Privacy Policy

PRIVACY AND DATA PROTECTION POLICY.

This privacy and personal data protection policy (hereinafter the “Policy”) regulates the collection, storage, processing, administration, transfer, transmission, and protection of information received from third parties through different information collection channels (hereinafter “Personal Data”). This policy is provided to the general public by the company ADVRSARY (“LEGAL NAME ADVRSARY”), identified with NIT 800,010,577-2, and located in the city of Medellín, Colombia, through its various divisions (websites, customer support, user assistance, logistics, shipments, legal advice, and others). It is in accordance with the provisions contained in Statutory Law 1581 of 2012, Decree 1377 of 2013, and other related regulations that establish general provisions for the protection of personal data.

LEGAL NAME ADVRSARY, which will be responsible for the processing of Personal Data, as defined in Law 1581 of 2012, respects the privacy of each of the third parties that provide their Personal Data through different collection and capture points established for this purpose. LEGAL NAME ADVRSARY receives the mentioned information, stores it appropriately and securely, and uses it, without preventing third parties from verifying its accuracy and exercising their rights regarding knowledge, updating, rectification, and deletion of the provided information, as well as their right to revoke the authorization given to LEGAL NAME ADVRSARY for the processing of their Personal Data. The data that LEGAL NAME ADVRSARY collects from third parties are processed and used in accordance with current regulations on information protection and privacy, as mentioned above.

LEGAL NAME ADVRSARY collects Personal Data for consultation, processing, and use purposes, with the following specific objectives:

1. Innovate, improve, develop, and implement new promotional campaigns for products and services; design and offer new products and services through the continuous analysis of preferences, tastes, and profiling of customers in demographic aspects and consumption habits, balance inquiries, among others.
2. Perform basic administrative management tasks.
3. Communicate promotions, news, products, and services offered and marketed by LEGAL NAME ADVRSARY through any channel designated for this purpose. This use will only be carried out if third parties voluntarily register the information and give their express authorization.

The use, determined by the different purposes mentioned above, including the sending of commercial and advertising information related to the products and/or services that LEGAL NAME ADVRSARY offers, may be exercised through (i) emails, (ii) text messages (SMS), and/or (iii) phone calls (mobile or landline).

The term “Personal Data” refers to the personal information provided to ADVRSARY (“LEGAL NAME ADVRSARY”) in any form and through any channel for receiving such information by third parties. This information includes data such as names, surnames, date of birth, type and number of identification document, gender, physical address, email address, landline phone, mobile phone, city of residence, area of performance, type of bank account, and bank account number.

Data subjects acknowledge that the provision of their Personal Data is voluntary, considering the features enabled for this purpose and the powers of use by ADVRSARY. They understand that this information will be part of a file and/or database containing their profile, which may be used by ADVRSARY in the terms and for the purposes established here.

Additionally, the information provided voluntarily by the data subject must be truthful and complete, and it will not be used, processed, or transferred beyond the limits defined by the data subject in their consent declaration (see Law 1581 of 2012 and regulatory decree 1377 of 2013), and those established by current legislation. In other words, it will be used for the commercial purposes that each distributor or customer has with ADVRSARY. Furthermore, ADVRSARY will share and transfer the information only if obligated to do so by an administrative or judicial authority order.

The customer authorizes ADVRSARY to share their Personal Data with commercial partners of ADVRSARY. Likewise, they authorize ADVRSARY and its commercial partners to use the provided Personal Data in the management of ADVRSARY and within the commercial alliances entered into by ADVRSARY to generate added value. Therefore, they authorize ADVRSARY to retain, update, process, obtain data from the use of the online store of ADVRSARY, consult, and process it in the ways established in this Policy.

