PRIVACY POLICY AND PROCESSING AND PROTECTION OF PERSONAL DATA

HOLALU SAS is a for-profit company, which is in charge of the design, manufacture and distribution of jewelry in general. At HOLALU SAS, it is respectful of the personal data and information provided by its current, past and potential clients, commercial allies and possible interested parties in the company's products (hereinafter, the Holders).

In this Privacy Policy and Treatment and Protection of Personal Data, hereinafter "the Policy", the purposes, measures and procedures of our databases are established, as well as the mechanisms that the Holders have to exercise their rights to know , update, rectify, delete the data provided or revoke the authorization granted with the acceptance of this Policy. The express or unequivocal acceptance of the guidelines and principles contained in this document implies the acceptance of the Holders of this Policy and their authorization for the uses and other treatments described here.

1. RESPONSIBLE AND IN CHARGE OF DATA PROCESSING

The person responsible for the processing of personal data and other information of the Holders is the company HOLALU SAS (hereinafter, ROSA INÉS CUARTAS), identified with the following data:

Tax identification number: 185.330-8;
Address and address: Cra. 14 #93B-29 Office 403 of Bogotá DC, Colombia;
Telephone: 320 8984 776;
Email: info@rosainescuartas.com

2. PROCESSING OF PERSONAL AND FINANCIAL DATA OF MINORS

The following statement is, especially, addressed to those children and adolescents who are minors and wish to purchase products and/or have ties of any kind with Rosa Inés Cuartas:

Hello! If you are a minor and wish to purchase any of our services, you are cordially invited to request permission from your parents or legal representatives, so that they can contact us.

Unfortunately, Rosa Inés Cuartas cannot receive your personal information directly, in order to better protect your rights. However, your parents can help you so you can buy our products or contact us!

We appreciate your interest in our brand. Good day!

3. PURPOSE OF THE DATABASE

The treatment of ROSA INÉS CUARTAS databases has the following purposes:

3.1. In relation to the database of employees, contractors and applicants for employees or proponents of ROSA INÉS CUARTAS

Keep and manage the information of the employment or commercial relationship with the Holders.
Compliance with legal, accounting, commercial and regulatory duties.
The control and preservation of the security of people, goods and information of ROSA INÉS CUARTAS.
Fulfill the purpose of the labor or civil relationship that may have been acquired with the Holders.
Protect the health of ROSA INÉS CUARTAS employees and contractors.
Prevent and verify the commission of crimes or criminal behavior by employees, contractors and applicants, for which different databases and sources may be consulted, such as databases of the National Police, Comptroller, Interpol, FBI, SDNT list (or “Clinton List”), SARLAFT, as well as the corresponding social networks, in the manner in which they are arranged.
Prevent and counteract a possible reputational risk that could affect ROSA INÉS CUARTAS, for which different databases and sources may be consulted, such as databases of the National Police, Comptroller, Interpol, FBI, SDNT list (or " Clinton List"), SARLAFT, as well as the corresponding social networks, in the manner in which they are arranged.
Maintain direct communication with the Holders for issues related to their employment or commercial relationship.
Selection of personnel, administration of contracts, management of labor relations and compliance with the obligations derived from it, granting benefits to its employees by itself or through third parties, as well as allowing employees access to the computer resources of the company. Company.
Keep a record of the disciplinary sanctions imposed on contractors and employees of ROSA INÉS CUARTAS.
Carrying out statistical, commercial, financial, social and technical analyses.
Communication with owners for contractual, informative and commercial purposes.
Compliance with legal, contractual, accounting, commercial and regulatory duties.
Checking and verification of the identity and criminal, disciplinary, financial and credit history of the holders.
The control and preservation of the safety of people, goods, rights, interests and information of ROSA INÉS CUARTAS.
Transmit, transfer and supply the information and personal data of the Holders to those third parties in charge of administering the social security system in Colombia, as well as to insurance companies.
Transmit, transfer and supply the information and personal data of the Holders to third parties, in those cases in which employer substitution occurs or in those cases in which ROSA INÉS CUARTAS cedes its contractual position.
Transmit, transfer and supply the information and personal data of the Holders to third parties, in order to give labor and/or professional references about the Holders.
Comply with the obligations related to the detection and prevention of money laundering, financing of terrorism, bribery (national and/or transnational) and corruption (both national and transnational). This purpose includes the necessary studies and reviews for Publicly Exposed Persons (PEP).
Within our social networks, such as Facebook, Instagram, Twitter, YouTube, among others, you can share or repost images and videos or when you tag the official accounts of Rosa Inés Cuartas.

