Privacy Policy (Personal Data Processing Policy)

Effective as of November 9, 2026 (version 3)

1. Who is responsible for your data

Sparta Sociedad de Comercialización Internacional SAS ("Fajas Sparta") is the controller of the personal data we receive through this website, fajassparta.com, through our meeting scheduler and in our relationship with our customers.

NIT (Colombian tax ID): 900199605-5
Domicile and address: Calle 37 # 8A-63, Cali, Colombia
Email for personal data matters: soporte@fajassparta.com.co
Phone: +57 602 408 4656

2. Who this Policy applies to

This Policy explains how we process the personal data of:

People who visit the site.
People who book a meeting with an advisor.
The contact persons of our customers and of companies interested in buying from us.

Company data, such as a company's legal name, is not personal data. The data of the people who write to us on its behalf is. If the customer is an individual and not a company, their billing data is also personal data.

This Policy implements the right of habeas data under the Political Constitution of Colombia (art. 15): the right of every person to know, update and rectify the information that has been collected about them. It is governed by Colombian law, in particular Law 1581 of 2012 and its regulation, Decree 1377 of 2013, now compiled in Decree 1074 of 2015, and by the instructions of the Superintendence of Industry and Commerce (SIC), Colombia's data protection authority. It applies equally to everyone, regardless of the country from which they contact us. If the law of your country gives you other rights over your data, this Policy does not limit them: you may submit your request through the channels in section 12.

3. What data we collect

When you book a meeting. Our scheduler runs on Cal (cal.com), a third-party service. In the booking form we collect:

Name, email and phone or WhatsApp number.
Country.
What you are interested in, for example distributing our brand or creating your own private-label brand.
How your business sells and roughly how much it sells per month.
If you add them, the email addresses of the people you invite to the meeting.
If you reschedule the meeting, the reason you choose to give us.

With your booking, Cal also stores the code with which Google Analytics recognizes your browser and your visit, so we know which page or ad brought you to us (section 7).

In the meeting and in the business relationship. The meeting is a video call through Cal Video, Cal's video call service. During and after it we process:

The contact details of the people from your company who speak with us: name, job title, email and phone.
What you tell us about your business so we can prepare a proposal.
Quotes, orders, invoicing and shipping.
If you accept it, the recording of the video call, with your image and your voice, and the text transcript that Cal makes of it.

When you browse the site. To show you the pages, our hosting provider receives technical data, such as your IP address and your browser. With cookies and similar measurement and advertising tools (section 7), we also collect data such as your type of device, the pages you visit, how you move through them (where you click and how far you scroll), the ad or site you came from and whether you booked a meeting.

What we do not ask for.

We do not ask for sensitive data, such as health data. The only exception is the optional recording of the video call, because image and voice may be considered sensitive data (section 5). Through the site and the scheduler, we do not ask for card or bank account numbers either. Although we manufacture post-surgical compression garments, we do not ask for medical records or patient data. Please do not send them to us.
The site is not directed to minors (persons under 18). If we notice that we have received data from a minor, we will delete it.

4. What we use your data for

We use your data for the following purposes, with your authorization or, where the law allows it, without it:

To schedule, confirm, reschedule and hold the meeting, and to send you reminders.
To handle your request: understand your business, prepare quotes and answer your questions.
To follow up with you on that request by email, phone or WhatsApp.
If you are a customer: to manage orders, invoicing and shipping, and to maintain the business relationship.
To measure and improve the site and our advertising (section 7).
To prevent fraud and impersonation.
To comply with legal, accounting, tax and customs obligations, and to respond to the authorities.
To exercise or defend our rights in the event of a claim.

Only if you accept it expressly:

To send you commercial information, such as news, catalogs and promotions, by email, WhatsApp or phone.
To record and transcribe the video call to remember what was discussed, prepare your quote and train our advisors.

You can book without accepting either of them.

We do not sell or rent your data. If we want to use it for a new purpose, we will ask you for a new authorization.

5. Your authorization

Before you book, the Cal form asks for your authorization with a box that you must check yourself. We never check it for you. That box is a valid authorization given by electronic means (Law 527 of 1999 and Decree 1074 of 2015).
Your image and your voice in a recording may be sensitive data. That is why we only record the video call if you authorize it explicitly and orally, at the start of the video call (Law 1581 of 2012, art. 6). You are not required to accept it, and if you do not accept it the meeting takes place anyway. You may withdraw this authorization at any time (sections 11 and 12).
If the video call is recorded and other people besides the person who booked take part in it, the person who booked must inform them that it is recorded and transcribed, and that Cal may send the link to the recording to the person who booked and to their guests. The person who booked must also have the authorization of those other participants.
You may also authorize us in writing, orally or through conduct that leaves no doubt. Silence never counts as authorization.
We keep proof of your authorization.
If you give us data about other people, for example about the person who receives a shipment, you must have their authorization and inform them of this Policy.
The law allows data to be processed without authorization in some cases, such as data of a public nature or information requested by an authority in the exercise of its functions (Law 1581 of 2012, art. 10).

