Privacy and personal data processing policy

1. Purpose and scope

This policy explains how Evlogia S.A.S., the entity responsible for operating Renne Peruvian Bistro, collects, uses, retains, shares and deletes personal data received through Renne's website and associated contact channels. It applies to general enquiries, commercial requests, Renne Pass and communications by email, phone or WhatsApp, including the ROS Renne records described in section 18. Section 17 describes pass-related processing; commercial terms are available separately. Employment, CCTV, suppliers and other specialised processing activities may be covered by additional notices or policies.

2. Data controller

Data controller

Evlogia S.A.S.

Tax ID

901.595.355-0

Public-facing name

Renne Peruvian Bistro

Registered location

Bogotá, D. C., Colombia

Address

Carrera 8A #99-41, Local 119, World Trade Center, Bogotá

Phone and WhatsApp

+57 324 229 9244

Privacy and written requests

admin@ppisas.com

Responsible area

Renne Administrative and Financial Area

3. Legal framework and principles

Processing is governed by the Colombian Constitution, Law 1581 of 2012, the applicable chapter of Decree 1074 of 2015, and any rules that amend or replace them. Renne applies the principles of legality, purpose limitation, freedom, accuracy and quality, transparency, restricted access and circulation, security, and confidentiality. Only data relevant and appropriate to each purpose is requested.

4. Data we may process

Depending on the channel, request and preferences selected, we may process:

• full name, email address, phone or WhatsApp number;
• company or organisation and city or service location, where relevant;
• subject, message, preferred channel and information voluntarily included;
• information required for private events, catering or corporate agreements through the specialised form;
• evidence of authorisation, including its version, date and time;
• when a person allows measurement: a pseudonymous browser identifier, pages visited, language, traffic source or referrer, permitted UTM parameters, interactions with the menu, bookings and editorial content, session statistics, approximate location, and browser and device information;
• the measurement preference and its date, stored locally in the browser;
• minimum technical information for security, availability and abuse prevention;
• the service history related to the enquiry or request;
• in ROS Renne, the sender’s number, message identifiers and dates, type and text received through WhatsApp, as described in section 18;
• the Renne Pass registration, administration and usage data described in section 17, when a person participates in a pass.

The general form does not request identity documents, financial data, passwords, files, health information or other sensitive data. Renne will not send names, email addresses, phone numbers, messages or data submitted through forms to Google Analytics.

5. Purposes

1. Receive, identify, classify and answer enquiries, comments or requests.
2. Contact the person through the channel supplied or selected.
3. Route requests to bookings, events, catering, corporate agreements, press or another relevant area.
4. Prepare and manage proposals or commercial relationships requested by the person.
5. Maintain a service record and avoid duplicate contacts, including recording requests through ROS Renne for handling by authorised staff within the scope of section 18.
6. When consent has been granted, understand how the website is used, distinguish traffic sources and visits to news pages, measure selections of the menu, bookings and editorial content, and improve navigation and content.
7. Handle access, correction, withdrawal, deletion, enquiry and complaint requests.
8. Prevent abuse, fraud, unauthorised access and security incidents.
9. Meet legal, contractual, accounting or tax duties and valid authority requests.
10. Prepare internal service metrics, preferably aggregated or anonymised.
11. Send marketing information only under a separate, optional and valid authorisation.
12. Issue, deliver, validate, update and administer Renne Pass, handle incidents and apply its terms, as described in section 17.

Submitting an enquiry does not make a booking, guarantee availability, accept a proposal, or create an agreement or contract.

6. Authorisation

Where required by law, Renne will obtain prior, express and informed authorisation no later than the time data is collected. The checkbox used to manage an enquiry will be unticked by default. Marketing authorisation must be separate and optional; refusing it will not prevent an enquiry. Renne will retain verifiable evidence of the authorisation and the accepted policy version. Publishing this policy, visiting the site or installing a pass does not replace any required authorisation. Previous enquiry consent does not automatically extend to Renne Pass; new purposes will be disclosed and authorised where required.

