1.- GENERAL PRINCIPLES AND POSTULATES.

• SPORT ENLACE SAS., hereinafter “THE COMPANY,” guarantees the protection of fundamental rights such as Habeas Data, privacy, confidentiality, good name, and image of individuals. To this end, all actions will be governed by the principles of good faith, legality, computer self-determination, freedom, and transparency
• Anyone who, in the course of any activity, including financial, commercial, and labor-related activities, whether permanent or occasional, may provide any type of information or personal data to the company, as the data controller, may access, update, and rectify it.

2.- LEGAL FRAME.

• These policies are developed and applied taking into account articles 15 and 17 of the Colombian Political Constitution, Law 1581 of 2012 and regulatory decrees 1727 of 2009, 2952 of 2010, 1377 of 2013, 886 of 2014 and 1081 of 2015, in addition to the Constitutional Court rulings C-1011 of 2008, and C-748 of 2011.

3.- DEFINITIONS.

• 3.1. Authorization:

Prior, express and informed consent of the owner to carry out the processing of personal data.

• 3.2. Database:

Organized set of personal data that is the object of processing.

• 3.3. Personal data:

Any information linked to or that can be associated with one or more specific or determinable natural persons.

• 3.4. Data controller:

A natural or legal person, public or private, who, either alone or in association with others, processes personal data on behalf of the data controller.

• 3.5. Data controller

A natural or legal person, public or private, who, either alone or in association with others, decides on the database and/or the processing of data.

• 3.6. Holder

Natural person whose personal data is being processed.

• 3.7. Processing

Any operation or set of operations on personal data, such as collection, storage, use (usage), circulation or deletion.

4.- SPECIFIC PRINCIPLES.

• 4.1. Principle of legality

In the use (usage), capture, collection, and processing of personal data, must be guaranteed the holder’s right to obtain from the COMPANY, at any time and without restrictions, information about the existence of any type of information or personal data that may be of interest to or owned by the Holder.

• 4.2. Principle of Freedom

The use (usage), capture, collection, and processing of personal data may only be carried out with the prior, express, and informed consent of the Holder. Personal data may not be obtained or disclosed without prior authorization, or in the absence of a legal statment, statutory, or judicial mandate that waives consent.

• 4.3. Principle of purpose

The use (usage), capture, collection, and processing of personal data to which THE COMPANY or its suppliers have access and which is collected and gathered will be subordinated to and serve a legitimate purpose, of which the respective owner of the personal data must be informed.

• 4.4. Principle of truthfulness or quality

The information subject to the use (usage), capture, collection and processing of personal data must be truthful, complete, accurate, up-to-date, verifiable and understandable. The processing of partial, incomplete, fragmented or misleading data is prohibited.

• 4.5. Principle of transparency

In the use (usage), capture, collection, and processing of personal data, must be guaranteed the Holder’s right to obtain from the COMPANY, at any time and without restrictions, information about the existence of any type of information or personal data that may be of interest to or owned by the Holder.

• 4.6. Principle of restricted access and circulation

Personal data, except for public information, may not be made available on the internet or other means of dissemination or mass communication, unless access is technically controllable to provide restricted knowledge only to Holders or authorized third parties. For these purposes, THE COMPANY’s obligations through its website remain the same.

• 4.7. Safety principle:

The personal data and information used, captured, collected and subject to processing by THE COMPANY will be protected to the extent that technical resources and minimum standards allow, through the adoption of technological protection measures, protocols, and all types of administrative measures that are necessary to provide security to electronic records and repositories, preventing their adulteration, modification, loss, consultation, and in general against any unauthorized use or access.

• 4.8. Confidentiality Principle:

Each and every person who administers, manages, updates, or has access to information of any kind stored in Databases or Banks undertakes to preserve and maintain it in a strictly accounting and technical manner, in the execution and performance of their duties. All persons currently employed or future employed for this purpose in the administration and management of databases must sign an additional document or other document to their employment or service provision contract to ensure this commitment. This obligation persists and is maintained even after their relationship with any of the tasks involved in Processing has ended

5.- PURPOSE OF DATA PROCESSING.

• 5.1. General part:

The processing planned by THE COMPANY for the personal data of employees, partners, allies, clients, suppliers, contractors, and other interested parties will be the collection, storage, use, and deletion of personal data for accounting, financial, commercial, marketing, and judicial purposes only, as well as for the conclusion and execution of business collaboration agreements with partners, clients, or other associates, for the conclusion of contracts with client companies, for the acquisition of goods and services necessary for the company’s operations, as well as those related to the administrative operation of the company’s facilities and other actions necessary for the company’s operation, including the guarantee of the rights of its associated individuals. The circulation of personal data will be carried out to allow contact with allied companies or individuals for purposes expressly requested and authorized by the owners, as well as for compliance with administrative or judicial orders from the State or international bodies. In any case, personal data may be processed for the following purposes:

• 5.1.1.

