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The policies outlined below apply to the Processing of Personal Data controlled by Team Foods Colombia S.A. and \/or Grasas S.A. (hereinafter referred to as "the Companies"), regarding customer, supplier, employee and general third party Personal Data.<\/p>\n
Article 1 Applicable regulations:<\/strong> This Policy is governed by the considerations set forth under articles 15 and 20 of the Article 2. Scope of Application:<\/strong> This Policy shall apply to Personal Data managed by the Companies and which are Article 3. Purpose:<\/strong> The purpose of this Policy is to comply with the obligations stipulated under literal k) Article 17 of Article 4. Contact Information:<\/strong> Team Foods Colombia S.A. is domiciled at Calle 45a Sur No. 56 – 21, Bogota D.C.,Colombia and may be contacted at the aforementioned address or email notification@alianzateam.com<\/p>\n Article 5. Definition:<\/strong> For the purposes of this Processing of Personal Data Policy, it shall be defined as:Authorization: Prior, explicit and informed consent of the Holder of the Personal Data to execute the Database:<\/strong><\/em> Organized set of Personal Data subject to processing .<\/p>\n Personal Data:<\/strong><\/em> Any information that may be associated with one or more specific or determinable natural persons. Public Personal Data:<\/strong><\/em> Refers to Personal Data which is not Semi-Private, Private or Sensitive in nature. Private Personal Data:<\/em><\/strong> Refers to data, which due to its intimate or reserved nature, is only relevant to Holder of the Semi-private Personal Data:<\/em><\/strong> Personal Data which is not intimate, reserved, nor public in nature and which Sensitive Personal Data:<\/em><\/strong> Information which involves the privacy of the Holder or which improper use may produce Personal data processing policy<\/p>\n Responsible for the Processing :<\/em> <\/strong>Natural person or company, public or private, independently or in association with Claim:<\/em><\/strong> Request from the Holder of the Data or the persons duly authorized by the same or by Law, to correct, update Responsible for the Processing :<\/strong> <\/em>Natural Person or legally established company, public or private, that individually or Holder:<\/em> <\/strong>Natural person whose Personal Data is subject to Processing . Diffusion:<\/em> <\/strong>Processing of Personal Data which implies communication of the same in the Republic of Colombia or Processing :<\/strong> <\/em>Any Personal Data operation or set of operations such as collection, storage, use, circulation or deletion.<\/p>\n Article 6. Principles applicable to the Processing of Personal Data:<\/strong> For the Processing of Personal Data, the Processing of Personal Data:<\/strong><\/em><\/p>\n Legality:<\/strong> <\/em>The Processing of Personal Data must be performed in accordance with the applicable legal provisions Purpose:<\/em> <\/strong>The Personal Data collected must be used for a specific and explicit purpose which must be informed to the Holder or as set forth under Law. The Holder must be informed clearly, sufficiently and in advance about the purpose of the information provided.<\/p>\n Voluntary authorization:<\/strong> <\/em>The collection of Personal Data may only be exercised with prior, explicit and informed Veracity or Quality:<\/strong><\/em> The information subject to the Processing of Personal Data must be truthful, comprehensive, Transparency:<\/strong><\/em> Within the Processing of Personal Data, the Holder\u00b4s right to obtain, at any time and without Access and restricted circulation:<\/strong><\/em> The Processing of Personal Data shall only be performed by the persons authorized Confidentiality:<\/em><\/strong> All employees that work in the Companies are obliged to keep Personal Data confidential, even after Article 7. Authorization:<\/strong> The Processing of Personal Data by the Companies requires voluntary, prior, explicit and Article 8. Form and mechanisms for granting Authorization:<\/strong> The Authorization may appear in any manner which guarantees its consequent consultation, specifically: i) in writing, ii) orally, or iii) by means of absolute authorization of the Holder which leads to reasonably conclusion that the Authorization was granted. In no case may silence be Article 9. Proof of Authorization:<\/strong> The Companies shall keep necessary records or mechanisms in order to establish Article 10. Rights of the Holders:<\/strong> In accordance with the provisions of article 8 of Law 1581 of 2012, the Holder of a. Know, update and rectify Personal Data before those responsible for the processing or corresponding Processing Regarding the Personal Data of our Clients and Suppliers: 10. Register the holders in the different systems of the Companies; Article 14.