PRIVACY NOTICE: In compliance with Statutory Law 1581 of 2012 on Data Protection and Regulatory Decrees, this Privacy Notice aims to inform the Owner about the treatment to which the data stored in our databases will be subjected and inform if these will be subject to transmission and / or transfer to third Companies. The conditions of treatment are as follows:
The Company Excolbi S.A.S, with Nit.900.675.960-7 is responsible for and/or in charge of the processing of your personal data.
In order to provide comprehensive care to employees, contractors, suppliers, former employees or third parties in general, it is understood who has an employment relationship, the Company, collects, stores, uses, circulates and eventually transfers and transmits personal data for the following purposes: Publications on social networks and website; Profile analysis; Social assistance; Cultural activities; data mining, media management and/or editorial content; Non-formal education; Attention to citizens and / or customers; Customer loyalty and campaigns with financial companies and associated with the Company Excolbi S.A.S; historical, scientific or statistical purposes; internal and external statistics; Sanctions and wake-up calls; Certification services; Administrative procedures; Entry and exit of documents; Administrative management; Collection and payment management; Digital marketing with own and third-party campaigns directly or indirectly linked to the Company Excolbi S.A.S; Submission of information related to the corporate purpose of the company; Billing management; Data update campaigns and information on changes in the processing of personal data; Custody and management of database information; Operational development; Sending communications; Transportation of passengers and reservations of transport tickets; Administration of information systems; Accounting management; Requirement by control bodies of non-sensitive, private and/or sensitive data; Opinion polls; Own advertising and that of third parties directly or indirectly linked to the Company, Advertising and commercial prospecting; Decision support system; Offering products and services; Schedule control; Social promotion of youth; Formation; Attention and follow-up of requests of judicial or administrative authority; Data Verification and References; Verification of legal and/or technical requirements. Sending communications; Administrative management; Communications services; Advertising and commercial prospecting; Offering products and services; Staff training; Promotion and prevention programmes.
DEFINITIONS:
Authorization: It refers to the expression of the prior, express and informed consent of the Owner for the Company or its Managers to carry out the Processing of the Personal Data of the owner.
Privacy Notice: This is the physical, electronic or any other format document generated by the Company, which has been made available to the Owner for the Processing of their Personal Data, which communicates to the Owner the information regarding the existence of the Personal Data Processing Policies that will be applicable to it, the way to access them and the characteristics of the Treatment that is intended to give to the Personal Data.
Database: They consist of an organized set of Personal Data that are subject to Treatment, and includes physical and electronic files.
Personal Data: According to Law 1581 of 2012, it is any information linked or that can be associated with one or more determined or determinable natural persons.
Public Data: Personal Data qualified as public by law or the Political Constitution. Data relating to the civil status of persons, their profession or trade, their status as a trader or public servant are public, among others.
Sensitive Data: Personal Data whose use affects the privacy of the Holder or whose improper use may generate discrimination, such as those that reveal racial or ethnic origin, political orientation, religious or philosophical convictions, membership in trade unions, social organizations, human rights or that promotes the interests of any political party or that guarantee the rights and guarantees of opposition political parties as well as data related to health, sex life, private data such as your home address and biometric data.
Holder: Natural person whose personal data are subject to Treatment.
Treatment: It is any operation or set of operations on Personal Data carried out by the Company, or the Data Processors on behalf of the Company, such as collection, storage, use, circulation or deletion.
Transfer: It consists of sending Personal Data to a recipient who, in turn, is responsible for the Treatment under the terms of Law 1581 of 2012.
Transmission: It is the communication of Personal Data to the Data Processor, inside or outside the territory of the Republic of Colombia, for the purpose of carrying out a Treatment by the Treatment Manager on behalf of the Company. The personal data of end customers, suppliers, contractors, employees, former employees, which are hereinafter collected or found in our databases will be processed for the following purposes:
End customers: The Company will use the information you provide to: 1. 1. Carry out the pertinent steps for the development of the pre-contractual, contractual and post-contractual stage, with respect to any of the products offered by it that it has or has not acquired or, with respect to any underlying contractual relationship it has with it, as well as comply with Colombian or foreign law and the orders of judicial or administrative authorities; 2. Manage procedures (requests, complaints, claims), perform risk analysis, carry out satisfaction surveys regarding the goods and services of the company, as well as its business partners; 3. Provide contact information and relevant documents to the commercial force and / or distribution network, telemarketing, market research and any third party with which the company has a contractual relationship of any kind; 4. To disclose, transfer and / or transmit my personal data inside and outside the country, to third parties as a result of a contract, law or lawful link that requires it, or to implement cloud computing services. 5. Perform through any means directly or through third parties, programming and provision of technical service, sale, purchase, billing, portfolio management, monitoring of product performance, collection, business intelligence, marketing activities, promotion or advertising, improvement of service, monitoring of collection, verification, consultation and control, enabling means of payment as well as any other related to our current products and services and future, for the fulfillment of contractual obligations and the corporate purpose of the company. 6. For the sending and receiving of goods or advertising material according to the requirements of the functions demanded and sustainability of the company’s business. 7. Control and prevent fraud in any of its forms.
