The company's personal data processing policy


Personal data processing policy


  • Object and scope.

  • In accordance with the provisions of article 13 of Decree 1377 of 2013, incorporated in article 2.2.2.25.3.1. of the Sole Regulatory Decree 1074 of 2015, it is the obligation of those responsible and those in charge of the processing of personal data to adopt a personal data processing policy to guarantee the rights of their owners in relation to the processing of the data.


    In application of the provisions contained in Law 1581 of 2012 and all its regulatory decrees, and primarily in article 15 of the Political Constitution of Colombia, which establishes that any person has the right to know, update and rectify personal data located in databases, Maguvi SAS (hereinafter the Responsible or Responsible) has adopted this Personal Data Processing Policy in order to guarantee the proper treatment of personal data that is contained or included in its databases or files.


    This Policy will apply to the treatment of personal and/or sensitive data that The Responsible party collects, manages and/or stores. This Policy and all other documents that are directly or indirectly related to the processing of personal data, will be abided by and complied with by the person designated by The Controller as the administrator of the processing of the data contained in their databases and/or files, as well as by third parties to whom personal information of the owners is transmitted or transferred, prior authorization granted by them.


    This Policy and all other documents that are directly or indirectly related to the processing of personal data are equally applicable, in their entirety, to all those events in which the Controller acts as Data Processor. . In such events, interpretations that compromise the legitimate interest and rights of the owners of the information will not be accepted when discussing the capacity in which The Responsible acts. For such purposes, in such cases the word "Responsible" is understood to be replaced by the word "In Charge" in this and all other documents related to the matter.

  • The responsible.

  • The person in charge is the commercial company Maguvi SAS, legally constituted before the Chamber of Commerce of Manizales, identified with NIT. 901130765-1. In its capacity as such, it has been incorporating in its different databases, personal information obtained through its different service channels and/or due to the relationships developed within the ordinary course of its economic activity.

     

    Through this Policy, the Controller establishes uniform practices for the collection, use, storage, updating, circulation, transfer, transmission and deletion, activities that will hereinafter be called "Treatment" of the information of all those people who have or have had relationship with The Responsible and that works in its databases or files.

  • Information of the Responsible.

  • In accordance with Article 13 of Decree 1377 of 2013, the Responsible establishes that he is in charge of the Treatment of the information that works in his databases and files. The contact details of the person in charge are the following:

    Home

    Manizales, Caldas, Colombia

    Address

    Vereda El Arenillo, Altamira House 1 Complex

    Email

    vvallejoarango@gmail.com


  • Treatment of the data and its purpose.

  • The personal data collected by The Responsible will be collected, stored, used, circulated, transmitted, transferred or deleted in accordance with the following guidelines:

  • Treatment of sensitive data.
  • Sensitive data is understood to be those that affect the privacy of the Owner or whose improper use may generate discrimination, such as those that reveal their racial or ethnic origin, their political orientation, their religious or philosophical convictions, their membership in unions, social organizations, of human rights or that promote the interests of any political party or that guarantee the rights and guarantees of opposition political parties, as well as their data related to health, their sexual life and biometric data, among others, the capture of still images or in movement, audio, fingerprints, photographs, iris, voice, facial or palm recognition, etc.

    This data may be used as long as:

    1. The Owner has given explicit authorization to said Treatment, except in cases where the granting of said authorization is not required by law.
    2. The Treatment is necessary to safeguard the vital interest of the Holder and he is physically or legally incapacitated. In these events, the legal representatives must grant said authorization.
    3. The Treatment is carried out in the course of legitimate activities and with due guarantees by a foundation, NGO, association or any other non-profit organization, whose purpose is political, philosophical, religious or union, provided that they refer exclusively to to its members or to people who maintain regular contact by reason of its purpose. In these events, the data may not be provided to third parties without the authorization of the Owner.
    4. The Treatment refers to data that is necessary for the recognition, exercise or defense of a right in a judicial process.
    5. The Treatment has a historical, statistical or scientific purpose. In this event, the measures leading to the suppression of the identity of the Holders must be adopted.