<\/strong> The division responsible for access request, rectification, updating, data deletion or revocation of consent or Authorization granted for the Processing of Personal Data to any of the Companies, is the Legal and Corporate Affairs Vice Presidency, located at Calle 45a Sur No. 56 – 21, Bogota DC, Colombia, email Notifications@alianzateam.com 18. Operate as bridge and coordinate the implementation of the Comprehensive Personal Data Management Article 15.<\/strong> Access Rights. The Holders of Personal Data processed by the Companies have the right to access their Personal Data and the details of said Processing, as well as to rectify and update the same if they are inaccurate or to \uf0b7 The request for rectification, updating, deletion or revocation must be submitted by means of the Article 17.<\/strong> Personal Data stored by the Companies shall be kept as long as required according to the purpose of the Article 18.<\/strong> Upon performing the corresponding commercial activity, the Companies process Sensitive Personal Data Article 19.<\/strong> In accordance with article 26 of Law 1581 of 2012, the Transfer of Personal Data of any kind to countries that do not provide adequate levels of data protection is prohibited. A country that offers an adequate level of data protection is considered when the standards set by the Superintendence of Industry and Commerce have been met. Article 20.<\/strong> When the Companies send or transmit data to one or more Managers located within or outside the Article 21<\/strong> The Companies shall be responsible for the protection of Personal Data, shall process the requests of the [vc_row css_animation=\u00bb\u00bb row_type=\u00bbrow\u00bb use_row_as_full_screen_section=\u00bbno\u00bb type=\u00bbfull_width\u00bb angled_section=\u00bbno\u00bb text_align=\u00bbleft\u00bb background_image_as_pattern=\u00bbwithout_pattern\u00bb][vc_column][rev_slider slidertitle=\u00bbPersonal data processing policy\u00bb alias=\u00bbtratamiento-de-datos-1″][\/vc_column][\/vc_row][vc_row css_animation=\u00bb\u00bb row_type=\u00bbrow\u00bb use_row_as_full_screen_section=\u00bbno\u00bb type=\u00bbgrid\u00bb angled_section=\u00bbno\u00bb text_align=\u00bbleft\u00bb background_image_as_pattern=\u00bbwithout_pattern\u00bb z_index=\u00bb\u00bb][vc_column css=\u00bb.vc_custom_1587406730089{padding-right: 100px !important;padding-left: 100px !important;}\u00bb][vc_column_text] The policies outlined below apply to the Processing of Personal Data controlled by Team Foods Colombia S.A….<\/p>","protected":false},"author":21,"featured_media":0,"parent":1467,"menu_order":0,"comment_status":"closed","ping_status":"closed","template":"full_width.php","meta":{"rank_math_lock_modified_date":false,"footnotes":""},"class_list":["post-1515","page","type-page","status-publish","hentry"],"_links":{"self":[{"href":"https:\/\/www.albora.co\/en\/wp-json\/wp\/v2\/pages\/1515","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/www.albora.co\/en\/wp-json\/wp\/v2\/pages"}],"about":[{"href":"https:\/\/www.albora.co\/en\/wp-json\/wp\/v2\/types\/page"}],"author":[{"embeddable":true,"href":"https:\/\/www.albora.co\/en\/wp-json\/wp\/v2\/users\/21"}],"replies":[{"embeddable":true,"href":"https:\/\/www.albora.co\/en\/wp-json\/wp\/v2\/comments?post=1515"}],"version-history":[{"count":6,"href":"https:\/\/www.albora.co\/en\/wp-json\/wp\/v2\/pages\/1515\/revisions"}],"predecessor-version":[{"id":1661,"href":"https:\/\/www.albora.co\/en\/wp-json\/wp\/v2\/pages\/1515\/revisions\/1661"}],"up":[{"embeddable":true,"href":"https:\/\/www.albora.co\/en\/wp-json\/wp\/v2\/pages\/1467"}],"wp:attachment":[{"href":"https:\/\/www.albora.co\/en\/wp-json\/wp\/v2\/media?parent=1515"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}
\nPolitical Constitution of Colombia, Law 1581 of 2012 "By which the general provisions for personal data protection are outlined", and SECTION 25 of Decree 1074 of 2015 \u201cBy which Law 1581 of 2012 is partially regulated\u201d.<\/p>\n
\nsubject to Data Processing.<\/p>\n
\nLaw 1581, 2012, as well as regulating the procedures for collection, handling and processing of Personal Data
\ncollected by the the Companies.<\/p>\n
\nProcessing of Personal Data.<\/p>\n
\nSome examples of Personal Data are as follows: name, citizenship ID details, address, email, telephone number,
\nmarital status, health related data, fingerprint, salary, assets, among others.<\/p>\n
