1. Introduction
In compliance with the Constitución Política de Colombia (the Colombian Constitution), Ley 1581 de 2012, Decreto 1377 de 2013, Decreto 1074 de 2015, and the other rules governing personal data protection in Colombia, MOVE ELECTROMOBILITY SOLUTIONS DE COLOMBIA S.A.S. (hereinafter "MOVE" or the "Company") adopts this Personal Data Processing and Protection Policy.
MOVE guarantees the constitutional right of all individuals to know, update, rectify, and delete the information collected about them in databases or files, as well as to revoke the authorization granted for the processing of their personal data.
2. Data Controller
Corporate name: MOVE ELECTROMOBILITY SOLUTIONS DE COLOMBIA S.A.S.
Company type: Simplified stock corporation (Sociedad por Acciones Simplificada, S.A.S.)
NIT (tax ID): 901969211-5
Domicile: Colombia
Address: Not applicable
Contact email: ventas@moveyow.com
MOVE acts as the Data Controller for personal data.
3. Applicable Legal Framework
This policy is governed primarily by the following rules:
- Article 15 of the Constitución Política de Colombia
- Ley 1581 de 2012
- Decreto 1377 de 2013
- Decreto 1074 de 2015
- Circular Externa 002 de 2015 of the Superintendencia de Industria y Comercio
- Applicable personal data protection legislation in Mexico (Ley Federal de Protección de Datos Personales en Posesión de los Particulares – LFPDPPP), where relevant
- Any other rules that amend, supplement, or replace the above
4. Definitions
For the purposes of this policy, the definitions set out in Ley 1581 de 2012 apply, including:
- Personal data: Any information linked to, or that can be associated with, a natural person.
- Sensitive data: Information that affects the data subject's privacy or whose misuse may lead to discrimination.
- Data subject: The natural person whose personal data are processed.
- Processing: Any operation performed on personal data, such as collection, storage, use, circulation, or deletion.
- Authorization: The data subject's prior, express, and informed consent to the processing of their personal data.
5. Principles for the Processing of Personal Data
MOVE will process personal data in accordance with the following principles:
- Legality: Processing will be carried out in accordance with the law.
- Purpose: Data will be processed for a legitimate purpose, of which the data subject is informed.
- Freedom: Processing will only take place with the data subject's authorization, except where the law provides otherwise.
- Truthfulness or quality: Information will be truthful, complete, accurate, and up to date.
- Transparency: The data subject's right to obtain information about the use of their data will be guaranteed.
- Restricted access and circulation: Access to the data will be limited to authorized persons.
- Security: Measures will be adopted to protect personal data.
- Confidentiality: Information will be handled with confidentiality.
6. Personal Data Collected
MOVE may collect and process, among others, the following personal data:
- Identification data (first name, last name, document type and number)
- Contact details (email, company, job title)
- Information related to contact, quote, or commercial information requests
- Technical data derived from use of the website (IP address, browser type, cookies, device)
MOVE does not collect or process financial data, banking data, or payment methods.
Sensitive data and data of minors will not be collected unless express, reinforced authorization exists in accordance with the law.
7. Processing Purposes
The personal data collected will be processed for the following purposes:
- Handling information, contact, and quote requests
- Providing and managing electric mobility and fleet management services
- Managing commercial, contractual, and pre-contractual relationships
- Complying with legal, regulatory, and contractual obligations in Colombia and Mexico
- Managing customer service processes, requests, complaints, and claims
- Sending operational, informational, and commercial communications related to the services
- Improving the user experience on the website and digital channels
- Conducting internal analysis, usage metrics, and business statistics
8. Rights of Data Subjects
Data subjects have the right to:
- Know, update, and rectify their personal data
- Request proof of the authorization granted
- Be informed about how their data have been used
- File complaints with the Superintendencia de Industria y Comercio (Colombia's data protection authority)
- Revoke the authorization and/or request the deletion of their data, where no legal or contractual duty exists
- Access their personal data free of charge
9. Procedure for Exercising Rights
Data subjects may exercise their rights by writing to the following email address:
Inquiries
Will be answered within a maximum of ten (10) business days from receipt.
Claims
Will be addressed within a maximum of fifteen (15) business days, in accordance with applicable regulations.
10. Authorization of the Data Subject
MOVE will request prior, express, and informed authorization for the processing of personal data, which may be obtained through physical, electronic, or digital means.
The data subject may revoke their authorization at any time, provided no legal or contractual duty prevents the deletion of the data.
11. Transfer and Transmission of Data
MOVE may transmit personal data to technology providers, operational providers, or strategic partners located in Colombia or Mexico, only where necessary for the proper provision of the services.
In all cases, MOVE will ensure adequate levels of personal data protection and compliance with applicable regulations.
12. Security Measures
MOVE adopts reasonable technical, human, and administrative measures to protect personal data against unauthorized access, loss, alteration, misuse, or disclosure.
13. Use of Cookies
MOVE's website may use cookies and similar technologies to improve the user experience, analyze site usage, and optimize its services.
Users may configure their browser to accept or reject cookies.
14. Term
This policy takes effect upon its publication on the website of MOVE ELECTROMOBILITY SOLUTIONS DE COLOMBIA S.A.S. and will remain in force for as long as personal data processing takes place.
Databases will be kept for a period consistent with the purpose for which the data were collected.
15. Modifications
MOVE reserves the right to modify this policy at any time. Any substantial change will be communicated in a timely manner through the website.