Website-form authorisation does not automatically extend to a person contacting Renne directly through WhatsApp. The channel notice and any required authorisation must cover the receipt and recording described in section 18. Contacting Renne through WhatsApp does not authorise marketing or future uses beyond those disclosed.

Measurement with Google Analytics is optional and governed by a separate choice. The tag will remain blocked until the person selects Allow measurement or clicks the notice’s X, whose effect of accepting and closing is explained in the notice itself. If the person selects Necessary only or makes no choice, no data will be sent to Google Analytics. The choice can be changed at any time through Privacy preferences.

7. Sensitive data and children

We do not request sensitive data in the general form. People must not include health, biometric or financial information, passwords, identity documents, or data that may affect their privacy or lead to discrimination. If unnecessary sensitive information is provided, Renne may refrain from processing it, ask for the enquiry to be resubmitted, or delete it where appropriate.

The forms are intended for people legally able to authorise processing. Renne does not seek to collect children's or adolescents' data. If such processing is lawful and necessary, special protection, best-interest, authorisation and rights requirements will apply.

8. Processors, international processing and third parties

Renne may appoint technology providers as processors for hosting, databases, communications, security, backups or support. They may process data only under authorised instructions and purposes, subject to security and confidentiality duties. Any international data transmission will be governed by the applicable contracts and safeguards.

If a person allows measurement, Google LLC will provide Google Analytics and may process information outside Colombia under its Analytics data-protection terms and Google Privacy Policy. Renne keeps optional data-sharing settings, Google Signals, user-provided data collection and ads personalisation disabled.

ROS Renne processing involves Meta/WhatsApp as the message-receiving platform and Hostinger as the server-hosting provider, within the scope described in section 18. Applicable obligations depend on each provider’s actual role and processing location; this policy does not replace their verification.

Renne does not sell personal data. It may disclose data to authorities under a legal duty or valid order, and to advisers or providers when necessary for an authorised purpose and subject to confidentiality.

9. External channels and websites

The website may link to WhatsApp, Instagram, Apparta, Google Maps or other services. A third party may process information under its own terms and policies when a person visits that service. Renne does not control external practices. WhatsApp is optional and another available channel may be used. This distinction does not exclude Renne’s responsibility for messages and records it receives and retains under its control, including ROS Renne records; section 18 explains that processing.

On pages that show Renne's location, the embedded map loads automatically as the visitor approaches that section. The browser connects to Google Maps, and that service's terms and privacy policies apply.

The forms use Cloudflare Turnstile to prevent automated and abusive submissions. When the verification loads or is completed, the browser connects to Cloudflare and that provider's terms apply. Renne receives only the result required to validate the submission.

10. Cookies, analytics and technical logs

Infrastructure may process minimum technical logs to deliver and secure the website, diagnose errors, limit request frequency and prevent abuse. Embedded Google Maps and Cloudflare Turnstile may use their providers' own technologies under their respective policies.

Google Analytics will be activated only after an affirmative choice. When measurement is allowed, Analytics may set the first-party _ga cookie with a pseudonymous identifier and receive navigation, session, referrer, approximate location, browser and device data, together with the limited events and parameters described in this policy. Google states that it may process the IP address temporarily to provide and protect the service and derive approximate location, but discards the IP address without associating it with user identifiers.

Renne uses basic consent mode: before acceptance, the tag does not load and no data, consent signals or cookieless pings are sent to Google. Enhanced measurement is disabled. Email addresses and URL parameters associated with form fields are redacted; controlled UTM parameters may be retained for attribution and must never contain personal data.

The preference is stored locally in the browser to remember the choice. It can be reset through Privacy preferences or by clearing the website's data in the browser. If Renne introduces advertising, profiling, new tools or additional non-essential cookies, it will update this policy and request the relevant choice before activation.

11. Security

Renne applies reasonable administrative, human and technical measures against loss, alteration, unauthorised access, use or disclosure. Access is limited by role. No system is completely secure; if an incident creates a risk for data subjects, the response procedure and legally required notifications to the authority or affected people will apply.

