Legal
Privacy Policy
Last Updated: 25 June 2025
Esmeralda ("we", "us", "our") is a retail consulting practice registered in Barranquilla, Colombia. We take the privacy of our clients and website visitors seriously. This policy explains what personal data we collect, how we use it, and what rights you have under Colombian law — specifically the Ley 1581 de 2012 (Protección de Datos Personales) and its regulatory decree.
1. Data We Collect
When you contact us through our website or engage our services, we may collect the following personal data:
- Full name
- Email address
- Phone number (if provided)
- Information about your business (name, location, type of retail)
- Content of messages you send us
We also collect standard technical data through our website, including IP address, browser type, and pages visited, via analytics tools. This data is collected in aggregate and is not linked to your identity without your consent.
2. How We Collect Data
- Through the contact form on our website
- By telephone or email when you reach out to us directly
- During service engagements (notes, session records)
- Via cookies and analytics on our website
3. Legal Basis for Processing
Under Ley 1581 de 2012, we process your personal data on the following bases:
- Your consent — when you submit a form or agree to communications
- Performance of a contract — when delivering a consulting service you have engaged
- Legitimate interests — for website analytics and service improvement, provided those interests do not override your rights
4. How We Use Your Data
- To respond to enquiries and arrange service sessions
- To deliver the consulting services you have requested
- To send session summaries, checklists, or roadmaps related to your engagement
- To improve our website and understand how visitors use it
- To comply with legal obligations under Colombian law
We do not use your data for automated decision-making or profiling. We do not sell or rent personal data to third parties.
5. Data Retention
We retain client contact and engagement data for up to three years after the end of a service engagement, unless a longer period is required by law. Website analytics data is retained for up to 14 months. You may request deletion at any time (see Your Rights below).
6. Data Protection Measures
We take reasonable technical and organisational steps to protect the personal data we hold:
- Encrypted transmission (HTTPS) for all web communications
- Limited internal access — only staff directly involved in your engagement see your data
- Secure email and file storage practices
- Prompt notification if we become aware of a data breach affecting you
7. Cookies
Our website uses cookies for essential functionality, analytics, and preferences. You can manage your cookie choices at any time by visiting our Cookie Policy page. Essential cookies cannot be disabled as they are necessary for the site to function.
8. Third-Party Services
We may use the following third-party services, each with their own privacy policies:
- Google Analytics — website usage statistics
- Google Maps — location display on our website
We do not integrate advertising networks or social media tracking pixels by default.
9. Your Rights
Under Ley 1581 de 2012 and its implementing regulations, you have the right to:
- Know what personal data we hold about you
- Request correction of inaccurate data
- Request deletion of your data (where no legal obligation requires retention)
- Withdraw consent at any time, without affecting the lawfulness of prior processing
- Lodge a complaint with the Superintendencia de Industria y Comercio (SIC), Colombia's data protection supervisory authority
To exercise these rights, write to us at [email protected] with your request. We will respond within the timescale required by Colombian law.
10. External Links
Our website may link to external sites. We are not responsible for the privacy practices of those sites and encourage you to read their own policies before sharing any personal information.
11. Children's Privacy
Our services are intended for business owners and adults aged 18 and over. We do not knowingly collect data from minors. If you believe we have inadvertently done so, please contact us and we will delete the data promptly.
12. Changes to This Policy
If we make material changes to this policy, we will update the "Last Updated" date at the top of this page. For significant changes, we will notify active clients by email. Continued use of our website after a change constitutes acceptance of the updated policy.
13. Contact
For privacy-related questions, data access requests, or complaints:
Carrera 53 #76-115, Barranquilla, Colombia