Personal Data Processing Policy

Effective Date: This policy is effective as of July 30, 2025.
Last Updated: July 30, 2025

In compliance with Law 1581 of 2012 and its regulatory decrees, Coloma Ltda. (hereinafter “The Company”), identified with Tax ID (NIT) 860.076.060-9, establishes this Personal Data Treatment Policy.

1. DATA CONTROLLER

Company Name: Coloma Ltda.
Tax ID (NIT): 860.076.060-9
Address: Cra 100 #25F-21, Bogotá D.C., Colombia
Contact Email: info@coloma.com.co
Responsible Department: Administration

2. PURPOSES OF DATA PROCESSING

The personal data provided to The Company will be used for the following purposes, as authorized by the data subject:

  • To address and manage your requests, questions, comments, or claims.
  • To contact the data subject via email, phone, or WhatsApp to respond to their requests.
  • To evaluate the possibility of establishing future contractual or commercial relationships.
  • To send commercial, advertising, or promotional information about our products, services, events, and news, through physical or digital means.
  • To perform statistical analysis and website usage behavior analysis to improve our services.

3. PERSONAL DATA COLLECTED

The Company may collect the following data: Full name, email address, phone number, and any other data that the data subject voluntarily provides in free-text fields. The Company does not collect sensitive data through its website.

4. RIGHTS OF THE DATA SUBJECT

As the subject of your personal data, you have the right to:

  • Know, update, and rectify your personal data.
  • Request proof of the authorization granted to The Company.
  • Be informed by The Company, upon request, regarding the use that has been made of your personal data.
  • File complaints with the Superintendence of Industry and Commerce (SIC) for violations of the law.
  • Revoke the authorization and/or request the deletion of your data when the principles, rights, and legal guarantees are not respected in the processing.
  • Access your personal data that has been processed, free of charge.

5. PROCEDURE TO EXERCISE YOUR RIGHTS

To exercise any of your rights, the data subject must send a formal request to the email info@coloma.com.co with the subject line “Habeas Data – [Your type of request]”. The request must contain at least:

  • Full name and identification number of the data subject.
  • A clear description of the inquiry or complaint.
  • Contact information to receive a response.

Response Times:

  • Inquiries: Will be addressed within a maximum term of ten (10) business days.
  • Complaints: Will be addressed within a maximum term of fifteen (15) business days.

6. DATA TRANSFER AND TRANSMISSION

The Company will not sell or transfer your personal data to third parties without your authorization. However, we may share your information with service providers (data processors) who assist us in our operations, such as web hosting providers, email marketing platforms, and data analytics services, who are obligated to maintain the confidentiality and security of the information.

7. SECURITY AND RETENTION MEASURES

The Company implements the necessary technical, human, and administrative measures to protect your data. The data will be retained for the time necessary to fulfill the purposes for which it was collected or to comply with legal obligations.

8. CHANGES TO THE POLICY

The Company reserves the right to modify this policy. Any changes will be timely informed through their publication on our website.