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Privacy Policy

With the authorization of personal data processing, the holder thereof accepts the terms of this policy. FRAILEHOMES S.A.S (hereinafter FRAILEHOMES) respects the personal data and information provided by its potential, current, and past clients.

In this Privacy Policy, the purposes, measures, and procedures for the collection, storage, use, circulation, and deletion of records in our databases are established, as well as the mechanisms available to data subjects to know, update, rectify, delete the data provided, or revoke the authorization.

This policy applies to any registration of personal data carried out in person, digitally, and/or virtually during any contact made between present and/or potential interested clients and FRAILEHOMES. The data subject registers or provides their information freely and voluntarily, and acknowledges having read and expressly accepts these terms.

Definitions:

  1. Authorization: Prior, express, and informed consent of the data subject to carry out the processing of personal data.
  2. Database: An organized set of personal data subject to processing.
  3. Personal data: Any information linked or that can be associated with one or more identified or identifiable natural persons.
  4. Sensitive data: Data that affects the privacy of the data subject or whose misuse may result in discrimination, such as those revealing racial or ethnic origin, political orientation, religious or philosophical beliefs, membership in unions, social organizations, human rights organizations, or promoting interests of any political party or ensuring the rights and guarantees of opposition political parties, as well as data related to health, sexual life, and biometric data.
  5. Processing: Refers to any operation or set of operations on personal data, such as collection, storage, use, circulation, or deletion.
  6. Data Processor: Natural or legal person, public or private, who, on their own or in association with others, processes personal data on behalf of the data controller.
  7. Data Controller: Natural or legal person, public or private, who, on their own or in association with others, decides on the database and/or the processing of these data.
  8. Data Subject: Natural person whose personal data is processed.

Provisions:

  1. RESPONSIBLE AND DATA PROCESSING MANAGER: The responsible and data processing manager of personal data is FRAILEHOMES, who assigns these functions to its representatives.
    1. The following are its contact details:
      1. Address: Bogotá D.C.
      2. Address: Av Carrera 45 #95-92
      3. Email: contact@frailehomes.com
      4. Phone number: (57) 302 855 8388
  2. PURPOSE OF THE DATABASE: The main purposes of the database are to inform you about the services we provide, for administrative, commercial, advertising, and/or contact purposes with the holders thereof.
  3. PERSONAL DATA: The information subject to processing by FRAILEHOMES, hereinafter in this document “Personal Data,” is that provided by the data subjects when accessing their goods and/or services, or on the occasion thereof, such as: name, surnames, identification, age, sex, telephone, physical and electronic address, country, city, and other necessary data requested in the registration process, which in no case will be of a sensitive nature within the terms of the law. FRAILEHOMES will not collect data considered as “Sensitive Data” as provided in Law 1581 of 2012 (Habeas Data), such as, for example, data revealing racial or ethnic origin, political orientation, religious or philosophical beliefs, membership in unions, social organizations, data related to health, sexual life, or biometric data.
  4. AUTHORIZATION FOR COLLECTION AND PROCESSING OF PERSONAL DATA AND OTHER INFORMATION: Through express verbal or written authorization, the data subject expressly or unequivocally authorizes FRAILEHOMES to collect personal data and any other information provided, as well as to process their personal data, in accordance with this Privacy Policy and the law.
  5. PROCESSING OF PERSONAL DATA STORED IN THE DATABASES OF FRAILEHOMES: FRAILEHOMES will only use, process, and circulate personal data for the purposes described and for the treatments authorized in this Privacy Policy or in the current laws. In addition to what is mentioned in other clauses, each HOLDER expressly authorizes FRAILEHOMES for the collection, use, and circulation of their personal data and other information for the following purposes:
    1. Establish communication between FRAILEHOMES and the HOLDER for any purpose related to the purposes established in this policy, whether by phone calls, text messages, emails, and/or physical means.
    2. Audit, study, analyze, and use the information from the Database to design, implement, and develop programs, projects, and events.
    3. Audit, study, analyze, and use the information from the Database for the socialization of policies, projects, programs, results, and organizational changes.
    4. Offer products and/or services
    5. Evaluate the consumption habits of the holders, make market analysis and/or segmentation and/or statistics.
    6. Request the opinion of the holder about products and/or services
    7. When the information must be disclosed to comply with laws, regulations, or legal processes, to ensure compliance with the terms and conditions, to stop or prevent fraud, attacks on the security of FRAILEHOMES or others, prevent technical problems, or protect the rights of others as required by the terms and conditions or the law.
    8. The others described in this policy or in the Law.
  6. STORAGE OF PERSONAL DATA: The data subject expressly authorizes FRAILEHOMES to store it in the way it considers most appropriate and to comply with the security required for data protection. Only personnel authorized by FRAILEHOMES may access the Databases where the data is stored, and therefore the personal data of our clients.
  7. SECURITY MEASURES: FRAILEHOMES undertakes to use correct and appropriate treatment of personal data, avoiding unauthorized access by third parties that allow knowing or violating, modifying, disclosing, and/or destroying the information stored in its databases. For this reason, FRAILEHOMES has security protocols and access to its information systems, storage, and processing including physical measures of security risk control.
  8. RIGHTS OF THE HOLDERS: FRAILEHOMES informs data subjects that, in accordance with current legislation, they have the right to know, update, rectify their information, and/or revoke the authorization for its treatment. In particular, the rights of data subjects are established in Article 8 of Law 1581 of 2012:
    1. Know, update and rectify your personal data. This right may also be exercised with respect to partial, inaccurate, incomplete, fractionated, and/or misleading data,
    2. Request proof of the authorization granted for the processing of your personal data,
    3. Be informed, upon request made through the channels established in this policy, regarding the use that has been made of your personal data,
    4. File complaints before the Superintendence of Industry and Commerce for breaches of the provisions of the law and other rules that modify, add or complement it,
    5. Revoke the authorization and/or request the deletion of one or more data,
    6. Access your personal data that have been subject to Processing free of charge.

