Bogotá, Colombia – Carrera 23 # 76 – 71 – Phone. (+57) 310-8190407

Info@sabajonapolo.com.co

PERSONAL DATA PROCESSING POLICY SABAJÓN APOLO S.A.

 

Company name: SABAJÓN APOLO SA Nit: 860.014.801-4
Address: CR 23 N° 76-71 Bogotá
Telephone: (1) 7434600
Email: info@sabajonapolo.com.co
Website: www.casaapolo.co

 

1. LEGAL REGULATIONS AND SCOPE OF APPLICATION
This personal data processing policy is prepared in accordance with the provisions of the Political Constitution, Law 1581 of 2012, Regulatory Decree 1377 of 2013 and other complementary provisions and will be applied by SABAJÓN APOLO SA regarding the collection, storage, use, circulation, deletion and all those activities that constitute processing of personal data.

 

2.DEFINITIONS
For the purposes of the execution of this policy and in accordance with legal regulations, the following definitions will be applicable:
a) Authorization: Prior, express and informed consent of the Owner to carry out the Processing of personal data;
b) Privacy notice: Physical, electronic document or any other format generated by the Controller that is made available to the Owner for the processing of their personal data. In the Privacy Notice, the Owner is informed of the information regarding the existence of the information processing policies that will be applicable, the way to access them and the purpose of the treatment that is intended to be given to personal data;
c) Database: Organized set of personal data that is subject to Processing;
d) Personal data: Any information linked or that can be associated with one or several specific or determinable natural persons;
e) Public data: It is the data classified as such according to the mandates of the law or the Political Constitution and that which is not semi-private, private or sensitive. Public are, among others, data relating to the marital status of people, their profession or trade, their status as a merchant or public servant and those that can be obtained without any reservation. Due to its nature, public data may be contained, among others, in public records, public documents, official gazettes and bulletins;
f) Private data: It is the data that, due to its intimate or reserved nature, is only relevant to the owner;
g) Sensitive data: Sensitive data is understood to be data that affects the privacy of the Owner or whose improper use may generate discrimination, such as data that reveals racial or ethnic origin, political orientation, religious or philosophical convictions, membership of unions, social organizations, human rights organizations or that promote the interests of any political party or that guarantee the rights and guarantees of opposition political parties, as well as data related to health, sexual life and biometric data;
h) Data Processor: Natural or legal person, public or private, who, by themselves or in association with others, carries out the Processing of personal data on behalf of the Data Controller;
i) Responsible for the Treatment: Natural or legal person, public or private, who alone or in association with others, decides on the database and/or the Processing of the data;
j) Owner: Natural person whose personal data is the subject of Treatment;
k) Treatment: Any operation or set of operations on personal data, such as collection, storage, use, circulation or deletion thereof.

 

