Privacy Policy

Last Update: 2021-12-06 00:00
Version: 2


 
 
1. Application of the Data Protection Policy 
2. Objectives 
3. Legal Framework 
4. Authorization 
5. Data that will not be subject to collection, storage, administration, use, transfer, or suppression
by RIVALO 
6. Data subject to processing by RIVALO 
6.1. Data collected electronically 
6.2. Data provided by holders 
7. Use of Information 
8. Treatment to the personal data and purpose of the treatment 4
9. Disclosure of Information 
10. Obligations 
11. Administrative structure for personal data protection and processing 6
12. Data Holders Rights 
13. Procedure for data holders to exercise their right to know, update, rectify, and suppress the
information and revoke the authorization 
14. Security 
15. Social Networks 
16. Database validity 
17. Contact information 
18. Changes to this Policy 
 
 
 
1. Application of the Data Protection Policy
This policy applies to all holders of personal information used and/or stored in RIVALO databases.
2. Objectives
This Policy has the following objectives:
a. Protect the constitutional right of all individuals to know, update, and rectify their collected data in
RIVALO databases or files, and the constitutional powers, rights, and guarantees set out in Article 15 of
the Political Constitution of Colombia, as well as the right to privacy set out in Article 20 thereof.
b. Set out the criterion about the gathering, collection, use, treatment, processing, exchange, transfer,
and transmission of personal data.
c. Set out RIVALO and its officers’ responsibilities concerning personal data processing.
3. Legal Framework
The definitions, principles, and applicable regulations set out in Law 1581 of 2012, as amended,
superseded, or supplemented govern this Policy.
Article 15 of the Political Constitutional of Colombia provides that all individuals have the right to know,
update, and rectify their personal data stored in databases or on file in public or private entities. Also, it
requires those in possession of personal data of third parties to respect the rights and guarantees set out in
the Constitution when collecting, processing, and exchanging that type of information.
Statutory Law 1581 of October 17, 2012, provides the minimum conditions for the lawful processing of
personal data of clients, employees, and any other individual. Paragraph k) of Article 18 thereto requires
those responsible for the processing of personal data to “adopt an internal handbook of policies and
procedures to guarantee the appropriate compliance with this law and in particular, for responding to
consultations and claims”.
Article 25 thereto provides that data processing policies are mandatory and that failure to comply thereto
will imply sanctions. Such policies cannot guarantee a treatment below the standard provided in Law 1581
of 2012.
RIVALO is committed to respecting and guaranteeing the rights of its clients, suppliers, employees, and in
general, of holders of personal data with whom RIVALO has had or has relations. It, therefore, adopts this
Data Protection Policy, mandatory in all the activities involving the collection, storage, use, circulation, and
transfer of such information in whole or in part.
4. Authorization
Information of which a client, consumer, or user is holder, and that is subject to collection, storage,
administration, use, transfer, or suppression by RIVALO, will require the prior and informed authorization
of its holder, which shall be obtained by any means that can be subject to further consultation.
 
 
5. Data that will not be subject to collection, storage, administration, use, transfer, or suppression by
RIVALO
Confidential information or any other information prohibited by law shall not be subject to collection,
storage, administration, use, transfer, or suppression by RIVALO.
Accordingly, RIVALO shall not collect, store, manage, use, transfer, or suppress data affecting the intimacy
of the holder or which inappropriate use may cause discrimination, such as data that reveals:
• Race or ethnic origin;
• Political orientation;
• Religious or philosophical beliefs;
• Affiliation to trade unions;
• Affiliation to social organizations;
• Affiliation to organizations promoting Human Rights or the interests of any political party, or
guaranteeing the rights and guarantees of opposition political parties;
• Health issues;
• Sex life.
6. Data subject to processing by RIVALO
The following data is subject to processing, i.e., any operation or set of operations on personal data, such
as collection, storage, use, transfer, or suppression by RIVALO:
6.1. Data collected electronically
The RIVALO website uses diverse technologies that make data usage easier, more efficient, and safer.
These technologies may imply automatic data collection by RIVALO or by third parties on its behalf.
Usually, these data do not contain personal details about the user. Examples of such technologies are
cookies, flash cookies, and web analytics.
6.2. Data provided by holders
In addition to the data collected automatically, we also process the data that you provide to us. It
includes, but is not limited to:
• Your contact information, including your name and last names, your home address, ID type and
number, your date and place of birth, your email address, and your phone number. RIVALO needs
your email address and your phone number to contact you in case RIVALO has questions or needs
to send information;
• If you have contacted customer service, the details, and records of such contact.
These data are characterized by the fact that it is you who provide the information. RIVALO will use this
information for the purposes described in this Personal Data Protection Policy. You may at all times
exercise the legal rights for such an effect.
RIVALO does not collect information of any type from underage.
 