12. Retention and deletion

• General enquiries with no commercial relationship, including ROS and WhatsApp records under Renne’s control: up to 24 months after the last interaction, then securely deleted or anonymised unless a legal duty or active request applies.
• Contacts with marketing authorisation: while authorisation remains valid and the authorised purpose continues, with necessity and inactivity reviewed every 24 months. Joining, using or reaching the expiry of a pass does not determine mailing-list membership. A person may opt out of one or more lists, channels or purposes; the corresponding marketing use will stop without automatically revoking other independent authorisations that remain valid.
• Google Analytics data: user-level and event-level data governed by the retention control is configured for 14 months, with the window reset on new activity. Analytics standard aggregated reports are not subject to that control and may be retained for longer.
• Measurement preference: remains in the browser until the person changes it or clears the website's data.
• Commercial, contractual or accounting records: up to 10 years after the last applicable record, or the relevant statutory period.
• Evidence of authorisation and rights requests: throughout processing and for the additional time required to demonstrate compliance.
• Renne Pass: each item of data is retained according to its purpose, valid authorisation and applicable obligations. Using, reaching the expiry of or deleting a pass from a wallet does not itself revoke the customer’s authorisations or automatically trigger an opt-out, blocking or deletion of their data. Records needed for benefits, balances, transactions and complaints are retained for as long as justified to address them; they do not by themselves authorise marketing.
• Opt-out and restricted retention: upon receipt of an opt-out request, the corresponding marketing use will stop and the person will be removed from the lists, channels or purposes they identified. Only the minimum information whose retention remains necessary and has a legal or contractual basis will be kept blocked for a maximum of 24 months from the request, to document its handling, prevent re-enrolment without authorisation or address responsibilities. Blocking restricts access to authorised staff and excludes use for campaigns, marketing segmentation or reactivation. Data will be deleted or anonymised earlier when no longer necessary or when erasure is required. At the end of the maximum period it will be deleted or anonymised, unless a specific legal or contractual duty requires a different period; the reason, affected data and period will be documented. The 24 months are not a mandatory waiting period for exercising the right to erasure.
• Security logs: for a limited and proportionate period.

Deletion does not apply where a legal or contractual retention duty exists. Where possible, the data will be blocked from uses unrelated to that duty.

13. Data subject rights

These rights also cover ROS and WhatsApp conversations and records under Renne’s control, subject to justified legal exceptions and the limits on third-party copies described in section 18.

• Know, access, update and correct personal data.
• Request evidence of authorisation, subject to legal exceptions.
• Be informed of how data has been used.
• Submit enquiries and complaints.
• Withdraw authorisation or request deletion where permitted.
• Access personal data free of charge.
• File a complaint with the Colombian Superintendence of Industry and Commerce after completing Renne's procedure where required by law.

14. How to exercise these rights

Personal data enquiries and complaints must be sent to admin@ppisas.com. They must include the person's name, a response channel, a clear description of the request, and relevant supporting documents. Renne may request reasonable information to verify identity or authority without collecting unnecessary data.

You may opt out of marketing free of charge through our contact channels, including admin@ppisas.com, or an unsubscribe option included in a message. No special wording is required: simply express that you no longer wish to receive those messages. You may identify particular lists or channels; a general request to stop advertising applies to all Renne marketing communications. Leaving a list and requesting full erasure have different scopes; both will be handled according to your request without requiring the pass to expire. Issuing or using another pass does not reactivate withdrawn marketing consent: new valid authorisation is required.

Enquiries

Renne will respond within 10 business days. If this is not possible, it will explain the reason and provide a new date no later than 5 additional business days after the initial deadline.

Complaints

If incomplete, correction will be requested within 5 days. If no completion is received within 2 months, the complaint will be treated as withdrawn. If Renne is not competent, it will transfer the complaint within 2 business days and inform the person. A complete complaint will be answered within 15 business days from the day after receipt; an explained extension will not exceed 8 additional business days.

Consumer complaints have their own statutory response deadline and are not subject to the extensions in this data procedure. For Renne Pass, see also the general terms.

The procedure is free. Where required by law, the enquiry or complaint procedure before Renne must be completed before a complaint is filed with the authority.

