Treatment of personal data
We respect your privacy and are committed to protecting it through our compliance with this privacy policy (“Policy”). This Policy describes the types of information we may collect from you or that you may provide (“Personal Information”) on the broers.com.co website, or any of its owned or affiliated websites, (“Website” or “Service”) and any of its related products and services (collectively, “Services”), and our practices for collecting, using, maintaining, protecting and disclosing that Personal Information. It also describes the choices you have regarding our use of your Personal Information and how you can access and update your Personal Information.
This Policy is a legally binding agreement between you (“User”, “you”, “you” or “your”) and the operator of this website (“Operator”, “we”, “us”, “us” or “our”). If you are entering into this agreement on behalf of a company or other legal entity, you represent that you have the authority to bind such entity to this agreement, in which case the terms “User”, “you” or “your” shall refer to such entity. If you do not have such authority, or if you do not agree to the terms of this agreement, you must not accept this agreement and you may not access and use the Website and the Services. By accessing and using the Website and Services, you acknowledge that you have read, understand and agree to the terms of this Policy. This Policy does not apply to the practices of companies we do not own or control, or to persons we do not employ or manage.
Identification of the data controller
Broers SAS, with NIT 901820696-2, is responsible for the processing of personal data collected through this website.
Personal data collection
You can access and use the website and services without telling us who you are or revealing any information that would identify you as a specific, identifiable individual. However, if you wish to use some of the features offered on the website, you may be asked to provide certain personal information (e.g., your name and email address).
We receive and store any information that you knowingly provide to us when you create an account or fill out any forms on the website. Where necessary, this information may include contact information (such as email address, phone number, etc.).
You may choose not to provide us with your personal information, but in that case you may not be able to take advantage of some of the website’s features. Users who are not sure what information is required may contact us.
Children’s privacy
We do not knowingly collect any Personal Information from children under the age of 13. If you are under 13, please do not submit any Personal Information through the Website and Services. If you have reason to believe that a child under the age of 13 has provided us with Personal Information through the Website and Services, please contact us to request that we remove that child’s Personal Information from our Services.
We encourage parents and legal guardians to monitor their children’s use of the Internet and to help enforce this Policy by instructing their children never to provide Personal Information through the Website and Services without their permission. We also ask all parents and legal guardians who supervise the care of children to take reasonable precautions to ensure that their children are instructed never to provide Personal Data when online without their permission.
Use and processing of the information collected
We act as data controllers and data processors when we process Personal Information, unless we have entered into a data processing agreement with you, in which case you would be the data controller and we would be the data processor.
Our role may also vary depending on the specific situation involving Personal Information. We act as a data controller when we ask you to provide us with Personal Information necessary to ensure your access to and use of the Website and Services. In such cases, we are a data controller because we determine the purposes and means of the processing of Personal Information.
We act as a data processor in situations where you submit Personal Information through the Website and Services. We do not own, control or make decisions about Personal Information submitted, and such Personal Information is processed solely in accordance with your instructions. In such cases, the user providing the Personal Information acts as the data controller.
In order to make the Website and Services available to you, or to comply with a legal obligation, we may need to collect and use certain Personal Information. If you do not provide the information we request, we may not be able to provide you with the requested products or services. Any information we collect from you may be used for the following purposes:
– Send administrative information
– Send product and service updates
– Solicit user feedback
– Improve the user experience
– Manage and operate the Website and Services
The processing of your Personal Data depends on how you interact with the Website and the Services, where in the world you are located and whether any of the following circumstances apply (i) you have given your consent for one or more specified purposes; (ii) the provision of information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereunder; (iii) the processing is necessary for compliance with a legal obligation to which you are subject; (iv) the processing is in connection with a task carried out in the public interest or in the exercise of official authority vested in us; (v) the processing is necessary for the purposes of legitimate interests pursued by us or a third party.
Please note that, under some legislation, we may be allowed to process information until you object to such processing by opting out, without having to rely on consent or any other legal basis. In any case, we will be happy to clarify the specific legal basis that applies to the processing and, in particular, whether the provision of personal information is a legal or contractual requirement, or a necessary requirement to enter into a contract.
Legitimacy for the processing of personal data
The collection and processing of personal data by Broers SAS is carried out with due legal legitimacy, in compliance with the following rules of the Republic of Colombia:
- Political Constitution of Colombia
- Law 1581 of 2012, which establishes general provisions for the protection of personal data.
- Decree 1377 of 2013, which partially regulates Law 1581 of 2012.
- Complementary and amending standards
Information management
You may delete certain Personal Information we have about you. The Personal Information you may delete may change as the Website and Services change. However, when you delete Personal Information, we may retain a copy of the unrevised Personal Information in our records for as long as necessary to fulfill our obligations to our affiliates and partners, and for the purposes described below. If you wish to delete your Personal Information or permanently delete your account, you may do so by contacting us.
Disclosure of information
Depending on the Services requested or as necessary to complete any transaction or provide any Service you have requested, we may share your information with our affiliates, contracted companies and service providers (collectively, “Service Providers”) that we rely on to assist in the operation of the Website and the Services available to you and whose privacy policies are consistent with ours or who agree to comply with our policies regarding Personal Information. We will not share any personally identifiable information with third parties and will not share any information with unaffiliated third parties.
Service providers are not authorized to use or disclose your information except as necessary to perform services on our behalf or comply with legal requirements. Service providers receive the information they need only to perform the functions entrusted to them, and we do not authorize them to use or disclose the information provided for their own marketing or other purposes.
