GENERAL INFORMATION AND PERSONAL DATA MANAGEMENT POLICY GENTE COMPETENTE SA

 

The society GENTE COMPETENTE SA, in his capacity as person responsible for the processing of personal data, in compliance with the provisions of Law 1581 of 2012 and in attention to the corporate commitment to respect the HABEAS DATA, As a constitutional right, guaranteeing that the holders of the information can know, rectify, update or request the elimination of said information, it formulates the following information and personal data management policy:

  1. INFORMATION AND PERSONAL DATA

The personal data requested for the execution of the business activity of GENTE COMPETENTE SA, Provided by its clients, employees, suppliers, strategic allies and collaborators, considered as private data and information not available to the public are:

  • Full Names / Company name.
  • Type and number of identification document (Natural or legal personnel).
  • Date of birth and gender.
  • Fixed and mobile phone numbers (Personal or Work).
  • Emails.
  • Social networks.
  • Addresses
  • Data of strategic allies, employees and collaborators necessary for the development of our corporate purpose.
  • Personal preferences.
  • Personal experiences.
  • Biometric data.
  • Personal event data.
  • Profession or trade data.
  • Data contained in the curriculum vitae. 
  1. PURPOSE

The personal data requested by GENTE COMPETENTE SA will be collected, stored, put into circulation, deleted and used internally exclusively for the development of the company's corporate purpose, by virtue of commercial, contractual, legal relationships, as well as any other that may arise in the development and execution of these , in accordance with current regulatory parameters. The data in question will be used in turn to keep historical records of the company and maintain contact with the holders of personal data or validate the veracity of the data provided.

  1. INFORMATION OBTAINING MECHANISM

The personal data that is the object of this policy may be obtained through any legal means, with the prior knowledge and authorization of the owners of the confidential information. Said information will be requested with the intention of developing the company's corporate purpose.

  1. DUTIES OF THOSE RESPONSIBLE AND IN CHARGE OF THE PROCESSING OF PERSONAL DATA

A. Those responsible for the treatment must fulfill the following duties:

  1. Guarantee the Holder, at all times, the full and effective exercise of the right to habeas data.
  2. Request and keep a copy of the respective authorization granted by the Owner.
  3. Properly inform the Holder about the purpose of the collection and the rights that assist him by virtue of the authorization granted.
  4. Keep the information under the necessary security conditions to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access.
  5. Guarantee that the information provided to the Person in Charge of Treatment is true, complete, exact, updated, verifiable and understandable.
  6. Update the information, communicating in a timely manner to the Treatment Manager, 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 up to date.
  7. Rectify the information when it is incorrect and communicate the pertinent to the Person in Charge of Treatment.
  8. Provide the Treatment Manager, as the case may be, only data whose Treatment is previously authorized.
  9. Require the Treatment Manager, at all times, to respect the security and privacy conditions of the Owner's information.
  10. Process the queries and claims formulated in the terms indicated in this document.
  11. Adopt an internal manual of policies and procedures to guarantee adequate compliance with Law 1281/2012.
  12. Inform the Treatment Manager when certain information is under discussion by the Holder, once the claim has been submitted and the respective procedure has not been completed.
  13. Inform at the request of the Owner about the use given to their data;
  14. Inform the data protection authority when there are violations of the security codes and there are risks in the administration of the information of the Holders.
  15. Comply with the instructions and requirements issued by the Superintendency of Industry and Commerce.

