Authorization: prior, express and informed consent of the holder to carry out the processing of personal data.

Privacy Notice: verbal or written communication generated by AZULU or any third party designated by the latter for the purposes, addressed to the holder for the processing of their personal data, which informs you about the existence of the policies of treatment of information that will be applicable, the way of accessing the same and the purposes of the treatment of personal data.

Personal data: any information that can be associated or linked to one or more natural persons determined or determinable. For the purposes of personal data will be AZULU among others the following: name, surname, age, gender, marital status, email, correspondence address, identification number, date of birth, telephone and profession.

Sensitive Data: sensitive data are understood as those that affect the privacy of the Holder or the abuse of which you can generate your discrimination, such as those revealing racial or ethnic origin, political orientation, religious or philosophical beliefs, trade union membership, social organizations, human rights or that promotes the interests of any political party or to ensure that the rights and guarantees of political opposition parties, as well as data relating to health, sexual life, and biometric data.

In charge of the Treatment: natural person or legal entity, public or private, which by itself or in association with others, perform the processing of personal data on behalf of the person responsible for the processing.

Responsible for the Treatment: natural person or legal entity, public or private, which by itself or in association with others, decides on the basis of data and/or the treatment of the data.

Holder: natural person whose personal data are object of treatment;

Treatment: any operation or set of operations on personal data, such as the collection, storage, use, movement or deletion.

Principle of purpose: the processing of personal data must comply with a legitimate purpose in accordance with the Constitution and the law, which must be reported to the Owner;

Principle of Freedom: The treatment can only be exercised with the consent, prior, express and informed consent of the holder. Personal data may not be obtained or disclosed without authorization, or in the absence of legal or judicial mandate that relieve the consent.

Principle of accuracy or quality: The information subject to treatment must be truthful, complete, accurate, up-to-date, verifiable and understandable. It is prohibited to the treatment of partial data, incomplete, or misleading.

Principle of transparency: In the treatment must be guaranteed the right of the holder to obtain at any time and without restrictions, information on the existence of data concerning him.

Principle of access and restricted circulation: The Personal Data, unless the public information may not be available on the Internet or other means of mass communication or disclosure, unless access is technically controllable to provide a knowledge restricted to holders or authorized third parties according to the law.

Principle of security: The information subject to treatment, it must be handled with the necessary technical, human and administrative measures necessary in order to provide security to the records to avoid their adulteration, loss, query, use or unauthorized access or fraudulent;

Principle of confidentiality: All persons involved in the processing of personal data are obliged to guarantee the reservation of the information, even after the end of its relationship with any The work includes the treatment, and may only perform supply or communication of personal data where this is appropriate to the development of the activities expressly authorized in the Law.

The purpose for which AZULU collects, stores, uses, purifies, analyzes, it circulates, transmits or transfers directly or indirectly personal data of the holder, such as but not limited to: name, surname, age, sex, marital status, email address, identification number, mailing address, date of birth and profession, is to: (

The personal data that is provided by the owner will be treated and used only for the purposes herein, and for a period counted from the time it is granted the authorisation to the time-frame for the entry into force of the society Bigfoot Colombia S.A.S. similarly, the information provided by the holder may be shared with law enforcement agencies, information providers, service providers, trade allies, partners, and third parties in general that provide services to AZULU or third parties on our behalf.

AZULU does not request or treatment on sensitive data.

AZULU ensures that the mechanisms through which makes use of the personal data are safe and confidential, as they have security mechanisms and the technological means suitable to ensure that they are stored in such a way as to prevent unwanted access by third parties.

In compliance with current legislation, AZULU has prepared the following mechanisms for obtaining the authorization or ratification by the Holders of Personal Data:

7.1 - The authorization may be recorded in a physical document, electronic or any other to ensure your reference, or by using a suitable technical or technological mechanism by which it can conclude that the holder has given permission to store your data in our data base. For the purposes has been defined for the sending of emails and/or the completion of forms on the web site and/or through,  technological mechanisms such as but not limited to a click of authorization. This authorization shall be issued by AZULU and made available to the holder prior to the processing of their personal data.

