PRIVACY AND COOKIES

PRIVACY POLICY AND PERSONAL DATA PROCESSING
Effective Date: November 2024

At Attrybe, a brand operated by CS90 S.A.S. (hereinafter, the “Controller” or “We”), we respect and protect the privacy of our customers and visitors (hereinafter, the “User” or “Data Subject”). This Privacy Policy and Personal Data Processing Policy (hereinafter, the “Policy”) describes the practices related to the collection, use, storage, processing, protection, and disclosure of personal information collected through our website www.attrybe.com (hereinafter, the “Site”), in compliance with Law 1581 of 2012 and its regulatory decrees.
By accessing, browsing, and using our Site, and/or providing your personal data, you fully accept this Policy.

1. Identification of the Data Controller

  • Corporate Name: CS90 S.A.S.
  • Tax ID (NIT): 901646472
  • Address: Medellín, Colombia.
  • Email: customerservice@attrybe.com
  • WhatsApp: +57 333 2811044
 

2. Definitions

For the purposes of this Policy, the definitions established in Article 3 of Law 1581 of 2012 are adopted:

  • Personal Data: Any information linked or that may be associated with one or more identified or identifiable natural persons.
  • Processing: Any operation or set of operations on Personal Data, such as collection, storage, use, circulation, or deletion.
  • Data Subject: A natural person whose Personal Data is subject to Processing.
  • Data Controller: A natural or legal person who decides on the database and/or the Processing of data.
  • Data Processor: A person who processes Personal Data on behalf of the Controller.

3. Purpose of Personal Data Processing

The Personal Data collected will be processed for the following purposes:

  • Order and Payment Processing: To manage, process, and ship purchase orders made through the Site.
  • Product Delivery: To deliver the purchased products to the address provided by the User.
  • Customer Service: To provide support and respond to inquiries, complaints, claims, or requests made by the User.
  • Marketing and Advertising: To send commercial communications, promotions, offers, news, and advertisements related to our products and services, provided the User has given explicit consent.
  • Analysis and Improvement: To perform statistical studies and data analysis to improve the quality of our products, services, and User experience.
  • Legal Compliance: To comply with legal and regulatory obligations and requests from competent authorities.
  • Fraud Prevention: To implement measures to detect and prevent fraudulent or unauthorized activities.

 

4. Personal Data Collected

4.1. Information Provided Directly by the User

  • Identification and Contact Data: Name, ID number, address, email, phone number.
  • Payment Information: Data necessary for payment processing, which is securely managed through Bold Commerce and Mercado Pago. CS90 S.A.S. does not store sensitive information such as credit card numbers or security codes.
  • Preferences and Purchase Habits: Voluntarily provided information regarding shopping preferences, survey responses, comments, and opinions, as well as interactions on the website.

4.2. Automatically Collected Information

  • Browsing Data: IP address, device type, operating system, browser type, visited pages, time spent, and other data collected through cookies and similar technologies (see Section 10 on Cookies).

 

5. Processing of Personal Data

The Processing of Personal Data will be carried out in accordance with the principles established in Law 1581 of 2012, including legality, purpose, freedom, accuracy, transparency, restricted access and circulation, security, and confidentiality.

6. Rights of the Data Subjects

In accordance with Article 8 of Law 1581 of 2012, the Data Subject has the following rights:

  • Access: To know, update, and rectify their Personal Data with the Controller or Processor.
  • Rectify: To request the correction of inaccurate, incomplete, or outdated data.
  • Delete: To request the deletion of their Personal Data when it is not being processed in accordance with legal principles and obligations.
  • Revoke: To revoke the consent granted for the Processing of their Personal Data.
  • Proof of Authorization: To request proof of the authorization granted, except in cases exempted by law.
  • Complaints to the SIC: To file complaints with the Superintendency of Industry and Commerce for violations of Law 1581 of 2012.

 

7. Procedure to Exercise Rights

The Data Subject may exercise their rights by sending a written request via email to customerservice@attrybe.com or via WhatsApp at +57 333 2811044. The request must include:

  • Full name and contact information of the Data Subject.
  • A clear and precise description of the Personal Data for which the right is being exercised.
  • For rectification or deletion requests, specify the corrections to be made and provide supporting documentation.

CS90 S.A.S. will respond within ten (10) business days. If a response is not possible within this timeframe, the Data Subject will be informed of the delay and the reasons for it, along with the date by which their request will be addressed, which will not exceed five (5) additional business days.

8. Duties of the Data Controller

CS90 S.A.S., as the Data Controller, undertakes to:

  • Guarantee the Data Subject the full and effective exercise of their rights.
  • Request and retain a copy of the authorization provided by the Data Subject.
  • Clearly inform the Data Subject about the purpose of the Processing and their rights.
  • Maintain the information under secure conditions to prevent its alteration, loss, consultation, use, or unauthorized access.
  • Timely update the information, rectifying Personal Data when appropriate.
  • Provide the Data Processor only with the Personal Data that has been previously authorized for Processing.
  • Require the Data Processor to respect the conditions of security and privacy of the Data Subject’s information.

