Privacy policy

1.Controller and Service

1.1Controller. Sherpas Group SpA, RUT 76.271.957-6, domiciled at La Siembra 8934, Vitacura, Santiago, Chile, represented by Gonzalo Esteban Díaz Pearcy (“Sherpas”), is the controller (responsable de datos) of the personal data it processes in connection with SEN Data (the “Service”). “User” means any person who accesses or uses the Service, and “Data Subject” means any person whose personal data Sherpas processes in connection with the Service, including Users, people who request access, people who visit this website and people who communicate with Sherpas.

1.2Service. SEN Data is a free alpha service, with access by request, that delivers public data on the Chilean electricity market (SEN — Sistema Eléctrico Nacional) to the User’s AI assistant (Claude or ChatGPT, including Codex). It connects through an MCP server, the standard AI assistants use to connect to data sources. The SEN Data trust page (the “trust page”, https://sherpas-sen-mcp.web.app) presents the Service’s current coverage and its declared limitations, for each data table.

1.3Contact and data protection officer. For any question about the processing of their data, the Data Subject may write to jorge@sherpas.net. As of the effective date of this policy, Sherpas has not appointed a data protection officer; that address is the channel for everything related to privacy.

2.Personal data processed and purposes

Sherpas processes the categories of personal data described below, for the purposes stated in each case. The basis for the processing is set out in section 3 and the retention periods in section 5.

2.1Use of the MCP server

For each tool call, Sherpas records the date and time, the tool used, the call parameters (filters, periods and any text the AI assistant sent, for example the name of a company or power plant being looked up; for the SQL query tool, the full SQL text), whether the call succeeded or failed, the response time and the number of rows. It also records who made it: the User’s e-mail, the client application that connects (OAuth client) and the name of the AI client (or its browser or client identifier).

This information is used to run and secure the Service, provide support, understand the cost of use and improve the metrics and tools. Sherpas does not receive the User’s conversation with their AI assistant, except what the User decides to include in a report (section 2.4): the AI assistant reasons on its own side and sends Sherpas only the tool call, with whatever text it decides to include in it. The record does not include the IP address, passwords or tokens, or the results returned.

2.2Sign-in

The User signs in with their Google account. Google gives Sherpas the User’s e-mail, the e-mail domain and whether it is verified; never their password. Sherpas uses this data to check that the User is on the list of admitted people and to link each call to their account. To keep the session open, Sherpas stores the session credentials (tokens), encrypted. If it detects that an already-used renewal credential is being reused, it records a technical security notice that contains neither the User’s e-mail nor their IP address.

The sign-in authorization screen informs the User that, by continuing, they accept the Terms of service and this policy (version 1.0), with links to both documents. The notice is shown in Spanish and in English.

2.3Server logs

Google Cloud automatically logs each request that reaches the MCP server: IP address, browser or client identifier, requested address (which may include technical sign-in parameters), method, result, size and response time. Sherpas uses these logs for security and to diagnose failures.

2.4Reports

The Service offers a tool for the User to send Sherpas a report about a specific result or problem, for example a figure they believe to be wrong or a question the Service could not answer. It is a report that the User deliberately writes, not the history of their conversation. It is designed to be sent only when the User asks their AI assistant to send it (/report); the server does not generate it on its own initiative, and the assistant is instructed not to send it without that request.

The only required field is a summary, in the User’s own words, of what they want to report. Optionally, the report may include up to three question-and-answer pairs that the User has expressly chosen to include. The AI assistant is instructed never to compile, summarize or reconstruct the conversation history and not to send anything until the User confirms the exact content. Sherpas adds the User’s e-mail, the date and the name of the AI client, and uses reports to fix errors and improve the Service. The User must not include passwords or third parties’ personal data in a report.

2.5Access-request form

If the Data Subject submits it, Sherpas stores their name, e-mail, organization, role (optional), the description of the intended use of the Service and the submission date, together with the record that they accepted the Terms of service and this policy through the form’s required checkbox: the version accepted and the date. This data is stored in a Google Cloud account belonging to Sherpas (Firestore), not in a third-party forms service, and is used to evaluate the request, contact the Data Subject and prove their acceptance. The form does not create an account or grant access by itself. Anyone who requests access by e-mail instead of using the form must state in the message that they accept both documents (version 1.0); that message is the record of their acceptance (section 2.7).

