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Policy for the treatment of personal data

ALVILLA S.A.S., a commercial company, identified with NIT. 860.000.989-9, with its main address at Calle 10 No. 32A-12, Bogotá D.C., Colombia, recognizes the importance of security, privacy and confidentiality of the personal data of its clients, users, collaborators, suppliers, shareholders, allies and in general of all its groups of interest with respect to which it processes personal information, for which reason, in compliance with the constitutional and legal provisions, it adopted the present policy for the processing of personal data by virtue of which it is established:

FIRST - NORMATIVITY: The following is a list of the main regulations in force in Colombia regarding the protection of personal data, with whose compliance ALVILLA S.A.S. is fully committed and which have been taken into account for the development of this document and ALVILLA S.A.S.'s Integral System for the Management of Personal Data.

  • Article 15 of the Political Constitution of Colombia
  • Statutory Law 1266 of 2008
  • Law 1273 of 2009
  • Statutory Law 1581 of 2012
  • Decree 1377 of 2013
  • Decree 886 of 2014
  • Decree 1074 of 2015
  • Title V of the Sole Circular of the Superintendency of Industry and Commerce

NOTE: When legislative or regulatory changes occur regarding Personal Data, the references made in this document shall be understood to be modified by the new provisions in the relevant sections. Without prejudice that the corresponding updates are made.

SECOND - OBJECT: The POLICY FOR THE TREATMENT OF PERSONAL DATA OF ALVILLA S.A.S., establishes the parameters under which ALVILLA S.A.S. will comply with and guarantee the application of the regulations corresponding to the protection of personal data in force, in order to correctly treat them. will comply with and guarantee the application of the regulations corresponding to the protection of personal data in force, with the purpose of giving a correct treatment to the same, for which it proceeds to establish the duties, rights and responsibilities of the parties, as well as the procedure to carry out the authorization for the use of the information, consultations and claims of the owners of the personal data and other activities that may be developed on the occasion of this policy.

THIRD - SCOPE: ALVILLA S.A.S., as the party responsible for the processing of personal data, shall ensure the security and quality in the processing of information, and compliance with Article 15 of the Political Constitution of Colombia, the current regulations regarding the protection of personal data, and especially the provisions of Law 1581 of 2012, Decree 1377 of 2013 and other provisions that modify, add or complement it. This document describes the guidelines that will be carried out to protect the personal data of the owners of the information and perform a proper treatment of these.

The treatment carried out by ALVILLA S.A.S. will be based on the authorization granted by the owner and will take into account the purposes expressly informed.

FOURTH - TARGETS: This POLICY FOR THE TREATMENT OF PERSONAL DATA OF ALVILLA S.A.S. is aimed at our clients, users, collaborators, suppliers, allies and in general our stakeholders about whom ALVILLA S.A.S. processes personal information.

FIFTH - DEFINITIONS: The terms used in the text of this ALVILLA S.A.S. PERSONAL DATA PROCESSING POLICY, which are included with initial capital letters shall have the meaning assigned to them in this numeral, or in the text of this ALVILLA S.A.S. PERSONAL DATA PROCESSING POLICY.

"Personal Data Protection Authority": The Personal Data Protection Office of the Superintendence of Industry and Commerce in the Republic of Colombia and any other competent authority for data protection established in the jurisdiction of the domicile of the Controller or Processor, as applicable.

"Regulatory Authority": shall mean the competent inspection, surveillance or control entity over the activities of the Controller and the Entrusted Party, including, but not limited to, the surveillance and control authorities in Colombia.

"Authorization": Prior, express, informed and unequivocal consent of the Data Subject to carry out the Processing of Personal Data, which must be obtained by any means that may be subject to subsequent consultation.

"Privacy Notice": Verbal or written communication generated by the Controller, addressed to the Data Subject for the Processing of his Personal Data, by means of which he is informed about the existence of the information processing policies that will be applicable to him, the way to access them and the purposes of the Processing that is intended to be given to the Personal Data.

"Database": Organized set of Personal Data that is the object of Processing.

