In accordance with the provisions of article 9 of Law 1581 of 2012 “By which general provisions for the protection of personal data are issued” and Articles 5, 6 and 7 of Decree 1377 of 2013 “By which Law 1581 of 2012 is partially regulated”, We inform you that this Personal Data Treatment Policy will apply to all databases and/or documents containing personal data collected by ELIASMAIDA2 ENTERTAINMENT S.A.S. (hereinafter EM2) when you visit our website www.em2enter.com (hereinafter the Platform), when you register your data to contact us, when you register your data as a User or when you register your data when you create a Profile.

I. Identification of the Data Controller.

EM2 with the Tax Number 900.621.196-4 and place of business at Calle 109 A # 17-34 in the city of Bogotá D.C., Colombia, email datospersonales@em2enter.com and cell phone (+57) 301 420 8860.

II. Definitions 

Authorization: prior, express, and informed consent given by the Owner so that the Data Controller can use the Personal Data.

Privacy Notice: is the verbal or written communication generated by the Data Controller and addressed to the Owner to inform him of the existence of the Personal Data Treatment Policy and how to access them, as well as the purpose(s) of the Treatment and use that is intended to give to the Personal Data of the Owner.

Database: organized set of Personal Data that is subject to Treatment.

Personal Data: any information that is linked or that may be associated with one or more natural persons, such as their name or identification number, or determinable, such as their physical features.

Processor: natural or legal person, public or private, who by himself or in association with others, performs the Treatment of Personal Data from the delegation made to him by the Data Controller, receiving instructions on how the Personal Data should be administered.

Data Controller: natural or legal person, public or private, who by itself or in association with others, decides on the purpose of the Database(s)and/or the Treatment.

Owner: natural person whose Personal Data are subject to Treatment.

Treatment: any operation or set of operations on Personal Data, such as collection, storage, use, circulation, or removal.

III. Treatment of Personal Data.

EM2 as Data Controller may collect, store, use, circulate, record, administer, report, process, employ, evaluate, analyze, confirm, update, and delete the Personal Data of the Owners for the following purposes:

• To carry out the relevant arrangements for the development of EM2’s social purpose regarding the compliance of the contract subscribed with the Owner of the information.
• Invite to Events and offer new Products to the Owner.
• Manage paperwork (requests, complaints, claims)
• Satisfaction surveys regarding Products displayed and offered through the Platform.
• Provide contact information to the commercial force and/or distribution network, telemarketing, market research and any third party with whom EM2 has a contractual relationship for the development of such activities.
• Contact the Owner through any means of communication to carry out surveys, studies and/or confirmation of Personal Data necessary for the execution of a contractual relationship.
• Contact the Owner through electronic means–SMS or chat to send news related to loyalty campaigns or service improvement.
• Contact the Owner via email to send statements or invoices regarding the obligations arising from the contract subscribed between the parties.
• Transfer Personal Data to comply with the anti-money laundering regulations that apply.
• Provide personal data to third parties with whom EM2 has subscribed a data treatment contract and it is necessary to deliverit for the fulfillment of the contractual obligations.
• Provide the information to third parties (Trademarks, Suppliers, Transporter,) with whom EM2 has contractual relationship and that it is necessary to deliver them for the fulfillment of the contract’s obligations.

IV. Rights of the Owners.

Your rights as Owner are those provided in the Constitution and Law 1581 of 2012 and which may be exercised at any time, especially the following:

• Know, update, and rectify your Personal Data before EM2. At any time, the Owner may request to update his data if he finds that it is partial, inaccurate, incomplete, fractional, that induces in error, or those whose Treatment is expressly prohibited or has not been authorized.
• Request proof of the authorization granted to EM2 for the treatment of your Personal Data. In accordance with the provisions of article 10 of Law 1581 of 2012, the authorization of the Owner will not be necessary in the following cases:
• Information required by a public or administrative entity in the exercise of its legal functions or by court order.
• Public data.
• Medical or health emergencies.
• Treatment of information authorized by law for historical, statistical, or scientific purposes.
• Data related to the Civil Registration.

1. EM2 must inform, previous request, theuse that has giventoyourPersonal
2. Filecomplaintsbefore the Superintendence of Industry and Commerce(SIC) for violations of the provisions ofthe Personal Data Protection Law andotherlawsthatmodify,add,orsupplement
3. Revoketheauthorizationand/orrequestthe removal ofthedatawhenthe Treatment doesnotrespectthe constitutional andlegalprinciples,rightsand Revocationand/orremovalshallproceedwhentheSIChasdeterminedthatEM2hasengagedin a conductcontrarytothislawandtheConstitution.
4. Access for free yourPersonalDatathathasbeen treated.
5. Refrainfromansweringquestionsaboutsensitivedataordatafromchildrenand

V. Autorization

EM2 must request prior, express, and informed authorization from the Owners of the Personal Data that is required to carry out the Treatment, which must be obtained by any means and may be subsequently consulted.