Customers, Suppliers, contractors and/or employees and former employees: Perform analysis, evaluations and selection of potential suppliers and/or contractors. Communication of our policies and procedures for linking suppliers. Analysis of information on quality and service levels received from suppliers. Legal compliance in tax, customs and commercial matters with administrative and judicial companies. Initiate business agreements to acquire goods or services Control and payments for goods and services received. Monitoring, control and accounting record of the obligations contracted with suppliers. Consultations, audits and reviews arising from agreements with suppliers and/or contractors. Control and prevent fraud in any of its forms.
Some of these tasks are carried out in compliance with a legal and contractual duty and therefore the processing of personal data is understood to be included in them.
RIGHTS OF THE HOLDERS
The Holders of the Personal Data registered in the Bases of the Company, have the following rights:
- Know, update and rectify your personal data. These rights may be exercised, among others, against partial, inaccurate, incomplete, fractional, misleading Personal Data, or those whose Treatment is expressly prohibited or has not been authorized;
- Request proof of the Authorization granted to the Company, except when expressly excepted as a requirement for the Treatment, in accordance with the provisions of article 10 of Law 1581 of 2012;
- Be informed regarding the use that has been given to your Personal Data by the Company, or the Data Processor, upon request;
- By means of a claim filed in accordance with Art. 15 of Law 1581 of 2012, you can request the revocation of the authorization and / or request the deletion of Personal Data when the Treatment is not respected.
- the principles, rights and constitutional and legal guarantees or at any time provided that the owner does not have the legal or contractual duty to remain in the databases of the Company, and in accordance with the procedure indicated in numeral IV., of this Policy.
CONSULTATION AND COMPLAINTS PROCEDURE
The Company guarantees the right of consultation, providing persons acting in exercise of this right, all the information contained in their individual registration or that is linked to the identification of the Holder.
The person responsible for attending to the requests in exercise of the rights by the holders will be the administrative area of the Company, as the area that will receive, process and channel the different requests received, and will send them to the respective aforementioned dependency in charge of the treatment, dependencies that once receive these communications, They will enter to comply with the function of protection of personal data, and must process the requests of the holders, in the terms, deadlines and conditions established by the current regulations, for the exercise of the rights of access, consultation, rectification, updating, deletion and revocation referred to in the current regulations on protection of personal data.
For the attention of requests for consultation of personal data, the Company guarantees that there are means of electronic and telephone communication.
The data for the exercise of rights are the gerencia@excolbi.com email and the physical address of the Company Excolbi S.A.S.
In any case, regardless of the mechanism implemented for the attention of consultation requests, they will be attended within a maximum term of ten (10) business days from the date of receipt. In case of impossibility to attend the consultation within said term, we will inform the interested party before the expiration of the 10 days, expressing the reasons for the delay and indicating the date on which your query will be attended, which in no case may exceed five (5) business days following the expiration of the first term.
Likewise, we guarantee the right to claim, to the databases for the correction, updating or deletion, or when they notice the alleged breach of any of the duties contained in Law 1581 of 2012 and other applicable regulations. The claim will be processed under the following rules:
- If the claim received does not have complete information that allows it to be processed, such as the identification of the Holder, the description of the facts that give rise to the claim, the address, and accompanying the documents that you want to assert, the claimant will be required within five (5) days of receipt to correct the failures. After two (2) months from the date of the request without the applicant submitting the required information, it will be understood that the claim has been withdrawn.
- Once the claim has been received in full, it will include in the database maintained by the Company, a legend that says “claim in process” and the reason for it, within a term not exceeding two (2) business days. This legend must be maintained until the claim is decided.
- The maximum term to attend the claim will be fifteen (15) business days counted from the day following the date of its receipt. When it is not possible to attend it within said term, the interested party will be informed before the expiration of the aforementioned term 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.
