Legal

Personal data processing policy

Versión vigente desde el 16 de septiembre de 2026. Aplica al sitio web elrosarionaturalmente.com y a los canales de atención comercial del proyecto El Rosario Naturalmente.

The protection of your personal data matters to us. Read this policy to learn what data we collect, what we use it for, how we protect it and how you can exercise your rights as a data subject, in accordance with Law 1581 of 2012 and Decree 1377 of 2013 (compiled in Decree 1074 of 2015).

1. Data controller

Company name: FRIOMERK S.A.S.
NIT (Tax ID): 900.554.002-7
Domicile and address: Carrera 81C # 16-21, Cali, Valle del Cauca, Colombia
Project: El Rosario Naturalmente, Quimbaya, Quindío
Email: contacto@elrosarionaturalmente.com
Phone and WhatsApp: +57 312 851 5247
Business hours (Colombia time): Monday and Tuesday from 8:30 a.m. to 4:30 p.m.; Wednesday to Saturday from 9:00 a.m. to 4:30 p.m.; Sundays and holidays from 10:00 a.m. to 5:00 p.m.

2. Definitions

Authorization: prior, express and informed consent of the data subject for the processing of their data.
Database: an organized set of personal data subject to processing.
Personal data: any information linked or that can be associated with a specific or identifiable natural person.
Sensitive data: data that affects the data subject's privacy or whose misuse may lead to discrimination. This site does not request sensitive data.
Data processor: a natural or legal person who processes data on behalf of the data controller.
Data controller: the party that decides on the database and the processing; in this case, FRIOMERK S.A.S.
Data subject: the natural person whose data is being processed.
Processing: any operation on personal data, such as collection, storage, use, circulation, updating or deletion.
Transfer: the sending of data to a recipient who is in turn a data controller, inside or outside Colombia.
Transmission: the communication of data to a data processor, inside or outside Colombia, so that it processes the data on behalf of the data controller.

3. Principles

We apply the principles of legality, purpose, freedom, accuracy or quality, transparency, restricted access and circulation, security and confidentiality set out in Article 4 of Law 1581 of 2012. We only process data with the data subject's authorization, for disclosed purposes and with reasonable security measures.

4. Data we collect

Depending on the channel you use, we may collect:

Identification and contact data: name, WhatsApp or phone number, email address, city and country of residence.
Commercial interest data: lot of interest, estimated purchase timeframe, questions or messages you send us.
Browsing and visit source data: the page from which you contact us, the first page visited, the referring site and campaign parameters (for example, utm_source or ad click identifiers), as well as data collected through cookies as described in section 8.
Data needed for the purchase, if you decide to proceed: identity document, address and any other data required by the reservation, purchase agreement (promesa de compraventa) and deed process, including the verification required by anti-money laundering and counter-terrorist financing regulations.

We do not request sensitive data or data from children or adolescents through this site.

5. Purposes

FRIOMERK S.A.S. will process your data to:

Respond to your requests for information and contact you by WhatsApp, phone call, email or text message about El Rosario Naturalmente.
Advise you on lots, availability, prices, payment options and visits to the property, and schedule those visits.
Follow up commercially on your request and send you information, news and offers about El Rosario Naturalmente and other FRIOMERK S.A.S. projects, when you have authorized it.
Manage the reservation, the purchase agreement, payments, the deed and the delivery of the lot, if you decide to buy.
Comply with legal, accounting, tax, and anti-money laundering and counter-terrorist financing obligations.
Measure the performance of the site and of advertising campaigns to improve our service and content.
Handle inquiries, requests, complaints and claims related to your data.

6. Authorization

Authorization is obtained in a prior, express and informed manner, through means that allow it to be consulted later: the authorization checkbox on the site's forms, campaign forms on social media, data messages via WhatsApp or email, or physical documents. For the site's forms, we keep the date, time and version of this policy that was accepted.

Authorization is not required in the cases set out in Article 10 of Law 1581 of 2012, such as information required by a public entity in the exercise of its functions or by court order, and data of a public nature.

7. Transmission and transfer

Your data is stored on servers of technology providers that act as data processors, inside or outside Colombia, such as the site's hosting provider, the email service and, when used, customer management, messaging, analytics and advertising tools. These transmissions are made to fulfill the purposes of this policy and with providers that offer security and confidentiality conditions. We do not sell your data. We only transfer it to third-party data controllers when you authorize it, when the law permits it or by order of a competent authority.

8. Cookies and similar technologies

The site uses the browser's local storage to remember the page through which you arrived and the campaign parameters, in order to know which channel brought you when you leave us your details. It may also use first-party and third-party cookies, for example from analytics or advertising tools such as Google or Meta, to measure visits and the effectiveness of campaigns.

You can block or delete cookies and local storage from your browser settings. The site will keep working, although some measurements will no longer be recorded.

9. Rights of the data subject

As a data subject, you have the right to:

Know, update and correct your personal data.
Request proof of the authorization granted, except in cases where it is not required.
Be informed, upon request, about how your data has been used.
File complaints with the Superintendencia de Industria y Comercio (Superintendence of Industry and Commerce) for violations of the law, after having exhausted the inquiry or claim process with FRIOMERK S.A.S.
Revoke the authorization or request the deletion of your data when there is no legal or contractual duty to keep it.
Access, free of charge, your personal data that is being processed.

10. Procedure for inquiries and claims

You can exercise your rights by writing to contacto@elrosarionaturalmente.com with the subject line “Datos personales” (Personal data). The request must include: the name and identification of the data subject or of the person acting on their behalf, a description of what is being requested, a physical or email address for the response and any documents you wish to rely on.

Inquiries

They are answered within a maximum of ten (10) business days from receipt. If it is not possible to respond within that period, we will inform you of the reason and the new date, which will not exceed five (5) additional business days.

Claims

If the claim is incomplete, we will ask you to correct it within five (5) business days following its receipt. If two (2) months pass without it being completed, it will be understood that you have withdrawn it. A complete claim is handled within a maximum of fifteen (15) business days from the day following its receipt. If that is not possible within that period, we will inform you of the reason and the new date, which will not exceed eight (8) additional business days.

11. Responsible department

The sales and marketing department of FRIOMERK S.A.S. handles inquiries and claims about personal data through the channels in section 1.

12. Security and retention

We adopt reasonable technical, human and administrative measures to protect your data against tampering, loss, consultation, use or unauthorized access. Only authorized personnel access the information. We keep the data for as long as it is needed for the purposes described, while there is a commercial or contractual relationship, or for the time required by law. Afterwards it is deleted, unless there is a legal duty to keep it.

13. Effective date and changes

This policy has been in effect since September 16, 2026. Any substantial change will be published on this page with its update date and, when required by law, you will be informed before it is applied.