PRIVACY POLICY
TABLE OF CONTENTS:
YO. Introduction and Scope.
II. Aim.
III. Scope.
IV. Obligations.
V. Data Controller.
VI. Glossary.
VII. Processing of Personal Data.
VIII. Purposes of the Processing of Personal Data.
IX. Rights of the Holders.
X Processing of personal data of children and/or adolescents.
XI. Handling requests, queries and complaints.
XII. Procedure for exercising the right to habeas data.
XIII. Validity.
I. INTRODUCTION AND SCOPE.
ANCESTRY UP CROWN SAS, in compliance with Statutory Law 1581 of 2012, Regulatory Decree 1377 of 2013, Decree 886 of 2014, Single Regulatory Decree 1074 of 2015, the Circulars issued by the Superintendence of Industry and Commerce on the matter, and other regulatory provisions that modify, add, complement or repeal it, and committed to the privacy, trust, quality and protection of Personal Data authorized by the Owners for Processing, we issue the following Privacy Policy.
II. OBJECTIVE.
This Privacy Policy aims to establish the criteria for the collection, storage, use, circulation and deletion of Personal Data processed by ANCESTRY UP CROWN SAS in compliance with the current and applicable regulatory provisions that make up the General Regime for the Protection of Personal Data, as well as any requirement arising from the Principle of Demonstrated Responsibility (accountability), as follows:
· Harvest.
ANCESTRY UP CROWN SAS collects Personal Data from Data Subjects through its website, customer service lines (telephone and email), physical points of sale, and through corporate social networks (WhatsApp, Instagram, Facebook, and other social and digital media or networks to which it has access).
· Storage.
ANCESTRY UP CROWN SAS will store the information on its own platforms and digital media and/or those of external providers that provide the levels of confidentiality, restricted circulation, and information security required by the laws, decrees, circulars, resolutions, and other current and applicable regulations of the Republic of Colombia.
· Use/Circulation.
ANCESTRY UP CROWN SAS uses and circulates the Personal Data of the Owners in accordance with the purposes described in this Privacy Policy.
· Suppression.
ANCESTRY UP CROWN SAS will delete the Personal Data of the Owners, once the purposes described in this Privacy Policy have been fulfilled, the need for Processing ceases, or at the express request of the Owner in exercise of the right to habeas data.
III. SCOPE.
This Policy applies to all personal information recorded in the databases of ANCESTRY UP CROWN SAS , which acts as the Controller of Personal Data.
