Policy for the Protection
and Treatment of
Personal Data

1. DEFINEITIONS
For the purposes of this Policy, it is understood by:

Personal data:
Any information linked or that can be associated with one or several determined or determinable natural persons.

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Public data:
That data that is not semi-private, private or sensitive. Among others, they are the data related to the marital status of people, their profession or trade and their quality as a merchant or public servant. By its nature, public data may be contained, among others, in public records and documents.

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Private data:
That data that due to its intimate or reserved nature is only relevant to the Owner.

 

Sensitive personal data:
Those data that affect the privacy of the owner or whose improper use has the potential to generate discrimination.

 

Semi-private personal data:
Those data that are not of an intimate, reserved, or public nature and whose knowledge or disclosure may be of interest not only to its owner, but also to a group of people or to society in general. In this case, the express authorization of the Owner of the information is required for its Treatment. For example: financial data, data relating to relations with social security entities.

 

Database:
Organized set of personal data that is subject to Treatment. For the purposes of this document, a Database is understood to be the one that contains information on the Personal Data of the Holders.

 

Headline:
Natural person whose personal data is subject to Treatment. For the purposes of this document, Holders are understood to be FLUVIP's employees, clients, suppliers, contractors and/or collaborators, as well as any person whose data is stored in a database that is the responsibility of FLUVIP.

 

Influencer:
Person or profile that, due to its level of followers, engagement and possibility of generating interactions on Social Networks, has a great capacity to communicate to a specific audience and, therefore, is in charge of publishing the Ads of the Advertiser's Products.

 

Employee:
Natural person who is linked by means of a labor contract to FLUVIP, or with a third-party contractor that provides services to FLUVIP.

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Customer or Advertiser:
Natural person who is linked by signing contracts to acquire FLUVIP products and/or services.

 

Providers:
Natural person who provides or supplies products and/or services to FLUVIP.

 

Contractors and/or collaborators:
Natural person who has a commercial and/or collaboration relationship with FLUVIP.

 

FLUVIP platform:
Portal www.fluvip.com that is made available to Influencers and their Advertisers so that they register there and access their Services. The Platform offers its visitors a description of the Services and gives the possibility for each Advertiser to select options that fit their needs and thus facilitate the choice of their Influencer.

 

Services:
It refers to the provision of intermediation and Influencer Marketing services by FLUVIP.

 

Influencer Marketing:
Marketing form through which promotion, marketing and advertising strategies for products, services and ideas are structured, through people and Profiles that have the elements to become potential recommenders to a specific audience.

 

Responsible for the Treatment:
Natural or legal person of a public or private nature, who, acting by herself or with others, decides on the Database and/or the Treatment of the data. For the purposes of this Policy, FLUVIP is understood as Responsible for Treatment.

 

Treatment Manager:
Natural or legal person, public or private, that by itself or in association with others, performs the Processing of personal data on behalf of the Data Controller, that is, FLUVIP.

 

Treatment:
Any operation or set of operations on Personal Data, such as collection, storage, use, circulation or deletion.

 

Transfer:
The transfer of data takes place when the Responsible for the Treatment of Personal Data sends the Personal Data to a recipient, who in turn is Responsible for the Treatment and is located inside or outside the country where they were received.

 

Transmission:
Treatment of Personal Data that implies the communication of the same, when its purpose is to carry out a Treatment by the Manager and on behalf of the Responsible.

 

2. AUTHORIZATION

The authorization of the Personal Data Holderspersonal or whoever is legitimated is an essential requirement for FLUVIP to collect, store, consult, use, process and in general, Treatment of your personal information. This authorization will be granted by the Holder in writing, orally or through unequivocal conduct of the Holder that allows a reasonable conclusion that the authorization was granted. It will be understood that the Owner has granted the authorization expressly and unequivocally when browsing, registering or using the services of the Platform. FLUVIP will take the pertinent measures to keep a copy or evidence, or to document the existence, of the authorization for future consultations.

 

The Owner's authorization will not be necessary in the case of:

Delivery of information required by a public or administrative entity in the exercise of its legal functions or by court order.
Processing of Public Data.
Cases of medical or health urgency.
Treatment of information authorized by law for historical, statistical or scientific purposes.

