CONTENTS
1. PURPOSE, SCOPE AND IDENTIFICATION OF THE DATA CONTROLLER
UBERFLUG COLOMBIA S.A.S. (hereinafter “UBERFLUG”), identified with Tax ID (NIT) 900.911.541-7, domiciled in Bogotá D.C., Colombia, owner and operator of the REALFLUENCERS.CO digital platform (hereinafter “REALFLUENCERS” or the “Platform”), adopts this Privacy and Personal Data Processing Policy to establish the criteria applicable to the collection, storage, use, circulation, updating, consultation, analysis, transmission, transfer, retention, erasure and, in general, any operation carried out on personal data.
This Policy applies to personal data processed by UBERFLUG in its capacity as Data Controller in relation to Realfluencers, influencers and content creators; clients, advertisers, companies and brands; registered users and visitors; prospects who complete forms; suppliers, contractors and partners; and any natural person whose data are lawfully processed through the Platform.
This Policy is supplemented by the Terms and Conditions, privacy notices, authorization mechanisms, the Cookie Policy and any other documents governing specific REALFLUENCERS features.
2. LEGAL FRAMEWORK
Personal Data Processing shall be carried out in accordance with Article 15 of the Political Constitution of Colombia; Statutory Law 1581 of 2012; Statutory Law 1266 of 2008, where applicable; Decree 1074 of 2015 and the regulatory provisions incorporated therein; the Sole Circular of the Superintendence of Industry and Commerce; External Circular No. 002 of August 21, 2024 on Personal Data Processing in Artificial Intelligence Systems; and any other laws, administrative instructions and judicial decisions that amend, supplement, regulate or replace the foregoing.
Personal data protection rules apply regardless of the technology used. Accordingly, the use of automated tools or artificial intelligence does not exclude compliance with the principles, rights, duties and security measures established under Colombian regulations.
3. DEFINITIONS
Authorization: Prior, express and informed consent of the Data Subject to carry out the Processing of personal data.
Database: An organized set of personal data subject to Processing.
Personal Data: Any information linked or capable of being associated with one or more identified or identifiable natural persons.
Public Data: Data that are not semi-private, private or sensitive and whose nature allows unrestricted access in accordance with the Constitution and the law.
Private Data: Data that, due to their intimate or restricted nature, are relevant only to the Data Subject.
Semi-private Data: Data whose knowledge or disclosure may be of interest, in addition to the Data Subject, to a particular sector, group of persons or society in general.
Sensitive Data: Data that affect the privacy of the Data Subject or whose misuse may give rise to discrimination, including, among others, data relating to health, sex life, biometrics, racial or ethnic origin, political orientation, religious or philosophical beliefs, and trade union membership.
Data Processor: A public or private natural or legal person that Processes personal data on behalf of the Data Controller.
Data Controller: A public or private natural or legal person that decides on the Database and/or the Processing.
Artificial Intelligence System or AI System: A machine-based system that, from the information it receives, infers how to generate outputs such as predictions, content, recommendations or decisions.
Data Subject: A natural person whose personal data are subject to Processing.
Processing: Any operation or set of operations performed on personal data, such as collection, storage, use, circulation, consultation, updating, analysis or erasure.
Transfer: The sending of personal data to a recipient acting as a Data Controller located inside or outside Colombia.
Transmission: Processing of personal data involving their communication to a Data Processor so that the Processor may Process them on behalf of the Data Controller, inside or outside Colombia.
Personal information that is publicly accessible on the internet or social networks does not, by that circumstance alone, acquire the status of Public Data. Its collection and use must have a valid legal basis and respect the purpose for which it was lawfully published or authorized.
4. PRINCIPLES APPLICABLE TO PROCESSING
Legality: Processing shall be subject to the Colombian legal system.
Purpose limitation: Processing shall pursue legitimate, specific purposes communicated to the Data Subject.
Freedom: Processing shall require prior, express and informed authorization, except where a legal exception applies.
Truthfulness or quality: Information must be truthful, complete, accurate, up to date, verifiable and understandable.
Transparency: The Data Subject may obtain information regarding the existence and characteristics of the Processing.
