Personal Data Treatment - One Half

Procedures manual

 LA VIE COLOMBIA S.A.S., society with address in Medellin, located at Calle 15 No. 35 – 1, Building C34, office 401, is a committed company, responsible with the privacy and the security of personal data of its employees, shareholders, suppliers, clients, distributors, commercial allies, affiliated companies, users, contractors, consultors, advisors, subscribers, former employees, former contractors, among others; information that has been collected by this society due to the performance of its corporate purpose, through administrative, commercial, civil, and labor relations, among others; in accordance with the Law 1581 of 2012 and the Decree 1377 of 2013, the following “POLICY FOR PRIVACY AND PROTECTION OF PERSONAL DATA” has been adopted, in which, all the related persons, directly or indirectly with this society, and from which today we have Personal Data into our database, or whom their personal data will enter in the future collected by any means used by the society LA VIE COLOMBIA S.A.S., shall be able to know the collecting, conservation and treatment procedures on regards with it, as well as the rights, warranties and procedures to make them effective:

 

 Definitions of Interest:

 Personal Data: Any information linked or that can be associated to several determined or determinable natural persons.

Database: Set of personal data systematically organized for its treatment.

Authorization: Express, previous, and informed consent from the owner of the personal data to perform a procedure.

Treatment: Operations or activities performed with the personal data, among which are the following: collect, use, copy, transfer, transmission, or suppression.

Sensitive data: Are those affecting the owner’s intimacy or with which improper use may produce discrimination, such as those from racial or ethnic origin, political orientation, religious or philosophic beliefs, membership in trade unions, social organizations, human right organizations or promotion of interests for a political party or that guarantee the rights and warranties of political parties from the opposition, as well as data related to health, sexual life, and biometric information.

 

Purpose of the personal data treatment

 The information provided by the owner of the data shall be included on our database and will be used as follows:

 

For Suppliers:

  • Perform purchase of goods and services
  • Notification about the cancellation of the obligations to the suppliers of the company, among other type of communications issued by LA VIE COLOMBIA S.A.S.
  • Evaluate the quality of the products and services provided by this society.

 

For Clients:

  • Provide our products and services.
  • Use the information with the purpose of promoting our products, services and offers, by physical means or through our website, or any other ways used for such effect.
  • Submit commercial information about products and services offered by the society, through different means of dissemination, previously authorized by the owner. 
  • Send communications related to our products, services, offers, sales, alliances, studies, contests, among others.
  • Inform about our products or services directly related to the contracts or services acquired by the owner.
  • Evaluate the quality of the products and services provided by this society.
  • Perform collection activities on regards with the liabilities incurred by the owner.
  • Perform internal studies about marketing and consumption behaviors of the users.

 

 

Personal Data Treatment

 LA VIE COLOMBIA S.A.S.  is the sole responsible for the treatment of the personal data of its employees, stakeholders, suppliers, clients, distributors, commercial allies, linked societies, users, contractors, advisors, consultors, subscribers, former employees, former contractors, and others. For such reason, the society shall act in accordance with the obligations arising from this condition. Therefore, the treatment may be extensive to its subsidiaries and may additionally be ordered to those representing the society or anybody the society may hire for the exercise of its representation or performance of its commercial purpose, which shall act in accordance with the procedures and personal data protection policies that were designed for such effect and implemented by the society LA VIE COLOMBIA S.A.S.

The Personal Data Treatment shall be performed under the terms and reach of the authorization issued by the proprietor of the personal data or in the terms established within the current legislation for such effect.

  

Responsible for the Personal Data Treatment

LA VIE COLOMBIA S.A.S., society identified with NIT 901.388.729-7, constituted by private document on Jun 18, 2020, registered in the Chamber of Commerce of Medellin on June 19, 2020, on Book 9th under the No. 11773, with address in Medellin, and with the following channels of communication:

Calle 15 No. 35 – 1, Building C34, Office 401, Medellin.

WhatsApp: +57 3044502008

 Email: hi@onehalf.com.co

 Website: oneahalfshop.com

 Responsible: Administrative area.

 

Way in which Personal Data is Obtained

Collection and storage activities for Personal Data can be performed via physical mail, mobile devices, websites, or any other digital mechanism or similar communication means known through which the voluntary and direct provision of the personal data is delivered by the proprietor to the society LA VIE COLOMBIA S.A.S., through the previously mentioned mechanisms.

 

Personal Data stored by La Vie Colombia S.A.S.

The Personal Data stored by La Vie Colombia S.A.S. depends on the direct or indirect relation the proprietor has with the company, for which it may be necessary to obtain from the proprietor his name, address, phone number, home address, email, date of birth, professional activity, position, employer, among others. Information that will be used for the purposes described in the present privacy and personal data protection policy.

 

Duties of the Responsible for the Personal Data

Effectively provide assurance to the Personal Data Proprietor, and for the exercise of his rights, in accordance with the Law 1581 of 2012 and the Decree 1377 of 2013 and other regulatory standards.

Request and keep proof of the respective authorization issued by the Personal Data Proprietor on regards with the treatment of his data.

Inform the proprietor of the Personal Data about the purpose of the treatment of his data and the protection policies adopted for this.

To preserve the Personal Data in accordance with the purpose for which they were collected and under the appropriate security measures, to prevent the manipulation, lost, consultation, use or unauthorized access by other people.

Update the Personal Data in accordance with the indications and requests made by the proprietor of the information.

Rectify the personal data when provided or described incorrectly.

Process and respond queries and complaints within the terms determined by the Law 1581 of 2012 and the Decree 1377 of 2013.