    The Holders of the information, in order to be able to consult it later, will grant express authorizations when the data collected and that is subject to Treatment consists of information considered sensitive. In any case, the Responsible will inform the Holders, through the authorization, the type of sensitive data that will be collected and what will be the purpose of its Treatment.


    In the databases and/or files of the Responsible, there is information from the Holders that, according to this section, are considered as sensitive data. Among the information stored there may be biometric data, union membership information, data related to health, judicial, disciplinary and/or fiscal records, and other similar data that are essential for due compliance with the following purposes:


    1. For legal matters and/or administrative procedures.
    2. Support conversations, dialogues, agreements, conditions, pacts and/or other similar activities, with associations, groups and/or union personnel.
    3. Manage, support, review and/or prepare all types of documents in which this type of information must be specified, for any reason.
    4. File and custody of this type of information.
    5. Matters related to internal security, especially, but not only, recordings with security, photographic and/or audio camera systems.
    6. Records of attendance at events, activities or programs advanced by The Responsible.
    7. Relationship and contracting with clients, suppliers and/or workers.
    8. For marketing purposes, campaigns and/or advertising guidelines.
    9. For customer profile studies
    10. To transmit or transfer the information of the owner with other managers and / or managers, for the purposes indicated here.

  • Treatment of personal data of minors.
  • The Processing of personal data of children and adolescents is prohibited, except in the case of data that is of a public nature and/or when the Treatment complies with the following parameters and requirements: .


    1. That responds to and respects the best interest of children and adolescents.
    2. That the respect of their fundamental rights be ensured.
    3. In the case of health data, they will be considered part of your medical history and will have the reservation established in Law 23 of 1981 and other regulations that regulate the matter.

    Once the above requirements have been met, the legal representative of the child or adolescent will grant authorization prior to the minor's exercise of his or her right to be heard, an opinion that will be assessed taking into account maturity, autonomy, ability to understand the matter and understanding of the consequences. that involves the Treatment.


    The personal data collected from minors, with prior authorization granted by the persons empowered to represent them, will have the purpose of:


    1. Exercise control and keep updated the identification data of minors, in order to fully satisfy the purpose of the other purposes.
    2. For legal matters and/or administrative procedures.
    3. With the objective of attending to queries, complaints, requests and/or claims.
    4. For matters related to the General Social Security System and parafiscal, when the employees of the Responsible Party are the legal representatives of the minor.
    5. For course participation.
    6. For registration processes for courses and filling out forms.
    7. Manage, support, review and/or prepare all types of documents in which the personal information of the minor is required in relation to hiring.
    8. To advance the procedures and proceedings that may take place, in order to adequately execute the pre-contractual, contractual and post-contractual stages.
    9. Records of attendance at events, activities or programs advanced by The Responsible
    10. For marketing purposes, campaigns and/or advertising guidelines. This purpose includes the sending of information on construction projects and the sending of information related to it.
    11. For customer profile study.
    12. For billing purposes and to carry out all the procedures that may take place in order to make payments and carry out collection actions and portfolio recovery. This purpose includes sending information and documents.
    13. For an adequate fulfillment of the contractual obligations contracted with the client, in relation to the services provided or products offered and/or sold by the Responsible Party.
    14. For the presentation of service offer. This purpose includes the promotion and presentation of services.
    15. For participation in sporting events.
    16. To advance procedures and proceedings before entities of the private sector.
    17. For marketing purposes, campaigns and/or advertising guidelines
    18. Manage, support, review and/or prepare all types of documents in which the client's personal information is required.
    19. For matters related to evaluation of the quality of the services provided or products offered and/or sold by the Responsible Party.
    20. In order to feed the directory databases with contact information of minors. This purpose includes the possibility of communicating with the minor by different means (chat, data and text messages, emails, social networks, physical correspondence, telephone calls, videoconferences, etc.).
    21. For the issuance of insurance policies.
    22. To transmit or transfer the information of the owner with other managers and / or managers, for the purposes indicated here.