Restricted access and circulation: Data shall only be Processed by authorized persons and for compatible purposes.
Security: Technical, human and administrative measures shall be adopted to prevent alteration, loss, consultation, use or unauthorized or fraudulent access.
Confidentiality: Persons involved in Processing shall ensure the confidentiality of non-public personal data.
Necessity and minimization: Only information that is adequate, relevant and necessary for the stated purpose shall be collected and Processed.
Storage limitation: Data shall be retained for the reasonable and necessary period required for the purpose that justified the Processing and to comply with legal or contractual obligations.
Accountability: UBERFLUG shall adopt appropriate, effective and verifiable measures that allow it to demonstrate compliance with the applicable regulations.
Privacy by design and by default: Data protection shall be incorporated from the planning, design, configuration and operation of products, processes and technologies.
Suitability, reasonableness and proportionality: Processing, particularly when involving AI, must be suitable for the proposed objective, necessary compared with less intrusive alternatives, reasonable, and proportionate to the impact on the Data Subject's rights.
5. DATA SUBJECTS AND CATEGORIES OF PERSONAL DATA
5.1. Data Subjects
Realfluencers, influencers and content creators.
Clients, advertisers, companies, brands and their representatives or corporate contacts.
Registered users, visitors and prospects.
Suppliers, contractors, partners and contact persons.
Natural persons whose data are lawfully incorporated into campaigns, requests, communications or operational records.
5.2. Categories of data
Identification and contact details: First name, last name, type and number of identification document when necessary, email address, telephone number, city, country, address, company, brand, position, and details of the representative or corporate contact.
Professional profile and social media: Name or pseudonym, username, profile links, photograph, professional description, content categories, general location, audience metrics, experience, portfolio, fees and availability.
Contractual, commercial and financial data: Proposals, campaigns, contracts, orders, deliverables, invoices, payments, collection accounts, withholdings, tax information, transaction history and any other information necessary for the commercial relationship.
Multimedia and content: Images, photographs, videos, audio files, documents, advertising materials, messages, files and content uploaded or shared through the Platform.
Technical and browsing data: IP address, date and time of access, browser, operating system, device, language, pages viewed, online identifiers, cookies, and security events or logs.
Campaign briefs: Information about the product or service, objectives, intended audience, dates, type of content, estimated budget, instructions and any other elements entered by the user to describe a campaign.
The absence of a name, email address or telephone number in a technical record does not mean that the information is anonymous. As long as an IP address, identifier, combination of attributes or other element can reasonably be associated with an identified or identifiable natural person, it shall be treated as personal data, as applicable.
6. SOURCES OF INFORMATION
Directly from the Data Subject, through forms, registrations, contracts, messages, files or communications.
Through the use and browsing of REALFLUENCERS, including technical logs, cookies and security events.
From clients or brands that provide information about contacts or third parties, when they are legally entitled to do so.
From suppliers or partners that demonstrate a lawful basis for providing the information.
From records and publicly accessible sources that are legally authorized.
From social networks or websites, exclusively where there is authorization, a legal basis, or another lawful basis and purpose compatible with the intended use.
UBERFLUG shall not presume that names, photographs, metrics, profiles, usernames or any other information visible on the internet may be freely collected, incorporated into a Database, profiled or reused for any purpose.
7. PURPOSES OF PROCESSING
7.1. Registration, operation and provision of services
Create, validate, manage and delete accounts.
Verify identity and data required for the contractual relationship.
Publish and manage authorized Realfluencer profiles.
Enable access to Platform features and services.
Facilitate interaction among brands, clients and influencers.
Manage campaigns, proposals, collaborations, deliverables and communications.
Carry out pre-contractual, contractual and post-contractual relationships.
Process invoicing, payments, withholdings and accounting or tax obligations.
Retain evidence of authorizations, transactions, communications and operations.
7.2. “Request Contact” form
Receive and analyze collaboration requests.
Contact the interested party and coordinate meetings or pre-contractual activities.
Understand the general characteristics of the campaign and prepare proposals.
Manage the campaign brief and conduct searches for compatible profiles.
Maintain traceability of the service provided.
Providing the data required to manage the request is voluntary. However, the absence of essential information may prevent the request from being properly handled.
