DATA PROCESSING POLICY

1. OBJECTIVE
The purpose of this Policy is to establish the guidelines to prevent the improper use and handling of personal data processed by Gabriel Gutiérrez.

2. REACH
This policy applies to all personal information registered in the databases of Gabriel Gutiérrez, who acts as the person responsible for the processing of personal data. 
Gabriel Gutiérrez will process your personal data for the sole purpose of providing you with its travel and experience creation services since this processing is essential for the execution of the agreed services.
This Policy establishes the rights to know, update, rectify, delete and in general any other right granted by applicable legislation and the responsibilities of the Owners of the information.

3. OBLIGATIONS
This policy is mandatory and strict compliance for Gabriel Gutiérrez.

4. DEFINITIONS
Authorization:  Prior, express and informed consent of the Owner to carry out the Processing of personal data.
Database:  Organized set of personal data that is subject to Treatment.
Personal data:  Any information linked or that can be associated with one or several specific or determinable natural persons.
Data Processor:  Natural or legal person, public or private, who, by themselves or in association with others, carries out the Processing of personal data on behalf of the Data Controller.
Responsible for the Treatment:  Natural or legal person, public or private, who alone or in association with others, decides on the database and/or the Processing of the data.
Owner : Natural person whose personal data is the subject of Treatment.
Processing:  Any operation or set of operations on personal data, such as collection, storage, use, circulation or deletion.
Privacy Notice: Verbal or written communication generated by the person responsible, addressed to the owner for the processing of their personal data, through which they will be informed about the existence of the information processing policies that will be applicable to them, the way to access to them and the purposes.

5. PRINCIPLES
Principle of legality regarding data processing: The processing of personal data carried out by Gabriel Gutiérrez is subject to the provisions of Law 1581 of 2012 and other provisions.
Principle of purpose: The processing of personal data carried out by Gabriel Gutiérrez is aimed at a legitimate purpose in accordance with the applicable regulation and informed to the owner of the information.
Principle of freedom: Whenever any personal data processing activity is carried out, the prior express and informed consent of the owner will be required.
Principle of truthfulness and quality: All information collected by Gabriel Gutiérrez will be complete, accurate, updated, verifiable and understandable.
Principle of transparency: The rights of the owner of personal data enshrined in the applicable local regulations are guaranteed at all times.
Principle of restricted access and circulation: Treatment may only be carried out by persons authorized by the owner and/or by the persons provided for in this law, and the limits derived from the nature of the personal data will also be respected.
Security principle: The information subject to Treatment by Gabriel Gutiérrez will be handled with the technical, human and administrative measures that are necessary to provide security to the records, avoiding their adulteration, loss, consultation, unauthorized or fraudulent use or access.
Principle of confidentiality: All persons to whom this data processing policy applies will be obliged to guarantee the confidentiality of the information, even after their relationship with any of the tasks included in the processing has ended.

6. RESPONSIBLE FOR THE TREATMENT
GABRIEL GUTIERREZ, identified with citizenship card No. 72,357,696 with main address in the city of Barranquilla, Republic of Colombia. Page www.wanderloop.com.co Telephone 3045751089 in the city of Barranquilla.

7. TREATMENT AND PURPOSE
The treatment that Gabriel Gutiérrez will carry out with personal information will be as follows: 
Collection, storage, use and circulation of personal data
Communicate information about services through the website
Communications via email.
Conduct marketing research.
Contact through different social networks.
Evaluations on quality of services.
Carry out the relevant procedures for the development of the operations of the corporate purpose
Make invitations to events and offer new products and services
Management of procedures such as requests, complaints, claims and requests
Conduct satisfaction surveys
Contact the Owner via email to send extracts, account statements or invoices in relation to the obligations derived from the contract entered into between the parties. 
Transmit personal data outside the country to third parties with whom GABRIEL GUTIERREZ has signed a data processing contract and it is necessary to deliver it to them for the fulfillment of the contractual object. 
Provide information to third parties with whom GABRIEL GUTIERREZ has a contractual relationship and it is necessary to deliver it to them for the fulfillment of the contracted object. 

8. PROCESSING OF SENSITIVE DATA
In the event that personal data of children and adolescents is obtained, authorization will be obtained from the minor’s parents or guardian.

9. RIGHTS OF THE OWNERS
As the owner of your personal data, you have the right to: 
Know, update and rectify your Personal Data. Being able to exercise this right, among others, against partial, inaccurate, incomplete, fragmented, misleading data, or those whose Processing is expressly prohibited or has not been authorized.
Request proof of the Authorization granted except when it is expressly excepted as a requirement for Treatment, as established by the applicable regulations. 
Be informed, upon request, regarding the use that has been given to your Personal Data and Sensitive Personal Data. 
Submit complaints to the SIC for violations of the provisions of the law and other regulations that modify, add or complement it. 
Revoke the Authorization and/or request the deletion of the data when the Processing does not respect constitutional and legal principles, rights and guarantees. The revocation and/or deletion will proceed under the terms of the applicable legislation. 
Access free of charge, as established in the applicable regulations, to your Personal Data and Sensitive Personal Data that have been processed.