3. PURPOSE FOR WHICH THE COLLECTION OF PERSONAL DATA AND THE PROCESSING OF THE SAME IS CARRIED OUT BY SABAJÓN APOLO S.A. MAY USE PERSONAL DATA TO:
a) Execute the existing contractual relationship with its clients, suppliers and workers, including the payment of contractual obligations;
b) Provide the services required by its users;
c) Inform about new services and/or changes in them;
d) Evaluate the quality of the service;
e) Carry out internal studies on consumer habits;
f) Send to physical, electronic mail, cell phone or mobile device, via text messages (SMS and/or MMS) or through any other analog and/or digital means of communication created or to be created, commercial, advertising or promotional information about the products and/or services, events and/or promotions of a commercial or non-commercial nature, in order to promote, invite, direct, execute, inform and in general, carry out campaigns, promotions or contests of a commercial nature or advertising, advanced by SABAJÓN APOLO SA and/or by third parties;
g) Develop the selection, evaluation, and job placement process;
h) Support internal or external audit processes;
i) Register the information of employees and/or pensioners (active and inactive) in the databases of SABAJÓN APOLO SA
i) Those indicated in the authorization granted by the data owner or described in the respective privacy notice, as the case may be;
j) Provide, share, send or deliver your personal data to affiliated, linked, or subordinate companies of SABAJÓN APOLO SA located in Colombia or any other country in the event that said companies require the information for the purposes indicated here. Regarding the data i) collected directly at the security points,
(ii) taken from the documents that people provide to security personnel and
(iii) obtained from video recordings that are made inside or outside the facilities of SABAJÓN APOLO SA, these will be used for security purposes of the people, property and facilities of SABAJÓN APOLO SA and may be used as evidence in any type of process. If personal data is provided, said information will be used only for the purposes indicated here, and therefore, SABAJÓN APOLO SA will not proceed to sell, license, transmit, or disclose it, unless: (i) there is express authorization to do so ; (ii) is necessary to allow contractors or agents to provide the entrusted services; (iii) is necessary in order to provide our services and/or products; (iv) it is necessary to disclose it to the entities that provide marketing services on behalf of SABAJÓN APOLO SA or to other entities with which there are joint market agreements; (v) the information is related to a merger, consolidation, acquisition, divestiture, or other corporate restructuring process; (vi) that is required or permitted by law. SABAJÓN APOLO SA may subcontract third parties for the processing of certain functions or information. When the processing of personal information is actually outsourced to third parties or personal information is provided to third party service providers, SABAJÓN APOLO SA warns said third parties about the need to protect said personal information with appropriate security measures, the use of the information is prohibited. for your own purposes and you are requested not to disclose personal information to others.

 

4.PRINCIPLES APPLICABLE TO THE PROCESSING OF PERSONAL DATA
The processing of personal data at SABAJÓN APOLO S.A. will be governed by the following principles:
a) Principle of purpose: The Processing of the personal data collected must obey a legitimate purpose, which must be informed to the Owner;
b) Principle of freedom: Treatment can only be carried out with the prior, express and informed consent of the Owner. Personal data may not be obtained or disclosed without prior authorization, or in the absence of a legal or judicial mandate that requires consent;
c) Principle of truthfulness or quality: The information subject to Treatment must be truthful, complete, exact, updated, verifiable and understandable. The Processing of partial, incomplete, fragmented or misleading data will not be carried out;
d)Principle of transparency: In the Treatment, the right of the Owner to obtain from SABAJÓN APOLO SA at any time and without restrictions, information about the existence of data that concerns him or her must be guaranteed;
e) Principle of restricted access and circulation: Treatment is subject to the limits derived from the nature of the personal data, the provisions of this law and the Constitution. Personal data, except public information, and the provisions of the authorization granted by the data owner, may not be available on the Internet or other means of dissemination or mass communication, unless access is technically controllable to provide restricted knowledge only. to the Owners or authorized third parties;
f) Security principle: The information subject to Processing by SABAJÓN APOLO SA must be protected through the use of the technical, human and administrative measures that are necessary to provide security to the records, preventing 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 confidentiality of the information, even after their relationship with any of the tasks included in the Processing has ended. FIRST PARAGRAPH: In the event that sensitive personal data is collected, the Owner may refuse to authorize the Treatment of it.

 

5. RIGHTS OF THE HOLDERS OF PERSONAL DATA SUBJECT TO PROCESSING BY SABAJÓN APOLO S.A.
the owners of personal data themselves or through their representative and/or attorney-in-fact or their successor in title may exercise the following rights, with respect to the personal data that they are subject to processing by SABAJÓN APOLO SA:
a) Right of access: By virtue of which you may access the personal data that is under the control of SABAJÓN APOLO SA, for the purposes of consulting them free of charge at least once every calendar month, and whenever there are substantial modifications to the Information Treatment Policies that motivate new queries;
b) Right to update, rectification and deletion: Under which you may request the updating, rectification and/or deletion of the personal data being processed, in such a way that the purposes of the processing are satisfied;
c) Right to request proof of authorization: except in events in which, according to current legal regulations, authorization is not required 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 Superintendence of Industry and Commerce.
FIRST PARAGRAPH: For the purposes of exercising the rights described above, both the owner and the person who represents him or her must demonstrate their identity and, if applicable, the capacity by virtue of which they represent the owner.
SECOND PARAGRAPH: The rights of minors will be exercised through the people who are authorized to represent them.

