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1. Introduction
MODA X2 S.A.S., acting as the data controller, adopts this Privacy Policy to clearly and transparently explain how it collects, uses, stores, accesses, shares, transmits, transfers, and deletes personal data from customers, users, suppliers, employees, job applicants, business partners, and visitors of the website www.x2underwearglobal.com This policy is issued in compliance with Colombian Law 1581 of 2012, Decree 1074 of 2015, and other applicable Colombian personal data protection regulations. Where applicable due to the user’s location or the nature of the service, MODA X2 S.A.S. will also seek to observe international privacy and data protection standards.
The purpose of this policy is to protect the personal information of data subjects and ensure the exercise of their rights, including the right to know, update, correct, delete, and request proof of the authorization granted for the processing of their personal data.

2. Scope
This Privacy Policy applies to all personal data processed by MODA X2 S.A.S., whether through physical, digital, electronic, telephone, in-person, or technological channels, including the website, social media, customer service channels, forms, payment gateways, commercial campaigns, and contractual relationships.
It also applies to third-party processors acting on behalf of MODA X2 S.A.S., such as technology providers, logistics operators, payment platforms, marketing agencies, analytics services, business partners, and other third parties required to fulfill the purposes described herein.
By browsing our website, registering, making a purchase, completing forms, or providing personal data through any authorized channel, the data subject confirms that they have read this Privacy Policy and authorizes the processing of their personal data in accordance with its terms.

3. Purposes of Data Processing
MODA X2 S.A.S. collects and processes personal data for the following purposes:
To manage user registrations, accounts, orders, payments, billing, shipping, deliveries, exchanges, warranties, and returns.
To comply with legal, contractual, accounting, tax, administrative, and commercial obligations.
To verify identity, prevent fraud, manage risks, and protect transaction security.
To respond to requests, inquiries, petitions, complaints, claims, and customer service matters.
To send communications related to purchases, orders, deliveries, product availability, or changes to service terms.
To send commercial, promotional, advertising, newsletter, brand update, product launch, discount, and loyalty campaign communications, where authorization or an applicable legal basis exists.
To conduct market research, consumer analysis, audience segmentation, satisfaction measurement, and user experience improvements.
To personalize content, recommendations, advertising, and browsing experience on the website.
To manage relationships with suppliers, business partners, contractors, and third parties.
To carry out recruitment, hiring, employment management, social security, wellness, and labor compliance processes.
To protect the security of facilities, assets, systems, employees, and visitors.
To share, transmit, or transfer information to providers, partners, technology platforms, logistics operators, payment gateways, storage services, analytics tools, or competent authorities, within or outside Colombia, when necessary to fulfill the purposes described herein and in accordance with applicable law.

4. Sensitive Data
Sensitive data refers to information that may affect the privacy of the data subject or whose misuse may lead to discrimination, such as health-related data, biometric information, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sexual life, or other specially protected data under applicable law.
MODA X2 S.A.S. will not request sensitive data unless it is strictly necessary for a legitimate, proportionate, and previously disclosed purpose. In such cases, the data subject will be informed that they are not required to provide sensitive data, and express authorization will be requested when required by law.

5. Children’s Personal Data
MODA X2 S.A.S. does not knowingly collect personal information from minors through its website, digital channels, or commercial activities.
If personal information from a minor is collected, MODA X2 S.A.S. will request prior, express, and verifiable authorization from the minor’s legal representative and will process such information only when necessary, proportionate, and respectful of the best interests of the child, their fundamental rights, and applicable regulations.
If a parent, guardian, or legal representative believes that a minor has provided personal data without authorization, they may request the deletion of such information through the contact channels established in this Privacy Policy.

6. Rights of Data Subjects
Data subjects have the right to:
Know, update, correct, and delete their personal data.
Request proof of the authorization granted for the processing of their data.
Be informed, upon request, about how their personal data has been used.
Revoke authorization and/or request the deletion of their data when there is no legal, contractual, or legitimate obligation preventing such deletion.
Access, free of charge, the personal data processed by MODA X2 S.A.S.
File complaints before the Colombian Superintendence of Industry and Commerce, SIC, if they believe that applicable personal data protection regulations have been violated.
Where a user is located in a jurisdiction with specific data protection laws, they may exercise any additional rights recognized by applicable legislation, to the extent such laws apply to MODA X2 S.A.S. based on the nature of the relationship, territory, or services offered.