3.2. In relation to the database of clients, suppliers and business partners of ROSA INÉS CUARTAS

Fulfillment of the corporate purpose of ROSA INÉS CUARTAS.
The development, execution and fulfillment of the contractual relationship that the owner has with ROSA INÉS CUARTAS.
Compliance with legal, accounting, commercial and regulatory duties.
Carrying out statistical, commercial, strategic, financial, social and technical analyses.
Communication with owners for contractual, informative and commercial purposes.
Compliance with legal, accounting, commercial and regulatory duties, including reporting to credit bureaus.
The control and preservation of the safety of people, goods and information of ROSA INÉS CUARTAS, for which different databases and sources may be consulted, such as databases of the National Police, Comptroller, Interpol, FBI, SDNT list (or "Clinton List"), SARLAFT, credit risk centers, as well as the Holder's social networks, in the manner in which they are arranged.
Prevent and counteract a possible reputational risk that could affect ROSA INÉS CUARTAS, for which different databases and sources may be consulted, such as databases of the National Police, Comptroller, Interpol, FBI, SDNT list (or " Clinton List"), SARLAFT, credit risk centers, as well as the Holder's social networks, in the manner in which they are arranged.
Checking and verification of the identity and criminal, disciplinary, financial and credit history of the holders.
Transmit, transfer and supply the information and personal data of the Holders to the subsidiaries, affiliates or affiliates of ROSA INÉS CUARTAS, commercial allies or to other national and/or international companies or persons that ROSA INÉS CUARTAS commissions to process the information and comply with the purposes described in this Policy and the purpose of the commercial or civil relationship with the Holders, or for said third parties to assume the position of Responsible.
Develop commercial and marketing activities, such as: consumption analysis; profiling, brand traceability; sending news, advertising, promotions, offers and benefits; customer loyalty programs; market research; Generation of campaigns and events for Company brands.
Transmit, transfer and supply, free of charge or for a fee, the information and personal data of the Holders to national and/or international business partners so that they can contact the Holders to offer them their products, information or services that in the opinion of ROSA INÉS CUARTAS may be of interest to the Owner.
Comply with the obligations related to the detection and prevention of money laundering, financing of terrorism and corruption (both national and transnational). This purpose includes the necessary studies and reviews for Publicly Exposed Persons (PEP).
Transmit, transfer and supply the information and personal data of the Holders to national and/or international third parties, in those cases in which ROSA INÉS CUARTAS participates in merger, integration, spin-off, liquidation and/or asset disposal processes.
In order to preserve the security of ROSA INÉS CUARTAS, analyze and verify the information of the employees and collaborators of ROSA INÉS CUARTAS and of those who participate in selection processes.
For the realization of contests, calls, events related to the Company's products and other activities that require the participation of the client to be carried out, ROSA INÉS CUARTAS will collect and store data for the delivery of the respective prizes in each one. of the events held.
Carry out the consultation to marketing and social responsibility, of the type of campaigns and contests carried out that are made to publish them.
Within our social networks, such as Facebook, Instagram, Twitter, YouTube, among others, images and videos of the people who are in our networks will be presented, as well as those people who tag the official accounts in ROSA INÉS CUARTAS networks and repost our content.

