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Personal Data Processing and Privacy Policy

Version 1.0 · Last updated: September 1, 2026

DATA CONTROLLER DETAILS

Data controller: ANCESTRINA SAS

NIT: 901.575.993-4

Registered city: Bogotá D.C., Colombia

Address: SEC CONDOMINIO RINCON DE SAN PEDRO KM 6 ZN VIA GUAYMARAL CA 48

Phone: +57 311 866 2045

General email: info@ancestrina.com

Privacy and data-protection email: privacidad@ancestrina.com

Legal representative: Víctor Mario Silva Menicagli

Website: https://ancestrina.com/

1. PURPOSE AND SCOPE

This Personal Data Processing and Privacy Policy sets out the conditions under which ANCESTRINA SAS, hereinafter “ANCESTRINA”, collects, stores, uses, circulates, transmits, updates, retains and, when applicable, deletes personal data processed in the course of its activities.

This Policy applies to personal data processed through ancestrina.com, forms, email, WhatsApp, courses, programs, the store, therapeutic-accompaniment activities, communications, events, social media and other channels through which ANCESTRINA lawfully interacts with data subjects.

2. LEGAL FRAMEWORK

This Policy is interpreted in accordance with Colombian legislation applicable to personal-data protection, particularly Article 15 of the Political Constitution of Colombia, Statutory Law 1581 of 2012, Decree 1074 of 2015, the rules that amend, supplement, regulate or replace them, and the instructions of the Superintendencia de Industria y Comercio (SIC).

3. DATA-PROCESSING PRINCIPLES

ANCESTRINA will process personal data in accordance with the applicable principles of legality, purpose, freedom, truthfulness or quality, transparency, restricted access and circulation, security and confidentiality.

4. PEOPLE TO WHOM THIS POLICY MAY APPLY

This Policy may apply, among others, to people who:

  • visit ancestrina.com;
  • request information or communicate with ANCESTRINA;
  • inquire about Individual Therapeutic Accompaniment or Couple Therapy;
  • participate in processes, courses, programs, masterclasses, events or training;
  • purchase physical products, books or digital resources;
  • voluntarily subscribe to communications;
  • interact with ANCESTRINA through WhatsApp, email or social media;
  • submit consumer-service requests, complaints or claims (PQR), warranty requests, withdrawal requests, refunds or billing matters;
  • send press, interview, collaboration or professional proposals;
  • authorize the use of testimonials, photographs, voice or audiovisual material;
  • maintain any other lawful relationship with ANCESTRINA.

5. CATEGORIES OF DATA WE MAY PROCESS

5.1 Identification and contact data

Depending on the circumstances, ANCESTRINA may process data such as name, surname, identification document when necessary, date of birth or age when relevant, city, country, email address, telephone number, WhatsApp, billing address and shipping address.

5.2 Information related to requests for therapeutic accompaniment

When a person requests guidance about an individual or couple process, they may voluntarily share information about their personal situation, relationships, partner, family, reason for consultation, emotions, relevant experiences, boundaries, decisions or expectations regarding the process.

At the initial-contact stage, ANCESTRINA will seek to request only the information reasonably necessary to guide the request, avoiding turning a contact form into an extensive clinical history.

5.3 Sensitive data

In certain inquiries, a person may decide to share data considered sensitive under Colombian law. This may include, among other things, information related to physical or mental health, sex life, sexual orientation, religious or philosophical beliefs, situations of violence, intimate family information or other data that may significantly affect the data subject’s privacy.

When ANCESTRINA requests or processes sensitive data, it will inform the person of its sensitive nature, the purpose of processing, the voluntary nature of answering questions involving this type of information, and will request explicit authorization when applicable. A person is not required to provide sensitive data they do not consider necessary for the stated purpose.

5.4 Purchase and transaction data

For commercial transactions, we may process information associated with orders, purchased products, value, purchase date, billing information, shipping address, order status, tracking, returns, warranties, refunds, PQR matters and other information necessary to perform and document the transaction.