2.6List of admitted people

To grant access, Sherpas keeps a list of admitted people, which contains the User’s e-mail and, in the access-decision record, their name or organization, the dates of admission and removal and a note on the decision. It is used to check who may use the Service and to keep a record of those decisions. The list is held in a private Sherpas repository (GitHub) and in the server configuration.

2.7E-mails sent to Sherpas

If the Data Subject writes to Sherpas (support, a request about their data or any other question), Sherpas keeps the message and the Data Subject’s e-mail address to reply and handle the request. If the message is an access request in which the Data Subject states that they accept the Terms of service and this policy, the message is also the record of that acceptance.

2.8Usage record (usage limit)

To enforce a technical hourly usage limit, Sherpas records how much the Service processes. Part of that record includes a pseudonymous identifier derived from the User’s account (not their e-mail in clear text). A pseudonymous identifier is not anonymous, so Sherpas treats it as personal data. The global hourly counters contain no personal data.

2.9Records from earlier stages

If the Data Subject took part in tests of earlier versions of SEN Data, which are no longer in service, Sherpas keeps their name, e-mail, a user identifier, their questions and the answers provided at that stage. These records are not deleted automatically; they are deleted at the Data Subject’s request, and the Data Subject may also ask for a copy of them.

2.10Website

Sherpas uses no analytics or advertising tools, and this website does not set its own cookies. The main page loads the Firebase (Google) library needed for the access-request form. When serving the site, Firebase Hosting (Google) and its content delivery network provider may process technical data about the visit, such as the IP address.

2.11Source of the data

Sherpas obtains the data directly from the Data Subject (form, e-mails, reports and the calls their AI assistant makes) and, at sign-in, from their Google account (e-mail, domain and whether it is verified). It does not buy data or obtain it from publicly accessible sources to identify the Data Subject.

3.Basis for the processing

3.1Until November 30, 2026. While the current text of Law No. 19.628 on the protection of privacy (article 4) is in force, Sherpas processes the personal data of a person requesting access with that person’s express consent, given in writing, in electronic form. The person gives it by checking the required box on the access-request form, whose text reads “He leído y acepto los Términos de Servicio y la Política de Privacidad de SEN Data (versión 1.0)” (in English, “I have read and accept the SEN Data Terms of Service and Privacy Policy (version 1.0)”). Together with the request, Sherpas records the name and e-mail that the person enters in the form, the version accepted and the date. Anyone who requests access by e-mail must state in the message that they accept both documents (version 1.0), and that message is the record of their acceptance (section 2.7). When the User signs in, the authorization screen also informs them that, by continuing, they accept both documents (section 2.2).

3.2Other Data Subjects and people already admitted. The following have not checked that box: people admitted before this version took effect, website visitors, people who write to Sherpas without requesting access, and people who took part in earlier stages. For them, Sherpas processes only the data needed to handle what the person has asked for or communicated, to provide and secure the Service and the website, and keeps the records from earlier stages only until their owner asks for their deletion (section 2.9). Sherpas will ask by e-mail that people already admitted accept this version expressly, and will state in that e-mail the version whose acceptance is requested.

3.3From December 1, 2026. From the entry into force of the amendments that Law No. 21.719 makes to Law No. 19.628, scheduled for December 1, 2026, the processing rests on the following bases:

1. performance of the contract with the User and pre-contractual measures taken at the Data Subject’s request (article 13, letter c), for the data the Service needs: the access request, sign-in, the list of admitted people, the usage record used to run the Service and provide support, and the e-mails the Data Subject sends to Sherpas to request access or support;
2. Sherpas’s legitimate interest (article 13, letter d), to protect the security of the Service and prevent abuse (server logs, sign-in security notices and the usage record), to improve the metrics and tools from the usage record, to keep the record of acceptance and of access decisions and the records from earlier stages until the Data Subject asks for their deletion, and to serve the website (technical data about the visit);
3. the Data Subject’s consent (article 12), for what is not necessary to provide the Service, such as the reports the User decides to send.

