PRIVACY POLICY AND PROTECTION OF PERSONAL DATA

(Procedure Manual)

HEALING PRESENTS S.A.S., a company domiciled in Medellín, identified with NIT 901.323. 867-3, located at Calle 6 A #16 – 45, is a company committed and responsible with the privacy and security of the Personal Data of its employees, shareholders, suppliers, clients, distributors, commercial allies, related companies, users, contractors, consultants, advisors, subscribers, former employees, former contractors and others, information that has been collected by this company by virtue of the development of its corporate purpose, by administrative, commercial, civil, labor relations, among others; under the terms of Law 1581 of 2012 and Decree 1377 of 2013, the following “PRIVACY POLICY AND PROTECTION OF PERSONAL DATA” has been adopted, in which, all persons directly or indirectly related to this company and of which is currently included information of Personal Data in our database or those data that in the future enter by any of the means of collection of information that the company HEALING PRESENTS S. A.S. has, may know the procedure for collection, storage and processing of Personal Data, as well as the rights, guarantees and procedures to enforce them:

I. DEFINITIONS OF YOUR INTEREST:

Personal Data:Any information linked or that can be associated with several determined or determinable natural persons.
Database: Set of personal data systematically organized for subsequent processing.
Authorization: Express prior and informed consent of the personal data owner to carry out a treatment.
Processing: Operations or activities that may be carried out with personal data, among which are: collection, use, copying, transfer, transmission, or deletion.
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 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, sexual life, and biometric data.

II. PURPOSE OF THE PROCESSING OF PERSONAL DATA

The information provided by the holder will be included in our database and will be used:

For shareholders:

In case of being a shareholder of the company, will be given notice of calls to the Ordinary and Extraordinary Meetings of the company or other types of communications by the administration of HEALING PRESENTS S.A.S.
Notification of the decree and distribution of profits of the company and the payment of dividends corresponding to the company’s shareholders.

For suppliers:

To carry out activities of purchases of goods and services.
Notification of cancellation of obligations to the company’s suppliers, among other types of communications from HEALING PRESENTS S.A.S.
Evaluate the quality of products and services provided by this company.

For customers/users:

To provide our services and products.
To use the results, evaluations, ratings that it gives to the services provided by HEALING PRESENTS S.A.S., without publishing personal data that allow the identification of each client or user, to promote our products, services, and offers, by physical means or through our website, or other means used for this purpose.
Sending commercial information about the products and services offered by the company through different means of dissemination previously authorized by the owner.
Sending communications related to our products, services, offers, promotions, alliances, studies, contests, among others.
Inform about new products or services directly related to the contracts or services acquired by the holder.
Evaluate the quality of the products and services provided by this company.
Carry out collection activities concerning obligations contracted by the holder.
Conduct internal studies on marketing and consumer behaviors of users.

For employees:

Store contact and profile information of all direct employees of the company.
Sending communications related to work-related matters and of interest to the company.

In general:

Sending information related to HEALING PRESENTS S.A.S., concerning its customers, suppliers, shareholders, employees, according to the existing contractual relationship.
To comply with the obligations undertaken by the holder of this authorization, according to the existing relationship with the company.
Notification of compliance with payment obligations to employees, suppliers, or third parties.
To comply with the duties of information that the company must comply with by legal mandate, by court decision, or competent authority.
We may contact the owner of the Personal Data in case there is a risk regarding the protection of his Personal Data.

The information and data provided may be subject to transmission and/or transfer to third countries to execute the activities related to the company and/or the treatment described above.

III. PROCESSING OF PERSONAL DATA

HEALING PRESENTS S.A.S. is responsible for the treatment of the Personal Data of its employees, shareholders, suppliers, clients, distributors, commercial allies, related companies, users, contractors, consultants, advisors, subscribers, former employees, former contractors, and others, for this reason, it will act in compliance with the obligations arising from this condition. Thus, this treatment may be extended to its Subsidiaries and additionally may be entrusted to those who represent the company or whom it may hire for the exercise of its representation or development of its corporate purpose, which must act in accordance with the procedures and policies for the protection of personal data, which for this purpose were designed and implemented by HEALING PRESENTS S.A.S.

Personal data processing shall be carried out under the terms and scope of the authorization issued by the Personal Data Holder or under the terms established in the legislation in force for such purpose.

IV. RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA

HEALING PRESENTS S.A.S. company identified with the NIT 901.323.867-3 constituted by a private document of September 5, 2019, registered in the Chamber of Commerce of Medellin on September 19, 2019, in the 9th book under No. 27257, domiciled in Medellin, and with the following communication channels:

Physical address: Calle 6 A #16 – 45, Medellín – Antioquia.

