PERSONAL DATA PROTECTION POLICY

Apr 15
4 min read

ANGELA VELEZ COMUNICACIÓN ESTRATÉGICA DIGITAL SAS

1. SCOPE

This personal data protection policy applies to all databases and/or files containing personal data processed by ANGELA VELEZ COMUNICACIÓN ESTRATÉGICA DIGITAL SAS, as the owner of this website, its contractors, strategic allies, or employees.

2. IDENTIFICATION OF THE DATA CONTROLLER

Ángela María Vélez, an individual residing at Cra 76 152b 77, Bogotá D.C., Email: gerencia@avcomunicaciones.com, acting as the legal representative of the company in charge of data processing, Ángela Vélez Comunicación Estratégica Digital S.A.S., identified with NIT 901.148.253-1 and email: ingenieria@avcomunicaciones.com. Phone: (+571) 313 8328999.

3. DEFINITIONS

Authorization: Prior, express, and informed consent of the Data Subject to carry out the Processing of Personal Data.
Privacy Notice: Verbal or written communication generated by the Controller, addressed to the Data Subject for the Processing of their Personal Data, informing them about the existence of the information Treatment Policies applicable to them, how to access them, and the purposes of the intended Processing.
Database: Organized set of Personal Data subject to Processing.
Personal Data: Any information linked to or associated with one or more specific or determinable natural persons.
Data Processor: Natural or legal person, public or private, who by themselves or in association with others, performs the Processing of Personal Data on behalf of the Data Controller.
Data Controller: Natural or legal person, public or private, who by themselves or in association with others, decides on the Database and/or the Processing of the data.
Terms and Conditions: General framework establishing conditions for participants in promotional or related activities.
Data Subject: Natural person whose Personal Data is subject to Processing.
Processing: Any operation or set of operations on Personal Data, such as collection, storage, use, circulation, or deletion.
Transfer: Data transfer occurs when the Controller and/or Processor, located in Colombia, sends information or personal data to a recipient who is also a Controller, located within or outside the country.
Transmission: Processing of Personal Data involving the communication of such data within or outside the territory of the Republic of Colombia for the purpose of Processing by the Processor on behalf of the Controller.

4. PROCESSING

For the proper development of activities related to the dissemination, marketing, and promotion of services, ANGELA VELEZ COMUNICACIÓN ESTRATÉGICA DIGITAL SAS collects, stores, uses, circulates, and deletes Personal Data of natural persons with whom it has or has had a relationship, including but not limited to employees and their relatives, shareholders, consumers, clients, distributors, suppliers, creditors, and debtors.

5. PURPOSE

Personal Data is processed by the controller for the following purposes:

Sending information to clients, contacts, and the agency's potential market.
Strengthening relationships with potential audiences by sending relevant information on digital communication.
Interaction with clients.
Responding to contacts through the website and customer service.
Improving, promoting, and developing services.
Marketing activities, statistics, research, and other purposes not contravening current Colombian legislation.
Handling judicial or administrative requirements and complying with judicial or legal mandates.
Contacting via email or any other means individuals with whom it has or has had a relationship for the aforementioned purposes.

6. RIGHTS OF DATA SUBJECTS

Natural persons whose Personal Data is processed have the following rights, which they may exercise at any time:

To know the Personal Data being processed and request updates or rectifications.
To request proof of the authorization granted to the agency.
To be informed, upon request, regarding the use given to their Personal Data.
To file complaints with the Superintendency of Industry and Commerce for violations of Data Protection Law.
To request the deletion of Personal Data and/or revoke authorization, except when there is a legal or contractual duty to remain in the database.
To access their processed Personal Data free of charge.

7. RESPONSIBLE AREA

The data controllers are responsible for the development, implementation, training, and observance of this Policy. They must report these Databases and immediately transfer all requests, inquiries, or claims received from Data Subjects.

8. AUTHORIZATION

The controller must request prior, express, and informed authorization from Data Subjects.

Prior: Consent must be granted at the latest at the time of collection.
Express: Consent must be explicit and specific; open-ended authorizations are invalid. This may be done in writing, orally, or through unequivocal conduct (e.g., accepting Terms and Conditions). Silence shall never be interpreted as unequivocal conduct.

9. SENSITIVE DATA PROVISIONS

Sensitive data (racial origin, political orientation, religious convictions, health, sex life, biometric data) is protected. Processing is prohibited unless there is express authorization. Subjects are not obliged to authorize the processing of sensitive data.

10. MINORS' DATA PROVISIONS

Processing of data belonging to children and adolescents will only be carried out if it responds to and respects their best interests and fundamental rights, with authorization from a legal representative.

11. PROCEDURES FOR INQUIRIES AND CLAIMS

Data Subjects may exercise their rights through the following channels:

Inquiries: Responded to within ten (10) business days.
Claims (Correction/Deletion): Responded to within fifteen (15) business days.
Enabled Media: Email: gerencia@avcomunicaciones.com

12. PASSIVELY OBTAINED INFORMATION

The website may collect information passively through "cookies" (IP address, browser type, domain name, access time). Users may configure cookie settings in their browsers.

13. DATA SECURITY

The controller will implement technical, human, and administrative measures to prevent adulteration, loss, or unauthorized access. However, total security is not guaranteed against technical failures or unauthorized third-party entry.

14. APPLICABLE LEGISLATION

This policy is governed by the Political Constitution of Colombia (Art. 15), Law 1266 of 2008, Law 1581 of 2012, Decree 1377 of 2013, and related regulations.

15. EFFECTIVE DATE

This Personal Data Protection Policy is effective as of August 1, 2025.