7.3. Customer service and quality
Handle requests, inquiries, petitions, complaints and claims.
Conduct satisfaction surveys and evaluate service quality.
Resolve technical incidents and follow up on requests.
Contact the Data Subject to confirm data required for performance of the contractual relationship.
7.4. Commercial and promotional communications
With the Data Subject's authorization, or where an applicable legal relationship permits it, UBERFLUG may send commercial, advertising or promotional information regarding REALFLUENCERS services, campaigns, news, events, loyalty initiatives, studies and content of interest by email, telephone, SMS, instant messaging or other authorized channels. The Data Subject may request the suspension of promotional communications at any time, without affecting communications necessary to perform a contract, provide a service, respond to a request or comply with a legal obligation.
7.5. Analytics, security and fraud prevention
Generate statistics and analytics regarding use of the Platform.
Improve features, navigation, content and user experience.
Prevent bots, unauthorized access, fraud, impersonation, abuse or use contrary to the Terms and Conditions.
Investigate security events and protect accounts, systems and infrastructure.
Comply with legal, judicial or administrative requirements.
7.6. Multimedia and public profiles
UBERFLUG may store and publish, according to the authorized purpose, image, video and audio files, profiles and other content supplied by users in order to display profile information, exchange materials between clients and Realfluencers, and carry out campaigns or requests developed through the Platform.
7.7. Third parties and partners
UBERFLUG may provide or transmit information to suppliers, advisors, contractors, partners and third parties when necessary to provide services, perform contracts, process payments, invoice, provide support, host information, protect the Platform, conduct analytics, comply with legal obligations or pursue other expressly disclosed purposes. Disclosure shall be limited to the data necessary and shall be subject to the applicable contractual and security measures.
8. SENSITIVE DATA AND DATA OF CHILDREN AND ADOLESCENTS
8.1. Sensitive data
The provision and Processing of sensitive data shall be optional for the Data Subject. UBERFLUG shall expressly inform the Data Subject when a request involves this category of information and shall not condition ordinary access to services on the provision of sensitive data, unless such data are strictly necessary and there is a valid legal basis.
Users shall refrain from including sensitive data in briefs, open-ended forms, messages or files when such data are not indispensable for the campaign or service.
8.2. Children and adolescents
Processing of data concerning children and adolescents shall be exceptional and shall be carried out only where it serves their best interests, respects their fundamental rights and complies with the applicable legal requirements. Where appropriate, authorization shall be obtained from the legal representative and the minor shall be heard in accordance with his or her maturity and ability to understand the Processing.
9. PROCESSING OF PERSONAL DATA THROUGH ARTIFICIAL INTELLIGENCE SYSTEMS
9.1. Functionality and provider
REALFLUENCERS uses the Gemini model, provided by Google and accessed through the Google AI / Generative Language API, as a support tool to analyze the text of the campaign brief entered by the user and facilitate the identification of useful criteria for searching for profiles that may be compatible with the campaign.
Artificial intelligence may interpret elements such as the product or service, dates, type of content, target audience, estimated budget and other criteria described by the user, for the purpose of structuring or improving the query performed in the Realfluencers search tool.
9.2. Data separation and disclosed architecture
According to the technology architecture disclosed by the REALFLUENCERS webmaster:
The first and last name, corporate email address, telephone number, and company or brand fields entered in the “Request Contact” form are stored in the REALFLUENCERS database, currently managed through Airtable.
Those identification and contact fields are not intentionally sent to the Gemini model to perform the search.
Gemini is used in the search tool to process the text of the campaign brief.
Cloudflare provides infrastructure, security, transport or web traffic management services and may retain technical usage and security logs.
The foregoing separation does not entirely exclude the possibility of Processing personal data through AI, because the brief is a free-text field in which the user could voluntarily or accidentally include names, social media profiles, identifiers or other information associated with natural persons.
9.3. Information that should not be included in the brief
Personal identification numbers.
Private addresses or precise geolocation.
Individual financial information or payment method data.
Passwords, credentials or access keys.
Health, biometric or genetic data.
Information about children or adolescents that is not strictly necessary and lawfully authorized.