Telephone number: (+57) 6045776715

E-mail address: suppor@healingpresents.co

Website: https://healingpresents.co/

V. PERSON IN CHARGE OF THE PROCESSING OF PERSONAL DATA

Natural or legal person, public or private, which by itself or in association with others, performs the processing of personal data on behalf of the data controller. In the case of HEALING PRESENTS, the employee or contractor, whether a natural or legal person, who is in charge of the processing of a specific database, in accordance with the appointment act that so designates him/her, shall be the data processor.

VI. MANNER IN WHICH THE PERSONAL DATA IS OBTAINED

The activities of collection and storage of Personal Data can be carried out through physical mail, electronic mail, mobile devices, web pages, mobile applications, or through any digital or similar mechanism of communication known or through the voluntary and direct supply that the owner of the Personal Data gives to HEALING PRESENTS S.A.S., through the different mechanisms mentioned above.

VII. PERSONAL DATA STORED BY HEALING PRESENTS S.A.S.

The personal data stored by HEALING PRESENTS S.A.S. depends on the direct or indirect relationship that the holder has with the company, for which it may be necessary to obtain from the holder his/her name, address, telephone number, residence address, e-mail, date of birth, professional activity, position, employer, among others, information that will be used for the purpose described in this privacy and personal data protection policy.

VIII. SENSITIVE DATA COLLECTED BY HEALING PRESENTS S.A.S.

The sensitive data collected by HEALING PRESENTS S.A.S. is for the sole purpose of the statistical and scientific study of the products and services offered by HEALING PRESENTS S.A.S. and is optional to be provided by the users of the Healing Presents app. Such information will not be collected automatically or tacitly, and the absence of the provision of such data will not prevent the user from performing all or part of the services contracted with HEALING PRESENTS S.A.S.

The sensitive and optional data to be provided by the users of the Healing Presents app are:

Type of Cancer (Optional Field)
Stage (Optional Field)
Time since diagnosis (Optional Field)
Name of an oncologist (Optional Field)

HEALING PRESENTS S.A.S. will at no time use sensitive data provided by users of the Healing Presents app with which to individualize or identify the user, only collect, store and publish the results and ratings obtained by each user who provided sensitive data for publications of results, effectiveness and study of the products and services offered in the Healing Presents app, without associating such results to the user or personal data of the owner of the data that can give with their individualization.

HEALING PRESENTS S.A.S. will collect additional express authorization to the owner of the data that optionally want to provide them.

HEALING PRESENTS S.A.S. will not transmit to third parties, in any way, sensitive data of the users of the app Healing Process; it is reiterated that the purpose of obtaining sensitive data is to improve the products and services offered by HEALING PRESENTS S.A.S., without associating the owner of the data in statistical or scientific publications of the same.

IX. DUTIES OF THE PERSON RESPONSIBLE FOR THE PERSONAL DATA.

Effectively guarantee the Personal Data Subject to exercise his/her rights in accordance with Law 1581 of 2012 and Decree 1377 of 2013 and other regulatory standards.
Request and keep proof of the respective authorization issued by the Personal Data Holder for the processing of his/her data.
Inform the Personal Data Holder about the purpose for the processing of their data and the protection policies that have been adopted for them.
Keep the Personal Data according to the purpose for which they were collected and under the appropriate security conditions, which are intended to prevent adulteration, loss, consultation, use, or unauthorized access by outsiders to the information.
Update the Personal Data according to the indications or requests required by the owner of the information.
Rectify the Personal Data when they are provided or described incorrectly.
To process and respond to queries and claims under the terms set forth in Law 1581 of 2012 and Decree 1377 of 2013.
Adopt an internal manual of policies and procedures to ensure the proper treatment of Personal Data.
Maintain updated the status of Personal Data when certain information is under discussion by the Holder.
Implement the security measures of personal data, following the instructions given by the Superintendence of Industry and Commerce on the matter.
Comply with the instructions and requirements issued by the Superintendence of Industry and Commerce.
And in general, to process personal data in accordance with the authorization given by the owners and in compliance with the purposes and purposes established in Law 1581 of 2012 and Regulatory Decree 1377 of 2013.

