Privacy Policy

Who we are

Suggested text: Our website address is: https://www.therichbaby.com.

For the purposes of this Information Treatment Policy, EDITORIAL THE RICH BABY , its affiliates, associates, allies or current and future controlling or controlled companies, will be TRB and our clients, subscribers, users, collaborators, advertisers, among others, will identify themselves as CLIENTS AND / OR USERS .

2. ABOUT YOUR PERSONAL DATA.

To access the services and benefits of the ” TRB ” Interaction spaces , and to be able to interact in them, you must voluntarily and freely provide your true, non-sensitive personal identification data, such as: name, surname, identification, age, gender, telephone, physical and electronic address, country, city and other necessary data that are requested in the registration process or filling out forms.

3. PURPOSE OF THE DATA PROCESSING.

The information provided by our clients and / or users is required to be captured, collected, stored, used, processed, circulated, shared, reproduced, adapted, extracted, summarized, transferred, processed with or without the help of technology for the following purposes : (i) Provide required services and products; (ii) Inform about new products or services that are related or not with the one contracted or acquired by the client; (iii) Comply with obligations contracted with our clients; (iv) Report changes to our products or services; (v) Evaluate the quality of the service, (vi) Conduct internal studies on consumer habits, (vii) Send to physical, electronic, cell phone or mobile device, – via text messages (SMS and / or MMS) or through any other analog and / or digital means of communication created or to be created, commercial, advertising or promotional information about the products and / or services, events and / or promotions of commercial type or not of these, in order to promote, invite, direct, execute, inform and in general, carry out campaigns, promotions or contests of a commercial or advertising nature. (viii) Share with third parties, including the transfer and transmission of your personal data to third countries for the purposes related to the operation. carry out campaigns, promotions or contests of a commercial or advertising nature. (viii) Share with third parties, including the transfer and transmission of your personal data to third countries for the purposes related to the operation. carry out campaigns, promotions or contests of a commercial or advertising nature. (viii) Share with third parties, including the transfer and transmission of your personal data to third countries for the purposes related to the operation.

4. INFORMATION SECURITY.

” TRB ” is committed to protecting its users as ourselves from unauthorized access or any unauthorized modification, disclosure or destruction of the information we possess.

The transmission of data through the Internet or any wireless network cannot be guaranteed to be 100% secure, therefore they assume and know that from its use there is a probable risk of vulnerability. However, we have security protocols and access to our information, storage and processing systems.

As a result, while we try to protect your personal information, we cannot ensure or guarantee the security of any information that you transmit to “ TRB ”, so you do so at your own risk.

In particular:

• We have controls over our information systems that allow us to maintain a better quality of your information.
• We review our information collection, storage and processing practices, including our physical security measures, to protect against unauthorized access to systems.
• TRB has deployed a series of internal procedures to guarantee the correct functioning of the technical security schemes. However, TRB is not responsible for any consequence derived from improper or fraudulent entry by third parties to the database and / or for any technical failure in maintenance.
• We restrict access to the personal information that we possess from our clients and / or users, to employees and contractors who need to know such information in order to process it for us, and who are subject to strict contractual confidentiality obligations and may be sanctioned or fired if not meet these obligations.

5. STORAGE OF YOUR PERSONAL DATA.

5.1. The personal data of all our clients and / or users will be stored in a database that is located behind a firewall for greater security. The server where the database rests is physically protected in a safe place. Only authorized personnel can access it and therefore the personal data of our clients and / or users.

6. RECEIPT OF YOUR INFORMATION / USE OF YOUR INFORMATION.

6.1. The private information of users and / or customers is in principle intended to provide the service for which it was linked.

6.2. When you register to be able to participate in the different spaces of Interaction of ” TRB ” or physically fill out our forms, you are asked in the process for basic information such as name, surname, occupation, age, address, date of birth, telephone, among others.

6.3. When you submit a request for assistance and / or complaint, we may ask for personal information.

6.4. We may ask for personal information at other times, you are free to provide it or not.

6.5. We can automatically receive and record information in our server logs from your browser, including your IP address, your computer name, the type and version of your web browser, referring addresses, among others. We can also record the visits you make to any of the websites or applications to which you enter that are owned by ” TRB “

6.6. There may be circumstances in which we may need to disclose personal information about a user and / or customer. (The employment of other companies to perform functions on our behalf, such as order fulfillment, providing customer service, sending email and correspondence, processing credit card payments, hiring servers located inside or outside of Colombia, or other functions necessary in the development of the commercial activity of TRB ).

