Personal Data Treatment

Personal Data Treatment SELETTI SAS

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Business Name: SELETTI SAS. Nit: 800.238.299-1
Address: CALLE 74B # 68G-54 Bogotá D.C. – Colombia Phone Number:(1)540-4746
E-mail Address: habeasdata@seletti.net
Web Page: www.seletti.net

1. LEGAL REGULATIONS AND SCOPE:

This Personal Data Processing policy is prepared in accordance with the provided in the Political Constitution, Law 1581 of 2012, Regulatory Decree 1377 of 2013 and other complementary provisions and will be applied by SELETTI SAS regarding the collection, storage, use, circulation, deletion, transfer and of all those activities that constitute the processing of personal data.

2. DEFINITIONS:

For the purposes of the execution of this policy and in accordance with legal regulations, The following definitions shall apply: a) Authorization: Prior, express consent and informed of the Holder to carry out the Processing of personal data; b) Notice of Privacy: Physical, electronic or any other document generated by the Responsible that is made available to the Holder for the processing of their personal data. In The Privacy Notice is communicated to the Holder the information regarding the existence of the policies of information processing that will be applicable, how to access them and the purpose of the treatment that is intended to give personal data; c) Database: Set organized personal data that is the object of Treatment; d) Personal data: Any information linked or that may be associated with one or more specific natural persons or determinable; e) Public data: It is the data qualified as such according to the mandates of the law or of the Political Constitution and one that is not semi-private, private or sensitive. They are public, among other , the data related to the marital status of people, their profession or trade, their quality of merchant or public servant and those that can be obtained without reservation. For his nature, public data may be contained, among others, in public records, public documents, gazettes and official bulletins; f) Private data: It is the data that by its intimate or reserved nature is only relevant to the holder; g) Sensitive data: It is understood by sensitive data those that affect the privacy of the Holder or whose improper use may generate its discrimination, such as those that reveal racial or ethnic origin, political orientation, religious or philosophical convictions, membership in unions, social organizations, of human rights or that promotes interests of any political party or that guarantee the rights and guarantees of opposition political parties, as well as health data, to the sexual life and biometric data; h) Responsible for the Treatment: Natural or legal person, public or private, that by itself or in association with others, perform the Data Processing personnel on behalf of the Treatment Manager; i) Responsible for the Treatment: Person natural or legal, public or private, that by itself or in association with others, decides on the basis of data and / or the processing of data; j) Owner: Natural person whose personal data is object of Treatment; k) Treatment: Any operation or set of operations on personal data, such as the collection, storage, use, circulation or deletion of these.

3. PURPOSE WITH WHICH THE COLLECTION OF PERSONAL DATA AND
TREATMENT IS PERFORMED THEREOF:

SELETTI SAS may make use of personal data to:
a) Execute the contractual relationship existing with its customers, suppliers and workers, including the payment of obligations contractual;

b) Provide the services and / or products required by its users;

c) Send to physical, electronic, cellular or mobile device, via text messages (SMS and / or MMS) or to through any other analogue and / or digital means of communication created or to be created, commercial, advertising or promotional information about products and / or services, events and / or commercial promotions or not of these, in order to promote, invite, direct, execute, inform and generally carry out campaigns, promotions or contests of character commercial or advertising, advanced by SELETTI SAS and / or by third parties.

d) Develop the selection process, evaluation, and employment relationship;

e) Support internal audit processes or external;

f) Record the information of employees and / or pensioners (active and inactive) in the SELETTI SAS databases.

g) Those indicated in the authorization granted by the owner of the data or described in the respective privacy notice, as the case may be;

h) Supply, share, send or deliver your personal data to subsidiaries, related companies, or subordinates of SELETTI SAS
located in Colombia or any other country in the event that these companies require the information for the purposes indicated here.

(i) obtained from the video recordings that are made inside or outside SELETTI SAS facilities, these will be used for security purposes of the people, goods and facilities of SELETTI SAS and may be used as evidence in Any type of process. If a personal data is provided, such information will be used only for the purposes indicated herein, and therefore, SELETTI SAS will not proceed to sell, license, transmit, or disclose it, unless: (i) there is express authorization to do so; (ii) be necessary in order to provide our services and / or products; (iii) it is necessary to disclose it to entities that provide marketing services on behalf of SELETTI SAS or other entities with which have joint market agreements; (iv) the information is related to a merger, consolidation, acquisition, divestment, or other restructuring process of the company; (v) that is required or permitted by law. SELETTI SAS may subcontract to third parties for the processing of certain functions or information. When information processing is effectively outsourced to third parties personal or personal information is provided to third party service providers, SELETTI SAS warns said third parties about the need to protect such personal information with measures appropriate security, these will be transmitted with confidentiality clauses that prevent the loss, disclosure or fraudulent access to it, the use of information is prohibited to own purposes and requests that personal information not be disclosed to others.

