Privacy Policy

We will never sell or share with unauthorized third parties sensitive user data such as real name, real ID, phone numbers, email address, physical address, IP address, full postal code, etc. Only an auditable anonymized model with generic market segmentation information is shared in our API, so that the free tier service is transparent without being invasive, and can be consumed using the Model Context Protocol (MCP).

PRIVACY AND DATA PROTECTION POLICY In accordance with the provisions of Law 1581 of 2012 and its regulatory decrees on the Protection of Personal Data, which regulates the right to information in the collection of data, we inform you of the following: - The personal data that you have provided to us in this and other communications maintained with you (Client) will be processed in the files under the responsibility of COFFEE PIE COLOMBIA S.A.S. BIC - The purpose of the processing is to properly manage the provision of the service you have requested. Likewise, these data will not be transferred to third parties, except for legally permitted transfers. - The data requested through this and other communications are mandatory for the provision of the service. These are adequate, relevant and not excessive. - Your refusal to provide the requested data implies the impossibility of providing you with the service. - Likewise, we inform you of the possibility of exercising the corresponding rights of access, rectification, cancellation and opposition in accordance with the provisions of Law 1581 of 2012 before COFFEE PIE COLOMBIA S.A.S. BIC as responsible for the management of the data provided here. You can exercise the aforementioned rights through email: atencionalcliente@coffeepie.org COFFEE PIE COLOMBIA S.A.S. INFORMATION AND PERSONAL DATA MANAGEMENT POLICY BIC Version: 1Effective Date: April 2019.Last Update: February 2019. GENERAL This policy is defined in accordance with the entry into force of Statutory Law 1581 of 2012, which aims to establish the general provisions for the protection of personal data and develop the constitutional right of all persons to know, update and rectify the information collected about them in databases or files, as well as the right to information; therefore, COFFEE PIE COLOMBIA S.A.S. BIC, taking into account its status as responsible for the processing of personal data that assists it, allows itself to formulate this text in order to effectively comply with said regulations and especially to address queries and complaints regarding the processing of personal data collected and handled by COFFEE PIE COLOMBIA S.A.S. BIC. The right to habeas data is the right of every person to know, update, and rectify the information collected about them in public or private files and databases. It guarantees all citizens the power to decide and control their personal information. Therefore, COFFEE PIE COLOMBIA S.A.S. BIC embraces these provisions, taking into account that, in order to carry out its corporate purpose, it is continually compiling and processing various databases of clients, shareholders, suppliers, business partners, and employees. By virtue of the foregoing, within the legal and corporate obligation of COFFEE PIE COLOMBIA S.A.S. BIC to protect the right to privacy of individuals, as well as the right to know, update, or request information stored about them in databases, COFFEE PIE COLOMBIA S.A.S. BIC has designed this policy for the management of personal information and databases, which describes and explains the treatment of Personal Information to which you have access through our website, email, physical information (invoices), text messages, voice messages, phone calls, face-to-face, physical or electronic means, current or future developed as well as other communications sent as well as through third parties that participate in our commercial or legal relationship with all of our clients, employees, suppliers, shareholders, strategic allies and affiliates. This will be adjusted as the applicable regulations on the matter are regulated and new provisions come into force. GENERAL OBJECTIVE With the implementation of this policy, we intend to guarantee the confidentiality of the information and the security of the treatment that will be given to it to all clients, suppliers, employees and third parties of whom COFFEE PIE COLOMBIA S.A.S. BIC has legally obtained information and personal data in accordance with the guidelines established by the law regulating the right to Habeas Data. Likewise, through the issuance of this policy, the provisions of section K of article 17 of the aforementioned law are complied with. DEFINITIONS 1. Authorization: Consent that is previously, expressly, and informedly issued by the owner of personal data so that the company can process their personal data. 2. Owner: Natural person whose data is processed by the company. 3. Database: Set of personal data. 4. Personal data: Information linked to a person. It is any piece of information linked to one or more specific or identifiable persons, or that can be associated with a natural or legal person. Personal data can be public, semi-private, or private. 5. Processing: Any operation or set of operations on personal data, which may include collection, storage, use, circulation, or deletion. 