Payments may be processed by external providers. ANCESTRINA must not store full card numbers, CVV codes or other financial information whose custody corresponds exclusively to the payment provider, unless an infrastructure expressly enabled and legally appropriate for doing so exists.

5.5 Course, program and digital-resource data

We may process identity, email address, purchased program, purchase date, access to content, progress when recorded by the platform, participation, questions, attendance and operational communications related to the program.

5.6 Technical and browsing data

Depending on the site’s effective configuration and the user’s consent preferences, data such as IP address, browser, operating system, device type, pages visited, date and time, referring page, interactions, technical identifiers, UTM parameters and data associated with cookies or similar technologies may be generated.

Details of these technologies are set out in ANCESTRINA’s Cookie and Tracking Technologies Policy.

6. CHILDREN AND ADOLESCENTS

ANCESTRINA’s general forms and services are primarily intended for adults. Occasionally, an adult may mention their children or other minors as part of a family or relational situation. People are asked to avoid providing full names or other identifying information about minors when such identification is not necessary.

When it is necessary to process the data of children or adolescents, ANCESTRINA must do so respecting their best interests, fundamental rights and the specific legal requirements that apply.

7. SOURCES OF PERSONAL DATA

Data may be obtained directly from the data subject through forms, purchases, communications, processes, courses, events, email, WhatsApp, social media or interactions with the website. Data may also come from third parties or public sources when there is a lawful basis and a legitimate purpose that permit such processing.

The fact that a person provides information about a third party does not authorize ANCESTRINA to use it for purposes other than those lawfully related to the request.

8. PURPOSES OF PROCESSING

8.1 Contact and guidance

  • receive and identify requests;
  • answer questions;
  • understand the general reason for contact;
  • determine the appropriate channel or service;
  • follow up on a conversation initiated by the data subject.

8.2 Individual Therapeutic Accompaniment

  • provide preliminary guidance on whether the service corresponds to the situation presented;
  • manage the initial conversation and scheduling;
  • provide the contracted service;
  • maintain operational communications with the client;
  • manage payments and necessary administrative records;
  • manage continuity, closure or follow-up when appropriate;
  • comply with contractual and legal obligations.

8.3 Couple Therapy

  • understand the initial request;
  • understand both partners’ willingness to participate;
  • guide the type of service;
  • manage scheduling, communications and payments;
  • provide the contracted service;
  • identify situations that require a different review before couple therapy is offered.

Information provided by one member of a couple will not automatically be treated as information authorized by the other.

8.4 Safety and responsible guidance

If a person voluntarily communicates information related to risk, violence, coercion or another sensitive situation, ANCESTRINA may process it only to the extent necessary to understand the request, determine an appropriate procedure, avoid automatically offering a service that may not be suitable, and comply with applicable legal obligations.

8.5 Ecommerce, store, billing and consumer service

  • process orders and payments;
  • issue invoices;
  • manage shipping and delivery;
  • handle PQR matters, warranties, withdrawal requests, returns and refunds;
  • prevent fraud;
  • comply with accounting, tax and consumer-protection obligations.

8.6 Courses, programs and resources

  • manage registrations and access;
  • provide the purchased program or resource;
  • send operational communications;
  • deliver materials;
  • manage attendance, support and payments;
  • communicate changes directly related to the program.

8.7 Marketing communications

Only where the corresponding authorization exists, ANCESTRINA may send information about content, courses, books, programs, events, services, news or commercial offers. Marketing authorization must be distinguishable from authorization necessary to respond to a request or perform a contract.

The data subject may withdraw consent for marketing communications without this legitimately affecting a service already contracted.

8.8 Analytics and website improvement

Where applicable and subject to cookie preferences, ANCESTRINA may use technical data to measure traffic, understand navigation, improve content, evaluate campaigns, detect errors and understand, in aggregate, the sources that generate visits or requests.

8.9 Security and compliance

We may process information to prevent fraud, protect infrastructure, control access, investigate security incidents and comply with lawful requests from competent authorities.

