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Data policy

General description

This protection policy establishes the conditions of security and confidentiality, the terms, conditions and purposes under which AYUDA TECNICA Y DE SERVICIOS S.A. collects, stores, uses, circulates, suppresses and treats the data of its customers, suppliers, contractors, employees and former employees, among others, and establishes the instituted procedures so that the holders of the data can exercise the rights established under the laws of protection of personal data.

Definitions

a) Authorization: Prior, express and informed consent of the Holder to carry out the processing of personal data;
b) Privacy Notice: Verbal or written communication generated by the Responsible party, addressed to the Holder of the Personal Data, by means of which they are informed about the existence of the Information Treatment Policies that will be applicable to them, the way to access them and the purposes of the treatment that is intended for the personal data.
c) Database: The organized set of personal data that is subject to Treatment;
d) Personal data: Any information linked to or associated with one or several natural persons determined or determinable;
e) Party in charge of the Treatment: The natural or juridical person, public or private, that by itself or in association with others, performs the processing of personal data on behalf of the party Responsible for the Treatment;
f) Habeas Data: The fundamental right of every person to know, update, rectify and/or cancel the information and personal data that has been gathered and/or processed from it, in public or private databases, as provided in the law and other applicable regulations
g) Claim: Request of the data from the subject or the persons authorized by it or by the Law to correct, update or delete their personal data or to revoke the authorization in the cases established in the Law.
h) Responsible for the Treatment: The natural or juridical, public or private person, that by itself or in association with others, decides on the database and/or on the treatment of the data;
i) Owner: Natural person whose personal data is subject to Treatment;
j) Treatment: Any operation or set of operations on personal data, such as collection, storage, use, circulation or deletion.

 

Principles

Subject to Article 4 of Law 1581 of 2012, the following principles shall apply to this policy:

 a) Principle of legality in the matter of data processing: The Treatment referred to in this law is a regulated activity that must be subject to what is established in it and in the other provisions that may develop it.
b) Principle of purpose: The Treatment must obey a legitimate purpose in accordance with the Constitution and the Law, which must be informed to the Holder;
c) Principle of freedom: The Treatment can only be exercised with the prior, express and informed consent of the Holder. Personal data may not be obtained or disclosed without prior authorization, or in the absence of a legal or judicial mandate that relieves the consent;
d) Principle of truth or quality: The information subject to Treatment must be truthful, complete, accurate, updated, verifiable and understandable. The processing of partial, incomplete, fractioned or misleading data is prohibited;
e) Principle of transparency: During the Treatment, the Right of the Holder to obtain from the Person in Charge of the Treatment, at any time and without restrictions, the information about the existence of data that concerns him must be guaranteed;
f) Principle of access and restricted circulation: The Treatment is subject to the limits that derive from the nature of the personal data, the provisions of this law and the Constitution. In this sense, the Treatment can only be done by persons authorized by the Holder and/or by the persons provided for in this law;

Personal data, except public information, may not be available on the Internet or other means of dissemination or mass communication, unless the access is technically controllable to provide restricted knowledge only to the Holders or to authorized third parties in accordance with this law;


g) Principle of security:
The information subject to Treatment by the Person Responsible for the Treatment or in charge of the Treatment referred to in this law, shall be handled with the technical, human and administrative measures that are necessary to grant security to the records avoiding their adulteration, loss, consultation, unauthorized or fraudulent use or access;
h) Principle of confidentiality: All persons involved in the processing of personal data which do not have the nature of public are required to guarantee the reservation of that information, even after the end of their relationship with any of the tasks involved in the treatment, being able to only supply or communicate personal data, when this corresponds to the development of the activities authorized in this law and in the terms thereof.

 

Data collection

AYUDA TECNICA Y DE SERVICIOS S.A. Requires the collection of the following information from its customers, suppliers, contractors, employees and former employees, among others: name and surname, correspondence address, email address, telephone number, identification document number, post, references. The owner of the data expressly accepts that AYUDA TECNICA Y DE SERVICIOS S.A. could use, obtain, compile, exchange, update, collect, process, reproduce and/or dispose of your personal data or information, partially or totally, for the purposes expressed in this Privacy Policy.