"Personal Data": shall be any information related to a natural person, such as name, age, identification number, contact telephone numbers, and in general, any data related to the person who is the Subject of the Personal Data, which separately or as a whole, allow his/her identification.

"Public Data: Data that is not semi-private, private or sensitive. Public data includes, among others, data relating to the civil status of persons, their profession or trade, and their status as merchants or public servants. By their 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. Examples: identity card number, marital status, family composition, your status as a merchant or public servant, civil registry, data contained in public documents, data contained in duly executed court rulings.

"Semi-private data": Data that are not of an intimate, reserved or public nature and whose knowledge or disclosure may be of interest not only to their owner but also to a certain sector or group of people in society in general, e.g., financial and credit data on commercial or service activities.

"Sensitive Data": Sensitive data are understood as those that affect the privacy of the Data Subject or whose improper use may generate discrimination, such as those that reveal racial or ethnic origin, political orientation, religious or philosophical convictions, membership in trade unions, social organizations, human rights organizations or that promote the interests of any political party or that guarantee the rights and guarantees of opposition political parties, as well as data related to health, sex life, and biometric data. Examples: Racial or ethnic origin, political orientation, religious or philosophical convictions, membership in trade unions, social and/or human rights organizations, data relating to health, data relating to sexual life, biometric data, habits of the person. 

"Private Data": Data that due to its intimate or reserved nature is only relevant to the Data Subject, it can be Sensitive or non-sensitive. Example: personal photograph or personal e-mail.

"Processor": The person who, independently, accepts and agrees to carry out the Processing of the Personal Data of the Data Subjects on behalf of the Controller, in accordance with the instructions given by the Controller and in accordance with the terms of this Agreement or any other contract, agreement, arrangement or commitment entered into by the Parties.

"Habeas Data: This is the right of every person to know, update and rectify all information related to him/her that is collected or stored in information centers.

NOTE: In the case of former employees, ALVILLA S.A.S. will store, even after the employment contract has ended, the information necessary to comply with the obligations that may arise by virtue of the labor relationship that existed in accordance with Colombian legislation, or by virtue of the services that may be rendered by virtue of the relationship, as well as to provide the labor certifications that may be requested by the former employee or by third parties for whom the former employee is in charge of a selection process.

"Applicable Personal Data Protection Law": Refers to any Personal Data protection, privacy or related rules concerning the collection, processing, transfer or transmission of the Personal Data of the Data Controllers, including those set forth in Section Three of this document and those that complement, substitute or modify them.

"Security measures": The information subject to Processing by the Responsible or the Person in Charge of the Processing of Personal Data, shall handle the information with the technical, human and administrative measures that are necessary to guarantee the protection of the Personal Data avoiding its adulteration, loss, consultation, use or unauthorized or fraudulent access.

ALVILLA S.A.S.'s "Policy for the Treatment of Personal Data": this is the policy that will govern the Treatment of Personal Data carried out by the Controller or on behalf of the Controller.

"Responsible": It is ALVILLA S.A.S., a legal entity that will independently determine the purpose and the way in which the Personal Data will be processed.

"Data Subject (Data Subject)": Is a determined or identifiable natural person, whose Personal Data is subject to the Processing thereof by the Controller or the Processor.

"Transfer": The transfer of Personal Data takes place when the Controller and/or Processor of Personal Data, sends the information or Personal Data to a Recipient, which in turn is the Data Controller and is located inside or outside the country.

"Transmission": It is the Processing of Personal Data that implies the communication of the same within or outside the territory of the Republic of Colombia, with the purpose of allowing the Controller and the Processor to carry out the Processing of the Personal Data.

"Processing": shall mean any operation or set of operations performed on the Personal Data, consisting of the collection, recording, organization, storage, consultation, use, disclosure by transmission, updating, transfer, dissemination or any other form and/or the blocking, erasure or destruction thereof.

