Privacy Policy XIRELLA

1. WHO IS RESPONSIBLE FOR THE PROTECTION OF YOUR PERSONAL INFORMATION
Main address: CALLE 13 # 32-98 ACOPI YUMBO – VALLE DEL CAUCA
E-mail: system@COLHUELLAS.com
Website: http://www.COLHUELLAS.com
Telephone: 6959212
Fax: 6901188

For further legal information, please refer to Law 1581 of 2012 and Decree 1377 of 2013.

This Personal Data Protection Policy applies from 1 October 2016.

2. WHAT PERSONAL DATA ARE COLLECTED
All of our activities are based on strict ethical principles and we are committed to providing a good level of privacy protection for all visitors to our website and (mobile) applications. For this reason, how we collect and store information depends on how our website and related services are used.
To register for XIRELLA, simply enter your email address, a password
BY AUTOMATIC MEANS
Several technologies are used on our website to make them easier to use, more efficient and safer. These technologies may involve the automatic collection of data, both by us and by third parties on our behalf. Generally, this data does not contain personal details

2.1.1 NAVIGATION DATA (CLICK-STREAM DATA)
When you visit one of our websites some data is transmitted from your browser to our server and collected and stored by us or by third parties on our behalf. These data may include in particular:
• the IP address of the visitor
• date and time of visit
• the URL of the site from which the visitor comes
• pages visited on our website
• information about the browser used (browser type and version, operating system, etc.)

2.1.2 COOKIES
Various places on our website use so-called cookies. They are essentially small text files that your browser stores on the hard drive of your computer or your user device. We may use cookies to identify the holder of a user account and to store items in a shopping basket during the purchase process. In other words, cookies help make our website easier to use, more effective and safer. Normally, the cookies we use are so-called “session cookies”, which are automatically deleted at the end of the visit to the respective Website. If not, the servers allow the use of cookies, but this function can also be deactivated. However, if disabled the function will not be available.

2.1.3 WEB BEACONS Y TRACKING LINKS
Web beacons or visitor counters (also known as pixel tags or invisible GIFs) are graphic elements invisible to the user. Tracking links (tracking links) or similar technologies are a few lines of programming code and may be incorporated into our website or app (mobile). They are mainly used for statistical and analytical purposes in conjunction with cookies. This technology can also be used to track traffic patterns on websites, to check if an email has been received and opened, and to see if there has been any response.

2.1.4 WEB ANALYTICS
Web analytics (Web analytics) is the term used to define a method for collecting and evaluating the behaviour of visitors to websites and applications (mobile). It includes analysis of traffic patterns to, for example, determine the frequency of visitors to certain parts of a website or app (mobile), or to find out what information and services are of most interest to our customers. For these purposes, we mainly use navigation data (click-stream) and the techniques listed above. Web analytics are performed by Coremetrics or other subcontracted companies. More information on the processing of Web analytics by Coremetrics can be found in Section 9.

2.2 DATA PROVIDED BY YOU
In addition to the data collected automatically, we also process the data you provide to us. This includes, but is not limited to:
• Your contact information, including your first and last name, identification number (citizenship card), address (billing or delivery), date of birth and email address and phone number. We need your email address and phone number in order to contact you if we have questions or information about your order
• Other information needed to process your order, such as information about the products you have ordered, billing and delivery address, and your bank or credit card details
• If you have created an online profile

3. HOW THE COLLECTED DATA ARE USED
• We will use the information we have collected about you to provide you with a pleasant shopping experience, to process your orders and to communicate offers about our products and services.
• We will use your personal data for purposes related to your order; for example, to notify you of the status of your order or delivery. We may use your data for the purpose of assessing your solvency, for which we may use third parties.
• If you have provided us with your personal data in connection with a promotion, event, app (mobile), etc., we may send you emails and other messages related to the service you have requested.
• If you contact customer service, we will use your personal data (including your history.
If you have given your consent to be contacted, we may contact you by ordinary mail, by email, by SMS, by telephone or any other electronic means for marketing, advertising and opinion studies of COL HUELLAS S.A. This includes, for example, information related to COL HUELLAS S.A.products, e-commerce activities, special offers, promotions, as well as information on local store openings, local XIRELLA store activities or scheduled events. In order to contact you in relation to information that is of particular interest to you, we will analyze and use in combination your overall interaction with XIRELLA (such as, for example, your shopping behaviour in virtual stores, in XIRELLA physical stores, your use of loyalty programs, your product ratings and evaluations, your contact history with our customer service department, your opening results and clicks on the newsletter, your browsing behavior (web tracking), the types of newsletters you are subscribed to, your participation in promotions or events, your interactions with my coach and your use of apps (mobile)). We may provide your contact details to XIRELLA WEB for marketing, advertising and opinion research purposes. In section 5 you will find information on your rights and in particular on how you can withdraw your consent.

