DATA PROTECTION

In accordance with Law 1581 of 2012, Decree 1377 of 2013 and other regulations that may add, modify or repeal them, in a free, prior, express, voluntary, and duly informed manner The provider authorizes the company GALIA MARKET to collect, collect, store, use, circulate, suppress, process, compile, exchange, treat, update and dispose of the data that have been provided and that have been incorporated in different databases or data banks, or in electronic repositories of all kinds that the company GALIA MARKET has. The data collected may be used for a. The support of the contractual relationship, if any, established with the company GALIA MARKET. b. The provision of services related to the products and services offered. In which the USER decides to subscribe, register, consult or purchase. c. The performance of all activities related to the service and / or product, will be included in a mailing list for sending GALIA MARKET requests. d. Communicating with you about changes to the services. e. Processing your requests, administration of activities, clarifications, market research and statistics. f. Marketing and selling of our products and services. g. Notifying you about new services or products that are related to those already contracted or purchased. h. Performing any complementary or ancillary activity necessary for the provision of the Services. i. To elaborate studies and programs that are necessary to determine consumption habits. j. To fine-tune security filters and business rules in commercial transactions. k. To carry out periodic evaluations of our products and services in order to improve their quality. l. To evaluate the quality of the service we provide. To evaluate the quality of the service we provide, and in general, to comply with the obligations we have contracted with you. m. The sending, by traditional and electronic means, of technical, operational and commercial information about products and services offered by GALIA MARKET and/or its associates or suppliers, currently and in the future. n. The request for satisfaction surveys, which the USER is not obliged to answer. o. and in the development of other functions of the Company. In this sense, GALIA MARKET is expressly and unequivocally authorized to maintain and manage all your information to continue to carry out the treatment of this subject to the provisions of the Privacy Notice and the Policy of Treatment of Personal Data. If you want your information to be deleted or modified later we invite you to contact us through the email gerencia@galiamarket.com.

PRIVACY POLICY AND TREATMENT OF PERSONAL DATA GENERAL CONSIDERATIONS.

Aware of the importance of the protection and proper handling of personal information provided by the owners of the information hereinafter GALIA MARKET who acts as responsible for the information received, has designed this policy and procedures that together allow proper use of their personal data.

In accordance with the provisions of Article 15 of the Political Constitution of Colombia, which develops the fundamental right to habeas data, referring to the right of all citizens to know, update, rectify the personal data that exist on it in databases and files in both public and private bases, which is inevitably related to the handling and processing of information that recipients of personal information must take into account. This right has been developed through the issuance of the Statutory Law 1581 of 2012 and the Regulatory Decree 1377 of 2013, based on which GALIA MARKET as RESPONSIBLE for the personal data it receives, handles and treats the information and thus proceeds to issue this policy of treatment of personal data, which is made known to the public so that they know the way GALIA MARKET treats their information. The provisions of this policy of treatment of personal data is mandatory for GALIA MARKET, its administrators, employees, contractors and third parties with whom GALIA MARKET enters into relations of any kind.

OBJECTIVE.

With the implementation of this policy, it is intended to ensure the confidentiality of information and security on the treatment that will be given to it to all customers, suppliers, employees and third parties from whom GALIA MARKET has legally obtained information and personal data in accordance with the guidelines established by the law regulating the right to Habeas Data. Also, through the issuance of this policy is in compliance with the provisions of paragraph K of Article 17 of that law.

DEFINITIONS OR GLOSSARY.

• Authorization: Prior, express and informed consent of the data owner to carry out the processing. This may be written, verbal or through unequivocal conduct that allows the reasonable conclusion that the data owner granted authorization.
• Privacy Notice: verbal or written communication generated by the person responsible for the processing of personal data, addressed to the owner of such data, through which he/she is informed about the existence of the data processing policies that will be applicable, how to access them and the purposes of the processing that is intended to be given to personal data.
• Data Base: It is the organized set of Personal Data that are subject to processing, electronic or not, whatever the modality of its formation, storage, organization and access.
• Consultation: Request from the owner of the data or from the persons authorized by the owner or by law to know the information about him/her in databases or files.