AYUDA TECNICA Y DE SERVICIOS S.A. through the different channels of contact with its customers, suppliers, contractors, employees and former employees, among others, such as administrative office and/or web page, could collect personal data such as your full name, telephone number and email address, that allows it to subsequently contact you, information regarding which the customer, supplier, contractor, employee and former employee, among others, as the owner of the data provided, expressly authorizes AYUDA TECNICA Y DE SERVICIOS S.A. to use it according to the purpose here informed

AYUDA TECNICA Y DE SERVICIOS S.A. could collect the information of its customers, suppliers, contractors, employees and former employees, among others, through third parties such as business partners, subcontractors and/or financial entities, for the purposes expressed in this Privacy Policy.

The owner of the data expressly authorizes AYUDA TECNICA Y DE SERVICIOS S.A. to collect the data in the terms expressed, as well as to consult, complement and update the said personal data at any time, with other databases managed by an information operator, in order to keep updated the information of its customers, suppliers, contractors, employees and former employees, among others.

 

Purposes of Customer Data Processing

The personal information of the customers, suppliers, contractors, employees and former employees, among others, will be collected, stored, used, circulated, shared, and/or processed in order to:

– Identify its customers, suppliers, contractors, employees and former employees, among others, AYUDA TECNICA Y DE SERVICIOS S.A. could collect the information from them for the execution of the contract for the provision of services.

– Maintain physical or electronic communication with its customers, suppliers, contractors, employees and former employees, among others, including the sending of information related to the contract for the provision of services. As well as the sending of information about other services, products or goods acquired by AYUDA TECNICA Y DE SERVICIOS S.A.

– Achieve the purpose of the contracts held with its customers, suppliers, contractors, employees and former employees, among others, so that they can use the services and/or goods acquired to AYUDA TECNICA Y DE SERVICIOS S.A.

– Subcontract third parties to process the information of their customers, suppliers, contractors, employees and former employees, among others, and/or to perform any other activity required by AYUDA TECNICA Y DE SERVICIOS S.A. in relation to the contract for the provision of services.

– Other purposes established in the Terms and Conditions of this Privacy Policy.

– For other purposes, such as statistical and market analysis; development and improvement of services and products of AYUDA TECNICA Y DE SERVICIOS S.A., commercial and promotional initiatives; data updating; identification and prevention of fraud, money laundering and other criminal activities; carry out regulatory controls and for market research purposes.

The customers, suppliers, contractors, employees and former employees, among others, authorize AYUDA TECNICA Y DE SERVICIOS S.A. to use, obtain, compile, exchange, update, collect, process, reproduce and/or dispose of their personal data or information, partially or totally, as well as to transfer this data or partial or total information to third parties.

AYUDA TECNICA Y DE SERVICIOS S.A. could contract with third parties the processing of information of its customers, suppliers, contractors, employees and former employees, among others, and/or to perform any other activity in relation to use, obtain, compile, exchange, update, collect, process, reproduce and/or dispose of the data or information of customers, suppliers, contractors, employees and former employees, among others, of AYUDA TECNICA Y DE SERVICIOS S.A.

Likewise, the customers, suppliers, contractors, employees and former employees, among others, authorize AYUDA TECNICA Y DE SERVICIOS S.A. to share their data with companies with which they have commercial agreements, such as banking entities, among others, for the purposes above and these third parties will be obliged to comply with all the regulations and privacy policies of AYUDA TECNICA Y DE SERVICIOS S.A.

Likewise, with the acceptance of this Privacy Policy, the customers, suppliers, contractors, employees and former employees, among others, declare that they know that AYUDA TECNICA Y DE SERVICIOS S.A. can provide this information to the judicial or administrative entities and government entities that exercise control functions over their operation when there is a legal requirement to do so. He also accepts that he could be subject to internal or external audit processes by companies in charge of this type of control.