 

6. DUTIES OF SABAJÓN APOLO S.A.
All those obliged to comply with this policy must keep in mind that SABAJÓN APOLO SA is obliged to comply with the duties imposed by law in this regard. Consequently, the following obligations must be met:
A. Duties when acting as responsible: (i) Request and keep, under the conditions provided in this policy, a copy of the respective authorization granted by the owner. (ii) Inform the owner clearly and sufficiently about the purpose of the collection and the rights granted to him by virtue of the authorization granted. (iii) Inform, at the request of the owner, about the use given to their personal data (iv) Process the queries and claims formulated 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 (vi)-Keep the information under the security conditions necessary to prevent its adulteration, loss, consultation, unauthorized or fraudulent use or access. (vii) Update information when necessary. (viii) Rectify personal data when appropriate.
B. Duties when acting as Personal Data Processor. If you carry out data processing on behalf of another entity or organization (Data Controller), you must comply with the following duties: (i) Establish that the Data Controller is authorized to provide the personal data that will be processed as Processor (ii) Guarantee the owner, at all times, the full and effective exercise of the right of habeas data. (iii) Keep the information under the security conditions necessary to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access. (iv) Timely update, rectify or delete the data. (v) Update the information reported by the Data Controllers within five (5) business days from receipt.
(vi) Process queries and claims made by the owners in the terms indicated in this policy.
(vii) Register in the database the legend “claim in process” in the manner established in this policy. (ix) Insert into the database the legend “information under judicial discussion” once notified by the competent authority about judicial processes related to the quality of personal data. (x) Refrain from circulating information that is being controversial by the owner and whose blocking has been ordered by the Superintendency of Industry and Commerce. (xi) Allow access to the information only to people authorized by the owner or empowered by law for this purpose. (xii) Inform the Superintendency of Industry and Commerce when violations of security codes occur and there are risks in the administration of the owners’ information.
C. Duties when processing through a Processor (i) Provide the Processor with only the personal data whose processing is previously authorized. For the purposes of the national or international transmission of data, a contract for the transmission of personal data must be signed or contractual clauses agreed upon as established in article 25 of decree 1377 of 2013.
(ii) Guarantee that the information provided to the Data Processor is true, complete, accurate, updated, verifiable and understandable. (iii) Communicate in a timely manner to the Data Processor all the news regarding the data that you have previously provided and adopt the other necessary measures so that the information provided to it remains updated. (iv) Inform the Data Processor in a timely manner of the rectifications made to the personal data so that he or she can proceed to make the pertinent adjustments. (v) Demand that the Data Processor, at all times, respect the security and privacy conditions of the owner’s information. (vi) Inform the Data Processor when certain information is under discussion by the owner,
D. Duties regarding the Superintendency of Industry and Commerce (i) Inform it of possible violations of security codes and the existence of risks in the administration of the owners’ information. (ii) Comply with the instructions and requirements issued by the Superintendence of Industry and Commerce.

 

7. REQUEST FOR AUTHORIZATION FROM THE OWNER OF THE PERSONAL DATA
In advance and/or at the time of collecting the personal data, SABAJÓN APOLO SA will request the owner of the data for authorization to carry out its collection and processing, indicating the purpose for which it is requested. the data, using for these purposes automated technical means, written or oral, that allow preserving proof of the authorization and/or the unequivocal conduct described in article 7 of Decree 1377 of 2013. Said authorization will be requested for as long as is reasonable. and necessary to satisfy the needs that gave rise to the request for the data and, in any case, in compliance with the legal provisions that govern the matter.

 

8. PRIVACY NOTICE
In the event that SABAJÓN APOLO SA cannot make this information processing policy available to the owner of the personal data, it will publish the privacy notice attached to this document, the text of which will be kept for consultation. subsequently by the owner of the data and/or the Superintendency of Industry and Commerce.

