PERSONAL DATA PROCESSING POLICY
KEYWORDS
Privacy Notice: Es un physical document, electronic or in any other format known or to be known, which is physical document, electronic or in any other format known or to be known, which is is -136bad5cf58d_puesto tú disposición para el tratamiento de tus Datos Personales.
Authorization: It is the prior, express and informed consent that you give us to carry out the Processing of Personal Data, in accordance with the purposes and under the terms of this Privacy and Personal Data Protection Policy.
Database: It is the organized set of Personal Data in digital, electronic or physical means, object of Treatment.
Successor in title: Person who by succession or transmission acquires the rights of another person.
Personal Data: Any information linked to or that may be associated with one or more specific or determinable natural persons.
Dato Personal Privado: Es la información que solo te concierne a ti, que tiene una naturaleza reservada.
Sensitive Personal Data: These are personal data that affect tu privacy, such as those that reveal racial discrimination or ethnic, 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 guarantees the rights and guarantees of opposition political parties, as well as the relative data to health, sex life, and biometric data.
Public Data: This is data that is not private, semi-private or sensitive. Data relating to the marital status of individuals, their profession or trade and their quality as a merchant or public servant are considered public data. Due to its nature, public data may be contained, among others, in public registries, public documents, gazettes, official bulletins and duly executed judicial sentences that are not subject to reservation.
Responsible for the Treatment: Natural or legal person, public or private, who by himself or in association with others, decides on the database and/or the Treatment of the data
Person in Charge of Treatment: Natural or legal person, public or private, who by himself or in association with others, carries out the Treatment of personal data on behalf of the Person in Charge of Treatment.
Habeas Data: It is the right that you have to know, update and rectify the information that has been collected about_cc78-3b194-bb194-de-cc78 136bad5cf58d_ti in files and databases of a public or private nature.
Holder: It is you!, a natural person whose Personal Data is subject to Treatment.
Transfer: It is the sending of Personal Data by a Person in Charge and/or Person in Charge of the Processing of Personal Data located in Colombia to a Person in Charge of the Treatment who is inside or outside the country.
Treatment: Any operation or set of operations on personal data, such as the collection, storage, use, circulation or deletion
Transmission: It is the Processing of Personal Data that implies the communication of those, inside or outside the territory of Colombia, carried out by the Manager on behalf of the Responsible.
WHAT IS YOUR GOAL?
The Political Constitution of Colombia in its article 15, law 1581 of 2012, decree 1377 of 2013, and other concordant regulations, CAMINO DE CAFÉ SAS establishes and publishes its policy for the treatment of personal data contained in the databases that collect in the development of its commercial activity, as well as the mechanisms for protection, administration and attention to petitions, complaints or claims tuyos with observance of the applicable legal norms.
SCOPE
This policy applies to all personal databases that are in the custody of CAMINO DE CAFÉ SAS and any Manager who may carry out any type of treatment in nombre tuyo. Similarly, the policy is addressed to the owners of the data contained in these databases, including but not limited to customers, potential customers, suppliers, employees, among others.
WHO RESPOND?
The person responsible for the treatment of the databases object of this policy is CAMINO DE CAFÉ SAS whose contact details are the following:
ADDRESS: CALLE 111 No. 13-08
CONTACT PERSON: ALEJANDRO OSPINA
PHONE: +57 350 3425296
EMAIL: info@travesiacoffee.com
NIT: 901.028.136-3
BEGINNING
For the proper treatment of personal databases, adjusted to current regulations, the following principles will be applied:
Principle of legality in matters of Data Processing: The Treatment referred to in this law is a regulated activity that must be subject to what is established in it and in the other provisions that develop it._cc781905- 5cde-3194-bb3b-136bad5cf58d_
Principle of purpose: The Treatment must obey a legitimate purpose in accordance with the Constitution and the Law, which you must be informed.
Principle of freedom: The Treatment can only be exercised with the prior, express and informed consent on your part. Personal data may not be obtained or disclosed without prior authorization, or in the absence of a legal or judicial mandate that relieves consent.
Principle of veracity or quality: The information subject to Treatment must be truthful, complete, exact, updated, verifiable and understandable. The Treatment of partial, incomplete, fragmented or misleading data is prohibited.