IV. OBLIGATIONS.
This Policy is mandatory and strictly enforced by ANCESTRY UP CROWN SAS
V. DATA CONTROLLER.
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Company Name |
ANCESTRY UP CROWN SAS |
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NIT |
901.526.126-6 |
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City |
Medellín, Antioquia, Colombia |
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Address |
20th South Street # 39ª – 72 |
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Phone |
304 455 44 84 |
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Contact email |
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Official website |
VI. GLOSSARY.
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Personal data |
This is any information that is linked to or can be associated with a specific person, such as their name or identification number, or that can make them identifiable, such as their physical characteristics. |
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Public data |
This is one of the existing types of personal data. Public data includes, among others, data relating to a person's marital status, their profession or occupation, and their status as a business owner or public servant. By its nature, public data may be contained in, among other things, public registries, public documents, official gazettes and bulletins, and duly enforceable court rulings that are not subject to confidentiality. |
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Semi-private data |
These are data that are not of a private, confidential, or public nature and whose knowledge or disclosure may be of interest not only to the data subject but also to a certain sector or society in general. Financial and credit data from commercial or service activities are some examples. |
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Private data |
This is data that, due to its intimate or confidential nature, is only relevant to the data subject. People's tastes or preferences, for example, are considered private data. |
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Sensitive data |
These are those that affect the data subject's privacy or may lead to discrimination, that is, those that reveal their racial or ethnic origin, political orientation, religious or philosophical beliefs, membership in unions, social organizations, or human rights organizations, as well as data related to health, sexual life, and biometric data, among others. |
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Authorization |
It is the consent given by any person so that companies or individuals responsible for processing information can use their personal data. |
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Database |
Organized set of personal data that is subject to processing. |
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Data Controller |
This is the natural or legal person who processes personal data, based on a delegation from the controller, receiving instructions on how the data should be managed. |
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Data Controller |
It is the natural or legal person, public or private, who decides on the purpose of the databases and/or their processing. |
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Holder |
It is the natural person whose personal data is being processed. |
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Treatment |
Any operation or set of operations on personal data, such as collection, storage, use, circulation or deletion. |
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Privacy Notice |
It is one of the verbal or written communication options provided by law to inform information holders of the existence and ways to access information processing policies and the purpose of their collection and use. |
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Transfer |
This is the operation carried out by the person responsible for or in charge of processing personal data when they send the information to another recipient, who, in turn, becomes the data controller. |
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Transmission |
Processing of Personal Data that involves communicating the same within or outside the territory of Colombia, so that a Processor can carry out the Processing on behalf of the Controller. |
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Purposes |
It refers to the purposes and intentions for which personal data are processed. |
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Consultation |
Request made by the Data Subject or their successors in title so that the Data Controller and/or Data Processor informs the Data Subject about the personal information held about the Data Subject in any database. |
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Claim |
Request made by the Data Subject or their successors in title to the Data Controller and/or Data Processor to correct, update or delete any information held by the Data Subject in any database, or when a presumed breach of any of the duties contained in the General Personal Data Protection Regulation for Data Controllers and/or Data Processors is observed. |
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General Regime for the Protection of Personal Data |
This refers to the regulatory provisions that govern the protection of personal data in Colombia, including: Statutory Law 1581 of 2012, Regulatory Decree 1377 of 2013, Decree 886 of 2014, Single Regulatory Decree 1074 of 2015, Circulars issued by the Superintendency of Industry and Commerce on the matter, and any others that complement or modify it. |
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Customers |
They are the natural or legal persons who acquire a good or service from ANCESTRY UP CROWN SAS |
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Interest Groups |
Refers to Shareholders and potential Board members; employees, potential employees, and collaborators; suppliers and contractors; and clients and potential clients of ANCESTRY UP CROWN SAS. |
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Demonstrated Responsibility (accountability) |
It refers to an organization's ability to demonstrate effective compliance with the General Personal Data Protection Regime by adopting and implementing appropriate technical and organizational measures to ensure the processing of personal data. |
VII. PROCESSING OF PERSONAL DATA.
· What personal data does the Controller collect and process?
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Personal identification data: |
Name, surname, ID type and number, image, language and country from which you interact with us, contact information, etc. |
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Contact information: |
Email address, phone number, and address. |
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Login details: |
Username and password. |
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Purchase history: |
Prices, products, and dates of visit and purchase. |
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Payment data – financial or transaction information: |
Transaction history, pending claims, payment or card details, order information, returns, discounts, etc. |
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Correspondence: |
Communications with our customer service or marketing communications. |
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Preferences: |
Choosing your language and email preferences. |
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Technical data – connection, geolocation and navigation information: |
IP address, device ID, location data, cookies and log files. |
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Statistics on website usage: |
Number of times certain pages and the most popular products are visited. |
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Interests: |
Types of products that receive the most attention and which ads are clicked on, in general, data about your tastes and preferences. |
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Others: |
Other personal data that you provide to us. |
Occasionally, data other than that indicated in the aforementioned categories may be shared. This includes, for example, other data provided to process a query or complaint. In this case, this data will be processed for the purpose of processing and managing the respective query or complaint.
· How long will the treatment be performed?
ANCESTRY UP CROWN SAS will process Personal Data for a period equal to the time it is maintained and used for the Purposes described in this Policy. This period will not be less than the duration of the Company or the contractual relationship entered into with the Personal Data Owner. Thus, once the purposes are completed or the need for processing ceases, the information will be deleted from the Company's Databases or archived using appropriate security measures. It will only be disclosed when required by an Authority exercising its functions or by law.
· Use of cookies.