 

3. PERSONAL DATA

3.1. TYPES OF PERSONAL DATA COLLECTED BY FLUVIP

FLUVIP will process the Personal Data that is necessary to carry out the commercial activities inherent to its corporate purpose, as well as to maintain and strengthen commercial, contractual, consumer and labor relations with the Holders thereof.

In particular, FLUVIP will collect the following personal data, among others that may be necessary for these purposes:

 

3.1.1. INFLUENCER DATA:

General or specific identification, biometric, location data related to commercial or professional activity, personal location data related to the private activity of the person, personal data for access to FLUVIP information systems, data on tastes and/or particular interests , and any other data that may be necessary to achieve the purposes described.

 

Likewise, if the Influencers have made it public on their social networks, Fluvip will have access to data related to union membership, social, human rights, religious, and political organizations, as well as preference, identity, and sexual orientation data of the person.

 

3.1.2. DATA USED:

Name, surname, type of identification, identification number, date and place of issue, marital status, gender, signature, nationality, family and/or beneficiary data, other identification documents, place and date of birth or death, age, photographs, location data related to commercial or professional activity, personal location data related to private activity, data related to the state of health, socioeconomic data, patrimonial data, data related to economic activity, data related to employment history, data related to educational level, training and/or academic history, general data related to health insurance and pensions, personal data for access to the FLUVIP information system, judicial and/or disciplinary record data and any other data that may be necessary to achieve the described purposes.

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3.1.3. CUSTOMER DATA:

Name, surname, type of identification, identification number, date and place of issue, gender, signature, nationality, place and date of birth or death, age, location data related to commercial or professional activity, personal location data related to with private activity, socioeconomic data, tax information data, patrimonial data, data related to economic activity, and any other data that may be necessary to achieve the purposes described.

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3.1.4. SUPPLIERS, CONTRACTORS AND/OR COLLABORATORS:

Name, surname, type of identification, identification number, date and place of issue, gender, signature, nationality, place and date of birth or death, age, location data related to commercial or professional activity, personal location data related to private activity, financial data, credit and/or rights of an economic nature, socioeconomic data, tax information data, patrimonial data, data related to economic activity, and any other data that may be necessary to achieve the purposes described.

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3.2. COLLECTION FORM

The data may be explicitly provided to FLUVIP through entry or linking formats, collected personally through its employees, service providers or representatives, obtained by consulting third parties that manage Databases, or implicitly collected from group analysis operations. objective, acquisition of products or services that are offered by FLUVIP, or the behavior of the Holders such as claims, requests for information, surveys, proposals, offers, visits to FLUVIP facilities, participation in projects, programs and events, among others.

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3.3. SENSITIVE DATA

For the treatment of sensitive data, the Holders are informed that they are not obliged to provide the aforementioned data or to authorize their treatment. Once said data is supplied and the corresponding consent is granted, the data will be collected and processed solely for the purposes described in this Privacy Policy.

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3.4. COOKIES

FLUVIP uses cookies and other tools that automatically collect information from people when they use the FLUVIP Website, understanding that entering and browsing the Website is an unequivocal conduct of authorization. The type of information that can be collected in this way includes: Information on the Uniform Resource Locator (URL), information about the browser used by the Owner, details of the pages visited by the Owner, IP address, clicks, hyperlinks, name user name, profile photo, inquiries, among others.

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3.5. OTHER COLLECTION SOURCES

FLUVIP may receive personal information from the Owner through other sources such as public Databases and information from third parties to which the Owner has granted authorization to share their information.

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3.6. SCOPE

This Policy applies to the databases for which FLUVIP is responsible. Therefore, this Policy does not cover the processing by third parties of:

Information collected on pages, platforms and/or applications that are not controlled by FLUVIP.
Information collected by third-party sites whose access has been via a link on the FLUVIP Website.