6. Data processor: Natural or legal person, public or private, that, by itself or in association with others, processes personal data on behalf of the data controller. 7. Data Controller: A natural or legal person, public or private, who, alone or in association with others, decides on the database and/or the processing of data. 8. Public Data: Data classified as such according to the mandates of the law or the Political Constitution. Public data includes, among others, data contained in public documents, final court rulings that are not subject to confidentiality, and data relating to the civil status of individuals. 9. Semi-Private Data: Semi-private data is data that is not of an intimate, reserved, or public nature and whose knowledge or disclosure may be of interest not only to its owner but also to a certain sector or group of people or society in general, such as financial and credit data related to commercial activity. 10. Private Data: Data that, due to its intimate or reserved nature, is only relevant to the owner. 11. Sensitive data: those related to racial or ethnic origin, membership in unions, social or human rights organizations, political or religious beliefs, sexual life, biometric or health data. This information may not be provided by the Owner of this data. 12. Privacy notice: Physical or electronic document generated by the Data Controller that is made available to the owner with information regarding the existence of the information processing policies that will be applicable to them, how to access them and the characteristics of the processing that is intended to be given to personal data. RIGHTS THAT ALL OWNERS OF PERSONAL DATA HAVE BEFORE THE COMPANY Any process that entails the processing by any area of ​​the company of personal data of clients, suppliers, employees and in general any third party with which COFFEE PIE COLOMBIA S.A.S. BIC maintains commercial and labor relations must take into account and inform you expressly and in advance, by any means by which proof of compliance can be kept, of the rights that assist the data owner, which are stated below: 1. Right to know, update, rectify, consult your personal data at any time before COFFEE PIE COLOMBIA S.A.S. BIC regarding data that you consider partial, inaccurate, incomplete, fractional or those that induce error. 2. Right to request at any time proof of the authorization granted to COFFEE PIE COLOMBIA S.A.S. BIC 3. Right to be informed by COFFEE PIE COLOMBIA S.A.S. BIC upon request by the data owner, regarding the use that has been given to them. 4. The right to file any complaints you deem pertinent to assert your right to Habeas Data against the company with the Superintendency of Industry and Commerce. 5. The right to revoke authorization and/or request the deletion of any data when you consider that COFFEE PIE COLOMBIA S.A.S. BIC has not respected your constitutional rights and guarantees. 6. The right to free access to the personal data you voluntarily decide to share with COFFEE PIE COLOMBIA S.A.S. BIC. To this end, the company, with the assistance of the technology department, is responsible for securely and reliably preserving and archiving the authorization forms duly granted by each of the personal data holders. CASES IN WHICH COFFEE PIE COLOMBIA S.A.S. BIC DOES NOT REQUIRE AUTHORIZATION FOR THE PROCESSING OF THE DATA IN ITS POSSESSION 1. When the information is requested from the company by a public or administrative entity acting in the exercise of its legal functions or by court order. 2. When the data is of a public nature because it is not protected by the scope of the regulation. 3. Duly verified medical or health emergency events. 4. In those events where the information is authorized by law to fulfill historical, statistical, and scientific purposes. 5. When the data is related to the civil registry of individuals because this information is not considered private data. TO WHOM MAY COFFEE PIE COLOMBIA S.A.S. PROVIDE INFORMATION? BIC WITHOUT THE NEED FOR AUTHORIZATION FROM THE DATA OWNERS To the data owners, their heirs or representatives at any time and through any means when requested by COFFEE PIE COLOMBIA S.A.S. BIC To judicial or administrative entities in the exercise of functions that make a requirement to the company to deliver the information. To third parties that are authorized by any law of the Republic of Colombia. To third parties that the Data Owner expressly authorizes to deliver the information and whose authorization is delivered to COFFEE PIE COLOMBIA S.A.S. BIC DUTIES THAT COFFEE PIE COLOMBIA S.A.S. BIC HAS WITH RESPECT TO DATA OWNERS COFFEE PIE COLOMBIA S.A.S. BIC recognizes that personal data are the property of the owners thereof and that only such persons may decide on them. In this regard, it will use the data exclusively for those purposes for which it is authorized under the terms of the law and, for the purposes of the foregoing, it is permitted to inform the company of the duties it assumes in its capacity as data controller: 1. The company must seek the means through which to obtain express authorization from the data owner to carry out any type of processing. 