Privacy Policy

Our collections are exclusive designs of Nitrato, their reproduction by third parties is prohibited.

What we do with your information:

1. The term “personal information” as used in this site is defined as any information that identifies or can be used to identify, contact, or locate the person to whom the information belongs. The personal information we collect will be subject to this privacy policy, and will be modified from time to time.

2. When you register with Nitrato we ask for your email address.

3. Nitrato uses the information we collect for the following general purposes: Delivery of products, identification, improvement of services, contacts.

4. At any time each user can modify or delete your account.

www.nitrato.co

PRIVACY POLICY OR TREATMENT OF PERSONAL DATA OF ESTAMPADOS COLORWAY S.A.S.

This Policy came into effect on May 11, 2019, replacing the one in force until that date.

We have modified our Privacy Policy or Treatment of Personal Data. The new version of our Privacy Policy or Personal Data Processing Policy will be effective as of May 11, 2019. The use of our services as of May 11, 2019 will be governed by this version.

The main changes to this version of our Privacy Policy or Personal Data Processing Policy, as well as those historically made to it, you will be able to find them in the following sections:

Section 1 Principles

Section 2 Sources of information collected or gathered by Estampados ColorWay S.A.S.

Section 3 Personal information

Section 4 Duties of the holder of personal data

Section 5 Treatment of the information by Estampados ColorWay S.A.S.

Section 6 Purposes of the processing of your personal data

Section 9 How we share your personal information with third parties

Sections 10 and 15 Exercising your rights as a holder of personal information and questions about the use of your personal information

Legal considerations by country Estampados ColorWay S.A.S.

We have included a section in which we tell you about the principles that govern the treatment of your personal information.

We have specified the information that you provide to us, which will be processed by Estampados ColorWay S.A.S.

We have added events of information coming from third parties.

For your clarity, we have included a definition of what is meant by personal information.

We have included a section in which we tell you what you must take into account and what you must do when you give us your personal information.

We invite you to read the new version of our Privacy Policy or Personal Data Treatment Policy in its entirety and familiarize yourself with it.

This Privacy Policy or Treatment of Personal Data of Estampados ColorWay S.A.S. applies to Colombia.

This Privacy Policy or Treatment of Personal Data of Estampados ColorWay S.A.S applies to all users of the services of Estampados ColorWay S.A.S, that is, businesses natural and legal persons, the latter in the events that under the respective law of Protection of Personal Data must be applied, payers of business customers Estampados ColorWay S. A.S that are linked directly with Estampados ColorWay S.A.S in the payment process through their access to the payment platform of Estampados ColorWay S.A.S, or all those natural persons whose data are collected or collected by Estampados ColorWay S.A.S in events, websites of Estampados ColorWay S.A.S.

This Privacy Policy or Treatment of Personal Data of Estampados ColorWay S.A.S establishes:

a) What personal data we collect or collect and the purposes for which we carry out its treatment.

b) For what purposes we use your personal data.

c) The channels through which you can contact us to request: (i) updating, (ii) modification, (iii) deletion or elimination1, and/or (iv) refusal to Estampados ColorWay S.A.S. to process your personal data.

In order to guarantee at all times your right to privacy and the protection of your personal data, we have tried to make this Policy as simple as possible for your better understanding. Your information and privacy are important to us!

As the owner of your personal data you consent to the treatment when being on the websites of Estampados ColorWay S.A.S we ask you to check and approve the box of acceptance of Terms and Conditions of Use of Services Estampados ColorWay S.A.S and this Privacy Policy or privacy notice, the latter in cases where applicable. We invite you to know, read carefully and familiarize yourself with this Policy, before accepting it and give us your personal data for treatment.

You are not obligated to provide us with your personal information; however, if you choose not to do so, you may not be able to use some of our services or we may not be able to respond to your inquiries and needs.

You will always have access to this Policy by accessing our websites, on the home page or in the Legal section.

Estampados ColorWay S.A.S may modify this Policy at any time. The modifications will be made known to you with the publication we make of them on our website and will be effective from the time of publication, unless otherwise indicated. If the modifications require your express consent, by modifying the purposes of the processing of your personal data, you will be informed so that you expressly accept and renew the authorization you have given us for the processing.

Delete data: Delete, erase, remove the holder’s personal data from the databases.

1. PRINCIPLES GOVERNING THE PROCESSING OF YOUR PERSONAL DATA

The processing of your personal data is governed by the following principles, which apply without prejudice to the other principles established in the applicable Personal Data Protection laws:

a) Legality Principle: The processing of your personal data will be done based on the provisions of the applicable law and this Privacy Policy or Processing of Personal Data.

b) Principle of purpose: The treatment that we make of your personal data must obey a purpose, which will be established in this Privacy Policy or Processing of Personal Data, in the applicable law or in the contract you have with Estampados ColorWay S.A.S. These purposes are legitimate and legal and are established for the proper provision of our services and / or for the improvement of the same or the experience and contact you have with Estampados ColorWay S.A.S.

c) Principle of freedom: The processing of your personal data can only be exercised with your prior, express and informed consent. Your personal data may not be obtained or disclosed by Estampados ColorWay S.A.S without your prior authorization, or in the absence thereof, without a legal or judicial mandate that relieves your consent.

d) Principle of transparency: As the owner of your personal data, you have the right to obtain information regarding your personal data, the purposes of processing, the databases in which they are contained, among other aspects relating to your privacy and the protection of your right to access your personal data.

e) Principle of security: Your personal information will be handled by Estampados ColorWay S.A.S. through the provision of technical, human and administrative measures that are necessary to provide security to your data, avoiding its adulteration, loss, consultation, use or unauthorized or fraudulent access.

f) Principle of confidentiality: Your personal data will be subject to confidentiality.

