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GENERAL TERMS OF SALE

Colombia Insider Adventure SAS – Tomplanmytrip
RNT No. 214707
Last updated: [03/26/2025]

1. General Provisions

These general terms of sale (hereinafter “GTS”) govern the contractual relationships between the agency Colombia Insider Adventure SAS, a Colombian legal entity registered under the number RNT 214707, operating under the trade name Tomplanmytrip, and any person (hereinafter “the Client”) wishing to benefit from the services offered on the website www.tomplanmytrip.com as well as on our other digital platforms (social networks, newsletters, video platforms…).

Any subscription to one of our services implies full and complete acceptance of these GTS, which prevail over any other document or prior exchange.

2. General Information on the Terms of Sale

2.1 Agency Responsibilities

Colombia Insider Adventure SAS acts in accordance with Law 300/96, regulatory decree 1075/97, decree 2438 of 2010, and any regulations that may amend, supplement, or replace them.

The responsibility of Colombia Insider Adventure SAS is strictly limited to the services mentioned in the contractual documents validated with the Client. It cannot be held liable in any case of:

Events of force majeure or unforeseen circumstances: natural disasters, political unrest, strikes, flight delays, etc.
Personal issues of the traveler: lack of visa or refusal of entry into the territory, health problems, delays in private or public transportation, lost or damaged luggage, etc.
Actions or errors of a partner or external supplier, except in cases where the agency acted as a direct seller.
Loss of enjoyment of a service due to the traveler or a third party.

2.2 Risks related to destinations

Certain services offered involve an element of adventure that includes rudimentary accommodation conditions, limited medical access, or remote areas. The client acknowledges being informed of these risks and fully accepts them. They understand that these conditions specific to certain destinations may result in slower or more difficult medical care in the event of an accident or incident, and accept that Colombia Insider Adventure SAS and its local partners cannot be held responsible for the consequences related to these delays or difficulties in accessing care.

2.3 Program modifications or interruptions

Colombia Insider Adventure SAS, or its providers, reserves the right to modify the services initially planned (transportation, accommodation, activities…) for reasons of safety, logistical feasibility (weather conditions, delays, strikes, local disturbances, unavailability of providers…), or force majeure. No compensation can be claimed for this.

If an equivalent service is not feasible, the agency will offer an alternative solution as far as possible. In case of additional costs related to this alternative, it must be expressly approved by the Client before any implementation.

2.4 Client Responsibility

The client agrees to comply with local laws, safety rules, instructions from supervising staff, and required administrative formalities (customs, visa, vaccination, etc.). The agency cannot be held responsible for the consequences of a failure to meet these obligations.

Any behavior deemed irresponsible, contrary to the law, or endangering the group may result in exclusion from the trip without a refund.

2.5 Travel Insurance

No insurance is included in our services. Colombia Insider Adventure SAS encourages all its readers and clients to take out travel insurance for their stay in Colombia. It is the Client’s responsibility to obtain appropriate travel insurance (repatriation, hospitalization, cancellation, civil liability, internal flights…).
The refusal to subscribe to it cannot, in any case, engage the responsibility of Colombia Insider Adventure SAS.

2.6 Air Transport and Delays

International and domestic airlines may change flight schedules without notice. Colombia Insider Adventure SAS cannot guarantee the flight schedules indicated on the programs. In case of delay, modification, or cancellation of domestic or international flights, Colombia Insider Adventure SAS will do its best to adjust the program while respecting the initial schedule, but the costs incurred by these unforeseen events (accommodation, meals, transportation, itinerary changes, etc.) remain the responsibility of the client.

2.7 Luggage

The Client is fully responsible for their luggage throughout the entire trip. The agency cannot be held responsible for the loss, theft, or damage of luggage or valuables, nor for delivery delays upon arrival. The Client is also responsible for ensuring that no illicit items (such as drugs or prohibited substances) are introduced, even unknowingly, into their personal effects, and must exercise the utmost vigilance in this regard.

3. Detailed Description of Services Offered

SERVICE 0 – Affiliate Programs

Colombia Insider Adventure SAS participates in affiliate programs with third-party platforms (Booking.com, Airbnb, Viator, GetYourGuide…). By clicking on an affiliate link and completing a purchase, the Client allows Colombia Insider Adventure SAS to receive a commission. By accessing these platforms via the provided links, the Client is redirected to external sites and thereby agrees to the terms of use specific to each platform.

Booking conditions: via the relevant platform and according to the T&Cs of the relevant platform.
Cancellation Conditions: according to the T&Cs of the concerned platform.
Payment: processed directly with the platform.
Rates: depend on the concerned platforms.
Liability: Colombia Insider Adventure SAS disclaims any responsibility in case of malfunction or dispute with the platform.

SERVICE 1 – Connecting with Local Partners

Colombia Insider Adventure SAS connects its users with carefully selected local partners. The business relationship is directly between the Client and the partner, outside the contractual sphere of the agency.

Booking Conditions: managed by the partner according to their T&Cs.
Cancellation Conditions: according to the partner’s T&Cs.
Payment: paid directly to the partner according to their payment terms.
Rates: prices are always given as an indication on the communication channels of Colombia Insider Adventure SAS and must be validated with the partner.
Liability: Colombia Insider Adventure SAS selects and recommends these partners for the quality of their services. However, the services are provided under their full responsibility, and Colombia Insider Adventure SAS cannot be held responsible for their content, execution, or quality.

SERVICE 2 – Tomplanmytrip Enhances the Client’s Itinerary

The Client can book a paid video call with a member of the Colombia Insider team on Google Meet. During this exchange, the client benefits from:
– A complete analysis of their previously established itinerary communicated to Colombia Insider
– Recommendations for the duration of stay in each destination
– Logical reorganization of the order of the trip stages
– Specific advice to make the most of each place visited
– Optimization of the schedule to multiply experiences
– Correction of poorly planned routes
– Personalized expertise from a member of the Tomplanmytrip team to choose between different destination options
– Sharing of recommendations and contacts for experiences and transportation in each location

At the end of this call, the client will receive by email: a list of reliable local agencies (Tomplanmytrip partner network including those not listed on the site) in line with the client’s expectations and destinations.
No detailed written document or revised itinerary is provided. All advice is communicated exclusively orally during the video call, except for the previously mentioned list of local agencies.