\nPublic data, among others, is data concerning people's marital status, their profession or trade and their
\ncommercial\/trading status or public employee.<\/p>\n
\nsame.<\/p>\n
\ninformation or disclosure may be of interest not only to its Holder but also to a certain segment or group of people
\nor to society in general, for example, the compliance and non-compliance with financial obligations or data
\nconcerning affiliations with the social security system.<\/p>\n
\ndiscrimination, such as racial or ethnic origin, political orientation, religious or philosophical convictions, membership of unions, social organizations, human rights or the promoting interests of any political party or which guarantees the rights and opposition of political parties as well as data related to health, sexual life and biometric data, among others; capture of images or images in movement, fingerprints, photographs, iris, voice, facial or palm recognition,
\namong others.<\/p>\n
\nothers, perform the Processing of Personal Data on behalf of the Responsible Party .<\/p>\n
\nor delete their Personal Data or to revoke the authorization as set forth under Law.<\/p>\n
\nin association with others, make decisions in terms of database and \/ or the Processing of data.<\/p>\n
\nTransfer: The Transfer of Personal Data takes place when the Responsible and \/ or Person in Charge of the Processing
\nof Personal Data, located in Colombia, sends the information or Personal Data to a recipient, who in turn is Responsible for the Processing located in Colombia or abroad.<\/p>\n
\nabroad, when the purpose is to perform personal data processing by the Manager on behalf of the Responsible
\nparty.<\/p>\n
\nCompanies shall apply the principles outlined below, which establish the instructions to be followed within the<\/p>\n
\n(Statutory Law 1581 of 2012 and its regulatory decrees).<\/p>\n
\nauthorization of the Holder.<\/p>\n
\nexact, updated, verifiable and understandable.<\/p>\n
\nrestrictions, information about the existence of data concerning him\/her must be guaranteed.<\/p>\n
\nby the Holder and \/ or as set forth under Law.
\nSafety:<\/strong> <\/em>The Personal Data subject to Processing must be handled in accordance with all necessary safety standards in order to prevent loss, adulteration, consultation, use or unauthorized or fraudulent access.<\/p>\n
\ntheir employment or contractual relationship has ended.<\/p>\nSECTION II.- AUTHORIZATION<\/h3>\n
\ninformed consent of the Holder.<\/p>\n
\ninterpreted as absolute authorization.<\/p>\n
\nwhen and how the authorization was obtained from the Personal Data Holders for the processing thereof.<\/p>\nSECTION III.- RIGHTS AND OBLIGATIONS<\/h3>\n
\nPersonal Data has the right to:<\/p>\n
\nManagers. This right may be exercised, among others, against partial, inaccurate, incomplete, fractioned, misleading
\ndata, or when processing is explicitly prohibited or has not been authorized;
\nb. Request proof of authorization granted to the Responsible Processing Officer, except when explicitly excepted as a
\nrequirement for the Processing, in accordance with the provisions of article 10 of Law 1581 of 2012;
\nc. Be informed by the Processing Manager, upon request, regarding the use that has been given of Personal Data;
\nd. Submit complaints due to violations of the provisions of Law 1581 of 2012 and other regulations which may have
\nmodified, added or complemented the same, before the Superintendence of Industry and Commerce.
\ne. Revoke the Authorization and \/ or request deletion of data when during the Processing, the principles, rights and
\nconstitutional and legal guarantees have not been not met. The revocation and \/ or deletion shall proceed when the
\nSuperintendence of Industry and Commerce has established that during the processing, the responsible party or
\nPerson in Charge have engaged in actions that violate Law 1581 of 2012 and \/ or the Constitution of Colombia;
\nF. Unrestricted free of charge access to Personal Data subject to processing .
\nArticle 11. Obligations of the Companies: The Companies recognize that the Personal Data is property of the people to
\nwhom they refer and that only they can decide in regards to the same. Therefore, the Companies shall use the
\nPersonal Data collected only for the purposes for which they are duly empowered to do so and recognizing, in any
\ncase, the current regulations on the Protection of Personal Data.
\nIn accordance with the provisions of article 17 of Law 1581 of 2012, the Companies are obliged to comply with the
\nfollowing obligations :
\na. Guarantee the Holder full and effective exercise of the right to habeas data at all times.