NOTE 1. Person in charge of requests, queries, and complaints. The person in charge of handling the requests, queries, and complaints of the data subjects to exercise their rights to know, update, rectify, and delete their data and revoke their authorization is the Coordinator of Purchases and Contracts.

NOTE 2. Procedure to exercise your rights. In case you wish to exercise your rights, the data subject must send an email or send a physical document to the contact addresses established in this Privacy Policy.

NOTE 3. Requests and Queries Regarding Personal Data. When the data subject or their successors in interest wish to inquire about the information held in the database, they must make the request in writing through any of the channels provided by FRAILEHOMES, who will respond to the request within a maximum period of ten (10) business days. The request must be made with the full name of the data subject, a description of the facts giving rise to the request, the residential address or email address, the contact telephone number, and the documents that they wish to submit. In compliance with the provisions of Law 1581 of 2012, if it is not possible to respond to the query within said term, the user will be informed, the reasons for the delay will be explained, and the date on which the query will be addressed will be indicated, which cannot exceed five (5) business days following the expiration of the initial term.

NOTE 4. Revocation of Authorization, Withdrawal, or Deletion from the Database and Claims Regarding Personal Data. When the data subject or their successors in interest consider that the information contained in the databases should be corrected, updated, or deleted, or when they notice the alleged non-compliance with any of the duties contained in Law 1581 of 2012, they may file a claim with FRAILEHOMES, which will be processed under the following rules: The claim shall be made by means of a request addressed to FRAILEHOMES, which must include: (i) the identification of the holder(s), (ii) the description of the facts giving rise to the claim, and (iii) the notification data (residential address and/or email address and contact telephone number), and the documents that they wish to submit shall be attached. If the claim is incomplete, FRAILEHOMES may request the interested party to correct the deficiencies within five (5) days following the receipt of the claim. If two (2) months have elapsed since the date of the request without the applicant providing the required information, it shall be deemed that they have withdrawn the claim. If FRAILEHOMES is not competent to resolve the claim, it shall transfer it to the appropriate authority within a maximum period of two (2) business days and inform the data subject of the situation, thus being relieved of any claim or liability for the use, rectification, or deletion of the data. Once the complete claim is received, a legend stating "claim in process" and the reason for it shall be included in the database within a term not exceeding two (2) business days. This legend shall be maintained until the claim is decided. The maximum term for addressing the claim shall be fifteen (15) business days counted from the day following the date of its receipt. If it is not possible to address the claim within said term, the data subject shall be informed of the reasons for the delay and the date on which the claim will be addressed, which in no case shall exceed eight (8) business days following the expiration of the initial term.

CONTACT: Any doubts or additional information will be received and processed by sending them to the contact addresses established in this Privacy Policy.

DATA VALIDITY: Personal data incorporated into the Database shall be valid for the period necessary to fulfill its purposes. Once such purpose(s) is (are) fulfilled, and provided there is no legal or contractual obligation to retain the information, the data shall be deleted from our Databases.

CHANGES IN THE PRIVACY POLICY: FRAILEHOMES reserves the right to modify, unilaterally and at any time, its policy and procedures for the processing of personal data. Any substantial changes in the Processing policies will be promptly communicated to the data subjects through publication on our websites.

CURRENT LEGISLATION: The current national legislation on the protection of personal data is contained in Law 1581 of 2012, Decree 1377 of 2013, Law 1266 of 2008, and the regulations amending or supplementing it.

DISCLOSURE OF INFORMATION: The data subject, by accepting this policy for the processing of personal data, declares to be aware that FRAILEHOMES may provide this information to judicial and/or administrative entities and other State entities that, in the exercise of their functions, request this information or when there is a court order. Likewise, they accept that they may be subject to internal or external audit processes by companies responsible for this type of control. The foregoing is subject to the confidentiality of the information.