4. PERSONAL DATA PROVIDED AND METHOD OF OBTAINING

ROSA INÉS CUARTAS will obtain your personal data either because you provide them directly through calls, forms, emails, writings, conversations, shipments, electronic files or because third parties transfer and/or transmit them and additionally may collect them from your behavior in Internet pages and social networks (which you access through any device, including computers, tablets and mobile devices). In this sense, ROSA INÉS CUARTAS may expressly request the Holders, or collect from their behavior, the data that is necessary to fulfill the purpose of the Databases, which are -among others- the following:

4.1. In connection with the database of employees and contractors

Name and surname, nationality, marital status, identification number, military ID, professional card, fingerprint, handwriting, date and place of birth, marital status, signature, mailing address, contact telephone number, email, employment history, clinical or health, academic and patrimonial, references, business history or financial, judicial, disciplinary and family information with other companies or with public entities, recent photographs, images on surveillance cameras; occupational medical history; name, identification number, telephone number, sex, date and place of birth, place of work position or profession of the spouse or permanent companion of employees and contractors and of their relatives up to the fourth degree of consanguinity, second degree of affinity and/or first civil degree , and any other data that may be necessary to achieve the purposes described. Keep in mind that, due to the social security regime, sensitive data will be processed.

4.2. In relation to the databases of clients, suppliers, business partners

Name and surname, identification number, date of birth, correspondence address, contact telephone number, email, commercial, judicial, security background, commercial and family relations with other companies or with public entities, PEP, needs and interests, place work, financial data.

4.3. In relation to sensitive data and its treatment

In accordance with Law 1581 of 2012, the following are considered sensitive data: Racial or ethnic origin, political orientation, religious or philosophical convictions, membership of unions, social organizations, data related to the state of health, sexual life and biometric data. Taking into account the characteristics of ROSA INÉS CUARTAS, the activities it carries out, and the purposes described in this Policy, ROSA INÉS CUARTAS requires processing of some sensitive data, in the manner and conditions indicated below.

4.4. Sensitive information related to health status

ROSA INÉS CUARTAS will collect and process the health data of its employees and contractors. These data are of a sensitive nature, for which reason, in accordance with the provisions of current regulations, the Holders are informed that they are not obliged to provide the aforementioned data or to authorize their treatment. Once said data is provided and the corresponding consent is granted, said data will be collected and processed solely to preserve and guarantee the well-being of the holders.

4.5. biometric data

ROSA INÉS CUARTAS will collect biometric data from its employees, contractors and visitors, such as fingerprints. As in the case of information on the state of health, these data are of a sensitive nature, and therefore the Holders are not obliged to provide them. ROSA INÉS CUARTAS will guarantee that the processing of this data will be done in accordance with the law and under strict security measures.

4.6. Financial data or data related to Law 1266 of 2008.

ROSA INÉS CUARTAS, by virtue of the fulfillment of its corporate purpose, will make use of financial platforms and payment gateways for the client to carry out the corresponding transaction in accordance with their purchase.

ROSA INÉS CUARTAS WILL NOT store and process the owner's financial data such as bank account passwords; CCV, CVV number or security number of the debit or credit card; debit or credit card expiration date; among others.

However, ROSA INÉS CUARTAS, in accordance with good business practices and to establish security measures after transactions, may collect, process, use and review financial data from bank receipts in risk centers, receipts from financial institutions or receipts issued by payment gateways, after the transaction is completed.

4.7. Data related to minors

In principle and as a general rule ROSA INÉS CUARTAS does not process personal data, however, in practice this is impossible, due to different regulations and the rights of minors. ROSA INÉS CUARTAS will only use, store and process personal data of minors who exceptionally purchase a piece or good or who are children, descendants or who depend on or are in charge of the employees or contractors of ROSA INÉS CUARTAS, and which are of a public. The purpose of said treatment will be solely to plan and carry out activities related to the personal and family well-being of employees and minors. For such purposes, the company will take into account the respect and prevalence of the rights of minors, their best interest and their fundamental rights.