2. The company must clearly and expressly inform its clients, employees, suppliers, and third parties in general from whom it obtains databases, the processing to which they will be subjected and the purpose of said processing. To this end, the company must design a strategy through which, for each event, mechanism, or data request made, it will inform them of the respective processing in question. Some of these means may be sending text messages, completing physical forms, through the COFFEE PIE COLOMBIA S.A.S. BIC websites, among others. 3. The company must inform the data owners in each case, the optional nature of responding and providing the respective information requested. 4. In all cases where data is collected, all data subjects must be informed of their rights regarding their data. 5. The company must provide the identification, physical or electronic address, and telephone number of the person or department responsible for the processing. 6. The company must guarantee, at all times, the data subject the full and effective exercise of the right to habeas data and petition, that is, the ability to access the information about them that exists or is stored in the database, request data updates or corrections, and process inquiries, all of which will be done through the consultation or complaint mechanisms provided for in this policy. 7. The company must maintain records of stored personal data with appropriate security measures to prevent deterioration, loss, alteration, unauthorized or fraudulent use, and periodically and promptly update and rectify the data whenever the data subjects report new developments or requests. PURPOSES FOR THE CAPTURE, USE, AND PROCESSING OF PERSONAL DATA COFFEE PIE COLOMBIA S.A.S. BIC, in the development of its corporate purpose and its relationships with third parties, understood as clients, employees, suppliers, creditors, strategic allies, among others; constantly collects data to carry out various purposes and uses, which can be classified as: ● Administrative, commercial, promotional, informational, marketing, and sales purposes. ● Offer all types of commercial services; as well as carry out promotional, marketing, and advertising campaigns. ● Search for a closer knowledge of all its clients, suppliers, employees, and related third parties. In relation to the foregoing, COFFEE PIE COLOMBIA S.A.S. BIC may perform the following actions: 1. Obtain, store, compile, exchange, update, collect, process, reproduce, and/or dispose of all or part of the data or information from those data subjects who grant it the proper authorization under the terms required by law and in the formats it deems appropriate for each case. 2. Classify, organize, and separate the information provided by the data subject. 3. Conduct research, compare, verify, and validate the data it obtains in a proper manner with credit risk centers with which it has commercial relations. 4. Extend the information it obtains, in accordance with the terms of the habeas data law, to the companies with which it contracts the services of capturing, storing, and managing its databases, subject to the proper authorizations obtained in this regard. 5. Transfer all or part of the data or information to its subsidiaries, businesses, companies, and/or affiliated entities and strategic allies. AUTHORIZATION In order to carry out the aforementioned purposes, COFFEE PIE COLOMBIA S.A.S. BIC freely, previously, expressly, and duly informed the data subjects of their authorization, and for this purpose, it has established appropriate mechanisms to ensure that the granting of said authorization can be verified in each case. This authorization may be provided in any medium, whether a physical or electronic document, or in any format that guarantees its subsequent consultation through technical and technological tools, as well as computer security developments. Authorization is a declaration that informs the data subject of the following information: ● Who is responsible for or in charge of collecting the information ● Data collected ● Purposes of the processing ● Procedure for exercising the rights of access, correction, updating, or deletion of data ● Information on the collection of sensitive data. DATA COLLECTED BEFORE THE ISSUANCE OF DECREE 1377 OF 2013 In order to comply with the provisions of Article 9 of Law 1581 of 2012, those responsible for the processing of personal data will establish mechanisms to obtain the authorization of the owners or whoever is authorized under the terms of the Law. These mechanisms may be predetermined through technical means that facilitate the owner's automated manifestation. Authorization may be granted in accordance with any of the following options: (i) In writing, (ii) Verbally or (iii) Through unequivocal conduct by the owner that allows us to reasonably conclude that they have granted authorization. Under no circumstances may silence be equated with unequivocal conduct. Likewise, in accordance with the provisions of Article 10 of Decree 1377 of 2013, COFFEE PIE COLOMBIA S.A.S. BIC published in newspapers of wide national circulation, the privacy notice through which it communicated the existence of this policy, informing the Superintendence of Industry and Commerce about it. As indicated in this Decree, if within thirty (30) business days from the implementation of the previous mechanism, the owners