Version: 4

Original Date: January 11, 2018

Last Update: April 20, 2023

GENERAL INFORMATION

The term "GESTRAL" used below refers to GESTRAL SAS and includes any natural or legal person associated with the products or services that GESTRAL offers or provides, directly or indirectly, in person or by any other means. This includes, but is not limited to, products or services offered under the name of (or by) "Nicolas Raute" in the same way.“Data Subject” and “Data Subjects” refer to the natural or legal persons and their legal representatives whose personal data is processed by GESTRAL.“Affiliates” refer to clients, prospects, suppliers, strategic partners, employees, subsidiaries, affiliates, subordinates, third parties, and other associated entities.“Media” refers to GESTRAL’s digital, physical, and electronic channels, including but not limited to its website, social media platforms (Instagram, Facebook, TikTok, YouTube, Pinterest, Clubhouse, Hotmart, Xperiencify, GoPlus (Go High Level version), Twitter, Telegram, WhatsApp), email, text messages, voice messages, applications, phone calls, face-to-face interactions, and any future communication channels. It also includes third parties involved in our social, commercial, or legal relationships with our Affiliates.(For GESTRAL's Terms and Conditions policy, visit: https://nicoraute.com/terms.)This policy is defined in compliance with Colombian Law 1581 of 2012, regulated by Decrees 1377 of 2013 and 886 of 2014, and any subsequent amendments, modifications, or repeals. Additionally, it is aligned with international data protection standards, including the General Data Protection Regulation (GDPR) of the European Union and the California Consumer Privacy Act (CCPA).GESTRAL, as the data controller, acknowledges the fundamental right of all individuals to access, update, and rectify their personal information stored in databases or archives, ensuring compliance with the constitutional right to privacy and information security. As part of its legal, corporate, and ethical duty, GESTRAL has formulated this policy to effectively comply with such regulations and to address data inquiries and complaints.This policy is subject to modifications at GESTRAL’s discretion and as new regulations take effect.

GENERAL OBJECTIVE

The purpose of this policy is to ensure the confidentiality and security of personal data processed by GESTRAL while complying with Colombian Law 1581 of 2012 and the HÁBEAS DATA rights of all individuals. This guarantees that all collected data will be processed lawfully, respecting data subjects’ rights to privacy, security, and information accuracy.This policy also ensures compliance with Article 17, Section K of Law 1581 of 2012, which mandates the adoption of measures to protect personal data.

DEFINITIONS

Authorization: Prior, explicit, and informed consent granted by the data subject for the processing of their personal data.

Data Subject: A natural person whose personal data is processed by GESTRAL.

Database: A structured set of personal data.

Personal Data: Any information linked to an identified or identifiable natural person. Personal data can be public, semi-private, or private.

Processing: Any operation on personal data, including collection, storage, use, circulation, or deletion.

Data Processor: A natural or legal person, public or private, that processes personal data on behalf of the Data Controller.

Data Controller: A natural or legal person that determines the purpose and means of processing personal data.

Public Data: Information classified as public by law, including civil status records and publicly available judicial rulings.

Semi-Private Data: Data that is neither public nor strictly private, such as financial and commercial data.

Private Data: Sensitive information that is only relevant to the data subject.

Sensitive Data: Information related to racial or ethnic origin, political or religious beliefs, trade union affiliations, health data, sexual orientation, and biometric data. This data is optional and not mandatory for the data subject to provide.

Privacy Notice: A physical or electronic document informing the data subject about the existence of GESTRAL’s data processing policies and their rights.

DATA SUBJECT RIGHTS

All data subjects whose personal data is processed by GESTRAL have the following rights:

The right to access, know, consult, update, and correct their personal data stored by GESTRAL.The right to request proof of authorization for data processing.The right to be informed about how their data is used.The right to file complaints with regulatory authorities (e.g., Colombia’s Superintendence of Industry and Commerce, EU Data Protection Authorities, or the California Attorney General).The right to revoke consent and request data deletion if GESTRAL fails to comply with applicable legal requirements.The right to free access to their personal data. The right to HÁBEAS DATA, ensuring the ability to update or rectify any stored personal data.

CONTACT INFORMATION FOR DATA INQUIRIES

For any inquiries, complaints, or requests related to personal data processing, data subjects may contact GESTRAL at:

Email: legal @ gestral.com (remove spaces)

Website: https://nicoraute.com/contact

In compliance with Colombian Law 1581 of 2012, GDPR, and CCPA, responses will be provided within 10 business days, with the possibility of an extension of up to 5 additional days.