2. SOURCES OF INFORMATION COLLECTED OR GATHERED BY ESTAMPADOS COLORWAY S.A.S.

Estampados ColorWay S.A.S may collect or gather personal information from the following sources:

a) Information you provide to us. To make use of the services of Estampados ColorWay S.A.S as a Merchant or Payer in any of the countries in which we operate, or, if you have a legal relationship with Estampados ColorWay S.A.S as a service provider, or you are interested in contacting us or knowing what Estampados ColorWay S.A.S is, we may make available registration forms in which you will be asked to provide your personal information, mainly to contact you and provide you with our services. For example, we request personal information related to your identification data (name, cell phone number, e-mail address, identification number or ID, among others). We may also ask you for more information, for reasons of public order laws related to tax or fiscal matters or for the prevention and control of money laundering and prevention of terrorism, among others. If you are a payer, we will ask you for information about your means of payment, such as credit card number, expiration date, card franchise, among others.

b) Information we obtain when you use our services. We collect information related to the service we offer. Among the information obtained in this way, we include the following data: (i) IP address, (ii) cookies. This information will identify your browser or your account Estampados ColorWay S.A.S and serves as a measure of information security, as well as to prevent identity theft or other behaviors that put at risk the personal data of the user or customer. We also collect information related to your payment habits (frequency, merchants to which you have paid using Estampados ColorWay S.A.S, payment behaviors), movements and transactions through Estampados ColorWay S.A.S, or any other information related to and generated by your interaction with the payment platform and its derived services.

c) Information we obtain from third parties such as credit bureaus, or identity validators, as well as third party allies whenever we can legally resort to these sources.

3. DEFINITION OF PERSONAL INFORMATION

In accordance with the applicable personal data protection laws and for the purposes of this Privacy Policy or Treatment of Personal Data, we will consider that the information you provide us has the character of personal, provided that the same, alone or in conjunction with other data delivered or generated, allows us to identify you and/or particularize you as an individual, or in cases where applicable, as a legal entity. Data such as, for example, your name, telephone number, address, bank account number and its ownership, among others, are of a personal nature. This information is your exclusive property.

In contrast to the above, the information that you register or deliver to Estampados ColorWay S.A.S. or that we generate from it and that does not reflect or refer to a particular natural person, or legal entity in the cases that according to the applicable data protection law is required, allowing your individual identification, such as that related to the amount of a transaction, the purchase of a particular good or service, the means of payment, the bank used or the information that we anonymize, among others, do not have the character of personal information.

4. DUTIES OF THE HOLDER OF PERSONAL DATA

4.1 When Estampados ColorWay S.A.S acts as the person in charge of your personal data and, consequently, we have not directly collected your consent for the treatment you must ask the person responsible for your data, which may be, for example, a business customer of Estampados ColorWay S.A.S technically integrated via API with us and with whom you have a consumer or business relationship for the purchase of their goods or for the provision of their services, to inform you and share this Privacy Policy. That responsible will be the one who collects your acceptance for the processing of your personal data.

4.2 All personal data and information you provide as a user of the services Estampados ColorWay S.A.S, must be truthful, complete, accurate, current, verifiable and understandable.

4.3 You must prove, when you exercise your right to correct, update, delete, revoke your consent for the processing of your personal data, that you are indeed the owner or who requests it is authorized by you, in the terms required by law.

5. HOW DOES ESTAMPADOS COLORWAY S.A.S TREAT YOUR PERSONAL INFORMATION?

5.1 Estampados ColorWay S.A.S will give your personal data the treatment authorized by you and by law. The treatment includes the purposes set forth in this Privacy Policy, or Privacy Notice, in cases where applicable under the Law.

5.2 For the purposes described in this Privacy Policy or in the Privacy Notice, Estampados ColorWay S.A.S. may process, collect, use, store, protect, among other activities, your personal information, including, among others, the following:

a) Identifying information (e.g., name, address, landline or cell phone number, e-mail address, user name provided by Estampados ColorWay S.A.S.).

b) Banking and payment information (e.g., credit card information, account number).

5.3 Estampados ColorWay S.A.S. may share your personal information among Estampados ColorWay S.A.S. Companies and/or with its suppliers, when necessary to provide you with our services. Estampados ColorWay S.A.S. and/or our suppliers will be obligated to use your personal information only for the purposes set forth in this Policy. Estampados ColorWay S.A.S. ensures that all third parties involved in the processing of your personal data use standards of protection in accordance with applicable law and in accordance with the provisions of this Privacy Policy.

Your acceptance of this Policy implies your consent to Estampados ColorWay S.A.S may share your personal information with Estampados ColorWay S.A.S and/or our suppliers within the limits described in the authorization and in this Policy.

5.4 We may also combine your personal information with other information we have, that comes from third parties or resulting from the use you make of our services, to provide and improve the services Estampados ColorWay S.A.S, its content and advertising, as well as for the development and / or offering of products and services themselves or partners, among others.

5.5 Estampados ColorWay S.A.S may treat all or some of your personal data on servers located in countries other than where Estampados ColorWay S.A.S provides its services in Latin America and where you reside as owner. This treatment may be carried out by Estampados ColorWay S.A.S (any of the companies Estampados ColorWay S.A.S) or by third parties commissioned by Estampados ColorWay S.A.S for this purpose. In this event, Estampados ColorWay S.A.S. will verify that those countries have adequate levels of protection of personal data and in accordance with those set forth in this Policy and applicable law and enforce the requirements of this Policy and legal requirements for the processing of your data. The aforementioned transfer is necessary for us to provide our services. By accepting this Privacy Policy, you understand this and consent to this.