X. RIGHTS OF THE HOLDER OF THE PERSONAL DATA AND, IN THE EVENT OF ABSOLUTE LACK THEREOF, OF HIS SUCCESSORS IN TITLE.

Under the terms of Law 1581 of 2012 and Decree 1377 of 2013, the rights granted to the holder of the Personal Data and in the event of absolute lack thereof, to their successors in title, are as follows:

Right to consult their Personal Data free of charge and to know if the same are being subject to any processing by the responsible company.
The right to request at any time the updating, rectification, and deletion of their personal data.
The right to revoke at any time the authorization given to the controller for the processing of personal data.
The right to request at any time proof of the existence of the authorization given to the controller for the processing of personal data.
Right to file complaints before the Superintendence of Industry and Commerce for violations of the provisions of Law 1581 of 2012 and other rules that modify, add or complement it.
The right to be informed by HEALING PRESENTS S.A.S. about the use of your Personal Data.
The other rights granted by the National Legislation.

XI. MEANS BY WHICH THE HOLDER AUTHORIZES THE PROCESSING OF THEIR PERSONAL DATA

The holders of the personal data must authorize the responsible for the treatment of the same, by means of the express acceptance at the time of registering their data/creating an account in the Healing Presents app, which is available for download in Apple and Play Store stores, or through the website https://healingpresents.co/.

XII. MANNER IN WHICH THE HOLDER OF THE PERSONAL DATA MAY EXERCISE HIS/HER RIGHTS

The owner of the information, who hereby issues authorization for the use of his Personal Data, may at any time access the data provided, as well as request the correction of the same, update them, delete them or request the revocation of this authorization, under the terms of Law 1581 of 2012 and Decree 1377 of 2013; the interested party may request via e-mail to support@healingpresents.co or through the “contact us” channel enabled on the website https://healingpresents.co/.

The request must contain, at least, the information identified below:

Identification of the Holder
Description of the facts that give rise to the consultation, suggestion, claim, or complaint.
Terms of the request
Address for notification.

XIII. RESOLUTION OF QUERIES AND CLAIMS FILED BY DATA OWNERS.

The Data Owners or their successors in title may make inquiries or complaints about the personal information of the Data Owner contained in the databases of HEALING PRESENTS S.A.S. through the following mechanisms:

E-mail support@healingpresents.co
Channel “contact us”: https://healingpresents.co/
Physical address: Calle 6 A #16 – 45, Medellín – Antioquia.
Telephone number: (+57) 6045776715

– PROCEDURE.

HEALING PRESENTS S.A.S. will answer the owner’s or their assignee’s inquiries about the personal information of the Holder that is stored in its databases.

The consultation will be received exclusively through the channels of HEALING PRESENTS S.A.S. previously mentioned.

The query will be answered within a maximum term of ten (10) business days from the date of receipt thereof. When it is not possible to attend the consultation within such term, the interested party will be informed, stating the reasons for the delay and indicating the date on which the consultation will be attended, which in no case may exceed five (5) working days following the expiration of the first term.

In the case of claims, the Data Subject or his assignees who consider that the information contained in a database should be corrected, updated, or deleted, or when they notice the alleged breach of any of the duties contained in this law, may file a claim through the channels offered by HEALING PRESENTS S.A.S. and shall be resolved under the following terms and conditions:

The claim shall be formulated by means of a request addressed to HEALING PRESENTS S.A.S. with the identification of the Holder, the description of the facts that give rise to the claim, the address, and accompanied by the documents to be asserted. If the claim is incomplete, the interested party will be required within five (5) days after 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. In the event that the person receiving the claim is not competent to resolve it, he/she will transfer it to the appropriate person within a maximum term of two (2) business days and will inform the interested party of the situation.

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 not exceeding two (2) business days. Said legend shall be maintained until the claim is decided.
The term to attend the claim shall be fifteen (15) business days from the day following the date of receipt. When it is not possible to attend to the claim within said term, HEALING PRESENTS S.A.S. shall inform the interested party of the reasons for the delay and the date on which the claim will be attended to, which shall not exceed eight (8) working days following the expiration of the first term.

Procedural requirement. The Data Subject or assignee may only file a complaint before the Superintendency of Industry and Commerce once he/she has exhausted the consultation or complaint process before the Data Controller or Data Processor.

The request must contain, at least, the information identified below:

Identification of the owner
Description of the facts that give rise to the consultation, suggestion, claim, or complaint.
Terms of the request
Address for notification

XIV. INTERNATIONAL TRANSFER AND TRANSMISSION OF PERSONAL DATA

The information and data provided may be subject to transmission and/or transfer to third countries for the execution of the activities related to the company and/or the treatment described in these Policies.

For the international transfer and transmission of personal data, the provisions of Article 26 of Law 1581 of 2012 and Article 24 of Decree 1377 of 2013 shall be observed.

The present ‘PRIVACY POLICY AND PROTECTION OF PERSONAL DATA’ is published on August 28, 2013 and becomes effective as of the day of its publication.