 

9. TEMPORATY LIMITATIONS ON THE PRECESSING OF PERSONA DATA. SABAJÓN APOLO S.A. may only collect, store, use or circulate personal data for as long as is reasonable and necessary, in accordance with the purposes that justified the treatment, taking into account the provisions applicable to the matter in question and the administrative aspects, accounting, fiscal, legal and historical information. Once the purpose(s) of the processing have been fulfilled and without prejudice to legal regulations that provide otherwise, the personal data in its possession will be deleted. Notwithstanding the above, personal data must be preserved when required to comply with a legal or contractual obligation.

 

10. AREA RESPONSIBLE AND PROCEDURE FOR THE EXERCISE OF THE RIGHTS OF THE OWNERS OF THE PERSONA DATA
The ACCOUNTING AREA of SABAJÓN APOLO SA will be responsible for addressing the requests, complaints and claims formulated by the owner of the data in the exercise of the rights contemplated in the numeral 5 of this policy, except for that described in literal e). For these purposes, the owner of the personal data or whoever acts as his representative may send his request, complaint or claim from Monday to Friday from 8:00 am to 5:00 pm to the email info@sabajonapolo.com.co, call the telephone line of SABAJÓN APOLO SA, Bogotá telephone (1) 7434600, or file it at the following address corresponding to our offices OFFICE ADDRESS Bogotá CR 23 N° 76-71.
The request, complaint or claim must contain the identification of the Owner, 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 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 he has withdrawn the claim. In the event that the person receiving 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. in 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.

 

11. DATA COLLECTED BEFORE THE ISSUANCE OF DECREE 1377 OF 2013
In accordance with the provisions of paragraph 3 of article 10 of Regulatory Decree 1377 of 2013 SABAJÓN APOLO SA will proceed to publish a notice on its official website www.casaapolo.co directed to the holders of personal data for the purposes of making known this information processing policy and how to exercise their rights as holders of personal data hosted in the databases of SABAJÓN APOLO SA.

 

12. SECURITY MEASURES
In development of the security principle established in Law 1581 of 2012, SABAJÓN APOLO SA will adopt the technical, human and administrative measures that are necessary to provide security to the records, preventing their adulteration, loss, consultation, use or access. unauthorized or fraudulent. The personnel who process personal data will execute the established protocols in order to guarantee the security of the information.

 

13. EFFECTIVE DATE
This Personal Data Policy was created on October 31, 2016 and comes into force as of November 4, 2016. Any change that occurs with respect to this policy will be informed to through the electronic address: www.casaapolo.co

 

Sincerely,

SABAJÓN APOLO SA

ADDRESS: CR 23 N° 76-71 Bogotá.

NOTICE OF PRIVACY

RESPONSIBLE FOR THE TREATMENT: SABAJÓN APOLO SA

ADDRESS: CR 23 N° 76-71 Bogotá

EMAIL: info@sabajonapolo.com.co

PHONE LINE: 7434600

 

PURPOSE FOR WHICH THE COLLECTION OF PERSONAL DATA AND THE PROCESSING OF THE SAME IS CARRIED OUT:

SABAJÓN APOLO SA may use personal data to: a) Execute the existing contractual relationship with its clients, suppliers and workers, including the payment of contractual obligations; b) Provide the services and/or products required by its users;
c) Inform about new products or services and/or changes in them; d) Evaluate the quality of the service; e) Carry out internal studies on consumer habits; f) Send to physical, electronic mail, cell phone or mobile device, via text messages (SMS and/or MMS) or through any other analog and/or digital means of communication created or to be created, commercial, advertising or promotional information about the products and/or services, events and/or promotions of a commercial or non-commercial nature, in order to promote, invite, direct, execute, inform and in general, carry out campaigns, promotions or contests of a commercial nature or advertising, advanced by SABAJÓN APOLO SA. and/or by third parties; g) Develop the selection, evaluation, and labor connection; h) Support internal or external audit processes; i) Register the information of employees and/or retirees (active and inactive) in the databases of SABAJÓN APOLO SA. i) Those indicated in the authorization granted by the data owner or described in the respective privacy notice, as the case may be; j) Provide, share, send or deliver your personal data to affiliated, linked, or subordinate companies of SABAJÓN APOLO SA located in Colombia or any other country in the event that said companies require the information for the purposes indicated here. Regarding the data (i) collected directly at the security points, (ii) taken from the documents provided by people to security personnel and (iii) obtained from video recordings that are made inside or outside the facilities of SABAJÓN APOLO SA., these will be used for personal security purposes, the goods and facilities of SABAJÓN APOLO SA. and may be used as evidence in any type of process. If personal data is provided, said information will be used only for the purposes indicated here, and therefore, SABAJÓN APOLO SA. will not proceed to sell, license, transmit, or disclose it, unless: (i) there is express authorization to do so; (ii) is necessary to allow contractors or agents to provide the entrusted services; (iii) is necessary in order to provide our services and/or products; (iv) it is necessary to disclose it to the entities that provide marketing services on behalf of SABAJÓN APOLO SA. or to other entities with which there are joint market agreements; (v) the information is related to a merger, consolidation, acquisition, divestiture, or other corporate restructuring process; (vi) that is required or permitted by law. SABAJÓN APOLO SA may subcontract third parties for the processing of certain functions or information. When the processing of personal information is actually outsourced to third parties or personal information is provided to third party service providers, SABAJÓN APOLO SA warns said third parties about the need to protect said personal information with appropriate security measures, the use of the information is prohibited. for your own purposes and you are requested not to disclose personal information to others. RIGHTS OF THE OWNERS OF PERSONAL DATA: The owners of personal data by themselves or through their representative and/or attorney-in-fact or their successor in title may exercise the following rights, with respect to the personal data that are subject to processing by SABAJÓN APOLO SA : warns such third parties about the need to protect such personal information with appropriate security measures, prohibits the use of the information for their own purposes and requests that they not disclose the personal information to others. RIGHTS OF THE OWNERS OF PERSONAL DATA: The owners of personal data by themselves or through their representative and/or attorney-in-fact or their successor in title may exercise the following rights, with respect to the personal data that are subject to processing by SABAJÓN APOLO SA : warns such third parties about the need to protect such personal information with appropriate security measures, prohibits the use of the information for their own purposes and requests that they not disclose the personal information to others. RIGHTS OF THE OWNERS OF PERSONAL DATA: The owners of personal data by themselves or through their representative and/or attorney-in-fact or their successor in title may exercise the following rights, with respect to the personal data that are subject to processing by SABAJÓN APOLO SA:

a) Right of access: By virtue of which you may access the personal data that is under the control of SABAJÓN APOLO SA, for the purposes of consulting them free of charge at least once every calendar month, and whenever there are substantial modifications to the Information Treatment Policies that motivate new queries;

b) Right to update, rectification and deletion: Under which you may request the updating, rectification and/or deletion of the personal data being processed, in such a way that the purposes of the processing are satisfied;

c) Right to request proof of authorization: except in events in which, according to current legal regulations, authorization is not required to carry out the treatment;

d) Right to be informed regarding the use of personal data; Right to file complaints with the Superintendency of Industry and Commerce: for violations of the provisions of current regulations on the processing of personal data;

e) Right to require compliance with orders issued by the Superintendence of Industry and Commerce.

 

PERSONAL DATA PROCESSING POLICY
It can be consulted at the following address: www.casaapolo.co. Any change that occurs with respect to this policy will be reported through the electronic address: www.casaapolo.co.
In the event that sensitive personal data is collected, the Owner may refuse to authorize its Treatment.
The ACCOUNTING AREA of SABAJÓN APOLO SA will be responsible for addressing the requests, complaints and claims formulated by the data owner in exercise of the rights contemplated in section 5 of the personal data processing policy, with the exception of that described in its literal. and). For these purposes, the owner of the personal data or whoever acts as his representative may send his request, complaint or claim from Monday to Friday from 8:00 am to 5:00 pm to the email info@sabajonapolo.com.co, call the telephone line in Bogotá 7434600, or file it at the following address, corresponding to our offices: CR 23 N° 76-71 Bogotá.

 

Sincerely,

SABAJÓN APOLO SA

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