• Personal data: Any information linked or that can be associated to one or several determined or determinable natural persons. These data are classified as sensitive, public, private and semi-private.
• Sensitive personal data: Information that affects the privacy of the person or whose misuse can generate discrimination, such as those that reveal racial or ethnic origin, political orientation, religious or philosophical beliefs, membership in trade unions, social organizations, human rights or promoting the interests of any political party or to ensure the rights and guarantees of opposition political parties, as well as data relating to health, sex life and biometric data (fingerprints, among                                         others). For the purposes of this policy, GALIA MARKET . warns the optional nature of the holder of the personal data to provide this type of information in cases in which, eventually, may be requested.
• Public personal data: It is the data qualified as such according to the mandates of the law or the Political Constitution and all those that are not semi-private or private. Public are, among others, the data contained in public documents, public records, official gazettes and bulletins and duly executed court rulings that are not subject to confidentiality, those relating to the marital status of individuals, their profession or trade and their status as merchants or public servants. The personal data existing in the commercial registry of the Chambers of Commerce are public (Article 26 of the Code of Commerce). Likewise, public data are those which, by virtue of a decision of the owner or a legal mandate, are in files of free access and consultation. These data may be obtained and offered without any reservation and regardless of whether they refer to general, private or personal information.
• Private personal data: Data that, due to its intimate or reserved nature, is only relevant to the person who owns it. Examples: merchants’ books, private documents, information extracted from the inspection of the domicile.

• Semi-private personal data: Semi-private data is data that is 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 certain sector or group of persons or to society in general, such as, among others, data concerning the fulfillment or non-fulfillment of financial obligations or data relating to relations with social security entities.
• Public Data: is data that is not semi-private, private or sensitive. Public data includes, among others, data relating to the civil status of individuals, their profession or trade, and their status as merchants or public servants. 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.
• Data Controller: Person who by himself or in association with others, decides on the database and/or the processing of data.
• Data processor: Person who carries out data processing on behalf of the data controller.
• To be “Authorized” is GALIA MARKET and all persons under the responsibility of this, which by virtue of the authorization and the Policy have the legitimacy to submit to processing the personal data of the holder. The Authorized includes the gender of the Entitled.
• “Enabling” or being “Enabled”, is the legitimization expressly and in writing by contract or document that takes its place, granted by GALIA MARKET to third parties, in compliance with applicable law, for the processing of personal data, making such third parties in charge of the processing of personal data delivered or made available.
• Claim: Request of the data owner or the persons authorized by the data owner or by law to correct, update or delete their personal data or when they notice that there is an alleged breach of the data protection regime, according to Article 15 of Law 1581 of 2012.
• Data subject: The natural person to whom the information refers.

• Processing: Any operation or set of operations on personal data such as, among others, the collection, storage, use, circulation or deletion of such information.
• Transmission: Processing of personal data that involves the communication of such data within Colombia (national transmission) or outside Colombia (international transmission) and whose purpose is the performance of a processing operation by the processor on behalf of the controller.
• Transfer: The transfer of data takes place when the controller and/or processor of personal data, located in Colombia, sends the information or personal data to a recipient, which in turn is responsible for the processing and is located inside or outside the country.
• Procedural requirement: The holder or assignee may only file a complaint before the Superintendence of Industry and Commerce once the consultation or complaint process has been exhausted before the data controller or data processor, according to Article 16 of Law 1581 of 2012.
• Electronic signature: It is a signature that uses technological methods to identify the author or participant of the message or document. It is also a solution that can be used by signatory users in the Judicial Branch independently of an information or procedural management system, as it works through an application.
• institutional web, independent. The judicial servers, as signatories, upload to the electronic signature Web application, the document in Word format on which the electronic signature is to be made.

PRINCIPLES FOR THE PROCESSING OF PERSONAL DATA. 