NOTE - INTERPRETATION: Without prejudice to other rules of interpretation under applicable law, which do not contravene the rules set forth below, both the Processor and the Responsible Party agree that the Agreement shall be interpreted in accordance with the following rules:

  1. Definitions denoting the singular also include the plural and vice versa or in feminine, neuter or masculine gender, as long as the context so requires.
  2. The definitions that are not expressly established in the POLICY FOR THE TREATMENT OF PERSONAL DATA OF ALVILLA S.A.S. shall be understood in the current and usual sense that they have in the corresponding technical language or in the natural and obvious one according to the general use of the same.

SIXTH - GUIDING PRINCIPLES FOR THE TREATMENT OF PERSONAL DATA: ALVILLA S.A.S. commits to the Holders of the information to treat their Personal Data in accordance with the following principles:

  1. Principle of legality in data processing: ALVILLA S.A.S. is aware that the Processing referred to in Law 1581 of 2012 is a regulated activity, which must be subject to what is established therein and in the other provisions that develop it.
  2. Principle of purpose: ALVILLA S.A.S. will treat Personal Data for a legitimate purpose, in accordance with the Political Constitution of Colombia and the law, which will be informed to the Data Subject.
  3. Principle of freedom: ALVILLA S.A.S. will treat Personal Data only with the prior, express and informed consent of the Data Subject. Personal Data may not be obtained or disclosed without prior authorization or in the absence of a legal or judicial mandate.
  4. Principle of truthfulness or quality: the information that is subject to Processing must be truthful, complete, updated, verifiable and understandable. At ALVILLA S.A.S., it is forbidden to Process Personal Data that is fractioned or misleading.
  5. Principle of transparency: ALVILLA S.A.S. is aware that the Data Controllers have the right to obtain, at any time and without restrictions, information about the existence of the Personal Data that concerns them.
  6. Principle of restricted access and circulation: the Processing is subject to the limits derived from the nature of the Personal Data, in accordance with the provisions of Law 1581 of 2012 and the Political Constitution of Colombia. In this sense, the Processing may only be carried out by persons authorized by the Holder and/or by the persons provided by law. With the exception of public information, ALVILLA S.A.S. will not make Personal Data available on the Internet or other means of dissemination or mass communication, except if access is technically controllable to provide restricted knowledge only to Data Holders or authorized third parties in accordance with Law 1581 of 2012.
  7. Security Principle: ALVILLA S.A.S. will handle the information subject to Processing referred to in Law 1581 of 2012 with the technical, human and administrative measures that are necessary to provide security to the records, avoiding their adulteration, loss, consultation, use or unauthorized or fraudulent access.
  8. Principle of confidentiality: all persons involved in the Processing of Personal Data that are not of a public nature are obliged to guarantee the confidentiality of the information, even after the end of their relationship with any of the tasks included in the Processing, and may only provide or communicate Personal Data when it corresponds to the development of the activities authorized in Law 1581 of 2012 and under the terms of the same.

SEVENTH - AUTHORIZATIONS: ALVILLA S.A.S. will request the Authorization in such a way that the Holder of the information grants his/her prior, express and informed consent for the Processing to which his/her Personal Data is subject.

Authorization may also be obtained from unequivocal conducts of the Data Subject, which allow to reasonably conclude that he/she gave his/her consent for the Processing of his/her information. Such conduct must clearly externalize the will to authorize the Processing.

The consent of the Holder may be obtained by any means that may be subject to subsequent consultation, such as written, verbal, virtual communication or by unequivocal conduct.

By virtue of its nature and corporate purpose, ALVILLA S.A.S. receives, collects, registers, keeps, stores, modifies, reports, consults, delivers, transmits, transfers, shares and eliminates personal information, for which it obtains the previous Authorization of the Holder.

The Authorization granted by the Holders of the information to ALVILLA S.A.S. allows, among other things, the following purposes: to offer and provide information on products and services, as well as to consult, report and update their Personal Data before the information and risk operators; to update the current contractual relationships and to comply with the agreed obligations, among others (see section Eight of the purposes).

ALVILLA S.A.S. will keep proof of such authorizations in an appropriate manner, ensuring and respecting the principles of privacy and confidentiality of the information.

Learn here the Authorization for the Treatment of personal information signed by our customers and / or suppliers.

