In HC Venture Capital S.A.S., the company that owns the trademark Archie Marketing, we respect people’s privacy and handle their personal data responsibly. This policy explains what data we collect, what we use it for, what your rights are and how you can exercise them, in accordance with Statutory Law 1581 of 2012, Decree 1377 of 2013 (compiled in Chapter 25 of Title 2 of Part 2 of Book 2 of the Single Regulatory Decree 1074 of 2015) and any other regulations that amend or supplement them.
1. Data controller
- Company name: HC Venture Capital S.A.S.
- Tax Identification Number (NIT): [NIT]
- Address: [Address], Medellín, Antioquia, Colombia
- Email: gerencia@archieagencia.com
- Telephone and WhatsApp: +57 313 635 1856
- Website: archieagencia.com
The department responsible for dealing with requests, enquiries and complaints regarding personal data is the Management, in the email gerencia@archieagencia.com.
2. Definitions
- Authorisation: the data subject’s prior, explicit and informed consent to the processing of their data.
- Database: an organised set of personal data being processed.
- Personal details: any information relating to, or which may be linked to, a specific or identifiable natural person.
- Sensitive data: data that affects the data subject’s privacy or the misuse of which may lead to discrimination, such as racial origin, political views, religious beliefs, health, sex life or biometric data.
- Data controller: a person who processes personal data on behalf of the data controller.
- Data controller: the person responsible for deciding on the data and its processing; in this case, HC Venture Capital S.A.S..
- Headline: a natural person whose personal data is being processed.
- Treatment: any processing of personal data, such as collection, storage, use, disclosure or erasure.
- Transfer: the transfer of data to a recipient who is responsible for processing, whether within or outside Colombia.
- Transmission: the transfer of data to a data processor, either within or outside Colombia, so that they may process it on behalf of the data controller.
3. Principles we apply
We process personal data in accordance with the principles of lawfulness, purpose, freedom, accuracy or quality, transparency, access and restricted circulation, security and confidentiality, as set out in Article 4 of Law 1581 of 2012.
4. Data we collect
- Contact and diagnostic forms: name, company, email address, WhatsApp number or telephone number, service of interest, estimated quote, message and preferred contact channel.
- Newsletter: email.
- Conversations via WhatsApp, email, phone calls or video calls: the information you provide us with so that we can process your request.
- Clients: contact details of your representatives and the team we work with, and the information required for invoicing and the performance of the contract.
- Suppliers, partners and candidates: contact details, business details and, in the case of candidates, the CV they send us.
- Navigation: IP address, device and browser type, pages visited and data collected via cookies, in accordance with the Cookie policy.
We do not request sensitive data via the Website. Should it ever be necessary to process such data, we will inform you that providing it is optional and will seek your express consent. The Website is not intended for minors and we do not intentionally collect their data.
5. Purposes of data processing
We use personal data to:
- Respond to your enquiries, arrange and carry out assessments, and prepare commercial proposals.
- To provide the contracted services, coordinate work with the client’s team, and submit reports and deliverables.
- Managing commercial relationships: invoicing, payments, debt collection and compliance with accounting, tax and legal obligations.
- Record and manage business contacts in our CRM, and track sales opportunities.
- To send you marketing information, our newsletter, invitations and updates about our services and those of Archie Tech, once you have given us your consent. You may withdraw this consent at any time.
- To measure and improve the website, our campaigns and the user experience using statistics.
- To assess suppliers, partners and candidates, and manage relationships with them.
- To deal with requests, enquiries and complaints, and to comply with orders from the relevant authorities.
- To safeguard the security of the Website and prevent fraud or misuse.
6. Authorisation
We seek your prior, explicit and informed consent, for example by ticking the consent box on our forms, by writing to us via WhatsApp or email, or by accepting a proposal. We keep a record of that consent.
No authorisation is required in the cases set out in Article 10 of Law 1581 of 2012, including: information requested by a public body in the course of its duties or by court order; data of a public nature; cases of medical or public health emergency; processing authorised by law for historical, statistical or scientific purposes; and data relating to the Civil Register of individuals.
7. Data subjects’ rights
As the data subject, you have the right to:
- To access, update and correct your personal data.
- Request proof of the authorisation you granted us, unless this is not required.
- To be informed, upon request, of how we have used your data.
- To lodge complaints with the Superintendency of Industry and Commerce regarding breaches of the law, once the consultation or complaint procedure with us has been exhausted.
- To withdraw your consent or request the erasure of your data where the principles, rights and legal safeguards are not respected, provided there is no legal or contractual obligation to retain it.
- Access your personal data free of charge.
8. How to exercise your rights
You can send your application to gerencia@archieagencia.com or via WhatsApp on +57 313 635 1856, stating your full name, identity number, contact details, a description of your request and, where applicable, any documents you wish to submit. If you are acting on behalf of someone else, please attach a document proving your authority to act on their behalf.
Enquiries
We respond to enquiries within a maximum of ten (10) working days from the date of receipt. If we are unable to do so within this timeframe, we will inform you of the reasons and the new response date, which will not exceed a further five (5) working days.
Complaints
If you believe that your personal data needs to be corrected, updated or deleted, or that we have breached the law, you may lodge a complaint. If your complaint is incomplete, we will ask you to complete it within the following five (5) working days; if two (2) months pass without you completing it, we will assume that you have withdrawn your complaint. We will respond to complaints within a maximum of fifteen (15) working days from the day following receipt of the complete complaint. If it is not possible to do so within that timeframe, we will inform you of the reasons and the new deadline, which will not exceed a further eight (8) working days.
9. Data processors and international data transfers
To carry out our operations, we use technology providers who process data on our behalf, such as web hosting, email, CRM, messaging, cloud storage, analytics and advertising platforms. Some of these providers have servers outside Colombia, which means your data may be transferred to other countries. In such cases, we require these providers to implement appropriate security and confidentiality measures, in accordance with Colombian law.
We do not sell or pass on your personal data to third parties. We only share it with affiliated companies, such as Archie Tech, where necessary to deal with your enquiry and with your consent, or where required by a competent authority.
10. Commercial communications
When we contact you for commercial purposes, we will do so only via the channels you have authorised and in accordance with the times and frequency set out in Law 2300 of 2023. You may ask us at any time to stop sending you commercial information by replying to our messages or by writing to gerencia@archieagencia.com.
11. Information security
We implement reasonable technical, organisational and administrative measures to protect personal data against loss, unauthorised disclosure, use or access, such as encrypted connections, access controls and backups. No system is completely foolproof; should an incident occur that affects your data, we will act in accordance with the law and notify the relevant authority where appropriate.
12. Data retention
We retain the data for as long as is necessary to fulfil the purposes described, for as long as a commercial or contractual relationship exists, or for as long as required by accounting, tax and legal regulations. We then securely delete or anonymise it.
13. Validity and changes
This policy comes into effect on 5 October 2026. We may update it to reflect changes in the law or in our processes. If the changes affect the purposes of data processing, we will inform you via the usual channels before implementing them and, where necessary, we will seek your consent again.