did not contact the CONTROLLER or the PERSON IN CHARGE to request the deletion of their personal data, the CONTROLLER and PERSON IN CHARGE may continue processing the personal data contained in their databases for the purpose or purposes provided for and indicated in the information processing policy. PROTECTION OF PERSONAL DATA OF MINORS AND ADOLESCENTS In compliance with the provisions of Statutory Law 1581 of 2012 and Regulatory Decree 1377 of 2013, COFFEE PIE COLOMBIA S.A.S. BIC ensures that the processing of personal data of children and adolescents will be carried out respecting their rights, which is why, in the commercial and marketing activities carried out by COFFEE PIE COLOMBIA S.A.S. BIC must have the prior, express and informed authorization of the father or mother or the legal representative of the child or adolescent. PROCEEDINGS REGARDING INQUIRIES AND REQUESTS MADE BY DATA HOLDERS Every personal data owner has the right to make inquiries and submit requests to the company regarding the handling and treatment of their information. A). PROCEDURE FOR PROCESSING CLAIMS OR REQUESTS: Any request, petition, complaint or claim (PQR) submitted to COFFEE PIE COLOMBIA S.A.S. BIC by any owner or their successors in title regarding the handling and treatment of their information will be resolved in accordance with the law regulating the right to habeas data and will be processed under the following rules: 1. The petition or claim will be made in writing or any other of the means defined in this policy for such purpose, addressed to COFFEE PIE COLOMBIA S.A.S. BIC, with the identification of the owner, the description of the facts that give rise to the claim, the address or means through which the company wishes to obtain a response, and, if applicable, accompanying the supporting documents that it wishes to assert. In the event that the document is incomplete, the company will request the interested party to correct the deficiencies within five (5) days following receipt of the claim. After two months from the date of the request, if the applicant does not present the required information, it will be understood that the claim or petition has been withdrawn. 2. Once the complete petition or claim has been received, the company will include in the individual record within a period of no more than two (2) business days a legend that says "claim in process" and the nature of the same. This information must be kept until the claim is decided. 3. The applicant will receive a response from COFFEE PIE COLOMBIA S.A.S. BIC within ten (10) business days following the date on which it has effective knowledge of the request. 4. When it is not possible to attend to the request within said term, the interested party will be informed, stating the reasons for the delay and indicating the date on which their request will be attended to, which in no case may exceed five (5) business days following the expiration of the first term. B). CONSULTATIONS: The Personal Information Management Policy by COFFEE PIE COLOMBIA S.A.S. BIC and the basic rights that data owners have in relation to it may be consulted through the following means: www.coffeepie.org. Any query that an owner may have regarding their personal information or data or when they consider it necessary to initiate a request for information or consider that their rights have been violated in relation to the use and management of their information; You can do so through the following email address: atencionalcliente@coffeepie.org If within the indicated ten (10) days, it is not possible for the company to attend to the query, the corresponding area must inform the interested party of the reasons for the delay and indicate the date on which it will be attended to, which in no case may exceed five (5) business days after the expiration of the first term. C). DATA CONTROLLER: COFFEE PIE COLOMBIA S.A.S. BIC It is the data controller; through this policy, it is allowed to report its identification data: Company name: COFFEE PIE COLOMBIA S.A.S. BIC, NIT: 900.000.000-0, Address: CL 70 SUR #43A-13, Vapah Office. Person or department responsible for handling requests, queries and complaints: the area in charge of receiving and channelling all requests and concerns is the Commercial Management through the email atencionalcliente@coffeepie.org D. DATA PROCESSOR: Eventually, COFFEE PIE COLOMBIA S.A.S. BIC may have the status of DATA PROCESSOR, in which case the identification data are as follows: Company name: COFFEE PIE COLOMBIA S.A.S. BIC, NIT: 900.000.000-0, Address: CL 70 SUR #43A-13, Vapah Office. Person or department responsible for handling requests, queries and complaints: the area in charge of receiving and channelling all requests and concerns is the Commercial Management through the email atencionalcliente@coffeepie.org IT SECURITY POLICIES For COFFEE PIE COLOMBIA S.A.S. BIC, it is essential and a priority to adopt the necessary technical, legal, human, and administrative measures to ensure the security of personal data, protecting its confidentiality, integrity, use, and unauthorized and/or fraudulent access. Likewise, please be advised that the company has implemented internal security protocols that are mandatory for all personnel with access to personal data and information systems. The internal security policies under which the owner's information is kept to prevent its adulteration, loss, consultation, use, or unauthorized or fraudulent access are as follows: 1. Policies for the perimeter technological infrastructure in the data network (Intrusion Prevention System (IPS), Firewalls, secure email, content control, network access control NAC, antivirus, and antimalware). 