Privacy Policy

This policy is addressed to the holders of personal information that is used and/or found in the databases of PRODUCTOS DE BELLEZA ANA MARIA S.A – PROBLEAM S.A (hereinafter PROBELAM S.A. S.A.), which acts as the party responsible for the processing of personal data.

PROBELAM S.A. guarantees the rights of its consumers, customers, employees and third parties in general and adopts the following personal information processing policy and data processing procedures

This policy is strictly binding on PROBELAM S.A., as the responsible party.

Both the person in charge and those in charge, i.e., employees, suppliers and third parties must observe and respect these policies in the performance of their duties and/or activities even after the termination of legal, commercial, labor or any other type of relationship. Likewise, they undertake to maintain confidentiality in relation to the data processed and provided.

Any breach of the obligations and policies contained in this document must be reported to: PROBELAM S.A..

If in the term of thirty (30) business days, counted from the disclosure of this policy, the Personal Data Subject has not contacted the Data Controller or processor to request the deletion of his/her personal data under the terms of Decree 1377 of 2013, the Data Controller may continue with the processing of the data contained in its databases for the purpose indicated in this information processing policy, without prejudice to the power of the Personal Data Subject to exercise his/her right at any time and request the deletion of YOUR DATA.

PROBELAM S.A., includes within its personal data processing policy the following definitions in accordance with Article 3 of the Statutory Law 1581 of 2012 and its Regulatory Decree 1377 of 2013:

• Authorization: Prior, express and informed consent of the Data Subject to carry out the Processing of personal data.
• Privacy Notice: Verbal or written communication generated by the responsible party, addressed to the holder for the processing of personal data, by which he/she is informed about the existence of the information processing policies that will be applicable, the way to access them and the purposes of the processing that are intended to be given to the personal data.
• Data Base: Organized set of personal data that is subject to Processing.
• Personal data: Any information linked or that can be associated to one or several determined or determinable natural persons.
• Public data: Data that is not semi-private, private or sensitive. Data related to the marital status of individuals, their profession or trade, and their status as merchants or public servants, among others, are considered public data. By their nature, public data may be contained, among others, in public records, public documents, official gazettes and bulletins and duly executed court rulings that are not subject to confidentiality.
• Sensitive data: Sensitive data are understood as those that affect the privacy of the Data Subject or whose improper use may generate discrimination, such as those that reveal racial or ethnic origin, political orientation, religious or philosophical convictions, membership in trade unions, social organizations, human rights organizations or those that promote the interests of any political party or that guarantee the rights and guarantees of opposition political parties, as well as data related to health, sex life, and biometric data.
• Data Processor: 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.
• Data Controller: Natural or legal person, public or private, who by himself or in association with others, decides on the database and/or the processing of the data.
• Data Subject: Natural person whose personal data is the object of processing.

PROBELAM S.A., in the development and application of its personal data processing policy will apply the following principles in accordance with Article 4 of the Statutory Law 1581 of 2012:

• Principle of legality: The processing of personal data shall be carried out in accordance with the provisions of the legal provisions governing the matter (Statutory Law 1581 of 2012 and its regulatory decree 1377 of 2013).
• Principle of purpose: The processing of personal data to which you have access and are collected, stored, purified, analyzed, updated by PROBELAM S.A., and/or by those in charge, will serve the legitimate purpose informed to the Holder.
• Principle of freedom: The processing of personal data will be carried out with the prior, express and informed consent of the Data Subject. Personal data may not be obtained or disclosed without prior authorization, or in the absence of a legal, statutory, or judicial mandate that relieves consent.
• Principle of truthfulness or quality: The information subject to processing shall be truthful, complete, accurate, updated, verifiable and understandable. The processing of partial, incomplete, fractioned or misleading data is prohibited.
• Principle of transparency: The processing of personal data shall guarantee the right of the Data Subject to obtain from PROBELAM S.A., at any time and without restrictions, information about the data concerning him/her.
• Principle of restricted access and circulation: Personal data, except for public information or information that does not require express authorization, may not be made available on the Internet or other means of mass dissemination or communication, unless access is technically controlled to provide restricted knowledge to Data Holders or authorized third parties.
• Security principle: The information subject to treatment by PROBELAM S.A., will be handled with the technical, human and administrative measures that are necessary to provide security to the records avoiding its adulteration, loss, consultation, use, unauthorized or fraudulent access.
• Principle of confidentiality: All persons involved in the processing of personal data that are not of a public nature are obliged to guarantee the confidentiality of the information even after the end of their relationship with some of the tasks involved in the processing.

For the processing of personal data, the prior and informed authorization of the Data Subject is required, which may be obtained by any means that may be consulted.

The authorization of the Holder is not required in the case of: (i) information required by a public or administrative entity in the exercise of its legal functions or by court order; (ii) data of a public nature; (iii) cases of medical or health emergency; (iv) processing of information authorized by law for historical, statistical or scientific purposes; (v) data related to the Civil Registry of Persons.