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4. PURPOSES AND PROCESSING

4.1. GENERAL PURPOSES

The purposes for which FLUVIP will treat the Personal Data and, which will apply in a general way to all Holders, are:

Fulfill the corporate purpose of FLUVIP.
Manage, administer and use all the information necessary to comply with FLUVIP's legal and contractual obligations, as well as tax, commercial, corporate and accounting obligations.
Execute contracts signed with FLUVIP.
Provide support in external and internal audit processes.
Send information to government or judicial entities at the express request of the same.
Collect data for the fulfillment of the duties that as responsible for the information and personal data corresponds to FLUVIP.
Socialize policies, projects, programs and organizational changes.
Seek the satisfaction of the Holders regarding the products and services offered by FLUVIP.
Provide better benefits, products and services to the Holders.
Personalize the experience of the Holders on the FLUVIP Web Page.
Carry out processes within FLUVIP, for development or operational purposes and/or system administration.
Maintain communication with the Owner.
Respond to questions, complaints, claims or comments from the Holders.
Send commercial and/or corporate information, as well as invitations to events and/or activities that FLUVIP organizes.
The other purposes determined by the Responsible Parties in the processes of obtaining Personal Data for Treatment, in order to comply with legal and regulatory obligations, as well as FLUVIP policies.
Additionally, the specific purposes applicable to the different Holders of the FLUVIP databases are:

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4.1.1. INFLUENCERS

Identify the right Influencer for the success of the advertising campaign. The Influencer is a person or a Profile that, due to its level of followers, engagement and possibility of generating interactions on Social Networks, has a great capacity to communicate to a specific audience and is therefore in charge of publishing the Product Announcements. of the Advertiser.
Provide the Influencer Marketing service, through which promotion, marketing and advertising strategies for products, services and ideas are structured, through people and profiles that have the elements to become potential Influencers to a specific audience. This audience refers to the potential and current followers of the Influencers and, therefore, to the public to which the Products will be recommended through the Ads.

4.1.2. EMPLOYEES

Keep and manage the information of the employment relationship with the Holder.
Verify conflicts of interest in new employees of FLUVIP and its affiliates, as well as their disabilities and incompatibilities.
Keep a record of the disciplinary sanctions imposed on FLUVIP employees.
Carry out Security Studies.
Promote employee wellness activities.

4.1.3. CUSTOMERS

Send and receive messages for commercial, advertising, and/or customer service purposes.
Maintain contact with customers and potential customers to send information related to the contractual and commercial relationship.
Provide effective customer service.
Inform about change of products and/or services.
Carry out billing activities, fraud prevention and money laundering consultations, verification of personal, commercial and labor references, consultation with risk information centers or consultation of web pages and lists issued by different private entities and/or governmental, national or foreign, criminal and disciplinary records in which FLUVIP deems necessary.
Carry out collection management (written, telephone or personal), collection, control, behavior, payment habit, as well as any other related to our products, services and reporting to risk information centers.

4.1.4. SUPPLIERS, CONTRACTORS AND/OR COLLABORATORS
Make the respective payments to suppliers and maintain business relationships.
Carry out financial studies and verification in databases of credit, financial risk, financing of terrorism and money laundering.

4.2. PROCESSING OF PERSONAL DATA

FLUVIP will treat the Personal Data of the Holders to fulfill the purposes described in this Policy as applicable, to each of the Holders. Within said treatments, and including but not limited to, FLUVIP may carry out the following:

Communication with the Holders for contractual, informative or commercial purposes.
Establish communication between FLUVIP and the Holders for any purpose related to the purposes established in this policy, either through calls, text messages, emails and / or physical.
Establish communication between FLUVIP and the Holders for any purpose related to the purposes established in this policy, either through calls, text messages, emails and / or physical.
Offer or inform the Owner about FLUVIP products and/or services that may be of interest to them, as well as provide general information through emails as part of a novelty, communication, bulletin, news or Newsletter.
If applicable, use the information to process claims, complaints, suggestions regarding the services offered by FLUVIP.
Carry out or implement the acquisition or offer of products or services by FLUVIP.
Collect information about the device that is being used to view or use the Website, such as IP address or the type of Internet browser or operating system used and link it with personal information to ensure that the Website provides the best online experience .
Evaluate the use of the Web Page (anonymously and comprehensively), as well as perform statistics on the activities of the Owners, such as, for example, hours of visits, frequency with which they are visited and the website that was transferred to the Web Page , so that the experience of the Holders on the Website is personalized.
Invite and contact the Holders to participate in conferences, workshops, and any other event developed by FLUVIP.
Audit, study and analyze the information from the Databases to design business strategies and increase and/or improve the products and services offered by FLUVIP.
Provide the information and Personal Data of the Holders to the subsidiaries, affiliates or affiliates of FLUVIP, commercial allies or to other companies or persons that FLUVIP commissions to carry out the processing of the information and fulfill the purposes described in this Policy.
When the information must be disclosed to comply with laws, regulations or legal processes, to ensure compliance with the terms and conditions, to stop or prevent fraud, attacks on the security of FLUVIP or others, prevent technical problems or protect the rights of others as required by the terms and conditions or by law.
Combine Personal Data with information obtained from other partners or companies or send it to them to implement joint business strategies.
For the cases in which it applies, consult, store and use the financial information obtained from third-party database administrators, with the prior express authorization of the Owner for said consultation.
The others described in this policy or permitted by law, as well as those necessary to fulfill the purposes described in this document.

