PRIVACY POLICY AND TREATMENT OF PERSONAL DATA ON THE INTERNET OF BETTINA SPITZ Y CIA LTDA.

BETTINA SPITZ Y CIA LTDA., as the person responsible for the processing of personal data, has adopted the following Policy in order to provide users with a clear overview of the personal data it collects, the treatment given to them and the procedures that The User has at his disposal to be able to make his rights effective. BETTINA SPITZ Y CIA LTDA respects the right to intimacy and privacy of users. its Policy is to comply with Law 1581 of 2012, Decree 1377 of 2013 and other applicable current legislation. in this sense, BETTINA SPITZ Y CIA LTDA will take the necessary measures for the due protection of the rights of users on the Website www.bettinaspitz.com (hereinafter, Website), in terms of privacy and use of data. personnel supplied. The term "Personal Information" refers to information that identifies the User.

1. RESPONSIBLE FOR THE TREATMENT AND/OR USE OF PERSONAL DATA.

The legal entity that is responsible for the processing of personal data provided through the WEBSITE and therefore the database in which they are located, is the company BETTINA SPITZ Y CIA LTDA., a company identified with NIT 830071630 -5 and with main address at Carrera 7c No. 108a-98, in Bogotá DC, Colombia. Whose telephone number and contact email are (571) 6207181 and [email protected], respectively.

2. PROTECTING YOU

BETTINA SPITZ Y CIA LTDA is committed to protecting your privacy. This Personal Data Processing Policy describes the information that BETTINA SPITZ Y CIA LTDA collects from its users and visitors and what may happen with said information. If you do not agree with this, do not use THE WEBSITE. Our Personal Data Treatment Policy ensures that any information provided by users will be kept private and secure. To attest to this, in this document we set out the details of the information we collect and how we use it. We will never collect information without your explicit consent. For this purpose, we clarify that you will not be able to register on THE WEBSITE until you grant your authorization for the processing of your personal data. In this sense, our Website will require you to give us your prior, express and informed consent by selecting the box that provides the following: "I have read and I agree with the Terms and conditions and with the policies and treatment of personal data". If you do not select this box before clicking on the "REGISTER" button, your data will not be stored in our database. This document is an integral part of the Terms and Conditions of BETTINA SPITZ Y CIA LTDA.

3. INFORMATION WE COLLECT.

We collect personally identifiable information (IP), which includes, but is not limited to, e-mail, cell phone, telephone, residence address, georeferencing and credit card information. This information is given voluntarily during the registration process or in response to explicit requirements presented by BETTINA SPITZ Y CIA LTDA. We may also collect your Internet Protocol (IP) address to help diagnose problems with our server, and to administer the Website. An IP address is a number assigned to the device through which the Website is accessed. Your IP address is also used to help identify you within a particular session and to gather general demographic information. It is established that at any time the Users of BETTINA SPITZ Y CIA LTDA may request the deletion of their account and information from the database of BETTINA SPITZ Y CIA LTDA, through the procedure detailed below. BETTINA SPITZ Y CIA LTDA automatically collects and stores certain information about the activity of Users within the Website. Such information may include the URL from which they come (whether or not they are on our Website), which URLs they access next (whether or not they are on our Website), what browser they are using, as well as the pages visited, searches performed , publications, purchases or sales, messages, etc.

4. RIGHTS THAT ASSIST YOU AS THE HOLDER OF THE INFORMATION.

In accordance with the provisions of article 8 of Law 1581 of 2012, you as the owner of all personal data provided have the following rights. a) Know, update and rectify all your personal data held in the database of BETTINA SPITZ Y CIA LTDA. b) Request proof of the authorization granted to BETTINA SPITZ Y CIA LTDA. c) Be informed by BETTINA SPITZ Y CIA LTDA, upon written request, regarding the use that has been given to your personal data; d) Submit to the Superintendency of Industry and Commerce complaints for violations of the provisions of Law 1581 of 2012, Decree 1377 of 2013 and other regulations that modify and/or complement them; e) 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.