5.6 When non-personal information is combined with personal information, the information will be treated as personal information by Estampados ColorWay S.A.S.

6. WHAT ARE THE PURPOSES OF THE PROCESSING OF YOUR PERSONAL DATA?

6.1 Our main objective in collecting your personal information is to be able to provide our services to you in a safe, efficient, personalized and smooth manner.

6.2 Estampados ColorWay S.A.S collects and treats your personal information as permitted or necessary for the fulfillment of the following purposes:

6.2.1 To process the payment transactions you make on our platform. To do this, Estampados ColorWay S.A.S will collect or collect the data of the holder buyer/payer to generate the payment process appropriate to the means of payment chosen by it, such as: means of payment in cash, debit card payments, credit card payments, payments with private or private label cards, payments with means of payment or benefits granted by Estampados ColorWay S.A.S to users of its services (merchants and payers) in the countries where they are available.

Depending on the type of payment chosen by the buyer/payer, Estampados ColorWay S.A.S. will share the data with the institutions that validate and process each means of payment, for authorization, validation and corresponding compensation. This implies that your personal data may be collected for these purposes by financial institutions issuing the means of payment, acquiring financial institutions, payment processing networks, franchises such as Visa, MasterCard or American Express, to name a few.

The result of the processing of the payment made, will be notified to the merchant client of Estampados ColorWay S.A.S. to which the payment is being made, subsequently and the holder buyer / payer.

By accepting this Privacy Policy, you authorize us to share your personal information with the enabling entities of the means of payment and with the entities responsible for processing and clearing of the same institutions, as well as with the merchant client of Estampados ColorWay S.A.S. from which you are acquiring a good or service.

6.2.2. Verify your identity.
6.2.3. Authenticate and validate that payments made with credit cards are not fraudulent and thus mitigate the risk of identity theft of cardholders. To do this, some of your personal and non-personal data, collected by Estampados ColorWay S.A.S directly or delivered to Estampados ColorWay S.A.S by the merchant, will enter the anti-fraud module of Estampados ColorWay S.A.S for such validation and there will remain for future reference and cross-reference information required to validate your payments.
6.2.4. Use your data in the filters provided by third parties to Estampados ColorWay S.A.S, in order to validate transactions and mitigate the risk of identity theft of cardholders.
6.2.5. Save your data in case you exercise your right of withdrawal on purchases made or that the purchase or purchases are subject to dispute or chargeback, in order to share the transaction information and, if required, your personal information, with the financial institutions responsible for resolving disputes or to return the resources for the withdrawal.
6.2.6. Use your personal data in transactional or monitoring reports that can be used by Estampados ColorWay S.A.S or merchants customers of Estampados ColorWay S.A.S to which you have paid, in case that as a holder you are a buyer / payer.
6.2.7. Compare your information to verify its accuracy.
6.2.8. Prevent the Estampados ColorWay S.A.S system from being used for illegal activities and for the purpose of enforcing our General Terms and Conditions of use of the system, as a buyer or as a merchant.
6.2.9. To provide you with support and troubleshooting service.
6.2.10. Provide you with information about Estampados ColorWay S.A.S or Estampados ColorWay S.A.S’s clients or partners, including advertising or promotional information.
6.2.11. Inform you about bugs and updates to the system or services of Estampados ColorWay S.A.S.
6.2.12. Contact you or send you notifications.
6.2.13. Resolve disputes.
6.2.14. Billing for the use of services Estampados ColorWay S.A.S.
6.2.15. Use your personal information for internal purposes, such as auditing, reporting, analysis or data mining, research to improve products, services and communications as a user you are Estampados ColorWay S.A.S. services.
6.2.16. Store your personal data for the time required for compliance with the purposes stipulated in this Policy or for compliance with contractual or legal purposes, and always under the time limits established in the commercial or privacy laws and protection of personal data in the different countries in which Estampados ColorWay S.A.S. provides its services.
6.2.17. If you are a buyer / payer, and you are interested in using the functionality of storing credit cards for future payments called “Estampados ColorWay S.A.S, which you will find available at the time of making your payments, you can store and have at your disposal in Estampados ColorWay S.A.S information related to credit cards you want. To make operational the functionality “Estampados ColorWay S.A.S. will store the data of your electronic equipment (identification of the device), as well as your credit cards, such as card number, expiration date, franchise, issuing bank.

The data of your credit card(s) will be stored by Estampados ColorWay S.A.S. applying the standards of security and protection of the information established by the regulations, which you will be able to consult in www.pcisecuritystandards.org/.

It is important that you know that your personal information will be stored by Estampados ColorWay S.A.S. under the functionality of Estampados ColorWay S.A.S. only if the payment transaction you are making to enable the functionality is approved by the issuers, acquirers, networks, and/or any other participant in the process of approval and validation of payments. If this does not occur, Estampados ColorWay S.A.S. will not store your credit card information.

This functionality is not required for you to access our services. Likewise, if you make use of “Estampados ColorWay S.A.S. but you wish, at any time, to stop using this functionality, you can contact us and we will send you a link or the procedure to remove your information in the functionality “Estampados ColorWay S.A.S.”.

