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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:

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

3. Legal Basis for Processing

Under Ley 1581 de 2012, we process your personal data on the following bases:

4. How We Use Your Data

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:

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:

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:

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:

[email protected]

Carrera 53 #76-115, Barranquilla, Colombia