The processing of personal data must be carried out in compliance with the general and special rules on the subject and for activities permitted by law. Consequently, the following principles apply for the purposes of this policy:

• Principle of legality: Data processing is a regulated activity that must be subject to the provisions of the law and other provisions that develop it.
• Principle of purpose: The processing must obey a legitimate purpose in accordance with the Constitution and the Law.
• Principle of freedom: The treatment can only be exercised with the prior, express and informed consent of the holder. Personal data may not be obtained or disclosed without prior authorization, or in the absence of legal or judicial mandate that relieves consent.
• Principle of truthfulness or quality: The information subject to processing must be truthful, complete, accurate, updated, verifiable and understandable. The processing of partial, incomplete, fractioned or misleading data is prohibited.
• Principle of transparency: The right of the owner to obtain from the controller, at any time and without restriction, information about the existence of data concerning him/her, must be guaranteed in the processing.
• Principle of restricted access and circulation: Processing is subject to the limits derived from the nature of the personal data, the provisions of the law and the Constitution. In this sense, the processing may only be carried out by persons authorized by the owner and/or by the persons provided by law.
• Security Principle: The information subject to Processing by the Data Controller or Data Processor referred to in this law, shall be handled with the technical, human and administrative measures necessary to provide security to the records avoiding their adulteration, loss, consultation, use or 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 any of the tasks involved in the processing, and may only supply or communicate personal data when this corresponds to the development of the activities authorized in this law and under the terms of this law.

RIGHTS OF THE OWNERS OF THE DATA.

In accordance with the legal provisions in force, the rights of the holders of personal information are the following:

• Right to know, update, rectify, consult your personal data at any time against GALIA MARKET regarding the data that you consider partial, inaccurate, incomplete, fractioned and those that mislead.
• The right to request at any time a proof of the authorization granted to GALIA MARKET except in those cases in which the responsible is legally released from having authorization to process the holder’s data.
• Right to be informed by GALIA MARKET upon request of the owner of the data, regarding the use that has been given to them.
• The right to file before the Superintendence of Industry and Commerce the complaints that he/she considers pertinent to enforce his/her right to Habeas Data.
• The right to revoke the authorization and/or request the deletion of any data when you consider that GALIA MARKET has not respected your constitutional rights and guarantees.
• Right to access free of charge to the personal data you voluntarily choose to share with GALIA MARKET

The information and/or personal data we collect from you are as follows:

Type of person: Natural/Legal

Natural: first and last names, type of identification, identification number, gender, marital status and date of birth, e-mail, financial data (bank accounts).

Legal: company name, NIT, address, telephone, cell phone, e-mail, country, city, financial data (bank accounts).

Information necessary to facilitate travel or other services, including preferences such as class of travel, names and surnames of passengers (type of document, document number, date of birth, name, surname, gender, email, nationality, passport expiration date), contacts in case of accident or any other anomaly (names and surnames, telephone).

This data may be stored and/or processed in servers located in data processing centers, either our own or contracted with suppliers, located in different countries, which is authorized by our customers/users, by accepting this policy of treatment and protection of personal data.

GALIA MARKET reserves the right to improve, update, modify, delete any information, content, domain or subdomain, which may appear on the website, without any obligation of prior notice, being understood as sufficient with the publication on the websites of GALIA MARKET For the solution of legal or internal requests and for the provision or offering of new services or products.

TREATMENT, SCOPE AND PURPOSES

I. GALIA MARKET informs the owners that the data collected from our customers, contractors and suppliers may be used for the following purposes. The treatment may be carried out by GALIA MARKET directly or through its contractors, consultants, advisors and / or third parties responsible for the processing of personal data, to carry out any operation or set of operations such as the collection, storage, use, circulation, deletion, classification, transfer and transmission (the “Treatment”) on all or part of their personal data:

a. The support of the contractual relationship established with GALIA MARKET

b. The provision of services related to the products and services offered.

c. The performance of all activities related to the service or product will be included in  a  mailing  list  for  the  sending  of  the

d. Send information about changes in the conditions of the services and products purchased, and notify you about new services or products.