Information regarding sexual orientation, racial or ethnic origin, political opinions, religious beliefs or trade union membership.
Any other sensitive, confidential or unnecessary data for describing the campaign.
REALFLUENCERS may implement notices, minimization rules, technical filters or human review to prevent unnecessary personal information or information incompatible with the purpose of the service from being sent to the AI system.
9.4. Purposes of AI
Interpret the campaign brief.
Structure search criteria.
Identify potentially relevant categories or attributes.
Facilitate the preliminary selection of profiles.
Improve the relevance of recommendations and searches.
Support the work of advisors or authorized users.
Personal data shall not be reused for purposes incompatible with those disclosed. Any material change in the purpose, categories of data, provider or scope of the Processing shall be subject to prior assessment and, where applicable, notice to and new authorization from the Data Subject.
9.5. Results, human review and non-discrimination
Results generated through AI are for guidance purposes and may contain errors, incomplete inferences or recommendations that do not fully reflect the context of a campaign or profile. They shall not be used as the sole basis for contractual, disciplinary, discriminatory or exclusionary decisions that produce legal effects or significant impacts on a natural person.
Where a recommendation may materially affect a Data Subject, UBERFLUG shall seek to provide a human review mechanism that allows the Data Subject, as appropriate, to submit additional information, request corrections or challenge the result.
9.6. Transparency and rights regarding AI
The Data Subject may request understandable information regarding the existence of Processing through AI, the categories of data involved, the purpose of the Processing, the technology providers, the general criteria used to produce a recommendation, and the existence of human review mechanisms. This duty does not require the disclosure of source code, trade secrets, credentials, vulnerabilities, cybersecurity measures or third-party protected information.
9.7. Risk management and impact assessment
Before implementing or materially modifying an AI feature, UBERFLUG shall assess the suitability, necessity, reasonableness and proportionality of the Processing, as well as the risks of bias, discrimination, inaccuracy, data leakage, manipulation, unauthorized use, loss of information or impairment of rights.
Where an AI feature is likely to pose a high risk to the rights of Data Subjects, UBERFLUG shall document a privacy impact assessment that includes, at a minimum, a description of the Processing operations, an assessment of specific risks, and the measures planned to prevent or mitigate their occurrence. If there is material uncertainty regarding the possibility of causing serious or irreversible harm, precautionary measures shall be adopted before the Processing continues.
10. TECHNOLOGY PROVIDERS, DATA PROCESSORS AND THIRD PARTIES
To operate REALFLUENCERS and provide its services, UBERFLUG may rely on third parties acting as Data Processors, sub-processors, independent Data Controllers or technology providers. Their involvement shall be limited to the purposes necessary to provide the service or comply with legal and contractual obligations.
10.1. Identified technology providers
Airtable: Service used for hosting, organizing and managing databases, including information entered in forms and the database of authorized profiles.
Cloudflare: Provider of infrastructure, security, content delivery and web traffic management or transport. It may process technical logs and security events associated with use of the Platform.
Google - Gemini: Provider of the artificial intelligence tool used to process the campaign brief in the search tool.
In addition, UBERFLUG may use providers of analytics, hosting, communications, payments, invoicing, support, cybersecurity, fraud prevention or other services necessary for the operation of REALFLUENCERS. The list of providers may change over time without, by itself, constituting a change in purpose, provided that the Processing remains compatible and the safeguards required by law are maintained.
UBERFLUG shall seek to enter into or verify, as applicable, data transmission agreements, processing agreements, confidentiality obligations, purpose restrictions, security measures, subcontracting rules, and mechanisms for the return or deletion of information.
11. DOMESTIC AND INTERNATIONAL DATA TRANSMISSION AND TRANSFER
The provision of technology services may involve personal information being Processed, stored or accessed from infrastructure located inside or outside Colombia. Where the operation constitutes a data transmission, UBERFLUG shall give instructions to the Data Processor and require reasonable measures regarding confidentiality, security, purpose limitation, exercise of rights, and deletion or return of the information. Where the operation constitutes an international data transfer, UBERFLUG shall verify the existence of a valid legal basis and compliance with the requirements established by Law 1581 of 2012 and the instructions of the Superintendence of Industry and Commerce.