4. PRINCIPLES APPLICABLE TO THE PROCESSING OF PERSONAL DATA:

The processing of personal data in SELETTI SAS will be governed by the following principles:
a) Principle of purpose: The processing of personal data collected must comply with a legitimate purpose, which must be informed to the Holder; b) Principle of freedom: The Treatment can only be carried out with the prior, express and informed consent of the Holder. The Personal data may not be obtained or disclosed without prior authorization, or in the absence of legal or judicial mandate that relieves consent; c) Principle of truthfulness or quality: Information subject to
Treatment must be truthful, complete, accurate, updated, verifiable and understandable. The processing of partial, incomplete, fractional or that mislead; d) Principle of transparency: In Treatment, the right of the Holder to obtain from SELETTI SAS at any time and without restrictions, information about the existence of data concerning you; e) Principle of access and circulation Restricted: The Treatment is subject to the limits that derive from the nature of the data personal, of the provisions of this law and the Constitution. Personal data, except the public information, and the provisions of the authorization granted by the owner of the data, 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 Holders or authorized third parties; f) Principle of security: Information subject to Treatment by SELETTI SAS should be protected through the use of technical, human and administrative measures that are necessary to grant security to the records avoiding their adulteration, loss, consultation, use or unauthorized or fraudulent access; g) Principle of Confidentiality: All persons involved in the processing of personal data are obliged to guarantee the reservation of the information, even after its relationship with some of the tasks that the Treatment includes. FIRST PARAGRAPH: In the event that collect sensitive personal data, the Holder may refuse to authorize their Treatment.

5. RIGHTS OF PERSONAL DATA HOLDERS SUBJECT TO TREATMENT BY SELETTI SAS:

The holders of personal data by themselves or through their representative and / or proxy or their Candidate may exercise the following rights, regarding personal data that are object of treatment by SELETTI SAS: a) Right of access: Under which you may access personal data that is under the control of SELETTI SAS, for the purpose of consult them for free at least once every calendar month, and whenever they exist Substantial modifications to the Information Processing Policies that motivate new consultations; b) Right to update, rectification and deletion: Under which you may request the update, rectification and / or deletion of the personal data processed, of such manner that the purposes of the treatment are met; c) Right to request proof of authorization: except in the events in which, according to current legal regulations, it is not required of the authorization to carry out the treatment; d) Right to be informed regarding the use of personal data; e) Right to file complaints with the Superintendence of Industry and Commerce: for violations of the provisions of current regulations on the processing of personal data; f) Right to require compliance with orders issued by the Superintendency of Industry and Commerce. FIRST PARAGRAPH: For the purposes of exercising the rights before described both the owner and the person representing him must prove his identity and, of be the case, the quality by virtue of the act that represents the holder. SECOND PARAGRAPH: The Rights of minors will be exercised through the persons who are empowered to represent them.

6. DUTIES OF SELETTI SAS:

All those obliged to comply with this policy must keep in mind that SELETTI SAS. is bound to fulfill the duties that the law imposes in this regard. Consequently, the following obligations: A. Duties when acting as responsible: (i) Request and keep, in the conditions provided in this policy, a copy of the respective authorization granted by the headline. (ii) Clearly and sufficiently inform the holder about the purpose of the collection and the rights that assist you by virtue of the authorization granted. (iii) Report at the request of the holder on the use given to your personal data (iv) To process the queries and claims made in the terms indicated in this policy (v) Ensure that the principles of truthfulness, quality, security and confidentiality in the terms established in the following policy are of mandatory compliance (vi) -Keep information under security conditions necessary to prevent their adulteration, loss, consultation, use or unauthorized access or fraudulent. (vii) Update the information when necessary. (viii) Rectify the data personal when appropriate. B. Duties when you work as Treatment Manager of personal data. If you perform data processing on behalf of another entity or organization (Responsible for the treatment) must fulfill the following duties: (i) Establish that the Responsible for the treatment is authorized to provide the personal data that will be processed as Manager (ii) Guarantee the holder, at all times, the full and effective exercise of the right of habeas data. (iii) Keep the information under the security conditions necessary for prevent their adulteration, loss, consultation, use or unauthorized or fraudulent access. (iv) Perform timely update, rectification or deletion of data. (v) Update the information reported by those responsible for the treatment within five (5) business days counted from your receipt. (vi) Process the consultations and claims made by the holders in the terms indicated in this policy. (vii) Register in the database the legend “claim in process” in the manner set out in this policy. (viii) Insert in the database the legend “information in judicial discussion” once notified by the competent authority on judicial processes related to the quality of personal data. (ix) Refrain from circulating information that is being disputed by the owner and whose blocking has been ordered by the Superintendence of Industry and Commerce. (x) Allow access to the information only to persons authorized by the holder or empowered by law for said effect. (xi) Inform the Superintendence of Industry and Commerce when they appear violations of the security codes and there are risks in the administration of the information of headlines. (xii) Comply with the instructions and requirements issued by the Superintendency of Industry and Commerce. C. Duties when performing treatment through a Manager (i) Provide the person in charge of the processing only with personal data whose processing is previously authorized For the purposes of national or international data transmission, You must sign a contract for the transmission of personal data or agree to contractual clauses as established in article 25 of decree 1377 of 2013. (ii) Ensure that the information that is given to the person in charge of the treatment is truthful, complete, exact, updated, verifiable and understandable. (iii) Communicate the Treatment Manager in a timely manner all the news regarding the data that you have previously provided and adopt the other necessary measures so that the information provided to it is kept updated. (iv) Inform in a timely manner to the person in charge of the treatment the rectifications made on personal data so that it can make the appropriate adjustments. (v) Require Responsible for treatment, at all times, respect for safety conditions and privacy of the holder’s information. (vi) Inform the person in charge of the treatment when certain information is under discussion by the owner, once it has been filed the claim and has not completed the respective procedure. D. Duties regarding the Superintendence of Industry and Commerce (i) Inform you of possible violations of the codes of security and the existence of risks in the administration of the information of the owners. (ii) Comply with the instructions and requirements issued by the Superintendence of Industry and Commerce.