To link the owners, with prior consent, to marketing programs and activities and to offer the company’s products and services, including promotions, events and campaigns associated with our corporate purpose;

• 5.1.2.

Involve data subjects, with prior consent, in our continuous improvement processes, requiring their support in our service evaluation work, suggestions, or opportunities for improvement;

• 5.1.3.

Make contact with companies, allies or their representatives to coordinate activities related to our corporate purpose;

• 5.1.4.

Coordinate the delivery of goods provided by our company for any purpose, within the framework of the business collaboration concluded or as part of the delivery of gifts or souvenirs;

• 5.1.5.

Control access to the company’s offices and establish security measures, including the establishment of closed-circuit television surveillance zones;

• 5.1.6.

To generate evidence of individuals’ participation in our training, communication, advisory, meeting, video call, consulting, or any other activity in which THE COMPANY provides its services or establishes civil, labor, or commercial relationships; when they are recipients of the information we provide; as well as the collection of information required by our partners or clients within the framework of the commercial or civil relationships established with them.

• 5.1.7.

Respond promptly to inquiries, requests, complaints, and claims made by owners and administrative or judicial authorities and transmit data to the authorities that request it, in accordance with the Law and the Constitution, always exercising the duty of professional secrecy;

• 5.1.8.

For contact, for reasons of strict necessity, with people associated with the company, such as employees and their families, shareholders, customers, suppliers, creditors, and debtors, for the aforementioned purposes.

• 5.1.9.

Informing owners about changes to product and service conditions, events, promotions, and information of interest due to the relationship established with the company.

• 5.1.10.

Use the information collected for the development of operations within the company (financial, purchasing, billing, collection, portfolio, sales, logistics, judicial or administrative processes, assistance in company services, among others), thus indicating that the owner authorizes the use of data messages exchanged through electronic means of contact as judicial evidence;

• 5.1.11.

To guarantee the rights and obligations of the company’s shareholders, including dividend payments, summonses, corrections, and other elements associated with corporate obligations.

• 5.1.12.

Any other activity of a similar nature to those previously described that are necessary to develop the corporate purpose of THE COMPANY;

• 5.1.13.

Contact, requests for information, and summonses to those participating in the company’s personnel and contractor selection processes;

• 5.1.14.

Carry out the company’s Human Resources Management activities, such as payroll, salary and social benefits payments, affiliations to entities of the General Social Security System, reporting of work-related accidents and occupational diseases, investigation of work-related accidents and incidents and occupational diseases, welfare and Occupational Health and Safety activities, exercising the employer’s disciplinary authority, linking to various benefits at the employee’s discretion or necessary for service provision (such as travel, accommodation, transfers, enrollment in training programs, etc.), among others.

• 5.2. Information for partners:

The Company’s intended processing of partners’ personal data will be for the purpose of maintaining commercial, civil, and administrative relationships associated with our partners, solely for purposes related to the collaboration provided between the partner and the Company. The use of this information and contact information is required for the following purposes:

• 5.2.1.

Security and Access: Information related to passwords, accounts, policy changes, platform changes, suspicious access reporting, and other technical information for the proper, secure, and user-friendly use of the platform and the services offered. This category includes the use of data for identity validation, security verification, and access restoration.

• 5.2.2.

Services: account statements, payment information, contact requests, documentation requests, clarifications, data generated through partner collaboration, and other quick information that will help you enjoy your experience with our services.

• 5.2.3.

Commercial: Promotions, services, offers, marketing, advertising, and other information or communications aimed at offering services of interest to the partner or to learn about their experience, obtain feedback on our service, and strengthen commercial ties with the partner.

• 5.3. Cookies:

When you enter the site, it may store or retrieve information in your browser, primarily in the form of cookies. This information is necessary for the provision of the portal’s services and may relate to the person using the service, their preferences, technical browsing conditions, or the equipment used. All of this information is collected solely for the purpose of optimally providing our services and minimizing technical risks on our portal, thereby enabling us to provide our services regularly and ensuring that your browsing experience is satisfactory. Likewise, the information obtained may be used to provide you with a more personalized web experience, thus allowing our portal to identify you solely for the purpose of improving your access to our services. This information is not stored in either first-party or third-party cookies, nor in any personally identifiable information or sensitive or private data about the user. Cookies are necessary for the website to function properly and cannot be deactivated under this policy. Therefore, access to the portal will constitute tacit acceptance of this policy. However, any blocking or deactivation of cookies by the user from their browser or using any software, application, plug-in, or application designed for this purpose will not affect the provision of the service, the browsing experience, or access to the benefits of the services provided. The details of the cookies used are listed below:

COOKIE	Usage
Hotjar	Detection of a user’s first page view session, detection in data sampling, user ID association, and linking the user to each visit
Google Analytics	Analytics of data on website usage, user behavior, traffic data análisis
Cloudflare	Website security and performance

• 5.4. Consent to use media information:

In accordance with this Privacy Policy, by registering and providing the required telephone number and email address, platform users authorize the use of these information sources for the following purposes related to our services:

• 5.4.1

Verification of proper phone number registration and validation of password change or reset requests (required): Sending SMS messages to the registered mobile number and sending and receiving WhatsApp platform messages will be used for password changes or resets, as well as for validating the phone number upon registration.

