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PRIVACY AND PERSONAL DATA PROCESSING POLICY – TAGLIAFERRO HOLDING S.A.S. NIT 901.919.447-2
TAGLIAFERRO HOLDING S.A.S., a commercial company legally incorporated under the laws of the Republic of Colombia, identified with NIT 901.919.447-2, hereinafter referred to interchangeably as "THE COMPANY", "THE CONTROLLER" or "TAGLIAFERRO HOLDING", acting in its capacity as Personal Data Controller, adopts this Privacy and Personal Data Processing Policy in order to strictly and fully comply with the legal provisions regulating the personal data protection regime, especially that provided in Statutory Law 1581 of 2012 and its partial regulation contained in Decree 1377 of 2013, norms that develop the fundamental right to habeas data enshrined in articles 15 and 20 of the Political Constitution of Colombia, TAGLIAFERRO HOLDING S.A.S. adopts and develops this document, through which the policies, principles, guidelines, and procedures applicable to the processing, administration, custody, and protection of personal data collected and processed within the framework of its activities are established, guaranteeing data subjects the exercise of their rights to know, update, and rectify the information contained in databases or files, as well as the observance of other applicable constitutional and legal freedoms, rights, and guarantees. This Policy is applicable to the personal data of users, clients, suppliers, distributors, collaborators, and, in general, any third party commercially, contractually, or labor-wise linked to the company for the purpose of fully complying with current regulations on personal data protection and guaranteeing the full exercise of the constitutional rights of data subjects. TAGLIAFERRO HOLDING S.A.S. is the owner and administrator of the registered trademarks The AstroLab HQ and ChronoLuna by AstroRebel, through which it develops commercial, digital, and e-commerce activities, which is why personal data processing may be carried out directly by TAGLIAFERRO HOLDING S.A.S., or through these brands, without this implying the existence of different controllers, with TAGLIAFERRO HOLDING S.A.S. remaining in all cases the sole Controller of the Processing vis-à-vis data subjects and competent authorities.
In the development of its corporate purpose and the commercial activities carried out by TAGLIAFERRO HOLDING and its brands The AstroLab HQ and ChronoLuna by AstroRebel, THE COMPANY collects, stores, uses, processes, circulates, transmits, transfers, and deletes personal data of clients, users, prospects, suppliers, strategic partners, contractors, collaborators, candidates for selection processes and, in general, any natural person with whom it maintains or has maintained a direct or indirect relationship, either through its websites, e-commerce platforms, social networks, digital channels, physical or electronic forms, customer service systems, technological tools, marketing campaigns, logistics processes, events, commercial activations or any other physical or electronic means. This Policy establishes the principles, purposes, rights, duties, procedures, and security measures applicable to the processing of personal data, and is understood as complementary and integrated with privacy notices, authorizations, terms and conditions, cookie policies and other documents that regulate the use of digital assets, products, and services offered by TAGLIAFERRO HOLDING S.A.S., and its brands.
The Personal Data Controller is TAGLIAFERRO HOLDING S.A.S., identified with NIT 901.919.447-2, with its main domicile at KM 2 via Chia Cajica, Hacienda Fontanar Conjunto Almendro Casa No. 1. For contact purposes, handling inquiries, complaints, and other requests related to personal data processing, TAGLIAFERRO HOLDING S.A.S., provides official channels enabled by its brands, including corporate email, contact numbers, and business WhatsApp, as well as contact forms available on websites operated under the brands The AstroLab HQ and ChronoLuna by AstroRebel. TAGLIAFERRO HOLDING S.A.S., has the following official channels: email hello@theastrolabhq.com, telephone line and corporate WhatsApp +57 311 704 4908, and the forms enabled on its website www.theastrolabhq.com. TAGLIAFERRO HOLDING S.A.S. may internally designate a responsible area or an officer for handling inquiries and complaints, without this implying an exemption from its legal responsibility as the Data Controller, in terms of Law 1581 of 2012.
This Policy is based on the Political Constitution of Colombia, especially its articles 15 and 20; on Statutory Law 1581 of 2012 and its regulatory decrees, particularly Decree 1377 of 2013 compiled in the Single Regulatory Decree 1074 of 2015; on Law 1266 of 2008 and its regulatory norms 2952/2010, applicable when dealing with financial, credit, commercial and services information; on the administrative instructions and guidelines issued by the Superintendence of Industry and Commerce in its capacity as national personal data protection authority; and on relevant constitutional jurisprudence on habeas data, privacy and personal information protection, among others, Sentences C-1011 of 2008 and C-748 of 2011, without prejudice to other norms that modify, add to or replace them.
