Habeas
Data

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Habeas Data

General

Article 1. Objective. In order to comply with the provisions of Law 1581 of 2012 and its regulatory decree number 1377 of 2013, below, the Holders of Personal Data contained in GRUPODOT SAS Databases are informed of the various aspects that make up the Company’s Data Processing Policy (“Treatment Policy”).

Responsible for the treatment: GRUPODOT S.A.S.
Name of the Responsible: GRUPODOT S.A.S.
Address: Carrera 19 N ° 84-17
Email: info@grupodot.com
Phone: 745 66 78 ext. 132

Article 3. Treatment to which the personal data and purpose will be subjected. The information that is collected and stored from shareholders, customers, suppliers, candidates, employees and any other natural or legal person that has contact with GRUPODOT SAS, depending on the relationship that the owner has with the company, the information that is collected or stores can include the following:

  • General data: Such as names, surnames, date of birth, number and type of identification, age, marital status, address, landline, mobile phone, email, comments, workplace, position and level.
  • Particular data according to the type of link: resume, employment information, academic information, financial information, nationality; and all other data related to the quality of shareholders, investors, employees or suppliers, as applicable.
  • Sensitive data: Biometric data and photographic records.

Treatment of sensitive data

Article 4. GRUPODOT S.A.S., will not collect, incorporate or store personal data sensitive, unless there is prior authorization from the owner of the information.

Article 5. The aforementioned authorization will only be requested when necessary and proportional for the execution of the relationship with the owner, as long as the Law requires or allows access to sensitive information of the latter.

Article 6. The authorization for the treatment of sensitive data will be requested prior to the incorporation of the same, and this will indicate the purpose for which it is incorporated. In addition, it will be specified that the answer to the questions about sensitive data is optional and the other elements described in this policy will be indicated to obtain authorization for the treatment of the information.

Article 7. Treatment of sensitive data may not be carried out for purposes other than those authorized by the owner.

Purpose of the treatment of the personal information of the holders

Article 8. Only the data that is necessary, pertinent and not excessive for the purposes authorized and informed to the owner and those indicated in this policy will be collected, provided that the treatment obeys a legitimate purpose and is proportional according to the sustained relationship with the owner.

Article 9. Treatment of personal data of clients. The personal data of the clients that are collected, will be used in order to select, evaluate and execute the contractual relationship that may arise between the parties, seeking greater knowledge of the supplier and client, better management of information for the decision making, transparency in relationships, and effectiveness and efficiency in processes and with the following purposes:

  • Carry out the pertinent steps for the development of the pre-contractual, contractual and post-contractual stage with GRUPODOT S.A.S. with respect to the services offered by it that it may or may not have acquired or, with respect to any underlying business relationship that it may have with it, as well as to comply with Colombian or foreign law and the orders of judicial or administrative authorities.
  • Manage procedures (requests, complaints, claims), carry out risk analysis, carry out satisfaction surveys regarding the services of the company, as well as its commercial allies.
  • Provide contact information and relevant documents to the commercial force and / or distribution network, market research and any third party with which the company has a contractual link of any kind.
  • Make known, transfer and / or transmit my personal data inside and outside the country, to third parties as a result of a contract, law or legal link that requires it.
  • Perform through any means directly or through third parties, programming and provision of services, sale, purchase, billing, portfolio management, monitoring of service performance, collection, business intelligence, marketing activities, promotion or advertising, service improvement, collection monitoring, verification, consultation and control, payment methods authorization as well as any other related to our current and future services, for the fulfillment of the contractual obligations and the corporate purpose of the company.
  • For the sending and receiving of merchandise or advertising material according to the requirements of the demanded functions and sustainability of the company’s business.
  • Control and prevent fraud in any of its forms.

Article 10. Treatment of personal data of employees. The treatment of personal data of GRUPODOT S.A.S. employees will be subject to the provisions of this policy and may only be used in compliance with current labor regulations, for the correct development of the obligations derived from the labor contract concluded between the parties, or in events in which you have the express authorization of the owner and for the following purposes:

  • Allow the exercise of your rights as an employee, established in the Substantive Labor Code and in the other applicable regulations.
  • Send information about the company, including invitations to events, quarterly bulletins (presentation of results), annual report, and those communications related to the activities carried out by GRUPODOT S.A.S.
  • Give certifications related to your status as an employee, such as certificates of income and withholdings, employment records, among others.
  • Share information with suppliers and clients with whom activities are carried out in compliance with its corporate purpose, with the limitations and rules established by GRUPODOT S.A.S.