6.7. The obligations included in these practices regarding the care or management that ” TRB ” must give to the personal information of its clients and / or users do not apply when the information is required by a public or administrative entity in the exercise of its legal functions or by court order.

6.8. The Information provided by Clients and / or Users may be used by “ TRB” de acuerdo con lo establecido en estas prácticas y con el fin de: : (i) Proveer servicios y productos requeridos; (ii) Informar sobre nuevos productos o servicios que estén relacionados o no con el contratado o adquirido por el cliente; (iii) Dar cumplimiento a obligaciones contraídas con nuestros clientes; (iv) Informar sobre cambios de nuestros productos o servicios; (v) Evaluar la calidad del servicio, (vi) Realizar estudios internos sobre hábitos de consumo, (vii) Enviar al correo físico, electrónico, celular o dispositivo móvil, – vía mensajes de texto (SMS y/o MMS) información comercial, publicitaria o promocional sobre los productos y/o servicios, eventos y/o promociones de tipo comercial o no de estas, con el fin de impulsar, invitar, dirigir, ejecutar, informar y de manera general, llevar a cabo campañas, promociones o concursos de carácter comercial o publicitario. (viii) Compartir, incluyendo la transferencia y transmisión de sus datos personales a terceros países para los fines relacionados con la operación.

6.9. In the event of a sale of the majority of the company's assets, customer and / or user information may be transferred to the buyer as part of the business establishment;

7. USE OF COOKIES.

” TRB ” may use cookies to personalize and facilitate the navigation of customers and / or users on its Site. Cookies are only associated with anonymous customers and / or users and their computer and do not provide references that allow the deduction of personal data of customers and / or users. Customers and / or users may configure their browser to notify and reject the installation of cookies sent by TRB , without affecting the ability of customers and / or users to access the Contents.

8. LINKS.

In the event that the Site contains links or hyperlinks to other Internet sites, TRB will not exercise any type of control over said sites and content. In no case will TRB assume any responsibility for the contents of any link belonging to a third party website, nor will it guarantee the technical availability, quality, reliability, accuracy, breadth, veracity, validity and constitutionality of any material or information contained in any of said hyperlinks. or other Internet sites. Likewise, the inclusion of these external connections will not imply any type of association, merger or participation with the connected entities.

9. KNOWLEDGE, UPDATE AND RECTIFICATION OF PERSONAL INFORMATION OF USERS.

At any time, customers and / or users may request ” TRB ” as the person responsible for personal data, to provide information about them, to update, rectify them, and they may also include new data if they wish, delete or exclude them. of the database unless the data is absolutely necessary for the provision of the service to which the client and / or user is registered and / or registered and wants to remain in it, otherwise, it will be disconnected and / or completely inactivated from the same.

If the user and / or client wishes to exercise their rights and therefore update, rectify, delete, among others,

10. RIGHTS OF CLIENTS AND / OR USERS (1581 OF 2012, ARTICLE 8).

• Know, update and rectify your personal data in front of the Treatment Managers or Treatment Managers. This right may be exercised, among others, against partial, inaccurate, incomplete, fractioned, misleading data, or those whose Treatment is expressly prohibited or has not been authorized;
• Request proof of the authorization granted to the Responsible for the Treatment except when expressly excepted as a requirement for the Treatment, in accordance with the provisions of article 10 of Law 1581 of 2012 .
• Be informed by the Treatment Manager or the Treatment Manager, upon request, regarding the use that has been given to your personal data.
• Present before the Superintendency of Industry and Commerce complaints for infractions to the provisions of this law and the other regulations that modify, add or complement it.
• Revoke the authorization and / or request the deletion of the data when the principles, rights and constitutional and legal guarantees are not respected in the Treatment. The revocation and / or deletion will proceed when the Superintendency of Industry and Commerce has determined that in the Treatment the Responsible or Person in Charge have engaged in conduct contrary to this law and the Constitution.
• Free access to your personal data that have been subject to Treatment.

11. VALIDITY.

The client and / or User accepts and acknowledges that this authorization will be valid from the moment it was accepted and during the time that EDITORIAL THE RICH BABY carries out the activities of its corporate purpose, that is, until 2050 or more in case that it be extended.