15. National Database Registry

Based on the current corporate confirmation, Evlogia S.A.S. does not exceed the total-assets threshold of 100,000 Colombian tax value units (UVT) that triggers RNBD registration for companies and non-profit entities. This condition will be reviewed periodically and whenever assets or regulation change. The absence of a registration duty does not remove any other personal data protection obligation.

16. Changes, versions and governing language

This policy may be updated for legal, operational or technology changes. Material changes to the controller's identity or purposes will be communicated before application, and renewed authorisation will be obtained where necessary. Previous versions will be retained as evidence.

Version 1.4, effective from 26 September 2026. It replaces version 1.3 dated 20 September 2026. It adds ROS Renne and WhatsApp message reception while retaining the Renne Pass, analytics and recruitment coverage. This update does not itself expand previously granted authorisations. Google Analytics is enabled on the public website and loads only when the visitor allows measurement. This English version is provided for accessibility; if there is any discrepancy, the approved Spanish version governed by Colombian law prevails.

17. Personal data in Renne Pass

When you register for a pass, the registration notice will identify required data, its purpose and the relevant authorisation. We may process your name, selected contact channels, pass identifier, programme and status, issue and validity dates, benefits or balances, usage records, incidents and acceptance evidence. If a programme requires proof of company affiliation or another requirement, only proportionate information disclosed in advance will be requested. Identity documents, birth dates, precise location and access to your address book are not required by default.

This data is used to deliver and administer the pass, verify entitlement, record use, prevent duplication or fraud, restore access and handle requests. A relationship with an employer or partner does not itself authorise disclosure of individual usage history. Pass data will not be sent to Google Analytics. Payment card details must not be entered in Renne Pass forms; any payment provider used must be identified in the relevant payment process.

Operations may use customer management tools such as Odoo and issuance and update providers such as PassKit. The registration notice must identify the providers actually used and relevant processing information. Renne will limit data to what is necessary and verify contracts, instructions, security and processing locations before transmission. Transmissions to processors and transfers to independent controllers have different requirements under Colombian law; they are not authorised without meeting those requirements.

Saving a pass in Apple Wallet or Google Wallet involves services subject to their providers’ policies. Information needed to issue or update the pass may pass through the issuance provider and the selected wallet. Renne retains responsibility for its own processing decisions and appointed processors as required by law.

For invitations or referrals, the recipient decides whether to register. Their address book will not be uploaded and they will not be contacted on the sender’s behalf without a valid basis. Sharing the recipient’s identity, acceptance or usage with another person requires specific authorisation or another applicable legal basis; an unidentified status or count will be used where sufficient.

Necessary operational notices are distinguished from promotions and offers. Marketing requires a separate, optional choice for authorised channels, respecting withdrawal, contact restrictions and Colombia’s Registro de Números Excluidos where applicable. Enabling device notifications does not replace that choice. You may exercise your rights at admin@ppisas.com; periods and exceptions are described in sections 12 to 14. Commercial conditions are found in the Renne Pass general terms and each pass.

18. ROS Renne and service through WhatsApp

ROS Renne is a tool that supports Renne's customer service under the responsibility of Evlogia S.A.S.; it is not a separate data controller. At its current stage, a receiver has been deployed and prepared to receive and record messages through Meta's WhatsApp Business Platform. This description does not announce the activation of a new commercial channel or guarantee automated service.

Data received and its purpose

The receiver may store the sender's phone number, message identifier, sending and receipt dates, message type and received text. Text includes the message body, button or interactive-reply text, and associated captions when received. It does not download images, files or audio, and does not transcribe audio. It retains minimum technical receipt records to prevent duplicates and establish receipt.

The purpose is to receive and record requests, retain the necessary service history and enable authorised staff to handle them. ROS records are not sent to Google Analytics. We do not request passwords or sensitive data through this channel; the precautions in section 7 apply.

Providers and access

Messages are received through Meta/WhatsApp, and Renne's records are stored on infrastructure under its control, hosted on a Hostinger virtual server. Access is restricted to authorised people according to their role; conversations are not publicly accessible.