Booking conditions: the service is confirmed upon appointment scheduling and payment. A booking confirmation is then sent to the client by email.
Cancellation Policy: Any cancellation request must be sent via email to Colombia Insider Adventure SAS (support@tomplanmytrip.com). The date the email is received will be used to calculate the deadlines.
Cancellation of this service is free up to 72 hours before the scheduled time of the video call. Beyond this period, no refund of the deposit will be possible.
In the event of a cancellation that results in a refund, the bank fees related to processing the initial payment will remain the responsibility of the Client and will be deducted from the refunded amount.
Payment: Payment is made by credit card (Visa, Mastercard, American Express, etc.) directly on the Calendly platform when booking the video call. The transaction is secured by the “Stripe” payment platform.
Rates: The service rate is displayed on our website www.tomplanmytrip.com. It may occasionally be communicated on our official channels (Emails, Instagram, Facebook, etc.) for informational purposes and must be confirmed with a member of the Colombia Insider Adventure SAS team.
Liability: No contractual commitment. In the event of a recommendation of a service or partner, the terms and conditions of the recommended service or provider will apply.

SERVICE 3 – Tomplanmytrip creates the client’s itinerary

By booking this service, the client benefits from personalized calls with a team member to validate their choices, refine their itinerary, and get answers to all their questions. After the initial exchanges, the client receives a detailed itinerary proposal accompanied by recommendations and contacts for transportation, accommodations, and activities. All of these options are then discussed and validated in collaboration with Colombia Insider. The finalized itinerary is delivered via a practical and intuitive digital tool accessible on both computer and mobile, and a final validation call concludes the support. The client remains free and responsible for making their own bookings for their services.

Booking Conditions: The service is validated upon scheduling the appointment and payment of the deposit. A booking confirmation is then sent to the Client by email.
After the first video call, a second payment will be required to continue the service. Upon receipt of this payment, Colombia Insider will deliver an initial itinerary proposal, then proceed with the necessary exchanges and adjustments until the final itinerary is completed.
Cancellation Policy: Any cancellation request must be sent via email to Colombia Insider Adventure SAS (support@tomplanmytrip.com). The date of receipt of the email will be used to calculate deadlines. Cancellation of this service is free up to 96 hours before the scheduled time of the first video call. Beyond this period, no refund of the deposit will be possible. In case of cancellation resulting in a refund, the bank fees related to the processing of the initial payment remain the responsibility of the Client and will be deducted from the refunded amount.
Once the second payment is made, no refund will be possible.
Payment: The deposit is paid by credit card (Visa, Mastercard, American Express, etc.) directly on the Calendly platform when booking the video call. This transaction is secured by the payment platform “Stripe”.
The second payment is made via a secure payment link (Bold, Wompi, Stripe, or other secure online payment platforms) which can be paid by credit card (Visa, Mastercard, American Express, etc.) or by bank transfer, according to the choice of Colombia Insider Adventure SAS.
Rates: The service price is displayed on our website www.tomplanmytrip.com. It may occasionally be communicated on our official channels (Emails, Instagram, Facebook, etc.) for informational purposes and must be confirmed with a member of the Colombia Insider Adventure SAS team.
The total amount of this service depends on the number of days covered by the itinerary. Interested clients will receive by email or via WhatsApp the total amount to be paid for the service, as well as the payment method to be used to finalize the reservation.
Liability: Colombia Insider Adventure SAS commits to providing a detailed, coherent, and personalized itinerary based on the information provided by the client. The itinerary is delivered in a digital format, accessible online via mobile or computer.
The agency’s responsibility ends with the delivery of the document. All bookings (accommodations, transportation, activities, etc.) must be made directly by the client. Colombia Insider Adventure SAS cannot be held responsible for any issues related to the chosen providers or the execution of the trip by the client.

SERVICE 4 – Tomplanmytrip organizes the client’s trip

Colombia Insider Adventure SAS assists the Client in the personalized development of their trip through several stages.
Personalized exchanges with the Client (calls, emails, WhatsApp) allow Colombia Insider Adventure SAS to refine the travel project according to their expectations. Several itinerary proposals are sent via a digital tool accessible on computer or mobile, until a near-final version is obtained and submitted for the Client’s approval.
Once the itinerary is approved, Colombia Insider Adventure SAS presents a final quote to the Client. If accepted, the client makes an initial payment according to the booking conditions defined below. After the Client confirms the final details, the agency handles all the reservations included in the service: accommodations, activities, and transportation.
The final itinerary is sent via a digital tool accessible on computer and mobile. Assistance in case of problems is provided throughout the entire stay.

Booking Conditions: The service is confirmed upon scheduling the appointment and payment of the deposit. The appointment confirmation is then sent to the Client by email.
After the first video call, Colombia Insider delivers an initial itinerary proposal, then proceeds with necessary exchanges and adjustments until the final itinerary is completed.
After the Client confirms the itinerary, Colombia Insider sends them a quote for the total amount of the trip for approval. Based on this, an initial payment of 50% of the total invoice amount for the trip (minus the deposit) is required. Upon receipt of this payment, the Client receives an invoice corresponding to the amount paid and a booking confirmation.
The balance of the trip is due 40 days before the arrival date. In case of non-payment within 30 days prior to arrival, Colombia Insider Adventure SAS may proceed with cancellation without compensation.
For any registration less than 40 days or for stays of 5 days or less, full payment is required immediately.
Travel insurance is mandatory for Clients subscribing to this service. The insurance policy must be submitted to Colombia Insider Adventure SAS at least 2 days before the start of the stay.
Cancellation conditions after deposit payment:
Any cancellation request must be sent via email to Colombia Insider Adventure SAS. The date the email is received will be used to calculate deadlines. Cancellation of this service is free up to 96 hours before the scheduled time of the first video call. Beyond this period, no refund of the deposit will be possible. In the event of a cancellation that results in a refund, the bank fees related to processing the initial payment will remain the responsibility of the Client and will be deducted from the refunded amount.
Cancellation conditions after the first or subsequent payments based on the overall quote:
Any cancellation request must be sent via email to Colombia Insider Adventure SAS (support@tomplanmytrip.com). The date the email is received will be used to calculate deadlines.
The client’s cancellation of their registration will incur cancellation fees according to the following conditions:
- Land services:
  – More than 40 days before the start of the stay: 30% of the total amount of the travel invoice
  – From 40 to 30 days before the start of the stay: 50% of the total amount of the travel invoice
  – From 29 to 10 days before the start of the stay: 75% of the total amount of the travel invoice
  – Less than 10 days before the start of the stay: 100% of the total amount of the travel invoice
- Special conditions:
  If one of our providers applies specific cancellation conditions, these will be explicitly indicated at the time of confirmation of the reserved services and strictly applied according to each provider’s policies.
- Domestic Flights:
  Airline tickets issued by Colombia Insider Adventure SAS will include cancellation and modification insurance.
  In case of cancellation, the customer will be refunded the ticket price, minus administrative and banking fees.
- Refund Conditions:
  Bank fees related to any potential refund are entirely the responsibility of the customer.
  The refund will be processed within 30 days from the receipt of the cancellation email, via bank transfer.
Travel Modification:
In case of cancellation or modification of part of the trip, or the number of participants, Colombia Insider Adventure SAS will revise the trip price based on the changes in services provided and the actual number of participants. Fees may be charged according to the modified services.
Any costs incurred by any addition, cancellation, or modification of services by the customer during the trip, or resulting from external events beyond our control, remain entirely the responsibility of the customer. The interruption of the trip, for any reason, will not result in any refund or compensation.
Payment:
The deposit is paid by credit card (Visa, Mastercard, American Express, etc.) directly on the Calendly platform when booking the video call. This transaction is secured by the “Stripe” payment platform.
The second payment is made via a secure payment link (Bold, Wompi, Stripe, or other secure online payment platforms) which can be paid by credit card (Visa, Mastercard, American Express, etc.) or by bank transfer, as chosen by Colombia Insider Adventure SAS.
Rates:
The total amount for the service for the stage depends on:
– the number of days covered by the personalized itinerary,
– the number of travelers involved in the stay.
– the reservations (accommodations, transportation, activities, etc.), established according to the choices previously validated with the client at the time of designing their itinerary.

