Privacy Policy

1. Identity of the Data Controller

The data controller responsible for the processing of personal data collected through the website panoramadiariocoi.com and related programs is:

Panorama Diario COI
Address: Cl. 44 #66 B 62, Bogotá, Colombia
Email: info@panoramadiariocoi.com
Phone: +57 320 802 7367

Panorama Diario COI operates as an educational center providing economic analysis, webinars, and individual consultation services. It does not operate as a financial services provider, investment advisor, or credit intermediary.

2. Legal Framework

This Privacy Policy is governed by the following Colombian legal instruments:

• Ley 1581 de 2012 (General Personal Data Protection Law of Colombia)
• Decreto 1377 de 2013 (Partial regulation of Ley 1581 de 2012)
• Decreto 1074 de 2015 (Sole Regulatory Decree for Commerce, Industry and Tourism)
• Instructions issued by the Superintendencia de Industria y Comercio (SIC) as the data protection supervisory authority

By accessing this website or participating in our programs, you acknowledge this Privacy Policy and consent to the processing of your personal data as described herein, to the extent such consent is required by applicable law.

3. Data We Collect

3.1 Data Provided Directly

When you complete a contact form, register for a webinar, or request a consultation, we collect:

• Full name
• Email address
• Phone number
• Organization or sector (where provided)
• The content of your message or inquiry
• Area of interest selected

3.2 Data Collected Automatically

When you visit our website, we may automatically collect:

• IP address and approximate geographic location
• Browser type and version
• Operating system
• Pages visited and time spent on each page
• Referring website address
• Date and time of access

This technical data is collected through cookies and similar technologies. Please refer to our Cookie Policy for further details.

3.3 Sensitive Data

We do not intentionally collect sensitive personal data as defined under Ley 1581 de 2012 (data relating to racial or ethnic origin, political opinions, religious beliefs, trade union membership, health, sex life, or biometric data). Please do not include such information in your communications with us.

4. Purposes of Processing

We process your personal data for the following purposes:

1. To respond to your inquiries and provide information about our educational programs
2. To schedule and deliver webinar sessions and individual consultations you have requested
3. To send you program-related communications, session reminders, and materials
4. To improve the quality and relevance of our educational content
5. To comply with legal obligations applicable to our operations in Colombia
6. To analyze website usage patterns for the purpose of improving user experience (using anonymized or aggregated data where possible)
7. To manage our relationship with program participants and respond to complaints or queries

We do not use your personal data for automated decision-making that produces legal or similarly significant effects on you.

5. Legal Basis for Processing

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

• Your consent: For optional communications and analytics cookies, we rely on the consent you provide via our cookie consent mechanism or when submitting a form
• Contractual necessity: Processing necessary to deliver the program or service you have requested
• Legal obligation: Processing required to comply with applicable Colombian law
• Legitimate interest: Processing for website security, fraud prevention, and improving our educational services, where such interests are not overridden by your rights

Where we rely on consent, you have the right to withdraw it at any time without affecting the lawfulness of processing carried out before withdrawal.

6. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes described in this policy, or as required by applicable law:

• Contact inquiries: Up to 24 months from the date of last contact
• Program participant records: Up to 5 years from the end of program participation, for legal and administrative purposes
• Website analytics data: Up to 26 months in anonymized or aggregated form
• Legal compliance records: As required by applicable Colombian tax and commercial law

When retention periods expire, data is securely deleted or anonymized so that it can no longer be associated with an identified or identifiable individual.

7. Data Sharing and Disclosure

We do not sell, rent, or trade your personal data to third parties. We may share your data in the following limited circumstances:

• Service providers: Third-party vendors who assist in operating our website, delivering webinar technology, or providing email communication services, subject to contractual data processing agreements that prohibit them from using data for their own purposes
• Legal requirements: When disclosure is required by Colombian law, court order, or request from a competent authority such as the Superintendencia de Industria y Comercio
• Protection of rights: Where necessary to protect the rights, property, or safety of Panorama Diario COI, our participants, or others

Any third-party service providers engaged by us are required to maintain appropriate security standards and to process data only on our instructions.

8. International Data Transfers

Some of our service providers may process data outside Colombia. When this occurs, we take steps to ensure that appropriate safeguards are in place in accordance with Ley 1581 de 2012 and the SIC's requirements for international data transfers, including requiring contractual protections equivalent to those applicable in Colombia.

9. Your Rights as a Data Subject

Under Ley 1581 de 2012, you have the following rights with respect to your personal data:

• Right to know: To be informed about the personal data we hold about you and how it is processed
• Right of access: To request a copy of the personal data we hold about you
• Right to update and rectify: To request correction of inaccurate or incomplete data
• Right to deletion: To request erasure of your data where it is no longer necessary for the purposes for which it was collected, subject to legal retention obligations
• Right to revoke consent: To withdraw consent to processing at any time where processing is based on consent
• Right to complain: 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 contact us at info@panoramadiariocoi.com with the subject line "Data Rights Request." We will respond within the timeframes established by applicable law (generally 10 business days for acknowledgment, 15 business days for resolution).

10. Cookies and Tracking Technologies

Our website uses cookies and similar technologies to function properly and to improve your experience. For detailed information about the cookies we use, their purposes, and how to manage your preferences, please refer to our Cookie Policy.

11. Security Measures

We implement technical and organizational measures appropriate to the risk level associated with the processing of your personal data. These include:

• Encrypted data transmission using TLS/SSL protocols
• Access controls limiting data access to authorized personnel only
• Regular review of security practices
• Procedures for detecting, reporting, and investigating personal data incidents

No transmission over the internet or electronic storage method is completely secure. While we apply reasonable security measures, we cannot guarantee absolute security of data transmitted to or stored on our systems.

12. Minors

Our programs and website are directed at adults. We do not knowingly collect personal data from individuals under 18 years of age. If you believe a minor has provided us with personal data, please contact us at info@panoramadiariocoi.com and we will take steps to delete that information promptly.

13. Changes to This Policy

We 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 or programs after a policy update constitutes acceptance of the revised terms.

14. Contact Information

For questions, requests, or complaints regarding this Privacy Policy or the processing of your personal data, please contact:

Panorama Diario COI
Data Privacy Inquiries
Cl. 44 #66 B 62, Bogotá, Colombia
Email: info@panoramadiariocoi.com
Phone: +57 320 802 7367

You also have the right to lodge a complaint with the Superintendencia de Industria y Comercio (SIC), the data protection supervisory authority in Colombia, at www.sic.gov.co.