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Transformente

Personal Data Processing Policy

1. Data controller

TRANSFORMENTE S.A.S., Tax ID (NIT) 901.643.128-1, domiciled in Medellín, Colombia.

Email: info@transformente.com · Phone: +57 300 785 56 75 · Website: transformente.com

2. Purpose and scope

This policy sets out how Transformente collects, stores, uses, shares and deletes the personal data of the people it works with: website visitors, clients, participants in processes and workshops, partners, suppliers, consultants and members of the Budas de Ciudad community. It applies to every database under Transformente's responsibility and is governed by Colombian law, in particular Law 1581 of 2012 and Decree 1074 of 2015.

3. Definitions

  • Data subject: the individual whose personal data is processed.
  • Personal data: any information linked or linkable to an identified or identifiable individual.
  • Sensitive data: data affecting the subject's privacy or whose misuse could lead to discrimination, such as health data, beliefs or biometric data.
  • Processing: any operation on personal data, including collection, storage, use, sharing or deletion.
  • Authorization: the data subject's prior, express and informed consent.
  • Processor: a party that processes data on behalf of the controller.
  • Transmission: sharing data with a processor, inside or outside Colombia, for processing on the controller's behalf.
  • Transfer: sending data to another controller, inside or outside Colombia.

4. Principles

Transformente processes personal data under the principles of legality, purpose limitation, freedom, accuracy, transparency, restricted access and circulation, security and confidentiality set out in Article 4 of Law 1581 of 2012.

5. Data we process

  • Visitors using the contact form: Name, email, organization and message
  • People booking a conversation: First and last name, email, organization, role, topic of the conversation and, optionally, WhatsApp number
  • Clients and process participants: Contact details, role, organization and information arising from workshops, assessments and coaching sessions
  • Budas de Ciudad guests and community: Contact details, image, voice and testimonials, with specific authorization for publication
  • Suppliers and consultants: Identification, contact, tax and banking data needed for the contractual relationship
  • Website browsing: Technical and statistical data collected through cookies (see section 11)

Sensitive data. Some assessments and human-development processes may include information about well-being, emotions or behavioral traits. Answering those questions is always optional. Transformente requests explicit authorization to process such data, uses it only for the stated purpose and applies enhanced confidentiality measures.

Children and adolescents. When a program includes minors, Transformente processes their data in their best interest and with respect for their fundamental rights, with the authorization of their legal guardian and, where appropriate, taking their views into account according to their maturity.

6. Purposes

Transformente processes personal data to:

  1. Respond to inquiries and schedule and hold initial conversations.
  2. Prepare proposals and deliver contracted services: systemic readings, learning labs, evolution journeys and digital activations.
  3. Design, run and analyze assessments and measure the progress of each process.
  4. Issue certificates, reports and proof of participation.
  5. Manage contractual, administrative, accounting and tax relationships with clients, suppliers and consultants.
  6. Send Transformente and Budas de Ciudad content, invitations and news to those who opt in, with the option to unsubscribe in every message.
  7. Publish testimonials, image or voice of guests and participants, with prior specific authorization.
  8. Produce website usage statistics to improve the experience.
  9. Comply with legal obligations and respond to requests from competent authorities.

7. Your rights

As a data subject, you have the right to:

  1. Access, update and correct your personal data.
  2. Request proof of the authorization you granted.
  3. Be informed about how your data has been used.
  4. File complaints with Colombia's Superintendence of Industry and Commerce (SIC) after completing the inquiry or claim process with Transformente.
  5. Revoke your authorization and request deletion of your data, where no legal or contractual duty requires its retention.
  6. Access your personal data free of charge.

8. Authorization

Transformente requests prior, express and informed authorization through means that preserve proof of it: the consent checkbox on the website forms, the booking form, physical or digital documents and contracts. Authorization may also be granted through unequivocal conduct of the data subject, as provided in Decree 1074 of 2015. Cases exempt from authorization are governed by Article 10 of Law 1581 of 2012.

9. Inquiries and claims

Channel: info@transformente.com, subject line "Personal data".

Responsible area: Legal Representative of Transformente S.A.S.

  • Inquiries are answered within a maximum of ten (10) business days from receipt. If more time is needed, Transformente will explain why and set a new date, no later than five (5) additional business days.
  • Claims (correction, update, deletion or non-compliance) must include the data subject's identification, a description of the facts, a contact address and supporting documents. If a claim is incomplete, Transformente will request the missing information within five (5) days; if two (2) months pass without a response, the claim is deemed withdrawn. Once complete, the claim is flagged in the database as "claim in progress" and answered within fifteen (15) business days, extendable by up to eight (8) additional business days with prior notice.

These rights may be exercised by the data subject, their successors, their representative or attorney, or anyone acting under a stipulation in their favor.

10. Processors and international transmission

To operate the website and its services, Transformente relies on technology providers acting as processors, which may host data on servers outside Colombia, mainly in the United States and the European Union:

  • Website hosting and security: Cloudflare
  • Content management: Sanity
  • Email, calendar and appointment booking: Google Workspace / Google Calendar
  • Web analytics: Google Analytics
  • Web form delivery: Web3Forms
  • Contact database (CRM): Supabase
  • Email notifications of new contacts: Resend

Each transmission is made to providers offering adequate levels of protection, under contractual terms that guarantee the security and confidentiality of the information, in accordance with Article 26 of Law 1581 of 2012 and SIC guidance.

11. Cookies and analytics

The website uses technical cookies, necessary for it to work, and Google Analytics cookies to understand, in aggregate, how visitors navigate the site. You can set your browser to block or delete cookies; the site's core features will keep working.

Analytics cookies are only set if you accept them in the cookie notice; you can change your choice at any time from “Cookie settings” at the bottom of every page.

12. Security

Transformente applies technical, human and administrative measures to protect data against alteration, loss and unauthorized access or use: access controls, corporate accounts with strong authentication, confidentiality agreements with consultants and suppliers, and restricted access to assessment data.

13. Effective date

This policy is effective as of September 23, 2026. Data is kept for as long as needed to fulfill the purposes described and the applicable legal, accounting and contractual obligations. Any material change will be announced on this website before it takes effect.