Privacy Policy

1. Introduction

Nariño Advisory S.A.S. ("Nariño", "we", "us") is committed to handling personal information with care. This policy explains what data we collect, why we collect it, how we use and protect it, and what rights you have in relation to it. It applies to information collected through our website at narinom.blog and through our advisory engagements.

This policy is governed by Colombian law, including Ley 1581 de 2012 (Protección de Datos Personales) and its regulatory decrees. If you have questions about how we handle your data, contact us at [email protected].

2. Data We Collect

We collect the following categories of personal information:

• Contact information: name, email address, phone number — provided through our contact form or direct correspondence.
• Business information: company name, role, and operational context shared during advisory sessions.
• Technical data: IP address, browser type, pages visited, and time spent on the site — collected automatically via analytics tools.
• Cookie data: preferences stored locally in your browser. See our Cookie Policy for details.

We do not collect sensitive personal data (health, financial accounts, biometric, or ethnic data).

3. How and Why We Use Your Data

We use personal data for the following purposes:

• Responding to enquiries: to contact you after a form submission and discuss your situation. Legal basis: consent.
• Delivering advisory services: to conduct sessions, prepare written summaries, and fulfil our engagement commitments. Legal basis: performance of a contract.
• Improving our website: to understand how visitors use the site and identify areas for improvement. Legal basis: legitimate interest.
• Legal compliance: retaining records as required by Colombian commercial and tax law. Legal basis: legal obligation.

We do not sell, rent, or trade personal data. We do not use it for automated decision-making or profiling.

4. Data Retention

Contact form submissions are retained for 12 months unless an engagement begins, in which case engagement records are retained for 5 years in accordance with Colombian commercial law. Website analytics data is retained for 14 months. You may request deletion at any time, subject to legal retention requirements.

5. Data Sharing

We share data only in limited circumstances:

• Analytics providers: we use tools (such as Google Analytics) to understand website usage. These tools may process IP addresses under their own privacy policies.
• Legal requirement: if required by Colombian law or a court order, we may disclose data to the relevant authority.
• Business transfer: in the event of a merger or acquisition, data may be transferred to a successor entity under equivalent privacy commitments.

6. Data Protection Measures

We use HTTPS encryption for all website communications. Client documents and engagement records are stored in access-controlled systems. Only advisory staff involved in an engagement have access to the relevant client data. In the event of a data breach affecting your personal information, we will notify you and, where required, the Superintendencia de Industria y Comercio (SIC) within the timeframes established by law.

7. Cookies

We use essential cookies for site operation and optional analytics cookies to understand site usage. You can manage your cookie preferences at any time through our Cookie Policy page. Rejecting non-essential cookies does not affect your ability to use the site or request our services.

8. Your Rights

Under Colombian data protection law (Ley 1581 de 2012), you have the following rights:

• Access: request a copy of the personal data we hold about you.
• Rectification: request correction of inaccurate or incomplete data.
• Deletion: request erasure of your data, subject to our legal retention obligations.
• Withdrawal of consent: withdraw consent for processing based on consent at any time.
• Objection: object to processing based on legitimate interest.
• Complaint: lodge a complaint with the Superintendencia de Industria y Comercio (SIC) at www.sic.gov.co if you believe your rights have been violated.

To exercise these rights, write to us at [email protected]. We will respond within 10 business days.

9. Third-Party Links

Our website may contain links to external sites. We are not responsible for the privacy practices of those sites. We encourage you to read their privacy policies independently.

10. Children's Privacy

Our services are intended for business representatives and are not directed at individuals under 18 years of age. We do not knowingly collect personal data from minors. If we become aware that a minor has submitted data through our site, we will delete it promptly.

11. Policy Updates

We may update this policy from time to time. When we do, we will update the "Last updated" date at the top of this page. For significant changes, we will notify active clients by email. Your continued use of the site after changes constitutes acceptance of the updated policy.