4.4. PROVISION OF PERSONAL DATA TO THIRD PARTIES

FLUVIP will only provide or give access to third parties to the personal information of the Holders when appropriate or necessary according to the purposes described in this policy.

Likewise, in the event that it is necessary to provide the Holders with third parties in charge to carry out the treatment on behalf of FLUVIP, the Holder authorizes FLUVIP to provide their information with those third parties and, among others, with:

Advertising agencies that support FLUVIP to comply and analyze the effectiveness of their products and/or services.
Third parties that must deliver to the Holder a product or service ordered, such as a postal or courier service.
To the police or government authorities in cases in which they have followed the due legal process to request that the Owner's information be shared with them.
Third parties who wish to send the Owner information about their products and services only in cases in which their prior consent has been given by the Owner.
Third-party service providers, Outsourcing companies, staff on mission or temporary.
Web analytics tool providers, such as Google.
Companies, organizations or individuals outside of FLUVIP, if it is considered that disclosing such information is necessary for legal reasons.
Other reasons that may lead us to share information with third parties may be:

Reinforce the applicable terms of use of the FLUVIP Website.
Carry out investigations of possible violations of applicable laws.
Detect, prevent and protect FLUVIP against fraud and any technical or security vulnerability.
Comply with applicable laws and regulations, and work together for any legal investigation and to comply with government requirements.
FLUVIP may likewise provide or transfer information to entities resulting from a total or partial spin-off and/or merger of the business, consolidations, change of control, reorganization or liquidation of all or part of the business. With the authorization granted to FLUVIP for the treatment of their data, the Owner expressly states that the authorization granted will continue in force in the event that FLUVIP were to merge, split or transform, for which the authorization will be understood as granted to the company resulting from the spin-off, merger or transformation.

 

5. RIGHTS OF THE HOLDER

The holders have the following rights regarding their Data: a) Know, update and rectify their Personal Data b) Request proof of the authorization granted c) Be informed, upon request, regarding the use that has been given to their Personal Data d) Submit complaints to the Competent Authority for violations of the personal data protection law, according to the applicable law) Revoke the authorization and/or request the deletion of the data f) Free access to your Personal Data that has been subject to Treatment.

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6. CONTACT DETAILS FOR QUERIES, RECTIFICATIONS AND CLAIMS

FLUVIP can be contacted at the following email: katherinebeltran@fluvip.com and at the following telephone number (57 1) 703-3229.

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7. PROCEDURE FOR CONSULTATIONS, RECTIFICATIONS AND CLAIMS

The actions that the Holders or their successors in title may present in relation to the queries, rectifications and claims that are related to the data of the Holders registered in the FLUVIP Databases are indicated below.

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7.1. INQUIRIES:
The queries and requests of the Holders or their successors in title will be attended to within a maximum term of ten (10) business days from the date of receipt thereof. When it is not possible to respond to the query within said term, the interested party will be informed at the notification address that has been included in the respective query, stating the reasons for the delay and indicating the date on which the query will be addressed, which in no case may exceed five (5) business days following the expiration of the first term. The response to the queries that the Holders or their successors submit may be delivered by any physical or electronic means.

