PRIVACY POLICIES
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POLICY FOR THE TREATMENT AND PROTECTION OF PERSONAL DATA CUEROS Y DISEÑOS S.A.S
CUEROS Y DISEÑOS S.A.S., abiding by the regulations that regulate the protection of personal data established in arts. 15 and 20 of the Political Constitution of Colombia, developed by Law 1581 of 2012, ruling C-748 of October 6, 2011 issued by the Constitutional Court and the other applicable provisions, establishes the Policy for the Treatment and Protection of Personal Data (hereinafter the “Policy”), in order for its owners to be aware of the rights to which they are entitled, the treatment and purpose to which the personal data are subjected and the mechanisms for the exercise of their rights.
1. WHAT DOES THE POLICY REGULATE AND TO WHOM DOES IT APPLY?
The purpose of the Policy is to establish the guidelines for the management and appropriate processing of personal data managed by CUEROS Y DISEÑOS S.A.S. as well as the rights of its owners and the way to exercise them. The Policy applies in general to the information collected in personal databases of CUEROS Y DISEÑOS S.A.S. that have, have had or will have some type of relationship with CUEROS Y DISEÑOS S.A.S., whose automated or manual processing is carried out in each of the offices.
2. WHO IS RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA?
CUEROS Y DISEÑOS S.A.S., domiciled in Medellín (Ant.), located at Carrera 20 Nº20 – 58. El Retiro (Ant.), Colombia. Telephone 5410402, email: contabilidad@purocuero.com.co
3. WHAT IS THE PROCESSING TO WHICH PERSONAL DATA ARE SUBJECTED?
The information collected by CUEROS Y DISEÑOS S.A.S. It is used by it and may be shared with third parties in charge of the information, other members of its economic conglomerate, strategic allies and third parties. Exceptionally, it may be assigned, transferred or transmitted within the national territory or abroad, maintaining its confidentiality, security and protection.
The treatment may be carried out through automated, computer, manual, mechanical, digital or electronic procedures or through a combination of two or more of these. The processing may include operations on personal data, such as: collection, storage, conservation, organization, consultation, use, evaluation, updating, blocking, circulation, reproduction, destruction, deletion, assignment, transfer or transmission to third parties, and in general, its prosecution.
4. FOR WHAT PURPOSE ARE PERSONAL DATA OBTAINED AND PROCESSED?
The personal information collected from the interest groups listed in the following sections, as well as that collected from third parties in general, have the following purposes:
– Development of the corporate purpose.
– Compliance with legal provisions and contractual obligations.
– Compliance with orders and requirements of state and private authorities.
– Compliance and determination of business policies.
– Identity and location verification.
– Organization, systematization and filing of the data provided.
– Legal, administrative or judicial procedures.
– Development of social responsibility, well-being or profit generation activities.
– Communication and contact.
– Sending information.
– Reports to public entities or individuals,
– Internal control activities and audits.
– Consultation for prevention and control of money laundering and terrorist financing.
The treatment may be carried out through automated, computer, manual, mechanical, digital or electronic procedures or through a combination of two or more of these. The processing may include operations on personal data, such as: collection, storage, conservation, organization, consultation, use, evaluation, updating, blocking, circulation, reproduction, destruction, deletion, assignment, transfer or transmission to third parties, and in general, its processing.
4.1. ACTIVE COLLABORATORS
The personal information provided by collaborators will be used for the following purposes:
– Compliance with current regulations, the contract, execution and compliance with the perfected legal acts and the orders issued by the competent authorities, whether judicial, administrative or individuals in the exercise of public functions.
– Delivery of certifications or information about the employment relationship by request, authorization or by management of the collaborator.
– Delivery of information to third parties that support human management in aspects such as: training, evaluation, certification, verification, comparison of labor skills and all types of processes necessary for the execution of the employment relationship.
– Sending information to entities in charge of social security and parafiscal management.
– Delivery of personal information to third parties for the management of welfare activities, generation of benefits or signing of agreements in favor of collaborators and/or their families.
4.2. FAMILY GROUP AND/OR BENEFICIARIES OF THE COLLABORATOR
The personal information provided by the collaborator’s family group and beneficiaries will be used for the following purposes:
– Organization, systematization and filing of the data provided.
– Compliance with current regulations, the contract, the legal acts signed and the orders issued by the competent authorities, whether judicial, administrative or individuals in the exercise of public functions.
– Compliance with legal and contractual obligations, as well as corporate social responsibility.
– Request for information and delivery of personal data to third parties for the management of welfare activities, generation of benefits or subscription of agreements, acts or contracts in favor of the family group and/or the established beneficiaries.
