GENERAL PRIVACY POLICY
Delié communicates to its stakeholders the Privacy Policy, which has been adopted in compliance with the current legal regime contained in Statutory Law 1581 of 2012.

The personal data in custody of Delié, in its capacity as responsible and / or responsible according to the case, will be treated in compliance with the principles and regulations provided for in United States laws and the good practices applicable to the personal data protection regime.

The personal data held by Delié. They will be treated in accordance with the following general purposes:

For the fulfillment of the obligations and / or commitments derived from the relationships, contractual or not, existing with its stakeholders.
For compliance with legal obligations involving personal data of its stakeholders.
For commercial management and relations with its stakeholders related to the products and services it offers to the market.
To communicate to your stakeholders information about your products, services, publications, training events, commercial activities and advertising associated with your business, whether it is done directly or not.
To deploy corporate social responsibility activities to their stakeholders.
To manage the security of people, property and information assets held by the organization.
In each business process, and in accordance with the personal data collected and treatment to be carried out, the respective privacy purposes will be previously informed in the respective privacy notice; name or company name and contact details of the person in charge or person in charge of the treatment, and if the treatment is carried out by a person in charge, in which case such person will be under the direction of Delié; the rights that assist the owner and the mechanisms provided by Delié. to publicize the Privacy Policy.

Any person who is part of one of the interest groups, in their capacity as owner or legitimately authorized, in relation to the processing of their personal data, has the right to:

Exercise your right of habeas data consisting of knowing, updating, rectifying, opposing and canceling the information collected from them, in those cases where appropriate.
Evidence of the existence of the consent granted, unless there is legal authorization for the treatment.
Exercise the actions that the law recognizes in terms of protection of personal data and habeas data.
For the exercise of habeas data, the holder of the personal data or whoever demonstrates a legitimate interest as indicated in the current regulations, may do so by contacting Delié through the email: contacto@delie.com or by contacting the national attention line : at 4480750. Whoever exercises habeas data must accurately supply the requested contact information in order to process, attend to and respond to their request and display the charges for the exercise of their rights.

Seeking to fulfill the obligations acquired with its stakeholders, Delié is authorized to transfer the use of personal data to its business partners. Said transfer will always be made for collaboration purposes, that is, to communicate relevant information to the owner of the data, never for commercial use by third parties.

The processing of personal data carried out by Delié in accordance with this policy will be based on the standard, procedures and instructions adopted by this organization for compliance with the legislation applicable to the protection of personal information.

SPECIFIC PRIVACY POLICIES
I authorize my personal data to be incorporated into the Delié database and that I am aware of the privacy policy defined by Delié that is explicitly found on the initial page of this website. In the same way I manifest, under the gravity of oath, that all the data registered here are truthful, complete, exact, real and verifiable.
I authorize Delié so that through my email, text messages and / or voice, you can send me information related to promotions and any information of interest that improves the business relationship since in case Delié accepts me as a client through These means inform me of my portfolio status and payment dates and notify me of future credit information reports that are pending under the terms of Law 1266 of 2008.
Cookies use policies
In order to better understand the needs of users and provide a better service, this site uses anonymous identifiers ("cookies") to collect anonymous information about preferences and interests of its users. The information collected by this means is used to create anonymous profiles for any purpose, including, but not limited to, developing, manufacturing, and marketing products. The information obtained by this means is never combined with personal data that allows identifying a certain person (such as name, address or email address) or any information that may be considered sensitive or that may compromise the privacy of users.

Payment information security
Payments made through the Site will be processed by our online payment agent PLACE TO PAY. Such information must be accurate and truthful and must be kept up to date. If any changes occur to your data, you should update them through the "My Account" page on our website.

Our VTEX e-commerce technology platform and our payment partner PLACE TO PAY

This policy is an integral part of the document of Terms and Conditions of use of the website, which are published on the site.

INTRODUCTION
Law 1581 of 2012 developed “the constitutional right that all people have to know, update and rectify the information that has been collected about them in databases or files, and the other rights, liberties and constitutional guarantees referred to in the article 15 of the Political Constitution; as well as the right to information enshrined in article 20 of the same ”. This constitutional right known as habeas data, gives citizens the possibility of deciding and controlling the information that others have about them and, in that order of ideas, Law 1581 of 2012 establishes mechanisms and guarantees that allow the full exercise of the aforementioned right. . In compliance with the provisions of Law 1581 of 2012, Vivell SAS, as the person responsible for the treatment of personal data and sensitive personal data of interested parties, has adopted the following Information Processing Policies, to ensure that the treatment of personal data and sensitive personal data are in accordance with current legal provisions.