3.4Withdrawal of consent. The Data Subject may withdraw their consent at any time, without retroactive effect, by writing to jorge@sherpas.net. While consent is the basis for the processing, withdrawing it means ceasing to use the Service.

3.5Information about legitimate interest. From December 1, 2026, the Data Subject may ask at any time to be told what the legitimate interest relied on is in each case and may object to that processing (section 8).

4.Recipients and access to the data

4.1Providers. Sherpas does not sell Data Subjects’ personal data or disclose it to third parties, except to providers that take part in providing the Service, including the following, and to authorities in the case of section 4.4:

1. Google Cloud and Firebase: host and process, to run the Service, the data described in section 2 (server, database, logs, website and form), under their data processing terms for Google Cloud and Firebase. For the website, Firebase Hosting relies on a content delivery network provider (Fastly).
2. Google, as sign-in provider: knows that the User is signing in to SEN Data and gives Sherpas the account data listed in section 2. It processes that data under its own privacy policy.
3. GitHub: in a private Sherpas repository, the list of admitted people (e-mails), the access-decision record and internal analyses of the Service’s use are kept.
4. Analysis tools of the Sherpas team: the team may analyze usage records with analysis tools, including artificial intelligence tools, which process the extracts the team gives them under each tool’s own terms.

4.2The User’s AI assistant. The User’s AI assistant belongs to another company (Anthropic, OpenAI or another), which processes the User’s conversation and the answers of SEN Data’s tools under its own privacy policy. Sherpas does not receive the full conversation: only what the assistant sends in each call and what the User decides to include in a report.

4.3Internal access. Within Sherpas, only team members with access to its technical account and Sherpas’s automated accounts (for the service, monitoring, continuous integration, data ingestion and loading, and deployment, among others) can read these records.

4.4Authorities. Sherpas discloses personal data to authorities when a law or a court order so requires.

5.Retention periods

5.1Periods. Sherpas keeps personal data for the following periods:

1. Tool calls, reports and sign-in security notices: 180 days. Automatic deletion is configured in the database.
2. Usage record with a pseudonymous identifier: 180 days, with automatic deletion active. The global hourly counters, which contain no personal data, are kept without a defined time limit.
3. Server logs (IP address and similar): 30 days.
4. Sign-in sessions: access credentials last 12 hours and renewal credentials up to about a year. An expired session can no longer be used to access the Service, but its record is not deleted automatically; it is deleted at the Data Subject’s request.
5. Access-request form, with the record of acceptance: no time limit or automatic deletion. If Sherpas declines the request or does not proceed with it, the Data Subject may ask for its deletion.
6. List of admitted people: the User’s e-mail remains on the active list while their access lasts and is removed when it ends. The access-decision record, held in a private Sherpas repository, keeps a trace of the admission and the removal (name or organization, e-mail, dates and a note on the decision), with no defined time limit.
7. E-mails sent to Sherpas: not deleted automatically; their deletion may be requested like that of any other data (section 8).
8. Records from earlier stages: not deleted automatically; deleted at the Data Subject’s request.

5.2Free alpha. These conditions apply to the free alpha; a commercial service may have its own privacy terms.

6.Security measures

6.1Measures applied. Sherpas applies the following security measures:

1. The whole connection is encrypted (HTTPS) and the site tells browsers to always use HTTPS.
2. The User signs in with Google through the standard authorization protocol OAuth 2.1. Only the User’s identity and e-mail are requested, together with keeping the session open.
3. People who connect with their Google account get in only if their e-mail is on the admitted list, which is checked both when the session is opened and on every request. Sherpas’s internal technical integrations use a separate credential, which is not handed to third parties.
4. Session records are stored encrypted, and the Service’s keys and secrets are held in a secrets manager, not in the code.
5. The Service can only read market data; it cannot modify it.
6. An hourly usage limit protects the Service from abuse and overload.

6.2Certifications. As of the effective date of this policy, Sherpas does not claim any security certification (such as ISO 27001 or SOC 2) or external audit.

