POLICY
Personal Data Processing Policy
Last updated: June 25, 2026
This Personal Data Processing Policy (the “Policy”) describes how AVM Partners (“we”, “us” or the “Data Controller”), which operates the website avm.partners (the “Website”), collects, stores, uses, circulates and deletes the personal data of users (“you” or the “Data Owner”). This Policy is issued in compliance with Colombian Statutory Law 1581 of 2012, Decree 1377 of 2013 and related regulations governing the protection of personal data in Colombia (the Habeas Data regime).
Where we process the data of individuals located in the European Union, we will additionally apply, as relevant, the General Data Protection Regulation (Regulation (EU) 2016/679, “GDPR”).
1. Data Controller
The Data Controller responsible for your personal data is:
- Legal name: AVM Partners
- Tax ID (NIT): —
- Registered address: Bogotá, Colombia
- Email: info@avm.partners
- Phone: +57 320 9032006
2. Governing Principles
The processing of personal data is governed by the principles of legality, purpose, freedom, accuracy or quality, transparency, restricted access and circulation, security and confidentiality, in accordance with Article 4 of Law 1581 of 2012.
3. Personal Data We Collect
We may collect and process the following categories of personal data:
- Identification and contact data you provide through our forms, such as name, email address, telephone number and company.
- Communication data contained in the messages you send us through our contact or enquiry forms.
- Marketing data such as your email address and preferences when you subscribe to our newsletter.
- Technical and browsing data such as IP address, browser type, device, pages visited and interaction, collected through cookies and similar technologies.
We do not knowingly request sensitive data (data affecting privacy or whose misuse may lead to discrimination, such as racial or ethnic origin, religious beliefs, health or biometric data). Should we require such data, we will request your express authorisation and inform you that you are not obliged to provide it.
4. Purposes of Processing
Your personal data will be processed for the following purposes:
- To attend to and respond to your enquiries, requests or queries submitted through the Website.
- To manage commercial relationships and provide our services.
- To send you marketing communications, news and our newsletter, where you have authorised this.
- To analyse and improve the operation of the Website.
- To comply with legal obligations and respond to requests from competent authorities.
5. Authorisation of the Data Owner
In accordance with Law 1581 of 2012, the processing of your data requires your prior, express and informed authorisation. This authorisation is obtained when you complete our forms by ticking the relevant box, or by any other means that allows it to be retained. By granting it, you declare that you have been informed of the purposes of processing and of your rights as a Data Owner.
6. International Transfer of Data
Some of our service providers (for example, email marketing platforms such as Mailchimp / Intuit Mailchimp and analytics providers) may store or process data outside Colombia, including in the United States. By accepting this Policy and granting your authorisation, you expressly consent to such international transfer and transmission of your data, in accordance with Article 26 of Law 1581 of 2012. We put in place contractual measures with such providers to ensure an adequate level of protection for your information.
7. Rights of the Data Owner (Habeas Data)
As the Data Owner, you have the right to:
- Access, update and rectify your personal data.
- Request proof of the authorisation granted.
- Be informed, upon request, of the use made of your data.
- File complaints with the Superintendence of Industry and Commerce (SIC) for breaches of the law.
- Withdraw authorisation and/or request deletion of data where appropriate under the law.
- Access your personal data that has been processed, free of charge.
If you are located in the European Union, you additionally have the rights granted under the GDPR, including data portability and the right to object to processing.
8. Procedure to Exercise Your Rights
You may exercise your rights or submit petitions, queries and complaints by sending a request to info@avm.partners, stating your name, contact details, a description of the facts and the right you wish to exercise. We will address queries within a maximum of ten (10) business days and complaints within a maximum of fifteen (15) business days, in accordance with Law 1581 of 2012.
9. Data Retention
We will retain your data for as long as necessary to fulfil the purposes described and while a relationship with you exists, as well as during applicable legal periods. Marketing data will be retained until you withdraw your authorisation or unsubscribe.
10. Information Security
We adopt reasonable technical, human and administrative measures to protect your personal data and prevent its alteration, loss, unauthorised consultation, use or access. However, no transmission over the internet can be guaranteed as completely secure.
11. Cookies
The Website uses cookies and similar technologies. Non-essential cookies are only activated with your consent. For further details, please see our Cookie Policy.
12. Term and Changes
This Policy is effective from the date of its publication and will remain in force until amended. We may update it periodically; the version in force will always be available on the Website with the date of the last update.