Adopt an internal manual of policies and procedures to ensure the appropriate treatment of the Personal Data.

Maintain up to date the Personal Data when determined information is being discussed by the proprietor.

Implement security measures for the Personal Data, following the instructions provided by the Superintendence of Industry and Commerce regarding the topic.

Comply with the instructions and requirements provided by the Superintendence of Industry and Commerce.

In general, treat the Personal Data in accordance with the authorization provided by the proprietors and attending the purposes and aims established within the Law 1581 of 2012 and the Regulatory Decree 1377 of 2013.

 

Rights Assisting the Proprietor of the Personal Data and before his absolute absence, his successors in title.

In accordance with the terms of the Law 1581 of 2012 and the Decree 1377 of 2013, the rights assisting the proprietor of the Personal Data and before his absolute absence, his successors in title, are the following:

Right to consult freely his Personal Data and to know if they are being subject of any treatment by the responsible society.

Right to request at any time the update, correction, and the removal of his personal data.

Right to remove at any moment the authorization provided to the responsible for his Personal Data treatment.

Right to request at any moment a proof demonstrating the existence of the authorization provided to the responsible for the treatment of the Personal Data.

Right to present before the Superintendence of Industry and Commerce complaints due to infringements to the provisions in Law 1581 of 2012 and other regulations that modify, add, or complement it.

Right to be informed by LA VIE COLOMBIA S.A.S. about the use of his Personal Data.

The other assisting rights specified within the National Regulations.

 

Means by which the Proprietor of the Personal Data Authorizes its use.

The proprietors of the Personal Data shall authorize the responsible for the treatment of such, through the completion of the AUTHORIZATION FORM, which is published on the website of the society LA VIE COLOMBIA S.A.S. and/or through the communication channels used by the society to submit such form or the system of acceptance of conditions implemented by LA VIE COLOMBIA S.A.S.

 

Ways in which the Proprietor of the Personal Data may exercise his rights.

The proprietor of the information, who by this means authorizes the use of his Personal Data, may at any time access to his data, as well as request the correction, update, deletion of it or request the removal of this authorization, in accordance with the Law 1581 of 2012 and the Decree 1377 of 2013. The interested person may contact the offices of LA VIE COLOMBIA S.A.S., located at Calle 15 No. 35 – 1, Building C34, office 401, Medellin, Colombia; or send an email to hi@onehalf.com.co.

 

The request must have, at least, the following information:

Proprietor`s ID

Description of the fact leading to the request, suggestion, claim or complaint.

Terms of the request

Address for notifications

  

Resolution of inquiries and Complaints filed by the Proprietors of the Data

 The Proprietors or his successor in title can make requests or claims on the personal information of the Proprietor within the database of LA VIE COLOMBIA S.A.S. by one of the following mechanisms:

Calle 15 No. 35 – 1, Building C34, Office 401, Medellin.

Whatsapp: +57 3044502008

Email: hi@onehalf.com.co

Website: onehalfshop.com

 

Procedure

LA VIE COLOMBIA S.A.S. shall respond the inquiries of the proprietor or his successors in title regarding his personal data held on its database.

The inquiry shall be received by LA VIE COLOMBIA S.A.S. exclusively through any of the aforementioned channels.

The inquiry shall be answered in a term of maximum ten (10) working days from the date of reception. When it is not possible to answer the inquiry within the established terms, the interested person shall be informed, stating the reasons of the delay, and setting up a new date for which the inquiry will be answered, which in any case may not exceed five (5) working days after the expiry of the first term.

In the case of claims, the Proprietor or his successors in title considering that the information contained within the database must be subject of correction, update, or deletion, or when they perceive a non-compliance of any of the responsibilities within this Law, they may present a claim through any of the means offered by LA VIE COLOMBIA S.A.S., and it shall be solved under the following terms and conditions:

  • The claim shall be made through a request to LA VIE COLOMBIA S.A.S. with the Proprietors ID, the description of the facts arising the claim, the address, with the respective documents to be enforced. If the claim is incomplete, it will be requested to the interested person within five (5) working days following the reception of the claim to rectify the information. If after two (2) months from the reception of the claim, there is no response from the claimant presenting the required information, it shall be understood that the claim has been abandoned.

 

In the case the person receiving the claim has no competence to solve it, the person shall submit it to whoever corresponds in a term of maximum two (2) working days and shall inform the situation to the claimant.

  • Once the claim is successfully received, it shall be specified into the database that it is “pending” and its reason in a term no longer than two (2) working days. Such status shall be maintained until the claim has been completely answered.
  • The term to solve the claim will be fifteen (15) working days from the date of reception. When LA VIE COLOMBIA S.A.S. cannot provide a solution to the claim within this term, the claimant shall be informed of the reasons of the delay and the date of the solution for the claim, which shall not be longer than eight (8) working days after the expiry of the first term.

Procedural Requirement. The Proprietor or his successor in title may only submit a claim before the Superintendence of industry and Commerce once the process of consultation or claim has expired before the Responsible for the Treatment or Data Processor.

The request must contain, at least, the following information:

Proprietor’s ID.

Description of the events arising the claim, suggestion, consultation of complaint.

Terms of the request.

Address for notifications.

 

International Transfer and Transmission of Personal Data

The information and data provided may be subject of transfer and/or transmission to third countries, for the exercise of activities related with the society and/or the treatment described within this policy.

For the international transfer and transmission of the personal data, the provisions of article 26 of the Law 1582 of 2012 and article 24 of the Decree 1377 of 2013 shall be considered.

This “PRIVACY AND PERSONAL DATA PROTECTION POLICY” is published on October 3, 2022, and begins to rule from the day of its publication.