privacy policy

I. Objective and Scope

This policy regulates the processing of personal data of allies, employees, contractors, suppliers, users, and any natural person (hereinafter Data Subject) whose personal data is collected by any of the means enabled for it and is or will be treated by FVR Ltd, domiciled in the Cayman Islands with registration number 378038, who will be responsible for the processing of said data (hereinafter VélezReyes+).

Its purpose is to guarantee the rights of the Data Subject, inform the mechanisms and procedures to make those rights effective, questions, complaints, and claims, and to inform about the treatment to which all your personal information (hereinafter referred to as Personal Data) will be subjected, and the purpose said treatment.

It is essential to bear in mind that this policy does not apply to any third-party site that can be accessed from the VélezReyes+ website; in those cases, the processing of Personal Data will be governed exclusively by the privacy policy published by the third party, who will be the person in charge of the treatment; therefore, we recommend knowing and accepting said policy before supplying Personal Data.

II. Authorization

VélezReyes+, its employees, and authorized third parties must obtain consent from the Data Subject before collecting Personal Data, which may be consulted or verified by the Data Subject or any competent authority.

For this, VélezReyes+ makes available to the Data Subject the authorization for the processing of their personal data in the various scenarios in which the data is obtained, physically or digitally, in such a way that the Data Subject can express its authorization before treatment by VélezReyes+.

Without prejudice to the preceding, VélezReyes+ reserves the right to process information whose authorization is not required by the regulations applicable to the matter, in which case, the commitments of VélezReyes+ concerning the Data Subject are established in the present policy.

III. Information Content

In carrying out its activities, VélezReyes+ will collect the information described below:

  • Personal identification information, including but not limited to: i) first and last names; ii) telephone; iii) address and country of residence; iv) email and v) other information that allows users to be identified.
  • Corporate and/or financial information to analyze the possibility of financial support from VélezReyes+.
  • Professional information of employees or prospective employees: In addition to the aforementioned personal identification data, the following will be requested: i) Professional information; ii) titles; iii) both personal and professional references; iv) photos; v) Any other information that is necessary to analyze your possible hiring or give continuity to it.

It is essential to bear in mind that the provision of all the information is voluntary, for which the Data Subject knows and understands that if they do not wish to provide personal data or information that is necessary to participate in the programs, activities, or proposals that VélezReyes+ makes available to the Users, the Data Subject will not be able to be part of them.

In particular, we request that the user refrains from supplying third parties' personal data without the prior and express authorization to do so. If they do so with approval, the Data Subject must know and accept this Policy.

Our products and services offered may be directed to adults or minors, therefore, minors must always provide their personal data and, in general, relate to VélezReyes+, through their legal representatives.

IV. Sensitive Data

In the exercise of its purpose VélezReyes+ may collect and process Sensitive Data, such as, but not limited to gender, ethnicity, biometric data (images, photographs and or voice recording).

In such cases, the user acknowledges and accepts that the provision of sensitive data is free and voluntary and, in case of authorizing their treatment, VélezReyes+ guarantees that they will be treated with adequate security standards and proportional to their nature.

V. Treatment

In compliance with the regulations that regulate the processing of personal data and those that complement them, VélezReyes+, in the course of its activities, will collect, use, manage, store, analyze, anonymize, index, segment, create profiles, summarize, process, will transmit, transfer, verify the Personal Data and perform various operations with the Personal Data. In this order, the Personal Data Processed by VélezReyes+ will be subject only to the purposes indicated below or those authorized by the Data Subject at the time of the collection of Personal Data.

The Personal Data stored, used, or transmitted will remain in the VélezReyes+ database for as long as necessary for the purposes mentioned below in this Policy for which they were collected. In this way, the validity of the database is closely related to i) the validity of the authorization and ii) the purposes for which the personal data was collected, and as long as the commercial and philanthropic activities carried out by VélezReyes+ continue and will retain the conditions contractual agreements that gave rise to its creation.

VI. Purposes

VélezReyes+ and those who, with the prior authorization of the Data Subject, have access to Personal Data by Law, contract, or other binding documents will carry out the Treatment with the following purposes:

(i) Periodically sending VélezReyes+ information; (ii) Contacting them to analyze the possibility of working with VélezReyes+; (iii) Analyzing the Data and information provided to determine whether it is feasible for VélezReyes+ to invest resources in the organization or in favor of the beneficiary; (iv) Manage and inform VélezReyes+ strategies and charitable activities; (v) Structure and determine profiles of the Holders, users of platforms or web pages owned by VélezReyes+, based on the personal, professional or financial/corporate information made available to VélezReyes+; (vi) Specify, analyze and optimize existing and future own and third-party services; (vii) Export information on human resources, credit risks and control and prevention of money laundering; (viii) Build segmented databases; (ix) To carry out activities of filing, updating, storage and processing of information, either by itself or through third parties with whom such management is contracted; (x) Geo-localization; (xi) To carry out statistical analysis of the data collected to optimize the operation of the service provided; (xii) To guarantee the effectiveness and security of the transactions carried out with the users; (xiii) To execute, develop and in general fully comply with the services, programs or procedures offered to the users or beneficiaries of VélezReyes+; (xiv) To complement the information and, in general, to carry out the necessary activities to manage the requests, complaints and claims submitted by the users and third parties, and direct them to the areas responsible for issuing the corresponding answers; (xv) To elaborate market studies, statistics, surveys, analysis of market trends, satisfaction surveys on the services provided; (xvi) For the transmission of personal data to third parties with whom contracts have been entered into in order to perform and comply with the service offered by VélezReyes+ (xvii) To manage all the information necessary for compliance with tax obligations and commercial, corporate and accounting records; (xviii) To identify users when they enter the Website; (xix) To share Personal Data with service companies or outsourcing companies that contribute to improve or facilitate the operations of the Foundation, including payment methods, insurance or payment management intermediaries, transportation and courier companies, and advertising agencies; (xx) To carry out the transmission or transfer of the data with third legal or natural persons in order to comply with the user with the services offered or contracted; (xxi) To inform about new products or services and/or changes in the same; (xxii) To evaluate the quality of the services provided; (xxiii) Send to the physical mail, electronic mail, cell phone or mobile device, via text message (SMS and/or MMS) or through any other analog and/or digital means of communication, information about products and/or services, events or activities, in order to promote, invite, direct, execute, inform and generally carry out activities carried out by VélezReyes+ and/or third parties; (xxiv) Develop the process of selection, evaluation, and employment; (xxv) Support internal or external auditing processes.

VélezReyes+ will ensure that the policies of third parties have standards similar to those of this Policy by signing agreements, conventions, and/or contracts.

VII. Rights of the Data Subject

As Data Subjects of Personal Data, they have the following rights:

  1. Know, update and rectify their Personal Data.
  2. Request proof of the authorization granted for the processing of their Personal Data.
  3. Be informed by VélezReyes+ about the uses or Treatment made to their Personal Data.
  4. Revoke the authorization and/or request the deletion of the data and;
  5. Free access to their data that has been processed.
  6. Submit complaints to the competent authority regarding Personal Data.
  7. Refrain from providing sensitive data.

 

They may exercise their rights by presenting their citizenship card or any identification document. In the case of legal entities, minor natural persons or natural persons legally incapable of acting on their own behalf, their legal representatives may exercise their rights, providing the documents that authorize them to do so.

VIII. Procedures for exercising their rights

For the Data Subject to exercise their rights, we present the existing procedures applicable to processing their Personal Data.

aid rights may only be exercised by the Data Subject of the information, their assignees or representatives, after proof of their identity; For this, VélezReyes+ makes available to the Data Subject, requesting the emaill contacto@velezreyesmas.com, a the format called "Form for Complaints, Claims and/or Requests - Processing of Personal Data (PQRs)" and indicates the documents that must be attached to it.

To address any doubt, query, complaint, question, claim or request for any information related to your Personal Data, particularly to exercise their rights to know, update, rectify and delete the data or revoke the authorization granted, the Data Subject must contact VélezReyes+, by email to contacto@velezreyesmas.com.

a. Consultations

If the Data Subject is interested in consulting their personal information, he may request it from VélezReyes+ through the mechanisms enabled for it, indicated in this numeral.

Consultation requests 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 10 days, stating the reasons for the delay, and indicating the date on which his query will be attended, which in no case may exceed five (5) business days following the expiration of the first installment.

b. Claims

The Data Subject or his successors in title who consider that the information contained in a database should be corrected, updated, or deleted, or when they notice the alleged breach of any of the duties of VélezReyes+ as Data Controller, or when they want to revoke the authorization of data processing granted, they may file a claim with VélezReyes+, which will be processed under the following rules:

The claim must be presented by the Data Subject or his representative in the format that, for this purpose, made available to the Data Subject VélezReyes+, which may be requested by mail at contacto@velezreyesmas.com. If the claim received does not have complete information that allows it to be processed, that is, with the identification of the Data Subject, the description of the facts that give rise to the claim, the address, and accompanying the documents that he wants to assert, VélezReyes+ will request the interested party to send that information within five (5) days of receiving it. After two (2) months from the date of the request without the applicant submitting the required information, it will be understood that the claim has been withdrawn.

Suppose the person receiving the claim is not competent to resolve it. In that case, it will be transferred to the appropriate person within two (2) business days, and the interested party will be informed of the situation.

Once the complete claim is received, a tag that says, "claim in process" and the reason for it will be included in the Database maintained by the Responsible Party within a term not exceeding two (2) business days. Said tag must be kept until the claim is decided.

The maximum term to address the claim will be fifteen (15) business days counted from the day following the date of full receipt. When it is not possible to attend to it within said term, the interested party will be informed before the expiration of the period above of the reasons for the delay and the date on which their claim will be addressed, which in no case may exceed eight (8) business days following the expiration of the first term.