2. Policies on the technological infrastructure and access control policies for information, applications, and databases (MS Active Directory platform, security modules, PGP encryption). 3. Technological implementation policies that minimize the risk of critical platforms in the event of a disaster (DRP Disaster Recovery Plan). 4. Technological implementation policies that protect the organization's computers and servers from malware. 5. Technological implementation policies that prevent the use of unauthorized USB storage devices. 6. Technological implementation policies that control the sending and transmission of electronic data characterized as confidential (DLP - Data Loss Prevention - Transfer). 7. Use of different environments on critical platforms so that developers and consultants can work without problems (DEV development, QA quality, and PDN Productivity). 8. Technological implementation policies that support the information contained on the different platforms. 9. Written policy on information security and use of information tools. 10. Confidentiality agreement with suppliers and third parties. 11. Confidentiality clause in employee employment contracts. 12. Self-control procedures and response to internal and external audits. 13. All events held in which customer information is captured include a Habeas Data paragraph, with its respective implications. 14. Habeas Data Notice. By participating in the Event, all participants declare that they know and authorize COFFEE PIE COLOMBIA S.A.S. BIC, in a free, prior, voluntary, express, and duly informed manner, to collect, record, process, disseminate, compile, exchange, update, and dispose of the data or partial information provided to them, for the purposes of participating in the Event; as well as to transfer said data or partial or total information to their businesses and companies so that COFFEE PIE COLOMBIA S.A.S. BIC can offer its products and/or services to its clients in a more personalized and direct manner, and also to contact the individual in the event that they are the winner of the Event, to send advertising information about their own brands, mailing, SMS, direct mail, and market all the data and information that they voluntarily provided at the time of participating in the Event. The use of the database will be from the beginning of the Event until the day that COFFEE PIE COLOMBIA S.A.S. BIC enters liquidation. COFFEE PIE COLOMBIA S.A.S. BIC guarantees that it complies with the protection of personal data provided by its clients by virtue of the provisions of the regulatory regulations of the right to HABEAS DATA, for which it is allowed to inform: 1. That the right to habeas data is the right that every person has to know, update and rectify free of charge the information that has been collected about them in files and databases of a public or private nature. 2. That the client as the owner of the information may access their data at any time, and may therefore modify, correct, update, revoke, and request proof of the authorization given if they so deem it, through this means or through the Customer Service offices of the warehouses throughout the country. 3. That the client as the owner of the information has the power or not to report any data that they freely have available and to make requests regarding the use that has been given to their data. 4. That, for the full and effective exercise of this right by all its clients, COFFEE PIE COLOMBIA S.A.S. BIC has provided the following means through which they may submit their requests, complaints, and/or claims: email: atencionalcliente@coffeepie.org Telephone: (+57) 317 355 6309. DATA PROTECTION In accordance with the provisions of Law 1581 of 2012 and its regulatory decrees on the Protection of Personal Data, which regulates the right to information in the collection of data, we inform you of the following: - The personal data that you have provided to us in this and other communications maintained with you will be processed in the files under the responsibility of COFFEE PIE COLOMBIA S.A.S. BIC - The purpose of the processing is to properly manage the provision of the service you have requested. Likewise, these data will not be transferred to third parties, except for legally permitted transfers. - The data requested through this and other communications are mandatory for the provision of the service. These are adequate, relevant and not excessive. - Your refusal to provide the requested data implies the impossibility of providing you with the service. - We also inform you of the possibility of exercising the corresponding rights of access, rectification, cancellation, and objection in accordance with Law 1581 of 2012, with COFFEE PIE COLOMBIA S.A.S. BIC, as the data controller of the data provided herein. You may exercise these rights by emailing atencionalcliente@coffeepie.org.