12. CUSTOMER SERVICE.

For inquiries, claims, complaints or to exercise the rights of the user or client, you can contact “ TRB ” at the email contact@therichbaby.com

EDITORIAL THE RICH BABY reserves the right to modify, at any time, unilaterally its privacy policy and the processing of personal data. We will not limit your rights derived from this Information Processing Policy and the use of personal data without your express consent. We will publish any modification of this Privacy Policy and use of personal data on this page. In addition, we will keep the previous versions of this Privacy Policy and the use of personal data.

This service is not aimed at children and adolescents, so it is requested that you refrain from continuing with the registration and / or service in the event that you are a person under eighteen (18) years of age .

14. HOW TO ACCESS, RECTIFY AND UPDATE YOUR PERSONAL DATA OR REQUEST THE DELETE OF THE SAME?

You have the right to access your personal data and the details of their treatment, as well as to rectify them, update them if they are inaccurate or request their elimination when you consider that they are excessive or unnecessary for the purposes that justified their obtaining or oppose the treatment of the same for specific purposes.

To exercise the aforementioned right you can do so by telephone or in writing, for which you must take into account the following:

visit our website www.therichbaby.com

CLAIMS:

Once the complete claim has been received, a legend that says “claim in process” and the reason for it will be included in the database maintained by EEC , within a period of no more than two (2) business days . Said legend must be kept until the claim is decided.
The maximum term to attend the claim will be fifteen (15) business days from the day following the date of receipt. When it is not possible to attend to it within said term, the interested party will be informed before the expiration of the aforementioned period of the reasons for the delay and the date on which their claim will be attended, which in no case may exceed eight (8) business days following the expiration of the first term.

INQUIRIES:

Queries will be answered within a maximum term of ten (10) business days from the date of receipt. When it is not possible to attend the query within said term, the interested party will be informed before the expiration of ten (10) days , stating the reasons for the delay and indicating the date on which the query will be attended, which in no case may exceed five (5) business days following the expiration of the first term.

15. INTERNAL MANUAL OF POLICIES AND PROCEDURES REGARDING PERSONAL DATA PROTECTION.

CHAPTER I GENERAL PROVISIONS

ARTICLE 1. APPLICABLE LEGISLATION. This manual was prepared taking into account the provisions contained in articles 15 and 20 of the Political Constitution, Law 1581 of 2012 “By which general provisions for the protection of personal data are issued” and Decree 1377 of 2013.

ARTICLE 2. SCOPE OF APPLICATION. This manual applies to the treatment of personal data collected and handled by EDITORIAL THE RICH BABY , its affiliates, associates, allies or current and future controlling or controlled companies.

ARTICLE 3. DATABASES. The policies and procedures contained in this manual apply to the databases of each existing and future business unit, which may consist of, but not necessarily limited to, the following: Editorials, Subscriptions, Forums, Advertising, Media Electronic, Distribution, Payroll, Billing, Collections, Accounting whose validity period is the same as the duration of the company EDITORIAL THE RICH BABY registered with the Bogotá Chamber of Commerce, that is, 2050 or more in case it is extended.

ARTICLE 4. PURPOSE. By means of this manual, the provisions of literal k) of article 17 of Law 1581 of 2012 are complied with, which regulates the duties of those responsible for the processing of personal data, among which is to adopt an internal manual of policies and procedures to guarantee adequate compliance with the law and especially, for the attention of inquiries and complaints.

It also has the purpose of regulating the procedures for the collection, handling and processing of personal data carried out by EDITORIAL THE RICH BABY , in order to guarantee and protect the fundamental right of habeas data within the framework of the provisions of the same law. .

ARTICLE 5. DEFINITIONS: For the purposes of applying the rules contained in this manual and in accordance with the provisions of Article 3 of Law 1581 of 2012, it is understood as:

1. Authorization: Prior, express and informed consent of the Holder to carry out the Processing of personal data;
2. Privacy Notice: A physical, electronic document or in any other format generated by the Responsible Party that is made available to the Owner for the processing of their personal data. In the Privacy Notice, the Owner is informed of the information regarding the existence of the information treatment policies that will be applicable, the way to access them and the characteristics of the treatment that is intended to be given to personal data.
3. Database: Organized set of personal data that is subject to Treatment.
4. Personal data: Any information linked to or that may be associated with one or more specific or determinable natural persons;
5. Private data : It is the data that due to its intimate or reserved nature is only relevant for the owner.
6. Sensitive data: Sensitive data is understood to be those that affect the privacy of the Holder or whose improper use may generate discrimination, such as those that reveal racial or ethnic origin, political orientation, religious or philosophical convictions, union membership, social, human rights organizations or organizations that promote the interests of any political party or that guarantee the rights and guarantees of opposition political parties, as well as data related to health, sexual life and biometric data.
7. Responsible for the Treatment: Natural or legal person, public or private, that by itself or in association with others, carries out the Treatment of personal data on behalf of the Person Responsible for the Treatment;
8. Responsible for the Treatment: Natural or legal person, public or private, that by itself or in association with others, decides on the database and / or the Treatment of the data;
9. Owner: Natural person whose personal data is subject to Treatment;
10. Treatment: Any operation or set of operations on personal data, such as the collection, storage, use, circulation or deletion of the same.

ARTICLE 6. PRINCIPLES. The principles that are established below, constitute the general parameters that will be respected by EDITORIAL THE RICH BABY in the processes of collection, use and processing of personal data.

1. Principle of purpose: The treatment of personal data collected by EDITORIAL THE RICH BABY must obey a legitimate purpose of which the Holder must be informed;
2. Principle of freedom: Treatment can only be carried out with the prior, express and informed consent of the Holder. Personal data may not be obtained or disclosed without prior authorization, or in the absence of a legal or judicial mandate that relieves consent;
3. Principle of truthfulness or quality: The information subject to Treatment must be truthful, complete, exact, updated, verifiable and understandable. Processing of partial, incomplete, fractional or misleading data is prohibited;
4. Principle of transparency: In the Treatment, the right of the Holder to obtain from EDITORIAL THE RICH BABY at any time and without restrictions, information about the existence of data concerning him must be guaranteed ;
5. Principle of access and restricted circulation: Personal data, except for public information, may not be available on the Internet or other means of dissemination or mass communication, unless the access is technically controllable to provide restricted knowledge only to the Holders or authorized third parties. ;
6. Security principle: The information subject to Treatment by EDITORIAL THE RICH BABY , must be protected through the use of technical, human and administrative measures that are necessary to provide security to the records avoiding their adulteration, loss, consultation, use or unauthorized or fraudulent access;
7. Principle of confidentiality: All persons who intervene in the Processing of personal data are obliged to guarantee the reservation of the information, even after the end of their relationship with any of the tasks included in the Processing.

CHAPTER II AUTHORIZATION

ARTICLE 7. AUTHORIZATION. The collection, storage, use, circulation or deletion of personal data by EDITORIAL THE RICH BABY requires the free, prior, express and informed consent of the owner thereof. EDITORIAL THE RICH BABY, in its capacity as responsible for the processing of personal data, has provided the necessary mechanisms to obtain the authorization of the owners, guaranteeing in any case that it is possible to verify the granting of said authorization.

ARTICLE 8. FORM AND MECHANISMS TO GRANT AUTHORIZATION. The authorization can be recorded in a physical, electronic document or in any other format or medium that guarantees its subsequent consultation. The authorization will be issued by EDITORIAL THE RICH BABY and will be made available to the owner prior to the processing of their personal data, in accordance with the provisions of Law 1581 of 2102.

With the consent authorization procedure, it is guaranteed that the owner of the personal data has been made known, both the fact that their personal information will be collected and used for specific and known purposes, as well as that they have the option of knowing any alternative to them. and the specific use that has been made of them. The foregoing in order for the owner to make informed decisions regarding their personal data and control the use of their personal information. The authorization is a statement that informs the owner of the personal data:

1. Who collects (responsible or responsible)
2. What it collects (data that is collected)
3. What do you collect the data for (the purposes of the treatment)
4. How to exercise rights of access, correction, updating or deletion of the personal data provided
5. If sensitive data is collected

ARTICLE 9. PROOF OF AUTHORIZATION. EDITORIAL THE RICH BABY will adopt the necessary measures to keep records of when and how they obtained authorization from the owners of personal data to process them.

ARTICLE 10. PRIVACY NOTICE: The Privacy Notice is the physical document, electronic or in any other format, which is made available to the Owner for the processing of their personal data. Through this document, the Holder is informed of the information regarding the existence of the information processing policies that will be applicable, the way to access them and the characteristics of the treatment that is intended to be given to personal data.