 

9. Security Measures

We implement the necessary technical, human, and administrative measures to protect Personal Data against unauthorized access, loss, misuse, disclosure, alteration, and destruction. However, the User acknowledges that Internet security measures are not infallible.

10. Transfer and Transmission of Personal Data

CS90 S.A.S. may transfer or transmit Personal Data to third countries or entities, including Data Processors, provided that:

  • Authorization from the Data Subject is obtained.
  • The transfer is carried out with affiliated or allied companies that ensure adequate levels of Personal Data protection.
  • It is necessary to fulfill the purposes described herein.

Data Processors:

  • Bold Commerce: For secure payment processing. Privacy policy available at: https://bold.co/legal/privacy
  • Mercado Pago: For secure payment processing. Privacy policy available at: https://www.mercadopago.com.co/ayuda/2746
  • Analytics and Advertising Services: Such as Google Analytics and other similar tools, for analysis and service improvement purposes.

 

11. Use of Cookies and Similar Technologies

11.1. What Are Cookies?

Cookies are small text files stored on your device (computer, tablet, smartphone) when you visit our Website. Cookies allow us to recognize your device, improve the Website’s functionality, and provide a personalized experience.

11.2. Types of Cookies Used

  • Essential Cookies:
    • Functionality: Necessary for the basic operation of the Website, such as navigating pages and accessing secure areas.
    • Examples: Keeping the contents of the shopping cart, logging into your account.
  • Performance and Analytics Cookies:
    • Functionality: Collect information about how Users use the Website, helping us understand and improve its performance.
    • Examples: Most visited pages, time spent on pages, errors encountered.
  • Advertising and Marketing Cookies:
    • Functionality: Used to display relevant and personalized advertisements and to measure the effectiveness of our advertising campaigns.
    • Examples: Showing products that may interest you, avoiding repetitive ads.

 

11.3. Third-Party Cookies

 

11.4. Cookie Management and Configuration

Users can control and/or delete cookies as desired:

  • Browser Settings: You can adjust your browser settings to block or delete cookies. Refer to your browser’s help section for instructions.
  • Limitations: Disabling certain cookies may affect Website functionality and limit your experience.

 

11.5. Consent to Use Cookies

By continuing to browse our Website, you agree to the use of cookies as outlined in this Policy. If you disagree, please adjust your browser settings or refrain from using the Website.

12. Updates to the Privacy Policy

CS90 S.A.S. reserves the right to update this Policy to reflect changes in our practices. Substantial changes will be communicated to Users through the Website or via email. The date of the most recent update will be indicated at the beginning of the Policy.

13. Acceptance of the Policy

By providing your Personal Data and/or using the Website, you declare that you have read and understood this Policy and grant your express and informed consent for the Processing of your Personal Data in accordance with the terms herein.

14. Contact

For exercising your rights as a Data Subject, submitting inquiries, requests, or complaints related to your Personal Data or this Policy, please contact us via:

 

CS90 S.A.S. appreciates your trust and is committed to protecting your privacy and Personal Data.

COOKIE POLICY

1. What Are Cookies?

Cookies are small text files stored on your device (computer, tablet, smartphone) when you visit our Website. Cookies allow us to recognize your device, improve the Website’s functionality, and provide a personalized experience.

2. Types of Cookies Used

2.1. Essential Cookies

  • Functionality: Enable the basic operation of the Website, such as navigating pages and accessing secure areas.
  • Examples: Maintaining the contents of the shopping cart, logging into your account.

 

2.2. Performance and Analytics Cookies

  • Functionality: Collect information about how Users interact with the Website to understand and improve its performance.
  • Examples: Most visited pages, time spent on pages, error reporting.

 

2.3. Advertising and Marketing Cookies

  • Functionality: Used to display relevant and personalized ads and measure the effectiveness of our advertising campaigns.
  • Examples: Showing products of interest to you, avoiding repetitive ads.

 

3. Third-Party Cookies

3.1. Payment Gateways

3.2. Analytics Tools

  • Google Analytics: We use Google Analytics to collect information about Website usage and improve our services.
  • Privacy Policy of Google Analytics: https://policies.google.com/privacy

 

4. Cookie Management and Configuration

Users can control and/or delete cookies as desired:

  • Browser Settings: You can adjust your browser settings to block or delete cookies. Refer to your browser’s help section for instructions.
  • Limitations: Disabling certain cookies may affect Website functionality and limit your experience.

 

5. Consent to Use Cookies

By continuing to browse our Website, you agree to the use of cookies as outlined in this Policy. If you disagree, we ask you to adjust your browser settings or refrain from using the Website.

6. Updates to the Cookie Policy

CS90 S.A.S. may update this Cookie Policy to reflect changes in our practices. We recommend reviewing this section periodically to stay informed about how we use cookies.

7. Contact

If you have any questions or concerns about our Cookie Policy, you can contact us via:

 

CS90 S.A.S. is committed to transparency and respecting your privacy while using our Website.

 

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