Personal Data Processing and Protection Policy

VIAJAR LIBREMENTE S.A.S.
November 1, 2025

Based on the General Regime of Personal Data Protection in Colombia, Law 1581 of 2012 and its Regulatory Decree 1377 of 2013.

Purpose and Scope of Application

This policy aims to establish the guidelines under which VIAJAR LIBREMENTE S.A.S., in its capacity as Data Controller, carries out the collection, storage, use, circulation, and suppression of personal data, guaranteeing the fundamental right to Habeas Data of the Data Subjects, in accordance with Law 1581 of 2012 and other related regulations.

Identification of the Data Controller

Concept Details
Business Name VIAJAR LIBREMENTE S.A.S.
Tax ID (NIT) #
Main Address Carrera 53 # 73 Sur – 40, Entrebosques Building, Tower 4, Apt 2208, Medellín, Colombia.
Contact Email info@gmail.com
Commercial Registration Medellín, Colombia

Key Legal Definitions

For the purposes of this policy, the definitions of Law 1581 of 2012 shall apply, highlighting:

  • Data Subject: Natural person whose personal data is subject to Processing (e.g., Donors, website users).
  • Processing: Any operation or set of operations performed upon personal data (e.g., collection, storage, use, circulation, suppression).
  • Authorization: Prior, express, and informed consent of the Data Subject to carry out the Processing of personal data.
  • Personal Data: Any information linked or that can be associated with one or more determined or determinable natural persons.

Principles Applicable to Data Processing

In the Processing of personal data, VIAJAR LIBREMENTE S.A.S. shall rigorously apply the following principles:

I. Legality: Processing shall be subject to the provisions of the law.
II. Purpose: Processing must comply with a legitimate and explicit purpose (see section 5), informed to the Data Subject.
III. Freedom: Processing can only be carried out with the prior, express, and informed consent of the Data Subject.
IV. Truthfulness or Quality: The information must be truthful, complete, accurate, up-to-date, verifiable, and comprehensible.
V. Transparency: The Data Subject’s right to obtain information about their data must be guaranteed.
VI. Restricted Access and Circulation: Data shall only be processed by authorized persons and will not be available on the internet unless access is technically controllable.
VII. Security: Information shall be managed with the necessary technical, human, and administrative measures to prevent its alteration, loss, unauthorized consultation, or access.
VIII. Confidentiality: Persons involved in the Processing are obliged to guarantee the confidentiality of the information.

Purposes of Personal Data Processing

VIAJAR LIBREMENTE S.A.S. collects personal data mainly for:

Data Collection Origin Data Collected Specific Purposes of Processing
Online Donations Name, Identification (ID or Tax Number), Email, Address, Phone, Donation amount. 1. Process the transaction and ensure traceability. 2. Comply with legal and tax obligations. 3. Issue donation certificates (if applicable). 4. Send acknowledgments and institutional communications.
Contact / Subscription Forms Name, Email. 1. Respond to inquiries and requests. 2. Send updates and institutional information. 3. Conduct internal studies to improve website content.
Contractor / Supplier Management Contact information, Financial / banking data. 1. Make or receive payments. 2. Comply with legal contracting obligations.

Data Subject Rights (Habeas Data)

The Data Subject has the right to:

  1. Know, update, and rectify their personal data.
  2. Request proof of the granted authorization, except when the law exempts this requirement.
  3. Be informed regarding the use made of their data.
  4. File complaints before the Superintendence of Industry and Commerce (SIC) for violations of Law 1581 of 2012.
  5. Revoke the authorization and/or request the suppression of the data (provided there is no legal or contractual duty preventing its suppression).
  6. Access their personal data that has been subject to Processing free of charge.

Procedure for Inquiries and Complaints

The Data Subject or their successors may exercise their Habeas Data rights as follows:

A. Inquiries (Request for Knowledge or Access)

  • Means: Inquiries must be directed to the email address info@viajarlibremente.com
  • Response Term: The inquiry shall be addressed within a maximum period of ten (10) business days counted from the date of receipt. If it is not possible to address the inquiry within that period, the interested party shall be informed, stating the reasons for the delay and indicating the new response date, which in no case may exceed five (5) business days following the expiration of the initial term.

B. Complaints (Request for Correction, Update, Suppression, or Revocation)

  • Means: Complaints must be directed to the email address info@viajarlibremente.com
  • Requirements: The complaint must contain the identification of the Data Subject, a description of the facts leading to the complaint, and the document they wish to update, correct, or suppress.
  • Response Term: The maximum period for addressing the complaint shall be fifteen (15) business days counted from the day following the date of its receipt. If the complaint is incomplete, the interested party will be required to correct the deficiencies.

Duties of VIAJAR LIBREMENTE S.A.S.

As the Data Controller, VIAJAR LIBREMENTE S.A.S. commits to:

  1. Guarantee the Data Subject the full and effective exercise of their Habeas Data rights.
  2. Request and retain a copy of the respective authorization granted by the Data Subject.
  3. Duly inform the Data Subject about the purpose of the collection and the rights they are entitled to.
  4. Retain the information under the necessary security conditions to prevent its alteration, loss, unauthorized or fraudulent consultation, or access.

 Effective Date

The present Personal Data Processing Policy is effective from the date of its publication on the website and as long as VIAJAR LIBREMENTE S.A.S. continues with the development of its corporate purpose.