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Privacy Protection Policy

Last updated: May 2026

 

1. Data Controller

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The data controller responsible for personal data collected through this website is:

Gärtner Abogados Consultores S.A.S. Legal form: Sociedad por Acciones Simplificada (S.A.S.), incorporated under Colombian law NIT: 900786440-5

EU Representative: Felipe Gärtner Jaramillo Email: contact@gartneradvisors.de

 

2. Applicable Legal Framework

 

The processing of personal data by Gärtner is governed by:

  • Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR), for data subjects located in the European Economic Area.

  • Colombian Law 1581 of 2012 and its implementing regulations, in particular Decree 1377 of 2013, for data subjects located in Colombia.

  • Any other applicable data protection legislation in relevant jurisdictions.

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3. Personal Data We Collect

 

Gärtner collects the following categories of personal data, depending on how the data subject interacts with the website or the firm's services:

 

3.1. Browsing Data When accessing the website, technical browsing data is automatically collected, including IP address (anonymised), browser type, operating system, pages visited, duration of visit, and referral data. This data is processed through the Wix platform and Google Analytics 4 (GA4).

 

3.2. User Account Data To access certain digital tools or services offered by Gärtner, users must create an account. In that process, the following data is collected: name, corporate email address, IP address, and usage data (frequency and volume of use, for access control purposes). No personal data beyond what is strictly necessary for the provision of the service is requested.

 

3.3. Contact Data When a data subject contacts Gärtner through the contact form or by email, the following data is collected: name, email address, company name, and the content of the message.

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Gärtner does not collect special categories of personal data (sensitive data) through its website.

 

4. Purposes and Legal Bases for Processing

 

PurposeData processedLegal basis (GDPR)

 

Technical operation of the websiteBrowsing data, session cookiesLegitimate interest (Art. 6(1)(f))

 

Statistical analysis of website usage (GA4)Anonymised browsing dataConsent (Art. 6(1)(a))

 

User account managementName, email, IP, usage dataPerformance of contract (Art. 6(1)(b))

 

Handling enquiries and communicationsName, email, company, messageLegitimate interest (Art. 6(1)(f))

 

Compliance with legal obligationsAs legally requiredLegal obligation (Art. 6(1)(c))

 

For data subjects located in Colombia, the legal basis is the prior, express, and informed authorisation of the data subject pursuant to Article 9 of Law 1581 of 2012, or the exceptions set out in Article 10 thereof.

 

5. Cookies and Tracking Technologies

 

This website uses cookies and similar technologies. The categories used are described below:

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  • Strictly Necessary Cookies Installed by the Wix platform to ensure the technical operation of the website (session management, language preferences, security). These do not require prior consent.

  • Analytical Cookies Google Analytics 4 (GA4) uses cookies to collect statistical information about website usage. Gärtner has configured GA4 with IP anonymisation enabled. These cookies are only installed after obtaining the user's consent through the cookie banner that appears on the first visit.

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​The user may withdraw consent at any time through the cookie settings available on the website, or by configuring their browser to reject or delete cookies. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

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For more information on Google Analytics cookies, visit: https://policies.google.com/privacy For more information on Wix cookies, visit: https://support.wix.com/en/article/wix-cookies

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6. International Data Transfers

 

Gärtner Abogados Consultores S.A.S. is domiciled in Colombia. Personal data of data subjects located in the European Economic Area is transferred to Colombia, which does not benefit from an adequacy decision by the European Commission under Article 45 of the GDPR.

 

This transfer is carried out with appropriate safeguards as provided for in Article 46 of the GDPR, in particular through the execution of the Standard Contractual Clauses approved by the European Commission between the controller and processors located in third countries, or through other legally recognised transfer mechanisms.

 

Data subjects may obtain information about the applicable safeguards by contacting Gärtner at contact@gartneradvisors.de.

 

7. Third-Party Providers (Sub-processors)

 

Gärtner uses the following third-party providers who may access personal data as data processors:

 

Wix.com Ltd. Provider of the website hosting platform. Data processed: browsing data, technical cookies, contact form data. Privacy policy: https://www.wix.com/about/privacy

 

Google LLC (Google Analytics 4) Provider of web traffic analytics services. Data processed: anonymised browsing data. Privacy policy: https://policies.google.com/privacy

 

Gärtner requires all its providers to comply with applicable data protection obligations and to execute the corresponding data processing agreements, but it is not liable for their management.

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8. Data Retention

 

Personal data will be retained for the time strictly necessary to fulfil the purpose for which it was collected, and in any event:

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  • Browsing data and analytical cookies: up to 14 months from collection, in accordance with GA4's standard configuration.

  • User account data: for the duration of the account and, following its deletion, for a maximum additional period of 3 years for compliance with legal obligations and resolution of potential claims.

  • Communication data (form/email): up to 3 years from the last communication, unless a contractual relationship is in force, in which case the retention periods applicable to that relationship shall apply.

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Once these periods have elapsed, data will be deleted or irreversibly anonymised.

 

9. Rights of Data Subjects

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Data subjects in the European Union (GDPR)

 

Data subjects located in the EEA have the right to:

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  • Access: obtain confirmation as to whether their data is being processed and access to it.

  • Rectification: request the correction of inaccurate or incomplete data.

  • Erasure: request the deletion of their data when it is no longer necessary for the purposes for which it was collected, among other grounds.

  • Restriction of processing: request the suspension of processing in certain circumstances.

  • Data portability: receive their data in a structured, machine-readable format.

  • Objection: object to processing based on legitimate interest.

  • Withdrawal of consent: where processing is based on consent, withdraw it at any time without affecting the lawfulness of prior processing.

  • Lodge a complaint with a supervisory authority: data subjects in Germany may contact the Bayerisches Landesamt für Datenschutzaufsicht (BayLDA): www.lda.bayern.de.

 

Data subjects in Colombia (Law 1581 of 2012)

 

Data subjects located in Colombia have the right to know, update, rectify, and delete their personal data, as well as to revoke their authorisation and file complaints with the Superintendencia de Industria y Comercio (SIC), Delegatura para la Protección de Datos Personales: www.sic.gov.co.

 

To exercise any of these rights, data subjects must send a written request to contact@gartneradvisors.de, stating their full name, the data to which the request refers, and the action they wish to take. Gärtner will respond within a maximum of 20 business days for consultation requests and 30 business days for claims, in accordance with Colombian law, or within the timeframes prescribed by the GDPR where applicable.

 

10. Minors

 

Gärtner's services are directed exclusively at businesses and professionals. Gärtner does not knowingly collect personal data from persons under the age of 16. If it is detected that data from a minor has been collected without verifiable consent from their legal representative, such data will be deleted immediately.

 

11. Modifications to This Policy

 

Gärtner reserves the right to modify this Data Protection Policy at any time to reflect regulatory changes or modifications to the services offered. The updated version will be published on the website with the date of the last update indicated. Data subjects are advised to review this policy periodically.

 

12. Contact

 

For any questions regarding this Data Protection Policy or the exercise of your rights, please contact Gärtner at:

 

contact@gartneradvisors.de 

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