4. DISCLOSURE
One of our fundamental principles states that your data will be treated confidentially. We will not sell your data to third parties. If required by law, your data will be disclosed to third parties. We may use service providers and data processors working on behalf of XIRELLA. Services may include system hosting and maintenance services, analysis services, email messaging services, delivery services, payment transaction management, solvency and management controls, etc. These third parties are granted access to such personal data that they need in order to provide the relevant service. Service providers and data processors are contractually obliged to treat information with the strictest confidentiality. In addition, they are contractually prohibited from using the data in any form other than that required. Steps have been taken to ensure that our service providers and processors working on behalf of XIRELLA protect the confidentiality of your data. There may be times when we disclose non-personal data to our partners anonymously. These non-personal data include, for example, information on the number of visitors to a website or (mobile) application over a certain period of time. Generally, this information is only disclosed in a grouped form.

5. YOUR RIGHTS
If you provide us with personal data through our Websites or other channels, this is done entirely voluntarily and you consent to us using such data in accordance with the provisions of this privacy policy. If you choose not to provide the requested information, you will not be able to access certain customer benefits. In some cases, only individuals who have provided us with the necessary personal data will be able to order products, use certain services and otherwise take advantage of the activities and offers available on our Website and app (mobile). As transparency and fair play are particularly important issues for us, we offer several options depending on the specific circumstances, to help you maintain control over your data. These options may include the ability to display and edit your data online. They may also include unsubscribing from certain services or deleting user accounts or receiving information about saved data.

5.1 CANCELLATION AND OPPOSITION RIGHTS
If the emails that XIRELLA sends that contain for example a newsletter or marketing content, have the option to cancel the receipt of such emails (unsubscribe) following the relevant instructions in the corresponding email. If you do not want to continue receiving our emails, you can click on this link and we will stop sending you emails in the future.
If you do not want information about your behavior collected and evaluated on our website or (mobile) application, you may choose not to participate in the data collection for Web analytics, as described in section 9 below.
If you do not wish to receive promotional information and offers in general, including those communicated by ordinary mail, by email, by SMS, by telephone or by any other electronic means, or if you wish to withdraw your consent, can write at any time by email to admin@colhuellas.com In case we have doubts about your identity, we can ask you to identify yourself.
For other types of messages you may receive, such as maintenance announcements or administrative notifications, the receipt of these messages can only be cancelled if you delete your account, since such messages are a mandatory part of user accounts and the corresponding use of our websites and (mobile) applications. You can also delete your account by sending an email to admin@colhuellas.com.

5.2 RIGHT OF ACCESS
You have the right to be informed at all times about your personal data that is stored, about its origin and recipients, and about the purpose for which this data is stored. You can obtain information about the personal data stored using the contact details in the Contact Information section below.

5.3 RIGHT OF RECTIFICATION
You have the right to request the correction, addition, deletion or blocking of personal data that has been saved about you. We will notify you within four weeks of receiving your request if and to what extent we will grant your request. If we are unable to comply with your request for any reason, we will inform you of the reasons.

6. INFORMATION SECURITY AND DATA INTEGRITY
We take appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction or loss, alteration, use, disclosure or unauthorized access, in particular where the processing involves the transmission of data over networks or any other unlawful form of processing and misuse.

7. SOCIAL NETWORKS
Our website and (mobile) applications provide social connectors to various social networks. When you choose to interact with a social network, your activity on our Website or through (mobile) applications will also be made available to social networks such as Facebook.

If you are logged in to one of the social networks during your visit to one of our websites or apps (mobile), the social network will be able to add that information to your profile. If you interact with one of the social connectors, that information will be transferred to the social network. If you do not want that data transfer to take place, log out of your social network session before entering our websites or (mobile) applications.

It is not up to us to influence this collection and transfer of data through social connectors. Read the privacy policies of those social networks for detailed information about the collection and transfer of personal data, about the rights you have and about how to get a satisfactory privacy setting.
Facebook: https://www.facebook.com/xirella.col/
Instagram: https://www.instagram.com/xirella.col/

9. GEOLOCATION SERVICES
We offer localization services in some of our (mobile) apps, such as Google Maps. If you use those (mobile) apps, you may receive information about your actual location (such as GPS signals sent by a mobile device) or information that can be used to approximate your location. You will always be asked if the Geolocation Service can be activated and you can also object to this Geolocation Service in the respective (mobile) application.
We use the Google Maps service to help you find the nearest XIRELLA store. To facilitate this process, we upload an image from Google Maps and save the route data and map image on our server.

For more information about Google Maps and its Privacy Policy, see its privacy policy.
Google: http://www.google.com/intl/en/policies/privacy/

10. CONTACT INFORMATION
If you have any questions about the processing of your personal data or about our privacy policy, you can contact us. Our contact details are:

COL HUELLAS S.A.
Legal Department
Calle 13 # 32 – 98 Acopi
Yumbo – Valle del Cauca
Colombia
admin@colhuellas.com
Or you can call our customer service line 695 92 12

11. CHANGES TO THIS POLICY
XIRELLA is committed to respecting the fundamental principles of Data Protection and considers that the privacy policy is binding. Therefore, we periodically review our privacy policy to ensure that it is error-free, clearly visible on our website, contains all required information, is fully enforced and complies with Data Protection principles. This privacy policy may be amended from time to time to keep it consistent with the changes and opportunities offered by the Internet and in accordance with current legislation. We will not restrict the rights granted to you under this privacy policy if we do not have your express consent. Significant changes to the policy will be posted on our website with an updated version of the privacy policy.

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