The Client will receive a detailed quote corresponding to the entirety of their travel program, minus the deposit paid for the reservation of the first call. Billing is done only in Colombian pesos (COP), the reference currency for this service. The equivalences in euros or USD mentioned are purely indicative and cannot be the subject of a claim in case of exchange rate variation.
Colombia Insider Adventure SAS will only proceed with reservations after the express and complete validation of the quote by the Client.

Liability:
Colombia Insider Adventure SAS is committed to providing a detailed, consistent, and personalized itinerary, tailored to the client’s expectations. The itinerary is delivered in digital format, accessible online via mobile or computer. The agency is committed to making the reservations (activities, accommodations, and transportation) agreed upon with the clients.
Colombia Insider Adventure will also offer assistance in case of problems during the trip concerning the following cases:
– Issues with reservations made by Colombia Insider Adventure SAS
– Support in case of unforeseen events (strikes, delays, cancellations, etc.)
– Support for the client in case of accident, theft, or assault, by guiding the client in their dealings with the relevant Colombian organizations or authorities.
Colombia Insider Adventure SAS reminds that travel insurance is particularly relevant in these cases and mandatory for clients who take this service.

SERVICE 5 – Group Stays

Colombia Insider Adventure SAS offers the organization of all-inclusive group stays in Colombia, with accommodations, transportation, and a program of activities defined in advance and supervised by a bilingual guide (French/Spanish or English/Spanish) present throughout the entire stay. The participants do not necessarily know each other and share a common adventure on a fixed date.

Booking Conditions:
The service is accepted and booked when the traveler’s deposit has been received by Colombia Insider Adventure SAS. After receiving the payment, the client receives a booking confirmation.
4 months before the tour departure, a first payment of 50% of the total amount minus the deposit already paid will be requested.
The balance of the trip is due 45 days before arrival. In case of non-payment 30 days before arrival, Colombia Insider Adventure SAS may cancel without compensation and without obligation to refund the deposit.
In case of registration less than 45 days before departure, full payment for the stay is required upon booking.
Travel insurance is mandatory for clients who wish to take this service and must be sent to Colombia Insider Adventure SAS at least 2 days before the start of the stay.
Cancellation Conditions:
Cancellation by Colombia Insider Adventure SAS:
Colombia Insider Adventure SAS reserves the right to cancel the stay if the minimum number of 6 participants is not reached at least 50 days before the start of the stay.
In this case, the client who made a reservation with a deposit will be fully refunded within 30 days following the announcement of the cancellation.

Cancellation by the Client:
Any cancellation by the client must be communicated by email to Colombia Insider Adventure SAS (support@tomplanmytrip.com).
The date of receipt of this email will determine the application of the following cancellation fees:
- Land Services:
  – More than 60 days before the start of the stay: 50% of the total amount of the travel invoice
  – From 59 to 30 days before the start of the stay: 75% of the total amount of the invoice
  – Less than 30 days before the start of the stay: 100% of the total amount of the invoice
- Special Conditions:
  If any of our suppliers apply specific cancellation conditions, these will be explicitly indicated at the time of confirmation of the reserved services, and strictly applied according to each supplier’s policies.
- Domestic Flights:
  Airline tickets reserved as part of the stay are non-refundable, regardless of the cancellation date, unless otherwise stated.
  They will be billed in addition to land services and not refunded in case of client cancellation.
  In case of a name change on an issued ticket, a flat penalty of €50 per person will be applied.
- Refund Conditions:
  Bank fees related to any possible refund are entirely the responsibility of the client.
  The refund will be processed within 30 days from the receipt of the cancellation email, by bank transfer.
Payment:
Via a secure link (Bold, Wompi, Stripe, or other secure online payment platforms), payable by credit card (Visa, Mastercard, American Express, etc.), or by bank transfer at the choice of Colombia Insider Adventure SAS.
Rates:
Group trips organized by Colombia Insider Adventure SAS are all-inclusive and offered at a fixed price per participant.
The applicable prices are those displayed on our website ww.tomplanmytrip.com. They may be occasionally communicated on our other official channels (Emails, Instagram, Facebook, etc.) as an indication and must be confirmed with a member of the Colombia Insider Adventure SAS team.
Clients interested in a trip will receive a personalized quote specifying: the total amount to be paid per participant, as well as the detailed itinerary of the corresponding trip.
The quote validated by the client will serve as proof for all included services. Any modification or price change after the quote validation may be charged to the client if it results from circumstances beyond the control of Colombia Insider Adventure SAS. In this case, the agency will propose alternative solutions as much as possible to best respect the initial commitment.
Liability:
Once the client books a group stay, Colombia Insider Adventure SAS commits to:
– Organize the stay according to the program provided to the client;
– Ensure the presence of a competent bilingual guide, selected by the agency;
– Ensure the smooth running of the experience, in coordination with its local providers.
In case of a problem beyond its control (delays, breakdowns, natural events, strikes…), the agency will implement all reasonable means to limit the impact on the course of the stay, without this giving rise to a refund or compensation. Colombia Insider Adventure SAS reminds that travel insurance is particularly relevant in these cases and mandatory for clients who take this service.

4. Acceptance of Conditions

The client declares that they know and fully accept these conditions, which constitute the unique, total, and exclusive agreement of any other contrary agreement or legal provision regarding the terms, conditions, and restrictions of the contracted services. RNT No. 214707.