For interpretation and application purposes, TAGLIAFERRO HOLDING S.A.S., adopts the definitions provided in Law 1581 of 2012 and other related norms, understanding Authorization as the prior, express and informed consent granted by the Data Subject to carry out the Processing;
4.1 Privacy Notice: Manifestation or communication, either verbal or written, issued by the Data Controller, by which the Data Subject is informed about the existence of this Policy, the means available to consult it, and the purposes for which their personal data will be processed.
4.2 Database: Structured or organized set of personal information that is subject to collection, storage, use, or any other form of processing.
4.3 Personal Data: Information of any nature that identifies or allows the direct or indirect identification of a specific or identifiable natural person.
4.4 Public Data: Information that is not private, semi-private, or sensitive, as well as that which has been expressly defined as public by the Constitution or law.
4.5 Sensitive Data: Personal information whose processing may affect the privacy of the Data Subject or whose improper use may lead to situations of discrimination.
4.6 Data Processor: Natural or legal person, public or private, who processes personal data on behalf of and under the instructions of the Data Controller.
4.7 Processing Policy: Refers to this document, by which TAGLIAFERRO HOLDING S.A.S., establishes and regulates the Personal Data Processing Policy applicable to the collection, use, storage, circulation, transmission, and deletion of personal data, in accordance with current legislation on personal data protection.
4.8 Products: These are the goods and/or services manufactured, developed, imported, distributed, and/or marketed by TAGLIAFERRO HOLDING S.A.S., directly or through its brands The AstroLab HQ and ChronoLuna by AstroRebel, including, among others, cosmetic products and any other product or service offered in the development of its corporate purpose.
4.9 Supplier: Any natural or legal person who, by virtue of a current contractual, legal or commercial relationship, provides services, supplies goods or performs activities for the benefit of TAGLIAFERRO HOLDING S.A.S., directly or through its brands The AstroLab HQ and ChronoLuna by AstroRebel.
4.10 Data Controller: Legal entity that decides on the collection, use and other forms of processing of personal data, being TAGLIAFERRO HOLDING S.A.S. for the purposes of this Policy.
4.11 Data Subject: Natural person to whom the personal information that is subject to processing corresponds.
4.12 Processing: Any activity, operation or procedure, automated or not, performed on personal data, including, among others, the collection, storage, use, circulation, transmission, transfer, modification, updating or deletion of the same.
In the development of its activities, TAGLIAFERRO HOLDING S.A.S., will strictly apply the principles established in Law 1581 of 2012, guaranteeing that processing is carried out in accordance with the principle of legality, by virtue of which processing is a regulated activity subject to the Constitution and law; the principle of purpose, according to which processing must obey a legitimate purpose, informed to the Data Subject; the principle of freedom, in accordance with which processing can only be exercised with prior, express and informed authorization from the Data Subject or in cases permitted by law; the principle of veracity or quality, which requires that information be truthful, complete, accurate, updated, verifiable and understandable, prohibiting the processing of partial or misleading data; the principle of transparency, which guarantees the Data Subject's right to obtain information on the use of their data at any time and without restrictions; the principle of restricted access and circulation, according to which processing is subject to limits derived from the nature of the data, legal provisions and the Data Subject's authorization, avoiding indiscriminate or massive access; the principle of security, implementing reasonable and proportional technical, human and administrative measures to prevent alteration, loss, consultation, unauthorized or fraudulent use or access; and the principle of confidentiality, guaranteeing reservation of information even after the relationship that originated the processing has ended, when applicable.
TAGLIAFERRO HOLDING S.A.S., may collect and process personal data related to the identification and contact of the Data Subject, data necessary for the provision or contracting of products and services, billing and payment data, commercial and relationship data, digital navigation and web analytics data (including, where applicable, information derived from Cookies and similar technologies), preference and commercial segmentation data, information necessary to handle petitions, complaints, claims and requests, and data linked to contractual or legal obligations. In all cases, TAGLIAFERRO HOLDING S.A.S. will endeavor to limit collection to relevant, adequate, and non-excessive data according to the informed purposes, adopting minimization and necessity criteria.
