1. SCOPE
This Personal Data Protection Policy will apply to all Databases and/or Files that contain Personal Data that are subject to Processing by BITS AMERICAS S.A.S, each one individually considered responsible and/or in charge of the processing of Personal Data. , BITS AMERICAS S.A.S.
2. IDENTIFICATION OF THE RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA
BITS AMERICAS S.A.S, company with address at Calle 106A # 54 - 27 in the city of Bogotá D.C., Colombia, email info@bitsamericas.com, telephone (+571) 4846220.
3. DEFINICIONES
· Authorization: Prior, express and informed consent of the Owner to carry out the Processing of Personal Data.
· Privacy Notice: Verbal or written communication generated by the Controller, addressed to the Owner for the Processing of their Personal Data, through which they are informed about the existence of the Information Processing Policies that will be applicable to them, the way to access to them and the purposes of the Treatment that is intended to be given to personal data.
· Database: Organized set of Personal Data that is subject to Treatment.
· Personal Data: Any information linked or that can be associated with one or several specific or determinable natural persons.
· 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. In events in which the Controller does not act as Data Base Manager, it will be expressly identified who will be the Manager.
· 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.
· Terms and Conditions: general framework in which the conditions are established for participants in promotional or related activities.
· Owner: Natural person whose Personal Data is the subject of Treatment.
· Treatment: Any operation or set of operations on Personal Data, such as collection, storage, use, circulation or deletion.
· Transfer: The transfer of data takes place when the Controller and/or Processor of personal data, located in Colombia, sends the information or personal data to a recipient, who in turn is Responsible for the Treatment and is located inside or outside from the country.
· Transmission: Processing of Personal Data that involves the communication of the same within or outside the territory of the Republic of Colombia when its purpose is to carry out a Processing by the Processor on behalf of the Controller.
4. TREATMENT
BITS AMERICAS S.A.S, acting as Responsible for the Processing of Personal Data, for the proper development of its commercial activities, as well as for the strengthening of its relationships with third parties, collects, stores, uses, circulates and deletes Personal Data corresponding to natural persons. with whom it has or has had a relationship, such as, without limitation, workers and their families, shareholders, consumers, clients, distributors, suppliers, creditors and debtors.
5. PURPOSE
Personal Data is processed by BITS AMERICAS S.A.S for the following purposes:
5.1. To send information to your workers and family members.
5.2. For the provision of health services to the family members of BITS AMERICAS S.A.S workers who are beneficiaries of the health service.
5.3. For the recognition, protection and exercise of the rights of the shareholders of BITS AMERICAS S.A.S.
5.4. To strengthen relationships with its consumers and clients, by sending relevant information, taking orders and responding to Requests, Complaints, Claims and Suggestions (PQRS) by the customer service area, evaluating the quality of its customer service and the invitation to events organized or sponsored by BITS AMERICAS S.A.S, among others.
5.5. For interaction with its Distributors, for verification of compliance with distribution standards, its legal obligations with its workers and for invitations to events organized or sponsored by BITS AMERICAS S.A.S, among others.
5.6. To consolidate a timely and quality supply with its Suppliers, through the invitation to participate in selection processes, the evaluation of compliance with their obligations and the invitation to events organized or sponsored by BITS AMERICAS S.A.S, among others.
5.7. To verify your creditors' balances.
5.8. For the determination of pending obligations, the consultation of financial information and credit history and the reporting to information centers of unfulfilled obligations, regarding its debtors.
5.9. To improve, promote and develop its products.
5.10. For marketing, statistical, research activities and other commercial purposes that do not contravene current legislation in Colombia.
5.11. For the attention of judicial or administrative requirements and compliance with judicial or legal mandates.
5.12. To eventually contact, via email, or by any other means, natural persons with whom you have or have had a relationship, such as, without the list being limited, workers and their families, shareholders, consumers, clients, distributors, suppliers. , creditors and debtors, for the aforementioned purposes.
6. RIGHTS OF THE OWNERS OF PERSONAL DATA
Natural persons whose Personal Data is subject to Processing by BITS AMERICAS S.A.S, have the following rights, which they can exercise at any time:
6.1. Know the Personal Data on which BITS AMERICAS S.A.S is carrying out the Treatment. Likewise, the Owner may request at any time that their data be updated or rectified, for example, if they find that their data is partial, inaccurate, incomplete, fragmented, misleading, or those whose Processing is expressly prohibited or not. has been authorized.
6.2. Request proof of the authorization granted to BITS AMERICAS S.A.S for the Processing of your Personal Data.
6.3. Be informed by BITS AMERICAS S.A.S, upon request, regarding the use that it has given to your Personal Data.
6.4. Submit complaints to the Superintendency of Industry and Commerce for violations of the provisions of the Personal Data Protection Law.