• 5.4.2

Email Registration Confirmation (Required): Sending messages to the partner’s email will be used to validate the registered email address.

• 5.4.3

This (required): Sending and receiving messages to the email address registered by the partner will be used to provide and receive information related to passwords, accounts, policy changes, platform changes, suspicious access reports, and other technical information for the proper, safe, and user-friendly use of the platform and the services offered. This medium will also be used to provide information on aspects related to accounts and services, such as account statements, payment information, contact requests, documentation requests, clarifications, and other quick information that may be useful to enjoy your experience with our services.

• 5.4.4

Commercial notifications (optional): The sending and receiving of SMS messages, WhatsApp messages and emails may be used to send information about promotions, services, offers, marketing, advertising and other information or communications that tend to offer services of interest to the user or to learn about their experience, obtain feedback on our service and strengthen commercial ties with the user. These messages will only be sent when the partner authorizes it when registering or setting up the account, authorization that may be revoked at any time by the partner according to their will. The provisions of this section will not imply an absolute nature of the information received from the user and at any time the user may exercise their right to correct, rectify, retract or request deletion of the information, as well as suspend or cancel this authorization, which is understood to be canceled at the time of closing the account on the portal, to which this authorization is associated. To exercise these rights, the user may request assistance by this means or by email at [email protected], the latter having two (2) business days to respond. Likewise, the user may suspend authorizations to receive service and commercial notifications by using the channels indicated herein. SPORT ENLACE SAS, as the owner of the portal, will be responsible for ensuring effective compliance with the conditions set forth in this consent, as well as the provisions of its Terms and Conditions and Privacy Policy. In this way, SPORT ENLACE SAS and the portal ratify their commitment to respecting users’ fundamental rights to privacy, confidentiality, good name, habeas data, legitimate trust, and other related rights, which will be guaranteed to our users, allowing for a satisfactory experience on our portals.

6.- BOYS, GIRLS AND ADOLESCENTS RIGHTS.

• Respect for the prevailing rights of minors will be ensured in the processing.
• The processing of personal data of minors is prohibited, except for data that is of a public nature.

 

7.- DUTIES OF THE COMPANY AS CONTROLLER OF PERSONAL DATA.

• 7.1

Guarantee the Holder, at all times, the full and effective exercise of the right to habeas data.

• 7.2

Request and retain a copy of the respective authorization granted by the owner.

• 7.3

Properly inform the owner about the purpose of the collection and the rights to which they are entitled by virtue of the authorization granted.

• 7.4

Keep information under the necessary security conditions to prevent its alteration, loss, unauthorized or fraudulent consultation, use, or access.

• 7.5

Ensure that the information provided to the data controller is truthful, complete, accurate, up-to-date, verifiable, and understandable.

• 7.6

Update the information, promptly communicating to the data controller any new developments regarding the data previously provided and adopting any other measures necessary to ensure that the information provided remains up-to-date.

• 7.7

Correct information when it is incorrect and notify the data controller accordingly.

• 7.8

Provide the data controller, as the case may be, only with data whose processing has been previously authorized.

• 7.9

Process queries and complaints.

• 7.10

Inform the Data Processor when certain information is being disputed by the Data Subject, once the claim has been filed and the respective process has not been completed.

• 7.11

Inform the Owner, upon request, about the use given to their data.

• 7.12

Inform the data protection authority when security code violations occur and when there are risks in the management of Data Subjects’ information.

8.- NATIONAL DATABASE REGISTRY.

9.- PRIVACY NOTICE:

• 9.1. Scope and Content of the Privacy Notice:

The Privacy Notice must, at a minimum, contain the following information:

• 9.1.1.

The identity, address and contact details of the person responsible for the processing

• 9.1.2.

The type of processing to which the data will be subjected and its purpose.

• 9.1.3.

The general mechanisms established by the data controller to ensure that the data subject is aware of the information processing policy and any substantial changes to it. In all cases, the data subject must be informed how to access or consult the information processing policy.

10.- PREROGATIVES AND OTHER RIGHTS OF THE OWNERS OF THE INFORMATION

• 10.1.

To access, to know, to rectify, and to update your personal data with THE COMPANY, as the data controller.

• 10.2

By any valid means, request proof of the authorization granted to THE COMPANY, in its capacity as data controller.