12. AUTHORIZATION FOR PROCESSING
Except in cases exempted by law, UBERFLUG shall request the Data Subject's prior, express and informed authorization through mechanisms that allow evidence of its granting to be retained and subsequently consulted. Authorization may be obtained through unticked acceptance boxes, electronic forms, contracts, documents, recordings, messages or other unequivocal conduct from which it may reasonably be concluded that the Data Subject authorized the Processing.
When requesting authorization, UBERFLUG shall inform the Data Subject, at a minimum, of: (i) the Processing to which the data will be subject and its purpose; (ii) the optional nature of responses when sensitive data or data of children and adolescents are involved; (iii) the Data Subject's rights; and (iv) the identification, physical or electronic address, and telephone number of the Data Controller.
Authorization shall be requested for the reasonable and necessary period required to fulfill the purposes that gave rise to the Processing, without prejudice to the periods during which information must be retained pursuant to legal, contractual, accounting, tax, evidentiary or security requirements.
Where authorization is requested for commercial or promotional communications that are not necessary to perform the main service, UBERFLUG shall seek to distinguish it from the acceptance required to manage the request or contractual relationship.
13. RIGHTS OF DATA SUBJECTS
Know, update and rectify their personal data.
Request proof of the authorization granted, except in cases exempted by law.
Be informed, upon request, of the use made of their personal data.
File complaints with the Superintendence of Industry and Commerce for violations of the data protection regime, after exhausting the applicable procedure before UBERFLUG.
Withdraw authorization and/or request erasure of the data where the Processing does not respect constitutional and legal principles, rights and guarantees, without prejudice to applicable exceptions.
Access, free of charge, their personal data subject to Processing in the cases and under the conditions established by law.
Request information related to the Processing of their data through AI systems and, where appropriate, request human review of results that may materially affect them.
Any other rights recognized by the Constitution, the law and the instructions of the competent authority.
14. INQUIRIES, COMPLAINTS, WITHDRAWAL OF AUTHORIZATION AND ERASURE
14.1. Contact channel
UBERFLUG's Administration area is responsible for coordinating the handling of requests related to personal data protection. Data Subjects may exercise their rights through:
Email: soporte@realfluencers.co
Address: Calle 70 # 9 - 95, Ark House, Bogotá D.C., Colombia.
Telephone: +57 301 794 0541.
14.2. Inquiries
Data Subjects or their successors may inquire about personal information contained in UBERFLUG's Databases. The inquiry shall be answered within a maximum period of ten (10) business days from the date of receipt. If it is not possible to respond within that period, the reasons for the delay and the date on which the inquiry will be answered shall be communicated; such date may not be more than five (5) business days after the expiration of the initial period.
14.3. Complaints
A Data Subject or successor who considers that information contained in a Database should be corrected, updated or erased, or who identifies an alleged breach of any of the duties established in Law 1581 of 2012, may submit a complaint to UBERFLUG. The complaint shall contain, at a minimum, the identification of the Data Subject, a description of the facts, the address or contact method, and the documents intended to support the complaint.
If the complaint is incomplete, the interested party shall be asked, within five (5) days of its receipt, to remedy the deficiencies. If two (2) months have elapsed since the request for additional information without the requested information being provided, the complaint shall be deemed withdrawn. Where UBERFLUG is not competent to handle the complaint, it shall forward it to the appropriate party within two (2) business days and inform the interested party, where applicable.
Once a complete complaint has been received, a notation stating “complaint in process” and the reason for the complaint shall be entered in the Database within no more than two (2) business days and shall remain there until the complaint is decided. The maximum period for responding to the complaint shall be fifteen (15) business days counted from the day following its receipt. If it is not possible to respond within that period, the reasons for the delay and the response date shall be communicated; such date may not be more than eight (8) business days after the expiration of the initial period.
14.4. Withdrawal of authorization and erasure
The Data Subject may request withdrawal of authorization and/or erasure of their data when the purposes that legitimized the Processing have ceased to exist, the Processing breaches the data protection regime, or another legal ground applies. Withdrawal or erasure shall not apply where there is a legal or contractual duty requiring the information to be retained, where it is necessary for the establishment, exercise or defense of claims, or where another exception provided by law applies.