7. APPLICATION FOR AUTHORIZATION BY THE PERSONAL DATA HOLDER:

In advance and / or at the time of collecting personal data, SELETTI SAS will request to the holder of the data his authorization to carry out his collection and treatment, indicating the purpose for which the data is requested, using automated technical means for that purpose, written or oral, that allow to keep proof of authorization and / or unequivocal conduct described in article 7 of Decree 1377 of 2013. Said authorization shall be requested for a period of time that is reasonable and necessary to meet the needs that gave rise to the request of the data and, in any case, with observance of the legal provisions that govern the matter.

8. PRIVACY NOTICE:

In the event in which SELETTI SAS cannot make available to the owner of the personal data the This information processing policy will publish the privacy notice attached to this document, whose text will be kept for later consultation by the holder of the data and / or the Superintendence of Industry and Commerce.

9. TEMPORARY LIMITATIONS TO THE PROCESSING OF PERSONAL DATA:

SELETTI SAS may only collect, store, use or circulate, and in general process the data personnel for as long as is reasonable and necessary, in accordance with the purposes that they justified the treatment, according to the provisions applicable to the subject matter and to the administrative, accounting, fiscal, legal and historical aspects of the information. One time accomplished the purpose or purposes of the treatment and without prejudice to legal regulations that provide the Otherwise, it will proceed to the deletion of personal data in your possession. Notwithstanding above, personal data must be kept when required for the compliance with a legal or contractual obligation.

10. RESPONSIBLE AREA AND PROCEDURE FOR THE EXERCISE OF THE RIGHTS OF PERSONAL DATA HOLDERS:

What kind of automated and / or profiling decision making do we do with user data

THE AREA OF ACCOUNTING AND HUMAN RESOURCES OF SELETTI SAS will be responsible for attending the requests, complaints and claims made by the holder of the data in exercise of the rights contemplated in numeral 5 of this policy, with the exception of that described in its literal

e). For such effects, the holder of the personal data or whoever exercises his representation may send his request, complaint or claim Monday through Friday from 8:00 a.m. to 5:00 p.m. to email habeasdata@seletti.net, call the telephone line of SELETTI SAS, telephone (1) 540-4746 Bogotá D.C., or file it at the following address that corresponds to our offices Calle 74 B No 68 G 54 Bogotá D.C. – Colombia. The petition, complaint or claim must contain 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. If the claim is incomplete, the interested party will be required within five (5) days following receipt of the claim to remedy the failures. Two (2) months after the date of the request, without the applicant submitting the required information, it will be understood that you have given up the claim. In case who receives the claim is not competent to resolve it, will transfer to whoever corresponds in a term maximum of two (2) business days and inform the interested party of the situation. Once the complete claim, a legend that says “claim in process” and the reason for it, in a term not exceeding two (2) business days. This legend must stay until the claim is decided. The maximum term to address the claim will be fifteen (15) business days from the day following the date of receipt. When do not if it is possible to address the claim within said term, the interested party will be informed of the reasons of the delay and the date on which your claim will be addressed, which in no case may exceed eight (8) business days following the expiration of the first term. In case of consultations, these will be attended within a maximum period of ten (10) business days counted from the date of receipt thereof. When it is not possible to answer the query within said term, the interested party will be informed, stating 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.

11. DATA COLLECTED BEFORE THE ISSUE OF DECREE 1377 OF 2013:

In accordance with the provisions of paragraph 3 of article 10 of Regulatory Decree 1377 2013 SELETTI SAS will publish a notice on its official website www.seletti.net addressed to the owners of personal data for the purpose of publicizing this policy of information processing and how to exercise your rights as holders of personal data hosted in the SELETTI SAS databases.

12. SECURITY MEASURES:

In development of the security principle established in Law 1581 of 2012, SELETTI SAS will adopt the technical, human and administrative measures that are necessary to grant security to records avoiding adulteration, loss, consultation, use or unauthorized or fraudulent access. The personnel who carry out the processing of personal data will execute the established protocols in order to guarantee information security.

13. DATE OF ENTRY INTO FORCE:

This Personal Data Policy was created on July 1, 2015 and enters into force at from the date. Any changes that occur with respect to this policy will be reported. through the electronic address: http://www.seletti.net

Sincerely,

SELETTI SAS