6.2.18. Customize, measure and improve the services provided by Estampados ColorWay S.A.S., as well as our web pages and access to the services of Estampados ColorWay S.A.S.
6.2.19. Information related to your payment habits, use of the services of Estampados ColorWay S.A.S, access to our websites, your movements and transactions paid through Estampados ColorWay S.A.S, which may include the review of the information of the business customers of Estampados ColorWay S. A.S that have been paid through our system, as well as any other information related to and generated by the interaction with the payment platform and derived transactions, may be used for the analysis of Estampados ColorWay S. A. S., which may be used for the analysis of Estampados ColorWay S. A. S., which may be used for the analysis of the payment platform and derived transactions. A.S, which may be performed by automated means and may lead to the creation of profiles that can be treated for the development and / or improvement and / or offering of products and / or services are own or in partnership with third parties, or for offering promotions or benefits, which in the opinion of Estampados ColorWay S.A.S are in your favor or your interest and / or that can improve your interaction and use of Estampados ColorWay S.A.S and / or future developments. The described activities may be carried out by Estampados ColorWay S.A.S. in cases where it has the quality of Responsible for the processing of your data and may be subject to additional consent from you, when required by the respective applicable legislation.
6.2.20. Request your opinion or participation in electronic surveys and send you communications and commercial and advertising information of the companies Estampados ColorWay S.A.S, customers of Estampados ColorWay S.A.S or third party allies, subject to additional consent when required by applicable law, in reference to products and / or services, as well as promotions regarding them, whether Estampados ColorWay S.A.S, its customers or allies.
6.2.21. Organize and carry out contests, games, offers or promotional or marketing operations, and similar events of Estampados ColorWay S.A.S and / or businesses linked or not to Estampados ColorWay S.A.S.
6.2.22. Send you discount coupons or grant benefits for future purchases through Estampados ColorWay S.A.S.
6.2.23. Propose your membership in loyalty programs, create user consumption profiles, and send you promotional and advertising materials that may be of interest to you.
6.2.24. Also, and as applicable authorize Estampados ColorWay S.A.S to consult and report your information and behavior on monetary obligations to credit risk centers, financial, commercial or service legitimately constituted, or other financial institutions, in accordance with the law.

Estampados ColorWay S.A.S. may also make validations of the credit risk profile from the personal information you have provided us or has been generated with the use of our services on your part.

6.2.25. Make backup copies of the databases, in order to protect them and ensure business continuity Estampados ColorWay S.A.S. If you want more information about backup processes, you can contact us.
6.2.26. The processing of your personal data may be carried out on servers of Estampados ColorWay S.A.S or third parties contracted by Estampados ColorWay S.A.S, located in different countries around the world (such as but not limited to Argentina, Brazil, Mexico, Chile, Peru and Panama, United States). Estampados ColorWay S.A.S. reserves the right to transfer (or transmit) your personal information outside the country of your residence and domicile, always ensuring that those countries have adequate levels of protection of personal data to those set forth in this Policy and applicable law.

The transfer is made to comply with the provision of our Services or supply other operational needs of the business or in the development of any of the purposes set out in this Policy.

By using the services Estampados ColorWay S.A.S, you understand that the transfer is necessary for the provision of our services and authorize such transfer.

6.3 Estampados ColorWay S.A.S will request your consent or verify the legal basis for the treatment, before using your personal data for any purpose other than those set out in both the Privacy Policy or the Privacy Notice, in the events in which the latter is applicable.

6.4 Whenever required by law, such databases or databases will be registered with the competent authorities.

The processing of your personal data will be limited to the fulfillment of the purposes set forth in this Policy and in the Privacy Notice when applicable, and to different purposes that are compatible or analogous to those set forth in such documents, without being required to obtain again the consent of the Data Subject.

7. ADVERTISING

7.1 Estampados ColorWay S.A.S does not market or obtain any profit from the use of your personal information.

7.2 Estampados ColorWay S.A.S may combine your personal information with information from Estampados ColorWay S.A.S, Comercios Estampados ColorWay S.A.S or third parties to improve and personalize the content of advertisements, promotions and advertising that may be of interest to you.

7.3 If you do not wish to receive advertising information, or do not want your data to be used to parameterize and customize your profile for marketing purposes of products and services of Estampados ColorWay S.A.S or the Estampados ColorWay S.A.S or third parties, you may at any time request the cessation of the use of your personal data for these purposes, through the means provided by Estampados ColorWay S.A.S for this purpose in this Policy.

8. COOKIES AND OTHER TECHNOLOGIES

8.1 The websites of Estampados ColorWay S.A.S, online services, email messages and advertisements may use “cookies” and other technologies such as pixel tags and web beacons. These technologies allow Estampados ColorWay S.A.S, understand the behavior of its users indicate which parts of the websites were visited and facilitate and measure the effectiveness of advertisements and web searches.

8.2 By using the software or websites of Estampados ColorWay S.A.S, you consent to the use of cookies.

8.3 You can decide to reject cookies at any time. However, if you do so, please note that some features are only available through the use of cookies and therefore if you decide not to accept them will not be available.

8.4 The information that is collected by cookies and other technologies is treated by Estampados ColorWay S.A.S as non-personal information, unless in accordance with the legislation of the countries in which Estampados ColorWay S.A.S provides its services must have this treatment.

8.5 Internet Protocol (IP) addresses and similar identifiers will be treated by Estampados ColorWay S.A.S as personal information, when in accordance with the legislation of the countries in which Estampados ColorWay S.A.S provides its services must have this treatment, otherwise it will be non-personal information.

9. HOW WE SHARE YOUR PERSONAL INFORMATION WITH OTHER USERS OF ESTAMPADOS COLORWAY S.A.S SERVICES AND WITH THIRD PARTIES.

9.1 Estampados ColorWay S.A.S may share your personal information with financial institutions, entities that provide the means of payment available on our platform, franchises, verification entities, networks or any others involved in the processing and validation of payments. By granting your authorization supported by this Policy, you authorize Estampados ColorWay S.A.S. to share your personal data with these entities.