Likewise, at ALVILLA S.A.S., when dealing with information related to the following types of Personal Data, the following special considerations will be taken into account:

  1. Sensitive Data: For the Processing of Sensitive Data, ALVILLA S.A.S. will inform the Data Subject of the following:
    • For the processing of this type of information, the Data Subject is not required to give his or her Authorization or consent.
    • The type of Sensitive Data that will be requested will be explicitly informed in advance.
    • The Processing and the purpose for which the Sensitive Data will be used will be communicated.
    • The Authorization of Sensitive Data shall be prior, express and clear.
  2. Personal Data of children and adolescents: ALVILLA S.A.S. will ensure that the Processing of this type of Personal Data is carried out in accordance with the rights of children and adolescents. In this sense, their special nature will be protected and it will ensure respect for their fundamental rights, in accordance with the provisions of Articles 5, 6 and 7 of Law 1581 of 2012, and Articles 6 and 12 of Decree 1377 of 2013, and other regulations that modify or add to them.

In order to comply with the above, ALVILLA S.A.S. shall act in accordance with the following:

  1. Authorization will be requested from the legal representative of the child or adolescent after the minor has exercised his or her right to be heard, an opinion that will be assessed taking into account the maturity, autonomy and capacity to understand the matter, in order to carry out the Processing of his or her Personal Data.
  2. The optional nature of answering questions about the Personal Data of children or adolescents will be informed.
  3. It will be explicitly and previously informed which Personal Data is the object of processing and the purpose of such processing.

ALVILLA S.A.S. informs all its stakeholders that, in accordance with Article 10 of Law 1581 of 2012, the Authorization of the Holder will not be necessary when dealing with: (a) information required by a public or administrative entity in the exercise of its legal functions or by court order, (b) Personal Data of a public nature, (c) cases of medical or health emergency, (d) Processing of information Authorized by law for historical, statistical or scientific purposes, and (e) Personal Data related to the Civil Registry of persons.

EIGHTH - PURPOSES: The following are the main purposes for which ALVILLA S.A.S. processes personal information:

  1. Clients:
    • To know their financial, commercial and credit behavior and compliance with their legal obligations.
    • Perform all necessary steps to confirm and update customer information.
    • Validate and verify customer identity for product and service offerings, as well as to share information with various market players.
    • Establish a contractual relationship, as well as maintain and terminate a contractual relationship.
    • Offer and provide products or services through any media or channel according to the customer's profile.
    • Receive information from ALVILLA S.A.S. regarding current and future commercial campaigns, promotion of products and services, and other communications necessary to keep the customer informed and communicated by means of: phone call, text message, email, Facebook, Twitter, Instagram or any social network integration or instant messaging, among others.
    • Receive messages related to collection management and portfolio recovery, either directly or through a third party contracted for such function.
    • To provide commercial, legal, product, security, service or any other type of information.
    • To know the customer's location and contact information for security purposes and to offer benefits and commercial offers.
    • Conduct commercial, statistical, risk and market analysis and research, including contacting the client for these purposes.
    • To know the status of the operations (active, passive or of any nature) or those that in the future the client may celebrate with ALVILLA S.A.S., with other financial or commercial entities, information operator, database administrator or any other similar entity that may be established in the future and whose purpose is any of the aforementioned activities.
    • Prevent money laundering, terrorist financing, as well as detect fraud, corruption, and other illegal activities.
    • Perform, validate, authorize or verify transactions, including, when required, the consultation and reproduction of Sensitive Data such as fingerprint, image or voice, among others.
    • Conduct satisfaction surveys concerning the services provided by ALVILLA S.A.S.
    • Consult fines and sanctions before the different administrative and judicial authorities or public databases whose function is the administration of data of this nature.
  1. Suppliers:
    • The information requested to the supplier may include information of the natural or legal person as appropriate. Likewise, it is possible that information may be requested from employees of the supplier or ally that are dedicated to fulfilling some function or relationship with ALVILLA S.A.S. that, due to the work performed, require access to the organization's facilities, applications and/or systems or others.
    • To carry out the supplier's linking process with ALVILLA S.A.S., generating the development of internal procedures, which are relationship, accounting, financial, commercial, logistic, among others.
    • Manage and verify commercial and reputational background and the risks of money laundering and financing of terrorism, as well as to detect and/or prevent fraud, corruption and other illegal activities by the supplier or its employees in relation to the operation of ALVILLA S.A.S.
    • Manage and strengthen contractual relations with the supplier, allowing greater control over the obligations assumed by the parties.
    • Review and evaluate the supplier's results, in order to strengthen the contracting processes within ALVILLA S.A.S.
    • Offer and provide products or services through any means or channel in accordance with the supplier's profile.
    • Perform commercial, statistical, risk, market and financial analysis and research based on the results of the supplier or partner.
  1. Applicants and collaboratorsThe information that ALVILLA S.A.S. collects from applicants or candidates for positions within the organization is treated with the purpose of carrying out the evaluation of admission and the process of linking the applicant. The treatment of the personal information of our collaborators has as purpose the management of the existing labor relations with them, as well as the development of the different activities established by the organization. Among which we highlight the following:
    • To comply with the obligations and rights derived from its activity as an employer, and the activities of its main and related corporate purpose, which may be carried out directly or with the support of third parties with whom your information will be shared for purposes related to the object of the contract.
    • Share your personal data with national or foreign authorities (judicial or administrative) when the request is based on legal, procedural, and/or tax reasons.
    • Access and authorization of benefits established by the employer, according to the requirements defined in each case.
    • Consultation of your Personal Data in the internal control lists, in compliance with national regulations and internal policies associated with the Money Laundering and Terrorism Financing Risk Management System - SARLAFT, as well as compliance with ethics and integrity standards established by ALVILLA S.A.S.
    • To disclose your information to the employee and mutual funds to which you have authorized to receive it.

