PRIVACY POLICY

HANDLING OF DATA
ALMAMOR® GROUP, informs that the content of the Privacy Policy (hereinafter "the Policy"), which is presented below, is applicable to the treatment of your personal data collected from access, use and navigation of the Website almamor.com (hereinafter "the Site"). By your interaction, use and navigation, as well as voluntary delivery of personal data in those cases where this aspect is enabled on the Site ("User"), we understand your consent and acceptance of the contents of this Policy, which is why we invite you to carefully read its contents.
For all purposes of treatment of personal data described in this document, the Responsible for it, according to the definition established in Law 1581 of 2012, will be ALMAMOR® GROUP, domiciled in Cr 50 N 45 - 79, Local 506, Medellin, Colombia, contact email [email protected].
This document was prepared taking into account the provisions of Law 1581 of 2012 "By which general provisions are issued for the protection of personal data and Decree 1377 of 2013 "By which Law 1581 of 2012 is partially regulated" which aim to "Develop the constitutional right that all persons have to know, update and rectify the information that has been collected about them in databases or files, and other rights, freedoms and constitutional guarantees referred to in Article 15 of the Political Constitution; as well as the right to information enshrined in Article 20 of the same. .”
In compliance with the current Colombian law, below, we present relevant information related to the legitimate treatment of personal data collected:

1. COLLECTION OF USER'S PERSONAL DATA.
The User's personal data may be collected through the Site by registering and opening an account on it, in order to participate in promotions, contests or proceed with the purchase of products using the e-commerce tools made available. To this end, at the time of registration, the User expressly authorizes the processing of his/her personal data in accordance with the authorization text made available and whose acceptance is a necessary step for the creation of the account on the Site.
Personal data may consist of name, identification number, e-mail, telephone, city, date of birth, among others such as consumption habits. The personal data to be processed will be of a private or semi-private nature as appropriate, expressly excluding from the collection, personal data of a sensitive nature, as well as personal data of minors. The personal data collected will be included in the databases owned by ALMAMOR® GROUP and will be used for the purposes set forth in this Policy.

2. PURPOSE OF THE PROCESSING OF PERSONAL DATA
The processing of personal data will be carried out in order to perform, through any means, marketing activities, promotion, own or third party advertising, technical support, marketing, service improvement, consultation, control, enabling means of payment, commercial and consumer assistance, service and technical support of products and services, as well as any other related to products and services, current and future ALMAMOR® GROUP. Notwithstanding the foregoing, the User may always request the cessation of sending emails. Likewise, personal data provided or obtained by ALMAMOR® GROUP, may be processed, collected, stored, used, updated, mainly to enable the provision of its services, for accounting records that may be required and for reports to control and surveillance authorities. Likewise, personal data will be used for administrative, commercial and advertising purposes and contact with the owners of the same.
Likewise, the User grants authorization for the transfer, communication, transference and/or national or international transmission or assignment of the personal data and databases to third parties whether they are responsible and/or in charge according to the business needs of ALMAMOR® GROUP. To this end, the User grants express authorization for the international transfer of personal data.
ALMAMOR® GROUP, undertakes that the information obtained from users will not be shared with companies or third parties that do not have any direct link with ALMAMOR® GROUP.

3. SECURITY MEASURES
ALMAMOR® GROUP has adopted technical, human and administrative measures that provide security to personal data avoiding its adulteration, loss, consultation, use or unauthorized or fraudulent access. ALMAMOR® GROUP maintains security protocols of mandatory compliance for staff with access to personal data and information systems, in order to ensure the security and confidentiality of the treatment.

4. Rights of the Holders
In accordance with Law 1581 of 2012, Users as holders of personal data have the following rights:
- (a) To know, update and rectify their personal data against the Data Controllers or Data Processors. This right may be exercised, among others, against partial, inaccurate, incomplete, fractioned, misleading data, or data whose processing is expressly prohibited or has not been authorized.
- b) Request proof of the authorization granted to the Data Controller, except when expressly exempted as a requirement for the processing, in accordance with the provisions of Article 10 of Law 1581 of 2012.
- c) To be informed by the Data Controller or the Data Processor, upon request, regarding the use made of their personal data.
- d) File complaints before the Superintendence of Industry and Commerce for violations of the provisions of Law 1581 of 2012 and other rules that modify, add or complement it.
- e) To revoke the authorization and/or request the deletion of the data at any time at will.
- f) Access free of charge to their personal data that have been subject to processing, all in compliance with the legal procedure in force.

5. EXERCISE OF RIGHTS AND CLAIMS
The exercise of rights, requests, queries and claims may be made to ALMAMOR® GROUP by means of a written letter sent to the main office of ALMAMOR® GROUP or by e-mail to [email protected].
This Policy is in force since November 2015, substantial changes will be duly informed by ALMAMOR® GROUP.

 

BROWSING DATA POLICY [COOKIES]

What are and what are not cookies/browsing data?

Cookies/browsing data are small information files or text fragments sent by a Portal or technological Application owned by ALMAMOR® GROUP and stored in the user's browser or device. Through cookies, the Portals remember information about the user's visit, which allows them to provide a better and safer browsing experience. Cookies are associated with both anonymous users, i.e., those who visit the Portals without identifying themselves or registering, and those who do.