9.2 Estampados ColorWay S.A.S may share your personal information with merchants customers of Estampados ColorWay S.A.S, in order to confirm the completion of a payment through Estampados ColorWay S.A.S. This includes sharing information related to the rejection of payment or unsuccessful payments.

Merchants customers Estampados ColorWay S.A.S. may not use your personal information for any purpose other than as set forth herein, unless you consent and you have expressly authorized and directly to Estampados ColorWay S.A.S. Commerce.

Estampados ColorWay S.A.S. is not responsible for the management, information protection practices or compliance with laws on protection of personal data by the business customers of Estampados ColorWay S.A.S.

9.3 Estampados ColorWay S.A.S will not disclose your credit card number or bank account number to the client trade Estampados ColorWay S.A.S to which you have paid through Estampados ColorWay S.A.S, unless you authorize us to do so.

9.4 Estampados ColorWay S.A.S may, in some cases and if necessary, share your personal data with group companies Estampados ColorWay S.A.S, operators, agents or service providers who are partners or contractors Estampados ColorWay S.A. S, for the provision of services Estampados ColorWay S.A.S. In all cases, Estampados ColorWay S.A.S require those who share your personal data, take appropriate organizational and technical measures to protect your personal data and respect the relevant legislation.

9.5 Estampados ColorWay S.A.S may share your personal data with credit bureaus and collection agencies, under the terms permitted by law.

9.6 Estampados ColorWay S.A.S may share your personal information with companies with which it may merge or with companies that intend to acquire, in whole or in part, the companies Estampados ColorWay S.A.S. In any case, this Policy will continue to govern the terms of use of the information, until it is replaced or modified, depending on the situation.

9.7 Estampados ColorWay S.A.S may disclose your personal information when we are required to do so in compliance with the policies of handling credit cards or rules of financial institutions involved in the processing and validation of payments.

9.8 Estampados ColorWay S.A.S may disclose your personal information, on the occasion of a legal process, litigation and / or at the request of public and governmental authorities within or outside your country of residence or in compliance with mandatory procedures, such as reports to government entities in terms of withholding and taxes.

9.9 Estampados ColorWay S.A.S may disclose your personal information if it is necessary to comply with the law or administrative or judicial order.

9.10 Estampados ColorWay S.A.S may disclose your personal information when it considers that there is sufficient evidence to believe that disclosure of personal information is necessary to prevent damage or financial loss to Estampados ColorWay S.A.S or any user of the services Estampados ColorWay S.A.S.

9.11 Estampados ColorWay S.A.S may disclose your personal information when required to report any suspected illegal activity.

9.12 Estampados ColorWay S.A. S may access and use your personal information when we believe in good faith that doing so is necessary to: (i) comply with applicable law; (ii) protect our users from spam or prevent attempts to defraud our users or our system; (iii) for the operation and maintenance of our websites, products and services, such as, for example, to prevent or stop an attack on our networks and our computer systems; (iv) protect our rights and property; (v) to enforce compliance with the terms governing the use of our websites, products or services.

9.13 Estampados ColorWay S.A.S may share your information with partners such as financial institutions and financial technology companies, among others, with which Estampados ColorWay S.A.S enter into agreements to explore, create and / or offer products and / or services. In such events, with the acceptance of this privacy policy you authorize Estampados ColorWay S.A.S to share your personal data with such third parties.

10. HOW TO ACCESS YOUR PERSONAL DATA AND EXERCISE YOUR RIGHTS AS OWNER

10.1 Estampados ColorWay S.A.S guarantees access to your personal information so you can exercise your right to modify, correct, update, delete or refuse its processing. You may access your information in the manner and times established by applicable law, according to the laws of your country or the country in which the processing of personal data is being carried out, as applicable.

10.2 You can perform all the actions referred to above in relation to your personal information, unless Estampados ColorWay S.A.S must keep it in the state in which it is registered in the system Estampados ColorWay S.A.S, for legal, contractual or legitimate business reasons that prevent it.

10.3 Estampados ColorWay S.A. S may reject, whenever legally permitted, requests for access, rectification, cancellation, opposition, changes, modifications, updates, among others, of your personal information, which are: (i) more repetitive than reasonable, (ii) requiring a disproportionate technical effort (for example, develop a new system or radically change an existing practice), (iii) that jeopardize the privacy of other users or (iv) that are impractical (for example, requests that refer to information stored in backup systems).

10.4 Estampados ColorWay S.A.S may provide the data update service free of charge. In the event that the update or modification of personal data generates a cost, you will be notified in advance and you will be charged whenever legally permitted.

10.5 In providing the services Estampados ColorWay S.A.S, your personal data are protected so that they can not be deleted accidentally or intentionally. For this reason, even if you request the removal of your data from our services, it is possible that Estampados ColorWay S.A.S. not immediately delete your personal data from our information systems or backup copies and residual stored on our active servers. Such complete deletion will be finalized or not according to: (i) our technical procedures for renewing backup copies or similar technical activities, (ii) events that could cause damage to the rights or legitimate interests of third parties, (iii) the existence of a legal obligation to retain the information.

10.6 The exercise of your rights must be made taking into account the following considerations:

a) The exclusive channel established by Estampados ColorWay S.A.S for the exercise of your rights, attention to queries, requests, complaints and claims is correo:gerencia@colorway.com.co.
b) You must submit a written request in which you identify yourself and show us that you are the owner of the personal data, or that the person requesting information on your behalf or exercising any of your rights is entitled to do so under the terms of applicable law.
c) You must also comply with the requirements of the applicable personal data protection law to exercise your rights. In that sense, you must, for example, support your request with facts and attach the evidence you wish to assert.