 

Rights of the holders of the data  

The natural persons whose Personal Data are subject to Treatment by AYUDA TECNICA Y DE SERVICIOS S.A., have the following rights, in accordance with article 18 of law 1581 of 2012, which they may exercise at any time. The same rights of the holders may be exercised by their successors in title, who prove such quality, by the representative or agent of the owner, who proves their quality, and by stipulation in favor of another or for another.

a) Right of access: Access free of charge to the personal data that has been subject to Treatment; obtain all the information regarding your own personal data, whether partial or complete, of the treatment applied to them, of the purpose of the treatment, the location of the databases that contain your personal data, and of the communications and/or cessions made with respect to them.
b) Right to update and rectify: the Holder may request at any time, that their data be updated, in case of any variation or rectified, in case of finding that their data are partial, inaccurate, incomplete, fractioned, misleading, or those whose Treatment is expressly prohibited or has not been authorized
c) Right to cancel: cancel personal data or delete them when they are excessive, not relevant or the treatment is contrary to the rules, except in those cases contemplated as exceptions by law or contractually agreed otherwise.
d) Right to revoke consent: Revoke the authorization and/or request the deletion of the data when, during the Treatment, the principles, rights and constitutional and legal guarantees are not respected.
e) Right to submit complaints, petitions and claims: Submit complaints about the improper treatment of your personal information before the Superintendence of Industry and Commerce – Delegation for the Protection of Personal Data.

 

Duties of those responsible for the processing of personal data.

Those responsible for the handling and processing of personal data must comply with the following duties, without prejudice to the other provisions set forth in law 1581 of 2012 and others that govern their activity:

a) Guarantee the Holder, at all times, the full and effective exercise of the right of habeas data;
b) Request and keep, under the conditions set forth in this law, a copy of the respective authorization granted by the Holder;
c) Properly inform the Holder about the purpose of the collection and the rights that assist him by virtue of the authorization granted;
d) Keep the information under the security conditions necessary to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access;
e) Guarantee that the information provided to the Treatment Manager is truthful, complete, accurate, updated, verifiable and understandable;
f) Update the information, communicating in a timely manner to the Treatment Manager, all the news regarding the data previously provided and adopt the other necessary measures so that the information provided to it is kept up to date;
g) Rectify the information when it is incorrect and communicate the pertinent information to the Treatment Manager;
h) Provide the Data Processor, as the case may be, only the data whose processing is previously authorized in accordance with the provisions of this law;
i) To demand from the Person in charge of the Treatment at all times, respect for the security and privacy conditions of the Holder’s information;
j) Process inquiries and claims formulated in the terms indicated in this law;
k) Adopt an internal manual of policies and procedures to ensure adequate compliance with this law and, in particular, to attend to inquiries and complaints;
l) Inform the Person in Charge of the Treatment when certain information is under discussion by the Holder, once the claim has been filed and the respective procedure has not been completed;
m) Inform at the request of the Owner about the use given to its data;
n) Inform the data protection authority when there are violations of the security codes and there are risks in the administration of the information of the Holders.
o) Comply with the instructions and requirements issued by the Superintendence of Industry and Commerce.

 

Duties of those in charge of handling and processing personal data.

Those responsible for the handling and processing of personal data must comply with the following duties, without prejudice to the other provisions set forth in law 1581 of 2012 and others that govern their activity:

a) Guarantee the Holder, at all times, the full and effective exercise of the right of habeas data;
b) Keep the information under the security conditions necessary to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access;
c) Carry out timely updates, rectifications or deletions of data under the terms of this law;
d) Update the information reported by the Treatment Managers within five (5) business days counted from its receipt;
e) Process inquiries and claims made by the Holders in the terms indicated in this law;
f) Adopt an internal manual of policies and procedures to ensure adequate compliance with this law and, in particular, for the attention of inquiries and complaints by the Owners;
g) Register in the database the legend “claim in process” in the form in which it is regulated in the present law;
h) Insert in the database the legend “information in judicial discussion” once notified by the competent authority about judicial processes related to the quality of the personal data;
i) Refrain from circulating information that is being disputed by the Holder and whose blockade has been ordered by the Superintendence of Industry and Commerce;
j) Allow access to information only to people who may have access to it;
k) Inform the Superintendence of Industry and Commerce when there are violations of the security codes and there are risks in the administration of the information of the Owners;
l) Comply with the instructions and requirements issued by the Superintendence of Industry and Commerce.

 

Security and Confidentiality

In order to guarantee the protection of privacy, confidentiality and integrity of information, AYUDA TECNICA Y DE SERVICIOS S.A. has adopted all the means, good practices and technical measures available to ensure the transmission of information to the databases and to avoid the alteration, loss, misuse, unauthorized access and theft of the personal data provided by Users for the purposes stated above. Nevertheless, the User must be aware that security measures are not infallible.