– Communication and contact in special cases.
4.3. RETIRED EMPLOYEES
Once the employment relationship has ended, CUEROS Y DISEÑOS S.A.S. will process the information of former collaborators for the following purposes:
– Compliance with current regulations and orders issued by the competent authorities, whether judicial, administrative or individuals in the exercise of public functions.
– Delivery of certifications, certificates or information about the contractual relationship with the former collaborator.
– Sending information to entities in charge of social security and parafiscal management.
– Legal, administrative or judicial procedures.
4.4. SHAREHOLDERS
Natural persons who acquire the status of shareholders will have their personal data processed for the following purposes:
– Compliance with current regulations and orders issued by competent authorities, whether judicial, administrative or individuals in the exercise of public functions.
– Registration in accounting, control and compliance with obligations.
– Legal, administrative or judicial procedures.
– Execution and compliance with statutes, regulations, protocols and other legal acts.
– Generation of certifications, which may involve sending personal information to third parties in charge, such as corporate control bodies.
– Sending information and calls or communications related to CUEROS Y DISEÑOS S.A.S.
4.5. SUPPLIERS, CONTRACTORS, SUBCONTRACTORS AND THEIR DEPENDENTS. SUPPLIERS, CONTRACTORS, SUBCONTRACTORS AND THEIR DEPENDENTS WILL HAVE THEIR PERSONAL INFORMATION PROCESSED FOR THE FOLLOWING PURPOSES:
– Compliance with current regulations, tax and contractual obligations and orders issued by the competent authorities, whether judicial, administrative or by individuals in the exercise of public functions.
– Verification, consultation, comparison and evaluation of information for selection purposes, establishing contractual relationships, acquiring goods or services, determining quality levels in products or services provided.
– Verification of compliance with the technical, professional, personal suitability and occupational health aspects of the dependents of the supplier, contractor or its subcontractors.
– Registration in accounting, compliance and control of obligations.
– Submission of information and communication of guidelines and procedures to execute the agreed acts.
– Generation of certifications about the owner of the information and the contractual relationship maintained.
4.6. CUSTOMERS
The following are the purposes of the collection of personal information by clients:
– Compliance with current regulations, tax and contractual obligations and orders issued by the competent authorities, whether judicial, administrative or by individuals in the exercise of public functions.
– Sending commercial, advertising and marketing information.
– Registration in accounting, compliance and control of obligations.
– Preparation of surveys, measurement of standards in service provision, satisfaction, management and market studies, generation of commercial information, marketing advertising, invitations to events and similar.
– Verify, consult, compare and evaluate the information provided by clients in legitimately established financial, public or any other databases.
– Share information with suppliers of products or services to fulfill obligations or with companies belonging to the same conglomerate, parent companies, subordinates or strategic allies to offer complementary or substitute products or services.
– Generation of certifications about the owner of the information and the contractual relationship maintained.
5.WHAT ARE THE RIGHTS OF THE OWNER OF PERSONAL DATA?
The Owner of personal data will have the following rights:
5.1. Know, update and rectify your personal data with the Data Controllers. This right may be exercised, among others, against partial, inaccurate, incomplete, fragmented, misleading data or those whose Processing is expressly prohibited or has not been authorized.
5.2. Request proof of the authorization granted to the Data Controller except when it is expressly excepted as a requirement for the treatment. Authorization is not necessary in cases of:
5.3. Information required by a public or administrative entity in the exercise of its legal functions or by court order.
5.3.1. Public data.
5.3.2. Medical or health emergency cases.
5.3.3. Processing of information authorized by law for historical, statistical or scientific purposes.
5.3.4. Data related to the Civil Registry of Persons.
5.3.5. In the others established by current regulations.
5.4. Be informed by the Data Controller, upon request, regarding the use that has been given to your personal data.
5.5. Submit complaints to the Superintendency of Industry and Commerce for violations of the provisions of this law and other regulations that modify, add or complement it.
5.6. Revoke the authorization and/or request the deletion of the data when the processing does not respect constitutional and legal principles, rights and guarantees. The revocation and/or deletion will proceed when the Superintendency of Industry and Commerce has determined that in the Treatment the Controller has engaged in conduct contrary to this law and the Constitution.
5.7. Free access to your personal data that has been processed.
6. WHAT IS THE PROCEDURE FOR THE EXERCISE OF THE RIGHTS OF THE INFORMATION OWNERS?
6.1. Empowered people.
The rights of the Owners of personal data may be exercised by:
– The owner.
– Your successors in title.
– The representative and/or attorney-in-fact of the owner.