11. LINKED WEBSITES AND THIRD PARTY APPLICATIONS

11.1 On the websites of Estampados ColorWay S.A.S there may be links that take you to another website.

11.2 The linked websites are not under the control of Estampados ColorWay S.A.S and have different privacy policies.

11.3 If you use extras, add-ons or third-party applications to access the services of Estampados ColorWay S.A.S, the provider of such applications may have access to certain personal data about you. Estampados ColorWay S.A.S. cannot control how the provider of the applications uses the personal data available in connection with them. Do not forget to read the privacy policies of the provider before installing or using the applications.

11.4 The Privacy Policy of Estampados ColorWay S.A.S. only concerns personal data that is collected directly by Estampados ColorWay S.A.S.

11.5 Estampados ColorWay S.A.S recommends you to be careful when providing your information on the Internet. Estampados ColorWay S.A.S does not accept any responsibility in relation to websites outside its control.

12. PROTECTION AND SECURITY OF PERSONAL INFORMATION

12.1 The protection and security of personal, financial and business information is treated and managed according to the Information Security Policy Estampados ColorWay S.A.S.

12.2 Estampados ColorWay S.A.S takes the legal, technical and organizational measures it deems necessary to maintain the security of your personal information, with due compliance with the corresponding obligations and exceptions under current legislation.

12.3 Estampados ColorWay S.A.S follows the industry standards for the protection of personal data, including, among other measures, firewalls, Virtual Private Network (“VPN”) and Transport Layer Security (“TLS”). Additionally, Estampados ColorWay S.A.S. is a certified entity under the PCI standard (Payment Card Industry Data Security Standard).

12.4 Estampados ColorWay S.A.S protects your personal information during processing with encryption methods, among other existing or future techniques to ensure the security of information.

12.5 Estampados ColorWay S.A.S reviews its policy on collection, storage and processing of your personal data, including physical security measures to prevent tampering, loss, consultation, use or unauthorized or fraudulent access to your personal information.

12.6 Estampados ColorWay S.A.S communicates its Privacy Policy to employees and suppliers and applies strict privacy protection measures within.

12.7 Estampados ColorWay S.A.S limits the access of contractors, agents and employees to the personal information they must process. Only authorized employees of Estampados ColorWay S.A.S. or its affiliates, subsidiaries or service providers who need access to such information in order to fulfill their job duties may have access to personal data. Estampados ColorWay S.A.S ensures that they comply with strict contractual confidentiality obligations and that they are subject to the contractual and legal consequences that such breach may generate them.

12.8 Estampados ColorWay S.A.S ensures that the obligation of confidentiality assumed by the persons involved in the processing of your personal information, subsists even after the end of the relationship between Estampados ColorWay S.A.S and those persons.

13. RETENTION OF PERSONAL INFORMATION

13.1 Estampados ColorWay S.A.S will retain your personal information for the period necessary to fulfill the purposes described in this Privacy Policy, unless the law requires or permits a longer retention period.

14. MINORS

14.1 Estampados ColorWay S.A.S does not collect, use or voluntarily disclose personal information from minors, according to the equivalent minimum age in the relevant jurisdiction, without the prior consent of the minor’s parents or guardians.

14.2 Estampados ColorWay S.A.S services are not intended or designed to attract minors.

14.3 If we learn that we collect the personal information of a minor according to the jurisdiction, without first receiving verifiable parental consent, we will take steps to delete the information as soon as possible.

14.4 We encourage parents to stay informed about their children’s online activities to ensure that no information is collected from a child without parental consent.

15. QUESTIONS ON THE PROTECTION OF INFORMATION

15.1 The exercise of rights, requests, inquiries and complaints may be made to Estampados ColorWay S.A.S under the following considerations:

15.1.1 If you have any questions or concerns about this Policy or data processing, or if you wish to file a complaint related to a possible infringement of applicable personal data protection laws, contact us at mail: gerencia@colorway.com.co.

15.1.2 The updating of personal data of users, as well as the rights of information, access, rectification, cancellation and opposition can be exercised by written communication to gerencia@colorway.com.co.

15.2 Estampados ColorWay S.A.S gives response to all your concerns in the shortest possible time and within the terms that the applicable law of Personal Data Protection requires.

15.3 If you are not satisfied with the response received by Estampados ColorWay S.A.S you can let us know, in which case we will take the necessary actions to satisfy your request, or you can refer your complaint to the competent data protection authority.

LEGAL CONSIDERATIONS BY ESTAMPADOS COLORWAY S.A.S

In order to comply with Law 1581 of 2012 and other related and complementary rules Estampados ColorWay S.A.S Colombia S.A.S. (“Estampados ColorWay S.A.S” or the “Company”) domiciled in the city of Bogota, at Calle 99 No. 99 No. 14-49 Piso 7, Bogota, Colombia. 14-49 Piso 7, Bogota, Phone: +57 (1) 6540721, informs you that it acts as Responsible for your personal data collected through the platform and / or transactional channel and / or through payments made through Estampados ColorWay S.A.S.

Consequently, with the verification and acceptance of this Policy and the acceptance of our contracts of use of the system (terms and conditions of merchants and terms and conditions of payers) you represent that you know this Policy of Treatment of Information or Privacy Policy (the “Policy”) and that you consent to the processing of your personal data, in the terms set forth therein.

This Policy of Estampados ColorWay S.A.S describes:

How to access your personal data and exercise your rights as owner?