• 10.3.

To receive information from THE COMPANY upon request, regarding the use it has given to your personal data.

• 10.4.

Approach the legally constituted authorities, especially the Superintendency of Industry and Commerce, and file complaints for violations of the provisions of current regulations and applicable standards, after consulting or submitting a request to the Data Controller.

• 10.5.

Modify and revoke authorization and/or request the deletion of data when the processing does not respect the constitutional and legal principles, rights, and guarantees in force.

11.- DUTIES OF THE COMPANY IN RELATION TO THE PROCESSING OF PERSONAL DATA.

12.- GUARANTEES OF THE RIGHT OF ACCESS.

13.- CONSULTATIONS.

• 13.1.

Enable electronic or other means of communication that it deems relevant.

• 13.2.

Establish simplified forms, systems, and other methods, which must be disclosed in the privacy notice.

• 13.3.

Use the customer service or complaints services that are in operation. In any case, regardless of the mechanism implemented for handling consultation requests, they will be attended to within a maximum period of ten (10) business days from the date of receipt. When it is not possible to attend to the consultation within this period, the interested party will be informed before the expiration of the 10 days, stating the reasons for the delay and indicating the date on which their consultation will be attended to, which in no case may exceed five (5) business days following the expiration of the first term.

14.- CLAIMS.

15.- IMPLEMENTATION OF PROCEDURES TO GUARANTEE THE RIGHT TO FILE CLAIMS.

• 15.1

The owner or his successors in title, upon proof of identity, or through electronic instruments that allow him to identify himself.

• 15.2

Your representative, upon accreditation of representation.

• 15.2.1.

When the request is submitted by a person other than the owner, proper proof of legal status or authority to act must be provided; if such status is not provided, the request will be deemed not submitted.

• 15.3

The request for rectification, update, or deletion must be submitted through the means enabled by THE COMPANY as indicated in the privacy notice and must contain, at a minimum, the following information:

• 15.4.

The name and address of the owner or any other means to receive the response.

• 15.5.

Documents that prove the identity or personality of your representative.

• 15.6.

A clear and precise description of the personal data in respect of which the data subject seeks to exercise any of the rights.

• 15.7.

If necessary, other elements or documents that facilitate the location of personal data.

16.- RECTIFICATION AND UPDATE OF DATA.

• THE COMPANY is obligated to rectify and update, at the data subject’s request, any information they consider should be organized in their personal data. In requests to rectify and update personal data, the data subject must indicate the corrections to be made and provide supporting documentation.
• THE COMPANY is fully free to implement mechanisms that facilitate the exercise of this right, provided they benefit the holder. Accordingly, electronic or other means deemed appropriate may be implemented.
• THE COMPANY may establish forms, systems, and other simplified methods, which must be disclosed in the privacy notice and made available to interested parties on the website.

 

17.- DELETION OF DATA.

• The owner has the right, at any time, to request THE COMPANY to delete (eliminate) his/her personal data when:

 

18.- REVOCATION OF THE AUTHORIZATION.

• Personal data Holders may revoke their consent to the processing of their personal data at any time, provided that this is not prevented by a legal or contractual provision. To this end, THE COMPANY must establish simple and free mechanisms that allow the Holder to revoke their consent, at least by the same means by which it was granted. It should be noted that there are two ways in which consent can be revoked. The first may apply to all the purposes for which consent was granted, meaning THE COMPANY must completely stop processing the Holders data; the second may apply to specific types of processing, such as for advertising or market research purposes. With the second method, partial revocation of consent, other processing purposes are safeguarded, which the controller, in accordance with the authorization granted, may carry out and with which the data subject agrees.

 

19.- INFORMATION SECURITY AND SECURITY MEASURES.

• In accordance with the security principle established in current regulations, THE COMPANY will adopt the necessary technical, human, and administrative measures to ensure the security of records, preventing their alteration, loss, unauthorized or fraudulent access, or access.

 

20.- USE AND INTERNATIONAL TRANSFER OF PERSONAL DATA AND PERSONAL INFORMATION BY THE COMPANY.

• Depending on the nature of the permanent or occasional relationships that any holders may have with THE COMPANY, all of their information may be transferred abroad, subject to applicable legal requirements. By accepting this policy, you expressly authorize the transfer of personal information. The information will be transferred for all relationships that may be established with THE COMPANY. Without prejudice to the exceptions provided by law, processing requires the prior, express, and informed authorization of the Holder, which must be obtained by any means that can be consulted and subsequently verified.

 

21.- PERSONAL DATA PROTECTION FUNCTION WITHIN THE COMPANY.

• In the event that you consider that THE COMPANY is using something contrary to that authorized and in violation of applicable laws, you may contact us through a reasoned communication addressed to SPORT ENLACE SAS, by email at [email protected] or by cell phone or WhatsApp at 3245918650.