OBJECTIVE
Ensure the preservation and confidentiality of the information of the interested parties (Clients, Suppliers, collaborators, Contractors, Subcontractors, Partners, etc.) of the company Vivell SAS, collected for the operation of the company, in accordance with the provisions of Article 15 of the National Constitution, Law 23 of 1981, Decree 1377 of 2013 and Decree 1995 of 1999, and following the guidelines of Law 23 of 1981 and resolution 2546 of July 2, 1998.

MANDATORY
These policies are mandatory and strictly observed by all Vivell S.A.S collaborators, as well as by contractors and third parties related to the company.

All employees must know and comply with these policies in the fulfillment of their functions, (In accordance with number 1 of article 58 of the Substantive Labor Code, the worker is a special obligation "to observe the precepts of the regulations and abide by and comply with the orders and instructions given in particular by the employer or his representatives ").

In cases where there is no employment relationship, a contractual clause must be included in which the contractor agrees to comply with these policies.

DEFINITIONS
• Authorization: Prior, express and informed consent of the Owner to carry out the Processing of personal data

• Authorized: It is the Company and all the people under the responsibility of the Company that by virtue of the Authorization and this Policy, have the legitimacy to Process the Personal Data of the Owner. The Authorized includes the gender of the Authorized.

• Privacy Notice: It is the verbal or written communication generated by the Responsible, addressed to the Owner for the Treatment of your Personal Data, through which you are informed about the existence of the Information Processing policies that will be applicable, the way of accessing them and the purposes of the Treatment that is intended to be given to Personal Data.

• Database: Organized set of Personal Data that is subject to Treatment.

• Personal Data: It is any information of any kind, linked or that can be associated with one or more determined or determinable natural or legal persons.

• Public data: It is the data that is not semi-private, private or sensitive. Public data are considered, among others, data related to the civil status of people, their profession or trade and their status as a merchant or public servant. By their nature, public data may be contained, among others, in public records, public documents, gazettes and official gazettes and duly executed judicial decisions that are not subject to reservation.

• Sensitive Data: It is the Personal Data that affects the privacy of the Holder or whose improper use may generate its discrimination, such as those that reveal union affiliations, racial or ethnic origin, political orientation, religious, moral or philosophical convictions, membership of unions, social organizations, human rights or that promote the interests of any political party or that guarantee the rights and guarantees of opposition political parties, as well as data related to health, sexual life, and biometric data.

• Person in charge: It is the natural or legal person, public or private, that by itself or in association with others, carries out the Processing of Personal Data on behalf of the Responsible.

• Habilitation: It is the legitimacy that expressly and in writing by means of contract or document that does its times, grants the Company to third parties, in compliance with the applicable Law, for the Treatment of Personal Data, turning such third parties into Managers of the treatment delivered or made available.

• Consultation: Request from the data owner or the people authorized by it or by law to know the information that rests on it in databases or files.

• Manual: It is the Internal Manual of Policies and Procedures for the Protection of Personal Data of the Company, in which the policies and procedures are recorded to ensure proper compliance with the Law.

• Responsible: Any person to whom the Policy is subject to compliance with this Policy for carrying out Personal Data Processing activities within, on behalf of, on behalf of or for the Company, including but not limited to anyone who is an employee, director or , representative, contractor, agent, deputy, delegate, ambassador, shareholder, partner, external consultant, supplier and client of the company.

• Holder: It is the natural or legal person to whom the information in a Database refers and who is the subject of the right of habeas data, as the holder of the corresponding Personal Data.

• Transfer: It is the Treatment that involves the communication of Personal Data within or outside the territory of the United States when it is intended to carry out a Treatment by the Manager on behalf of the Responsible.

• Transmission: It is the Treatment activity through which Personal Data is communicated, internally or with third parties, inside or outside the territory of the United States, when said communication is intended to carry out any Treatment activity by the recipient of the Personal Data.

• Treatment: It is any operation or set of operations, electronic or not, that allow the collection, conservation, ordering, storage, modification, relationship, use, circulation, evaluation, blocking, destruction and, in general, the processing of Personal Data, as well as its transfer to third parties through communications, inquiries, interconnections, transfers, data messages.

SENSITIVE DATA
Vivell SAS prohibits its collaborators, contractors and direct or indirect third parties from disclosing data considered sensitive in the constitution and the law, such as racial or ethnic origin, political preference, union affiliation, affiliation with governmental or non-governmental social organizations, human rights organizations. , religious convictions, sexual orientation, biometric or health data, etc., which are subject to reservation and confidentiality.