In accordance with Law 1581 of 2012, the holders of personal data have the following rights, which may be exercised by sending an email to the Data Protection Area, at the following address gerencia@colorway.com.co

a) To know, update and rectify their personal data with respect to 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) Be informed by the Data Controller or the Data Processor, upon request, regarding the use that has been made of their personal data.
d) File complaints with the Superintendency of Industry and Commerce for violations of the provisions of Law 1581 of 2012 and other rules that modify, add or supplement it.
e) 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.

In accordance with the provisions of Law 1266 of 2008, in addition to the provisions of Law 1581 of 2012, in relation to the rights indicated in paragraph 2.4. of this section “LEGAL CONSIDERATIONS BY COUNTRY ESTAMPADOS COLORWAY S.A.S” / COLOMBIA, Estampados ColorWay S.A.S guarantees the exercise of the following rights to the holders when applicable: a. Exercise the fundamental right to habeas data under the terms of the law, through the use of the procedures of consultations or claims, without prejudice to other constitutional and legal mechanisms. b. Request the respect and protection of other constitutional or legal rights, as well as other provisions of the law, through the use of the procedure of claims and petitions. c. Request proof of the certification of the existence of the authorization issued by the source or by the user. d. Request information about the authorized users to obtain information. e. Request information or request the updating or rectification of the information. f. Request information about the authorized users to obtain information. g. Request information or request the updating or rectification of the information. h. Request information about the authorized users to obtain information. i. Request information about the authorized users to obtain information. j. Request information or request the updating or rectification of the information. k. Request information about the authorized users. Request information or request the updating or rectification of the data contained in the database, which will be done by Estampados ColorWay S.A.S. as operator, as established in the procedure for consultations, claims and requests under Law 1266 of 2008 f. Request information about the use that the user is giving to the information.

The personal data authority in Colombia is the Superintendence of Industry and Commerce to which you may address in the terms established in the current legal regime.

2.2. Authorization model

Estampados ColorWay S.A.S will request your authorization for the processing of your personal data using informed authorizations, such as the following, in the events that can not make available to you this Privacy Policy and you can not know in advance the same, nor assent to its application for the processing of personal data you provide us:

2.2.1 MODEL AUTHORIZATION FORMAT BY WAY OF EXAMPLE.

AUTHORIZATION FOR THE PROCESSING OF INFORMATION

In order to comply with Law 1266 of 2008 and Law 1581 of 2012 and other related and complementary rules Estampados ColorWay S.A.S Colombia S.A.S. (“Estampados ColorWay S.A.S” or the “Company”) domiciled in the city of Bogotá, at Calle 99 No. 14-49 Piso 7, Bogotá, Colombia. 14-49 Piso 7, Bogotá, informs you that it acts as Responsible for your personal data and financial data collected through the platform and/or transactional channel and/or through the payments made by the payment system Estampados ColorWay S.A.S. Consequently, with the acceptance you state that you know the Privacy Policy included in this document and you know and authorize in a free, prior, express and informed manner that:

The information you provide when you open an account Estampados ColorWay S.A.S or to proceed with a payment to a business linked to Estampados ColorWay S.A.S from which you have purchased a product or service and which may correspond to identifying information such as name, email, contact number, address, as well as banking and payment information (for example, credit card information, account number, among others), be used either directly by Estampados ColorWay S. A.S. or by authorized third parties such as businesses, financial institutions issuing payment methods, acquiring franchises such as Visa and MasterCard, among others, for billing, payment processing and / or that the transaction processed is accepted or rejected. It will also be subject to treatment by Estampados ColorWay S.A.S through databases and systems Estampados ColorWay S.A.S, managed directly by Estampados ColorWay S.A.S or by authorized third parties according to business needs in order to validate transactions, verify your identity, and mitigate the risk of identity theft of cardholders. All under strict security and confidentiality.

Information related to your payment habits, movements and transactions through Estampados ColorWay S.A.S, as well as merchants against which you have made payments with Estampados ColorWay S.A.S, or any other information related to and generated by your interaction with the payment platform and derived transactions, will be used for the analysis and study of feasibility and participation, offering by Estampados ColorWay S. A.S of promotions, benefits, products and innovative services, which in the opinion of Estampados ColorWay S.A.S are in your favor and can improve your interaction and use of Estampados ColorWay S.A.S and / or future developments. Your information is subject to the treatment that is necessary for the development of the corporate purpose of the Company always under guidelines of security, confidentiality and protection necessary according to the applicable regulations in force.

Your information collected and subjected to treatment is used to send you information that we believe may be of interest to you, and in general marketing efforts, advertising, offers, promotions, surveys, or other operations aimed at making you aware of Estampados ColorWay S.A.S. services, both current and future.

The treatment of your information, either through a transmission or international transfer, and that may occur in other countries (such as but not limited to Argentina, Brazil, Mexico, Chile, Peru and Panama, United States) by any or some of the companies Estampados ColorWay S.A.S or third party suppliers of Estampados ColorWay S.A.S, in order to provide the services Estampados ColorWay S.A.S, or supply other operational needs in accordance with the terms and conditions applicable. Estampados ColorWay S.A.S. will ensure that these countries and third parties offer adequate levels of protection for your information.

Provide you with support and troubleshooting services.

To prevent the Estampados ColorWay S.A.S. system from being used for illegal activities and to enforce our General Terms and Conditions of use of the system.

Customize, measure and improve the services provided by Estampados ColorWay S.A.S, our web pages and access to the services of Estampados ColorWay S.A.S.

Compare information to verify its accuracy.

Inform you about bugs and service updates.

Contact you or send you notifications, if necessary. Estampados ColorWay S.A.S. respects your preferences regarding the means of communication and contact. If you do not wish to receive notifications through text messages on your device, or prefer to receive them by a single means of communication, for example by email, you can let us know by contacting us directly.