15. RETENTION, ARCHIVING AND DELETION
UBERFLUG shall retain personal data for the reasonable and necessary period required to fulfill the purposes communicated to the Data Subject and for as long as there is a legal, contractual or pre-contractual relationship that justifies the Processing. Once the purposes have been fulfilled, the information may remain blocked or subject to restricted access for any additional periods required by accounting, tax, commercial, contractual or evidentiary rules, fraud prevention requirements, information security needs or the handling of claims.
Law 1581 of 2012 does not establish a single universal retention period applicable to all categories of data. Accordingly, UBERFLUG shall apply criteria of necessity, purpose, proportionality and compliance with legal obligations to determine the life cycle of each Database.
As a minimum operational rule, UBERFLUG shall:
Retain evidence of authorizations and requests to exercise rights for as long as necessary to demonstrate compliance with legal obligations.
Retain contractual and transactional information for the periods required by commercial, accounting and tax legislation or by other applicable special rules.
Delete or anonymize data once the purpose has expired and there is no legal or contractual retention obligation.
Restrict access to information that must be retained solely to comply with legal obligations, handle claims or exercise rights of defense.
Periodically review the need to retain prospect forms, briefs, inactive profiles, logs, content, AI results and any other information that is no longer actively used.
16. INFORMATION SECURITY AND INCIDENT MANAGEMENT
UBERFLUG shall adopt reasonable technical, human, administrative, physical and contractual measures proportionate to the nature of the information and the risks of the Processing, for the purpose of preventing unauthorized alteration, loss, consultation, use, access, disclosure, manipulation or destruction.
Such measures may include, as applicable:
Access controls and role-based permission management.
Authentication and secure credential management.
Encryption during transmission and, where appropriate, at rest.
Secure management of API keys and technology secrets.
Logging and monitoring of access, events and activities.
Backups and recovery procedures.
Vulnerability management, updates and secure configuration.
Supplier assessments and data protection clauses.
Staff training and confidentiality duties.
Procedures for incident management, containment, analysis and documentation.
Secure deletion or disposal of information and media.
Periodic reviews and audits of controls.
Where security safeguards are breached and there is a risk to the management of Data Subjects' information, UBERFLUG shall comply with the reporting, management and cooperation duties applicable before the Superintendence of Industry and Commerce and any other competent authorities.
17. COOKIES, ANALYTICS AND SIMILAR TECHNOLOGIES
REALFLUENCERS may use cookies, pixels, tags, local storage technologies and similar mechanisms to enable operation of the Platform, maintain sessions, remember preferences, measure usage, prevent fraud, analyze browsing and, where authorization exists, personalize content or manage advertising.
Non-essential cookies or technologies shall be subject to reasonable information and consent-management mechanisms that allow users to accept, reject or configure them, as applicable. The Platform may provide a supplementary Cookie Policy identifying categories, purposes, duration and active providers.
18. DUTIES OF UBERFLUG COLOMBIA S.A.S.
Guarantee the Data Subject's full and effective exercise of the right of habeas data.
Request and retain evidence of authorizations when required.
Inform the Data Subject of the purpose of collection and the rights available to them.
Retain information under appropriate security conditions.
Ensure that information supplied to Data Processors is truthful, complete, accurate, up to date, verifiable and understandable.
Update and rectify information and timely communicate relevant changes to Data Processors, where appropriate.
Supply Data Processors only with data whose Processing is lawful.
Require Data Processors to comply with applicable security, confidentiality and privacy conditions.
Handle inquiries and complaints within the statutory time limits.
Adopt internal policies and procedures for proper compliance with the data protection regime.
Inform the Data Processor when data are disputed by the Data Subject.
Inform the Data Subject, upon request, of the use made of their data.
Inform the data protection authority when events occur that must legally be reported.
Comply with the instructions and requirements of the Superintendence of Industry and Commerce.
19. ACCOUNTABILITY, PRIVACY BY DESIGN AND RISK MANAGEMENT
UBERFLUG shall incorporate data protection criteria into the design, development, acquisition, configuration and modification of features involving the Processing of personal information. The organization shall seek to document compliance decisions, risk identification, mitigation measures, third-party management and assessments performed in relation to new technologies.