Thismanifestationofthe Owner canbegiventhroughdifferentmechanisms enabled byEM2,suchas:

• Inwriting, filling in theAuthorizationFormat(Annex1).
• Orally,bytelephoneconversationor
• Tacitly,throughconducts that allow concluding that theauthorizationwasgranted,forexample,throughtheirexpressacceptanceof the TermsandConditions of anactivitywithinwhich the authorization of the participants is required for the Treatment of their Personal Data.
• Express, by using the Platform, sending information or creating a Profile.

VI. Sensitive Data.

The Owner has the right not to respond to any sensitive information requested by EM2, related, among others, to data on its racial or ethnic origin, membership of trade unions, social or human rights organizations, political, religious, sexual life, biometric or health data.

VII. Data of Minors.

The provision of the personal data of minors is optional and must be done with the authorization of the parents or legal representatives of the minor.

VIII. Attention to Petitions, Complaints, and Inquiries.

To file requests, complaints, and inquiries and exercise the rights contained herein, you can contact EM2, from Monday through Friday from 8:00 AM – 1:00 PM and 2:00 PM to 6:00 PM on the cell phone (+57) 301 420 8860, at the place of business located at Calle 109 A # 17-34 in the city of Bogota D.C., or by email at datospersonales@em2enter.com

IX. Procedures to exercise inquiries and claims

INQUIRIES

The Owners or their successors in title may consult the personal information of the Owner that EM2 has in their Databases. You can file your inquiries from Monday through Friday from 8:00 AM – 1:00 PM and 2:00 PM to 6:00 PM on the cell phone (+57) 301 420 8860, at the place of business located at Calle 109 A # 17-34 in the city of Bogota D.C., or by email at datospersonales@em2enter.com

EM2 must provide all the information contained in the individual record or that is related to the Owner’s ID. When filing the request for inquiries, the following documents must be submitted:

• Owner: Attach a copy of the ID.
• Successor: ID, death certificate, document that proves thequalityinwhichheactsand ID numberofthe
• Legal representative and/or attorney: ID (Registration Certificate), document that proves the quality in which it acts (POA) and ID number of the Owner.

Inquiries will be attended within a maximum period of ten (10) working days from the date of receipt. When it is not possible to attend the inquiry within this term, the interested party will be informed, expressing the reasons of the delay, and indicating the date on which his inquiry will be attended, which in no case may exceed five (5) working days following the expiration of the first term.

CLAIMS

The Owner or its successors who consider that the information contained in a database should be corrected, updated, or removed, or when they notice a breach of any of the duties contained in this law, may file a claim before EM2, which will be processed under the following rules:

• Theclaimwillbe filedbeforeEM2fromMondaytoFriday from 8:00AM–1:00PMand2:00PMto6:00PMtothecellphone(+57)3014208860,atthe place of business atCalle109A # 17-34inthe city of BogotáC.,orbyemail at datospersonales@em2enter.com. The request must indicate the Owner’s ID, the facts that support the claim and contact details. If the claim is incomplete, the interested party will be required within the following five (5) days from the receipt of the claim to complete the failures. If two (2) months after the interested party is required, the required information is not sent to EM2, it is understood that the interested party has given up the claim. If the person who receives the claim is not competent to resolve it, he/she shall transfer it to the competent person within a maximum of two (2) working days and inform this to the interested party.
• Once the complete claim is received, it shall be included in the database with a legend that says, “pending claim” within two (2) business days. Such legend must be maintained until the claim is decided.
• The maximum term to solve the claim will be fifteen (15) business days from the day following the receipt of the claim. When it is not possible to attend the claim within said term, the reasons of the delay will be informed to the interested party and the date on which his claim will be solved, which in no case may exceed eight (8) working days following the expiration of the first term.

X. Information obtained passively.

When the services contained within the Platform are accessed or used, EM2 may collect information passively through information management technologies, such as “cookies”, through which information about the hardware and the device is collected. Computer software, IP address, browser type, operating system, domain name, access time and the addresses of the websites of origin; By using these tools, Users Personal Data is not directly collected. Information will also be collected of the websites the person visits most frequently on these websites in order to know their browsing habits. However, the User of the Platform has the possibility of configuring the operation of “cookies”, according to the options of his internet browser.

XI.  Security of personal data.

EM2 in strict application of the Security Principle in the Treatment of Personal Data, will provide the necessary technical and administrative measures to provide security to the records avoiding their adulteration, loss, consultation, use or unauthorized or fraudulent access. EM2’s obligation and liability are limited to having the right means for this purpose. EM2 does not guarantee the total security of your information and is not responsible for any consequences arising from technical failures or improper entry by third parties to the Database or files on which the Personal Data under treatment remain.

XII. VALIDITY

This policy is effective since January 1^st, 2014.