e. Manage your   requests,   clarifications,   and

f. Elaborate studies and programs that are necessary to determine consumption habits

g. Refining security filters and business rules in commercial transactions; confirming, processing such transactions, with your financial institution, with our    service    providers,    and    with

h. Conduct periodic evaluations of our products and services in order to improve their

i. The sending, by traditional and electronic means, of technical, operational and commercial information about products and services offered by GALIA MARKET, its  associates  or  suppliers,  now  and  in  the

j. Requesting satisfaction  surveys,  which  is  not  obliged  to

k. The transmission and/or transfer of data to other companies, commercial alliances or third parties in order to fulfill the obligations acquired. The transmission and transfer may be made even to third countries that may have a different level of protection with respect to the Colombian one, when necessary   for   the   fulfillment   of   our

l. To comply with obligations undertaken by GALIA MARKET with its customers at  the  time  of  acquiring  our  services  and

m. Respond to inquiries, requests, complaints and claims that are made by regulatory agencies and other authorities that under applicable law must receive personal

n. Any other activity of a similar nature to those described above that are necessary to develop the corporate purpose of GALIA MARKET.

The data collected from our workers:

a. To comply with the obligations undertaken by GALIA MARKET with workers holders of the information, in relation to payment of wages, social benefits, and others enshrined in the employment contract and current labor regulations.

b. Inform the worker of developments that occur in the development of the employment contract   and   until   after   its

c. Evaluate the   quality   of   the   services   we

d. Conduct internal studies on the habits of the worker who is the owner of the information or request personal information for the development of programs or     management

e. Perform payroll  deductions  authorized  by  the

f. Manage your requests, administration of activities, clarifications and investigations.

g. Marketing and   selling   of   our   products   and

h. Sending, by traditional and electronic means, technical, operative and commercial information of products and services offered by associates or suppliers, currently and in the future.

i. To elaborate studies and programs that are necessary to determine consumption.

j. Carry out the transmission and/or transfer of data to other companies, commercial alliances or third parties in order to fulfill the obligations acquired. The transmission and transfer may even be made to third countries that may have a different level of protection with respect to the Colombian, when  necessary  for  the  fulfillment  of  our

k. The request for surveys, which the employee is not obliged to answer.

l. To transfer, either by way of transmission or transfer, the information received to all judicial and/or administrative entities when it is necessary for the fulfillment of our duties as an employer in order to comply with our own obligations regarding labor, social security, pensions, professional risks, family compensation funds (Integral Social Security System) and taxes.

m. To transfer the employer’s personal information to third parties who legitimately have the right to access such information.

n. Deliver either by way of transmission or transfer of the employee’s personal information to all entities that are related to the fulfillment of the responsible party in its capacity as employer.

o. To generate electronic signature in the web applications or software that GALIA MARKET prefers. These electronic signatures that users authorize GALIA MARKET generate, will be used to sign the accounts receivable in which the user is creditor of the charges are generated to GALIA MARKET as a debtor of the contractual relationship.

p. Any other activity of a similar nature to those described above that are necessary to develop the corporate purpose of GALIA MARKET and its labor obligations acquired by virtue of the conclusion of the employment contract or by operation of law.

ll. The processing of personal data will be carried out with the prior authorization of the owner of the data, except in the events in which the data is of a public nature. For this purpose, the authorization has been included as integral part of the registration format that every user of GALIA MARKET PLATFORM must complete, before submitting data to the platform. Authorization will be obtained through any means that may be subject to subsequent consultation, such as the website, forms, formats, face-to-face activities or through social networks, etc. Authorization may also be obtained from unequivocal conduct of the data owner that allows to reasonably conclude that he/she granted authorization for the processing of his/her information.

lll. If you provide us with personal information about a person other than yourself, such as your spouse or a co-worker, we understand that you have the authorization of such person to provide us with their data; and we do not verify, nor assume the obligation to verify the identity of the user/customer, nor the veracity, validity, sufficiency and authenticity of the data provided by each of them. By virtue of the above, we do not assume responsibility for damages or prejudices of any nature that could have origin in the lack of veracity, homonymity or the impersonation of the identity information.

lV. The personal data collected will be subject to manual or automated processing and incorporated into the corresponding files or databases (hereinafter the “File”) of GALIA MARKET, either as data processor and responsible for data protection. To determine the term of the treatment will be considered the rules applicable to each purpose and the administrative, accounting, tax, legal and historical aspects of the information.