ROSA INÉS CUARTAS will not process the personal data of children and adolescents who wish to enter the official website of ROSA INÉS CUARTAS, our social networks and/or make use of our Company's customer service; To exercise their rights and, in particular, to make purchases, the parents or legal representatives of the minor will contact ROSA INÉS CUARTAS to resolve any request, complaint or claim, as well as attend to any request to purchase our products. or services.

5. AUTHORIZATION FOR THE COLLECTION AND PROCESSING OF PERSONAL DATA AND OTHER INFORMATION

Through the voluntary provision of any of the personal data in the manner indicated in the previous numeral, and/or the express verbal or written authorization, the Owner expressly or unequivocally authorizes ROSA INÉS CUARTAS to process their personal data and any other information that provide in accordance with this Policy and the law.

6. TREATMENT OF PERSONAL DATA STORED IN ROSA INÉS CUARTAS DATABASES

ROSA INÉS CUARTAS will only use, process and circulate the personal data and other information of the Holders for the purposes described and for the treatments authorized in this Treatment Policy or in the laws in force. In addition to what is mentioned in other clauses, the Owner expressly authorizes ROSA INÉS CUARTAS to collect, use and circulate their personal data and other information for the following purposes and in the following circumstances:

Establish communication between ROSA INÉS CUARTAS and the Holders in the development of the Company's corporate purpose, as well as for any purpose related to the purposes established in this policy, either through calls, text messages, emails and/or physical .
Audit, study and analyze the information from the Databases to design and execute administrative, labor, security and financial strategies related to the personnel of ROSA INÉS CUARTAS.
Provide the information and personal data of the Holders to the subsidiaries, affiliates or affiliates of ROSA INÉS CUARTAS, commercial allies or to other companies or persons that ROSA INÉS CUARTAS commissions to process the information and comply with the purposes described in this document. Policy and the purpose of the labor or civil relationship with the Holders.
Analyze and verify the information of the employees and collaborators of ROSA INÉS CUARTAS and of those who participate in selection processes.
Transfer, transmit and supply, free of charge or for a fee, the information and personal data of the Holders to national and/or foreign business partners so that they can contact the Holders to offer them their products, information or services that in the opinion of ROSA INÉS CUARTAS may be of interest to the Holder.
Transfer, transmit and supply the information and personal data of the Holders to third parties, in those cases in which ROSA INÉS CUARTAS participates in merger, integration, spin-off and/or liquidation processes.
Verify conflicts of interest or possible irregularities in the new contractors and/or employees of ROSA INÉS CUARTAS.
Perform financial, legal, commercial and security risk rating, as well as report to credit bureaus, data credit and others, on legal, commercial and credit behavior.
Consult, store and use the financial information obtained from third-party database administrators, with prior authorization from the Owner for said consultation.
Combine personal data with information obtained from other partners or companies or send it to them to implement joint business strategies.
When the information must be disclosed to comply with laws, regulations or legal processes, to ensure compliance with the terms and conditions, to stop or prevent fraud, attacks on the security of ROSA INÉS CUARTAS or others, prevent technical problems or protect the rights of others.
Audit, study and analyze the information from the Databases to design business strategies and increase and/or improve the Products and Services offered by ROSA INÉS CUARTAS.
Audit, study, analyze and use the information from the Database to design, implement and develop programs, projects and events.
Audit, study, analyze and use the information from the Database for the socialization of policies, projects, programs, results and organizational changes.
Transmit, transfer and supply the information and personal data of the Holders to national and/or foreign strategic allies so that they contact the Holders to offer them goods and services of interest, receive offers from the holders, invite participation in programs, projects events, socialize policies, projects, programs, results and organizational changes.
Sell or assign the data to national and/or foreign third parties.
The others that are necessary to fulfill the purposes described in this Treatment Policy.

7. APPLICATION FOR AUTHORIZATION FOR NEW USES AND CHANGES IN THE POLICY.

ROSA INÉS CUARTAS may request authorization from the Holders for the use or circulation of their data or information for purposes other than those expressed in this Policy and in the Terms and Conditions, for which it will publish the changes in this Treatment Policy in its website www.rosainescuartas.com or in any means that it deems appropriate as the case may be.