The personal data collected by TAGLIAFERRO HOLDING S.A.S. will be used, among others, to: manage the commercial, contractual, or pre-contractual relationship with the Data Subject; process requests for information, quotes, orders, purchases, payments, deliveries, returns, warranties, and after-sales services; manage databases of clients, prospects, suppliers, partners, contractors, and other third parties; execute administrative, accounting, tax, financial, and billing processes; verify, validate, and update information to prevent fraud, impersonation, and operational risks; manage transactional, operational, and service communications; handle petitions, complaints, claims, requests, inquiries, and requirements; carry out marketing, advertising, commercial prospecting, sending institutional information, campaigns, promotions, benefits, launches, events, satisfaction surveys, market studies, and user experience analysis, always respecting the Data Subject's right to request deletion or revoke authorization for non-essential purposes; administer technological tools such as CRM, automation, forms, email marketing platforms, messaging and support, as well as digital advertising campaigns and results measurement; comply with legal and regulatory obligations and requirements from administrative or judicial authorities; and, in general, execute the necessary activities for the development of the corporate purpose of TAGLIAFERRO HOLDING S.A.S, always within the framework of the law, observing the duty of information and the Data Subject's authorization when applicable.
TAGLIAFERRO HOLDING S.A.S. recognizes that sensitive personal data is subject to special and reinforced protection, given that its improper use can generate significant risks of discrimination, affecting privacy, good name, honor, and other fundamental rights of the Data Subject. Consequently, its processing is strictly governed by the provisions of articles 5 and 6 of Law 1581 of 2012, Decree 1377 of 2013, Decree 1074 of 2015, as well as current constitutional jurisprudence.
As a general rule, TAGLIAFERRO HOLDING S.A.S. does not require or condition access to its products, services, or activities on the provision of sensitive personal data, understood as those that affect the Data Subject's privacy or whose improper use can generate discrimination, such as data related to racial or ethnic origin, religious, philosophical, or political convictions, union affiliation, health information, sexual life, and biometric data.
Notwithstanding the foregoing, exceptionally, when for strictly necessary, legally justified reasons directly related to a legitimate purpose, the processing of sensitive data is indispensable, TAGLIAFERRO HOLDING S.A.S. will rigorously observe the following rules:
a) Express and qualified authorization: The processing of sensitive data will only be carried out when the Data Subject has granted prior, express, free, informed, and specific authorization, clearly indicating the purpose of the processing and the type of sensitive data subject to collection, in accordance with article 6 of Law 1581 of 2012.
b) Optional nature of provision: In any case, TAGLIAFERRO HOLDING S.A.S. will clearly, expressly, and unequivocally inform the Data Subject that the provision of sensitive data is optional, and that refusal to provide it will not result in any type of reprisal, exclusion, or discriminatory treatment.
c) Limited and proportional purpose: Sensitive data will be collected and processed exclusively for the specific authorized purpose, prohibiting any different, expanded, or unrelated use directly linked to said purpose.
d) Reinforced security and confidentiality measures: The company will implement reinforced technical, human, and administrative measures aimed at guaranteeing the security, confidentiality, integrity, and reservation of sensitive data, preventing unauthorized or fraudulent access, use, disclosure, or processing.
e) Respect for human dignity and fundamental rights: In no case shall the processing of sensitive data lead to practices that violate human dignity, the right to privacy, good name, honor, or any other fundamental right of the Data Subject, observing at all times the principles of legality, purpose, freedom, veracity, transparency, restricted access and circulation, security, and confidentiality.
f) Prohibition of unnecessary or excessive processing: TAGLIAFERRO HOLDING S.A.S. will refrain from processing sensitive data when such processing is not strictly necessary, lacks legal support or valid authorization, or may generate unjustified risk to the Data Subject's rights.
The company reaffirms its commitment to the responsible, ethical, and legal processing of sensitive personal data, understanding that any improper use of this type of information constitutes a serious infringement of the current personal data protection regime in Colombia.
TAGLIAFERRO HOLDING S.A.S. recognizes that the personal data of children and adolescents (NNA) enjoy enhanced and prevalent protection, in accordance with the provisions of Article 44 of the Political Constitution, Law 1581 of 2012, Decree 1377 of 2013, Decree 1074 of 2015, and the repeated jurisprudence of the Constitutional Court.