6.5. Request BITS AMERICAS S.A.S to delete your Personal Data and/or revoke the authorization granted for its Treatment, by submitting a claim, in accordance with the procedures established in section 11 of this Policy. However, the request for deletion of the information and the revocation of the authorization will not proceed when the Owner of the information has a legal or contractual duty to remain in the Database and/or Files, nor while the relationship between the Owner and BITS AMERICAS S.A.S, by virtue of which your data was collected.
6.6. Free access to your Personal Data subject to Processing.
7. AREA RESPONSIBLE FOR THE IMPLEMENTATION AND ENFORCEMENT OF THIS POLICY
The Administrative and Financial Management of BITS AMERICAS S.A.S. is in charge of the development, implementation, training and observance of this Policy. For this purpose, all officials who carry out the Processing of Personal Data in the different areas of BITS AMERICAS S.A.S are obliged to report these Databases to the Administrative and Financial Directorate and to immediately transfer all requests to it. , complaints or claims received from the Holders of Personal Data.
The Administrative and Financial Department has also been designated by BITS AMERICAS S.A.S as the area responsible for handling requests, queries, complaints and claims before which the Owner of the information may exercise their rights to know, update, rectify and delete the data and revoke authorization.
8. AUTHORIZATION
BITS AMERICAS S.A.S must request prior, express and informed authorization from the Owners of the Personal Data on which the Treatment is required.
8.1. Prior authorization means that consent must be granted by the Owner, no later than at the time of collection of the Personal Data.
8.2. Express authorization means that the Owner's consent must be explicit and specific; open and non-specific authorizations are not valid. The Owner is required to express their willingness to authorize BITS AMERICAS S.A.S to process their Personal Data.
This manifestation of the Owner's will may occur through different mechanisms made available by BITS AMERICAS S.A.S, such as:
· In writing, for example, by filling out an authorization form such as the one indicated in Annex 1.
· Orally, for example, in a telephone conversation or video conference.
· Through unequivocal conduct that allows us to conclude that you have granted your authorization, for example, through your express acceptance of the Terms and Conditions of an activity within which the authorization of the participants is required for the Processing of their Personal Data.
IMPORTANT: In no case will BITS AMERICAS S.A.S assimilate the Owner's silence to unequivocal conduct.
Whatever the mechanism used by BITS AMERICAS S.A.S, it is necessary that the authorization be preserved so that it can be consulted later.
8.3. Informed Authorization means that, when requesting consent from the Owner, they must be clearly informed:
· The Personal Data that will be collected.
· The identification and contact information of the Controller and the Data Processor.
· The specific purposes of the Treatment that is intended to be carried out, that is: how and for what purpose the collection, use, circulation of Personal Data will be carried out.
· What rights you have as the Owner of Personal Data; For this purpose, see section 6 of this Policy.
· The optional nature of the response to the questions asked, when they relate to sensitive data or the data of girls, boys and adolescents.
9. SPECIAL PROVISIONS FOR THE PROCESSING OF PERSONAL DATA OF A SENSITIVE NATURE.
In accordance with the Personal Data Protection Law, data of a sensitive nature is considered data that affects privacy or whose improper use can generate discrimination, such as data related to:
· Racial or ethnic origin.
· Political orientation.
· Religious/philosophical convictions.
· Membership in unions, social organizations, human rights organizations or political parties.
· Health.
· Sex life.
· Biometric data (such as fingerprint, signature and photo).
The Processing of Personal Data of a sensitive nature is prohibited by law, unless there is express, prior and informed authorization from the Owner, among other exceptions enshrined in Article 6 of Law 1581 of 2012.
In this case, in addition to complying with the requirements established for authorization, BITS AMERICAS S.A.S must:
· Inform the Owner that since it is sensitive data, he is not obliged to authorize its Treatment.
· Inform the Owner which of the data that will be processed is sensitive and the purpose of the Treatment.
IMPORTANT: No activity may be conditioned on the Owner providing sensitive Personal Data.
10. SPECIAL PROVISIONS FOR THE PROCESSING OF PERSONAL DATA OF BOYS, GIRLS AND ADOLESCENTS
According to the provisions of Article 7 of Law 1581 of 2012 and Article 12 of Decree 1377 of 2013, BITS AMERICAS S.A.S will only carry out the Treatment, that is, the collection, storage, use, circulation and/or deletion of the corresponding Personal Data. to children and adolescents, as long as this Treatment responds to and respects the best interests of children and adolescents and ensures respect for their fundamental rights.
Once the above requirements have been met, BITS AMERICAS S.A.S must obtain the Authorization of the legal representative of the child or adolescent, prior to the minor's exercise of his or her right to be heard, an opinion that will be valued taking into account maturity, autonomy and ability to understand the matter. .
11. PROCEDURE FOR ATTENTION AND RESPONSE TO REQUESTS, QUERIES, COMPLAINTS AND CLAIMS FROM PERSONAL DATA HOLDERS
The Holders of the Personal Data that are being collected, stored, used, put into circulation by BITS AMERICAS S.A.S, may exercise at any time their rights to know, update, rectify and delete information and revoke the authorization.