5. TREATMENT AND/OR USE WE MAKE OF THE INFORMATION.

By virtue of the commercial activity of BETTINA SPITZ Y CIA LTDA and in order to provide an excellent service so that Users can carry out operations in an agile and secure manner, we request and store certain personal data. The final and ultimate purpose of collecting this information is based on the fact that the business relationship with our users can be successfully completed. That is, the information we collect is collected and stored in order to be able to choose, send and deliver to the user the goods purchased through the website. The foregoing does not prevent this information from being used by BETTINA SPITZ Y CIA LTDA so that, through the Website, users are offered services and functionalities that best suit their needs. Likewise, it allows BETTINA SPITZ Y CIA LTDA to send you by different means and channels (including mail, SMS, etc.) information on offers, products and services that we believe may be of interest to you. Taking into account the foregoing, the Personal Data that we collect have the following purposes: – Obtain the information that is necessary to be able to specify the consumer relationship with users. – Get in direct contact with users whenever BETTINA SPITZ Y CIA LTDA considers it convenient in order to offer them by different means and channels (including mail, SMS, etc.) daily offers of other products and/or services. – Develop internal studies on the interests, behavior and demographics of the Users with the aim of better understanding their needs and interests and giving them a better service or providing them with related information. – Improve our commercial and promotional initiatives to analyze the pages most visited by Users, the searches carried out, improve our content offer, personalize said content, presentation and services. – Send information or messages about new products and/or services, display advertising or promotions, banners, of interest to our Users, news about BETTINA SPITZ Y CIA LTDA, in addition to any other information that we deem appropriate. If you prefer, you can request to be excluded from the lists for sending promotional or advertising information. – Share Personal Data with service companies or “outsourcing” companies that help improve or facilitate the operations of BETTINA SPITZ Y CIA LTDA such as, but not limited to, means of payment, insurance or intermediaries in payment management, among others. These companies generally have privacy policies similar to ours. However, BETTINA SPITZ Y CIA LTDA will ensure that the minimum standards are met, by signing agreements or conventions whose purpose is the privacy of your Personal Data. However, BETTINA SPITZ Y CIA LTDA is not responsible for the improper use of the User's Personal Data by these companies. In some cases, these service providers will be the ones who collect information directly from the User (for example, if we ask them to carry out surveys or studies). In such cases, you will receive notice of a service provider's involvement in such activities, and it will be at your discretion what information you choose to provide and what additional uses the providers decide to make. In the event that You provide, on your own initiative, additional information to said service providers directly, said service providers will use that information in accordance with their own personal data processing policies. – Provide the Personal Data of the Users to the state authorities and the entities that intervene in the resolution of disputes between them, such as insurance companies or competent courts to resolve such disputes.

6. CONFIDENTIALITY OF INFORMATION.

The data of the Users will be provided only by BETTINA SPITZ Y CIA LTDA in the forms established in these Personal Data Processing Policies. BETTINA SPITZ Y CIA LTDA will do everything in its power to protect the privacy of the information. It may happen that by virtue of court orders, or legal regulations, BETTINA SPITZ Y CIA LTDA is compelled to disclose information to the authorities, in which case you will be informed that the information is confidential. In the event that third parties intercept or access certain information or data transmissions illegally, BETTINA SPITZ Y CIA LTDA will not be liable for the information that is revealed.

7. MINORS.

Our services are only available to those who have the legal capacity to contract. Therefore, those who do not comply with this condition must have the authorization of their legal representative in order to provide personal information to be included in our databases.

8. COOKIES.

The User of the Website knows and accepts that BETTINA SPITZ Y CIA LTDA may use a tracking system through the use of cookies. Cookies are small files that are installed on the hard drive, with a limited duration in time that help to personalize the services. We also offer certain features that are only available through the use of cookies. These are used in order to know the interests, behavior and demographics of those who visit or are visitors to our Website and in this way, better understand their needs and interests and give them a better service or provide related information. We will also use the information obtained through cookies to analyze the pages browsed by the User and the searches carried out, in order to improve our commercial and promotional initiatives, display advertising or promotions, banners of interest, send news about BETTINA SPITZ Y CIA LTDA, improve our offer of content and articles, and personalize said content, presentation and services. Additionally, BETTINA SPITZ Y CIA LTDA uses cookies so that the User does not have to enter their password as frequently during a browsing session, to account for and corroborate the registrations, the User's activity and other concepts and commercial agreements, always with the objective of benefiting of the User. BETTINA SPITZ Y CIA LTDA will not use them for other purposes. It is established that the installation, permanence and existence of cookies on the User's computer depends on their exclusive will and can be removed from their computer whenever they wish. To know how to delete cookies from the system, it is necessary to review the “Help” section of the browser.