In projects involving AI or advanced analytics, measures such as minimization, pseudonymization, anonymization or other techniques intended to reduce unnecessary identification of Data Subjects shall be applied according to the level of risk. Security and privacy measures shall be capable of periodic evaluation and improvement.
20. AMENDMENTS, EFFECTIVE DATE AND ACCESS TO THE POLICY
20.1. Amendments
UBERFLUG may amend this Policy when its services, features, providers, technologies, operations or the regulatory framework change. Material changes relating to purposes, categories of data, recipients, AI systems or Data Subject rights shall be communicated before implementation and, where legally required, new authorization shall be requested.
20.2. Effective date
This Policy is Version 3 and takes effect on August 12, 2026. It shall remain in force for as long as UBERFLUG Processes personal data through REALFLUENCERS and until it is replaced by a subsequent version.
20.3. Access
The current version shall be available on the REALFLUENCERS website, in the Privacy and Personal Data Processing Policy section: https://realfluencers.co/en/privacy-policy
Requests relating to personal data protection shall be sent to soporte@realfluencers.co
ANNEX 1. PRIVACY NOTICE - “REQUEST CONTACT” FORM
UBERFLUG COLOMBIA S.A.S., Tax ID (NIT) 900.911.541-7, operator of REALFLUENCERS.CO, shall Process the data entered in this form to receive and manage your request, contact you, analyze the characteristics of your campaign, prepare proposals and coordinate a possible collaboration. The campaign brief text may be processed using Google Gemini to support the search for compatible profiles; the first name, corporate email address, telephone number, and company or brand fields are not intentionally sent to the model to perform that search.
You may review the Privacy and Personal Data Processing Policy at https://realfluencers.co/en/privacy-policy and exercise your rights to know, update, rectify, request proof of authorization, be informed about the use of your data, withdraw authorization, request erasure, and submit inquiries or complaints through the email address soporte@realfluencers.co
Mandatory authorization to manage the request: “I have read the Privacy Notice and authorize UBERFLUG COLOMBIA S.A.S. to Process my personal data in order to manage this contact and collaboration request.”
Optional authorization for commercial communications: “I authorize the sending of commercial, advertising or promotional communications regarding REALFLUENCERS services, campaigns and news.”
ANNEX 2. WARNING FOR THE CAMPAIGN BRIEF FIELD
Do not include unnecessary personal data. Avoid entering identity documents, private addresses, financial information, health data, biometric data, passwords, information about children or adolescents, or any other sensitive or confidential data. The brief text may be analyzed using an artificial intelligence tool to support the search for profiles compatible with the campaign.
ANNEX 3. GENERAL AUTHORIZATION FOR PERSONAL DATA PROCESSING
In my capacity as Data Subject, I hereby give my prior, express and informed authorization to UBERFLUG COLOMBIA S.A.S., Tax ID (NIT) 900.911.541-7, to collect, store, use, consult, update, circulate, transmit, transfer and erase my personal data in accordance with the REALFLUENCERS.CO Privacy and Personal Data Processing Policy and for the purposes described therein, related to the provision of services, contractual and commercial management, handling of requests, security, analytics, compliance with legal obligations and, where applicable, the processing of briefs through artificial intelligence tools.
I declare that I have been informed that: (i) I may know, update and rectify my data; (ii) I may request proof of authorization; (iii) I may be informed about the use made of my data; (iv) I may withdraw authorization or request erasure where legally appropriate; (v) I may submit inquiries and complaints to UBERFLUG and, after exhausting the applicable procedure, file a complaint with the Superintendence of Industry and Commerce; and (vi) I am not required to authorize the Processing of sensitive data or data of children and adolescents unless such Processing is strictly necessary and legally permissible.
Channel for exercising rights: soporte@realfluencers.co Address: Calle 70 # 9 - 95, Ark House, Bogotá D.C., Colombia. Telephone: +57 301 794 0541.
I state that this authorization was presented to me before the collection of my data and that I grant it freely, voluntarily and on an informed basis.
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