On the other hand, cookies are not a virus or any other type of malicious program that can damage users' devices. Additionally, cookies cannot delete or read information from the user's computer or device.

How does ALMAMOR® GROUP obtain cookies?

Cookies are created and/or updated in the user's computer or device automatically when the user accesses the ALMAMOR® GROUP Portal, which allows ALMAMOR® GROUP or third parties hired by it, to track the user's cookies and therefore the information that these cookies contain or obtain from the user. It is important to clarify that cookies are only read by the website that created them.

What kind of cookies does ALMAMOR® GROUP use and what are they used for?

1. Essential Cookies. These cookies are essential for the Use of the Portal, in the sense of facilitating the registration process on the Portal, as well as allowing users faster and safer access to selected services within the Portal. Without these cookies, ALMAMOR® GROUP may not be able to offer users certain services within the Portal and the Portal may not function normally.

2. Functional Cookies. Through the use of functional cookies, it is possible for ALMAMOR® GROUP or the third party it hires, to personalize the services offered on the Portal, providing each user with information that is or may be of interest to them, based on their use of the services and the specific pages they visit on the Portal. Through these cookies, ALMAMOR® GROUP or the third parties it hires, will be able to offer users a better experience and better performance in navigation within the Portal.

3. Advertising Cookies. ALMAMOR® GROUP or the third party that it hires, through the use of these cookies, may deliver to the user advertising that it considers may be of interest, according to the preferences and behaviors that the user has or has had within the network of ALMAMOR® GROUP Portals. Through these cookies, it will be possible to optimize the advertising that the user sees on the Portal. Advertising cookies may be delivered to ALMAMOR® GROUP advertisers, to be used by them for their marketing and advertising campaigns.

4. Analysis or Performance Cookies. Through analysis or performance cookies, ALMAMOR® GROUP or the third party it hires, can perform various analyses and studies of the information collected, in order to improve the products and services that ALMAMOR® GROUP offers to users.

ALMAMOR® GROUP and third parties with whom it contracts services for the use of cookies, are the only ones who can access the information stored in the cookies that have been installed on the user's computer. The information stored in the cookies cannot be read by other users, nor can they access it.

Can I disable the installation and use of cookies by ALMAMOR® GROUP?

The user can disable both the installation and use of cookies by ALMAMOR® GROUP. To disable the installation and use of cookies the user must perform the procedure by browser as indicated below:

- Internet Explorer: Tools -> Internet Options -> Privacy -> Settings. For more information, you can consult Microsoft Support or the browser's Help.

- Firefox: Tools -> Options -> Privacy -> History -> Custom Settings. For more information, you can consult Mozilla Support or browser Help.

- Chrome: Settings -> Show advanced options -> Privacy -> Privacy -> Content settings. For more information, you can consult the Google Support or the browser Help.

- Safari: Preferences -> Security. For more information, you can consult Apple Support or browser Help. The opt-out systems listed above may result in a "reject" cookie being set on your computer to make your opt-out choice work.

Additionally, there are other third-party tools, available online, that allow users to detect cookies on each website they visit and manage their disabling.

What happens if cookies are disabled?

If the user disables the installation or use of cookies for the Portals, he/she may lose or affect some functionalities of the site, such as, for example:

1. Being able to enter the Portals without having to indicate each time your username and password, this will save you time and allow you to use features such as newsletters, alerts, saved news, among others. 2. Publication of comments within the Portals. 3. Unrestricted access to content within the Portals. 4. Security in the use of the information entered into the Portals. 5. Speed in the use of any service within the Portals.

Does ALMAMOR® GROUP share the information obtained through cookies with third parties?

ALMAMOR® GROUP may share information obtained through cookies with external persons or third parties (allies, customers, suppliers or companies linked to ALMAMOR® GROUP), in order to improve usability and user services. Likewise, the information received through cookies will be used by ALMAMOR® GROUP and the aforementioned third parties for the purposes described in this document, those indicated in our Privacy Policy, and any of its updates.

Where is the information obtained through cookies stored?

ALMAMOR® GROUP may hire third parties to store and obtain information through cookies, or to include cookies within the ALMAMOR® GROUP portals, which may be located in Colombia or abroad. Likewise, ALMAMOR® GROUP may provide third parties with the information obtained from cookies to create user profiles, offer personalized campaigns, without this implying the provision of personal information.

The information obtained through these cookies, referring to the user's computer, may be combined with your personal data only if you are registered in an ALMAMOR® GROUP Portal.

What do I need to know about the cookie policy and where can I contact you if I have any questions?

This Policy contains the necessary information that every user of the Portals should know about the use of cookies by ALMAMOR® GROUP or third parties contracted by ALMAMOR® GROUP. ALMAMOR® GROUP may modify this document at any time and without prior notice in order to keep them current and updated. Therefore, we recommend users to review the date of preparation or update of the same, which is established at the end of this document.

In case of doubts or concerns about the use of cookies or about any of the points detailed in this Policy, please write to the following email: [email protected]