ARTICLE 11. MINIMUM CONTENT OF THE PRIVACY NOTICE. The Privacy Notice, at a minimum, must contain the following information:

1. The identity, address and contact details of the Data Controller;
2. The type of treatment to which the data will be subjected and the purpose thereof, and
3. The general mechanisms provided by the Controller so that the Holder is aware of the information treatment policy and the substantial changes that may occur in it. In all cases, you must inform the owner how to access or consult the information processing policy.
4. The rights that assist the owner.

ARTICLE 12. PRIVACY NOTICE AND INFORMATION PROCESSING POLICIES. EDITORIAL THE RICH BABY will keep the model of the privacy notice that was transmitted to the Holders while the processing of personal data is carried out and the obligations derived from it remain. For the storage of the model, EDITORIAL THE RICH BABY may use computer, electronic or any other technology.

CHAPTER III RIGHTS AND DUTIES

ARTICLE 13. RIGHTS OF THE INFORMATION HOLDERS. In accordance with the provisions of article 8 of Law 1581 of 2012, the owner of personal data has the following rights:

1. Know, update and rectify your personal data in front of EDITORIAL THE RICH BABY , in its capacity as data controller.
2. Request proof of the authorization granted to EDITORIAL THE RICH BABY , in its capacity as Data Controller.
3. Be informed by EDITORIAL THE RICH BABY upon request, regarding the use that has been given to your personal data;
4. Present before the Superintendence of Industry and Commerce complaints for infractions to the provisions of Law 1581 of 2012, once the consultation or claim process has been exhausted before the Data Controller.
5. Revoke the authorization and / or request the deletion of the data when the principles, rights and constitutional and legal guarantees are not respected in the Treatment.
6. Free access to your personal data that have been subject to Treatment.

ARTICLE 14. DAILY DUTIES IN RELATION TO THE PROCESSING OF PERSONAL DATA. EDITORIAL THE RICH BABY will keep in mind, at all times, that personal data are the property of the people to whom they refer and that only they can decide on them. In this sense, it will use them only for those purposes for which it is duly empowered, and in all cases respecting Law 1581 of 2012 on the protection of personal data.

In accordance with the provisions of article 17 of Law 1581 of 2012 EDITORIAL THE RICH BABY undertakes to permanently comply with the following duties in relation to the processing of personal data:

1. Guarantee the Holder, at all times, the full and effective exercise of the right to habeas data;
2. Keep the information under the security conditions necessary to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access;
3. Carry out in a timely manner, this is in the terms provided in articles 14 and 15 of Law 1581 of 2012, the updating, rectification or deletion of the data;
4. Process the queries and claims made by the Holders in the terms indicated in article 14 of Law 1581 of 2012;
5. Insert in the database the legend “information in judicial discussion” once notified by the competent authority about judicial processes related to the quality or details of the personal data;
6. Refrain from circulating information that is being controversial by the Holder and whose blocking has been ordered by the Superintendency of Industry and Commerce;
7. Allow access to information only to people who can have access to it;
8. Inform the Superintendency of Industry and Commerce when there are violations of the security codes and there are risks in the administration of the information of the Holders;
9. Comply with the instructions and requirements issued by the Superintendency of Industry and Commerce.

CHAPTER IV ACCESS, CONSULTATION AND CLAIM PROCEDURES

ARTICLE 15. RIGHT OF ACCESS: The power of disposition or decision that the owner has about the information that concerns him, necessarily entails the right to access and know if his personal information is being processed, as well as the scope, conditions and generalities of said treatment. In this way, EDITORIAL THE RICH BABY must guarantee the owner their right of access in three ways:

1. The first implies that the owner can know the effective existence of the treatment to which their personal data are subjected.
2. The second, that the owner can have access to their personal data that are in the possession of the person in charge.
3. The third implies the right to know the essential circumstances of the treatment, which translates into the duty of EDITORIAL THE RICH BABY to inform the owner about the type of personal data processed and each and every one of the purposes that justify the treatment.

PARAGRAPH: EDITORIAL THE RICH BABY will guarantee the right of access when, after accreditation of the identity of the owner or legal status of his representative, the details of personal data are made available to him, free of charge, through electronic means that allow direct access of the Holder to them. Said access must be offered without a time limit and must allow the holder the possibility of knowing and updating them online.