\nb. Request and keep, as set forth under Law 1581 of 2012, a copy of the corresponding authorization
\ngranted by the Holder;
\nc. Duly inform the Holder about the purpose of the collection and his\/her rights by virtue of the authorization granted;
\nd. Keep Personal Data under required safety standards in order to prevent adulteration,
\nloss, consultation, use or unauthorized or fraudulent access;
\ne. Guarantee that the information provided to the Processing Manager is truthful, comprehensive, accurate, updated,
\nverifiable and understandable;
\nF. Update the information, informing the Person in Charge of Processing in a timely manner, of all updates regarding
\npreviously provided data and implement other necessary measures so that the information provided is kept updated;
\ng. Rectify the information when it is incorrect and inform any pertinent issues to the Processing Manager;
\nh. Provide the Processing Manager, as corresponds, only data which Processing is previously authorized in
\naccordance with the provisions of Law 1581 of 2012;
\ni. Require the Processing Manager to respect safety and privacy conditions of the Holder's information at all times.
\nj. Process inquiries and claims formulated in the terms indicated under Law 1581 of 2012;
\nk. Inform the Processing Manager when certain information is under discussion with the Holder, once the claim has
\nbeen submitted and the corresponding procedure has not been completed;
\nl. Inform, at the request of the Holder, about the use given of their data;
\nm. Inform the data protection authority in the event of safety and code violations, and
\nin case of risks in the administration of the holders\u00b4 information.
\nn. Comply with the instructions and requirements issued by the Superintendence of Industry and Commerce.
\nSECTION IV- PRIVACY NOTICE
\nArticle 12. The privacy notice is a physical or electronic document, or in any other format made known to the Holder,
\nbefore or at the time of collection of their Personal Data, and is the means by which information is informed in
\nregards to Information Processing Policies which shall be applicable, the ways to access them and, in general, the
\npurposes for which Personal Data has been obtained and the processing that the Companies proceed.
\nSECTION V- PURPOSES OF THE PROCESSING
\nArticle 13. Information processing. The Personal Data managed by the Companies shall be collected, used, stored,
\nupdated, transmitted and \/ or transferred, for the following purpose or purposes:<\/p>\n
\n1. To provide required services and products;
\n2. Inform about changes, modifications or new products or services related or not with the products or services
\ncontracted or acquired by the Holder by any means of communication;
\n3. Comply with obligations contracted with the Holder;
\n4. Evaluate the quality of the product and service, perform market studies and statistical analysis for internal uses
\nand participation of the Holders in marketing and promotional activities.
\n5. Provide design and implementation of customer loyalty programs;
\n6. Share Personal Data, including the Transfer and Transmission of Personal Data to third parties for purposes related
\nto the operation of the Companies;
\n7. Perform internal studies in regards to the fulfillment of commercial relations and market studies at any level;
\n8. Perform internal or external audit processes typical of the commercial activity that the Companies carry out;
\n9. Allow companies associated to the Companies, with which it has entered into contracts including provisions to
\nguarantee the safety and proper Processing of the Personal Data processed, to contact the Holder with the purpose
\nof offering goods or services of interest;
\n10. Control access to the offices and plants of the Companies, including the establishment of video-monitored areas;
\n11. Respond queries, requests, complaints and claims made by the Holders and control bodies and process the
\nPersonal Data to other authorities that by virtue of law must receive Personal Data;
\n12. Use the different services corresponding to websites, including content and format downloads;
\n13. Transfer information collected to different areas of the Companies and associated companies in Colombia and
\nabroad when necessary for operational development and payroll management (collection of portfolio and
\nadministrative charges, treasury, accounting, among others );
\n14. Register the Holders in the Companies\u00b4 systems and process their payments or collections;
\n15. Any other similar and \/ or complementary activity in nature, to those previously outlined, necessary for the
\ndevelopment of the corporate purpose of the Companies.
\nRegarding the Personal Data of our candidates:
\n1. Manage and operate, directly or by means of third parties, the personnel selection and hiring processes, including
\nthe evaluation and qualification of participants and verification of work based and personal references, and the
\nperformance of safety related studies;
\n2. Any other similar and \/ or complementary activity in nature to those previously outlined and necessary for the
\ndevelopment of the corporate purpose of the Companies.
