provisions of their national law.
These provisions shall not affect the mandatory consumer rights of the User, based on their country of residence. In case of conflict between rules, the most favorable provision to the User shall apply.
This EULA has been written in three languages: Spanish, English, and Brazilian Portuguese, to ensure accessibility and understanding by Users in the various regions where Castiero operates.
In the event of discrepancy, ambiguity, interpretation conflict, or translation error between the available versions, the Spanish version shall prevail, as it is the original legal version drafted and registered by Arbeláez Carvajal Tec S.A.S.
The User may choose their preferred language version for reading and consultation, but agrees that, in any legal or contractual circumstance, the Spanish version shall be considered the definitive text.
If any clause, provision, or term of this EULA is declared null, invalid, or unenforceable by a competent judicial or administrative authority, such nullity shall:
The remaining provisions shall remain fully valid and enforceable.
The parties agree to replace any invalid clause with a valid provision that reflects, to the extent possible, the commercial and legal intent of the clause being replaced.
This principle of contractual preservation shall be applied as a priority to maintain the legal relationship between the User and Arbeláez Carvajal Tec S.A.S.
This document constitutes the total, complete, and exclusive agreement between Arbeláez Carvajal Tec S.A.S. and the User regarding the use of the Castiero® Software. It supersedes any prior agreement, communication, proposal, or understanding—whether verbal or written—on the same subject.
No additional conditions proposed by the User shall be binding upon Arbeláez Carvajal Tec S.A.S., unless expressly agreed upon in a written contract signed by both parties.
If Castiero offers features subject to particular conditions (e.g., membership levels, subscriptions, rewards programs, or enterprise licenses), such conditions shall complement this EULA. In case of conflict, the more specific provision related to the feature in question shall prevail.
For any request, inquiry, claim, complaint, exercise of data rights, or matters related to this EULA, the User may contact the owning company through the following official channels:
For legal purposes, all communications must be conducted in Spanish. Castiero is committed to responding within the timeframes established by Colombian law for digital services.