SPECIAL RULES FOR THE EXERCISE OF THE RIGHTS OF THE HOLDERS:
The request for rectification, updating or deletion must be submitted through the means enabled by the Company, indicated in the privacy notice and in this document, and contain, at least, the following information:
- The name, address of the holder and means of contact to receive the response such as telephone, email, address of residence.
- The documents that accredit the entity or the representation of its representative.
- The clear and precise description of the personal data with respect to which the owner seeks to exercise any of the rights.
- In any given case other elements or documents that facilitate the location of personal data.
- The Company has the obligation to rectify and update at the request of the owner, the information of the latter that turns out to be incomplete or inaccurate, in accordance with the procedure and the terms indicated above. In this regard, the following shall be taken into account:
The Society has full freedom to enable mechanisms that facilitate the exercise of this right.
Deletion of data. The owner has the right, at any time, to request the Company, the deletion (elimination) of his personal data when:
- Consider that they are not being treated in accordance with the principles, duties and obligations provided for in Law 1581 of 2012.
- They are no longer necessary or relevant for the purpose for which they were collected.
- The period necessary for the fulfillment of the purposes for which they were collected has been exceeded.
This deletion implies the total or partial elimination of personal information in accordance with what is requested by the owner in the records, files, databases or treatments carried out by the Company, the owner must warn that the right of cancellation is not absolute and the person responsible can deny the exercise of the same when:
- Requests for deletion of information will not proceed when the owner has a legal or contractual duty to remain in the database.
- The deletion of data hinders judicial or administrative proceedings linked to tax obligations, the investigation and prosecution of crimes or the updating of administrative sanctions.
- The data is necessary to protect the legally protected interests of the owner; to perform an action based on the public interest, or to comply with an obligation legally acquired by the holder.
If the cancellation of personal data is appropriate, the Company must operationally carry out the deletion in such a way that the elimination does not allow the recovery of the information. It should also be taken into account that in some cases certain information must remain in historical records for compliance with legal duties of the organization, so its deletion will be against the active treatment of them and according to the request of the owner.
INTERNATIONAL TRANSFER OF PERSONAL DATA
When data is sent or transferred to another country, it will also be granted with the authorization of the owner of the information that is being transferred. Unless the law says otherwise, the existence of such authorization is necessary to carry out the international circulation of data. That is to say that there is the prior, express and unequivocal authorization of the owner that allows to transmit their personal data internationally. This transfer of personal data is made only to third parties with whom the Company has a contractual, commercial and / or legal relationship.
IDENTIFICATION OF DATABASES AND PERIOD OF VALIDITY:
The databases under treatment by the Company are those enshrined in the document Personal Data and Exercise of Rights and will be in force for an indefinite period.
This transfer of personal data is made only to third parties with whom the Company has a contractual, commercial and / or legal relationship.
VALIDITY AND UPDATING OF POLICIES
These policies apply from the date of knowledge of the people. As a general rule, the term of the authorizations on the use of personal data by customers and / or users is understood by the end of the commercial relationship or the link to the service and during the exercise of the corporate purpose of the Companies.
The authorizations on the data of the clients and / or users may terminate by their will at any time. If the person is an active person of the Company, he will not be able to use his data for anything other than the provision of the product or service and for the offer of subsequent renewals when the service has this modality.
When the terms of the privacy policies of any of the services or products contracted by a holder, change in essence, as a general rule, in the services that have the option of renewal, the new authorization will be obtained in it. For other cases, authorization will be obtained in the manner established for each privacy policy or notice or through the usual means of contact between the company and the holders.
AUTHORIZATION OF USE OF IMAGE RIGHTS ON PHOTOGRAPHS AND AUDIOVISUAL FIXATIONS (VIDEOS) AND INTELLECTUAL PROPERTY GRANTED TO THE COMPANY.
In accordance with the provisions of the Political Constitution of Colombia of 1991, Law 23 of 1982, Law 1581 of 2012 and Regulatory Decree 1377 of 2013 according to the data provided to the Company or through its portals, in my capacity as a natural person, or legal person through this document I grant express AUTHORIZATION of the use of the image rights that recognize me and / or recognize me, the Political Constitution, the Law and other regulations concordant to the Company, the authorization will be governed by the following clauses:
First: Authorization and Purpose – By means of this instrument I authorize the Company, to make the use and treatment of my image rights obtained in the company or the different events, to include them on photographs, procedures analogous to photography, audiovisual productions (videos), as well as copyright, related rights and in general all those intellectual property rights that have to do with the image right.
