Privacy Policy

1. Identity of the Controller

The data controller responsible for the personal data collected through this website is:

Strategia Andina
Cra. 31 #9c-139, La Alameda, Cali, Valle del Cauca, Colombia
Email: info@strategiaandinao.com
Phone: +57 310 214 0359
Website: strategiaandinao.com

Strategia Andina is a consultation and training center specializing in personal economic education. It does not provide investment advice or any financial services regulated by the Superintendencia Financiera de Colombia.

2. Legal Framework

This Privacy Policy is governed by Colombian law, in particular:

• Ley 1581 de 2012 (General Data Protection Law of Colombia)
• Decreto 1377 de 2013 (Regulatory Decree implementing Ley 1581)
• Decreto 1074 de 2015 (Sole Regulatory Decree for the Commerce, Industry and Tourism sector)
• Circulares and guidelines issued by the Superintendencia de Industria y Comercio (SIC) as the data protection authority in Colombia

Where users access this website from outside Colombia, we apply the same standard of protection as required by Colombian law and endeavor to meet applicable local requirements as well.

3. Data We Collect

3.1 Data you provide directly

When you use our contact form, you provide us with:

• Full name
• Email address
• Phone number
• The content of your message

3.2 Data collected automatically

When you visit our website, we may automatically collect:

• IP address and approximate geographic location
• Browser type and version
• Device type and operating system
• Pages visited and time spent on each page
• Referring URL (the page you came from)
• Date and time of your visit

3.3 Cookie data

We use cookies and similar tracking technologies as described in our Cookie Policy. Please refer to that document for full details of the cookies we use and how to manage them.

4. Purposes of Processing

We process your personal data for the following purposes:

• Responding to inquiries: To reply to messages submitted through our contact form and provide information about our educational programs.
• Program administration: To manage enrollment in consultations, workshops, and webinars.
• Website improvement: To understand how visitors use our website and improve its content and functionality.
• Legal compliance: To meet our obligations under Colombian law, including record-keeping requirements.
• Communications: With your explicit consent, to send you information about upcoming programs, new content, or updates relevant to personal economic education.

We do not use your personal data for automated decision-making or profiling that produces legal or similarly significant effects.

5. Legal Basis for Processing

Under Ley 1581 de 2012, we process your personal data on the following legal bases:

• Consent (autorización): For non-essential processing such as marketing communications, we rely on your freely given, specific, informed, and unambiguous consent. You may withdraw this consent at any time.
• Contractual necessity: For processing required to provide the educational services you have requested.
• Legitimate interest: For analytics and website improvement activities, where our interest in improving our educational programs does not override your rights and freedoms.
• Legal obligation: Where processing is required to comply with applicable Colombian law.

6. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes described in this policy, or as required by law.

• Contact form submissions: retained for up to 24 months from the date of submission, or longer if required to fulfill an ongoing service relationship.
• Analytics data: retained in aggregated, anonymized form for up to 26 months.
• Cookie consent records: retained for 13 months from the date of consent.

When your data is no longer needed, we delete or anonymize it in a secure manner.

7. Data Sharing and Disclosure

We do not sell, rent, or trade your personal data to third parties. We may share your data in the following limited circumstances:

• Service providers: With trusted third-party service providers who assist us in operating our website and delivering our programs (such as hosting providers and email service providers), under contractual obligations of confidentiality.
• Legal requirements: When required to do so by law, court order, or government authority, including the Superintendencia de Industria y Comercio.
• Protection of rights: When necessary to protect the rights, property, or safety of Strategia Andina or others.

All third-party service providers are required to process your data only on our instructions and in accordance with this Privacy Policy.

8. International Data Transfers

Some of our service providers may be located outside Colombia. Where we transfer personal data outside Colombia, we ensure that adequate protections are in place, consistent with the requirements of Ley 1581 de 2012 and the SIC's guidelines on international data transfers. We use standard contractual clauses or rely on the recipient country's adequate protection status where applicable.

9. Your Rights

Under Ley 1581 de 2012, you have the following rights regarding your personal data:

• Right to access (conocer): To request a copy of the personal data we hold about you.
• Right to update (actualizar): To request correction of inaccurate or incomplete data.
• Right to rectification (rectificar): To correct errors in your personal data.
• Right to deletion (suprimir): To request deletion of your personal data, subject to legal retention requirements.
• Right to revoke consent (revocar la autorización): To withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
• Right to complain (presentar queja): To lodge a complaint with the Superintendencia de Industria y Comercio (SIC) if you believe your data protection rights have been violated.

To exercise any of these rights, please contact us at info@strategiaandinao.com. We will respond within the timeframes required by Colombian law (generally within 10 business days for access requests and 15 business days for deletion requests).

10. Cookies

We use cookies and similar technologies on our website. For detailed information about the types of cookies we use, their purposes, and how to manage your cookie preferences, please refer to our Cookie Policy.

11. Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include SSL/TLS encryption for data in transit, access controls limiting who can access personal data, and regular review of our security practices.

While we take reasonable precautions, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security of your data.

12. Minors

Our website and services are directed at adults. We do not knowingly collect personal data from individuals under the age of 18. If you believe we have inadvertently collected data from a minor, please contact us immediately at info@strategiaandinao.com and we will delete the data promptly.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. When we make significant changes, we will update the "Last Updated" date at the top of this page. We encourage you to review this policy periodically. Continued use of our website after changes are posted constitutes acceptance of the updated policy.

14. Contact and Complaints

For any questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact:

Strategia Andina — Data Protection Contact
Email: info@strategiaandinao.com
Phone: +57 310 214 0359
Address: Cra. 31 #9c-139, La Alameda, Cali, Valle del Cauca, Colombia

If you are not satisfied with our response, you have the right to lodge a complaint with the Superintendencia de Industria y Comercio (SIC), the data protection supervisory authority in Colombia, at www.sic.gov.co.