In Philippi, Prietocarrizosa, Ferrero DU & Uría SAS; Philippi, Prietocarrizosa, Ferrero DU & Uría S. Civil de R.L. and Philippi, Prietocarrizosa, Ferrero DU & Uría SpA (hereinafter, PPU or the Controllers) use different technologies to improve the efficiency and control of our web portal, including the experience of users who browse our website. These technologies include the use of third-party cookies. This Cookies Policy (hereinafter the Policy) regulates the collection, storage, organization, use, circulation, updating and management (hereinafter the “Treatment”) of Personal Data that is collected by the Responsible by means of cookies through the website of the Controllers.

Rights that assist the owner

Know, update and rectify your personal data in front of the Managers and Managers who process the personal data collected on behalf of the Managers. This right may be exercised against partial, inaccurate, incomplete, fractioned, misleading data or those whose treatment is expressly prohibited or has not been authorized.
Request proof of the authorization granted to the Controllers, except when expressly excepted as a requirement for processing.
Be informed about the treatment that has been given to your personal data by the Responsible and the Treatment Managers.
Submit complaints to the Superintendence of Industry and Commerce for any violation of current personal data protection regulations.
Revoke the authorization and/or request the deletion of your data when the treatment does not respect the constitutional and legal principles, rights and guarantees or when there is no legal or contractual obligation to remain in the respective database.
Free access to your personal data that has been processed.

Use of cookies

A cookie are small information files that are downloaded to the user’s computer, Smartphone or Tablet when accessing certain web pages to obtain personal information, track behavior, and store and retrieve information about browsing and consumption habits that are carried out from said equipment. Through cookies, web pages remember information about the user’s visit, which allows a better and safer browsing experience to be provided.

The PPU website uses “cookies” as online tracking and advertising technology. By enabling cookies or keeping that feature enabled, the user authorizes PPU to automatically collect and store information including, but not limited to: the IP address or device ID assigned to the end device, platform ID, computer, mobile device, or any other device or mechanism through which you access the web page, text content and images, as well as data files provided for download, the activities of users on the web page, the type of browser browsing, as well as the date and time of entry and use, cookies, fingerprints, web logs, web becons, web crawlers, among others.

Cookie types

The types of cookies that are being used on this portal are identified below, as well as their function:

By duration:

Session: store user data only for the duration of their session on the website. Once the user leaves the website, the collected information is deleted.

Persistent: store user data for long periods of time, but with a specific expiration time. The period of time is greater than the duration of the user’s session on the website.

By function:

Necessary: They help make a web page usable by enabling basic functions such as page navigation and access to secure areas of the web page. The website cannot function properly without these cookies.

Preferences: The purpose of these cookies is to remember in which language the user is viewing the website so that when entering again it appears in this same language.

Statistics: Statistical cookies help web page owners understand how visitors interact with web pages by collecting and providing information anonymously.

Marketing: Marketing cookies are used to track visitors to web pages. The intent is to display ads that are relevant and engaging to the individual user, and therefore more valuable to publishers and third-party advertisers.

Purposes of cookies

PPU uses “cookies” for the following purposes: (i) to carry out performance measurement exercises; (ii) marketing and advertising purposes; (iii) design personalized service experiences; (iv) recognize the user’s device; (v) track user activity while browsing the website; (vi) improve the use of the website; (vii) generate statistical data on the user’s use of the website; (viii) identify repeat users of the website and their preferences for using the website (for example, display language); (ix) record anonymous user data such as IP address, geographic location, websites visited, among others; and (x) detect the submission of forms through automated programs or “bots”.

PPU may share information obtained through cookies with external persons or third parties (allies, clients, suppliers or companies linked to PPU), as Responsible and/or Processors, in order to improve user services. The information may be sent to external persons or third parties located in the following countries, among others: (i) Chile; (ii) Columbia; (iii) Peru; and (iv) Spain. Likewise, the information received through cookies will be used by PPU and the aforementioned third parties, for the purposes described in this policy, and any of its updates. The information obtained through cookies may be sent to external persons or third parties located in countries that do not provide adequate levels of data protection.

Third party cookies

Third-party cookies are those created and operated by external persons or third parties. The PPU website may contain cookies that will be used to collect information by third parties. These cookies are generated directly by external persons or third parties (allies, clients, suppliers or companies linked to PPU) and are sent from the server of these third parties to the user’s computer. Therefore, these third parties act as controllers of the collected data.