The information that a client enters in the website of AYUDA TECNICA Y DE SERVICIOS S.A. www.haciendanapoles.com is kept strictly confidential and is not shared with third parties other than those indicated in this Privacy Policy.

AYUDA TECNICA Y DE SERVICIOS S.A. will keep, under the conditions of security and confidentiality described here, and for the purposes indicated in this document, the personal data of its suppliers, contractors, employees and former employees, among others, during the entire execution time of each service provision contract signed between AYUDA TECNICA Y DE SERVICIOS S.A. and its customers, suppliers, contractors, employees and former employees, among others, and for ten (10) more years.

 

Data on children under 18 years of age

AYUDA TECNICA Y DE SERVICIOS S.A. will ensure the proper use of the personal data of children and adolescents under 18 years of age, seeking to respect their best interests, in the interest of respecting their fundamental rights and as possible, taking into account their opinion, as holders of their personal data.

Therefore, if a client, supplier, contractor, employee and former employee, among others, provides data in such a way that it can be identified that this data corresponds to a person under 18 years of age, AYUDA TECNICA Y DE SERVICIOS S.A. will act in accordance with the here expressed to treat the said data, in accordance with this Privacy Policy.

 

Updating of Personal Data

A customer, contractor, employee and former employee, among others, can update their personal data through the following channels:

Email: protection.datos@haciendanapoles.com

Through the following numbers: national line 018000510344

Office Hours: 8:00 am – 6:00 pm Monday to Friday.

Likewise, the owner of the information, through the following channels, may request not to be send correspondence, or not be contacted to offer a good or service offered by AYUDA TECNICA Y DE SERVICIOS S.A.

 

Procedure for exercising the Rights of the Holders of Information

To exercise the rights conferred by the law applicable to each person, the Client, contractor, employee and former employee, among others, can make their request to the following electronic address: protection.datos@haciendanapoles.com and the corresponding legal procedures will be followed.

It is necessary to leave proof of the following:

a) Name and identification of the owner of the data or the legitimized person
b) An accurate and complete description of the facts that give rise to the claim/query
c) A physical or electronic address to send the response and report on the status of the procedure
d) Documents and other relevant evidence that you want to enforce.
e) Date of receipt of the query/claim.

Once the identity of the owner is verified, the required personal data will be provided.

 

The response to the query/claim must be communicated to the applicant within a maximum term of fifteen (15) business days from the date of receipt of the same. When it is not possible to attend the query/claim within the said term, the interested party will be informed, stating the reasons for the delay and indicating the date on which his/her consultation will be attended, which in no case may exceed eight (8) business days following the expiration of the first term.

 

Person or area responsible for the protection of personal data.

The Management area or whoever is acting on its behave, or whoever is appointed, will assume the function of protection of personal data and will process the requests of the holders, for the exercise of the rights referred to in Law 1581 of 2012, the Decree 1377 of 2013 and the present policy. It can be contacted through the following means: protection.datos@haciendanapoles.com

 

Entry into force and term

AYUDA TECNICA Y DE SERVICIOS S.A. reserves the right to modify this Privacy Policy at any time. Any change will be informed and published in a timely manner on the website www.haciendanapoles.com

The last revision made to this Privacy Policy was September 30, 2017, date from which it is applicable.

 

Data of the person in charge of the treatment.
Name or Social reason: AYUDA TECNICA Y DE SERVICIOS S.A.
Address or domicile: Medellín, carrera 43f N 12-19
Email: protection.datos@haciendanapoles.com
Phone: 018000510344
Website: www.haciendanapoles.com

 

Data of the Person in charge of processing personal data
Name or Social reason: Claudia Orozco
Address or domicile: Cra 43F num 12-19
Email: protection.datos@haciendanapoles.com
Phone: 018000510344
Website: www.haciendanapoles.com

Municipio de Puerto Triunfo - Antioquia (a 165 km de Medellín - a 249 km de Bogotá)
Contáctenos, Medellín, Área comercial:  +57 (4) 444 29 75 Línea Nacional 018000 510 344 - 318 219 45 53 - 317 538 72 61 - 318 219 4421