PRIVACY POLICIES RON LA HECHICERA

1. OBJECT:

To establish the rules for the recollection, storage, use, circulation and suppression of personal data processed by RON LA HECHICERA S.A.S. (hereinafter LA HECHICERA), identified with NIT 900.540.612-9 through its website www.lahechicera.co, in order to guarantee the rights of habeas data of the respective owners of the personal data, which was recognized by the Political Constitution of Colombia in its article 15 and regulated by Law 1581 of 2012 and the sole Decree 1074 of 2015.

The purpose of the Treatment Policy is to protect the constitutional right of Habeas Data that all people have to know, update, and rectify the information that has been collected and stored by LA HECHICERA through its website www.lahechicera.co, as well as the other rights and constitutional guarantees referred to in articles 15 and 20 of the Colombian National Constitution.

2. DEFINITIONS:

Database: Organized set of personal data that is processed through LA HECHICERA’s website and can be physical or electronic.

Personal Data: Any information linked to or that can be associated with a specific person, such as their name or identification number, or that can make them determinable, such as their physical features.

Private data: It is that personal data that due to its intimate or reserved nature is relevant only to its Owner.

Public Data: It is one of the existing types of personal data. Public data is considered, among others, data related to the marital status of people, their profession and their status as merchants or public servants. Due to its nature, public data may be contained, among others, in public records, public documents, official gazettes and bulletins, and duly executed court rulings that are not subject to confidentiality.

Semi-private Data: It is that personal data known and of interest both for the owner and for a certain sector of people or for society in general, so it is not of an intimate, reserved or public nature.

Sensitive Data: Are those that affect the privacy of the owner or may lead to discrimination, that is, those that reveal their racial or ethnic origin, their political orientation, religious or philosophical convictions, membership of unions, social organizations, of human rights, as well as data related to health, sexual life, and biometric data, among others.

Treatment Responsible: Natural or legal person, public or private that by itself or in association with others, decides on the database and/or Treatment of the data.

Transfer: This is the operation carried out by the person in charge or in charge of the processing of personal data, when they send the information to another recipient, who, in turn, becomes responsible for the processing of said data.

Treatment: Any operation or set of operations on personal data, such as collection, storage, use, circulation or deletion.

Treatment Manager: Natural or legal person, public or private, that by itself or in association with others, performs the Processing of personal data on behalf of the Treatment Manager.

User: The natural person who makes use of LA HECHICERA’s website, which allows them to access its content.

3. PERSONAL DATA TREATMENT:

LA HECHICERA, subject to constitutional and legal provisions, will be governed in its role as the person responsible for the processing of personal data by the guiding principles that the Colombian legal system has established in this matter, these are, according to article 4 of Law 1581 of 2012:

– PRINCIPLE OF LEGALITY REGARDING DATA PROCESSING: LA HECHICERA will manage its databases in full compliance with the constitutional and legal postulates that regulate the matter.

-PRINCIPLE OF PURPOSE: The purpose for which personal data is managed and processed will be completely in accordance with the law; they will be legitimately used for the development of commercial, operational and/or administrative activities of the company.

-PRINCIPLE OF FREEDOM: LA HECHICERA will process only those data for which it has consent or those that without consent the law enables them to process.

-PRINCIPLE OF TRUTH OR QUALITY: The storage and treatment of truthful, current and exact information will be ensured; permanent measures will be implemented to promote the updating of the data that is stored, avoiding the processing of partial, incomplete, fractional or misleading data, which is expressly prohibited by law.

-PRINCIPLE OF TRANSPARENCY: LA HECHICERA will have a communication means that allow the owners to consult their personal data that is processed by this company.

-PRINCIPLE OF ACCESS AND RESTRICTED CIRCULATION: Control and restriction of stored data is guaranteed, especially data that by their nature require special treatment (sensitive data, of children and teens).

-PRINCIPLE OF SECURITY: The necessary and appropriate measures will be taken to protect the stored data, not only by THE MANAGER as data controller, but also by any person in charge of their processing.

-PRINCIPLE OF CONFIDENTIALITY: LA HECHICERA will guarantee the confidentiality of the information stored and will supply or communicate it only when it corresponds to the development of the activities authorized by law.