\nRegarding the Personal Data of our staff:
\n1. Develop activities of human resource management within the Companies, such as payroll, affiliations to the
\ngeneral social safety system, occupational health and welfare activities, exercise employer's sanctioning power,
\namong others;
\n2. Make necessary payments resulting from the employment contract execution and\/or its termination, and any
\nother social benefits applicable in accordance with law;
\n3. Contract employment benefits with third parties, such as life insurance, medical expenses, among others;
\n4. Notify authorized contacts in case of emergencies during working hours or during the
\ndevelopment of the same;
\n5. Coordinate professional development of employees, employee access to computer resources of the Companies
\nand assist in their use;
\n6. Plan business activities;
\n7. Transfer information collected to different areas of the Companies and associated companies in Colombia and
\nabroad when necessary for the development of the operations and payroll management (collection of portfolio and
\nadministrative collections, treasury, accounting, among others );
\n8. Control offices and plant access of the Companies, including the set up of video-monitored areas;
\n9. Manage training;<\/p>\n
\n11. Any other similar and \/ or complementary activities nature to those outlined herein, necessary for the
\ndevelopment of the corporate purpose of the Companies.<\/p>\nSECTION VI- PERSON AND AREA RESPONSIBLE FOR REQUESTS, COMPLAINTS OR CLAIMS OF HOLDERS OF<\/h3>\n
INFORMATION.<\/h3>\n
\nThe Personal Data Protection Officer\u00b4s main functions is to ensure effective implementation of policies and procedures accepted by the Companies in order to comply with the Colombian System for the Protection of Personal
\nData, and to take charge of the structuring, design and administration of the Comprehensive Personal Data Management program.
\nThe Company's Personal Data Protection Officer shall:
\n1. Manage the appropriate procedure of any claim submitted by the Holders in accordance with the provisions of this
\nPolicy.
\n2. Verify that the information received by the Holder is sufficient in order to provide a response;
\n3. Evaluate the need to extend the term for responding Claims;
\n4. Allocated the claim within the Companies as appropriate;
\n5. Assign responses to claims;
\n6. Send responses to the Holders in accordance with the terms established under Law, in this Policy and in the
\nPolicies and Procedures Guidelines of the Companies;
\n7. Order warning inclusion in the databases against claims or those under judicial evaluation;
\n8. Ensure compliance with this Policy;
\n9. Provide support to the divisions of IT, Structure and Design and administer the Comprehensive Data Management
\nProgram staff in line with the indications approved for this purpose by the Board of Directors and the Company Presidency;
\n10. Keep the Presidency informed of the progress status of the implementation of the Comprehensive Personal Data
\nManagement Program, by means of semi-annual reports outlining detailed activities, outstanding activities,
\nexecution timeframe and resources required for said purpose;
\n11. Prepare annual reports on the implementation and operational processes of the Comprehensive Personal Data
\nProgram Management before the General Assembly of Shareholders .
\n12. Implement a training program of protection of Personal Data within the Companies and ensure permanent training activities for the staff;
\n13. As part of his\/her duties, the Company's Personal Data Protection Officer shall supervise the training of new staff members in appropriate Processing of Personal Data and, especially, the obligations to be complied with in his\/her job position;
\n14. Audit the compliance of the different areas of the Companies regarding adequate compliance with the
\nColombian System for the Protection of Personal Data, this Policy and those resulting from the implementation of the Comprehensive Personal Data Management Program;
\n15. Develop required control in order to guarantee the implementation and effectiveness of the Comprehensive
\nPersonal Data Management Program together with the support of the Technology Area, and strict compliance
\nof the Companies\u00b4 terms and obligations under the Colombian System of Protection of Personal Data;
\n16. Coordinate and encourage definition and implementation of the risk management system
\nassociated with the Processing of Personal Data;
\n17. Coordinate and promote the definition and implementation of the Comprehensive Data Management Program
\nthat controls the staff.<\/p>\n
\nProgram with the areas of the Companies.
\n19. Maintain the inventory of Companies' Personal Databases permanently updated. Finally, perform semi-annual
\naudits directly or with the support of the internal audit area.