9. WHAT ANCESTRINA WILL NOT DO WITH PERSONAL DATA

  • It will not sell personal databases to third parties.
  • It will not use private therapeutic narratives as advertising material without specific authorization.
  • It will not use sensitive information obtained through therapeutic requests to create advertising audiences based on health, sex life, violence, diagnosis, emotional condition or intimate narratives.
  • It will not send the text of open-ended therapeutic form fields to analytics or advertising tools.
  • It will not assume that requesting information, purchasing a product or completing a form authorizes any future purpose.

10. TESTIMONIALS, IMAGE, VOICE AND CONTENT

General authorization for personal-data processing does not automatically authorize publication of a person’s name, photograph, video, voice, testimonial, personal story or fragments of a therapeutic process.

When ANCESTRINA wishes to use such material publicly, it must obtain a specific authorization defining its scope, purpose, media, and the applicable identification or anonymization. Refusing to provide a testimonial will not affect any service.

11. PROVIDERS, PROCESSORS AND THIRD PARTIES

ANCESTRINA may use providers of hosting, email, forms, CRM, cloud storage, ecommerce, payments, logistics, email marketing, video conferencing, scheduling, courses, analytics, security and technical support.

These third parties must receive only the information necessary for the functions they perform and will be subject to the agreements, confidentiality duties and mechanisms applicable under the law and the nature of each relationship.

Before publishing or updating this Policy, ANCESTRINA will maintain a current internal inventory of providers that receive personal data and will verify the website’s actual configuration.

12. INTERNATIONAL TRANSFER AND TRANSMISSION

Some technology providers may operate infrastructure outside Colombia. When processing involves an international transfer or transmission of personal data, ANCESTRINA will apply the mechanisms required by Colombian law and will document, as appropriate, who receives the data, in what capacity, for what purpose and under what legal mechanism.

13. RETENTION

Personal data will be retained for the time necessary to fulfill the stated purpose, perform a contractual relationship, handle claims, comply with accounting, tax, legal or recordkeeping obligations, protect legitimate rights, or address applicable responsibilities.

When the purpose no longer exists and there is no lawful retention obligation, the data must be deleted, anonymized or otherwise processed in a legally appropriate manner.

14. SECURITY AND INTERNAL ACCESS

ANCESTRINA will adopt reasonable technical, administrative and human measures according to the nature of the data processed. These may include access controls, authentication, encrypted connections, backups, software updates, permission limits, confidentiality agreements, provider management and incident-response procedures.

Information submitted in personal or couple inquiries must not be indiscriminately available to community managers, advertising agencies, designers, SEO providers, ecommerce staff or people who are not involved in the necessary management of that information.

The internal rule is: anyone who does not need a piece of data to perform their role should not have access to it.

15. USE OF WHATSAPP

When a person voluntarily writes to ANCESTRINA via WhatsApp, the information will be processed to respond to and manage their request. WhatsApp is operated by a third party and is also subject to that third party’s own terms and policies.

ANCESTRINA recommends not using WhatsApp to spontaneously send complete clinical histories, highly sensitive documents, intimate images, unnecessary third-party information or unsolicited medical material. When structured or particularly sensitive information must be collected, ANCESTRINA may indicate a different channel.

16. SOCIAL MEDIA

Interactions with ANCESTRINA’s official accounts on Instagram, YouTube or other platforms are also subject to those platforms’ privacy policies. ANCESTRINA may receive data that a person chooses to provide when sending messages, commenting, registering or using tools made available by those platforms.

17. COOKIES AND SIMILAR TECHNOLOGIES

ANCESTRINA may use cookies and similar technologies. Information about which technologies are used, who places them, their purpose, duration, categories, consent requirements and the mechanisms for accepting, rejecting or configuring preferences is available in the Cookie and Tracking Technologies Policy.

