1. Responsible Party
The responsible party for the processing of personal data collected through this website is:
Novum Digital
Local 4 Bloque 2, Cl. 31 #22D-253, Alameda La Victoria, Cartagena de Indias, Bolívar, Colombia
Email: info@novumdigitalcoi.com
Website: novumdigitalcoi.com
Novum Digital operates as a digital educational consultancy. We provide informational and educational content related to savings strategies and economic organization. We do not provide regulated financial services, investment advice, or any service requiring authorization from the Superintendencia Financiera de Colombia.
2. Legal Framework
This Privacy Policy is governed by Colombian data protection legislation, principally:
- Ley 1581 de 2012 (Statutory Law on Personal Data Protection), which establishes the general framework for the protection of personal data in Colombia.
- Decreto 1377 de 2013, which partially regulates Law 1581 of 2012 and establishes procedures for the collection, storage, use, circulation, and deletion of personal data.
- Decreto 1074 de 2015 (Decreto Único Reglamentario del Sector Comercio, Industria y Turismo), which consolidates regulatory provisions applicable to personal data protection.
- Circular Externa 002 de 2015 of the Superintendencia de Industria y Comercio (SIC), which provides guidelines on data protection compliance.
The Superintendencia de Industria y Comercio (SIC) is the supervisory authority responsible for overseeing compliance with data protection legislation in Colombia. Data subjects who consider that their rights have been violated may file a complaint with the SIC through its official channels.
3. Data We Collect
Novum Digital collects personal data through the following channels:
3.1 Contact Form
When you complete the contact form on our website, we collect:
- Full name
- Email address
- The content of your message or inquiry
3.2 Automatic Technical Data
When you visit our website, our servers and analytics tools may automatically collect certain technical information, including:
- IP address (anonymized where possible)
- Browser type and version
- Operating system
- Pages visited and navigation path
- Date and time of visit
- Referring URL
3.3 Cookie Data
We use cookies and similar technologies to improve your browsing experience. Please refer to our Cookie Policy for detailed information on the cookies we use and how to manage your preferences.
We do not collect sensitive personal data as defined in Article 5 of Law 1581 of 2012, including data relating to racial or ethnic origin, political opinions, religious beliefs, health, sexual life, biometric data, or union membership.
4. Purposes of Processing
We process your personal data for the following specific purposes:
- Responding to inquiries: To review and respond to questions submitted through our contact form regarding our educational programs and services.
- Service communication: To provide information about our educational programs, workshops, and webinars that may be of interest based on your inquiry.
- Website improvement: To analyze how our website is used in aggregate, in order to improve content, navigation, and user experience.
- Legal compliance: To comply with applicable legal obligations under Colombian law, including record-keeping requirements.
- Technical operation: To ensure the proper technical functioning, security, and integrity of our website and digital systems.
We do not process your personal data for automated decision-making, profiling for commercial purposes, or any purpose incompatible with those stated above.
5. Legal Basis for Processing
Under Law 1581 of 2012, the processing of personal data requires a legal basis. The bases on which Novum Digital relies are:
5.1 Consent
When you submit the contact form, you provide explicit consent to the processing of your data for the purposes of responding to your inquiry. You may withdraw this consent at any time by contacting us at info@novumdigitalcoi.com. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.
5.2 Legitimate Interest
We process certain technical and navigation data on the basis of our legitimate interest in ensuring the security and proper functioning of our website, and in understanding how our educational content is used in aggregate.
5.3 Legal Obligation
We may process personal data where required to comply with a legal obligation applicable to Novum Digital under Colombian law.
6. Data Sharing and Third Parties
Novum Digital does not sell, rent, or commercially transfer your personal data to third parties. We may share data in the following limited circumstances:
6.1 Service Providers
We work with third-party service providers who assist in operating our website and delivering our services. These include hosting providers, email service providers, and analytics platforms. These providers act as data processors and are contractually bound to process data only on our instructions and in accordance with applicable law.