\n20. Validate the formation of Personal Databases and register it in the National Registry of Databases
\nof the Superintendence of Industry and Commerce;
\n21. Update the information of the National Registry of Databases whenever required in compliance with the
\napplicable law; including the management of safety and incidents reports before the Superintendence of Industry
\nand Commerce;
\n22. Manage contracts for the international transfer of Personal Data or manage compliance declarations, as
\nrequired, in accordance with the National Registry of Databases;
\n23. Respond inquiries submitted within the organization regarding the Comprehensive Management Program
\nof Databases and the Colombian System for Protection of Personal Data;
\n24. Confirm the responsibilities of each of \u200b\u200bthe Companies\u2019 divisions in regards to Data Processing
\nPersonnel under his\/her responsibility, and establish due compliance indicators for frequent compliance verification;
\n25. Attend visits of the Superintendence of Industry and Commerce concerning the supervision of the
\nColombian System for the Protection of Personal Data within the organization.<\/p>\nSECTION VII ACCESS, CONSULTATION AND CLAIM PROCEDURES<\/h3>\n
\nrequest elimination when considered that they are disproportionate or unnecessary for its purposes or contrasting to the specific purpose processing.
\nSubmission of requests and for the purpose of guaranteeing the herein referred to rights, enquires should be addressed to:
\n\u2022 Physical mail:
\nTeam Foods Colombia S.A. Calle 45a Sur No. 56 – 21, Bogot\u00e1 D.C.
\nGrasas S.A. Calle 45a Sur No. 56 – 21, Bogot\u00e1 D.C.
\nBy email:
\nTeam Foods Colombia S.A. notifications@alianzateam.com
\nGrasas S.A. notifications@alianzateam.com
\nThese channels may be used by Personal Data Holders, or third parties to act on their behalf as authorized by law, in
\norder to exercise the following rights:
\na.Queries: The Holder may access his\/her Personal Data free of charge. Thus, the holder may submit a request
\nindicating the information required by means of any of the mechanisms indicated above. The request shall be
\nanswered by the Companies within a maximum term of ten (10) business days as of the date of receipt. When it is
\nnot possible to answer the request within said term, this circumstance shall be reported to the applicant, stating the
\nreasons for the delay and indicating the date on which their query shall be answered, which in no case may exceed
\nfive (5) business days following the expiration of the first term.
\nb. Claims: In accordance with the provisions of Article 14 of Law 1581 of 2012, when the Holder or his\/her duly
\nauthorized third party considers that the information processed by the Companies should be subject to correction,
\nupdate or deletion, or when it should be revoked due to presumed violations of any legal obligations, they may
\nsubmit a request to the Companies, which shall be processed under the following set of rules:
\n\uf0b7 The Holder or or his\/her duly authorized third party must provide evidence of identity, authorization,
\nrepresentation or provision in favor of another or for another third party. When the request is performed by
\na third party and it is not proven that he\/she acts on his\/her behalf, the request shall not be processed.<\/p>\n
\ninstruments enabled by the Companies and outlined in this document and enclose, at least, the following
\ninformation:
\ni. The name and address of the Holder or any other methods for receiving response.
\nii. Documents showing the identity of the applicant and, if applicable of his\/her duly authorized
\nrepresentative including the corresponding authorization.
\niii. Clear and precise description of the Holder\u2019s Personal Data to which he\/she pursues to exercise the
\nrights and the specific request.
\nThe maximum term to meet this request shall be fifteen (15) business days as of the day following the date of
\nreceipt.
\nWhen it is not possible to answer the request within said term, this circumstance shall be reported to the applicant,
\nstating the reasons for the delay and indicating the date on which their query shall be answered, which in no case
\nmay exceed five (8) business days following the expiration of the first term.
\nIf the claim is incomplete, the interested party shall, within five (5) days after receiving it, correct the corresponding
\nerrors. If after two (2) months as of the date of the request, without the applicant submitting the required
\ninformation, the claim shall be interpreted as a withdrawn claim. Once a complete claim has been received, a
\nreference indicating "claim in process" and due reason shall be included in the Database, within a term not
\nexceeding two (2) business days. Said reference must be preserved until the claim is decided upon.
\nFirst Paragraph. Rectification and update: When the claims are intended for rectification or update, the Holder must
\nindicate the corresponding corrections and submit documentation that supports their request.
\nSecond paragraph. Deletion: The deletion of Personal Data is performed by means of total or partial elimination of
\npersonal information as requested by the Holder, notwithstanding, the Companies may deny such request when the
\nHolder has a legal or contractual duty to remain in the Database.