4. PERSONAL DATA OWNER RIGHTS:

In full development of the provisions of article 15 of the Political Constitution of Colombia and its regulations, the owner of personal data is assisted by the following Rights:

Right to know: what personal data about him/her is held by those responsible and/or in charge of data processing.

Right to update: the data that is processed by the person in charge and/or in charge of data processing with the aim that they are adjusted to reality and allow an optimal quality of information.

Right to delete: to cancel the databases processed by the person in charge and/or in charge of the data.

Right to revoke the authorization: This revocation can be total or partial according to the owner’s will, and provided that such situation is reported in a timely manner.

The owner of the personal data will have the power to decide whether or not to answer the questions that are asked about his/her sensitive data or about data of children and teen, as provided in letter “b” of article 12. of 2012 Colombian law 1581.

In no case will personal data be processed that does not have the prior, express and informed consent of the owner in accordance with article 9 of Law 1581.

5. LA HECHICERA DUTIES.

LA HECHICERA acknowledges the ownership of personal data and therefore uses personal data to fulfill the purposes expressly authorized by the owner or by current regulations.

In the treatment and protection of personal data, LA HECHICERA will have the following duties, without prejudice to others provided for in the provisions that regulate this matter:

1. a) To know, update and rectify their personal data storage by LA HECHICERA in its capacity as data controller. This right may be exercised, among others, against data that is partial, inaccurate, incomplete, divided, that induces an error, or those whose treatment is expressly forbidden or has not been authorized.
2. b) To request proof of the authorization granted to LA HECHICERA except when it is not required by law.
3. c) To be informed by LA HECHICERA, upon request, about the use that has been given to their personal data.
4. d) To file complaints before the Superintendence of Industry and Commerce for violations of the provisions of Law 1581 of 2012 and other regulations that modify, add, or complement it.
5. e) Revoke the authorization and/or request the delete of the data when the Treatment does not respect the constitutional and legal principles, rights and guarantees.
6. f) To have free access to the personal data that have been processed by LA HECHICERA.
7. POLICY LEGAL SCOPE:

This policy applies to all personal data registered in the databases from the LA HECHICERA website, www.lahechicera.co, who acts as RESPONSIBLE for the processing of personal data.

7. TREATMENT RESPONSIBLE:

RON LA HECHICERA S.A.S. identified with NIT 900.540.612-9, with main address at Calle 93A No. 14 – 17, Office 604 of Bogotá D.C., Republic of Colombia. Webpage www.lahechicera.co, email info@lahechicera.co.

8. TREATMENT PURPOSES:

8.1. USERS: LA HECHICERA will use the personal data given by its owner to:

1. To store, organize, classify and catalog the personal data entered by THE USER within the systems, files and databases of LA HECHICERA.
2. To manage procedures (requests, applications, complaints, claims), carry out risk analysis, satisfaction surveys regarding the company’s services, as well as its business partners.
3. To validate that you are of legal age and can access the website.
4. To develop activities of technical support, maintenance, development, improvement, and surveillance of the USER’s account on the website of LA HECHICERA.
5. Send information such as news, sales, newsletters, and advertising about LA HECHICERA or its allies with whom it has a signed contract, through text messages, emails, offers published on the platform and push notifications.
6. Develop studies of the behavior of the USER in relation to their activity on the website of LA HECHICERA, and based on this make commercial offers, improvements, and changes to the website.
7. Provide contact information and relevant documents to the commercial force and/or distribution network, telemarketing, market research and any third party with which the company has a contractual relationship of any kind.
8. Disclose, transfer and/or transmit the personal data of the holders inside and outside the country, to third parties because of a contract, law or legal link that requires it, for the presentation of the respective services or under commercial agreements or alliances.
9. Carry out studies of the behavior of the USER regarding the offers and activity on the website of LA HECHICERA and, based on this, present reports and statistical analyzes for both LA HECHICERA and its allies with whom it has a signed contract.
10. Submit reports to the inspection, surveillance, and control authorities.
11. Control and prevent fraud in any of its modalities.
12. PERSONAL DATA AUTHORIZATION:

Int the processing of personal data of the owner, the prior and informed authorization of the latter is required, which must be obtained by any means that can be subject to subsequent consultation.

LA HECHICERA, in the terms provided in the Law, generated a privacy notice in which the holders are informed that they can exercise their right to the processing of personal data, through the page www.lahechicera.co.