ARTICLE 16 CONSULTATIONS. In accordance with the provisions of article 14 of Law 1581 of 2012, the holders or their successors in title may consult the personal information of the Holder that resides in any database. Consequently, EDITORIAL THE RICH BABY will guarantee the right of consultation, providing the holders with all the information contained in the individual record or that is linked to the identification of the Holder.

For the attention of requests for consultation of personal data EDITORIAL THE RICH BABY guarantees:

1. Enable electronic means of communication or others that it considers pertinent.
2. Establish forms, systems and other simplified methods, which must be informed in the privacy notice.
3. Use the customer service or claims services that you have in operation.

In any case, regardless of the mechanism implemented to attend to consultation requests, they will be attended to within a maximum term of ten (10) business days from the date of receipt. When it is not possible to attend the query within said term, the interested party will be informed before the expiration of ten (10) days, stating the reasons for the delay and indicating the date on which the query will be attended, which in no case may exceed five (5) business days following the expiration of the first term.

ARTICLE 17. CLAIMS. In accordance with the provisions of article 14 of Law 1581 of 2012, the Holder or his successors in title who consider that the information contained in a database should be subject to correction, updating or deletion, or when they notice the alleged breach of any of the duties contained in Law 1581 of 2012, they may file a claim with the Data Controller, which will be processed under the following rules:

1. The claim may be submitted by the Owner in the formats that EDITORIAL THE RICH BABY presents on its website for this purpose. If the claim received does not have complete information that allows it to be processed, that is, with the identification of the Holder, the description of the facts that give rise to the claim, the address, and accompanying the documents that you want to assert, the interested party within five (5) days of receipt to correct the faults. After two (2) months have elapsed from the date of the request without the applicant submitting the required information, it will be understood that the claim has been withdrawn. If for any reason EDITORIAL THE RICH BABYreceives a claim that in reality should not be directed against him, he will transfer it to the corresponding person within a maximum term of two (2) business days and will inform the interested party of the situation.
2. Once the complete claim is received, a legend that says ” claim in process ” and the reason for it will be included in the database maintained by EDITORIAL THE RICH BABY , within a term not exceeding two (2) business days . Said legend must be kept until the claim is decided.
3. The maximum term to attend the claim will be fifteen (15) business days from the day following the date of receipt. When it is not possible to attend to it within said term, the interested party will be informed before the expiration of the aforementioned period of the reasons for the delay and the date on which their claim will be attended, which in no case may exceed eight (8) business days following the expiration of the first term.

ARTICLE 18. IMPLEMENTATION OF PROCEDURES TO GUARANTEE THE RIGHT TO SUBMIT CLAIMS. At any time and free of charge, the owner or his representative may request EDITORIAL THE RICH BABY to rectify, update or delete their personal data, after proving their identity.

The rights of rectification, updating or deletion can only be exercised by:

• The owner or his successors in title, after proof of their identity, or through electronic instruments that allow them to identify themselves. Your representative, after accreditation of the representation.
• When the request is made by a person other than the owner and it is not proven that it acts on his behalf, it will be considered not submitted.

The request for rectification, updating or deletion must be submitted through the means enabled by EDITORIAL THE RICH BABY indicated in the privacy notice and contain, at least, the following information:

1. The name and address of the owner or any other means to receive the answer
2. The documents that prove the identity or personality of its representative.
3. The clear and precise description of the personal data with respect to which the owner seeks to exercise any of the rights.
4. In case of other elements or documents that facilitate the location of personal data.

Paragraph 1. RECTIFICATION AND UPDATING OF DATA. EDITORIAL THE RICH BABY has the obligation to rectify and update at the request of the owner, the information of the latter that turns out to be incomplete or inaccurate, in accordance with the procedure and the terms indicated above. In this regard, the following will be taken into account:

In requests for rectification and updating of personal data, the owner must indicate the corrections to be made and provide the documentation that supports their request. EDITORIAL THE RICH BABY has full freedom to enable mechanisms that facilitate the exercise of this right, as long as they benefit the owner. Consequently, electronic or other means that it deems pertinent may be enabled. EDITORIAL THE RICH BABY may establish forms, systems and other simplified methods, which must be informed in the privacy notice and which will be made available to interested parties on the website. EDITORIAL THE RICH BABY will use the customer service or attention services that it has in operation, as long as the response times are not greater than those indicated by article 15 of Law 1581 of 2012. Each time EDITORIAL THE RICH BABY makes a tool available new to facilitate the exercise of their rights by the holders of information or modify existing ones, it will inform you through its website.