The treatment of sensitive data is prohibited, with the exception of the cases explicitly indicated in article 6 of Law 1581 of 2012, that is, in cases where:

a. The Owner has given his explicit authorization to said Treatment, except in cases where the granting of said authorization is not required by law

b. The Treatment is necessary to safeguard the vital interest of the Holder and the latter is physically or legally incapacitated. In these events, legal representatives must grant their authorization

c. The Treatment is carried out in the course of legitimate activities and with the due guarantees by a foundation, NGO, association or any other non-profit organization, whose purpose is political, philosophical, religious or union, provided that they refer exclusively to its members or to people who maintain regular contacts by reason of their purpose. In these events, the data may not be provided to third parties without the authorization of the Owner

d. The Treatment refers to data that is necessary for the recognition, exercise or defense of a right in a judicial process;

e. The Treatment has a historical, statistical or scientific purpose. In this event, the measures leading to the suppression of the identity of the Holders must be adopted.

In cases where the treatment of sensitive data is possible, the following obligations must be met:

a. Inform the owner that because it is sensitive data, he is not obliged to authorize its Treatment.

b. Inform the owner explicitly and previously, in addition to the general requirements of the authorization for the collection of any type of personal data, which of the data that will be subject to Treatment are sensitive and the purpose of the Treatment, as well as obtaining their express consent .

RIGHTS OF DATA HOLDERS
Persons obliged to comply with these policies must respect and guarantee the following rights of the data holders:

a. Know, update and rectify your personal data in front of the Treatment Managers or Treatment Managers. This right may be exercised, among others, against partial, inaccurate, incomplete, fractional data that is misleading, or those whose Treatment is expressly prohibited or has not been authorized.

b. Request proof of the authorization granted to the Data Controller except when expressly excepted as a requirement for Treatment, in accordance with the provisions of article 10 of Law 1581 of 2012.

c. Be informed by the Treatment Manager or the Treatment Manager, upon request, regarding the use that has been made of your personal data.

d. Submit complaints to the Superintendence of Industry and Commerce for violations of the provisions of this law and other regulations that modify, add or complement it.

e. Revoke the authorization and / or request the deletion of the data when the Treatment does not respect the principles, rights and constitutional and legal guarantees. The revocation and / or suppression will proceed when the Superintendence of Industry and Commerce has determined that in the Treatment the Person in Charge or Person in Charge has incurred in conduct contrary to the Constitution and the law.

f. Free access to your personal data that has been processed.

PROCEDURE FOR EXERCISE OF RIGHTS BY HOLDERS
The Holders of personal data must file their queries, requests or complaints in the Customer Service Office by communicating to the email:servicioalcliente@grupovivell.com

a. Inquiries: Vivell S.A.S must respond to inquiries within ten (10) business days from the date it was received. When it is not possible to comply with this time, the interested party must be informed expressing the reasons for the delay and the date on which the consultation will be attended to within a period of no more than five (5) days.

b. Claims: The Holder or successor in title that consider that the information contained in a database should be subject to correction, updating or deletion, or when it notices the alleged breach of any of the duties contained in the law or in this Policy, may present a claim to Vivell SAS which will be processed under the following rules:

i. The claim will be formulated by means of a request addressed to the Data Controller or the Treatment Manager, by email with the identification of the Owner, the description of the facts that give rise to the claim, the address, and accompanying the documents that you want to assert. If the claim is incomplete, Vivell S.A.S. will require the interested party within five (5) days after receiving it to correct the failures. If two (2) months have elapsed since the date of the request, without the applicant submitting the required information, it will be understood that the claim has been abandoned.

ii.Once the complete claim has been received, a legend will be included in the database that says, "claim pending" and the reason for it, within a term not exceeding two (2) business days. Said legend must be kept until the claim is decided.

iii. The maximum term to attend the claim will be fifteen (15) business days from the day following the date of receipt. When it is not possible to attend the claim within said term, the interested party will be informed 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 after the expiration of the first finished.

iv. The Holder or successor in title may file a complaint with the Superintendence of Industry and Commerce, once he has exhausted the process of consultation or claim before the Responsible for Treatment or Person in Charge of Treatment.

c. Revoke of the authorization and / or suppression of the data: The Holders may at any time request Vivell S.A.S. the suppression of your personal data and / or revoke the authorization granted for the Treatment of the same, by filing a claim, in accordance with the provisions of article 15 of Law 1581 of 2012, decree 1377 of 2013 and the Procedure indicated in this Policy.

If the respective legal term has expired, Vivell S.A.S. the personal data has not been deleted, the Holder will have the right to request the Superintendence of Industry and Commerce to order the revocation of the authorization and / or the deletion of the personal data. Notwithstanding the foregoing, personal data must be kept when required to fulfill a legal or contractual obligation.

MODIFICATION
Vivell S.A.S, reserves the right to modify its policy of protection and treatment of personal data, when the circumstances or the law advise or order it; case in which the modification will be announced through the means that the company considers appropriate for the case