In view of the foregoing, as a general rule, TAGLIAFERRO HOLDING S.A.S. refrains from processing personal data of minors, except in those exceptional cases expressly permitted by law, that is, when dealing with public data, or when processing is strictly necessary, serves the best interest of the minor, and effectively guarantees respect for their fundamental rights, especially the rights to privacy, good name, honor, and comprehensive protection of their personal data.
In cases where the processing of personal data of children and adolescents is appropriate, TAGLIAFERRO HOLDING S.A.S. will strictly observe the following principles and obligations:
a) Prior and express authorization:Processing will only be carried out with the express, prior, and informed authorization of the minor's legal representative, which must be granted by any means allowing for its subsequent verification, in accordance with Article 9 of Law 1581 of 2012 and Article 7 of Decree 1377 of 2013.
b) Legitimate and limited purpose: Data will be collected and processed exclusively for specific, explicit, and legitimate purposes, directly related to the authorized activity, prohibiting any different, excessive, or unnecessary use.
c) Principle of the best interest of the minor: In any case, data processing must respect and guarantee the best interest of the child or adolescent, a guiding principle that will prevail over any other commercial, contractual, or administrative interest.
d) Proportional and secure processing: TAGLIAFERRO HOLDING S.A.S. will implement reinforced technical, human, and administrative measures to guarantee the security, confidentiality, and integrity of minors' personal data, preventing their alteration, loss, unauthorized or fraudulent consultation, use, or access.
e) Respect for the rights of the minor: At all times, the full exercise of the minor's rights and those of their legal representative will be guaranteed, particularly the rights to access, update, rectify, and delete data, as well as the possibility of revoking the authorization granted, when appropriate under the law.
f) Prohibition of unnecessary processing: In no case will TAGLIAFERRO HOLDING S.A.S. process personal data of children and adolescents when such processing is not strictly necessary, does not have a legitimate purpose, or could jeopardize their fundamental rights.
The company reaffirms its commitment to the comprehensive protection of minors' personal data, understanding that any violation in this area constitutes a serious breach of current regulations and the constitutional principles governing the protection of childhood and adolescence in Colombia.
TAGLIAFERRO HOLDING S.A.S will request the Data Subject, when applicable, prior, express, and informed authorization for the processing of their personal data, which may be obtained by any means allowing for its subsequent consultation, verification, and traceability, including physical means, electronic means, data messages, websites, digital forms, acceptance of terms in digital channels, communications, and other mechanisms permitted by law. The authorization may include essential purposes for the relationship (e.g., contractual management, billing, handling requests) and additional purposes (e.g., marketing and advertising), without prejudice to the Data Subject's right to revoke authorization for the latter or to request the deletion of their information when appropriate.
In accordance with the provisions of Article 8 of Law 1581 of 2012 and other concordant norms, Data Subjects whose personal data is processed by TAGLIAFERRO HOLDING S.A.S. shall, at all times, have the following rights:
To know, update, and rectify their personal data before TAGLIAFERRO HOLDING S.A.S., the Data Processors, or third parties who have received the information as a result of an authorized transmission or transfer, especially when dealing with partial, inaccurate, incomplete, fragmented, misleading data, or data whose processing has not been authorized or is legally prohibited.
To request proof of the authorization granted for the processing of their personal data, except in cases where the law expressly exempts this requirement.
To be informed, upon request, by TAGLIAFERRO HOLDING S.A.S. or by the Data Processor, about the use, purpose, and scope of their personal data.
To submit petitions, complaints, or claims to TAGLIAFERRO HOLDING S.A.S. related to the processing of their personal data, as well as to file complaints with the Superintendency of Industry and Commerce for alleged infringements of the personal data protection regime provided for in Law 1581 of 2012 and the norms that modify, add to, or complement it.
To revoke, at any time, the authorization granted for the processing of their personal data and/or request its deletion, when they consider that the processing has not respected constitutional and legal principles, rights, and guarantees, provided that there is no legal or contractual duty preventing its elimination.
To access their personal data that has been processed by TAGLIAFERRO HOLDING S.A.S. free of charge, under the terms, conditions, and limits established by current regulations.
In strict compliance with the provisions of Articles 14 and 15 of Law 1581 of 2012, Decree 1377 of 2013, the Single Regulatory Decree 1074 of 2015, and in observance of the constitutional principles governing the protection of the fundamental right to habeas data, TAGLIAFERRO HOLDING S.A.S. guarantees Data Subjects, their beneficiaries, legal representatives, or duly accredited attorneys-in-fact, the full, effective, and timely exercise of the rights to know, access, update, rectify, and delete their personal data, and, when applicable, to revoke the authorization granted for its processing.