In case there are substantial changes in the content of the Treatment policies, referring to the identification of the person in charge and the purpose of the Treatment of personal data, which may affect the content of the authorization, the Treatment Manager must communicate these changes to the Owner before or at the latest at the time of implementing the new policies. In addition, you must obtain a new authorization from the Owner when the change refers to the purpose of the Treatment.

8. STORAGE OF PERSONAL DATA

The Owner expressly authorizes ROSA INÉS CUARTAS to store it in the way it deems most appropriate and comply with the security required for the protection of the Owners' data.

9. AREA THAT WILL CARRY OUT THE PROCESSING OF PERSONAL DATA

The area in charge of dealing with the requests, queries and claims of the owners to exercise their rights to know, update, rectify and delete their data and revoke their authorization is the General Management of ROSA INÉS CUARTAS.

The contact details to exercise your rights as the owner of the information are found in this Policy and in any case are: info@rosainescuartas.com – cel: 3208984776

10. SECURITY MEASURES FOR THE PROTECTION OF PERSONAL DATA AND OTHER INFORMATION

The security measures that ROSA INÉS CUARTAS has in place seek to protect the data of the Holders in order to prevent its adulteration, loss, use and unauthorized access. To this end, ROSA INÉS CUARTAS diligently implements human, administrative and technical protection measures that are reasonably within its reach. The Holder expressly accepts this form of protection and declares that he considers it convenient and sufficient for all purposes.

11. RIGHTS OF HOLDERS

ROSA INÉS CUARTAS informs its owners that, in accordance with current legislation, they have the right to know, update, rectify their information, and/or revoke the authorization for their treatment. In particular, the rights of the holders as established in article 8 of Law 1581 of 2012 are:

Know, update and rectify your personal data
Request proof of authorization granted
Be informed, upon request, regarding the use that has been given to your personal data;
Submit complaints to the Superintendence of Industry and Commerce for violations of the provisions of the law
Revoke the authorization and/or request the deletion of the data
Free access to your personal data that have been processed.

Area in charge of requests, queries and claims. The area in charge of dealing with the requests, queries and claims of the owners to exercise their rights to know, update, rectify and delete their data and revoke their authorization is the Quality Area of ROSA INÉS CUARTAS.
Procedure to exercise your rights. In the event that you wish to exercise your rights, the Owner must send an email or physical mail to the contact addresses established in this Policy for the Treatment and Protection of Personal Data. The procedure that will be followed for said communications will be the following:
Petitions and Consultations on Personal Data. When the owner of the data or his successors wish to consult the information that rests in the database, ROSA INÉS CUARTAS will respond to the request within a maximum period of ten (10) business days. In compliance with the provisions of Law 1581 of 2012, when it is not possible to attend to the query within said term, the Holders will be informed, the reasons for the delay will be expressed and the date on which their query will be addressed will be indicated. , which may not exceed five (5) business days following the expiration of the first term.
Revocation of authorization, withdrawal or deletion of the Database and claims on Personal Data. When the owner of the data or his successors in title consider that the information contained in the databases must be corrected, updated or deleted, or when they notice the alleged breach of any of the duties contained in Law 1581 of 2012, they may present a claim before ROSA INÉS CUARTAS, which will be processed under the following rules:
The claim may be made by means of a request addressed to ROSA INÉS CUARTAS with the identification of the Holders, the description of the facts that give rise to the claim, the address, and the documents that they want to assert will be attached.

If the claim is incomplete, ROSA INÉS CUARTAS may require the interested party within five (5) days after receipt of the claim to correct the failures. After two (2) months from the date of the request, without the applicant submitting the required information, it will be understood that the claim has been withdrawn.

In the event that ROSA INÉS CUARTAS is not competent to resolve the claim, it will notify the appropriate person within a maximum term of two (2) business days and will inform the Holder of the situation, which will relieve it of any claim or responsibility for the use, rectification or deletion of the data.