To request the authorization of the Data Subject, PROBELAM S.A., as data controller, will need to obtain at least the following information from the Data Subject: (i) name or company name, (ii) identification document or NIT, (iii) domicile, (iv) address, (v) e-mail and (vi) contact telephone numbers.

If at the time of subscription on our website through the newsletter or the “write to us” form the user clicks on the “Subscribe”, “send” or “My account” button, or similarly labeled keys, that fact will indicate the user’s express consent to this Privacy Policy”, the above taking into account that we do not have check boxes.

Additionally, throughout the purchase process at www.cosmeticosanamaria.com we will request some personal information from our customers. In compliance with Law 1581 of 2012 “Personal Data Protection Act” and Decree 1377 of 2013, the mechanisms through which we make use of these are safe and confidential, as we have the appropriate technological means to ensure that they are stored to prevent unwanted access by third parties, and in the same order we ensure the confidentiality of the same.

We will use the information submitted by our customers to process and deliver orders, to send notifications about order status, and to send information that may be useful to our customers or that they have specifically requested, including information about our products and services, unless they have informed us that they object to being contacted for these purposes.

We may share your information with third parties to assist us with any of the functions mentioned in our Privacy Policy. For example, we may use third parties to assist us with product promotion delivery, collect payment from you, ship products or outsource our customer service systems. We may exchange information with third parties for fraud protection and credit risk reduction purposes. Third parties agree to maintain the privacy policies of this document for the handling of their data.

Payments made through the Site will be processed by our online payment agent PAYCO, PAGA Y COBRA ONLINE SAS (EPAYCO). Only your information must be provided on our site. Such information must be accurate and truthful and must be kept up to date. If there are any changes to your information, you must update it through the “My Account” page on our website. Our e-commerce technology platform and our payment partner EPAYCO are PCI certified for the secure handling of credit card information. While we cannot guarantee 100% security, these systems have proven to be effective in handling sensitive information and will make it difficult for a hacker to decipher your data.

PROBELAM S.A. as responsible for the Treatment ensures that the Data Processors comply with the policies of Treatment of information in physical or electronic media, in a clear way to inform the Holders.

The information obtained with prior authorization of the Holder, will have the following purpose:

• To be contacted for the offering of products, services, offers, promotions, alliances, studies, contests, contents, as well as from related companies.
• Send product information and news.
• Conduct market research surveys.
• Evaluate the quality of products and services.
• Consider me as a candidate for future job opportunities at PROBELAM S.A..
• Identify myself as a supplier.
• To identify myself as a beneficiary of training or product demonstrations provided through agreements with other institutions.
• Conduct surveys on benefits or products received.
• Make the necessary notifications and follow-ups at the time of use and purchase of the e-commerce.

Personal data subjects shall have the following rights:

1. To know, update and rectify your personal data with respect to the data controllers or data processors.
2. Request proof of the authorization granted to the data controller except when expressly exempted as a requirement for the processing, in accordance with the provisions of Article 10 of Law 1581 of 2012;
3. Be informed by the controller or processor, upon request, regarding the use it has made of your personal data;
4. To revoke the authorization and/or request the deletion of the data when the treatment does not respect the principles, rights and constitutional and legal guarantees.
5. Access free of charge to your personal data that has been processed.
6. To be able to manage changes of your data at the moment of using the shopping cart in order to have a good result of your transaction and order delivery.

PROBELAM S.A. will make available to the Holder the data to submit the request for deletion by e-mail to servicioalcliente@cosmeticosanamaria.com or in writing at its main office located at Cra 62 # 14-75 Bogota.

As a general rule, the term of the authorizations on the use of personal data is understood to be valid during the exercise of PROBELAM S.A.’s corporate purpose.

PROBELAM S.A.’s Privacy Policy is subject to continuous improvement and enhancement, and is therefore subject to change without notice. Therefore, we recommend its periodic consultation.

Productos de Belleza Ana María S.A., is a company dedicated to the design, manufacture and marketing of products for facial and body care and makeup, which has as its purpose the permanent development of activities focused on the quality of our products, processes and services; the safety and health of our workers and the prevention of environmental pollution, thus allowing us to be an organization with high levels of effectiveness in its operations.

The top management of Productos de Belleza Ana María S.A. is responsible for directing its efforts and ensuring the necessary resources to implement and maintain the integrated management system.

The organization shall act to comply with all legal guidelines on occupational health and safety, environmental and technical product requirements defined by legislation.

All employees accept their responsibilities as defined in the Integrated Management System of Productos de Belleza Ana María S.A., in order to achieve the objectives set and create an awareness and culture of self-care, protection of colleagues, environmental conservation and quality in our products and services.

For the development of this purpose, Productos de Belleza Ana María S.A., acquires the following commitments that are embodied in these principles:

• Continuous improvement of our Integrated Management System, involving workers, suppliers, contractors, visitors and users of our services and always seeking the satisfaction of our customers and stakeholders.
• The integral protection of all our workers, controlling the possible risks generating accidents and occupational diseases, designing programs and procedures aligned with the activities of preventive and occupational medicine, hygiene and industrial safety.
• Prevent pollution by identifying, evaluating and controlling significant environmental aspects and impacts.