\nArticle 16. Revocation of Authorization. Holders of personal data may revoke the Authorization previously granted at
\nany time, except in those events in which a legal or contractual provision impedes such action. In any case, the
\nHolder must indicate in his\/her corresponding request if it is a full or partial revocation, the latter, when he\/she
\nrequests to eliminate only some of the authorized data, the Holder must clearly indicate which data to be delete.<\/p>\nSECTION VIII- DATABASES VALIDITY PERIOD<\/h3>\n
\nProcessing and \/ or for the term required in order to comply with a legal or contractual obligation. The Companies
\nhave adopted measures for timely and safe elimination of their Personal Data, outlined in the Policies and Procedure Guidelines.<\/p>\nSECTION IX – PROCESSING OF SENSITIVE PERSONAL DATA<\/h3>\n
\nfor specific purposes. The Companies shall only perform the Processing of sensitive Personal Data as long as it has
\nbeen previously authorized by the corresponding Holder and shall handle them under safety and confidentiality
\nstandards in accordance with their nature.
\nIn accordance with the above, the Companies have implemented administrative, technical and legal procedures as
\nduly outlined in the Policies and Procedures Guidelines, which are mandatory for The Companies\u2019 employees and, as
\napplicable, their suppliers, associated companies and \/ or commercial allies.
\nHowever, it shall be notified that the collection of Sensitive Personal Data is not meant as a condition for accessing
\nany of our products or services.<\/p>\nSECTION X- TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES<\/h3>\n
\nThey may, however, never be less than those required by law 1581 of 2012.
\nThis prohibition shall not apply when it refers to:
\n1. Information for which the Holder has granted his\/her explicit and unequivocal authorization for the Transfer;
\n2. Exchange of medical data, when required by the Holder's Processing for health matter reasons or public hygiene;
\n3. Bank or stock transfers, in accordance with the legislation applicable;
\n4. Transfers agreed within the framework of international treaties in which the Republic of Colombia is
\nincluded, based on the principle of reciprocity;
\n5. Transfers required for contractual execution between the Holder and the Data Controller, or for the execution of
\npre-contractual measures as long as the Holder's Authorization is available;
\n6. Transfers legally required in order to safeguard public interest, or for the recognition, exercise
\nor defense of a right within a judicial process.<\/p>\nSECTION XI- INTERNATIONAL AND NATIONAL TRANSMISSIONS OF DATA TO MANAGERS<\/h3>\n
\nterritory of the Republic of Colombia, they must establish contractual clauses or enter into a Personal Data
\nTransmission contract in which, among others, as outlined below:
\n1. The capacity and purposes of the processing .
\n2. The activities that the Person in Charge shall perform on behalf of the Companies.
\n3. The obligations that the Manager must fulfill in regards to the Holder of the Companies\u00b4 data.
\n4. The duty of the person in charge of processing the data in accordance with the authorized purpose for the same
\nand in view of the principles of the Colombian Law and this Policy.
\n5. The obligation of the Person in Charge in order to adequately protect the Personal Data and the Databases as well
\nas keeping confidentiality regarding the Processing of the transmitted data.
\n6. A description of the specific safety measures to be adopted by both the Companies and
\nby the final user Data Controller.
\nThe Companies shall not request Authorization when international transmission of data is protected by any of the
\nexceptions provided within the Law and corresponding Regulatory Decrees.<\/p>\nSECTION XII- FINAL PROVISIONS<\/h3>\n
\nHolders, and shall guarantee the exercise of the corresponding rights.
\nArticle 22.<\/strong> Safety measures: Upon exercising the safety principles established under Law 1581 of 2012, the
\nCompanies shall undertake the necessary technical, human and administrative measures in order to guarantee the
\nsafety of the Personal Data subject to Processing, thus avoiding its adulteration, loss, consultation, use or
\nunauthorized or fraudulent access.
\nArticle 23.<\/strong> Validity: This Policy is effective as of June 1, 2017.[\/vc_column_text][vc_empty_space height=\u00bb45px\u00bb][\/vc_column][\/vc_row][vc_row css_animation=\u00bb\u00bb row_type=\u00bbrow\u00bb use_row_as_full_screen_section=\u00bbno\u00bb type=\u00bbfull_width\u00bb angled_section=\u00bbno\u00bb text_align=\u00bbleft\u00bb background_image_as_pattern=\u00bbwithout_pattern\u00bb][vc_column][vc_column_text][sc name=\u00bbfooter-en\u00bb][\/vc_column_text][\/vc_column][\/vc_row]<\/p>","protected":false},"excerpt":{"rendered":"