POLICY FOR THE PREVENTION OF MONEY LAUNDERING AND TERRORISM FINANCING

1. Purpose

Define and apply the guidelines, controls, and necessary actions to guard against the risks of money laundering (ML) and terrorism financing (TF), engaging all members of the company in this approach.

2. Scope

This policy applies to all processes of COLOMBIA INSIDER S.A.S. exposed to ML/TF risk factors.
The counterparties involved in these risks, and subject to these guidelines, include:

Clients
Suppliers
Partners or shareholders
Company employees
Cash management
Other third-party creditors
Affiliated agencies

3. Legal Framework

In order to comply with Colombia’s international commitments to combat illicit activities and terrorism, the Colombian government has enacted a set of regulations requiring various economic sectors to implement actions aimed at reducing risks and facilitating the detection of individuals or entities involved in these crimes.

International standards and regulations on money laundering and terrorist financing, and their adoption in Colombia:

INTERNATIONAL STANDARD	ADOPTION IN COLOMBIA
Vienna Convention of 1988 – United Nations Convention Against Illicit Traffic in Narcotic Drugs and Psychotropic Substances	Law 67 of 1993 – Ruling C-176 of 1994
United Nations Convention for the Suppression of the Financing of Terrorism (1989)	Law 808 of 2003 – Ruling C-037 of 2004
Palermo Convention (2000) – United Nations Convention Against Transnational Organized Crime	Law 800 of 2005 – Ruling C-962 of 2003
Merida Convention (2003) – United Nations Convention Against Corruption	Law 970 of 2005 – Ruling C-172 of 2006

International Standards: International recommendations from the United Nations, FATF (Financial Action Task Force), CFATF (Caribbean Financial Action Task Force), GAFISUD (Financial Action Task Force of South America). Australian Standard for risk management AS/NZS 4360. International Standard for risk management ISO 31000:2009. NRS Model (Responsible and Secure Enterprises). Integrated Framework for Enterprise Risk Management.

NATIONAL STANDARDS	DESCRIPTION
Law 222 of 1995 and Decree 4350 of 2006	Through which the Superintendence of Companies is authorized to exercise control over foreign commercial companies and sole proprietorships regarding compliance with the law and their statutes.
Article 86, paragraph 3, of Law 222 of 1995	It mentions the authority of the Superintendence of Companies to impose fines and sanctions, successive or not, up to 200 SMLM, on anyone violating its orders, the law, or its statutes.
Article 10 of Law 526 of 1999, modified by Law 1121 of 2006	It specifies that authorities exercising inspection, surveillance, and control functions must instruct supervised entities on the characteristics, periodicity, and control mechanisms related to information to be transmitted to the UIAF.
Article 2 of Decree 1497 of 2002	It is established that public and private entities belonging to sectors other than the financial, insurance, and securities sectors must transmit information to the UIAF when required, according to the modalities and deadlines it determines.
Article 7 of Decree 1023 of 2012, paragraph 26	Its point 26 establishes that it is the responsibility of the Superintendence of Companies to instruct entities under its supervision on the measures to be adopted for the prevention of money laundering and terrorism financing risks.
External Circular No. 100-000005 of June 17, 2014, repealed by the Basic Legal Circular No. 100-000003 of July 22, 2015, then modified on August 19, 2016, by the Basic Legal Circular No. 100-000006.	Issued by the Superintendence of Companies, these aim for the real sector to implement the Self-Management System for Money Laundering and Terrorism Financing Risk, starting with companies whose revenues, as of December 31, 2013, were higher than 160,000 SMLV.
CONPES 3793 – December 18, 2013	Through which guidelines are established for the implementation of the National Policy against Money Laundering and Terrorism Financing.
External Circular 034 of 2015 – Financial Superintendence	It introduces modifications to the SARLAFT regime, providing instructions regarding client knowledge and the verification by the entity of the information provided by the client as well as certain insurance products.

External Circulars 022 (04/19/2007) and 026 (2008) from the Financial Superintendence	It aims for supervised entities to implement a Money Laundering and Terrorism Financing Risk Management System, to prevent their use in giving an appearance of legality to assets originating from criminal activities or for channeling resources towards terrorist activities.
External Circular 61 of 2007 consolidates, in a single instruction, a large part of the content of Title I, Chapter XI of the Basic Legal Circular 07 of 1996, as well as Circulars 03 and 10 of 2005 – Financial Superintendence.	The objective is to guide entities towards effective management of money laundering and terrorism financing risk, to continue adopting international recommendations and standards, and to reorganize the regulatory framework.
The Organic Statute of the Financial System of 1993, articles 102 to 107 (Decree 663 of 1993)	It established the SIPLA, which includes policies, people, tools, and mechanisms for prevention, reporting of suspicious and cash transactions; it created the role of Compliance Officer as well as training programs; it assigns responsibilities to financial entities and the Financial Superintendence, and establishes a sanction regime for entities that do not adopt the established procedures.
Law 1121 of 1996	Law on the prevention, detection, investigation, and sanction of terrorism.
The Basic Legal Circular of the Financial Superintendence	Chapter XI, Title I
NTC 3100 – Colombian Technical Standard	Risk Management
Decree 1497 of 2002 (IUAF)	This decree extended the obligation to establish and implement mechanisms for detecting suspicious transactions and their reporting to all economic sectors.
Decree 1497 of 2002 (IUAF)	Prevention and control of money laundering
External Circular No. 100-000011 of November 25, 2011, from the Superintendence of Ports and Transport	It aims for companies transporting land freight vehicles to implement the Comprehensive System for the prevention and control of money laundering and terrorism financing.
Law 190 of 1995	Anti-Corruption Statute
Law 793 of 2003 regarding the extinction of property rights	Inter-institutional coordination committee for the control of money laundering (decrees 950 of 1995 and 754 of 1996)

4. Definitions

This policy defines:

The expected conduct principles from company members in the face of money laundering (ML) and terrorist financing (TF) risks;
The obligations of employees, as members of COLOMBIA INSIDER S.A.S.;
The individuals responsible for monitoring and ensuring the proper application of this policy.

5. Policies related to the prevention of money laundering and terrorist financing risks

Policy No. 1: Actively cooperate in the fight against ML/TF

All members of COLOMBIA INSIDER S.A.S. are required to participate in the detection, prevention, and reporting of risks related to money laundering and terrorist financing.