For these purposes, the company has established the following procedure, which will at all times be governed by the principles of legality, purpose, freedom, veracity, transparency, restricted access and circulation, security, confidentiality, and good faith.
The Data Subject or their beneficiaries may submit inquiries regarding the personal information contained in the databases of TAGLIAFERRO HOLDING S.A.S., in order to know, among other aspects, the existence of their data, the use made of it, the purposes of the processing, the retention period, and the third parties to whom such information may have been provided.
Inquiries must be submitted through the channels enabled by the company and must allow for the full identification of the applicant, in order to guarantee the security of the information and prevent unauthorized access.
Upon receipt of the inquiry, TAGLIAFERRO HOLDING S.A.S. will respond within a maximum of ten (10) business days from the date of receipt. If it is not possible to respond to the inquiry within this period, the company will inform the interested party, before the expiration of the initial period, of the reasons for the delay and the new date on which the request will be addressed, which may not exceed five (5) additional business days.
The response to the inquiry will contain clear, sufficient, and understandable information, guaranteeing in all cases the confidentiality of personal data and the reservation of information protected by legal mandate.
12.2 Right to Complaint: The Data Subject or their beneficiaries who consider that the information contained in the databases of TAGLIAFERRO HOLDING S.A.S. should be subject to correction, updating, or deletion, or when they notice an alleged non-compliance with legal duties regarding personal data protection, may submit a formal complaint to the company.
The complaint must be addressed to TAGLIAFERRO HOLDING S.A.S. and must contain, at a minimum:
a) Full identification of the Data Subject.
b) Clear, precise, and detailed description of the facts giving rise to the complaint.
c) Physical and/or electronic address for notification purposes.
d) The documents or evidentiary elements to be invoked, when applicable.
If the complaint is incomplete, the company will request the interested party, within five (5) business days following its receipt, to correct the deficiencies or complete the necessary information. If two (2) months have passed since the date of the request without the applicant providing the requested information, it will be understood that the complaint has been abandoned, without prejudice to the possibility of submitting a new one.
Once the complaint has been duly received, TAGLIAFERRO HOLDING S.A.S. will include in the corresponding database a legend indicating "COMPLAINT IN PROCESS" within a period not exceeding two (2) business days, which will be maintained until the complaint is resolved.
The maximum term to respond to the complaint will be fifteen (15) business days, counted from the day following the date of its complete receipt. If it is not possible to respond to the complaint within this period, the company will timely inform the interested party of the reasons for the delay and the new date on which it will be resolved, which may not exceed eight (8) additional business days.
The Data Subject may at any time request the revocation of the authorization granted and/or the deletion of their personal data, provided that there is no legal or contractual duty preventing its elimination. The request will be analyzed in accordance with current regulations and will be resolved within the legal terms established for complaints.
The deletion of data may be total or partial, according to the nature of the request and the legal obligations that must be met by TAGLIAFERRO HOLDING S.A.S.
The gratuitousness of the procedure.
The diligent, respectful, and timely handling of requests.
The protection of the confidentiality and integrity of personal data.
The non-imposition of requirements additional to those provided by law.
Respect for due process and the principle of good faith.
In no case will the submission of inquiries or complaints lead to retaliation, discriminatory treatment, or any adverse effect on the Data Subject's contractual or commercial relationship with the company.
In its capacity as Personal Data Controller, TAGLIAFERRO HOLDING S.A.S. will strictly comply with the duties set forth in Law 1581 of 2012, its regulatory decrees, and other concordant norms, and in particular undertakes to:
Guarantee Data Subjects at all times the full, effective, and permanent exercise of the fundamental right to habeas data, in accordance with applicable constitutional and legal principles.
Request, obtain, and retain, under the terms provided by law, the prior, express, and informed authorization granted by Data Subjects for the processing of their personal data, when such authorization is required.
Inform Data Subjects clearly, sufficiently, and timely about the specific purposes for which their personal data is collected, as well as about the rights they hold by virtue of the authorization granted.
Retain personal information under reasonable and adequate technical, human, and administrative security conditions that prevent its alteration, loss, unauthorized or fraudulent consultation, use, or access.