Principle of transparency: In the Treatment it must be guaranteed your right to obtain from the Treatment Manager or the Treatment Manager, at any time and without restrictions, information about the existence of data that concerns you.
Principle of access and restricted circulation: The Treatment is subject to the limits that derive from the nature of personal data, the provisions of this law and the Constitution. In this sense, the Treatment may only be carried out by persons authorized by ti and/or by the persons provided for in this law. Personal data, except public information, may not be available on the Internet or other means of disclosure or mass communication, unless access is technically controllable to provide restricted knowledge only a ti_cc781905-5cde-3194 -bb3b-136bad5cf58d_or authorized third parties in accordance with this law.
Security principle: The information subject to Treatment by the Treatment Manager or Treatment Manager referred to in this law, must be handled with the 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.
Confidentiality principle: All persons involved in the processing of personal data that are not of a public nature are obliged to guarantee the confidentiality of the information, even after the end of their relationship with any of the tasks that includes the Treatment, being able to only carry out supply or communication of personal data when it corresponds to the development of the activities authorized in this law and in the terms of the same.
WHAT ARE WE GOING TO USE YOUR DATA FOR?
In carrying out its main activity, CAMINO DE CAFÉ SAS collects data aimed at fulfilling the following purposes:
Keep in touch with you to inform you about events, services, programs, campaigns and content related to the activities that we develop for our_31819s0cc5c9de-5-cc7819s0cc7819s0cc7819s bb3b-136bad5cf58d_different audiences, in order to maintain a close and reliable link with each one.
Serve administrative and informational purposes.
Offer you all kinds of commercial services; as well as carry out promotional, marketing, advertising and contest campaigns.
Provide information on events, services and workshops.
Comply with the obligations imposed by Colombian labor law.
Comply with obligations contracted with people linked directly or indirectly with CAMINO DE CAFÉ SAS
Issue certifications related to the relationship of the owner of the data with the Person.
Manage the functions performed by workers.
Contact authorized persons in emergencies.
Inform you about blog posts or new information published on social networks or on the website.
Communicate about any relevant, new or interesting information.
Segmentar a nuestros suscriptores para analizar sus datos and behaviors.
Carry out all the necessary activities for the development of the economic activity of CAMINO DE CAFÉ SAS
Properly provide the contracted services, as well as keep you informed about the progress, status and other issues related to the contracted activity.
Perform all activities necessary to properly execute existing contracts with workers, suppliers, customers and other business contacts.
Maintain efficient communication of information that is useful for the development and fulfillment of existing contracts with workers, suppliers, customers and other business contacts.
Keep our clients and allies informed on current issues related to their market and the development of their corporate purpose.
Carry out the administrative procedures associated with the development of the economic activity of CAMINO DE CAFÉ SAS
Send you commercial information about the activities carried out by CAMINO DE CAFÉ SAS on the launch of new products or services.
Improve the navigability content of the website, as well as ensure compliance with its terms and conditions.
Send you communications by physical mail, electronic mail, mobile device, or through any other analog and/or digital means of communication with commercial, advertising or promotional information about services, events, promotions, campaigns and/or contests of a commercial or advertising nature, advanced by CAMINO DE COFFEE SAS
Contact you in case of complaints, claims or suggestions about the CAMINO DE CAFÉ SAS service
Carry out satisfaction campaigns, monitor the provision of our services and evaluate the quality of the services provided by us.
Develop selection, evaluation, and employment processes.
Contact and hire suppliers of products or services that CAMINO DE CAFÉ SAS needs for the development of its activities; as well as making necessary requests to report the tax information related to those.
Submit information to control and surveillance authorities and support internal or external audit processes.
Perform statistical studies or accounting processes.
Perform searches for closer knowledge with all its users, suppliers, employees and linked third parties.
Advance agreements, events or institutional programs directly or in association with third parties.
Carry out georeferencing activities and statistical studies
Develop projects of innovation, creation, generation, appropriation, advice and adaptation of business strategies, as well as the creation and support of entrepreneurship units, brands and companies.
Transmit the information to third parties in order to develop the purposes described here.
OUR COMMITMENT TO PRIVACY AND SECURITY
CAMINO DE CAFÉ SAS is committed to the confidentiality and privacy of Personal Data stored in our Databases, under access and availability restrictions, preventing consultation by unauthorized third parties.