7.2 - With this authorisation procedure consent is expressly guarantees that the personal data holder knows and accepts that AZULU will collect, store, use, purged, analyze, circulate, transmit, transfer, updated or deleted in the terms of law, information for the purposes for which the effect will report prior to the granting of the authorization, and for the purpose contained in the present document.

7.3 - In the authorization requested by AZULU will be set as a minimum: (i) The complete identification of the person from whom personal data is collected; (ii) the authorization referred to in paragraph 7.2 above; (iii) the purpose of the processing of personal data, and; (iv) the rights of access, correction, updating or deletion of personal data supplied by the holder of the same.

7.4 - Is attached as Annex 1 the model of authorisation for the collection and treatment of personal data for the purpose of informing and allow the access information of AZULU, its subsidiaries, affiliates, subsidiaries, linked third party business partners and allies of these, related services, special offers, products, alliances, competitions, curriculum and content.

7.5 - It will be the responsibility of AZULU take the necessary measures to keep records of when and how it obtained the authorization on the part of the Owners.

7.6 - The Holders of Personal Data may request at any time and without restriction of any kind, the removal of your data and/or revoke the authorization granted for the treatment of the same.

7.7 - for the data collected before the issue of the Decree 1377 of 2013, that is to say on 27 June 2013 shall be as follows:

An email will be sent to all persons in respect of whom Personal Data has AZULU informing them about the implementation of the Policy of AZULU Processing of Personal Data and the method of exercising their rights.

In this e-mail will include the Privacy Notice referred to in Annex 2 of this Manual. Such notice shall include as a minimum: (i) Name and contact information of AZULU; (ii) the treatment to which will be submitted the data and the purpose of it; (iii) The rights to the holder, and; (iv) The access mechanisms by which holders can gain access to the data registered in the database of AZULU,in which will be announced the policy of Processing of Personal Data of AZULU and the substantial changes that occur to the same.

If the term of thirty (30) days from the date of dispatch of the notice referred to in subparagraph (a) above, the Holder has not responded or has not been contacted by any means with AZULU to request the deletion of your personal data, you may continue the treatment of the data. Is attached as Annex 3 The format of email should be sent to each one of the holders in respect of which AZULU possesses information before the entry into force of this policy.

In the same way, and to ensure that the privacy notice to all employees, suppliers, customers, users, and third parties who may have any kind of relationship with AZULU, published during a period of not less than eight (8) calendar days in the web page

Proviso: It shall be the duty of AZULU and in particular in the area of marketing lead registration and support of all the authorizations issued by the holder or in their absence, the dispatch of the communication referred to in subparagraph (c) of this article. All media must be available at all times during the processing of personal data and five (5) years. For the AZULU storage you can use computer, electronic, or any other technology.

To know, update and rectify your Personal Data AZULU. This right may be exercised, among others against partial data, fractional, inaccurate, incomplete, misleading, or those whose treatment is expressly prohibited or has not been authorized.

Request where appropriate proof of the authorization granted to AZULU.

Be informed by AZULU or the person in charge of the treatment, with respect to the use that has been given to their Personal Data.

Submit to the Superintendency of Industry and Commerce complaints for violations of the provisions of the 1581 Act of 2,012, prior exhaustion of the complaints procedure established in the policy of processing of personal data;

Revoke the authorization and/or request the deletion of personal data when in the treatment there is respect for the principles, rights and constitutional guarantees. Legal. In the same way, the recall and/or withdrawal will proceed when the Superintendency of Industry and Commerce has determined that those responsible or responsible have engaged in conduct contrary to this law and the Constitution.

Free access to their personal data which have been the subject of treatment.

To ensure that the holder of the information, at all times, the full and effective exercise of the right of habeas data.

Keep a copy of the communication and the respective authorization granted by the owner.

Inform the holder about the purpose of the collection and the rights to which they are entitled by virtue of the authorization granted.

Reserve the information under the conditions of security measures necessary to prevent their adulteration, loss, query, use or unauthorized access or fraudulent.

In the case of share and/or update the information with any treatment, ensure that the Authorization given by the holder is sufficient and that the information it is truthful, complete, accurate, up-to-date, verifiable and comprehensible.