Policy No. 2: Conduct principles for employees

The attitude of all company employees towards the prevention of money laundering and terrorist financing must align with the company’s ethical principles and values, based on the highest standards of integrity.
The following specific criteria are defined:

a) Knowledge of third parties related to the company

Every employee involved in national or international operations or transactions is required to apply the control measures defined by the company, both in this policy and in internal procedures, to ensure a thorough and diligent identification of third parties, as part of their duties.

b) Contribution to Achieving Objectives

All employees of COLOMBIA INSIDER S.A.S. must actively participate in verifications or information gathering required for the prevention of money laundering and terrorist financing.
They are also required to report any unusual or suspicious operations identified in the course of their duties and in accordance with this policy.

c) Confidentiality of Information

No employee of COLOMBIA INSIDER S.A.S. may disclose to third parties any information related to internal AML/CFT procedures or controls, nor the reports submitted to the competent authorities in this area.

Policy No. 3: Principles of Third-Party Relations

The relationships established by COLOMBIA INSIDER S.A.S. in the course of its activities must adhere to the following principles:

Compliance with current national and international laws, as well as specific regulations applicable to AML/CFT;
Adherence to the fundamental principles of the United Nations Global Compact;
Compliance with the company’s code of ethics;
Transparent conduct in the execution of tasks and management of results;
Risk management in a responsible, reasonable, and sustainable manner;
No transactions with individuals or entities listed on UN or OFAC sanctions lists;
Transmission to the UIAF of any unusual or suspicious operations identified.

Policy No. 4: Analysis, Verification, and Reporting of Payments from Tax Havens

In accordance with Decree 1966 of October 7, 2014, payments from jurisdictions considered tax havens will be subject to analysis, review, and, if necessary, reporting to the competent authorities. This Policy was reviewed and approved by the Board of Directors on March XX, 2021.

COOKIE USE POLICY

In accordance with Colombian legislation on personal data protection (Law 1581 of 2012, Decree 1074 of 2015, and all norms modifying, supplementing, or replacing them), we inform that COLOMBIA INSIDER S.A.S., through its websites, notably www.tomplanmytrip.com, may use cookies, both from the site and third parties, for various purposes.

In this sense, we present below the COOKIE USE POLICY adopted by www.tomplanmytrip.com, hereinafter referred to as THE PORTAL, which contains the essential information that any user of the site must know regarding the use of cookies placed by the site itself or by third parties with access to the site.

THE PORTAL reserves the right to modify this policy at any time to keep it up to date and in compliance with current legal provisions.

We therefore recommend that users check the date of drafting or updating, indicated at the end of this document.

For any questions regarding the use of cookies or the topics covered in this policy, you can write to the following address: support@tomplanmytrip.com

DEFINITION AND TYPES OF COOKIES

A cookie is a small file containing information, downloaded to the user’s device when they access certain web pages. This file allows storing and retrieving information about the navigation performed from this device. Thanks to cookies, sites can retain certain data related to the user’s visit, thus improving and securing their browsing experience.

The cookie can be associated with an anonymous user (not identified or not registered), as well as with a logged-in user.

It is important to specify that cookies are not viruses, nor any other type of malicious program aimed at damaging users’ devices. They cannot delete or read the information contained on the visitor’s computer or device.

Cookies are created or updated automatically when the user accesses the PORTAL. This allows the PORTAL, or authorized third parties, to track the user’s activity, via the information that cookies contain. These cookies can only be read by the site that generated them.

THE PORTAL may share the information obtained through cookies with third parties (partners, providers, affiliated companies), in order to improve the services offered. This information will be used by THE PORTAL and the third parties concerned, in accordance with the purposes described in this Policy and its updates.

There are several types of cookies, classified according to their origin, lifespan, or purpose:

Essential Cookies

These cookies are indispensable for the proper functioning of the Portal. They facilitate, among other things, the recording of information and allow for faster and more secure access to the services chosen by the user.
Without these cookies, www.tomplanmytrip.com may not be able to offer certain services, or may not function properly.

Functional Cookies

These cookies allow www.tomplanmytrip.com or authorized third parties to customize the user experience by providing content or services tailored to their needs or preferences.
They also allow partners, providers, or entities affiliated with the PORTAL to improve the site’s usability and performance.

Advertising Cookies

These cookies, used by www.tomplanmytrip.com or its commercial partners, aim to present the user with targeted advertisements, based on their browsing preferences.
They allow for the optimization of displayed advertising content and may be shared with companies affiliated with the PORTAL for use in their marketing campaigns.

Analytics or Performance Cookies

These cookies allow the PORTAL, or its partners, to perform statistical analyses on browsing data, in order to improve the efficiency and quality of services offered to users.

The cookies installed on the user’s device are only accessible by the PORTAL and its authorized partners.
They cannot be viewed or used by other users or unauthorized third parties.

DISABLING COOKIES

You can disable the cookies used on this site without affecting its basic functionality; however, the information collected via these cookies helps improve our services, particularly by analyzing site traffic or the impact of displayed advertisements.

Disabling the installation or use of cookies can be done directly from the browser used. Here is the procedure to follow according to your browser:

Internet Explorer: Tools → Internet Options → Privacy → Settings.
More information via Microsoft’s help or the browser’s support.
Mozilla Firefox: Tools → Options → Privacy → History → Use custom settings.
More information via Mozilla’s help.
Google Chrome: Settings → Show advanced settings → Privacy → Content settings.
More information via Google’s help.
Safari: Preferences → Security.
More information via Apple’s help.

This policy has been in effect since April 14, 2022.

PRIVACY NOTICE

This Privacy Notice establishes the conditions under which COLOMBIA INSIDER AVENTURE S.A.S. processes your personal data.

1. IDENTIFICATION INFORMATION OF THE DATA CONTROLLER

Name: COLOMBIA INSIDER AVENTURE S.A.S.
Identifier: 901.280.235-2
Address: CRA 64 # 81 URB Posada Del Viento
City: Copacabana, Antioquia, Colombia
Email: support@tomplanmytrip.com
Website: https://www.tomplanmytrip.com

2. PROCESSING AND PURPOSE

The processing carried out by COLOMBIA INSIDER AVENTURE S.A.S. of the personal information of the Holders will consist of the collection, storage, use, and circulation of such information for the following purposes:
(i) Carry out and manage procedures (requests, complaints, claims).
(ii) Provide the products and/or services acquired, directly or with the participation of third parties.
(iii) Promote and advertise our activities.
(iv) Conduct transactions.
(v) Report to various national administrative control and surveillance authorities, police or judicial authorities, financial entities, and/or insurance companies.
(vi) Conduct internal administrative activities such as: audits, accounting reports, statistical analyses, or billing.
(vii) Maintain accounting records.
(viii) Manage correspondence.
(ix) Conduct control, monitoring, surveillance, security, and protection activities of the facilities, assets, and personnel of COLOMBIA INSIDER AVENTURE S.A.S.