7. Duties of the Data Controller
MODA X2 S.A.S., as the data controller, undertakes to:
Process personal data only for authorized, disclosed, or legally permitted purposes.
Ensure that the information is accurate, complete, up to date, verifiable, and understandable.
Implement reasonable technical, human, administrative, and organizational measures to protect the confidentiality, integrity, and availability of personal data.
Keep proof of the authorizations granted by data subjects, where required.
Handle inquiries, requests, and claims within the timeframes established by applicable law.
Notify the competent authority and, where appropriate, the affected data subjects of security incidents that may compromise their personal data.
Require data processors to comply with confidentiality, security, and proper data use obligations.

8. Use of Cookies and Similar Technologies
The website www.x2underwearglobal.com uses cookies, pixels, tags, analytics tools, and similar technologies to enable website functionality, improve browsing experience, analyze usage patterns, measure campaign performance, personalize content, and provide advertising related to the user’s interests.
Cookies may be first-party or third-party cookies and may serve technical, functional, analytics, advertising, or personalization purposes.
When accessing the website, users may accept, reject, or configure the use of cookies where such option is available. Users may also delete or disable cookies through their browser settings. However, disabling certain cookies may affect the proper functioning of some sections of the website.
MODA X2 S.A.S. recommends that users periodically review their cookie settings and the privacy policies of third parties that may participate in analytics, advertising, payment processing, social media, or integrated website functionality.

9. International Data Transfer and Transmission
MODA X2 S.A.S. may transmit or transfer personal data to third parties, providers, technology platforms, servers, analytics tools, payment gateways, logistics operators, cloud storage services, or business partners located in Colombia or in other countries, when necessary to fulfill the purposes described in this Privacy Policy.
When personal data is transmitted or transferred outside Colombian territory, MODA X2 S.A.S. will seek to ensure that such third parties adopt appropriate security, confidentiality, and data protection measures, in accordance with applicable Colombian regulations and, where applicable, international data protection standards.
Where required by law, MODA X2 S.A.S. will request the data subject’s authorization or implement the legal mechanisms required to carry out such international transfers or transmissions.

10. Inquiries, Claims, and Requests
Data subjects may exercise their rights of access, update, correction, deletion, authorization withdrawal, and any other rights recognized by law by contacting MODA X2 S.A.S. through the following channels:
Email: x2ropainterior@gmail.com
Phone: 316 629 7386 | 322 654 6772
Address: Carrera 48 A # 50 Sur - 118, Sabaneta, Antioquia, Colombia
Requests must include, at minimum, the identification of the data subject, a clear description of the request, contact details to receive a response, and any documents proving the capacity in which the person is acting when the request is submitted by a representative, attorney-in-fact, or authorized third party.
Response times will be as follows:
Inquiries: up to ten (10) business days from the date of receipt.
Claims: up to fifteen (15) business days from the date of receipt.
If it is not possible to respond to an inquiry or claim within these timeframes, MODA X2 S.A.S. will inform the data subject of the reasons for the delay and the date on which a response will be provided, in accordance with the terms allowed under Law 1581 of 2012 and other applicable regulations.

11. Information Security
MODA X2 S.A.S. implements reasonable technical, administrative, human, and organizational measures to protect personal data against loss, unauthorized access, misuse, alteration, disclosure, destruction, or fraudulent processing.
Access to personal data will be limited to the individuals, departments, providers, or third parties that need to know such information in order to fulfill the authorized purposes or the applicable legal, contractual, or commercial obligations.
Although MODA X2 S.A.S. adopts appropriate security measures, no internet-based information transmission, storage, or processing system can guarantee absolute security. Therefore, the company works continuously to strengthen its controls and reduce the risks associated with personal data processing.

12. Term and Updates
This Privacy Policy becomes effective as of October 10, 2025, and will remain in force for as long as MODA X2 S.A.S. processes personal data necessary to fulfill its commercial, contractual, legal, accounting, tax, employment, or administrative purposes.
MODA X2 S.A.S. may update, modify, or adjust this Privacy Policy at any time. Material changes will be published on the website www.x2underwearglobal.com with reasonable prior notice before they become effective or will be communicated through the channels the company considers appropriate, when required by law.
Users are encouraged to periodically review this Privacy Policy to stay informed of any changes regarding the processing of their personal data.

13. Acceptance
By accessing, browsing, registering, completing forms, contacting MODA X2 S.A.S., or making a purchase through www.x2underwearglobal.com, the user declares that they have read, understood, and accepted this Privacy Policy, and authorizes the processing of their personal data in accordance with the purposes and conditions set forth herein.
Where processing requires specific authorization, MODA X2 S.A.S. may request it through physical or electronic forms, acceptance checkboxes, digital records, written communications, or any other valid mechanism under applicable law.