For all purposes, the request for data deletion and the revocation of the data processing authorization will be processed as a claim, and the terms contemplated in paragraph b above of this Policy will apply to them.

c. Suppression

The Data Subject has the right, at all times, to request VélezReyes+ the deletion (elimination) of their Personal Data when they consider that they are not being treated in accordance with the principles, duties and obligations provided for in the Law; They have ceased to be necessary or relevant for the purpose for which they were collected or; The period necessary for the fulfillment of the purposes for which they were collected has been exceeded.

This suppression implies the total or partial elimination of the personal information in accordance with the request of the Data Subject in the records, files, databases, or treatments carried out by VélezReyes+.

VélezReyes+ may deny the exercise of the same when the Data Subject has a legal or contractual duty to remain in the database; The elimination of data hinders judicial or administrative actions related to fiscal obligations, the investigation and prosecution of crimes, or the updating of administrative sanctions or; The data is necessary to protect the legally protected interests of the Data Subject; to carry out an action based on the public interest, or to comply with an obligation legally acquired by the Data Subject or VélezReyes+

d. Revocation of the Authorization

The Data Subject of the Personal Data can revoke the consent to processing their Personal Data at any time, as long as a legal provision does not prevent it. For this, VélezReyes+ will establish simple and free mechanisms that allow the Data Subject to revoke their consent, at least by the same means by which they granted it.

There are two ways in which the revocation of the consent can occur.

  • Total: It may be about all the consented purposes, that is, that VélezReyes+ must completely stop processing the Data Subject's data.
  • Partial: It can occur in certain types of treatment, such as for advertising or market research purposes. With this modality, other purposes of the treatment that VélezReyes+, in accordance with the authorization granted, can carry out and with which the Data Subject agrees are kept safe.

 

Due to the preceding, it will be necessary for the Data Subject, when submitting the consent revocation request to VélezReyes+, to indicate whether the revocation he intends to make is total or partial. In the second hypothesis, it must be indicated with which treatment the Data Subject is not satisfied.

There will be cases in which the consent, due to its essential nature in the relationship between the Data Subject and VélezReyes+ for the fulfillment of a contract or by legal provision, cannot be revoked, which the Data Subject will be informed of.

IX. Transfer and transmission of Data

The Data Subject expressly authorizes VélezReyes+ to transfer and/or transmit their Personal Data to third parties (partners, suppliers, clients, contractors) who may process the Personal Data to carry out the necessary steps so that VélezReyes+ can provide high-quality services to the Data Subject.

In any case, the third party receiving the Personal Data transferred or transmitted by VélezReyes+, shall be obliged to comply with this Processing Policy and the strict scope of the authorization previously given by the Data Subject to carry out the respective processing, in such a way that, at a minimum, the third party must match or exceed the requirements set forth in our Policy in order to be allowed to process the data.

X. Transformations, dissolution, liquidation, spin-off, or merger

The Data Subject expressly authorizes VélezReyes+ to share their Personal Data, including Sensitive Data, with legal entities other than VélezReyes+ that arise as a result of the dissolution and liquidation of VélezReyes+. In this way, if the Responsible Party transforms, either because a new legal entity was established, regardless of its corporate type, or because it has transferred all its assets to an already established legal entity, all Personal Data, including Sensitive Data, will be shared, or transmitted by the provisions of this Data Protection Policy.

XI. Security

VélezReyes+ will adopt the technical, technological, human, and administrative measures that are necessary to provide security to the records, trying to avoid their adulteration, loss, consultation, use or unauthorized or fraudulent access.

It will maintain mandatory security protocols for personnel accessing personal data and information systems.

Likewise, it will require its service providers to comply with at least the same security and data privacy standards to which VélezReyes+ is subject.

XII. Contact

To address any doubt, query, complaint, question, question, claim or request for any type of information related to their Personal Data, particularly to exercise their rights to know, update, rectify and delete the data or revoke the authorization granted, the Holder must contact VélezReyes+, by email to contacto@velezreyesmas.com.

The user service hours are from Monday to Friday from 8:00 am to 6:00 pm, making responsible for internal control over the processing of personal data to the administrative area, with email contacto@velezreyesmas.com, who will be responsible for monitoring and control of the PQRS through which the (s) Holder (s) will recognize and claim their rights.

XIII. Modifications

VélezReyes+ reserves the right to modify this policy at any time. Any modification will enter into force and will have effects against related third parties from its publication.

This document will be reviewed and updated (where applicable) at least once a year unless significant changes occur that require more frequent updating.

Any changes to this treatment policy will be published on the website www.velezreyesmas.com and will become effective within 24 hours of their publication.

XIV. Applicable regulations

This Data Processing Policy shall be governed by the applicable Cayman Islands personal data regulations, specifically The Data Protection Act (DPA).

XV. Validity

This data policy was updated on November 2, 2023 and this version is effective as of the same date.