9. EMAILS AND PUSH NOTIFICATIONS

We may send you emails or PUSH notifications as part of a process inherent to the development and provision of our services, or in the following circumstances: After the registration process, notifying you of your account information. The e-mails or PUSH notifications established in our Terms and Conditions, in relation to the purchase procedure –such as the receipt email of the purchase order, purchase confirmation, etc.– E-mails or PUSH notifications with reminders of the services we offer (especially those that you have not yet used or have not used in a considerable time). E-mails or PUSH notifications with news and updates, as part of a Newsletter. Promotional emails or PUSH notifications. E-mails or PUSH notifications to offer related services. In any case, in each of the e-mails we send, we will always offer the possibility of canceling the subscription (opt-out) to stop receiving them in the future.

10. SECURITY AND STORAGE

We employ various security techniques to protect such data from unauthorized access by visitors to the Website from inside or outside BETTINA SPITZ Y CIA LTDA. However, it is necessary to keep in mind that perfect security does not exist on the Internet. Therefore, BETTINA SPITZ Y CIA LTDA is not responsible for illegal interceptions or violation of its systems or databases by unauthorized persons. BETTINA SPITZ Y CIA LTDA, is not responsible for the improper use of the information obtained by these means or for the lack of diligence of the users.

11. TRANSFER IN GENERAL CIRCUMSTANCES.

If there is a sale, merger, consolidation, change in corporate control, transfer of substantial assets, reorganization or liquidation of BETTINA SPITZ Y CIA LTDA then, at our discretion, we may transfer, sell or assign the information collected on the Website to one or more relevant parties.

12. PROCEDURE BEFORE THE CUSTOMER SERVICE AREA OF THE ONLINE STORE SO THAT USERS CAN EXERCISE THEIR RIGHTS.

In case you want to exercise the rights that assist you as the owner of the information, please do not hesitate to contact us, in accordance with the following procedures:

A. Requests, Petitions, and Inquiries.

BETTINA SPITZ Y CIA LTDA has the following mechanisms to process your request effectively. At any time, users may contact us to raise requests and requests. This request can be made either by email addressed to [email protected], by written communication addressed to Carrera 7c # 109a-98, in Bogotá DC, Colombia, or by calling: (571) 6207181. In The mail and/or written letter must explain the request clearly and specifically, in such a way that it is possible for us to know and understand what the final intention of the user is (updating, deleting, rectifying personal data and/or revoking the authorization, among others). This is so that we can provide the most efficient and effective response possible to your request. Along with the specific request, the communication must include the full name of the owner and the identification number, so that we can determine who makes the request and with respect to the personal data of who will carry out the procedure. In any case, BETTINA SPITZ Y CIA LTDA undertakes to provide a response to your request within a term of 5 (five) to 10 (ten) business days, inclusive.

B. EXERCISE OF THE RIGHT OF ACCESS.

At any time users of BETTINA SPITZ Y CIA LTDA may demand through written communication, either physically or by email, that the company provides or facilitates access to the personal data it has in its possession. This right may be exercised free of charge once a month and/or each time BETTINA SPITZ Y CIA LTDA makes substantial changes to this Personal Data Processing Policy. The response term established for these procedures will be resolved within the same 5 (five) to 10 (ten) business days, inclusive.

C. CLAIMS

The owner of the data, or who by law or authorization is empowered for this purpose, may file a written claim with BETTINA SPITZ Y CIA LTDA including the identification of the Owner, the description of the facts that give rise to the claim and the address, accompanying the documents that you want to assert. For all the special effects of their processing, these will be governed by what is contemplated in article 15 of Law 1581 of 2012.

13. MODIFICATIONS OF THE PRIVACY POLICIES.

BETTINA SPITZ Y CIA LTDA may modify the terms and conditions of this Personal Data Processing Policy at any time. Any change will be effective as soon as it is published on the Website. Depending on the nature of the change, we may announce the change through: (a) the home page of the Website, or (b) an e-mail. In any case, the use of our Website implies acceptance by the User of these Terms. If you do not agree with our current Personal Data Processing Policy, refrain from using the Website.

14. FINAL PROVISIONS.

This Personal Data Processing Policy will be fully valid and effective as of June 1, 2016.