10. TYPE OF INFORMATION TO COLLECT
Name
Last name
Sex:
Birthdate
Country of Residence
Type and number of identity document
Nationality
Email
Cell phone number
Civil status
Emergency Contact Name
Emergency Contact Telephone or Cell Number
Questions to Establish Profile
Photocopy of Passport
Tourism License
Photocopy of ID Card or Identity Document
Past court

11. OTHER INFORMATION TO BE COLLECTED BY THE USE OF THE SERVICES
IP adress
Date, time and time spent on the platform.

Domain
Computer hardware and software
Internet connection.
Operating system data
Information regarding what is selected on the platform as well as what is selected.
Information about cell phone use.
Data that allows you to identify the type of device and its configurations
Everything reviewed by users, travelers or hosts.
Source URL
Pages that led to the platform
Geographic information
All information relevant to cookies
Information about payment transactions, such as the payment instrument used, date and time of payment, amount, payment instrument expiration date, billing zip code and other data related to the transaction.

12. COOKIE CONSENT 
By accessing our website, you agree to the use of cookies in accordance with this policy, unless you have adjusted your browser settings to reject them. You can change your cookie preferences at any time.

13. INTERNATIONAL TRANSFERS
Gabriel Gutiérrez may transfer personal data to third parties or other countries, provided that the legal and security requirements established by applicable laws are met.

14. DATA OBTAINED FROM THIRD PARTIES
In some cases, information will be collected through third parties, which will be framed within the following events:
Services Contracted with Third Parties: if you have services contracted with social networks (X, Instagram, Pinterest, Facebook, TikTok, among others), the owner grants us authorization for the social media platforms mentioned above to provide us with the information it controls. or the one that you have authorized through the privacy settings on that platform
Contracted Providers: Since the services offered by Gabriel Gutiérrez function as an intermediary between Travelers and Hosts Within the Platform, travelers, hosts and users will be able to rate their experiences and share information about the aforementioned, which may be used by Gabriel Gutierrez. 
Alternative Sources: for security reasons, such as money laundering, terrorist financing, risk assessment, information is received from information centers that are external entities.

15. ATTENTION TO REQUESTS, QUERIES AND CLAIMS 
The customer service area (area or person in charge of handling queries and complaints) is the department in charge of processing the holders’ requests to make their rights effective. 

16. COMMERCIAL COMMUNICATIONS
Gabriel Gutiérrez will only contact the owner for commercial purposes. 

17. PROCEDURE FOR THE EXERCISE OF THE RIGHT OF HABEAS DATA 
In compliance with the regulations on the protection of personal data, Gabriel Gutiérrez presents the procedure and minimum requirements for the exercise of your rights: 
For the filing and attention of your request, we ask you to provide the following information: 
Full name and surname 
contact information (physical and/or electronic address and contact telephone numbers), 
Means to receive a response to your request, 
Reason/fact that gives rise to the claim with a brief description of the right you wish to exercise (know, update, rectify, request proof of the authorization granted, revoke it, delete, access the information) 
Signature and identification number. 
The maximum period provided by law to resolve your claim is fifteen (15) business days, counting from the day following the date of receipt. When it is not possible to attend to the claim within said term, GABRIEL GUTIERREZ will inform the interested party of the reasons for the delay and the date on which their claim will be attended to, which in no case may exceed eight (8) business days following the expiration. of the first term.
Once the terms indicated by Law 1581 of 2012 and the other rules that regulate or complement it have been met, the Owner who is denied, totally or partially, the exercise of the rights of access, updating, rectification, deletion and revocation, may bring your case to the attention of the Superintendency of Industry and Commerce – Delegation for the Protection of Personal Data.
In accordance with the Law, Gabriel Gutiérrez may deny access to Personal Data, or revoke authorization, or request deletion of data in the following cases:
When the applicant is not the Owner of the Personal Data, or the successor in title, or the legal representative is not duly accredited for this purpose.
When the applicant is not a public or administrative entity in the exercise of its legal functions, or there is no court order;
When the Owner has a legal duty to remain in the database;
When the applicant’s personal data is not found in its database;
When the rights of a Third Party are violated; 
When there is a legal impediment, or the resolution of a competent authority, that restricts access or personal data, or does not allow rectification, cancellation or opposition thereof; and
When the rectification, cancellation or opposition has been previously made.

18. ACCEPTANCE OF THE POLICY
By registering or using our services, you expressly accept and consent to the processing of your personal data in accordance with the terms and conditions established in this data processing policy.

19. MODIFICATIONS 
Gabriel Gutiérrez may autonomously modify formal, procedural or substantial aspects of these documents at any time.

20. TERM OF STORAGE OF INFORMATION
Personal data will be saved and maintained by Gabriel Gutiérrez for as long as necessary for the development of the relationship with the owners and in accordance with the authorization granted by them. 

21. VALIDITY
This Policy for the Processing of Personal Data applies as of September 1, 2023.
The databases in which personal data will be recorded will have a validity equal to the time in which the information is maintained and used for the purposes described in this policy. Once that purpose(s) is fulfilled and as long as there is no legal or contractual duty to retain your information, your data will be deleted from our databases.