6.2 Legal Requirements
We may disclose personal data when required to do so by law, court order, or competent authority, including the Superintendencia de Industria y Comercio or other Colombian regulatory bodies.
6.3 Business Transfers
In the event of a merger, acquisition, or transfer of all or part of our business, personal data may be transferred to the successor entity, subject to the same level of protection provided by this policy.
All third parties with whom we share data are required to implement appropriate technical and organizational measures to protect personal data.
7. Retention Periods
We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law:
- Contact form data: Retained for up to 24 months from the date of your inquiry, or until you request deletion, whichever occurs first.
- Technical log data: Retained for up to 12 months for security and operational purposes.
- Cookie preference data: Retained for 12 months from the date of your consent, after which you will be asked to renew your preferences.
- Legal compliance records: Retained for the period required by applicable Colombian law, which may extend beyond the periods stated above.
When personal data is no longer required, it is securely deleted or anonymized in accordance with our internal data management procedures.
8. Your Rights as a Data Subject
Under Law 1581 of 2012 and its regulatory decrees, you have the following rights with respect to your personal data:
- Right to Know (Derecho de Acceso): You have the right to know what personal data we hold about you, the origin of that data, and the purposes for which it is processed.
- Right to Update (Derecho de Actualización): You have the right to request that inaccurate or incomplete personal data be updated or corrected.
- Right to Rectification: You have the right to request correction of data that is partial, inaccurate, incomplete, or misleading.
- Right to Deletion (Derecho de Supresión): You have the right to request the deletion of your personal data when it is no longer necessary for the purposes for which it was collected, when you withdraw consent, or when the data has been processed unlawfully. This right is subject to legal retention obligations.
- Right to Revoke Consent: Where processing is based on consent, you may withdraw your consent at any time without affecting the lawfulness of prior processing.
- Right to File a Complaint: You have the right to file a complaint with the Superintendencia de Industria y Comercio (SIC) if you believe your data protection rights have been violated.
To exercise any of these rights, please send a written request to info@novumdigitalcoi.com, including your full name, a description of your request, and a copy of an identification document. We will respond within the timeframes established by Law 1581 of 2012: ten (10) business days for access requests, and fifteen (15) business days for complaints and other requests, extendable by an additional eight (8) business days where justified.
9. International Data Transfers
Some of our third-party service providers may be located outside Colombia. Where personal data is transferred internationally, we ensure that such transfers comply with the requirements of Law 1581 of 2012 and Decree 1377 of 2013, which require that the recipient country provides an adequate level of data protection, or that appropriate safeguards are in place, such as contractual clauses approved by the SIC.
We take reasonable steps to ensure that any international transfer of personal data is conducted in a manner that protects the rights and interests of data subjects in accordance with Colombian law.
11. Minors
Our website and educational programs are designed for adults. We do not knowingly collect personal data from individuals under 18 years of age. If you are a parent or guardian and believe that a minor has provided us with personal data without appropriate consent, please contact us at info@novumdigitalcoi.com and we will take steps to delete such data promptly.
12. Changes to This Policy
Novum Digital may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or operational circumstances. When we make material changes, we will update the "Last Updated" date at the top of this page. We encourage you to review this policy periodically.
Continued use of our website following the publication of changes constitutes acceptance of the updated policy, to the extent permitted by applicable law. Where changes require renewed consent, we will request it through appropriate mechanisms.
13. Contact for Privacy Matters
For any questions, requests, or concerns relating to this Privacy Policy or the processing of your personal data, please contact us:
Novum Digital
Attn: Data Protection
Local 4 Bloque 2, Cl. 31 #22D-253, Alameda La Victoria, Cartagena de Indias, Bolívar, Colombia
Email: info@novumdigitalcoi.com
If you are not satisfied with our response, you have the right to file a complaint with the Superintendencia de Industria y Comercio (SIC) at www.sic.gov.co.