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Consumption Patterns Tracking Data (Free Tier):

1. Demographics

• Age, Gender, Marital Status, etc: This is essential for personalizing campaigns.

• Educational Level, Annual Income, Occupation: Helps create a more detailed user profile.

• Relatives: Segments are made if there are relatives in the user's environment (such as children, nephews, neighbours, pets, etc) without sensitive data about them, only their age, gender and relation for segmentation purposes like christmas, halloween, valentine's day, etc.

2. Interests

• Categories and Specifics: Includes broad categories (such as "technology" or "fashion") and specific ones ("Samsung™ Galaxy," "Nike™ Shoes," etc.).

3. Behavior

• Purchase Frequency, Device Preference: Information about how the user interacts online and with which devices.

• Time on Platforms and Purchase Frequency: Useful for understanding what type of content the user is interested in.

• Purchase History: Important for remarketing campaigns.

4. Psychographics

• Lifestyle and Values: Key information for personalizing ads based on values, interests, and behaviours.

5. Brand Affinity and Loyalty

• Favourite Brands and Loyalty Points: Helps create personalized campaigns with discounts, benefits, or product ads from brands the user already follows.

6. Devices and Approximate Location

• Geolocation, Devices, Operating Systems, and Browser: Used to segment by geographic location or device type, which is important for ad personalization.

7. Subscriptions and Financial Profile

• Subscriptions to services such as Netflix™, Spotify™, Amazon™ Prime, etc, allow segmentation by the type of content consumed.

• Credit Cards Brands and Credit Score: In order to provide offers or discounts based on partnerships with different credit card brands (MasterCard™, Visa™, Amex™, Nequi™, Daviplata™, etc), only the brands names to which the user has access are shared anonymously, but never the sensitive data associated with them. For users security and ethical reasons, we abstain from storing such type of data.

If you are a user and consider that you are not willing to accept this type of business model, either because you don't want to watch ads or you find it intrusive with your privacy, we invite you to purchase a credit package valid weekly, monthly or annually, since with that prepaid monetization model an anonymous profile with your consumption patterns is NOT displayed in our API, your choice!...

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"It's better to lose money than to lose reputation, money is easier to recover" - Warren Buffett