3. RIGHTS OF THE HOLDER

As the holder of your personal data, you have the following rights:
(i) Access the provided data that has been processed free of charge.
(ii) Know, update, and correct your information, especially if it is partial, inaccurate, incomplete, fragmented, misleading, or if its processing is prohibited or unauthorized.
(iii) Request proof of the authorization granted.
(iv) File a complaint with the Superintendency of Industry and Commerce (SIC) in case of violation of the current legal provisions.
(v) Revoke the authorization and/or request the deletion of the data, provided there is no legal or contractual obligation preventing their deletion.
(vi) Not answer questions regarding sensitive data. Responses to these questions are optional, as are those concerning data of children and adolescents.

4. MECHANISMS FOR ACCESSING THE PROCESSING POLICY

The Holder can access our Information Processing Policy, available on the website of COLOMBIA INSIDER AVENTURE S.A.S., during business hours.

PERSONAL DATA PROTECTION POLICY

1. PURPOSE

This policy aims to guarantee the constitutional right of every person to know, update, and correct the information concerning them that has been collected in databases or files held by COLOMBIA INSIDER AVENTURE S.A.S.

For this purpose, COLOMBIA INSIDER AVENTURE S.A.S. is considered the Information Controller, with the following details:
Name: COLOMBIA INSIDER AVENTURE S.A.S.
Identifier: 901.280.235-2
Address: CRA 64 # 81 URB Posada Del Viento
City: Copacabana, Antioquia, Colombia
Email: support@tomplanmytrip.com
Website: https://www.tomplanmytrip.com

2. SCOPE

This Policy applies to all personal data recorded in any database held by COLOMBIA INSIDER AVENTURE S.A.S., allowing for its processing.

3. COVERAGE

This Policy applies to the agency, directors, employees, contractors, and visitors of COLOMBIA INSIDER AVENTURE S.A.S., as well as all databases in its possession. It governs the relationships between COLOMBIA INSIDER AVENTURE S.A.S., as the Controller, and any potential subcontractor.

4. RESPONSIBLE ADMINISTRATION

COLOMBIA INSIDER AVENTURE S.A.S., through its communication department, will assume the role of Controller, being responsible for making decisions regarding databases and/or data processing, defining the purpose and method of data collection, storage, and management. It is also required to request and retain the express authorization of the Holder.

5. DEFINITIONS

Authorization: Prior, express, and informed consent of the Holder for the processing of their personal data.
Database: Organized set of personal data subject to processing.
Personal data: Any information related or that can be associated with one or more identified or identifiable natural persons.
Data Processor: Natural or legal person, public or private, that processes personal data on behalf of the Controller.
Data Controller: Natural or legal person, public or private, who decides, alone or jointly, on the database and/or processing.
Holder: Natural person to whom the personal data subject to processing relates.
Processing: Any operation or set of operations performed on personal data, such as collection, storage, use, circulation, or deletion.

6. PRINCIPLES APPLICABLE TO THE PROCESSING OF PERSONAL DATA

Principle of Legality: The processing of personal data is a regulated activity that must comply with legal provisions and applicable standards.
Principle of Purpose: The processing must pursue a legitimate purpose, in accordance with the Constitution and the law, and this purpose must be clearly communicated to the Holder.
Principle of Freedom: Processing can only be carried out with the prior, express, and informed consent of the Holder. Personal data cannot be obtained or disclosed without prior authorization, except for legal obligation or judicial decision.
Principle of Truthfulness or Quality: Information subject to processing must be true, complete, accurate, up-to-date, verifiable, and understandable. It is prohibited to process inaccurate, incomplete, fragmented, or misleading data.
Principle of Transparency: The Holder has the right to obtain, at any time and without restrictions, information on the existence of data concerning them, whether from the Responsible Party or the Processor.
Principle of Restricted Access and Circulation: Processing is limited by the nature of the data, legal and constitutional requirements. It can only be carried out by persons authorized by the Holder or empowered by law. Personal data, except those of a public nature, must not be made accessible on the Internet or through other mass dissemination channels, unless access can be technically limited to the Holders or authorized third parties.
Principle of Security: Processed data must be protected by adequate technical, human, and administrative measures to prevent their alteration, loss, consultation, unauthorized or fraudulent use or access.
Confidentiality Principle: All individuals involved in the processing of non-public personal data are required to ensure the confidentiality of this data, even after the end of their contractual relationship. They can only communicate or transmit it within the scope of authorized activities.

7. NAME AND PERSONAL INFORMATION COLLECTED

The types of data collected vary according to the Holder’s relationship with COLOMBIA INSIDER AVENTURE S.A.S., and are tailored to the specific purposes mentioned below.

COLOMBIA INSIDER AVENTURE S.A.S. has identified the following databases:

Users / Clients
Suppliers, third parties and/or contractors
Employees

7.1 Information collected in the Users / Clients database

Name
Identification number
Email address
Postal address
Mobile phone number
Credit card number
IP address
Location

7.2 Information collected in the Suppliers, Third Parties and/or Contractors database

Name
NIT identification number
Name and identification number of the legal representative
Economic activity
Address
Phone
Email address
Mobile phone number
Financial information

7.3 Information collected in the Employee database

Name
Identification number
Date of birth
Marital status
Address
Phone
Email address
Cell phone number
Emergency contact person
Financial information

8. PURPOSES OF INFORMATION PROCESSING

The processing of personal data will be carried out in accordance with the current legal framework, in order to allow COLOMBIA INSIDER AVENTURE S.A.S. to fulfill its corporate purpose. In this regard, the Holders, by accepting this Policy, authorize COLOMBIA INSIDER AVENTURE S.A.S. to collect and process their personal data for the following purposes:

8.1 General uses of databases:

Collection
Storage
Use
Circulation (transmission and transfer)
Processing
Deletion

