Terms & Conditions and Data Processing Policy

DATA PROCESSING POLICY

This policy governs the processing of the personal data of users of FVN GROUP SAS (owner of the website www.fvn.com.co) received through the various information collection channels, with regard to its collection, storage, management, transfer, transmission, protection and deletion. By entering their data and information, visitors and users of our Website express and grant their consent to the use of such data as described in this Privacy and Personal Data Processing Policy.

In compliance with Decree 1377 of 2013, we inform personal data subjects that FVN GROUP SAS carries out the following types of Processing on their personal data. The types of Processing listed below must be authorized by the data subjects in advance, expressly and in an informed manner:

Collecting information about the users of its Website and the customers of FVN GROUP SAS

Storing in our databases the information about the users, customers or service providers of FVN GROUP SAS for the purposes set out in these policies.

Using the information provided by users and personal data subjects for the purposes set out in this Policy.

Transferring personal data to third parties for marketing purposes and the other purposes necessary for the development of its events described in this document, including providing it to the organizers who will be in charge of delivering the service contracted by the user.

FVN GROUP SAS expressly states that the company's databases will not be sold to third parties for commercial purposes.

Protection of information:

FVN GROUP SAS is committed to protecting your privacy and guaranteeing your habeas data rights so that you can access, update, rectify and request the deletion of the personal data being managed. Therefore, we inform you that, in accordance with Law 1581 of 2012 and Decree 1377 of 2013, as a personal data subject you have the following rights:

To access, update and rectify your personal data held by FVN GROUP SAS

To request proof of the authorization granted to FVN GROUP SAS in its capacity as Data Controller/Processor.

To file complaints with the Superintendence of Industry and Commerce for violations of the provisions of Law 1581 of 2012 and Decree 1377 of 2013, once you have exhausted the inquiry or claim process with  FVN GROUP SAS.

To revoke the authorization and/or request the deletion of the data when the Processing does not respect constitutional and legal principles, rights and guarantees.

To access, free of charge, your personal data that has been subject to Processing.

Content of the Information:

In order to carry out its commercial activities and properly provide the service offered, FVN GROUP SAS will collect the information described below:

Personally identifiable information (PII), including but not limited to: first and last names, phone number, address and other types of information that make it possible to identify users. Personal information will also be requested in order to purchase the services, namely: (i) first and last names; (ii) address; (iii) email address; (iv) phone number; (v) data related to the payment method; (vi) any other information required by the event organizer for the event to run properly.

Email address for using the Website.

This information will be collected with the express consent of FVN GROUP SAS users.

Purpose and use of the information collected:

FVN GROUP SAS will collect the personal data and information of its users solely for the following purposes:

To store it in customer databases.

To ensure the effectiveness and security of the transactions carried out at FVN GROUP SAS.

To manage the Website that the user visits to explore options and/or possible promotions.

To fully comply with the services agreed upon with customers and users, in accordance with their purposes, in order to provide the services of FVN GROUP SAS.

To complement the information and, in general, carry out the activities necessary to manage the requests, complaints and claims submitted by users and third parties, and forward them to the areas responsible for issuing the corresponding responses.

To send information and commercial offers about the services of FVN GROUP SAS, as well as to carry out marketing and/or sales activities for services that FVN GROUP SAS provides or may come to provide or offer.

To prepare market studies, statistics, surveys, market trend analyses and satisfaction surveys about the services provided.

To transmit personal data to third parties for holding events, with whom contracts have been entered into for the purpose of carrying out and fulfilling the service offered through FVN GROUP SAS, for commercial, administrative and/or operational purposes.

To manage all the information necessary to comply with tax obligations and with commercial, corporate and accounting records.

To identify users when they log in to the Website.

To invoice and collect payment for the service.

To send information or messages about new products and/or services, display current advertising or promotions, banners, news about the services provided and any other information we deem appropriate.

It is expressly stated that the company's databases will not be sold to third parties for commercial purposes. All the uses established above will be carried out solely for the development of the company's corporate purpose.

The user expressly acknowledges that the commercial information collected will be used for commercial purposes, which includes sending commercial and advertising information related to the products and/or services offered by FVN GROUP SAS, which may be done through (1) emails, (b) text messages (SMS) and/or (c) phone calls (mobile phones or landlines)

Procedures:

So that you can access your personal information and exercise your rights to access, update, rectify and request the deletion of the personal data being managed, below we present the existing procedures applicable to the processing of your personal information:

INQUIRIES. In accordance with article 14 of Law 1581 of 2012, data subjects or their successors in title may consult the Data Subject's personal information held in any database. Consequently, FVN GROUP SAS has adequate mechanisms for data subjects to exercise their right of inquiry, providing them with all the information contained in the individual record or linked to the Data Subject's identification.

The right of Inquiry referred to above, as well as the other rights whose procedure is explained below, may only be exercised by the data subject or their successors in title, upon proof of their identity, or through electronic means that allow them to identify themselves, or by their representative, upon proof of representation.

Inquiry requests will be answered within a maximum of ten (10) business days from the date of receipt. When it is not possible to answer the inquiry within this period, the interested party will be informed before the 10 days expire, stating the reasons for the delay and indicating the date on which their inquiry will be answered, which in no case may exceed five (5) business days following the expiration of the first period.