NOTE: In the case of former employees, ALVILLA S.A.S. will store, even after the employment contract has ended, the information necessary to comply with the obligations that may arise by virtue of the labor relationship that existed in accordance with Colombian legislation, or by virtue of the services that may be rendered by virtue of the relationship, as well as to provide the labor certifications that may be requested by the former employee or by third parties for whom the former employee is in charge of a selection process.

  1. ShareholdersThe information and Personal Data of the shareholders, including personal and contact information, as well as the information and documentation provided through virtual channels, telephone channel, e-mail and information updates will be collected, consulted, updated, modified and processed directly by ALVILLA S.A.S. and/or by third parties designated by it, for the following purposes:
    • To carry out the activities of integral administration of the shareholders' registry book.
    • Provide information related to procedures, complaints and shareholder requests.
    • Provide access to information to judicial or administrative authorities requesting such data in the exercise of their functions.
    • Manage the risk of Money Laundering and Financing of Terrorism and corruption.
    • Fulfillment of the necessary activities and purposes of the issuer's relationship with the shareholders.
  1. Access to buildings, surveillance and security of facilities:
    • To have information on each one of the workers, Outsourcing personnel that work for ALVILLA S.A.S. and visitors that enter the organization's facilities.
    • Control and identify access to the organization's facilities.
    • Maintain security and access control to buildings and other facilities.

NOTE: ALVILLA S.A.S. informs all Data Holders that the Personal Data collected directly at the security points of the administrative headquarters, buildings, branches and other facilities, which are provided in documents of the security personnel, and the Personal Data obtained from the video recordings made inside or outside the ALVILLA S.A.S. facilities, are used for security purposes of people, goods and facilities.

NINTH - RIGHTS OF THE OWNER: The Owners of the information that is the object of Processing by ALVILLA S.A.S. may:

  1. To know, update, rectify, suppress or revoke their Personal Data and to be informed of the Processing that ALVILLA S.A.S. carries out on the Personal Data.
  2. Submit requests and claims related to the regulations in force regarding the protection of Personal Data.
  3. To request revocation of the Authorization and/or suppression of Personal Data in the event that ALVILLA S.A.S. determines that the conduct is contrary to the current regulations. The request for suppression or revocation will not proceed when the Holders have the legal or contractual duty to remain in ALVILLA S.A.S.'s database.

