Privacy Policy and Personal Data Processing

Data controller: MAIA MANAGEMENT S.A.S. — NIT: 901.862.977-7
Brand: Be Vida (be-vida.com)
Version: 1.0
Effective date: December 1, 2024
Last updated: December 1, 2024

1. Identification of the Data Controller

The controller of the personal data collected through the website be-vida.com is:

• Legal name: MAIA MANAGEMENT S.A.S.
• NIT: 901.862.977-7 (DV 7)
• Commercial registry: 218217 — Santa Marta Chamber of Commerce
• Address: Calle 24 #3-99, Edificio Banco de Bogotá, Suite 1102, Level 11, Santa Marta, Magdalena, Colombia
• Phone: +1 903 459 8763
• Data contact email: privacy@maia-management.com
• Legal representative: Andrew John Sidney Gallie, CE 8129525

2. Applicable Legal Framework

This policy is governed by current Colombian regulations on personal data protection, in particular:

• Law 1581 of 2012 — Personal Data Protection Law (Habeas Data)
• Decree 1377 of 2013 — Regulation of Law 1581
• Decree 1074 of 2015 — Single Regulatory Decree of the Commerce Sector
• Applicable circulars from the Superintendence of Industry and Commerce (SIC)

3. Personal Data We Collect

Through the be-vida.com website we may collect the following data:

We do not collect sensitive data (health data, racial origin, political opinions, biometric data, sexual orientation) through this website.

Data of minors: This site contains information about alcoholic beverages. It is intended exclusively for persons aged 18 or older. We do not knowingly collect data from minors.

4. Purposes of Processing

The personal data collected will be processed for the following purposes:

• Responding to inquiries, requests and questions submitted via the contact form
• Managing commercial relationships with bars, restaurants and distributors interested in Be Vida products
• Sending information about products, news and events (only with explicit consent)
• Analyzing website usage to improve the user experience (Google Analytics, only with consent)
• Complying with applicable legal obligations

5. Legal Basis for Processing

The processing of personal data is based on:

• Free, prior, express and informed consent of the data subject, obtained via the acceptance checkbox in the contact form and the cookie banner
• The execution of a contractual or pre-contractual relationship with clients and suppliers
• Compliance with applicable legal obligations of MAIA MANAGEMENT S.A.S.

6. Rights of the Data Subject (Habeas Data)

In accordance with article 8 of Law 1581 of 2012, the data subject has the right to:

• Know the personal data we hold about you and the purpose of its processing
• Update your data when it is inaccurate, incomplete or has changed
• Rectify data that is incorrect
• Delete your data when it is not necessary for the purpose that motivated its collection, or when the processing does not respect the principles of Law 1581
• Revoke authorization for processing, in cases where it is legally appropriate
• File complaints with the Superintendence of Industry and Commerce (SIC) for violations of data protection regulations
• Request proof of the authorization granted
• Be informed about the use given to your personal data

To exercise any of these rights, send your request to: privacy@maia-management.com with the subject "Habeas Data Rights". We will respond within the time frames established by law (maximum 10 business days for queries and 15 business days for claims).

7. Data Transfer and Transmission

The personal data collected may be transmitted to the following processors, solely for the purposes described in this policy:

Data transfer to the listed providers is carried out with adequate guarantees in accordance with article 26 of Law 1581 of 2012. Google LLC offers adequate guarantees through its Standard Contractual Clauses. Netlify, Inc. complies with internationally recognized data protection frameworks.

We do not sell, lease or trade personal data to third parties.

8. Cookie Policy

This website uses cookies. A cookie is a small text file stored on your device when you visit our site. We use the following cookie categories:

You can manage your cookie preferences at any time by clicking Manage cookie preferences or through your browser settings.

9. Security Measures

MAIA MANAGEMENT S.A.S. implements technical, administrative and physical measures to protect your personal data against unauthorized access, loss, alteration or unauthorized disclosure, including:

• Encrypted data transmission via HTTPS/TLS
• Restricted access to personal data, limited to authorized personnel
• Use of forms with anti-spam protection (honeypot)
• Service providers with contractual security commitments

10. Data Retention

Personal data collected through the contact form will be retained for the time necessary to respond to your inquiry and, if a commercial relationship is established, for the duration of that relationship plus applicable legal retention periods (generally 5 years for tax and commercial purposes in Colombia).

Browsing data collected by Google Analytics is retained according to the service's configuration (default maximum of 14 months of individual user data).

11. Changes to This Policy

MAIA MANAGEMENT S.A.S. reserves the right to modify this privacy policy when it deems necessary. Changes take effect upon publication on this website. We recommend that you review this page periodically.

12. Contact and Supervisory Authority

For any inquiry, Habeas Data rights request or complaint related to the processing of your personal data:

• Email: privacy@maia-management.com
• Address: Calle 24 #3-99, Edificio Banco de Bogotá, Suite 1102, Level 11, Santa Marta, Magdalena, Colombia
• Phone: +1 903 459 8763

If you believe your request has not been adequately addressed, you have the right to file a complaint with the Superintendence of Industry and Commerce (SIC) — www.sic.gov.co.

MAIA MANAGEMENT S.A.S. | NIT 901.862.977-7 | be-vida.com | Santa Marta, Colombia | Version 1.0 — December 2024