  • In the case of contractors, contractors and suppliers.
  • The personal data collected from the contracting parties, contractors and suppliers will have the purpose of:

    1. Exercise control and keep the identification data updated, in order to fully satisfy the purpose of the other purposes.
    2. Carry out the procedures and procedures that may arise, in order to adequately execute the pre-contractual, contractual and post-contractual stages. This purpose includes analysis, evaluation and selection.
    3. For the issuance of insurance policies.
    4. To carry out audits, audits and reviews derived from the agreements or contracts entered into with the contracting party, contractors or suppliers.
    5. To advance procedures and proceedings before entities of the private sector.
    6. In order to register the information of the SGSST to include your information in said registry.
    7. For legal matters and/or administrative procedures.
    8. With the objective of attending to queries, complaints, requests and/or claims.
    9. For billing purposes and to execute all the procedures that may take place in order to make payments and carry out collection actions and portfolio recovery. This purpose includes sending information and documents.
    10. For accounting management. This purpose includes tasks of monitoring, control and accounting records of obligations.
    11. To demand compliance with legal and contractual obligations under your responsibility.
    12. Manage, support, review and/or prepare all types of documents in which the personal information of the contracting party, contractor or supplier is required.
    13. For proper compliance with contractual obligations, as well as all legal obligations that the parties may incur by virtue of the contract entered into.
    14. In order to advance efforts and procedures for compliance with tax obligations.
    15. For the evaluation of the provision of services, as well as the analysis of information on the quality and levels of service received.
    16. For the sending of notifications, as well as the attention of requirements by the judicial and administrative authorities, when applicable.
    17. In order to feed the directory databases with contact information of contractors, contractors and suppliers. This purpose includes the possibility of communicating with the contractor, contractor or supplier by different means (chat, data and text messages, emails, social networks, physical correspondence, telephone calls, videoconferences, etc.).
    18. For the presentation of service offer. This purpose includes the promotion and presentation of services.
    19. Store the information of the contracting parties, contractors and suppliers, whether in physical files and/or digital files, as long as it is essential to serve other purposes.
    20. To transmit or transfer the information of the owner with other managers and / or managers, for the purposes indicated here.

  • Regarding clients.
  • The personal data collected from customers will have the purpose of:


    1. Exercise control and keep the identification data updated, in order to fully satisfy the purpose of the other purposes.
    2. To advance the procedures and proceedings that may take place, in order to adequately execute the pre-contractual, contractual and post-contractual stages.
    3. For course participation.
    4. For registration processes for courses and filling out forms.
    5. For marketing purposes, campaigns and/or advertising guidelines.
    6. For customer profile study.
    7. For legal matters and/or administrative procedures.
    8. With the objective of attending to queries, complaints, requests and/or claims.
    9. For billing purposes and to carry out all the procedures that may take place in order to make payments and carry out collection actions and portfolio recovery. This purpose includes sending information and documents.
    10. For an adequate fulfillment of the contractual obligations contracted with the client, in relation to the services provided or products offered and/or sold by the Responsible Party.
    11. For the presentation of service offer. This purpose includes the promotion and presentation of services.
    12. To advance procedures and proceedings before entities of the private sector.
    13. Manage, support, review and/or prepare all types of documents in which the client's personal information is required.
    14. For matters related to evaluation of the quality of the services provided or products offered and/or sold by the Responsible Party.
    15. In order to feed the directory databases with customer contact information. This purpose includes the possibility of communicating with the client by different means (chat, data and text messages, emails, social networks, physical correspondence, telephone calls, videoconferences, etc.).
    16. With the purpose of exercising control and keeping the client's identification data updated in order to fully satisfy the purpose of the other purposes.
    17. Store customer information, whether in physical files and/or digital files, as long as it is essential to serve other purposes.
    18. To transmit or transfer the information of the owner with other managers and / or managers, for the purposes indicated here.

    The above purposes apply to both confirmed customers and potential customers.


  • Regarding partners.