WhatsApp participates under its privacy policies and business data processing terms, according to its role. Hostinger provides hosting under its data processing terms. These services may involve processing outside Colombia. Renne must verify the actual location and applicable conditions, distinguish transmissions to processors from transfers to independent controllers, and meet the relevant requirements in section 8. This policy does not grant unlimited permission to share data.

Authorisation and limits on automation

Contacting Renne directly through WhatsApp does not mean accepting marketing or any future use of the conversation. Website-form authorisation does not automatically cover this interaction either. Renne must provide the channel notice and obtain and retain any required authorisation for its purposes no later than collection. Marketing requires a separate, optional and valid choice; refusing it does not prevent a service request.

At this stage, the receiver does not send automatic replies, use artificial intelligence to analyse or answer conversations, create bookings automatically, or connect to Renne.Chat. Before adding these functions, new purposes or new providers, Renne will review the notice, processing conditions, necessary authorisations and this policy where appropriate. Publishing this policy does not authorise those uses in advance.

Retention and rights over conversations

General enquiries without a commercial relationship, including their ROS and WhatsApp records under Renne's control, are subject to the maximum of 24 months after the last interaction in section 12, with its justified exceptions. In the current receiver, the period runs in calendar months from the person's last newly received message. Technical retries and delivery or read statuses do not restart it; a new enquiry after expiry does not restore the expired history.

The receiver has automatic cleanup scheduled hourly and before storing new messages. This is periodic processing: it does not guarantee immediate deletion, and failures must be remedied. If a conversation is necessary evidence for a legal or contractual obligation or an active request, exceptional retention must be justified and documented, with a review date. An overdue review requires human intervention; it does not automatically delete records subject to an obligation. These periods do not require waiting before requesting erasure.

Technical delivery and event records, and the cleanup audit —date, action and count, without text or phone numbers— are ordinarily retained for up to 30 days, with hourly review. After a message is deleted, only a technical fingerprint of its identifier and an expiry date are retained for up to 30 days, without text or a phone number, to prevent an immediate technical retry from recording it again. This does not block new enquiries or constitute marketing authorisation.

Access and deletion in the receiver use a private administrative tool, following human verification of the request and applicable exceptions. Receiving a message requesting erasure does not trigger automatic deletion. Local cleanup does not amount to erasure of disks, provider snapshots or external copies; any copies under Renne's responsibility must be included in its retention and rights management.

Access, update, correction, withdrawal and erasure requests also cover these records and are handled by Renne's Administrative and Financial Area at admin@ppisas.com, under sections 13 and 14. Renne will handle requests concerning copies under its control and those of its processors, subject to justified legal exceptions. It cannot itself delete copies that Meta/WhatsApp or the other participant retains under their own responsibility; the relevant service's or controller's procedures may be needed for those copies.

Employment supplement 1.1 · Applications and résumés

Recruitment supplement updated on 19 September 2026; its purpose and retention period remain unchanged under this Policy. For an application, Renne processes first and last names, email, mobile number, area of interest, the strengths and expectations statement, the résumé and its security metadata: sanitised original name, random internal name, detected format, size, integrity hash and private reference.

The sole purpose is to record and assess the profile, organise it by area, and consider it for current or future opportunities. After durable storage, the application fields and résumé are also sent to Renne's authorised operational inbox through Gmail as an internal reception and management channel. Submission does not promise a vacancy, interview, response or employment and does not authorise marketing communications.

The form does not request age, date of birth, identity document, photograph, gender, marital status, nationality, medical information or salary expectations. The person should avoid including unnecessary sensitive or potentially discriminatory data.

The résumé will remain outside public routes and the repository and access is restricted to staff authorised to assess and manage applications. Format, signature and macro validation reduces disallowed content but does not certify that a file is malware-free.

Data relating to unsuccessful applicants will be retained for up to 12 months from receipt of their application for the stated purpose and then deleted or anonymised, unless a legal duty, pending complaint or renewed valid authorisation applies. If employment is established, the processing for that relationship will be disclosed. Deletion includes working copies, including email, with the time technically necessary for secure backup rotation. The rights and procedures for access, correction, withdrawal and deletion are those set out in this Policy.