In accordance with art. 20 of Decree 1377 of 2013, the exercise of the aforementioned rights may be exercised by the following persons:

  1. By the owner, who must prove his identity sufficiently by the different means made available to him by the person in charge.
  2. By their successors in title, who must prove their status as such.
  3. By the representative and/or attorney-in-fact of the Holder, upon accreditation of the representation or power of attorney.
  4. By stipulation in favor of or for another.
  5. The rights of children or adolescents shall be exercised by the persons who are empowered to represent them.

TENTH - ALVILLA S.A.S. DUTIES: ALVILLA S.A.S., as the party responsible for the Personal Data stored in its Databases, undertakes to:

  1. To guarantee to the Data Subject the full and effective exercise of his/her rights.
  2. Request and keep a copy of the Authorization granted by the Holder or proof thereof.
  3. Inform the Data Subject about the purposes of the collection, the uses of his/her Personal Data and his/her rights according to the Authorization granted.
  4. Keep the information in secure conditions to prevent its adulteration, loss, consultation, use or unauthorized access.
  5. To guarantee that the information provided to third parties or persons in charge of processing is truthful, complete, accurate, updated, verifiable and understandable.
  6. To update the information held by any third party or Responsible Party, with respect to all developments in relation to the data provided and to take the necessary measures to ensure that the information is up to date.
  7. Rectify the information when it becomes known that it is incorrect.
  8. Ensure that third parties and/or persons in charge of the treatment of personal information for which ALVILLA S.A.S. is responsible, have effective measures and policies to guarantee the adequate treatment of said information. Likewise, they will be required to commit to accept and apply the provisions of this POLICY FOR THE TREATMENT OF ALVILLA S.A.S. PERSONAL DATA and other guidelines established by ALVILLA S.A.S. or certify that their internal policies include at least the provisions set forth herein. In case it is not possible to issue the certification, ALVILLA S.A.S. must corroborate that the internal policies of the third parties and/or Data Processors include security and/or privacy criteria equivalent or superior to those provided for herein. In this sense, the third parties and/or Agents shall adopt the security and privacy measures and conditions for the Personal Data that is shared with them, at least at the same level of protection adopted by ALVILLA S.A.S.
  9. To process the queries and claims formulated in accordance with the provisions of the POLICY FOR THE TREATMENT OF PERSONAL DATA OF ALVILLA S.A.S. and the law.
  10. To inform the Personal Data Protection Authority when security breaches occur and there are risks in the administration of the data subjects' information.

Eleventh - ATTENTION OF CONSULTATIONS, COMPLAINTS AND CLAIMS: The Owners of the information when they need to make a consultation, complaint or claim may make use of:

Inquiries: The Data Controllers, their successors in title or any other person who may have a legitimate interest, may request to be informed about the Personal Data of the Data Controller that is stored in any ALVILLA S.A.S. Database.

In accordance with the above, ALVILLA S.A.S. will guarantee the right of consultation, making known the personal information linked to the Data Subject.

Inquiries regarding access to information, proof of the Authorization granted by the Holder, uses and purposes of the personal information, or any other inquiry related to the personal information provided by the Holder, must be submitted through the channels provided by ALVILLA S.A.S.

The consultation will be answered within a maximum term of ten (10) business days from the date of receipt of the same.

When it is not possible to attend the consultation within the term provided, the interested party shall be informed, stating the reasons for the delay and the date on which the consultation will be attended, which shall not exceed five (5) business days following the expiration of the first term, in accordance with the provisions of Article 14 of Law 1581 of 2012.