  • The personal data collected from members will have the purpose of:


    1. Exercise control and keep the identification data updated, in order to fully satisfy the purpose of the other purposes.
    2. In order to feed the directory databases with customer contact information. This purpose includes the possibility of communicating with the client by different means (chat, data and text messages, emails, social networks, physical correspondence, telephone calls, videoconferences, etc.).
    3. For the management of procedures with suppliers, contractors and contractors.
    4. Manage, support, review and/or prepare all types of documents in which the member's personal information is required.
    5. In order to advance efforts and procedures for compliance with tax obligations.
    6. For accounting management. This purpose includes tasks of monitoring, control and accounting records of the obligations.
    7. To transmit or transfer the information of the owner with other managers and / or managers, for the purposes indicated here.

  • Regarding workers.

  • The personal data collected from workers will have the purpose of:


    1. For construction and updating of the worker's employment history. This purpose includes resumes of brigade members.
    2. With the purpose of exercising control and keeping updated the identification data of the worker in order to fully satisfy the purpose of the other purposes.
    3. For adequate compliance with the contractual obligations contracted in the employment contract entered into with the worker, as well as the legal obligations derived from the bond or relationship in labor matters.
    4. Sending notifications to the worker for the attention of requirements by the judicial and administrative authorities.
    5. To communicate with the worker through different means (chat, data and text messages, emails, social networks, physical correspondence, telephone calls, videoconferences, etc.). This purpose applies to applicants.
    6. For the collection of resumes and to advance personnel selection processes. This purpose includes conducting interviews and assessment and analysis of resumes and applies to applicants.
    7. Store the worker's information, whether in physical files and/or digital files, as long as it is essential to serve other purposes during the fulfillment of the employment contract and/or once it has been completed. This purpose extends to the storage of data and resumes submitted by applicants.
    8. For the conclusion of confidentiality agreements.
    9. To advance investigation of work accidents.
    10. To advance procedures, proceedings and/or disciplinary actions, as well as to impose the respective sanctions.
    11. With the objective of issuing labor certifications that are requested by the worker, as well as licenses and permits.
    12. For purposes of affiliation to the Comprehensive Social Security System and parafiscal contributions. This purpose extends, as far as the worker's family is concerned.
    13. With the objective of attending to queries, complaints, requests and/or claims.
    14. In order to contribute in judicial processes and/or administrative procedures, judicial evidence that contains personal data of the worker.
    15. Payment and discounts for payroll, vacations and social benefits.
    16. Training, induction and reinduction of personnel.
    17. Sociodemographic profile study.
    18. Delivery of endowments.
    19. Application of policies, plans and systems in health and safety at work and prevention in health and occupational risks.
    20. For purposes of delivery and use of representation and travel expenses.
    21. Schedule control.
    22. To transmit or transfer the owner's information with other managers and / or managers, for the purposes listed here.

    The above purposes apply, as regards, to practitioners who are carrying out their internship with The Responsible Party, without this implying that an employment contract is set up . In this regard, it is understood that the word "worker" and the purposes indicated in this section, for this and all other documents related to the matter, cover practitioners who are carrying out their practice with The Responsible.

  • Rights that assist the Holder.

  • The Responsible informs and guarantees the Holders of the information, the following rights:

    1. Know, update and rectify the information of your personal data in front of the Responsible and/or Managers of your Treatment, a right that can be exercised against inaccurate, partial, incomplete, fractional data, which lead to error, among others, or those whose use is unaware of the purposes for which they were collected.
    2. The Holder may at any time request proof of the authorization granted by him to the Person Responsible for the Treatment of personal data.
    3. The Holder may also be informed, upon request to the Responsible, about the handling that he has given to his personal data.
    4. The Holder may submit to the Superintendence of Industry and Commerce (SIC), complaints for violations of the provisions of Law 1581 of 2012 and Decree 1377 of 2013 and other regulations that modify, complement or add to them.
    5. The Owner may also revoke the authorization and/or request the deletion of their personal data when they consider that the Constitutional and legal principles, rights and guarantees were not respected, deletion that will proceed when the Superintendency of Industry and Commerce has determined that in the Treatment the Responsible or Person in Charge have incurred in conduct contrary to the Constitution and the law, provided that there is no contractual relationship between the Owner of the information and The Responsible or when there is no legal duty that requires that the information be kept in the database .
    6. The Owner will be able to freely access their personal data subject to Treatment by The Responsible.
  • Duties of the person in charge and the person in charge of handling personal data.