18. AUTOMATED DECISIONS

ANCESTRINA will not make therapeutic decisions, sensitive risk assessments or admission decisions based exclusively on automated systems without human intervention. Technology tools may assist with administrative tasks such as classification, scheduling, confirmations and reminders.

19. RIGHTS OF DATA SUBJECTS

Under Colombian law, the data subject may, as applicable:

  • know, update and rectify their personal data;
  • request proof of the authorization granted, except where the law provides otherwise;
  • be informed of the use made of their data;
  • access personal data being processed free of charge;
  • submit inquiries and claims;
  • request deletion of data when appropriate;
  • withdraw authorization when legally applicable;
  • file complaints with the Superintendencia de Industria y Comercio after completing the applicable procedure before the controller or processor.

20. CHANNEL FOR EXERCISING DATA-PROTECTION RIGHTS

Requests related to personal-data protection must be sent to:

  • Email: privacidad@ancestrina.com
  • Controller: ANCESTRINA SAS
  • NIT: 901.575.993-4
  • Address: SEC CONDOMINIO RINCON DE SAN PEDRO KM 6 ZN VIA GUAYMARAL CA 48, Bogotá D.C., Colombia
  • Phone: +57 311 866 2045

The request must contain the information reasonably necessary to identify the data subject, understand the request and establish representation when applicable. ANCESTRINA will not require unnecessary information in order to make the exercise of rights more difficult.

21. INQUIRIES

Inquiries will be answered within a maximum of ten (10) business days from receipt. When it is not possible to respond within that period, the interested person will be informed of the reason for the delay and the new response date, which may not exceed five (5) additional business days.

22. CLAIMS, CORRECTION, UPDATE OR DELETION

When a person considers that their data should be corrected, updated or deleted where applicable, or that there has been a breach of the personal-data protection regime, they may submit a claim to privacidad@ancestrina.com.

Complete claims will be answered within a maximum of fifteen (15) business days counted from the day after receipt. When it is not possible to resolve the claim within that period, the reasons will be explained and a new response date will be provided, which may not exceed eight (8) additional business days.

23. WITHDRAWAL OF AUTHORIZATION AND DELETION

The data subject may request withdrawal of authorization or deletion of their data when legally applicable. Deletion may not always be immediate where there is a legal or contractual retention obligation, a pending claim, an accounting or tax duty, or another legitimate need to retain certain records for a required period.

A person may opt out of marketing communications without this requiring deletion of information that must be retained to perform a contract, preserve an invoice or comply with legal obligations.

24. COMPLAINTS BEFORE THE AUTHORITY

Colombia’s personal-data protection authority is the Superintendencia de Industria y Comercio. The data subject may file a complaint with that authority after completing the inquiry or claim process before ANCESTRINA when that prior requirement applies.

25. MARKETING COMMUNICATIONS

Promotional communications must have the corresponding authorization and provide a reasonably simple mechanism to stop receiving them.

Requesting information about a process does not mean automatically subscribing to marketing. Purchasing a product does not mean agreeing to indefinite advertising. Completing a form does not amount to authorizing purposes other than those disclosed.

26. LINKS TO THIRD PARTIES

The website may include links to video platforms, social media, payment providers, scheduling services, education platforms, stores or other sites. Once the user leaves ancestrina.com, processing performed directly by those third parties is also subject to their own policies and conditions.

27. CHANGES TO THIS POLICY

This Policy may be updated when services, forms, technologies, providers, processing purposes or applicable law change. When a material change affects a previously granted authorization, ANCESTRINA will take the corresponding information and renewed-authorization measures.

28. EFFECTIVE DATE

This Policy takes effect on September 1, 2026 and replaces any previous version of ANCESTRINA’s Privacy Policy published for the same purposes.

29. CONTACT

MAIN LEGAL REFERENCES

  • Political Constitution of Colombia, Article 15.
  • Statutory Law 1581 of 2012 — General personal-data protection regime.
  • Decree 1074 of 2015 — Regulations applicable to personal-data processing.
  • Instructions and guidelines of the Superintendencia de Industria y Comercio.