7. Use of Information
RIVALO will use your information to provide a pleasant service experience and to communicate offers
about our services, as well as to guarantee the appropriate provision thereof.
If you contact Customer Service, we will use your personal data (including your contact history) so that
Customer Service can process your request and provide the best service possible.
If you have expressly consented so, we will send you newsletters. We may also contact you to ask for your
opinion after having provided you with our services.
If you have expressly consented to be contacted, we may contact you by mail, email, SMS, phone, or any
other electronic mean for marketing and advertising purposes and to carry out opinion surveys.
8. Treatment to the personal data and purpose of the treatment
Collected data shall be treated in a transparent, fair, and legal manner, with the main purposes of
contracting and executing the services by the person responsible for data processing, and to contact by
phone, electronically (SMS, chat, email, and other means considered as electronic), physically and/or in
person.
RIVALO may process personal data for the following purposes:
a. Carry out the actions required for the development of the pre-contractual, contractual, and postcontractual stages by RIVALO, and comply with the Colombian or foreign law and the orders issued by
legal or administrative authorities;
b. Carry out procedures (requests, claims, and complaints) and make satisfaction surveys about RIVALO’s
services;
c. Provide contact information and relevant documents to third parties with whom RIVALO has a
contractual relationship of any nature;
d. Disclose, transfer, and/or transmit personal data inside and outside the country to third parties under a
contract, law, or legal relationship requiring so, or to implement cloud-based computer services, which
require the holders’ express and unconditional authorization. The international transfer of data shall
only be done if the other country has the standards defined by the Superintendence of Industry and
Commerce (SIC) to be considered a secure data transfer;
e. Create databases for the purposes described herein;
f. Send electronic invites to campaigns and services launches (email and SMS);
g. Record calls made by data holders as support for claims and complaints.
 
In addition, to comply with the legal requirements, RIVALO may also:
a. Know the information of the holder of the data held by financial information databanks operators
referred to in Law 1266 of 2008, as amended or superseded, and provide information to them;
b. Access and consult the information of the holder of the data held or contained in databases or files of
any Private or Public entity (including but not limited to Ministries, Administrative Departments, DIAN
(Colombian Tax and Customs Administration), the Office of the Attorney General of Colombia, the
National Civil Registry of Colombia, the courts, tribunals, and High Courts), whether national,
international, or foreign.
9. Disclosure of Information
Your data will be processed confidentially. However, RIVALO reserves the right to transfer your data to
third parties with which it entered into a confidentiality agreement and the holder of the personal data
expressly consents to such transfer. Additionally, if legally required, your data will be disclosed to third
parties. If the requirement is due to corporate needs and provided that the existing law permits it, RIVALO
may transfer your data to other Colombian and foreign individuals and/or legal entities. The international
transfer will be made only and exclusively if the country receiving the personal data provides an adequate
level of data protection.
It is understood that a country provides an adequate level of data protection when it meets the standards
set by the Superintendence of Industry and Commerce (SIC) of Colombia in this regard, which in no case
shall be lower than those required by the applicable law for its recipients.
In any case, your data will not be transferred without your express and prior consent.
RIVALO may use service suppliers and data processing companies working on behalf of RIVALO. Services
may include web hosting and maintenance services, analysis services; email messaging services, delivery
services, payment transactions management, solvency and address controls, etc. These third parties are
granted access to such personal data they require to provide the relevant service. Services providers and
processing companies are contractually bound to treat information with the utmost confidentiality. They
are also contractually prohibited from using the data in any way other than required.
10. Obligations
RIVALO and any third party acting on its behalf, or even those that although not acting on RIVALO’s behalf
are in charge of processing personal data, will mandatorily and strictly comply with these policies
Both individuals responsible and persons in charge, i.e., employees, contractors, and third parties shall
observe and respect these policies while performing their duties and/or activities, even upon termination
of the legal, commercial, or employment relationship, or engagement of any other nature. Likewise, they
commit to preserving the confidentiality of the data processed.
Failure to comply with these obligations, and in general, with the policies contained in this document shall
be reported to soporte@rivalo.co.
 