  • The Responsible and Person in Charge of the Treatment of personal data guarantees the Holders of the information, the fulfillment of the following duties:

    1. Guarantee the Owner, at all times, the full and effective exercise of the right of habeas data .
    2. Request and keep a copy of the respective authorization granted by the Holder.
    3. Duly inform the Owner about the purpose of the Processing of their personal data.
    4. Keep the information under the necessary security conditions to prevent its adulteration, loss or fraudulent consultation.
    5. Guarantee that the information provided is true, complete, updated, verifiable and understandable.
    6. Rectify the information when it is incorrect.
    7. Demand from the Treatment Manager at all times, respect for the security and privacy conditions of the Owner's personal data.
    8. Process inquiries and claims made under the terms of the law.
    9. Inform at the request of the Owner the handling that is given to their personal data.
    10. Comply with the instructions and requirements of the Superintendency of Industry and Commerce (SIC).
    11. Timely update, rectify or delete data under the terms of Law 1581 of 2012 and Decree 1377 of 2013.
    12. Update the information reported by the Treatment Managers within five (5) business days from its receipt.
    13. Register in the database the legend "claim in process" in the manner in which it is regulated in Law 1581 of 2012 and Decree 1377 of 2013.
    14. Refrain from circulating information that is being controversial by the Holder and whose blocking has been ordered by the Superintendence of Industry and Commerce (SIC).
    15. Allow access to information only to people who may have access to it.
    16. Inform the Superintendence of Industry and Commerce (SIC) when there are violations of security codes and there are risks in the administration of the information of the Holders.
    17. Comply with the instructions and requirements issued by the Superintendence of Industry and Commerce (SIC).
    18. The others ordered by Articles 17 and 18 of Law 1581 of 2012.
  • procedures.

  • Who can make inquiries, requests and claims?

  • The Data Holders, their successors in title, their representatives or third parties authorized by them, may consult and/or request the provision of information on the data collected, make requests for the deletion of information, rectify it and/or revoke the authorization for Treatment. of the personal information of the Owner that rests in the databases of the Responsible, submit claims, queries and/or requests about the Treatment, and in general, to exercise the rights that by law correspond to the Owner of the information. The rights of children and adolescents will be exercised through the people who are empowered to represent them.

    Article 9 of Decree 1377 of 2013 states in its second paragraph that "The request for the deletion of the information and the revocation of the authorization will not proceed when the Owner has a legal or contractual duty to remain in the database." which is applicable to contractors and contractors, clients and workers of the Responsible.

  • Channels for inquiries, requests and claims
  • In order to facilitate access to information to the Holders of it, The Responsible has established the following channels so that they, their successors in title, their representatives or authorized third parties, submit their requests and / or raise their queries and / or claims, as well as to enforce the rights that assist the Holders of the information:

    Official or area in charge of care

    Administrative area

    Home

    Manizales, Caldas, Colombia

    Address

    Vereda El Arenillo, Altamira House 1 Complex

    Email

    hello@marcelogutierrez.co

  • Forms of presentation of queries, requests and claims 
  • Given that any query, request and/or claim presented by the Holder, his successors in title, his representatives or authorized third parties, must have evidence of its processing, the Responsible party preferentially establishes the physical written form as the means for its presentation, Clarifying that notwithstanding the foregoing, queries, requests and/or claims made via email remain fully valid and will be treated in the same way as if they had been physically submitted.

    Any query, request, and/or claim that is made must contain at least the following information, in order to safeguard the rights of the Holders and with the purpose of facilitating the attention of what is required:

    1. Name and surname of the principal.
    2. Type of document and identification number of the Holder.
    3. Location data of the Holder.
    4. Description of the facts that give rise to the request, query or claim.
    5. Documents that you consider support your request, query or claim.
    6. Means by which you want to receive a response.
    7. Name of the petitioner, which, if different from the Holder, must attach the documents that allow him to act on his behalf.
    8. Signature of the petitioner.