Once the complete claim is received, a legend that says "claim in process" and the reason for it will be included in the database, within a term of no more than two (2) business days. Said legend must be maintained until the claim is decided.

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 the claim within said term, the Holder will be informed of the reasons for the delay and the date on which his claim will be addressed, which in no case may exceed eight (8) business days following the expiration of the first term. The withdrawal or deletion will not proceed when there is a contractual duty to remain in the ROSA INÉS CUARTAS database.

12. USE OF COOKIES AND DEVICE FINGERPRINTING

This authorization for the processing of personal data includes, like other websites, the use of cookies and device fingerprinting. ROSA INÉS CUARTAS uses certain technologies, such as cookies and device fingerprinting, whose purpose is to make your visit to our sites easier and more efficient, providing you with a personalized service and recognizing you when you return to our site. For the purposes of this Privacy Notice, "cookies" will be identified as the text files of information that a website transfers to the hard drive of the users' computer in order to store certain records and preferences.

Websites may allow advertising or third-party functions that send "cookies" to the owners' computers.
Cookies are only associated with an anonymous user and his or her computer, and do not provide the user's name and surname. In many cases, you will be able to browse any of the ROSA INÉS CUARTAS websites anonymously. When you access any ROSA INÉS CUARTAS website, your IP address (the Internet address of your computer) is recorded to give us an idea of which parts of the website you visit and how much time you spend in each section. We do not link your IP address to any of your personal information, unless you have registered with us and logged in using your profile.
Therefore, it is possible that in certain applications ROSA INÉS CUARTAS recognizes users after they have registered for the first time, without them having to register each time they visit to access the areas and services or products reserved exclusively for them.
In other services it will be necessary to use certain access codes, and even the use of a digital certificate, in the characteristics that are determined.
The cookies used cannot read cookie files created by other providers. ROSA INÉS CUARTAS encrypts the user's identification data for greater security.
To use the ROSA INÉS CUARTAS website, it is not necessary for the user to allow the installation of cookies sent by ROSA INÉS CUARTAS, or fingerprinting, notwithstanding that in such a case it will be necessary for the user to register in each of the services whose provision requires prior registration.
This type of mechanism, in addition to allowing a personalized experience, makes commercials and advertisements your measure.
ROSA INÉS CUARTAS will not be responsible for the transactions or operations that are carried out on other links or platforms that appear on our page, unless there is fault on the part of ROSA INÉS CUARTAS. Notwithstanding the foregoing, in order for the user to take the relevant security measures, if the user decides to select a window or link displayed on the ROSA INÉS CUARTAS website, the latter will inform the user that they are leaving its website. through a popup window.
ROSA INÉS CUARTAS has reasonable assurances on its website, however, its responsibility is limited to the information and tools contained on its page. Any event on external platforms, even if the income is generated on the ROSA INÉS CUARTAS page, is independent, autonomous, and the responsibility will be exclusive of the owner of said page or platform, unless there is fault on the part of ROSA INÉS CUARTAS. If the user comes to have doubts regarding the legality or origin of a web page, we invite him to close said page and inform us.

13. CONTACT

Any questions or additional information will be received and processed by sending them to the contact addresses established in this Policy for the Treatment and Protection of Personal Data and in any case they are: info@rosainescuartas.com - 3208984776

In order to better serve you, we advise the Holder to send a brief explanation of the claim (facts) and if possible: the evidence that supports his request (evidence) and; your request clearly and numbered.

14. VALID PERIOD OF THE DATABASE

The personal data incorporated into the Databases will be valid for the period necessary to fulfill its purposes.

15. CURRENT LAW

The current national legislation on the protection of personal data is contained in Law 1581 of 2012, Decree 1074 of 2015, the SIC Circular, Law 1266 of 2008 and the regulations that modify or complement them.

This policy will be in force from the first (1) of March of the year 2023.

VERSION	DATE OF ISSUE	APPROVED BY
1.0	03-01-2023	RIC

[1] Image taken from rimasdecolores.blogspot.com . The author is unknown.

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