V. When at the time of providing the service the holder is accompanied by minors or persons considered disabled, and in which the collection of personal data occurs, GALIA MARKET will always request the authorization of whoever has the legal representation of the minor. Now, if personal information of the population mentioned here is delivered without being the legal representative, you state that you have the authorization of the respective legal representative, directly assuming the responsibility that this entails. GALIA MARKET will strive to ensure that at all times respect the rights of these, and their best interests are The representative must guarantee the right to be heard and assess their opinion of the treatment taking into account the maturity, autonomy and capacity of minors. The representatives are informed of the optional nature of answering questions about minors’ data. The data of minors, included in a special category of protection, will be treated in accordance with the provisions of the applicable legislation, will be treated in accordance with the provisions of the applicable legislation on the subject and in accordance with the provisions of our personal data policy.

VI. The company has adopted the security levels of protection of personal data legally required, and has installed all the technical means and measures at its disposal to prevent the loss, misuse, alteration, unauthorized access and unlawful removal of personal data provided to GALIA MARKET, however, the owner should be aware that Internet security measures are not unbreakable.

VII. if you choose to delete your information, to the extent permitted by law, we will retain certain personal information in our files for the purposes of accounting and tax identification of transaction data, fraud prevention, dispute resolution, investigating disputes or incidents, enforcing our terms and conditions  of  use,  and  complying  with  legal  requirements. However, at the time you choose to revoke your authorization, the information stored will not be used for the purposes set forth herein, only as strictly necessary and as defined in the preceding paragraph.

VIII. Security Risks that should be taken into account when making transactions on the Internet: a) It is possible that a user may be deceived by means of e-mails or DNS servers, to visit a fake site that has the same design, but where the card data is loaded into the fake system, stealing information from the cardholder. Therefore, it is important to generate the culture that users should enter directly through known domains to reduce risks. b) It is possible that the computer where the user is performing the transaction, has installed without prior knowledge, some spyware or malicious software that captures everything typed on the keyboard or captures information from input devices and sent to a network or host on the Internet. Therefore, it is recommended that the transaction be made on the computer at home or at the office. c) It is possible that the owner may be impersonated if the owner denies having sent and/or received the transaction and it is used by a third party. d) It is recommended that the equipment where electronic transactions are made has an updated and active antivirus to mitigate the risks of fraud.

IX. If the personal information was collected or provided prior to July 30, 2013 and you did not express your opposition to the transfer of your personal data, it will be understood that you have given your consent. In the event that you wish to ratify your consent or express your refusal, you may do so by sending an e-mail to gerencia@galiamarket.com.

X. Like other websites, GALIA MARKET uses certain technologies, such as cookies and device fingerprinting, that allow us to make your visit to our sites easier and more efficient, providing you with a personalized service and recognizing you when you return to our site. For purposes of this Privacy Notice, “cookies” shall be identified as text files of information that a website transfers to the hard drive of a user’s computer for the purpose of storing certain records and preferences.

a) Web sites may allow advertising or third party functions that send “cookies” to the computers of the owners

b) Cookies are only associated with an anonymous user and your computer, and do not themselves provide the name and surname of the same, in many cases, you can browse any of the websites of GALIA MARKET, When you access any GALIA MARKET website, your IP address (the Internet address of your computer) is recorded to give us an idea of which parts of the website you visit and how much time you spend in each section. We do not link your IP address to any personal information about you, unless you have registered with us and logged in using your profile. Similarly, GALIA MARKET will have access to Geolocation. Therefore, Galia Market requires the authorization of users to access the data necessary to obtain your Geolocation. It’s understood and accepted that such authorization is conceded when users submit their registrations forms to GALIA MARKET’s platform.

c) Therefore, it is possible that in certain applications GALIA MARKET recognize users after they have registered for the first time, without having to register on each visit to access the areas and services or products reserved exclusively for them.

d) In other services will require the use of certain passwords, and even the use of a digital certificate, in the characteristics to be determined.

e) The cookies used can not read cookie files created by other providers. GALIA MARKET encrypts the user’s identification data for greater security.

f) To use the website of GALIA MARKET, it is not necessary that the user allows the installation of cookies sent by GALIA MARKET, notwithstanding that in such a case it will be necessary for the user to register for each of the services whose provision requires prior registration.

NATIONAL  OR  INTERNATIONAL  TRANSFER  OF  PERSONAL  DATA.