8.2 General purposes of databases:

Execution of the corporate purpose of COLOMBIA INSIDER AVENTURE S.A.S.
Management, administration, and use of all information necessary to comply with legal and contractual obligations, as well as tax, commercial, corporate, and accounting obligations.
Execution of contracts signed with COLOMBIA INSIDER AVENTURE S.A.S.
Support in internal and external audits.
Transmission of information to governmental or judicial authorities upon their express request.
Data collection for compliance with the legal and regulatory obligations of the Controller or the Processor.
Communication on policies, projects, programs, and organizational changes.
Seeking the satisfaction of the Holders regarding the products and services offered.
Improvement of the offer of services, products, and benefits.
Personalization of the experience of the Holders on the website of COLOMBIA INSIDER AVENTURE S.A.S.
Carrying out internal activities for operational, development, or system management purposes.
Maintaining communication with the Holder.
Responding to questions, claims, complaints, or comments from the Holders.
Sending commercial and/or institutional information, invitations to events or activities organized by COLOMBIA INSIDER AVENTURE S.A.S.
Management of claims, suggestions, and complaints related to the services offered.
Collection of information about the device used to access the website (IP address, browser type, operating system) and association with personal data to optimize the online experience.
Evaluation of the use of the site (anonymously and globally), carrying out usage statistics, such as consultation hours, visit frequency, or referring site, to personalize the user experience.
Audit, analysis, and study of databases to design commercial strategies and improve the offer of products and services.
Transfer of personal data to the parent company of COLOMBIA INSIDER AVENTURE S.A.S. for processing in accordance with the stated objectives.
Communication of personal data to subsidiaries, affiliated companies, business partners, or third parties mandated by COLOMBIA INSIDER AVENTURE S.A.S. for the purposes provided in this Policy.
Disclosure of data when necessary to comply with laws, regulations, or legal procedures, ensure the enforcement of general conditions, prevent fraud or security attacks, or protect the rights of others.
Cross-referencing data with information obtained from partners to implement joint business strategies.
Consultation, storage, and use of financial information obtained through third-party databases, subject to the express authorization of the Holder.
Any other purpose determined by the Managers in the processes of collecting personal data to fulfill legal obligations and internal policies.

8.3 Specific purposes for the Users / Clients database:

The personal data collected through this database have the following purposes, in accordance with the Personal Data Protection Policy of COLOMBIA INSIDER AVENTURE S.A.S.:

Have the information provided at the time of contract signing, in order to comply with its clauses.
Inform about new brand developments, products, services, promotions, and commercial campaigns of COLOMBIA INSIDER AVENTURE S.A.S., conduct satisfaction surveys, and strengthen customer service channels.
Conduct studies and evaluations of the offered products and services, including market trend and customer profile analyses.
Send communications about new services or their modifications, as well as commercial messages related to products and services.
Conduct internal studies on consumption habits.
Evaluate the quality of the service.
Provide the requested services.
Implement mechanisms for fraud detection and prevention, including alerts, monitoring, preventive blocks, reviews, transaction limits, verifications, and other risk reduction measures.
Apply the purposes defined in the authorization granted by the Holder or mentioned in the Privacy Notice.
Send commercial or promotional messages regarding the services, events, or campaigns of COLOMBIA INSIDER AVENTURE S.A.S. or third parties by mail, email, SMS, WhatsApp, MMS, or any other analog or digital means.
Carry out billing activities, money laundering prevention, verification of personal, professional, or commercial references, consultation of public or private databases, including sanction lists or criminal or disciplinary records.
Manage collection procedures, payment behaviors, and report data to credit rating agencies.
Cross-reference data to assess the feasibility of future services.
Share, with authorization, the data collected within the framework of the contractual relationship with third parties.
Transfer the data to the parent company for processing and fulfillment of the purposes outlined in this Policy.
Send information of interest regarding services, news, or legal developments related to COLOMBIA INSIDER AVENTURE S.A.S.
Fulfill its functions as a technology provider, payment gateway, and clearinghouse.

8.4 Purposes of the Suppliers, Third Parties, and/or Contractors Database:

a. For commercial purposes.
b. For accounting needs.
c. To comply with judicial decisions and administrative, legal, tax, and regulatory provisions.
d. For the preparation of documents, contracts, agreements, and receipts.
e. For compliance with contractual obligations, including the possibility of transferring data to third parties such as: financial entities, notaries, OFAC or anti-terrorism lists, lawyers, etc.
f. To honor contractual commitments made by COLOMBIA INSIDER AVENTURE S.A.S., particularly regarding invoice payments.
g. To inform the provider of any changes to the contractual relationship.
h. To evaluate the quality and performance of the provider in the context of their contractual obligations.
i. To conduct audits related to the contractual relationship.
j. For the preparation of the company directory and to ensure compliance with confidentiality obligations.
k. For any other use authorized in writing by the provider regarding the use of their data.

8.5 Purposes of the Employee Database:

a. Carry out the necessary steps for the development of the contractual employment relationship.
b. Fulfill the obligations arising from the employment relationship, particularly those related to the payment of wages, social benefits, social security contributions, and other elements agreed upon in the employment contract.
c. Inform the employee of any changes to the contractual relationship.
d. Evaluate the quality and performance of the employee within the scope of their duties.
e. Make salary deductions authorized by the employee.
f. Conduct internal audits.
g. Create professional email addresses; establish the company directory; assign work tools; provide usernames, passwords; ensure compliance with confidentiality obligations and other contractual obligations.
h. Verify personal and professional references; contact relatives, dependents, or beneficiaries in case of emergency.
i. Offer, alone or in collaboration with third parties, or on behalf of third parties, financial, commercial, social services (particularly related to pension funds, social security), organize promotional, charitable, or social campaigns.
j. COLOMBIA INSIDER AVENTURE S.A.S. may also use the personal data of its employees for other purposes, provided they are compatible and analogous to the purposes previously mentioned.

9. OBLIGATIONS OF COLOMBIA INSIDER AVENTURE S.A.S.

a) Guarantee the Holder, at all times, the full and effective exercise of their right to habeas data;
b) Request and keep a copy of the express authorization granted by the Holder;
c) Appropriately inform the Holder about the purpose of the collection and the rights recognized to them under the authorization;
d) Keep the information under appropriate security conditions to prevent its alteration, loss, consultation, unauthorized or fraudulent use or access;
e) Ensure that the information transmitted to the Subcontractor is truthful, complete, accurate, up-to-date, verifiable, and understandable;
f) Update the information, timely communicating to the Subcontractor any developments regarding the previously transmitted data, and adopt the necessary measures to ensure the data is updated;
g) Rectify inaccurate data and inform the Subcontractor;
h) Transmit to the Subcontractor only the data whose processing has been previously authorized;
i) Require the Subcontractor, at all times, to comply with the conditions of security and confidentiality of personal data;
j) Manage requests, claims, and complaints made by the Holders;
k) Inform the Subcontractor when certain information is disputed by the Holder, as soon as a claim has been filed and the process is ongoing;
l) Inform the Holder, upon request, of the use of their data;
m) Inform the data protection authority in case of a breach of security measures or when there are risks in the management of the Holders’ data;
n) Comply with the instructions and requirements issued by the Superintendence of Industry and Commerce.