ADVRASARY clarifies that, although the processing activities of the information provided by data subjects are carried out by ADVRSARY personnel, they may be performed by contractors and/or service providers (data processors) who may have access to the Personal Data in the databases of ADVRSARY due to a special assignment (data processor). They are contractually obligated to store, process, protect, and maintain such information as confidential and may not process it for any purpose other than that contractually indicated by ADVRSARY. By accepting this Policy, the purposes described in this paragraph are accepted.

The data subject may know, update, rectify, and delete the information provided. They may also exercise their right to revoke the authorization given for the processing of their Personal Data by ADVRSARY through the following channels:

• In the User registration area of the website, social media, blogs, banners, capture pages, physical point of sale.
• If the third party is not registered as a User on the aforementioned portal, they may exercise their rights through the Questions, Complaints, Claims, and Suggestions (PQRS) Module, available on the websites or via email (ADVSRY CORREO@GMAIL.COM), where they can state their concerns, which will be addressed by the Customer Service area. By legal provision, the mentioned area has thirty (30) business days to respond to the request.
• Through the email channel of ADVRSARY (ADVSRY CORREO@GMAIL.COM).
• If the third party does not have access to the aforementioned mechanisms, they may submit their request in writing to the address ADVRSARY ADDRESS in the city of Medellín, Colombia. Attention: LEGAL ADDRESS.
• The area responsible for handling PQRs and exercising the rights of data subjects will be LEGAL ADDRESS.
• In addition to what is established in this Policy, the procedures for handling inquiries and complaints will be those established in the applicable regulations, especially those referred to in articles 14 and 15 of Law 1581 of 2012.

LEGAL NAME ADVRSARY will store and process the information provided by data subjects securely, taking all precautionary measures to protect their information against loss, misuse, alteration, unauthorized or fraudulent access, or use. Similarly, this processing may be carried out by contractors and/or service providers (data processors) who may have access to the personal data in the databases of LEGAL NAME ADVRSARY due to a special assignment (data processor). They are contractually obligated to store, process, protect, and maintain such information as confidential and may not process it for any purpose other than that contractually indicated by LEGAL NAME ADVRSARY.

LEGAL NAME ADVRSARY is not responsible for any consequences arising from the unauthorized access of third parties to the database and/or any technical failure in the operation and/or data preservation in the information storage system, for reasons not attributable to them.

By legal provision, LEGAL NAME ADVRSARY refrains from collecting any information from minors or sensitive data from its customers, as defined in Law 1581 of 2013.

When visiting the Shopify, Facebook, Instagram, Mercado Libre, Linio portals under the ADVSRY MARCA profiles belonging to LEGAL NAME ADVRSARY, certain information is automatically stored on servers for system administration, processing, statistical purposes, or for backup purposes. This information includes the name of the internet service provider used, in some cases, the Internet Protocol (IP) address, the browser software version, the computer operating system used to access the visited portals, and even any search history used to find such portals.

To facilitate the use of the aforementioned portals, LEGAL NAME ADVRSARY uses “Cookies,” which are small units of information temporarily stored on the user’s computer hard drive, useful for navigating the site. The information contained in ‘Cookies’ serves, for example, for session control, particularly enhanced navigation, and to achieve high performance as a user-friendly website, as well as storing personal information regarding identification. Most network browsers automatically accept ‘cookies.’ Users can prevent this by changing their browser settings. ‘Cookies’ stored on the PC can be deleted at any time by clearing temporary internet files (“Tools/Extras” in the browser bar – “Internet Options”).

For more information related to legal data protection provisions and those related to complaint procedures regarding them, it is suggested to visit the website of the Superintendence of Industry and Commerce (www.sic.gov.co).

LEGAL NAME ADVRSARY reserves the right to modify this policy at any time and without prior notice. Any modification will enter into force and take effect concerning related third parties from its publication on the corresponding channel. Consequently, customers are recommended to visit and consult the portals: Shopify, Facebook, Instagram, Mercado Libre, Linio in the corresponding module frequently to be aware of these changes.

This privacy policy comes into effect from the day of its publication on the portal.