Second: Scope of the authorization – This authorization of use is granted to be used in format or material support in printed editions, and extends to the use in electronic, optical, magnetic, social networks, website, data message or similar and in general for any means or support known or to be known in the future. The publication may be made directly or through a third party designated for that purpose and without profit.
Third: Territory and Exclusivity – the rights authorized herein are given without any geographical, territorial or temporal limitation. Similarly, the authorization of use established here will not imply exclusivity, so I reserve the right to grant authorization of similar use in the same terms in favor of third parties.
Fourth: Moral Rights – the Society will comply with the current regulations on moral rights of authors, which will continue to be filed in the head of its owner.
For proof of the foregoing is authorized from the date of linking or relationship with the Company through the portal.
AUTHORIZATION FOR THE PROCESSING OF PERSONAL DATA.
As established by Law 1581 of 2012 and its regulatory Decrees, I declare, freely, previously and expressly, that I AUTHORIZE the Company, to carry out the collection of the personal data that I provide below, of which I declare I am the owner and / or its legal representative. This authorization will allow the Company to collect, store, use, circulate, delete, process, compile, update, dispose of and eventually transmit and transfer, my personal data, in accordance with the purposes established for employees, contractors, suppliers, former workers, or third parties linked to the company, according to stipulations contained in the privacy notice, which is below.
PRIVACY NOTICE OF PROTECTION OF PERSONAL DATA.
In compliance with Statutory Law 1581 of 2012 on Data Protection (LEPD) and regulatory decrees, the purpose of this Privacy Notice is to inform the Owner about the treatment to which the data stored in our databases will be subjected and inform if these will be subject to transmission and / or transfer to third Companies. The conditions of treatment are as follows:
- 1. Carry out the pertinent steps for the development of the pre-contractual, contractual and post-contractual stage with the Company, with respect to any of the products offered by it that it has or has not acquired or, with respect to any underlying contractual relationship it has with it, as well as comply with Colombian or foreign law and the orders of judicial or administrative authorities; 2. Manage procedures (requests, complaints, claims), perform risk analysis, carry out satisfaction surveys regarding the goods and services of the company, as well as its business partners; 3. Provide contact information and relevant documents to the commercial force and / or distribution network, telemarketing, market research and any third party with which the company has a contractual relationship of any kind; 4. To disclose, transfer and / or transmit my personal data inside and outside the country, to third parties as a result of a contract, law or lawful link that requires it, or to implement cloud computing services. 5. Perform through any means directly or through third parties, programming and provision of technical service, sale, purchase, billing, portfolio management, monitoring of product performance, collection, business intelligence, marketing activities, promotion or advertising, improvement of service, monitoring of collection, verification, consultation and control, enabling means of payment as well as any other related to our current products and services and future, for the fulfillment of contractual obligations and the corporate purpose of the company. 6. For the sending and receiving of goods or advertising material according to the requirements of the functions demanded and sustainability of the company’s business. 7. Control and prevent fraud in any of its forms.
In order to provide comprehensive care to citizens, customers, suppliers, contractors and / or employees and former employees.
If you wish to submit queries, requests or claims that deal with the protection of personal data, you may contact the contact channels of the portal, or by writing to the physical address of the Company Excolbi S.A.S, or to the email that appears as judicial notifications.
The personal data processing policy, as well as the substantial changes that occur in it, can be consulted through the web portal.
It is optional to provide information that is about Sensitive Data, understood as those that affect privacy or generate some type of discrimination, or about minors.
The Company may contain links or access to websites and content of other persons or Companies, but is not responsible for their content, does not control, endorse or guarantee the content included in such sites, nor is it responsible for the operation or accessibility of the linked web pages; nor suggests, invites or recommends the visit to them, for which reason it is not responsible for the result obtained, including the changes or updates made in the linked site or the accuracy or completeness of the information provided there.
Consequently, the Citizen-Users, etc. accept that the Company is not responsible for any content, associated link, resource or service associated with the site of a third party, nor will it be responsible for any loss or damage of any kind arising from the use made of the contents of third parties.
The Company provides the links for your convenience and the existence of these on our websites, however, this does not imply that the Company approves or maintains current contractual relationships with the organizations or companies to which it links, or to their products or services and vice versa for organizations or companies that link to the website.
Under the gravity of the oath I certify that all the data noted here are true and true.