Privacy & Personal Data Protection Policy

1. General Provisions

This Privacy and Personal Data Protection Policy (hereinafter, the “Policy”) is issued in compliance with the provisions of the Political Constitution of Colombia, Law 1581 of 2012, Law 1266 of 2008, Law 1480 of 2011, Decree 1377 of 2013, and any other applicable regulations.

Vault & Eden acknowledges and safeguards the fundamental rights of all natural persons to know, update, rectify, and delete their personal data in accordance with the applicable legal framework.

The collection, storage, use, and processing of personal data by Vault & Eden shall be strictly limited to the development of its corporate purpose, as well as the commercial, administrative, and communication activities arising therefrom.

2. Definitions

For purposes of this Policy, the following terms shall be understood as follows:

Authorization: Prior, express, and informed consent granted by the data subject for the processing of their personal data.

Database: A structured set of personal data subject to processing.

Data Transfer: The disclosure of personal data to unauthorized third parties.

Client/Consumer: Any natural or legal person acquiring products or services from Vault & Eden.

Personal Data: Any information that identifies or allows the identification of a natural person.

Sensitive Data: Information that affects the privacy of the data subject or which, if misused, may result in discrimination (e.g., racial or ethnic origin, political orientation, health status, sexual life, biometric data, etc.).

Processor: A natural or legal person that processes personal data on behalf of the Controller.

Data Subject: The natural person whose personal data is subject to processing.

Processing: Any operation performed on personal data, including but not limited to collection, storage, use, circulation, or deletion.

Transmission: The communication of personal data from Colombia to a third party, whether national or international.

Personal Data Breach: Any unauthorized access, use, or disclosure of personal data constituting a violation of applicable laws.

3. Objectives

General Objective:
To establish the principles, guidelines, and procedures governing the processing of personal data by Vault & Eden.

Specific Objectives:

To guarantee the protection and confidentiality of personal information belonging to clients, suppliers, partners, employees, and other third parties.

To ensure strict compliance with the applicable data protection legislation, particularly habeas data regulations.

To implement and promote corporate best practices in information management.

4. Data Retention
Vault & Eden shall retain personal data only for as long as necessary to fulfill the purposes for which it was collected or as required by applicable law. Upon fulfillment of such purposes, the data shall be deleted, returned, or securely archived to prevent unauthorized processing.
5. Security Measures
Vault & Eden has adopted and shall maintain physical, administrative, and technological safeguards proportionate to the nature of the data processed and the risks associated therewith, in order to prevent loss, unauthorized access, or misuse of personal data.
6. Rights of Data Subjects

In accordance with Article 8 of Law 1581 of 2012, data subjects are entitled to:

  1. Know, update, rectify, or request the deletion of their personal data.
  2. Request proof of the authorization granted for data processing.
  3. Be informed by Vault & Eden, upon request, about the use given to their personal data.
  4. File complaints before the Superintendencia de Industria y Comercio for any violation of applicable data protection rules.
  5. Revoke the authorization granted or request the deletion of their personal data when legal principles and constitutional guarantees are not respected.
  6. Access their personal data free of charge.
7. Procedure for the Exercise of Rights

Data subjects may exercise their rights and submit inquiries, complaints, or claims related to the processing of their personal data through the following channels:

Telephone: +57 318 9672774

Email: atelier@vaultandeden.com

Vault & Eden undertakes to process and respond to all requests within the legal time limits established under Colombian law.

8. Processing of Minors’ Data
Vault & Eden does not process personal data of minors, except where such data is of a public nature or where prior, express, and verifiable consent has been obtained from the minor’s legal representatives. In such cases, Vault & Eden shall ensure the protection of the rights of minors at all times.
9. Responsibility for Data Processing

Vault & Eden shall act as the Data Controller with respect to the personal data of its clients, employees, suppliers, and other third parties with whom it maintains contractual or commercial relationships.

In cases where Vault & Eden products are marketed through partner channels or third parties, Vault & Eden shall assume joint liability as established by law, ensuring proper and timely handling of any petition, complaint, or claim (PQR).

10. Updates
This Policy may be amended or updated at any time to comply with regulatory changes or internal strategic decisions. Any modification shall be duly published on the official website: www.vaultandeden.com