6. What we expect from you

That the data you give us is true, complete and current, and that you let us know if it changes. If you give us false data or data about another person without their authorization, you are responsible for it.
That you only give us data about other people, such as members of your team or the person who receives a shipment, if you have their authorization and inform them of this Policy.
That you do not send us sensitive data, such as health or patient data, or payment data through the site, the scheduler, email or WhatsApp.
That you use the channels in section 12 for your requests about data. Be wary of messages that, in the name of Fajas Sparta, ask you for personal data or payments from numbers, email addresses or accounts that you do not know.

7. Cookies, measurement and advertising

Cookies are small files that the site stores in your browser. We use cookies and similar tools, our own and third parties':

Google Tag Manager (Google): manages several of the site's measurement tools.
Google Analytics 4 (Google): measures visits and how the site is used. We use its advertising features: Google Signals, demographics and interests reports, and remarketing with Google Ads. With them, Google combines Analytics cookies with its advertising cookies and, if you are signed in to your Google account and have ad personalization turned on, with data from that account.
Google Ads (Google): measures which ads generate meetings and shows you ads if you have already visited the site.
Meta Pixel and Conversions API (Meta): measures which ads on Facebook, Instagram and other Meta platforms generate meetings and shows you ads if you have already visited the site.
Tagging server (Stape): receives the site's measurement data and Cal's booking notifications, and sends to Google and Meta only what this section describes.
Microsoft Clarity (Microsoft): shows us how the site is used, with heatmaps and recordings of browsing sessions: where you click, how far you scroll and how you move through the pages. It masks what you type and does not see the Cal scheduler, which loads separately. We use it to improve the site and our advertising. Microsoft also receives this data and uses it for its own purposes, including its advertising service (Microsoft Advertising), according to its Privacy Statement (microsoft.com/en-us/privacy/privacystatement).
YouTube in privacy-enhanced mode (Google): shows our videos. It only loads if you press play.

As a result, third-party vendors such as Google and Meta use cookies to show you our ads on other sites and apps, based on your previous visits to this site. How Google uses information from sites that use its services: policies.google.com/technologies/partner-sites. Google's information on business data privacy: business.safety.google/privacy.

When you book a meeting, the site notifies Google and Meta that a booking took place, so we know which ads work. Cal also notifies our tagging server of the booking. That notification includes the booking data, but the server only sends Google Analytics your answers about what you are interested in, how your business sells and how much it sells, together with your browser's code, so we know which pages and ads bring us each type of customer. It never sends your name, email or phone number to Google or Meta.

Your choice. Measurement and advertising cookies are activated when you enter the site, but they are not necessary for it to work. If you do not want us to measure your visit or to show you ads because of it, you can limit this as follows:

Block or delete cookies in your browser settings.
Install the Google Analytics opt-out browser add-on (tools.google.com/dlpage/gaoptout).
Turn off personalized ads in Google's ad settings (www.google.com/settings/ads) or in your Meta account, or opt out of interest-based advertising from NAI member companies (optout.networkadvertising.org).
Opt out of Microsoft Clarity at optout.aboutads.info, selecting Microsoft. According to Microsoft, Clarity also honors the Global Privacy Control (GPC) signal if your browser sends it.

If you block cookies, you can still use the site and book your meeting. Blocking them does not stop all measurement: some tools keep measuring without cookies. For example, Clarity may measure each page separately, and Google may use your IP address to measure visits and personalize ads.

If you visit us from the European Union, the European Economic Area, the United Kingdom or Switzerland. We do not currently direct our advertising to those countries. The site uses the same measurement and advertising tools with all visitors, including those from those countries, and does not show a notice asking for separate permission. You can limit them with the options in this section, including the Clarity opt-out. Some providers may limit on their own what they measure from those visitors: for example, according to Microsoft, Clarity does not use cookies with them and measures each page separately.

Each cookie lasts for the period set by its provider. The Cal scheduler and the video call platform may use their own cookies, according to their policies.

8. Who we share your data with

We only share what is necessary for the purposes of this Policy:

Our team: the sales advisors and authorized staff who need it for their work.
Providers that process data on our behalf (processors): Cal (scheduling and video calls), Webflow (website hosting), the tagging server (measurement) and our email service. They may only use your data to provide their service to us, with security and confidentiality.
Google, Meta and Microsoft, including Google Analytics, YouTube, WhatsApp and Microsoft Clarity: to measure the site and to measure and show our advertising (section 7), to show our videos if you press play and to communicate with you through WhatsApp. They also process that data on their own behalf, as independent controllers, according to their own policies. Fajas Sparta is not responsible for the processing that those companies carry out on their own behalf, to the extent permitted by law.
Carriers and customs brokers, to ship orders.
External advisors, such as accountants and lawyers, who are bound by confidentiality.
Authorities, when the law or an order requires it.

9. Data outside Colombia

Several of our providers store or process your data outside Colombia, for example in the United States. Cal, Webflow, Google, Meta, Microsoft and Stape (our tagging server) are United States companies, and some of their subcontractors operate in other countries. To ship orders, we also share data with carriers and customs brokers, in Colombia and in the country of destination.