ANCESTRY UP CROWN SAS may use cookies to improve its platforms or websites and the browsing experience, as well as to adapt the advertising and content that the Owner views. The Owner may modify their preferences regarding the use of cookies, but some cookie restrictions mean that they will not be able to take full advantage of the benefits available on the platforms or websites. The information collected through cookies is encrypted and will not be used to identify and/or reveal user information.
· How is processing carried out in the payment procedure?
The Company offers a link to the websites of the respective financial institutions (payment gateways) as an alternative for payment for products. The information will not be shared with third parties unless necessary to fulfill the purposes stated below, in accordance with the Transfer Agreements entered into by the Company.
VIII. PURPOSES OF THE PROCESSING OF PERSONAL DATA.
Without prejudice to other purposes that the Data Subjects specifically authorize, ANCESTRY UP CROWN will process the personal data of its Stakeholders for the following purposes:
· Manage user registration, purchase the product or service offered, and send personalized communications.
· Carry out administrative management, marketing and commercial prospecting activities.
· Sending invitations to events and offering new products or services, as well as communicating with customers about product offers, discounts, and promotions.
· Manage and process requests, complaints, claims, petitions, and suggestions.
· Conduct satisfaction surveys regarding the products offered by ANCESTRY UP CROWN, as well as product usability and quality analyses (for analytical and statistical purposes).
· Provide contact information to strategic allies, the sales force and/or distribution network, telemarketing, market research and any third party with which ANCESTRY UP CROWN has a contractual relationship for the development of activities of this type (market research and telemarketing, etc.) for the execution of the same.
· Contacting the Owner via telephone, electronic means (SMS), social media, and email to send order information, conduct surveys, conduct studies, and/or confirm personal data necessary for the execution of the contractual relationship, as well as sending news related to discount campaigns, loyalty programs, or service improvements.
· Validate personal information by cross-checking it with public databases, restricted lists, money laundering and terrorist financing checklists, criminal or security records checks, credit bureaus, and with specialized companies, which allow for establishing your status as a debtor, user, client, supplier, citizen, guarantor, taxpayer, and/or as a holder of commercial, financial, or any other type of services.
· Monitor behavior within ANCESTRY UP CROWN facilities using video surveillance systems to ensure the security of property and people. In this regard, and to maintain the security of property and people, ANCESTRY UP CROWN may also establish technological and physical access controls.
· Provide the services and products offered by ANCESTRY UP CROWN and accepted in the signed contract.
· To sign, execute, and manage pre-contractual, contractual, and post-contractual relationships of a commercial, labor, civil, and any other nature that may arise.
· Provide information to third-party clients, suppliers, or business partners, both within and outside the country, with whom ANCESTRY UP CROWN has a contractual relationship, and which must be provided to fulfill contractual obligations entrusted to or in the hands of ANCESTRY UP CROWN . In this regard, the Data Subject expressly authorizes the Transmission and/or Transfer of Personal Data to said third parties both within and outside the country for the aforementioned purposes, as well as the Transmission and/or Transfer that said third parties may make to other clients, suppliers, or business partners to fulfill contractual obligations. The Transmission and/or Transfer may be to third countries that provide adequate levels of personal data protection.
· Carry out all necessary procedures and steps to confirm and update customer information.
· Carry out all accounting, fiscal, tax, and billing procedures.
· Manage electronic transactions with payment portals.
· Provide a warranty on purchased products, in accordance with applicable law.
IX. RIGHTS OF THE HOLDERS.
As the owner of your personal data, you have the right to:
(Yo) Access free of charge to the data provided that has been processed.
(ii) Know, update, and rectify your information in the event of partial, inaccurate, incomplete, fragmented, misleading data, or data whose processing is prohibited or unauthorized.
(iii) Request proof of the authorization granted, except when expressly exempted as a requirement for Treatment, in accordance with the provisions of Article 10 of Law 1581 of 2012.
(iv) To be informed by the Data Controller or Data Processor, upon request, regarding the use that has been given to your personal data.
(v) Submit complaints to the Superintendency of Industry and Commerce (SIC) for violations of current regulations.
(vi) Revoke authorization and/or request the deletion of data when the processing does not respect constitutional and legal principles, rights, and guarantees, provided that there is no legal or contractual obligation that prevents their deletion.