    In order to protect the constitutional and legal rights of the Owners of the information, The Responsible will not process requests, queries and/or claims if the person other than the Owner does not accredit the power to act on behalf of the latter.

  • Term for processing a query, request or claim
  • Requests and inquiries
  • Requests and inquiries will be addressed within a maximum term of ten (10) business days from the day of receipt. When it is not possible to attend to the request or query within said term, the Holder or interested party will be informed of the reasons for the delay and the date on which it will be attended will be indicated, a term that in any case may not be greater than five (5) business days following the expiration of the first term.

  • claims
  • Claims will be addressed within a maximum term of fifteen (15) business days from the day after receipt. When it is not possible to address the claim within said term, the Holder or interested party will be informed of the reasons for the delay and the date on which it will be addressed will be indicated, a term that in any case may not exceed eight (8) business days. following the expiration of the first term.

    Once The Controller has received the complete claim, the case will be marked within two (2) business days in the database with the legend "CLAIM IN PROCESS" or a similar one, indicating the reason for it, and thus will hold until the answer is defined.

    In the case of claims made with the purpose of deleting personal data, if the term established in this section has expired The Responsible has not deleted the information, the Holder may request the Superintendence of Industry and Commerce to order the revocation of the authorization and/or or deletion of your data.

  • Generalities of the procedure.
  • After the request, consultation and/or claim has been filed, the document will be sent to the person in charge so that he is the one who gives a timely, clear, complete and in-depth response. The person in charge may refer the request, query and/or claim to other agencies and/or areas when he considers that these are suitable to support a timely, clear, complete and in-depth response.

    If, after studying the particular case, The Controller considers that it is not competent to respond to the query, request and/or claim, the owner or the person authorized by the latter will be informed of such situation. Once said event has been communicated, the Responsible Party, within the following two (2) business days, will forward the request to whoever it deems competent to give the respective response. When The Responsible party considers that it is not competent to respond to the request, query and/or claim and does not consider who is, it will communicate said situation to the person who has submitted the request.

    When the request, query and/or claim is sent via email, the filing date and class of attached documents will be those registered and received in the respective mail.

    If the request, query and/or claim is incomplete, the Holder or interested party will be required within five (5) business days following receipt to correct the identified shortcomings. If the request is met and it is verified that the request was not duly corrected, the Holder or interested party will be informed of this situation so that they can correct it again within five (5) business days following the sending of the communication. If after the second request it is verified that the request was not duly corrected again, the request, query and/or claim will be rejected.

    The rejection of the request will operate only when aspects that are essential to give a timely, clear, complete and in-depth response to the request are not duly corrected and that without them, fundamental rights of the Holder of the information may be violated. In all other events, if the Controller considers that it is feasible to respond to the request despite not having been duly corrected, it will do so. The rejection will not prevent the Holder or the person authorized by him, from resubmitting the request with all the requirements.

    If after two (2) months from the date of the request to correct the request, the Owner or interested party has not submitted the required information, it will be understood that they have withdrawn from it.

    In the events in which repetitive requests, queries and/or claims already resolved are raised, the Responsible may refer to the previous responses to resolve. This provision will not apply when the petition has been rejected for not complying with the requirements demanded by law and those indicated in this document, provided that the new petition is submitted with all the requirements.

    In no case may the Responsible party refuse to receive and/or file the request, except when the person presenting the request is a person other than the Owner of the information and does not prove the power to act on behalf of the latter.

  • Procedural requirement and disagreement with the response to claims, requests or inquiries
  • In accordance with the provisions of Article 16 of Law 1581 of 2012, the Owner or interested party may only file a complaint with the Superintendency of Industry and Commerce once the procedural requirement consisting of the consultation process or direct claim has been exhausted before The Responsible.

  • Procedure costs
  • The Owner or interested party may consult their personal data free of charge at least once every calendar month, or every time there are substantial modifications to the Information Treatment Policy that lead to new consultations.

