Privacy Policy
1. Controller Identity
Enfoque Global COI (hereinafter "we", "us", or "the Company") is the data controller responsible for the personal data collected through the website enfoqueglobalcoi.com and through its educational consulting services.
Our registered address is Cl. 74 # 15 - 80 Oficina 203, Bogotá, Colombia. You may contact us at info@enfoqueglobalcoi.com or by telephone at +57 310 302 9920.
This Privacy Policy applies to all personal data we process in connection with the operation of this website and the provision of our educational services. It is governed primarily by Colombian Law 1581 of 2012 (Ley Estatutaria de Protección de Datos Personales) and its regulatory decrees, including Decree 1377 of 2013.
2. Legal Basis for Processing
We process personal data only when we have a lawful basis to do so. The legal bases we rely on are:
- Consent: When you voluntarily submit your personal data through our contact form, you provide express consent for us to process that data for the purposes described in this policy. You may withdraw your consent at any time by contacting us.
- Contractual necessity: When you engage with our educational services, we process data necessary to deliver those services.
- Legitimate interest: We may process certain technical data (such as server logs) for the legitimate interest of maintaining website security and operational integrity.
- Legal obligation: We may process or retain data when required to do so by applicable Colombian law.
3. Data We Collect
3.1 Data you provide directly
When you use our contact form, you may provide your full name, email address, telephone number, and a written message. Providing your name and email is required to respond to your inquiry. Your telephone number is optional.
3.2 Data collected automatically
When you visit our website, our servers automatically record certain technical information, including your IP address, browser type and version, operating system, referring URL, pages visited, and the date and time of your visit. This information is used solely for technical and security purposes and is not linked to your identity unless required for security investigations.
3.3 Cookie data
We use cookies and similar technologies as described in our Cookie Policy. Please refer to that document for full details on the types of cookies we use and how you can manage your preferences.
4. Purposes of Processing
We process personal data for the following purposes:
- To respond to inquiries submitted through our contact form and to provide information about our educational programs
- To deliver educational consulting services, individual sessions, webinars, and training programs to registered participants
- To send administrative communications related to services you have engaged with, including session confirmations and educational materials
- To maintain and improve the technical performance and security of our website
- To comply with applicable legal and regulatory obligations under Colombian law
- To analyze aggregate, anonymized website usage patterns for the purpose of improving our educational content and user experience
We do not use personal data for automated decision-making or profiling that produces legal or similarly significant effects on individuals.
5. Data Retention
We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law.
Contact form inquiries and associated personal data are retained for a period of two years from the date of submission, after which they are securely deleted unless an ongoing service relationship requires continued retention.
Data related to educational service delivery is retained for the duration of the service relationship and for five years thereafter, in accordance with Colombian commercial record-keeping requirements.
Technical server logs are retained for a maximum of twelve months and then deleted or anonymized.
6. Data Sharing and Disclosure
We do not sell, rent, or trade personal data to third parties for commercial purposes. We may share personal data in the following limited circumstances:
- Service providers: We may share data with trusted third-party service providers who assist us in operating our website and delivering our services (such as email delivery services and cloud hosting providers). These providers are contractually bound to process data only on our instructions and in accordance with applicable data protection law.
- Legal requirements: We may disclose personal data to public authorities or law enforcement when required by Colombian law, court order, or other legal process.
- Business transfers: In the event of a merger, acquisition, or transfer of all or part of our business, personal data may be transferred as part of that transaction, subject to equivalent data protection commitments.
7. International Data Transfers
Our primary operations are based in Colombia. If we transfer personal data to service providers located outside Colombia, we do so only where an adequate level of data protection is ensured, either through the recipient country's data protection framework, contractual safeguards, or other mechanisms recognized under Colombian data protection law.
Where personal data is transferred to countries not recognized as providing adequate protection, we implement appropriate safeguards such as standard contractual clauses or binding corporate rules, in accordance with the requirements of the Superintendencia de Industria y Comercio (SIC).
8. Your Rights
Under Colombian Law 1581 of 2012, you have the following rights regarding your personal data:
- Right of access (consulta): You may request confirmation of whether we process your personal data and obtain a copy of that data.
- Right of rectification (corrección): You may request correction of inaccurate or incomplete personal data we hold about you.
- Right of deletion (supresión): You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to any legal retention obligations.
- Right to withdraw consent (revocación): Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing prior to withdrawal.
- Right to lodge a complaint (queja): You have the right 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@enfoqueglobalcoi.com. We will respond to your request within the timeframes established by Colombian data protection law (generally fifteen business days for access requests).
9. Cookies
Our website uses cookies to enhance your browsing experience and to understand how visitors interact with our content. We use strictly necessary cookies that are essential for the website to function, as well as optional analytics and functional cookies that are activated only with your consent.
You can manage your cookie preferences at any time through the cookie settings panel that appears when you first visit the site, or by adjusting your browser settings. For full details, please see our Cookie Policy.
10. Security Measures
We implement appropriate technical and organizational measures to protect personal data against unauthorized access, disclosure, alteration, or destruction. These measures include encrypted data transmission (HTTPS/TLS), access controls limiting data access to authorized personnel only, and regular review of our security practices.
While we take data security seriously, no method of transmission over the internet or method of electronic storage is completely secure. We cannot guarantee absolute security, and we encourage you to take precautions when sharing personal information online.
11. Minors
Our educational services are directed at adult professionals. We do not knowingly collect personal data from individuals under the age of 18. If you believe a minor has submitted personal data to us, please contact us immediately at info@enfoqueglobalcoi.com and we will take steps to delete that data promptly.
12. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or our services. When we make material 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 or services after changes are posted constitutes your acknowledgment of the updated policy. If changes materially affect how we process your data, we will take appropriate steps to notify you.
13. Contact and Complaints
For any questions, requests, or concerns regarding this Privacy Policy or our data processing practices, please contact us:
Enfoque Global COI
Cl. 74 # 15 - 80 Oficina 203, Bogotá, Colombia
Email: info@enfoqueglobalcoi.com
Phone: +57 310 302 9920
If you are not satisfied with our response, you have the right to file a complaint with the Superintendencia de Industria y Comercio (SIC), the Colombian data protection authority, at www.sic.gov.co.