Based on the foregoing, CAMINO DE CAFÉ SAS guarantees that your Personal Data will be protected under typical industry standard conditions, protected under industry standard conditions adulteration, loss, theft, public consultation, unauthorized or fraudulent use or access, as well as the implementation of internal practices that contribute to a secure information environment.
OUR DUTY
CAMINO DE CAFÉ SAS as Responsible for the Processing of personal data, will comply_with the following duties:
Guarantee, at all times, the full and effective exercise of the right of habeas data.
Request and keep, under the conditions provided by law, a copy of the respective authorization granted by ti.
Inform you duly about the purpose of the collection and the rights that assist you by virtue of the authorization that you gave us.
Keep the information under the necessary security conditions to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access.
Guarantee that the information provided to the Treatment Manager is true, complete, accurate, updated, verifiable and understandable.
Provide the Person in Charge of Treatment, as the case may be, only data whose Treatment is previously authorized in accordance with the provisions of this law.
Require the Treatment Manager at all times to respect the security and privacy conditions of the Holder's information.
Process queries and claims formulated in the terms indicated in Law 1581 of 2012.
Inform the Person in Charge of Treatment when certain information is under discussion by the Holder, once the claim has been filed and the respective procedure has not been completed.
Inform you, prior to the request, about the treatment given to your data.
Inform the data protection authority when there are violations of the security codes and there are risks in the administration of the Holders' information.
Comply with the instructions and requirements issued by the Superintendence of Industry and Commerce.
YOUR PERMISSION
The authorization may consist of a physical or electronic document, a data message, websites, in any other format that guarantees its subsequent consultation, or through a suitable technical or technological mechanism, which allows expressing or obtaining consent via click or double click. , through which it can be unequivocally concluded that if you did not give us permission, the data would never have been captured and stored in the database.
The authorization will be generated by CAMINO DE CAFÉ SAS and will be made available to you in advance and prior to the processing of your personal data. The collection of data will be limited to those that are pertinent and adequate for the purpose for which they are collected or required in accordance with current regulations, meeting the needs of the company for the development of its corporate purpose. Except in the cases expressly provided for by law, personal data may not be collected without your authorization.
By accepting this policy, any holder who supplies or facilitates information regarding their personal data, will be consenting to their treatment by CAMINO DE CAFÉ SAS under the terms and conditions indicated in the regulation, that is, directly , express and unequivocal.
YOUR RIGHTS
Any process that involves the treatment by CAMINO DE CAFÉ SAS of personal data of both users, suppliers, employees and in general any third party with which it maintains commercial and labor relations, must take into account the rights that_cc781905-5cde-3194-bb3b -136bad5cf58d_te assist you, which are listed below:
Know, update, rectify and consult your personal data at any time in front of CAMINO DE CAFÉ SAS or those in charge of data processing. This right may exercer, among others, against partial, inaccurate, incomplete, fractional, misleading data, or those whose Treatment is expressly prohibited or has not been authorized .
Request proof of the authorization granted to CAMINO DE CAFÉ SAS, or any other signed by the owner of the Personal Data for this purpose, except when expressly excepted as a requirement for Data Processing in accordance with the law.
Be informed by CAMINO DE CAFÉ SAS or the person in charge of the treatment, prior request of the owner of the data, regarding the use that has been given to them.
Submit complaints to the Competent Authority for violations of the provisions of the law and other regulations that modify, add or complement it, to assert their right to Habeas Data against the company.
Revoke the authorization and/or request the deletion of the data when the principles, rights and constitutional and legal guarantees are not respected in the Treatment. The revocation and/or deletion will proceed when the Superintendence of Industry and Commerce has determined that in the Treatment the Person in Charge has incurred in conduct contrary to Law 1581 of 2012 and the Constitution.
Free access to Personal Data that has been subject to Processing, for which the company is responsible for safely and reliably conserving and archiving the duly granted authorization forms of each of the personal data holders.
PASOS FOR THE ATTENTION OF INQUIRIES, CLAIMS AND REQUESTS
Consultas Los Titulares o sus causahabientes: podrán consultar tu información personal que repose en CAMINO DE CAFÉ SAS_cc781905-5cde -3194-bb3b-136bad5cf58d_, who will be in charge of supplying all the information contained in the individual record or that is linked to tu identification. The query, once received by the entity, will be answered within a maximum term of ten (10) business days from the date of receipt of the query. When it is not possible to attend the query within said term, you will be informed, stating the reasons for the delay and indicating the new date on which such query will be attended, which in no case may exceed five (5) business days following the expiration of the first term.