The Superintendence of Industry and Commerce includes the United States and the countries of the European Union on its list of countries with an adequate level of data protection.

When a provider processes your data on our behalf (transmission), it may only use it to provide its service to us, with security and confidentiality, according to its data processing terms.
When we send data to another company that processes it on its own behalf (transfer) and that company is in a country without an adequate level of protection, we only do so in the cases permitted by article 26 of Law 1581 of 2012. For example, with your express authorization or when it is necessary for a contract with you.

By checking the authorization box in the Cal form, you expressly authorize your data to be sent and stored outside Colombia, for the purposes of this Policy.

10. How long we keep your data

If you book and do not become a customer: up to 5 years after our last contact. Then we delete it.
If you are a customer: for as long as the business relationship lasts and, afterwards, for the time required by commercial, accounting and tax rules. For example, Colombian law requires merchants to keep their books and papers for ten years (Law 962 of 2005, art. 28).
Video call recordings and their transcripts: 5 years from the meeting. Then we delete them, unless we need them to handle a claim from you.
Browsing data: the time set in the configuration of each tool.
Commercial information: until you ask us to stop sending it, without exceeding the periods above.
If there is a claim or a proceeding in progress, we keep the data needed to handle it until it ends, even if the period above has passed.

11. Your rights

As the owner of your data (data subject), you may:

Know, update and rectify your data.
Request proof of the authorization you gave us, except in the cases in which the law does not require it (Law 1581 of 2012, art. 10).
Be informed, upon request, of how we have used your data.
Consult your data free of charge, at least once every calendar month and every time we make a substantial change to this Policy. If you consult it more often, we may only charge you for shipping, reproduction and, where applicable, certification of documents.
Revoke your authorization and ask us to delete your data, unless we must keep it because of a legal or contractual duty (Decree 1074 of 2015, art. 2.2.2.25.2.6).
Ask us at any time to stop sending you commercial information.
If we contact you by email, phone or WhatsApp, use that same channel to ask us to correct, update or delete your data, to make an inquiry or a claim, or to ask us to stop contacting you.
File complaints with the Superintendence of Industry and Commerce (sic.gov.co). You must first submit your inquiry or claim to us (Law 1581 of 2012, art. 16).

These rights may be exercised by you, your representative or attorney-in-fact, your heirs if you have died, or the other persons authorized by law. Anyone who exercises these rights must prove their identity or the capacity in which they act.

12. How to exercise your rights

The area responsible for handling your inquiries and claims is Customer Service.

Email: soporte@fajassparta.com.co
Letter: Calle 37 # 8A-63, Cali, Colombia
Phone, for guidance: +57 602 408 4656

Submit your inquiry or claim in writing, by email or by letter, so that there is a record. If we contacted you by phone or WhatsApp, you can also do it through that channel. In your request, please include:

Your name and the email or phone number with which you contacted us.
What you are requesting and, if it is a claim, the facts on which it is based.
The address or email where you want to receive the answer.
Any documents you wish to rely on.

Deadlines are counted in Colombian business days (Law 1581 of 2012, arts. 14 and 15).

Inquiries (to know your data or how we use it). We respond within a maximum of 10 business days from receipt. If this is not possible, we will explain why and give you a new date, which will not exceed 5 additional business days.

Claims (to correct, update or delete data, revoke the authorization or report non-compliance):

If the claim is incomplete, we will tell you within 5 business days of receiving it, so that you can complete it. If 2 months pass from that notice without you completing it, we will consider that you have withdrawn it.
If we are not competent to resolve it, we will forward it to the competent party within a maximum of 2 business days and let you know.
Within a maximum of 2 business days from receiving the complete claim, we will mark your data with the legend "claim in process" (reclamo en trámite) and its reason, until we resolve it.
We respond within a maximum of 15 business days, counted from the day after receipt. If this is not possible, we will explain why and give you a new date, which will not exceed 8 additional business days.

13. Security

We take reasonable technical, human and administrative measures to protect your data against loss, alteration and unauthorized use or access.

No system is completely secure. If a security incident occurs that puts your data at risk, we will report it to the Superintendence of Industry and Commerce within the time limits set by law.

Video call recordings and their transcripts are for internal use: we do not publish them or share them beyond what this Policy states. When a recorded meeting ends, Cal may send you, and the people you invited to the booking, an email with a link to download the recording.

14. Changes to this Policy

We may update this Policy. The version in force is the one published on this page, with its date.

If we change who is the controller of your data or the purpose for which we use it, we will let you know before applying the change. If the change concerns the purpose, we will ask you for a new authorization.

15. Effective date and language

This Policy is effective from the date indicated at the beginning of this page. Our databases will remain in force for as long as Fajas Sparta carries on its business. Each piece of data is kept for the periods in section 10.

This Policy was written in Spanish. If this English translation does not match the Spanish version, the Spanish version prevails.