Data Privacy Policy

In compliance with Law 1581 of 2012, which establishes provisions for the protection of personal data, DAVID BEJARANO, in his capacity as the data controller, informs the general guidelines on this matter:

General Information

The person responsible for the processing of your personal data is DAVID BEJARANO, identified with Foreigner ID No. 626574, with main offices located at CR 50 72-205, Barrio Lagos del Cacique, Bucaramanga.

Website: www.pullsayo.com

Contact Information:
The Customer Service channels provided by DAVID BEJARANO are:

Phone: +57 317 346 6081
Email: coach@davidbejarano.com

Data Processing Policy

Through this policy, DAVID BEJARANO, in compliance with his legal and regulatory duty, seeks to effectively guarantee the constitutional right of protection of personal and family privacy for all citizens, by establishing prompt instruments and controls to ensure proper handling of the information under his administration.

This policy sets out the terms, conditions, and purposes under which DAVID BEJARANO, as the controller of personal data obtained through his various service channels, processes the information of all individuals who, at any time, for reasons related to the entity’s activities, have provided personal data (hereinafter referred to as “Data Subject”).

These terms and conditions apply to any registration of personal data made in person and/or virtually for the purpose of accessing any product, service, or benefit of DAVID BEJARANO. The Data Subject provides their information freely and voluntarily and acknowledges that they have read and expressly accept these terms and conditions.

DAVID BEJARANO is directly responsible for processing Personal Data; however, he reserves the right to delegate such processing to a third party. DAVID BEJARANO requires the processor to comply with and implement appropriate guidelines and procedures for the protection and strict confidentiality of personal data.

Purpose of Data Processing

Authorization for the processing of your personal data allows DAVID BEJARANO to collect, transfer, store, use, circulate, delete, share, update, and transmit such data in order to fulfill the following purposes:

1. Validate information in compliance with the legal requirement of customer due diligence applicable to DAVID BEJARANO.

2. Process and protect contact data (name, personal identification, physical and electronic addresses, social networks, and phone numbers).

3. Authorization includes the ability for DAVID BEJARANO to send messages and notifications containing information on workshops, training sessions, virtual and in-person courses, information about services and promotions, as well as the delivery of DISC personality test results. However, he reserves the right to delegate the test analysis to a third party, in accordance with the service portfolio and through the channels previously provided by the Data Subject.

4. Carry out collection and debt recovery actions, asset investigations, as well as send account status information, balances, and outstanding payments under existing contracts for the execution of commercial relationships.

5. Request and receive from public entities and/or private companies the personal, financial, employment, and social security information stored in their databases, for collection and legal actions.

Rights of the Data Subject

The Data Subject is informed of the rights provided by data protection laws, which DAVID BEJARANO guarantees through compliance with the defined procedures:

• To know, update, and rectify their personal data with the Entity.

• To request proof of the authorization granted, except when expressly excluded as a requirement in accordance with Article 10 of Law 1581 of 2012.

• To be informed, upon request, of the use given to their personal data.

• To file complaints before the Superintendence of Industry and Commerce for violations of this law or related regulations.

• To revoke the authorization and/or request the deletion of data when constitutional and legal rights, principles, and guarantees are not respected.

• To access their personal data free of charge.

Information Security

DAVID BEJARANO is committed to the proper use and handling of personal data contained in his databases, preventing unauthorized access, disclosure, modification, or destruction of such information.

Security protocols, physical access controls, firewall systems, intrusion detection mechanisms, and vulnerability monitoring are in place to safeguard client data. Access to databases is restricted, even for employees, who are all bound by confidentiality agreements.

Passwords created by users for portal access are encrypted, known only by the user, and must be updated periodically. DAVID BEJARANO cannot access or retrieve them. Users are advised to maintain their own device and network security when accessing the portals.

Cookies may be used to track user navigation within the portals, without providing personal identification. Users can configure browsers to reject cookies without restricting portal access.

Storage of Personal Data

Personal data voluntarily provided through registration on DAVID BEJARANO’s web portals is stored in secure databases protected by firewalls and physically secured servers. Only authorized personnel bound by confidentiality agreements may access them.

Modifications to the Policy

DAVID BEJARANO reserves the right to unilaterally modify this policy at any time. Any changes will be published, and previous versions will be retained. Continued use of services after notification constitutes acceptance of the new guidelines.

Disclosure of Information

By accepting this policy, the Data Subject acknowledges that DAVID BEJARANO may provide information to affiliated or allied entities, judicial or administrative authorities, and other state entities lawfully requesting it. Information may also be subject to internal or external audits, subject to confidentiality.

Validity of the Policy

This data processing policy is effective as of the date of its approval by DAVID BEJARANO.

Inquiries and Complaints

For inquiries, complaints, or to exercise rights as a client or user, you may contact any of the Customer Service channels made available by DAVID BEJARANO, within the timeframes established by Law 1581.

This data processing policy was issued on the 15th day of December, 2019.