– A third party duly authorized by the owner or by the Law.
6.2. Application.
To make effective the exercise of their rights, the owner or his representative will send a duly signed written communication which will contain at least the following information:
– Full name of the data owner.
– Identification of the data owner.
– Procedure to be carried out: which can be: correction, update, elimination or revocation.
– Description of the facts that give rise to the request or query.
– Owner location data:
– Address
– Telephone or cell phone
– If it is considered necessary, documents that are intended to be asserted may be provided.
– In order to protect the personal data collected by CUEROS Y DISEÑOS S.A.S., until the status of owner or person authorized to request information from the owner is proven, it will not be possible to substantively resolve the request that is presented.
6.3. Requests and queries.
The Owners or their successors may make requests and queries about the Owner’s personal information that resides in a database of CUEROS Y DISEÑOS S.A.S. The request or query may be formulated in writing sent to the email accounting@purocuero.com.co
The query will be answered within a maximum period of ten (10) business days from the date of receipt. When it is not possible to attend to the query within said term, the interested party will be informed, expressing the reasons for the delay and indicating the date on which their query will be attended to, which in no case may exceed five (5) business days following the expiration of the first term.
6.4. Request for correction, update or deletion of personal data.
The Owner or his successors who consider that the information contained in a database of CUEROS Y DISEÑOS S.A.S. must be corrected, updated or deleted, they may file a claim with the company, which will be processed under the following rules:
– The claim will be made through a request addressed to CUEROS Y DISEÑOS S.A.S., which will contain the information indicated in section 6.2 of this Policy.
– If the claim is incomplete, the interested party will be required within five (5) days following receipt of the claim to correct the deficiencies.
– After two (2) months from the date of the request, without the applicant presenting the required information, it will be understood that the claim has been abandoned.
– In the event that the person who receives the claim is not competent to resolve it, he or she will forward it to the appropriate person within a maximum period of two (2) business days and will inform the interested party of the situation.
– Once the complete claim is received, a legend that says “claim in process” and the reason for it will be included in the database, within a period of no more than two (2) business days. Said legend must be maintained until the claim is decided.
– The maximum term to address the claim will be fifteen (15) business days counted from the day following the date of receipt. When it is not possible to address the claim within said term, the interested party will be informed of the reasons for the delay and the date on which their claim will be addressed, which in no case may exceed eight (8) business days following the expiration of the first term.
6.5. Revocation of authorization for the processing of personal data.
The owner of the personal data or his representative may revoke the authorization granted to CUEROS Y DISEÑOS S.A.S. for the processing of your personal data. The revocation will proceed through written communication sent to CUEROS Y DISEÑOS S.A.S. in the terms of section 6.2 of this Policy. CUEROS Y DISEÑOS S.A.S. will delete the data within a period of fifteen (15) business days from the day following the date of receipt of the request, as long as the request is appropriate.
6.6. Requests for deletion and revocation of authorization for the processing of personal data.
In the case of requests for deletion of personal data or revocation of authorization for the processing of personal data, these will not be granted if it exists for
CUEROS Y DISEÑOS S.A.S.:
– A legal or contractual obligation for personal data to remain in the database.
– When the deletion of data hinders or hinders extrajudicial, judicial or administrative actions related to tax obligations, disciplinary offenses, punishable prosecutorial acts or others that generate civil, administrative or criminal sanctions.
– When the data is required for the protection of the interests, powers and rights of the owner or to comply with an obligation acquired by the owner.
7. HOW IS THE POLICY FOR THE PROCESSING AND PROTECTION OF PERSONAL DATA MODIFIED?
CUEROS Y DISEÑOS S.A.S. reserves the right to modify this Policy at any time, in response to legal, regulatory, jurisprudential, technological modifications or for better provision of its services. Any substantial change in this Policy will be promptly communicated to the owners of the personal data in an efficient manner, understood as that which CUEROS Y DISEÑOS S.A.S. used in the ordinary course of their interaction with the Owners, who will be informed that the updated text of the Policy may be requested by email at contabilidad@purocuero.com.co
8. WHAT IS THE VALIDITY OF THE PROCESSING OF PERSONAL DATA?
As a general rule, the processing of personal information will remain valid for up to ten (10) years from its last processing. This term corresponds to that established by the current standard for the conservation of information. Exceptionally, legal rules will be applied that establish a different, lower or higher period, without prejudice to the fact that certain stored information may be subject to deletion before the indicated term, if it is not regulated by a rule that establishes a specific conservation period and is They fulfilled the purposes that justified their treatment.
This policy is effective upon publication.