Guarantee that the information provided to Data Processors is truthful, complete, accurate, updated, verifiable, and understandable, avoiding the processing of partial, inaccurate, or misleading data.
Update and rectify personal information promptly when appropriate, and immediately communicate such changes to the Data Processors with whom it has a relationship.
Provide Data Processors, as the case may be, only personal data whose processing has been previously authorized by the Data Subject or is legally enabled.
Require Data Processors at all times to comply with the security, confidentiality, and protection conditions for Data Subjects' personal information, in accordance with current regulations and the instructions issued by TAGLIAFERRO HOLDING S.A.S.
Diligently process, and within legal terms, inquiries, petitions, complaints, and claims submitted by Data Subjects or their beneficiaries, related to the processing of their personal data.
Inform Data Processors when certain information is under discussion by the Data Subject, once a complaint has been filed and until the corresponding process has concluded.
Inform the Data Subject, when requested, about the specific use made of their personal data.
Adopt internal policies, manuals, procedures, and control measures aimed at ensuring adequate compliance with the personal data protection regime and, in particular, the correct handling of inquiries and complaints.
Timely inform the Superintendency of Industry and Commerce, in its capacity as personal data protection authority, when security code violations or incidents occur that imply risks in the administration of Data Subjects' information, in accordance with current instructions.
Comply with the instructions, requirements, and guidelines issued by the Superintendency of Industry and Commerce regarding personal data protection.
To use and process personal data only when its processing is duly authorized or legally permitted, always respecting the principles, rights, and guarantees provided in Law 1581 of 2012 and other applicable regulations.
In the development of its operation, TAGLIAFERRO HOLDING S.A.S may transmit personal data to data processors located in Colombia or abroad, such as technology providers, CRM platforms, email marketing, analytics, messaging, hosting, cloud services, payment gateways, logistics or support, who will act on behalf of TAGLIAFERRO and under instructions, contractual obligations of confidentiality, security and limited use. Likewise, it may transfer data to third-party controllers when there is authorization from the Data Subject or legal authorization, and whenever this is necessary for the execution of the relationship or for informed purposes. In any case, TAGLIAFERRO will adopt reasonable measures to ensure that such third parties observe protection standards consistent with this Policy and with applicable regulations.
TAGLIAFERRO HOLDING S.A.S may use Cookies, pixels, SDKs, tags or similar technologies in its digital assets in order to enable functionalities, improve the browsing experience, remember preferences, allow statistical analysis, measure campaigns, optimize advertising and understand users' interaction with content. The user may manage, block or disable Cookies from their browser settings, without prejudice to the fact that certain functionalities of the site may be limited. The specific management of Cookies will be understood to be harmonized with this Policy and with the informative notices that TAGLIAFERRO HOLDING S.A.S makes available through its digital channels.
TAGLIAFERRO HOLDING S.A.S implements reasonable and proportionate technical, human and administrative measures to the risk, aimed at protecting personal data against unauthorized access, loss, misuse, alteration or disclosure, including access controls, authentication mechanisms, permission management, internal policies, confidentiality agreements, incident management protocols, good digital security practices and staff training, without prejudice to the fact that no system is absolutely infallible and that the obligation of TAGLIAFERRO HOLDING S.A.S is understood to be one of means, in accordance with the applicable legal standard and the nature of the information.
TAGLIAFERRO HOLDING S.A.S will carry out, when applicable and in accordance with current mandatory criteria, the registration, update or modification of its databases in the National Database Registry managed by the Superintendence of Industry and Commerce, complying with the formal and substantive requirements established by the competent authority.
This Policy is effective from its publication and will remain in force for the term necessary to fulfill its purposes and for the duration of the relationships with the data subjects, without prejudice to the applicable legal terms of document retention. TAGLIAFERRO HOLDING S.A.S may modify it at any time to adapt it to regulatory, operational or institutional changes; such modifications will be informed through publication in its official channels or through privacy notices when appropriate.
TAGLIAFERRO HOLDING S.A.S undertakes to keep personal data confidential, even after the relationship with the Data Subject has ended, and to use it exclusively for authorized or legally permitted purposes, adopting internal measures to prevent unauthorized access, improper disclosures or uses contrary to law, and ensuring that its employees, contractors and Processors assume equivalent confidentiality and security obligations.
TAGLIAFERRO HOLDING S.A.S.
Publication: February 04, 2026