11. Administrative structure for personal data protection and processing
RIVALO has an administrative infrastructure that among other functions is destined to ensure the due
processing of requirements, petitions, consultations, claims, and complaints related to data protection, to
guarantee the exercise of the Constitutional and legal rights, in particular the right to know, update, rectify,
and suppress personal information, and the right to revoke the consent granted for the processing of
personal data.
12. Data Holders Rights
In your capacity as the holder of the information you provide to us, you have the following rights:
• Freely access to your personal data subject to processing;
• Know, update, and rectify your personal data with the processing official or the person in charge of
the processing. This right may be exercised, among others, concerning partial, inaccurate,
incomplete, fractioned, and error-inducing data or data which processing is expressly prohibited or
has not been yet authorized.
• Request evidence of the authorization granted to the processing official, unless expressly
exempted as a requirement for processing according to Article 10 of Law 1581 of 2012;
• Upon request, be informed by the processing official or the person in charge of the processing
about the use given to your personal data;
• Revoke the authorization and/or request of data suppression when the processing fails to respect
the constitutional and legal principles, rights, and guarantees. Such revoking/suppression shall
come into effect when the Superintendence of Industry and Commerce has determined that the
processing officer or the person in charge of the processing has acted contrary to the Law and the
Constitution.
• Present to the Superintendence of Industry and Commerce complaints about violations to the
provisions of Law 1581, as amended, supplemented, or complemented.
To exercise these rights, you must keep in mind the following information:
1. For consultations about personal data, authorization requests, or information about the use given
to the data, you may send a written request to soporte@rivalo.co.
The consultation must contain the holder’s complete name, home address, and phone number,
and a description of the consultation.
Regardless of the mechanisms used to file consultation requests, these shall be responded to no
later than ten (10) business days after receipt. When it is not possible to respond to the
consultation within such term, the interested party shall be notified before the expiration of the
10-day term, expressing the reasons for the delay and indicating the date when the consultation
will be responded, which in no case shall exceed five (5) business days following expiration of the
first term.
 
2. For requests to correct, update, or suppress data, or presentation of claims for alleged noncompliance of RIVALO’s duties related to the data protection, you can present the request by
sending an email to soporte@rivalo.co.
The claim or request shall be submitted through a communication addressed to RIVALO, including
the holder’s complete name, home address, and contact phone number, and the description of
the facts that gave rise to the claim or request. You must attach any documents you intend to be
considered.
If the claim or request is incomplete, within five (5) business days following receipt, you will be
required to rectify the error. If after two (2) months following the date of the requirement, the
petitioner fails to submit the information, the claim shall be deemed as withdrawn.
In case the person that receives the claim is not competent to solve it, he/she shall forward it to
the competent officer in a maximum term of two (2) business days and shall inform the situation
to the petitioner. Requests to update, correct, rectify or suppress personal data shall be responded
to within fifteen (15) business days following the day after the complete claim was received. When
it is not possible to respond to the consultation within such term, the interested party shall be
notified before the expiration of the term, expressing the reasons for the delay and indicating the
date when the consultation will be responded, which in no case shall exceed eight (8) business
days following expiration of the first term.
13. Procedure for data holders to exercise their right to know, update, rectify, and suppress the information
and revoke the authorization
Articles 14, 15, and 16 of Law 1581 of 2012 set out the procedure to exercise the rights to know, update,
rectify, and suppress the information and revoke the authorization.
14. Security
RIVALO is committed to the correct use and processing of the personal data in its databases, avoiding
unauthorized access to third parties who could know or affect, modify, disclose, and/or destroy such
information.
Accordingly, it has designed and implemented security and access protocols to information systems,
storage, and processing including security risk-control physical measures.
Access to databases is restricted even for employees and collaborators. All officials are committed to
database confidentiality and appropriate handling, observing the legal guidelines on data processing.
As publicly known, no transmission through the Internet is completely safe or can be guaranteed; the user
undertakes such possible risk, which he/she accepts and knows.
 
15. Social Networks
Our website provides social connections to several social networks. When you choose to interact with a
social network, your activity on our website will also be made available to social networks such as Twitter,
Facebook, and Instagram.
If you have logged in to a social network while visiting our websites, the social network may add that
information to your profile. If you interact with social media, the information will be transferred to the
social network. If you do not wish such data transfer to take place, log out from the social network before
logging in to our website.
We cannot decide on or control this data collection and transfer through social media. For detailed
information about personal data collection and transfer, your rights, and how to set your privacy
preferences, please read the privacy policies of these social networks.
16. Database validity
The validity of the database will be a reasonable period of time necessary to meet the purposes of the data
processing, considering the provisions set out in Article 11 of Decree 1377 of 2013, observing the relevant
provisions applicable thereto, and the administrative, accounting, tax, legal, and even historical aspects of
the information.
17. Contact information
Our contact information is the following:
RIVALO
Calle 69A No. 9-47 Bogotá, D.C.
Phone: +571 7224237
Email: soporte@rivalo.co
18. Changes to this Policy
At RIVALO, we constantly review our data protection policy to ensure it is free of errors. This privacy policy
can be modified to comply with the existing provisions. Any modification shall take effect to holders
according to the legal terms.
Significant changes to the processing policies shall be timely communicated to data holders through the
company’s website and/or by email.
When the change refers to the purpose of the processing, the holder shall grant a new authorization.
Effective date and place: Bogotá, D.C., Colombia. December 6, 2021.
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