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7.2. RECTIFICATIONS AND CLAIMS:

The Holder or his successors in title who consider that the information contained in the FLUVIP Databases must be corrected, updated or deleted, or when they notice the alleged breach of any of the duties contained in the law, may file a claim with FLUVIP So:

1. The claim will be made by means of a request addressed to the area in charge, in accordance with the provisions of Number Six of this Privacy Policy, with the identification of the Holder, the description of the facts that give rise to the claim, the address, and accompanying the documents that you want to enforce. If the claim is incomplete, the interested party will be required within five (5) days following receipt of the claim to correct the failures. After two (2) months from the date of the request, without the applicant submitting the required information, it will be understood that the claim has been withdrawn.
In the event that the person receiving the claim is not competent to resolve it, they will transfer it to the appropriate person within a maximum term of two (2) business days and inform the interested party of the situation.
2. Once the complete claim is received, a legend that says 'claim in process' and the reason for it will be included in the database, within a term of no more than two (2) business days. Said legend must be maintained until the claim is decided.
3. The maximum term to resolve the claim will be fifteen (15) business days from the day following the date of receipt. When it is not possible to address 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 following the expiration of the first term. The response to the rectifications or claims that the Holders or their successors in title present may be delivered by any physical or electronic means.

7.3. REVOCATION OF AUTHORIZATION

The Holders of the Personal Data may revoke the consent to the processing of their Personal Data at any time, as long as the legal or contractual provision does not prevent it. For this, the Holder must follow the same procedure established for Rectifications and Claims.

It should be taken into account that there are two modalities in which the revocation of consent can be given: (i) It can be for all the consented purposes, in this sense FLUVIP and/or the Treatment Managers must completely stop treating the Data of the Holder and, (ii) it can occur on certain types of treatment, such as for advertising purposes or marketing studies.

Due to the foregoing, it will be necessary for the owner, when submitting the revocation request, to indicate in it whether the revocation he intends to carry out is total or partial. In the second case, it must be indicated which Treatment the Holder is not satisfied with. In the event that the Holder does not indicate it clearly, it will be understood that the request is complete.

The mechanisms or procedure that FLUVIP establishes to deal with revocation requests may not exceed the deadlines set to deal with claims.

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7.4. PROCEDURE REQUIREMENT
The Owner or successor in title may only file a complaint with the Competent Authority once the consultation, claim or revocation of the authorization process has been exhausted before the area in charge, in accordance with the provisions of Number Six of this Privacy Policy.

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8. SECURITY MEASURES FOR THE PROTECTION OF PERSONAL DATA AND OTHER INFORMATION

FLUVIP will take reasonable precautions to keep personal information secure and to require any third party that handles or processes Personal Data on behalf of FLUVIP to do the same. Access to personal information is restricted to prevent unauthorized access, modification or improper use, and its processing will only be permitted by persons linked to FLUVIP or expressly commissioned to do so.

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9. DATABASE VALIDITY PERIOD

The Databases to which FLUVIP will treat, as well as the duly authorized Personal Data incorporated into them will be valid for the period necessary to fulfill their purposes. Once this term has expired, FLUVIP will proceed to eliminate the database or delete the data of the holders, as appropriate.

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10. INTERNATIONAL DATA TRANSFERS AND TRANSMISSIONS
 

10.1. TRANSFER

It is possible that FLUVIP has to transfer personal information of the Holders to Responsible Parties in different countries. By accepting this Policy for the Treatment of Personal Data, the Holder authorizes and gives his express consent for said Transfer, to any country or territory.

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10.2. TRANSMISSIONS
With the authorization granted by any of the means provided for this purpose, the Holder authorizes FLUVIP to carry out national and international transmissions of Personal Data to a Manager, to allow the Manager to carry out the Treatment on behalf of FLUVIP. These transmissions will not require the Owner to be informed or have additional express consent.

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11. MODIFICATIONS IN THE PERSONAL DATA PROCESSING POLICY

Any substantial change or modification of this Policy for the Processing of Personal Data will be timely communicated to the Holders by posting it on the FLUVIP Website.

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12. INFORMATION AND DATA OF MINORS

FLUVIP will only use, store and process the personal data of minors with the express consent of their parents or legal representatives. In the case of the data of minors, children or dependents of employees or collaborators, the purpose of said treatment will be to plan and carry out activities related to their personal and family well-being. For such purposes, FLUVIP will take into account the respect and prevalence of the rights of minors, their best interest and their fundamental rights.

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13. VALIDITY AND MODIFICATIONS OF THE POLICY FOR THE PROCESSING OF PERSONAL DATA

This Policy for the Processing of Personal Data is in force as of May 22, 2017. Any substantial change or modification of this Policy for the Processing of Personal Data will be timely communicated to the Holders by posting on the Website of FLUVIP.