10. DUTIES OF OFFICIALS IN CHARGE OF DATA PROCESSING

a) Guarantee the Holder, at all times, the full and effective exercise of their right to habeas data;
b) Keep the information under sufficient security conditions to prevent any alteration, loss, consultation, unauthorized or fraudulent use or access;
c) Update, rectify, or delete the data in a timely manner;
d) Update the transmitted data within a maximum period of five (5) business days from their receipt;
e) Handle requests and claims made by the Holders;
f) Adopt an internal procedures manual to ensure adequate compliance with the law and this policy, especially for handling requests and claims from Holders;
g) Record in the database the mention “claim in progress”;
h) Add the mention “information subject to judicial proceedings” in the database when a judicial procedure related to the quality of the data is notified by a competent authority;
i) Refrain from disseminating information contested by the Holder and whose processing suspension has been ordered by the Superintendence of Industry and Commerce;
j) Allow access to the information only to authorized persons;
k) Inform the Superintendence of Industry and Commerce in case of security breaches or risks affecting data management;
l) Comply with the instructions and requirements of the Superintendence of Industry and Commerce.

11. PROHIBITIONS

a) It is prohibited to carry out processing that is incompatible with the purpose authorized by the Holder or provided by law, except in cases of explicit and unequivocal consent from the Holder;
b) It is prohibited to process partial, inaccurate, incomplete, fragmented, or misleading data, or data whose processing is expressly prohibited or unauthorized;
c) Personal data, except for public information, cannot be made accessible on the Internet or through other mass communication channels, unless a technical access control allows limited consultation to the Holders or authorized third parties;
d) The processing of sensitive data is prohibited, unless the Holder has given explicit consent for this purpose;
e) The processing of personal data of children, adolescents, and teenagers is prohibited, except when it involves public data or when authorization has been granted in advance, expressly, and knowingly by their parents or legal representatives.

12. RIGHTS OF HOLDERS

a) Know, update, and correct their personal data;
b) Request proof of the authorization given to COLOMBIA INSIDER AVENTURE S.A.S., unless the authorization is not required according to the law¹;
c) Be informed, upon request, by COLOMBIA INSIDER AVENTURE S.A.S. or by the Processor, about the use that has been made of their personal data;
d) File a complaint with the Superintendence of Industry and Commerce for any violation of the law or regulations regarding data protection;
e) Revoke the authorization and/or request the deletion of the data when the legal or constitutional principles, rights, and guarantees are not respected. This revocation or deletion will be applicable when a violation has been determined by the Superintendence;
f) Access their processed personal data free of charge.

¹ Exceptions to Authorization: according to Article 10 of Law 1581 of 2012, the Holder’s authorization is not required in the following cases:
a) Data requested by a public or judicial entity;
b) Data of a public nature;
c) Situations of medical or sanitary emergency;
d) Processing authorized by law for historical, statistical, or scientific purposes;
e) Data from the Civil Registry of Persons.

13. PROCESSING OF MINORS’ DATA

COLOMBIA INSIDER AVENTURE S.A.S. may, exceptionally, process personal data of minors (children and adolescents), within the framework of administrative actions, activities of interest, or at the request of a competent authority.

The processing will only be authorized if the following conditions are met:

a) The purpose of the processing serves the best interest of the child or adolescent;
b) The processing respects their fundamental rights;
c) The minor’s right to be heard is respected; their opinion will be considered based on their maturity, autonomy, and capacity for understanding;
d) The conditions provided by Law 1581 of 2012 for the processing of personal data are fulfilled.

14. PERSON OR SERVICE RESPONSIBLE FOR REQUESTS, INQUIRIES, AND CLAIMS

COLOMBIA INSIDER AVENTURE S.A.S. informs the Holders that the service in charge of handling requests, inquiries, and claims is the communication service, accessible via the channels mentioned in this policy, in compliance with the procedure described below.

15. INQUIRIES AND CLAIMS

15.1 Inquiries

The Holder or their successors may inquire about the personal data held by COLOMBIA INSIDER AVENTURE S.A.S.

The request must be made in writing, either by mail to the following address:
CRA 64 # 81 URB Posada Del Viento ap 334, Copacabana, Colombia
or by email to: support@tomplanmytrip.com

If the request is incomplete, the interested party will be invited, within five (5) days, to correct or complete the request. In the absence of a response within two (2) months, the request will be considered abandoned.

The request will be processed within a maximum of fifteen (15) business days from receipt. If this deadline cannot be met, the requester will be informed of the reasons for the delay and the new response date, which cannot exceed an additional five (5) business days.

15.2 Complaints

The Holder or their successors who believe that the information held needs to be corrected, updated, or deleted, or who believe that a breach of legal obligations has occurred, may file a complaint.

This complaint should be addressed to:
CRA 64 # 81 URB Posada Del Viento ap 334, Copacabana, Colombia
or to the email support@tomplanmytrip.com,
and must include:

Name and identification number of the Holder
Description of the facts motivating the complaint
Correspondence address
Email
Supporting documents

If the complaint is incomplete, a period of five (5) days is granted to complete the file. After a period of two (2) months without a response, the request will be considered abandoned.

Once the complaint is complete, a note “complaint in progress” and its reason will be added to the database within two (2) business days, until a final decision is made.

The processing time is fifteen (15) business days from receipt. In case of exceeding, a new maximum period of eight (8) business days may be granted, subject to informing the applicant.

16. COMPLAINTS BEFORE THE SUPERINTENDENCIA DE INDUSTRIA Y COMERCIO

Before being able to file a complaint with the Superintendencia de Industria y Comercio, the Holder or their successors must first exhaust the internal consultation or complaint procedure with COLOMBIA INSIDER AVENTURE S.A.S.

17. DATA COLLECTED BEFORE DECREE 1377 OF 2013

For the data collected before the enactment of decree 1377 of 2013 (repealed and integrated into the Unified Decree 1074 of 2015), COLOMBIA INSIDER AVENTURE S.A.S. makes available in its offices the information processing policies, also sent to each Holder via the registered email address.

If, within thirty (30) days after the sending of these policies, the Holder does not express their desire to correct, delete, or authorize the processing of their data, COLOMBIA INSIDER AVENTURE S.A.S. will continue to process the data in accordance with the purposes established in the Privacy Notice.

18. APPLICABLE NATIONAL LEGISLATION

This Policy is governed by the following provisions:

Law 1581 of 2012
Law 1266 of 2008
Unified Regulatory Decree 1074 of 2015
as well as by any other complementary, modifying, or repealing norm.

19. EFFECTIVE DATE

This Policy is effective as of July 1, 2024.