Resolving disputes.

Use your personal information for internal purposes, such as audits, data analysis and research to improve products, feasibility studies in terms of installment sales, granting credit, analysis of your behavior against monetary obligations that relate to Estampados ColorWay S.A.S, services and communications with users of Estampados ColorWay S.A.S. services.

Store your personal data for the time that is required for the fulfillment of the purposes for which they were collected and in accordance with commercial laws or privacy and protection of information that is applicable.

If you are a payer, store and have at your disposal, for when you need to make payments, the information related to your electronic equipment, as well as your means of payment, such as card numbers, security codes, as long as you decide to make use of storage functionalities such as “Estampados ColorWay S.A.S. or similar. Your credit card data will be stored by Estampados ColorWay S.A.S, taking into account the standards of security and protection of information established by the Payment Card Industry PCI DSS regulations, which you can consult in www.pcisecuritystandards.org .

Request your opinion or participation in electronic surveys.

Send you communications and commercial and advertising information of the companies Estampados ColorWay S.A.S, of the businesses registered in Estampados ColorWay S.A.S and third parties that include promotions for the purchase of goods or services through Estampados ColorWay S.A.S.

Organize and carry out contests, games, offers or promotional or marketing operations, and similar events of Estampados ColorWay S.A.S and / or businesses linked or not to Estampados ColorWay S.A.S.

Send you discount coupons or provide benefits for future purchases through Estampados ColorWay S.A.S.

Propose your affiliation to loyalty programs, create user consumption profiles, and send you promotional and advertising materials that may be of interest to you.

Estampados ColorWay S.A.S. will request your consent before using your personal data for any purpose other than those set forth in this authorization and corresponding Privacy Policy.

Estampados ColorWay S.A.S. will collect your personal data in their databases or personal data banks and will give them the treatment set forth in this authorization and complementary Privacy Policy.

You also authorize Estampados ColorWay S.A.S. to access, consult, compare and evaluate information about you that is stored in the databases of any central credit risk, financial, or any commercial or service database that allows to establish your behavior as a debtor, user, customer, holder of financial, commercial or any other type of services when required for the development and offering of new products and services. Likewise, and as applicable, you authorize Estampados ColorWay S.A.S. to report your information and behavior on monetary obligations to credit, financial, commercial or service risk centers legitimately constituted, or other financial institutions, in accordance with Law 1266 of 2008 and other applicable regulations.

You also state with the click of acceptance that the information provided is true, that you have not omitted or altered any information. This authorization is extended to whoever represents the rights of Estampados ColorWay S.A.S., whoever contracts for its exercise, or whoever assigns their rights, obligations or contractual position in any capacity. This authorization will remain in force, until it is revoked according to the events provided by law, without being able to be revoked in whole or in part, in force of the link or under the legal rules that require the Company to keep it stored.

You may at any time exercise your rights to know, update, rectify and delete your personal information, as well as to request proof of authorization, revoke it, and file claims with the Responsible or initiate complaint proceedings before the Superintendence of Industry and Commerce. We invite you to know the Information Processing Policy where you will learn more about the procedure for exercising your rights, available below or here.

HERE ENDS THE TEXT OF AUTHORIZATION FOR YOUR ACCEPTANCE. IF YOU DO NOT GIVE YOUR CONSENT WE WILL NOT BE ABLE TO PROVIDE THE SERVICE ESTAMPADOS COLORWAY S.A.S.

HERE IS THE PRIVACY POLICY FOR YOUR QUICK KNOWLEDGE AND CONSULTATION.

2.3. TRANSFER AND TRANSMISSION

The processing of your personal data may be carried out on servers of Estampados ColorWay S.A.S or third parties contracted by Estampados ColorWay S.A.S,

Estampados ColorWay S.A.S. reserves the right to transfer or transmit your personal information outside the country of your residence and domicile, always ensuring that those countries have adequate levels of protection of personal data to those established in this Policy and applicable law.

The transfer or transmission is made to comply with the provision of our Services or supply other operational needs of the business or in the development of any of the purposes set out in this Policy.

By using Estampados ColorWay S.A.S. services, you understand that the transfer or transmission is necessary for the provision of our services and you authorize such transfer or transmission.

2.4. USE OF YOUR INFORMATION AND REFERRAL TO THIRD PARTY ALLIES

Information related to your payment habits, use of the services of Estampados ColorWay S.A.S, access to our websites, your movements and transactions paid through Estampados ColorWay S.A.S, which may include the review of information from merchants customers Estampados ColorWay S.A. S that have been paid through our system, as well as any other information related and generated by the interaction with the payment platform and derivative transactions, may be used for analysis of Estampados ColorWay S.A.S, which may be performed by automated means and may lead to the creation of profiles such as scores with content and credit purpose. This information may be sent to third party allies, such as financial institutions for analysis and review by such third parties in relation to credit risk, in order to make the offering of products or services jointly with Estampados ColorWay S.A.S or own such third parties, which may have credit or financial and serve as a basis for decision-making by such third parties. With the acceptance of the privacy policy you are authorizing the performance of these activities with respect to such data, by Estampados ColorWay S.A.S. In case you do not want such operations on your data to be performed, we invite you to send us a communication to the mail indicated in this policy in exercise of your right to revocation of consent. Similarly, if you wish to exercise your right to access, rectify and/or update the information indicated, we also provide you with the aforementioned email address, in accordance with the provisions of Law 1266 of 2008 and/or Law 1581 of 2012, as applicable, as indicated in these CONSIDERATIONS APPLICABLE BY PAIS ESTAMPADOS COLORWAY S.A.S/ Colombia.