Preservation of information
We will retain and use your Personal Information for the period necessary to comply with our legal obligations, for as long as your user account remains active, to enforce our agreements, resolve disputes and unless a longer retention period is required or permitted by law.
We may use any aggregate data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that personally identifies you. Once the retention period expires, the Personal Information will be deleted. Therefore, the right of access, the right of suppression, the right of rectification and the right of data portability will not be enforceable after the expiration of the retention period.
Cookies
Our website and services use “cookies” to help personalize your online experience. A cookie is a text file that is placed on your hard drive by a Web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.
We may use cookies to collect, store and track information for security and customization purposes, as well as for statistical purposes. Please note that you can accept or decline cookies. Most browsers automatically accept cookies by default, but you can usually modify your browser setting to decline cookies if you prefer.
Do Not Track Signs
Some browsers incorporate a “Do Not Track” feature that tells websites you visit that you do not want your online activity tracked. Tracking is not the same as using or collecting information in connection with a website. For these purposes, tracking refers to the collection of personally identifiable information from consumers who use or visit a website or online service as they move through different websites over time. The way in which browsers communicate the “Do Not Track” signal is not yet uniform. As a result, the website and services are not yet configured to interpret or respond to “Do Not Track” signals communicated by your browser. Even so, as described in more detail throughout this Policy, we limit our use and collection of your Personal Information. For a description of Do Not Track protocols for browsers and mobile devices, or to learn more about the choices available to you, please visit internetcookies.com.
Characteristics of social networks
Our website and services may include social media features, such as Facebook and Twitter buttons, Share buttons, etc. (“social media features”). These social media features may collect your IP address, the page you are visiting on our website and our services, and may set a cookie to enable the social media features to function properly. Social Media features are either hosted by their respective providers or hosted directly on our website and services. Your interactions with these Social Media are governed by the privacy policy of their respective providers.
E-mail marketing
We offer electronic newsletters to which you may voluntarily subscribe at any time. We are committed to maintaining the confidentiality of your e-mail address and will not disclose it to third parties, except as permitted in the section on use and treatment of information. We will maintain the information sent by e-mail in accordance with applicable laws and regulations.
In compliance with the CAN-SPAM Act, all emails sent by us will clearly indicate from whom the email originated and provide clear information on how to contact the sender. You may opt out of receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or by contacting us. However, you will continue to receive essential transactional emails.
Push notifications
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We offer push notifications to which you can also voluntarily subscribe at any time. To ensure that push notifications reach the correct devices, we rely on a unique device token for your device that is issued by your device’s operating system. While it is possible to access a list of device tokens, they will not reveal to us your identity, your device’s unique device identifier or your contact information. We will retain emailed information in accordance with applicable laws and regulations. If, at any time, you wish to stop receiving push notifications, simply adjust your device settings accordingly.
Links to other resources
The Website and Services contain links to other resources that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other resources or third parties. We encourage you to be aware when you leave the Website and Services and to read the privacy statements of each and every resource that may collect Personal Information.
Information security
We maintain the information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. We maintain reasonable administrative, technical and physical safeguards in an effort to protect against unauthorized access, use, modification and disclosure of Personal Information under our control and custody. However, transmission of data over the Internet or a wireless network cannot be guaranteed.
Therefore, while we strive to protect your Personal Information, you acknowledge that (i) there are security and privacy limitations on the Internet that are beyond our control; (ii) the security, integrity and privacy of all information and data exchanged between you and the Website and the Services cannot be guaranteed; and (iii) such information and data may be viewed or tampered with in transit by a third party, despite best efforts.
Because the security of Personal Information depends in part on the security of the device you use to communicate with us and the security you use to protect your credentials, please take appropriate steps to protect this information.
Data Breach
In the event that we become aware that the security of the Website and Services has been compromised or that Users’ Personal Data has been disclosed to unrelated third parties as a result of outside activity, including, without limitation, security attacks or fraud, we reserve the right to take reasonably appropriate action, including, without limitation, investigation and reporting, as well as notifying and cooperating with law enforcement authorities. In the event of a data breach, we will use reasonable efforts to notify affected individuals if we believe there is a reasonable risk of harm to you as a result of the breach or if notification is required by law. When we do so, we will send you an email.
Changes and modifications
We reserve the right to change this Policy or the terms relating to the Website and the Services at any time and at our discretion. When we do so, we will revise the updated date at the bottom of this page. We may also notify you in other ways at our discretion, such as through the contact information you have provided to us.
An updated version of this Policy will be effective immediately upon posting of the revised Policy, unless otherwise specified. Your continued use of the Website and Services after the effective date of the revised Policy (or any other act specified at that time) will constitute your consent to such changes. However, without your consent, we will not use your Personal Data in a manner materially different from that stated at the time it was collected.
Acceptance of this policy
You acknowledge that you have read this Policy and agree to all of its terms and conditions. By accessing and using the Website and Services and submitting your information, you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to access or use the Website and Services.
Contact
If you have any questions, concerns or complaints about this Policy, the information we have about you or if you wish to exercise your rights, we encourage you to contact us using the details below:
We will attempt to resolve complaints and disputes and will make all reasonable efforts to comply with your wish to exercise your rights as soon as possible and, in any event, within the time limits provided by applicable data protection legislation.
This document was last updated on October 29, 2024.