Claims The Holder or his successors in title: who consider that the information contained in a database should be corrected, updated or deleted, or when they notice the alleged breach of any of the duties contained in this law, they may file a claim before CAMINO DE CAFÉ SAS which will be processed under the following rules:
a) El reclamo se formulará mediante comunicación escrita dirigida a CAMINO DE CAFÉ SAS_cc781905-5cde-3194 -bb3b-136bad5cf58d_con your identification, the description of the facts that give rise to the claim, the address, and accompanying the documents that you want to assert to the email info@ travesiacoffee .com . If the claim is incomplete, the interested party will be required within five (5) days after receipt of 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 CAMINO DE CAFÉ SAS receives a Claim for which it is not competent to resolve it, the company will transfer it to the appropriate person; a legal professional or when CAMINO DE CAFÉ SAS is a person in charge, he or she will transfer the person in charge, within a maximum term of two (2) business days_cc781905-5cde-3194- bb3b-136bad5cf58d_and you will be informed.
b) Una vez recibido el reclamo completo, la entity will include in the respective database a legend that says "claim in process" and the reason for it, in a term not exceeding two (2) business days. The company will keep said legend in the data under discussion until the claim is decided.
c) El término máximo para atender el reclamo será fifteen (15) business days counted from the day following the date of receipt. Cuando no fuere posible atender el reclamo dentro de dicho término, nosotros te informaremos los motivos de la demora and the new date on which it will be attended tu claim, which in no case may exceed eight (8) business days first term.
Procedural Requirement The Holder or his successor in title: may only file a complaint with the Superintendency of Industry and Commerce once the Consultation or Claim process has been completed directly with us._cc781905 -5cde-3194-bb3b-136bad5cf58d_
Request for updating and/or rectification: CAMINO DE CAFÉ SAS, will rectify and update, at your request, the information that is inaccurate or incomplete, according to the procedure and the terms indicated above, for which tu you must submit the request according to the channels provided by the company, indicating the updating and rectification of the data and in turn must provide the documentation to support such a request.
Revocation of the authorization and/or deletion of the Data: you can revoke the consent at any time o authorization given treatment -3194-bb3b-136bad5cf58d_your personal data, as long as there is no impediment enshrined in a legal or contractual provision. Likewise, you have the right to request at any time a CAMINO DE CAFÉ SAS, to the e-mail info@travesia_coffe78.com905coffe- 136bad5cf58d_info @travesia_coffe78.com905coffe-136bad5cf58d_ 5cde-3194-bb3b-136bad5cf58d_the suppression or deletion of your personal data when:
You consider that they are not being treated in accordance with the principles, duties and obligations set forth in current regulations.
They are no longer necessary or relevant for the purpose for which they were obtained.
The time necessary for the fulfillment of the purposes for which they were obtained has been fulfilled. Such suppression implies the total or partial elimination of the personal information, in accordance with your request por in the records, files, databases or treatments carried out by_cc781905-5cde-3194-bb3b- 136bad5cf58d_CAMINO DE CAFÉ SAS The cancellation right is not absolute and therefore CAMINO DE CAFÉ SAS, may deny revocation of authorization or deletion of personal data in the following cases:
When you have a legal or contractual duty to remain in the database.
When the elimination of data hinders judicial or administrative actions related to tax obligations, the investigation and prosecution of crimes or the updating of administrative sanctions.
When the data is necessary to protect nuestros legally protected interests; to carry out an action based on the public interest, or to comply with an obligation legally acquired by Mentoia.
WHAT ABOUT MINORS DE AGE?
CAMINO DE CAFÉ SAS does not process the Personal Data of minors. However, at the time it does so, CAMINO DE CAFÉ SAS will guarantee respect for the rights of children and adolescents, which prevail in any case, and will collect in all cases the respective authorization for their treatment granted by the legal representative of minor holders.
CREATION DATE
This Policy is effective as of March 10, 2016.
EXPIRATION DATE
Indefinite until all the purposes established in the data use policy are fulfilled.