CLAIMS. In accordance with article 14 of Law 1581 of 2012, the Data Subject or their successors in title who consider that the information contained in a database should be corrected, updated or deleted, or who notice an alleged breach of any of the duties contained in Law 1581 of 2012, may file a claim, which will be processed under the following rules:

The claim must be filed by the Data Subject or their representative, taking into account the provisions of article 15 of Law 1581 of 2012, using the form or forms proposed for this purpose by the Data Controller. If the claim received does not contain complete information allowing it to be processed, that is, the identification of the Data Subject, a description of the facts giving rise to the claim, the address, and the supporting documents to be submitted, the interested party will be asked, within five (5) days of its receipt, to correct the deficiencies. If two (2) months elapse from the date of the request without the claimant submitting the required information, the claim will be deemed withdrawn.

If whoever receives the claim is not competent to resolve it, they will forward it to the appropriate party within a maximum of two (2) business days and inform the interested party of the situation.

Once the complete claim is received, a note reading "claim in process" and the reason for it will be added to the database maintained by FVN GROUP SAS within no more than two (2) business days. This note must remain until the claim is resolved.

The maximum period to address the claim will be fifteen (15) business days from the day following the date of receipt. When it is not possible to address it within this period, the interested party will be informed, before that period expires, of the reasons for the delay and the date on which their claim will be addressed, which in no case may exceed eight (8) business days following the expiration of the first period.

DELETION. The data subject has the right, at any time, to request that FVN GROUP SAS delete (erase) their personal data when they consider that it is not being processed in accordance with the principles, duties and obligations set forth in Law 1581 of 2012; when it is no longer necessary or relevant for the purpose for which it was collected; or when the period necessary to fulfill the purposes for which it was collected has been exceeded.

This deletion implies the total or partial erasure of personal information, as requested by the data subject, from the records, files, databases or processing carried out by FVN GROUP SAS. However, the company may refuse to exercise this right when the data subject has a legal or contractual duty to remain in the database; when the deletion of data would hinder judicial or administrative proceedings related to tax obligations, the investigation and prosecution of crimes or the updating of administrative sanctions; or when the data is necessary to protect the legally protected interests of the data subject, to carry out an action in the public interest, or to comply with an obligation legally acquired by the data subject.

REVOCATION OF AUTHORIZATION: Personal data subjects may revoke their consent to the processing of their personal data at any time, provided that a legal provision does not prevent it. To this end, FVN GROUP SAS will establish simple, free mechanisms that allow the data subject to revoke their consent, at least through the same means by which it was granted.

There are two ways in which consent may be revoked. The first may cover all the purposes consented to, that is, FVN GROUP SAS must completely stop processing the data subject's data; the second may apply to specific types of processing, such as for advertising or market research purposes. With the second way, that is, partial revocation of consent, other processing purposes that the controller may carry out in accordance with the authorization granted, and with which the data subject agrees, remain unaffected.

Therefore, when submitting the request to revoke consent to FVN GROUP SAS, the data subject must indicate whether the revocation they intend to make is total or partial. In the second case, they must indicate which processing they do not agree with.

There will be cases in which consent cannot be revoked, because it is necessary in the relationship between the data subject and the controller for the performance of a contract or by legal provision.

Data Transfer:

The customer expressly authorizes FVN GROUP SAS to share their Personal Data with its business partners, who will develop and carry out the service chosen by the user. Likewise, the customer authorizes FVN GROUP SAS and its business partners to use the Personal Data provided in FVN GROUP SAS's own management and within the commercial alliances that FVN GROUP SAS enters into in order to generate added value. Therefore, the customer authorizes FVN GROUP SAS to retain, update, process, consult and handle such data in the ways established in this Policy. 

Minors

Our services are only available to persons who have the legal capacity to enter into contracts. Therefore, those who do not meet this condition must refrain from providing personal information to be included in our databases.

FVN GROUP SAS will not process sensitive data of minors, such data being defined by Law 1581 of 2012 as data that affects the privacy of the data subject or whose misuse may lead to discrimination, such as data revealing union membership, racial or ethnic origin, political orientation, religious, moral or philosophical beliefs, or membership in unions, social or human rights organizations, or organizations that promote the interests of any political party or that guarantee the rights and guarantees of opposition political parties.

Security

In furtherance of the security principle established in Law 1581 of 2012, FVN GROUP SAS will adopt the technical, technological, human and administrative measures necessary to provide security to the records, preventing their alteration, loss, consultation, use or unauthorized or fraudulent access.

FVN GROUP SAS will maintain mandatory security protocols for personnel with access to personal data and information systems.

Handling of Requests

To address any question, inquiry, complaint, query, claim or request for any type of information related to their personal data, particularly to exercise their rights to access, update, rectify and delete the data or revoke the authorization granted, the user must contact the administration department by phone or email at 311 7192436 or gerencia@fvn.com.co

Amendments

FVN GROUP SAS reserves the right to amend this policy at any time and without prior notice. Any amendment will take effect with respect to related third parties as of its publication on the corresponding channel.

Effective Date

This data policy takes effect as of April 7, 2018. Personal data that is stored, used or transmitted will remain in the FVN GROUP SAS database for as long as necessary for the purposes mentioned in this Policy, for which it was collected. Thus, the validity of the database is closely related to the purposes for which the personal data was collected. In this regard, the retention period or validity is subject to the Processing purposes set out herein