Control and deactivation of cookies:

We record that it is possible for the user to deactivate and/or eliminate the cookies already installed on their equipment, following the instructions of their Internet browser, through one of the following procedures, depending on the browser used:

Microsoft Internet Explorer (in the Tools Menu): Internet Options > Privacy > Advanced
Firefox: Options > Privacy > Cookies
Google Chrome (in the Tools Menu): Settings > Show advanced options > Privacy (Content Settings) > Cookies
Safari, iPad and iPhone: Preferences > Privacy
Opera: Settings > Options > Advanced > Cookies

Likewise, when entering our web portal we will request your authorization for the use of cookies. The user has the possibility to choose which types of cookies accept or reject. The essential cookies for the operation of the website are excepted from the above.

Procedures for the exercise of rights as a data owner (applicable to Colombia)

Procedure for access and/or consultation

The Owner of the data may exercise their rights of access and consultation by contacting the email datospersonales@ppulegal.com, or (1) 3268600 ext. 1640.

The query will be answered within a maximum term of ten (10) business days from the date of receipt. When it is not possible to respond to the query within said term, the interested party will be informed, stating the reasons for the delay and indicating the date on which the query will be addressed, which in no case may exceed five (5) business days following the expiration of the first term

Procedure to request updating, correction, deletion, revocation of the authorization or to present claims

When the Owner considers that the information that rests in the databases of the Responsibles must be subject to correction, updating or deletion, or when he notices the alleged breach of any of the duties contained in this law, he may file a claim with the Responsibles , which will be processed under the following rules:

The claim will be formulated by means of a request that can be sent to the email datospersonales@ppulegal.com.
To prevent unauthorized third parties from accessing the personal information of the Data Owner, it will be necessary to previously establish the Owner’s identification. When the request is made by a person other than the Holder and it is not proven that he is acting on behalf of the Holder, it will be considered as not submitted.
The request must contain the following information:
The identification of the Holder.
Contact details (physical and/or electronic address and contact telephone numbers).
The documents that prove the identity of the Holder, or the representation of his representative.
The clear and precise description of the personal data with respect to which the Owner seeks to exercise any of the rights.
The description of the facts that give rise to the claim.
The documents that you want to enforce.
Signature, identification number and fingerprint.
Filing in original.
If the claim is incomplete, the Responsible(s) will require the interested party within five (5) days of receipt of the claim to correct the failures. After two (2) months from the date of the request, without the applicant submitting the required information, it will be understood that the claim has been withdrawn.
If the Area that receives the claim is not competent to resolve it, it will notify the corresponding person within a maximum term of two (2) business days and inform the interested party of the situation.
Once the complete claim is received, a legend that says “claim in process” and the reason for it will be included in the database, within a term of no more than two (2) business days. Said legend must be maintained until the claim is decided.
The maximum term to address the claim will be fifteen (15) business days from the day following the date of receipt. When it is not possible to address the claim within said term, the interested party will be informed of the reasons for the delay and the date on which their claim will be addressed, which in no case may exceed eight (8) business days following the expiration of the first finished.

Procedure for the exercise of rights as a data owner (applicable to Peru)

Security of the information

In development of the principle of security, the Responsible Parties have adopted reasonable technical, administrative and human measures to protect the information of the Holders and prevent adulteration, loss, consultation, use or unauthorized or fraudulent access. Access to personal data is restricted to its Owners and the Responsible Parties will not allow access to this information by third parties, except for an express request from the Owner of the data or legitimate persons in accordance with the applicable regulations.

Information of the Responsible

Philippi, Prietocarrizosa, Ferrero DU & Uría S.A.S.

Address: Bogota D.C., Colombia.
Address: Cra. 9 N. 74 – 08 Office 105.
Email: rueda@ppulegal.com
Telephone: 3268600 ext. 1437

Philippi, Prietocarrizosa, Ferrero DU & Uría S. Civil de R.L.

Address: Lima, Peru.
Address: Avenida Santa Cruz N. 888, Int. 401.
Email: [Complete]Telephone: +511 513-7200

Philippi, Prietocarrizosa, Ferrero DU & Uría SpA

Address: Santiago, Chile.
Address: El Golf 40 20th floor Las Condes C.P. 7550107
Email: [Complete]Telephone: +562 23643700

Validity of the Policy

This Policy has been in force since [Complete]. Any substantial change in this Policy will be made known through an announcement on the website www.ppulegal.com.