Paragraph 2. DATA SUPPRESSION. The owner has the right, at all times, to request EDITORIAL THE RICH BABY to suppress (delete) their personal data when:

1. Consider that they are not being treated in accordance with the principles, duties and obligations set forth in Law 1581 of 2012.
2. They are no longer necessary or relevant for the purpose for which they were collected.
3. The period necessary for the fulfillment of the purposes for which they were collected has been exceeded

This deletion implies the total or partial elimination of personal information in accordance with what is requested by the owner in the records, files, databases or treatments carried out by EDITORIAL THE RICH BABY It is important to bear in mind that the right of cancellation is not absolute and the person in charge can deny the exercise of the same when:

The request to delete the information will not proceed when the owner has a legal or contractual duty to remain in the database. The elimination of data hinders judicial or administrative actions related to tax obligations, the investigation and prosecution of crimes or the updating of administrative sanctions. The data is necessary to protect the legally protected interests of the owner; to carry out an action based on the public interest, or to comply with an obligation legally acquired by the owner.

If the cancellation of personal data is appropriate, EDITORIAL THE RICH BABY must carry out the deletion in such a way that the deletion does not allow the recovery of the information.

ARTICLE 19. REVOCATION OF THE AUTHORIZATION. The owners of personal data can revoke their consent to the processing of their personal data at any time, as long as a legal provision does not prevent it. For this, EDITORIAL THE RICH BABY must establish simple and free mechanisms that allow the owner to revoke their consent, at least by the same means by which they granted it.

It should be taken into account that there are two modes in which the revocation of consent can be given. The first one may be about all the consented purposes, that is, that EDITORIAL THE RICH BABY must completely stop treating the owner's data; the second can occur on certain types of treatment, such as for advertising or market research purposes. With the second modality, that is, the partial revocation of consent, other purposes of the processing that the person in charge, in accordance with the authorization granted, can carry out and with which the owner agrees are kept safe.

Therefore, it will be necessary for the owner at the time to raise the request for revocation of consent to EDITORIAL THE RICH BABY , indicate in it if the revocation he intends to carry out is total or partial. In the second hypothesis, it must be indicated with which treatment the owner is not satisfied.

There will be cases in which the consent, due to its necessary nature in the relationship between the owner and the person responsible for the fulfillment of a contract, by legal provision cannot be revoked.

The mechanisms or procedures that EDITORIAL THE RICH BABY establishes to respond to requests for revocation of consent may not exceed the deadlines set to address claims as indicated in article 15 of Law 1581 of 2012.

CHAPTER V INFORMATION SECURITY.

ARTICLE 20. SECURITY MEASURES. In development of the security principle established in Law 1581 of 2012, EDITORIAL THE RICH BABY will adopt the technical, human and administrative measures that are necessary to grant security to the records avoiding their adulteration, loss, consultation, use or unauthorized or fraudulent access .

ARTICLE 21. IMPLEMENTATION OF SECURITY MEASURES. EDITORIAL THE RICH BABY will maintain mandatory security protocols for personnel with access to personal data and information systems.

The procedure must consider, as a minimum, the following aspects:

1. Scope of the procedure with detailed specification of the protected resources.
2. Measures, norms, procedures, rules and standards aimed at guaranteeing the level of security required in Law 1581 of 2012
3. Functions and obligations of the personnel.
4. Structure of the personal databases and description of the information systems that process them.
5. Notification, management and response procedure for incidents.
6. Procedures for making backup copies and data recovery.
7. Periodic controls that must be carried out to verify compliance with the provisions of the security procedure that is implemented
8. Measures to be taken when a support or document is to be transported, discarded or reused.
9. The procedure must be kept up to date at all times and must be reviewed whenever relevant changes occur in the information system or in its organization.
10. The content of the procedure must be adapted at all times to the current provisions regarding the security of personal data.

CHAPTER VI FINAL PROVISIONS.

ARTICLE 22 EDITORIAL THE RICH BABY appoints the Coordinator of the Call Center – Customer Service in addition to other functions, to fulfill the function of protection of personal data and to process the requests of the holders, for the exercise of the rights of access, consultation, rectification, updating, deletion and revocation referred to in Law 1581 of 2012.