    When the Owner or interested party wants to consult their personal data more frequently than once every calendar month, The Responsible may charge the Owner or interested party the costs of sending, reproducing and certifying documents.

    The reproduction costs may not be greater than the costs of recovery of the corresponding material. For this purpose, the Responsible Party must demonstrate to the Superintendence of Industry and Commerce, when it so requires, the support of said expenses.

  • The authorization.

  • The collection, storage, use, circulation or deletion of personal data by the Responsible requires the free, prior, express and informed consent of the Owner thereof. The Responsible has arranged the necessary mechanisms to obtain the authorization of the Holders, guaranteeing in any case that it is possible to verify the granting of said authorization.

    The authorization may consist of a physical, electronic document, or in any other format that allows ensuring its subsequent consultation and from which the acceptance by the Owner of the information of the Treatment of their personal data by the Responsible Party can be unequivocally concluded. .

    The authorization request will be issued by the Responsible and will be made available to the Holder, prior to the Processing of their personal data, in order for them to know and make informed decisions regarding:

    1. That certain information about you is collected and used for certain purposes;
    2. Faced with the option of knowing any change in them;
    3. To control the use of your personal data.

    Pursuant to article 12 of Law 1581 of 2012, the authorization request will contain:

    1. The Treatment to which your personal data will be submitted and the purpose thereof.
    2. The optional nature of the answer to the questions that are asked, when these are about sensitive data or about the data of girls, boys and adolescents.
    3. The rights that assist you as Owner.
    4. The identification, physical and electronic address of the Responsible.

    The Responsible Party will adopt the necessary measures to maintain suitable technical or technological records or mechanisms that certify when and how authorization was obtained from the Holders of personal data for the Treatment thereof.

  • Cases in which authorization is not required for data processing
    1. When it comes to public personal data.
    2. When personal data is required by a public entity in the exercise of its functions.
    3. When dealing with cases of medical or health urgency.
    4. When they are treated by authorization of the law for historical, statistical or scientific purposes.
    5. When the data is related to information contained in the civil registry.

  • Persons to whom information on data processing may be provided

  • The information that meets the conditions established in this Policy may be provided to the following persons:

    1. To the Holders, their successors in title or their legal representatives.
    2. To public or administrative entities in the exercise of their legal functions by court order.
    3. To third parties authorized by the Owner or by law.
  • Notice of Privacy.

  • It is the physical document, electronic or in any other format, which is made available to the Owner for the Processing of their personal data. Through this document, the Holder of the information is informed about the existence of the Information Treatment Policy that will be applicable to him, the way to access it and the characteristics of the Treatment that is intended to be given to personal data.

    The privacy notice contains:


    1. The contact details of the person in charge.
    2. The Treatment to which the data will be submitted and the purpose thereof.
    3. The rights that assist the Holder.
    4. The mechanisms provided by The Responsible , so that the Owner knows the Information Treatment Policy and the substantial changes that occur in it or in the corresponding Privacy Notice. In all cases, you must inform the Holder how to access or consult the Information Treatment Policy.

    The privacy notice and the authorization request may concur in the same act.

  • Modification and/or updating of the personal data protection policy.

  • Any substantial change in this Data Processing Policy, in the Privacy Notice and/or in the Internal Manual of Policies and Procedures, will be communicated in a timely manner to the Holders of the data through the usual means of contact provided by the owner. In the same way, it may be communicated through the Website of the Responsible, where it will also have a copy of this Policy.

    Communications will be sent at least ten (10) business days prior to the effective date of implementation of the new Policy, Notice and/or Manual or substantial update thereof.

  • Validity

  • The Responsible informs that this Personal Data Treatment Policy begins on September 8, 2021.

    Once the purposes of the Treatment have been fulfilled - and without prejudice to legal regulations that provide otherwise -, the personal data in the possession of the Responsible will be deleted. Notwithstanding the foregoing, personal data must be kept when required to comply with a legal or contractual obligation.

    Marcelo Gutierrez Villegas

    Legal representative