B. Those in charge of the treatment must fulfill the following duties:

  1. Guarantee the Holder, at all times, the full and effective exercise of the right to habeas data.
  2. Keep the information under the necessary security conditions to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access.
  3. Timely update, rectify or delete the data under the terms of this law.
  4. Update the information reported by the Data Controllers within ten (10) business days from receipt.
  5. Process the queries and claims made by the Holders in the terms indicated in this policy.
  6. Adopt an internal manual of policies and procedures to guarantee adequate compliance with Law 1581/2012 and, especially, for the attention of inquiries and claims by the Holders;
  7. Register in the database the legend "claim in process" in the manner in which it is regulated in this policy.
  8. Insert in the database the legend "information in judicial discussion" once notified by the competent authority about judicial processes related to the quality of personal data.
  9. Refrain from circulating information that is being controversial by the Holder and whose blocking has been ordered by the Superintendency of Industry and Commerce.
  10. Allow access to information only to people who can have access to it.
  11. Inform the Superintendency of Industry and Commerce when there are violations of the security codes and there are risks in the administration of the information of the Holders.
  12. Comply with the instructions and requirements issued by the Superintendency of Industry and Commerce.
  13. RIGHTS OF THE HOLDERS OF PERSONAL DATA

The holders of the personal information supplied to GENTE COMPETENTE SA have the right to:

  1. Know, update, rectify your personal data in front of the Data Controller or the Data Controller.
  2. Request proof of the prior authorization given by the owner for data processing.
  3. File complaints with the Superintendence of Industry and Commerce for violations of the provisions of this law and the other regulations that modify, add or complement it.
  4. Revoke the authorization and / or request the deletion of personal data when in the Treatment the principles, rights, constitutional and legal guarantees of the owner are considered violated.

The holders of personal data may enforce their rights before GENTE COMPETENTE SA sending request to email info@competentpeople.com

The person in charge and / or in charge of data processing will respond to the request in a term not exceeding ten (10) business days. When it is not possible to attend the query within said term, the interested party will be informed, stating the reasons for the delay and indicating the date on which the query will be attended, which in no case may exceed five (5) business days after expiration. of the first term.

  1. CLAIMS PROCEDURE

The owner who considers that the information contained in a database should be subject to correction, updating or deletion, or when he / she notices the alleged breach of any of the duties contained in law 1581/2012, may file a claim with the Responsible for the Treatment or the Person in Charge of Treatment which will be processed under the following steps:

  1. The claim will be formulated by means of a request addressed to the Treatment Manager or the Treatment Manager, with 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 enforce. If the claim is incomplete, the interested party will be required within five (5) days after receiving the claim to correct the faults. 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. In the event that whoever receives the claim is not competent to resolve it, it will transfer it to the corresponding person within a maximum term of two (2) business days and will inform the interested party of the situation.
  1. Once the complete claim is received, a legend that says “claim in process” and the reason for this will be included in the database, within a term of no more than two (2) business days. This legend will remain until the claim is decided.
  2. The maximum term to attend the claim, once it is complete, will be fifteen (15) business days from the day following the date of receipt. When it is not possible to attend 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 will exceed eight (8) business days following the expiration of the first term. . 
  1. PRIOR AUTHORIZATIONS

The holders of the personal data supplied to GENTE COMPETENTE SA They must authorize through any means the Treatment of the data, including those that have been obtained on the occasion of labor and / or commercial relations between the parties, said information will have the treatment indicated in articles 5, 6 and 10 of Law 1581 of 2012, and 5, 6, and 10 of decree 1377 of 2013, the above taking into account that GENTE COMPETENTE SA You have the legal duty to issue the corresponding labor and / or commercial certifications in each case.

  1. RESPONSIBLE AND IN CHARGE OF THE PROCESSING OF PERSONAL DATA

GENTE COMPETENTE SA In your capacity as person responsible for the processing of personal data, through this policy you inform your identification data:

BUSINESS NAME:                  GENTE COMPETENTE SA

TIN:                                        No. 900299394-5

PRIMARY RESIDENCE:      CLL 4 SUR No 43 A - 195 OFFICE 258 El Poblado Executive Center - Medellín

PHONE:                          +57 4 268 35 87 - + 57 321 868 80 45

 

The agency in charge of the processing of personal data in application of this policy will be the administrative area, who will attend to requests, queries, claims through email info@competentpeople.com

Sincerely, 


__________________________

LEGAL REPRESENTATIVE

GENTE COMPETENTE SA