(vii) Please refrain from answering questions about sensitive data. Responses regarding sensitive data or data about children and adolescents are optional. Therefore, no fields requesting the completion or collection of sensitive data are mandatory. ANCESTRY UP CROWN SAS will not condition the purchase of a good or product on the provision of such information.
X. PROCESSING OF PERSONAL DATA OF CHILDREN AND/OR ADOLESCENTS.
As a general rule, ANCESTRY UP CROWN SAS will refrain from processing personal data of children or adolescents. However, in the event that a child or adolescent purchases any goods or products, ANCESTRY UP CROWN SAS will limit itself to processing public personal data. and those that may be provided for the purposes of executing the contractual and post-contractual relationship will be treated solely and exclusively for such purposes, understanding the capacity of enjoyment that all persons have and the relative legal capacity of adolescents in the Republic of Colombia, in accordance with the current and applicable regulatory provisions that regulate the matter.
Notwithstanding the foregoing, ANCESTRY UP CROWN SAS appreciates that any type of acquisition of a good or product by a child or adolescent is done through or with the authorization of his or her legal representative. ANCESTRY UP CROWN SAS will act on the good faith of the person holding the legal representative status to grant authorization for the processing of the personal data of the child or adolescent.
In any case, the best interests of children and adolescents will always be respected and upheld, and their constitutionally protected fundamental rights and guarantees will be ensured.
XI. ATTENTION TO PETITIONS, CONSULTATIONS AND COMPLAINTS.
The Customer Service Department is responsible for processing requests from holders to exercise their rights through the following channels:
Email: ancestryupcrownsas@gmail.com
Address: 20 Sur Street # 39ª – 72, Medellín, Antioquia, Colombia.
Phone: 304 455 44 84
Web page: https://www.apcrown.com.co/
Likewise, the Data Subject has the right to exercise his or her rights through the same means by which his or her information was collected, and a record of receipt and processing of the respective request will be kept for the same means.
XII. PROCEDURE FOR THE EXERCISE OF THE RIGHT TO HABEAS DATA.
In compliance with the regulations on personal data protection, ANCESTRY UP CROWN SAS presents the procedure and minimum requirements for exercising your rights:
To file and process your request, we ask you to provide the following information:
· Full name and surname.
· Contact information (physical and/or electronic address and contact telephone numbers).
· Means to receive a response to your request.
· Reason(s)/fact(s) giving rise to the claim with a brief description of the right you wish to exercise (know, update, rectify, request proof of the authorization granted, revoke it, delete it, access the information).
· Signature (if applicable) and ID number.
Regarding the terms for handling queries and complaints, we have:
· Consultations.
The maximum term provided by law to resolve your query is ten (10) business days, counted from the day following the date of receipt. When it is not possible to address the claim within this term, ANCESTRY UP CROWN SAS will inform the interested party of the reasons for the delay and the date on which their claim will be addressed, which, in no case, may exceed five (5) business days following the expiration of the first term.
· Claims.
The maximum term provided by law to resolve your claim is fifteen (15) business days, counted from the day following the date of receipt. When it is not possible to address the claim within this term, ANCESTRY UP CROWN SAS will inform the interested party of the reasons for the delay and the date on which their claim will be addressed, which, in no case, may exceed eight (8) business days following the expiration of the first term.
Once the terms established by Law 1581 of 2012 and other regulatory provisions that regulate or complement it have been met, the Data Subject who is denied, in whole or in part, the exercise of the rights of access, update, rectification, deletion, and revocation may bring his or her case to the attention of the Superintendency of Industry and Commerce before the Office for the Protection of Personal Data.
XIII. VALIDITY.
· Validity of the Privacy Policy.
This Personal Data Processing Policy is effective as of November 3, 2022. The updated version is effective as of September 4, 2024.
· Validity of the Databases.
The databases in which personal data will be stored will be valid for the same period as the information is maintained and used for the purposes described in this Policy. Once these purposes have been fulfilled, and provided there is no legal or contractual obligation to retain your information, your data will be deleted from our databases.