Article 11. Treatment of personal data of the candidates. The data provided by those interested in vacancies and personal information obtained from the selection process, is limited to that related to their participation in it; therefore, its use for different purposes is prohibited, once the candidate’s information has been collected it will be returned to it or destroyed once the selection process ends, whether or not it is selected to occupy the position.

Article 12. Treatment of personal data of retired workers. The data corresponding to people whose employment relationship has ended will continue to be stored for authorized purposes and under the same conditions and security levels in accordance with the provisions of Decree 1072 of 2015, in its article 2.2.4. 6.13.

Article 13. Treatment of personal data Suppliers. The treatment of the personal data of the suppliers, natural person and / or owner of GRUPODOT S.A.S., will be subject to the provisions of this policy, and may only be used in compliance with the contractually established, for the correct development of the obligations derived from the commercial contract concluded between the parties, or in events in which the express authorization of the owner is available.

  • Carry out 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 providers.
  • Legal compliance in tax, customs and commercial matters with administrative and judicial entities.
  • Initiate business agreements to acquire goods or services.
  • Control and payments for the goods and services received.
  • Accounting monitoring, control and record of the obligations contracted with the suppliers.

Article 14. Treatment of personal data of the shareholders. The data and information of natural persons who have the status of shareholders will be considered reserved information, since it is registered in the books of commerce and is subject to special protection by legal provision. However, the information will be revealed by judicial disposition, in the cases established by the norms that regulate the public stock market or in the events in which there is the express authorization of the owner and for the following purposes:

  • Allow the exercise of the rights derived from the quality of shareholder or investor, facilitating that they can exercise the political and economic rights established in the Commercial Code, in Decree 2555 of 2010, and in the other regulations applicable to the matter.
  • Send information about GRUPODOT S.A.S., including invitations to events, quarterly bulletins (presentation of results), annual report, and those communications related to the activities carried out by the company.
  • Give certifications regarding the relationship of the data owner with the company, such as income certificates, shareholding certificates, among others.
  • Share information with suppliers with whom activities are carried out in compliance with its corporate purpose, with the limitations and established rules.
  • Comply with court orders.

Rights that assist you as owner

Article 15. Without prejudice to the other rights enshrined in the Political Constitution, Law 1581 of 2012 and the other regulations that clarify, modify, regulate or add them, the Holders have the right to:

  • Know, update and rectify your personal data in front of GRUPODOT S.A.S. in its capacity as Data Controller. This right may be exercised, among others, against partial, inaccurate, incomplete, fractional data that is misleading, or those whose Treatment is expressly prohibited or has not been authorized.
  • Request proof of the Authorization granted to GRUPODOT S.A.S. except when expressly excepted as a requirement for Treatment, in accordance with the provisions of article 10 of Law 1581 of 2012.
  • Be informed by GRUPODOT S.A.S., upon request, regarding the use that has been given to your Personal Data.
  • Be informed by GRUPODOT S.A.S., upon request, regarding the use that has been given to your Personal Data.
  • Revoke the Authorization or request the deletion of the data when the Treatment does not respect the principles, rights and constitutional and legal guarantees.
  • Free access to Personal Data that has been processed.

Mechanisms to exercise your rights as holder

Article 16. Your rights are: to know, update, rectify and delete the data and revoke the authorization. The data processing officer is the figure before which the Holders may raise their requests so that GRUPODOT S.A.S., as the person in charge of the treatment, carries out the necessary actions for the exercise of the rights of the holder, according to what is described in the manual of personal data processing.
Article 17. Channels of attention for queries and complaints: To make requests, queries or claims in order to exercise the rights to know, update, rectify, delete the data or revoke the authorization granted, the owner or his successors can use any of the following communication channels:

Name of the person in charge: GRUPODOT S.A.S.
Address : Carrera 19 N ° 84-17
Email: info@grupodot.com
Phone: 745 66 78 ext. 132

Artículo 18. Date of entry into force of the policy of treatment of the
information.

The Information Processing Policy of GRUPODOT S.A.S. entered into force on February 20, 2013.

This policy was updated on March 31, 2019.