2. Claims

  • Correction, updating, suppression and revocation: The Data Holders, their assignees or any other person with a legitimate interest, who consider that the information contained in any of ALVILLA S.A.S.'s Databases should be subject to correction, updating or suppression or who notice a possible breach of the duties established in Law 1581 of 2012 and its regulatory decrees, may file a claim following the requirements of Article 15 of the same law.
  • Requirements to file a claim:
    • Identification of the holder or of the person filing the claim, indicating his name and identification number.
    • Describe the reason for the claim in a clear and express manner, where the facts that originated the claim are established, presenting the documents that the claimant intends to assert.
    • Prove the legitimate interest of the person filing the claim and attach, if necessary, the corresponding supports.
    • Indicate the telephone number, physical or electronic address to which the response to the request should be notified and sent.

In any case, if the claim is incomplete, the interested party will be required within five (5) days of receipt of the claim to correct the faults. If after two (2) months from the date of the request, without the applicant presenting the required information, ALVILLA S.A.S. will understand that the claim has been withdrawn.

When ALVILLA S.A.S. is not the competent entity to resolve the claim presented, it will be transferred to the corresponding party within a maximum term of two (2) business days, and the interested party will be informed of this situation.

In the event that the claim is received complete, a legend will be included in the Data Base stating "in process" and the reason for the claim, within a term no longer than two (2) business days. This legend will remain until the claim is resolved and will be adjusted according to internal procedures.

However, the maximum term to address the claim will be fifteen (15) business days from the day following the date of receipt. When it is not possible to address it within such term, the interested party will be informed of the reasons for the delay and the date on which the claim will be resolved, which in no case may exceed eight (8) business days following the expiration of the first term.

The Holders, their assignees or any other person with a legitimate interest, may file a complaint before the Superintendence of Industry and Commerce, but only once they have exhausted the consultation or complaint process before ALVILLA S.A.S., as the Responsible Party and/or any Responsible Party, in accordance with the provisions of Article 16 of Law 1581 of 2012.

  • Suppression of information: In case of requesting the suppression of all or part of your personal information, you must take into account that ALVILLA S.A.S. will analyze the request made. However, the suppression of the information will not proceed in case the Holder has a legal or contractual duty to remain in the Database that ALVILLA S.A.S. manages.
  • Revocation of the Authorization: In case of requesting the revocation of the Authorization of his/her Personal Data, ALVILLA S.A.S. will analyze the request made and will inform the Data Subject if this revocation proceeds.
    However, the revocation of the Authorization will not proceed in case the Holder has any legal or contractual duty to remain in the Database managed by ALVILLA S.A.S.
    . The consultations and claims presented will be processed according to the internal processes and procedures.

TWELFTH - CHANNELS OF ATTENTION FOR CONSULTATIONS, COMPLAINTS AND CLAIMS: ALVILLA S.A.S. has enabled the following channels of attention for the Owners of Personal Data to exercise their rights to know, update, rectify and/or delete their personal information.

Address:Calle 10 No. 32A - 12, Bogotá D.C., Colombia.
Phone:(601) 370 0088
E-mail:contabilidad@alvilla.com
Hours of Operation:Monday through Friday from 8:00 a.m. to 5:00 p.m.
Web site:www.alvilla.com

THIRTEENTH - TRANSFER AND TRANSMISSION OF PERSONAL DATA: ALVILLA S.A.S., as the party responsible for the personal information stored in its Databases and in the development of the purposes described in this document, may carry out national or international Transfers or Transmissions of Personal Data.

ALVILLA S.A.S. is committed to verify the level of protection and security standards of the country receiving the personal information, to make the declaration of conformity (when applicable) and to sign a transfer contract or other legal instrument that guarantees the protection of the Personal Data being transferred.

By virtue of this exchange relationship, ALVILLA S.A.S. has adopted several guidelines for the relationship with third parties, in order to protect the information that is the object of this activity.

In order to protect the information, ALVILLA S.A.S. will verify if the Superintendence of Industry and Commerce has included the respective country in the list of countries that offer an adequate level of data protection or will review the regulations in force in the country receiving the information, in order to determine if it has the appropriate conditions to guarantee adequate levels of security for the information that is the object of the Transmission or Transfer.

FOURTEENTH - VALIDITY: This POLICY FOR THE TREATMENT OF PERSONAL DATA OF ALVILLA S.A.S. is effective as of the date of its approval on August 8, 2022.