GALIA MARKET may transfer data to other data controllers when authorized by the owner of the information or by law or by an administrative or judicial order.

INTERNATIONAL AND NATIONAL TRANSMISSION OF DATA TO DATA PROCESSORS.

GALIA MARKET may send or transmit data to one or more data processors located within or outside the Republic of Colombia in the following cases:

a) When authorized by the owner and b) When without having the authorization exists between the controller and the data processor a contract for data transmission.

DUTIES OF THE DATA CONTROLLER.

• Guarantee the holder, at all times, the full and effective exercise of the right of habeas data.
• Request and keep, under the conditions provided for in this law, a copy of the respective authorization granted by the holder.
• Duly inform the owner about the purpose of the collection and the rights he/she has by virtue of the authorization granted.
• Keep the information under the necessary security conditions to prevent its adulteration, loss, consultation, unauthorized or fraudulent use or access.
• To process the consultations and claims formulated under the terms set forth in this law.
• Adopt an internal manual of policies and procedures to ensure adequate compliance with this law and, in particular, for the handling of inquiries and complaints.
• Inform upon request of the owner about the use given to their data.
• Inform the data protection authority when there are violations to the security codes and there are risks in the administration of the information of the owners.

• Comply with the instructions and requirements issued by the Superintendence of Industry and Commerce.

PETITIONS, COMPLAINTS AND CLAIMS

For the purpose of receiving requests, complaints and inquiries related to the handling and processing of personal data, GALIA MARKET has assigned the email gerencia@galiamarket.com, to channel, study and answer them. Therefore, you may send your requests to this address, which will be treated in accordance with the provisions of Law 1581:

Consultations: The holders or their assignees may consult the personal information of the holder that is in our database. GALIA MARKET will provide them with all the information contained in the individual record or that is linked to the identification of the holder. The query will be answered within a maximum period of ten (10) working days from the date of receipt of this. When it is not possible to answer the consultation within such term, the interested party will be informed and the date on which the consultation will be answered will be indicated, which in no case may exceed five (5) business days following the expiration of the first term.

Claims: The holder or his assignees who consider that the information contained in a database should be subject to correction, updating or deletion, or when they notice the alleged breach of any of the duties contained in the law, may file a claim with GALIA MARKET, which will be processed under the following rules:

• The claim shall be made by request addressed to GALIA MARKET with the identification of the owner, the description of the facts that give rise to the claim, the address, and accompanying documents you want to assert. If the claim is incomplete, GALIA MARKET will require the interested party within five (5) days of receipt of the claim to correct the faults. After two (2) months from the date of the requirement, without the applicant submitting the required information, it will be understood that the claim has been abandoned.
• Once the complete claim has been received, a legend will be included in the database stating “claim in process” and the reason for the claim, within a term no longer than two (2) business days. Said legend shall be maintained until the claim is decided.

• The maximum term to address 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 such term, the interested party will be informed and the date on which the claim will be addressed will be indicated, which in no case may exceed eight (8) business days following the expiration of the first term.
• In any case, the owner or the assignee may only file a complaint before the Superintendence of Industry and Commerce once the consultation or complaint process before GALIA MARKET has been exhausted.
• The area responsible for receiving and processing complaints is the Information Security Management.
• The request for deletion of information and revocation of authorization will not proceed when the holder has a legal or contractual duty to remain in the database.

DATA OF THE PERSON IN CHARGE OF THE TREATMENT.

Company name: GALIA MARKET

Address: Santiago de Cali, Calle 12B # 85-39 Apt 309.

E-mail: gerencia@galiamarket.com.

Telephone: +57 313 8809450

QUESTIONS OR SUGGESTIONS

If you have any questions or queries about the process of collection, processing or transfer of your personal information, or consider that the information contained in a database should be corrected, updated or deleted please send us a message to the following email, Gerencia@galiamarket.com

VALIDITY

GALIA MARKET reserves the right to modify this policy to adapt to new legislation or case law, as well as good practice. In such cases, GALIA MARKET will announce on this page the changes introduced withreasonable notice before their implementation.

This policy was created and posted on the GALIA MARKET website on January 15, 2024 and is effective as of the date of posting.