10. COOKIES POLICY:
11. Definition: Cookies are a small data file created by the website visited and stored in the browser or device used by the USER which contain small amounts of information that are sent between LA HECHICERA’s web server and the USER’s browser, and this information is stored in the browser’s memory. The objective of this process is that the website visited can check that cookie in a future connection of the USER and use it.
12. Form of Obtaining and Types of Cookies: The Cookies are obtained by LA HECHICERA when the USER enters the page www.lahechicera.co. The Cookies used by the website are the following:
13. Essential: Those that are essential to be able to access the website and to have a complete browsing experience on it.
14. Personalization: those that allow the USER to personalize their experience within the web page and are remembered when entering the portal again.
15. Advertising: those used by LA HECHICERA to show advertising to the USER that may be of interest to them based on their preferences.
16. Analysis: Those that are used by LA HECHICERA to obtain a profile of behavior and preferences of the USER.
17. Disabling Cookies: The USER may disable the use of cookies within the web page by configuring the browser used to access it, however, this could affect the normal functioning of the web page and the experience you will have. The disabling or blocking will depend on the browser used by the USER, for which the USER must review its configuration and proceed according to the options available.
18. INQUIRES AND CLAIMS PROCEDURE:
19. Inquires. The owners or their successors in title may consult the personal information of the owner that rests in any database of LA HECHICERA.

The owner may send their questions or queries related to their personal data collected and processed by LA HECHICERA to the following channels:

CITY	ADDRESS	E-mail
Bogotá D.C.	Calle 93A No. 14 – 17, Oficina 604 de Bogotá D.C.	info@lahechicera.co

LA HECHICERA will answer your inquiry within ten (10) business days from the date it was received. When it is not possible to respond to the inquiry in that term, the interested party will be informed before the expiration of 10 days, informing the reasons for the delay and indicating the date on which the inquiry will be sent, which in no case may exceed five (5) business days following the expiration of the first term..

2. Claims. The personal data owner who considers that the information contained in any database must be corrected, updated or deleted, or when they notice the alleged breach of any of the legal duties, may file the claim through any of the following service channels:

CITY	ADDRESS	E-mail
Bogotá D.C.	Calle 93A No. 14 – 17, Oficina 604 de Bogotá D.C.	info@lahechicera.co

The claim must contain at least: The identification of the owner of the personal data, the description of the facts, the address of the owner, and any documents de claimant considers important. If it does not contain this information, the interested party will be required by LA HECHICERA within five (5) days following its receipt to correct the faults. After two (2) months from the date of the request without the applicant submitting the required information, it will be understood that the claim has been withdrawn.

Once the complete claim has been received, a legend that says, “CLAIM IN PROCESS” and the reason for it will be included in the database maintained by LA HECHICERA, within a term of no more than two (2) business days. Said legend must be maintained until the claim is answered. The maximum term to answer the claim will be fifteen (15) business days from the day following the date of receipt. When it is not possible to attend to it within said term, claimant will be informed before the expiration of the term of the reasons for the delay and the date on which their claim will be answered, which in no case may exceed eight (8) business days following the expiration of the first term.3.

Suppression. The right of deletion of data is not absolute, LA HECHICERA can deny it when:

• The owner has a legal or contractual duty to remain in the database.
• The deletion of data hinders judicial or administrative actions related to tax obligations, the investigation and prosecution of crimes or the updating of administrative sanctions.
• The data is necessary to protect the legally protected interests of the owner; to carry out an action based on the public interest, or to comply with an obligation legally acquired by the owner.
• If the cancellation of the personal data is appropriate, LA HECHICERA must carry out the deletion operationally in such a way that the deletion does not allow the recovery of the information.

12. Databases Validity:

The validity term of the databases will be the same period of validity of LA HECHICERA, except those databases whose purpose is for a one-time specific activity and its validity will be until the end of said activity.

13. Databases validity and update.

This policy applies from the moment of its publication. When the terms of the privacy policy are changed, as a general rule, a new authorization will be obtained in the established manner through the usual means of contact between the company and the owners. Any substantial change in the treatment policies will be communicated in a timely manner to the owners of the data through the usual means of contact and/or through the website www.lahechicera.co and email sent to the owners.