Rectify the information when it is incorrect.

The processing of queries and claims made by the holder in the terms of the present Manual and the Policy of Processing of Personal Data AZULU.

Report at the request of the holder on the use of their data.

To inform the data protection authority when violations of the security codes and risks exist in the administration of the Cardholder Information.

Comply with the instructions and requirements to be provided by the Superintendency of Industry and Commerce.

Comply with the other provisions contained in the Law and in the regulatory decrees.

Record in the database the legend "claim" when appropriate.

Insert into the database of the legend "judicial" information in discussion once notified by the competent authority on judicial processes related to the quality of the personal data;

Refrain from circulating information that is being disputed by the holder and whose lock has been ordered by the Superintendency of Industry and Commerce; to

To allow access to the information only to those persons who can have access to it.

Toreport through the web page of AZULU that implements the new mechanisms to enable the holders of the information to give effect to their rights, as well as any modification to the Processing of Personal Data.

In response to the express prohibition contained in article 12 of Decree 1377 of 2,013 AZULU, fails to collect personal data from children and adolescents in their databases.

For this reason, it is the responsibility of all direct and indirect workers of AZULU, without exception, to comply with the policy of information processing, and in particular with the due attention of the petitions, complaints and claims that the holder submits to the company by this concept.

To exercise their rights, the holder or a person acting on his behalf, may submit their requests, complaints and/or grievances before AZULU by the following means: (

i) By e-mail to: [email protected]

ii) Phone: 7505352 in Bogota

(iii) Written Communication by electronic means via the web page of AZULU.

The area responsible for the management and treatment of the databases, as the case may be, will always be the responsibility of the customer service department who will be responsible for meeting the requests, complaints and claims made by the holder, in the exercise of their rights,

The attention of a query, request, complaint or claim (PQR), received in writing, e-mail, by electronic means, via telephone or verbally, it shall be handled according to the following procedure:

Inquiry: When the principal claim is a query, that is to say, you see the personal information of the owner, which rests on the basis of data of AZULU, the procedure shall be as set here:

The query is formulated using the AZULU formats contained in The web page or e-mail: [email protected]

Once received the consultation must respond to the Holder, whatsoever it may be, within ten (10) working days counted from the date of receipt of the same.

If it is not possible to meet the query within that term, it shall inform the Holder, stating the reasons for the delay and stating the date on which will attend the consultation, which may not exceed five (5) working days following the expiry of the first term.

Claim: When the principal claim is a claim, i.e., when the owner considers that the information contained in the database of AZULU should be subject to correction, updating or deletion, or when you notice the breach of any of the duties contained in the 1581 Act of 2012 by AZULU, the procedure shall be as set here:

- The claim shall be made by means of an application addressed to the responsible or in charge of information, with the number of identification of the holder, the description of the events giving rise to the claim, the direction and the documents it deems necessary.

-- If the claim is incomplete, it shall require the holder or who made his times within five (5) business days following the receipt of the claim in order to correct any errors.

-- If after two (2) months from the date of application for relief, the Holder or who does their times does not have the information required, it shall be deemed to have waived the claim.

-- Upon receipt of a complaint with the requirements, you must include the same in the databases in a term not exceeding two (2) business days identifying him with a legend that says "claim" and the reason for it. The legend must be maintained until the claim is decided.

-- If after two (2) months from the date of application for relief, the Holder or who does their times does not have the information required, it shall be deemed to have waived the claim.

-- The maximum term to meet the claim shall be fifteen (15) working days counted from the day following its receipt. When it is not possible to meet the claim within this term, the person concerned shall be informed of the reasons for the delay and the date by which you will serve your claim, which may not exceed eight (8) working days following the expiration of the term.

-- In the event that AZULU receives a complaint and is not competent to resolve it, shall, to the extent possible, to whom it corresponds in a maximum term of two (2) business days and inform of the situation to the person concerned.

-- When the application is submitted by a person other than the holder and is not attesting that the same acts on behalf of that, it shall be considered not to have been lodged.

In the same way we remind you that you have the right to know, update, rectify and request the deletion of your personal data at any time, for which we ask them to communicate its decision to the above-mentioned email account or through the web page