7.Data location and international transfers

7.1International transfer. The personal data Sherpas stores is located outside Chile, mainly in the United States, and is therefore subject to international transfer.

7.2Locations. As of the effective date of this policy, the locations are as follows:

1. the database and analytics (BigQuery): United States multi-region;
2. the MCP server (Cloud Run): central United States region (us-central1);
3. Firestore: United States multi-region;
4. Google Cloud’s technical logs: Google’s “global” location, which is not pinned to a country;
5. the website: delivered through the content delivery network of Firebase Hosting (Google and its provider Fastly), with worldwide presence.

7.3Applicable regime. International transfers of data are governed by Law No. 19.628 and, from December 1, 2026, by articles 27 and 28 of that law, as amended by Law No. 21.719.

7.4Changes of location. Sherpas does not commit to keeping a fixed region: these locations may change.

8.Data Subject rights

8.1Rights. The Data Subject may exercise their rights of access (to know what personal data Sherpas processes and ask for a copy), rectification (to correct it), erasure (also called cancellation: to ask for its deletion), objection (to object to its processing, in the cases the law allows), temporary blocking and portability (to obtain a copy in a structured, commonly used electronic format), in addition to any other rights the law grants to the Data Subject.

8.2How to exercise them. To exercise these rights, the Data Subject must write to jorge@sherpas.net, stating which right they wish to exercise and the e-mail they use with SEN Data. Exercising these rights is free of charge. To protect the data, Sherpas may ask the Data Subject to confirm their identity before handing it over or deleting it. Sherpas will reply to the same e-mail.

8.3Response time. Until November 30, 2026, Sherpas replies within two business days, in accordance with article 16 of Law No. 19.628. From December 1, 2026, it replies within 30 calendar days, extendable once for a further 30 days, and handles temporary blocking requests within two business days (article 11 of that law).

8.4Complaint. If Sherpas does not reply or rejects the request, the Data Subject may, until November 30, 2026, apply to the civil court of first instance (juez de letras en lo civil) of Sherpas’s domicile and, from December 1, 2026, file a complaint with the Agencia de Protección de Datos Personales (the data-protection agency created by Law No. 21.719) within the following 30 business days.

8.5Data Subjects in the European Union. If the Data Subject is in the European Union, they may exercise the rights granted by the rules that apply to them, including the General Data Protection Regulation (GDPR) to the extent that it applies.

9.Automated decisions and practices Sherpas does not follow

9.1No automated decisions. Sherpas takes no automated decisions about people. Access requests are reviewed by a person; there is no automatic approval. There are two automatic controls, both technical: checking that the User’s e-mail is on the list of admitted people when signing in with Google, and applying an hourly usage limit to the whole Service, regardless of who is querying.

9.2Use of the records. Sherpas takes no decisions about the Data Subject from the per-person records: it uses them to provide support, understand the cost of use and improve the Service. Sherpas does not train models on the User’s questions; the AI assistant is a separate service (section 4).

9.3Other practices. Sherpas does not sell or transfer personal data, does not display advertising, does not use advertising or analytics cookies, and does not request or process sensitive data, health data, payment card data, identification numbers or credentials. It asks the User not to enter them in their queries or reports.

10.Minors’ data

10.1 The Service is intended for professional use and is not directed to persons under 18 years of age. Sherpas does not knowingly collect personal data from persons under 18.

11.Changes to this policy

11.1 If Sherpas makes a material change to this policy, it will announce it by e-mail to admitted people and on this page at least 15 days before the new version takes effect, and the new version will state its number and date. If the change requires new consent, Sherpas will ask for it expressly.

12.Governing law and language

12.1Governing law. This policy is governed by the laws of Chile.

12.2Language. This English version of the policy is a translation of the Spanish original; where the two differ, the Spanish version prevails.

13.Contact

13.1 For any question about this policy, the Terms of service, a request about personal data or the Service, the Data Subject may write to jorge@sherpas.net or visit the Support page. Sherpas Group SpA · La Siembra 8934, Vitacura, Santiago, Chile.