For this purpose, the following procedure will be followed, in accordance with the Personal Data Protection Law:
11.1. ATTENTION AND RESPONSE TO REQUESTS AND QUERIES:
What does the procedure consist of?
The Owner or his successors may request BITS AMERICAS S.A.S, through the means indicated below:
· Information about the Personal Data of the Owner that is subject to Processing.
· Request proof of the authorization granted to BITS AMERICAS S.A.S for the Processing of your Personal Data.
· Information regarding the use that BITS AMERICAS S.A.S has given to your personal data.
Means enabled for the presentation of requests and queries:
BITS AMERICAS S.A.S has established the following means for the reception and attention of requests and queries, all of which allow proof of these to be preserved:
· Communication addressed to BITS AMERICAS S.A.S, Calle 106A # 54 - 27 in the city of Bogotá D.C.
· Request submitted to email: info@bitsamericas.com.
Attention and response from BITS AMERICAS S.A.S:
Requests and queries will be responded to within a maximum period of ten (10) business days from the date of receipt. When it is not possible to attend to the request or query within said term, the interested party will be informed, expressing the reasons for the delay and indicating the date on which their request or query will be attended to, which in no case may exceed five (5). business days following the expiration of the first term.
11.2. ATTENTION AND RESPONSE TO COMPLAINTS AND CLAIMS:
What does the procedure consist of?
The Owner or his successors may request BITS AMERICAS S.A.S, through a complaint or claim submitted through the channels indicated below:
· The correction or update of the information.
· The deletion of your Personal Data or the revocation of the authorization granted for the Treatment of these.
· That the alleged non-compliance with any of the duties contained in the Personal Data Protection Law be corrected or corrected.
The request must contain a description of the facts that give rise to the complaint or claim, the address and contact information of the applicant, and must be accompanied by the documents that you wish to assert.
Means enabled for the presentation of complaints and claims:
BITS AMERICAS S.A.S has established the following means for the reception and attention of complaints and claims, all of which allow proof of their presentation to be preserved:
· Communication addressed to BITS AMERICAS S.A.S, Calle 106A #54 - 27 in the city of Bogotá D.C.
· Request submitted to email: info@bitsamericas.com.
Attention and response from BITS AMERICAS S.A.S:
If the complaint or claim is presented incomplete, BITS AMERICAS S.A.S must require the interested party within five (5) days following receipt of the complaint or 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 or she has withdrawn the complaint or claim.
In the event that the person who receives the complaint or claim is not competent to resolve it, they will notify the General Management within a maximum period of two (2) business days and will inform the interested party of the situation.
Once the complete complaint or claim is received, a legend that says "claim in process" and the reason for this will be included in the Database within a period of no more than two (2) business days. Said legend must be maintained until the complaint or claim is decided.
The maximum term to address the complaint or claim will be fifteen (15) business days counted from the day following the date of receipt. When it is not possible to address the complaint or claim within said term, the interested party will be informed of the reasons for the delay and the date on which the complaint or claim will be addressed, which in no case may exceed eight (8) business days. following the expiration of the first term.
12. INFORMATION OBTAINED PASSIVELY
When you access or use the services contained within the websites of BITS AMERICAS S.A.S, it may passively collect information through information management technologies, such as “cookies”, through which information is collected. about your computer hardware and software, IP address, browser type, operating system, domain name, access time and referring website addresses; Through the use of these tools, Personal Data is not directly collected from users. Information will also be collected about the pages that the person visits most frequently on these websites in order to understand their browsing habits. However, the user of the BITS AMERICAS S.A.S websites has the possibility of configuring the operation of the "cookies", according to the options of their internet browser.
When emails are received from the domain of BITS AMERICAS S.A.S, it may passively collect information for the management of the information, from which information is collected in accordance with section 5. Purpose. Therefore, notice is given in each email sent from the BITS AMERICAS S.A.S domain.
NOTICE: The information contained in this message and in the attached files is confidential and reserved and is directed exclusively to its recipient, without the intention of it being known by third parties, therefore, in accordance with current legal regulations, its interception, Theft, loss, reproduction, reading or use by any other person is prohibited. If you have received this message by mistake, please forgive us, notify us and delete it. The opinions, conclusions and other information contained in this email not related to the official business of the sender, should be understood as personal and are in no way
endorsed by BITS AMERICAS S.A.S. BITS AMERICAS S.A.S has adopted mechanisms to prevent this message and its annexes from containing viruses or defects that may affect the information, computers or systems that receive it, however, it is the responsibility of the recipient to confirm this fact at the time of sending it. its reception and opening. Consequently, BITS AMERICAS S.A.S is exonerated from any liability for damages, alterations or harm caused by its reception or use.
13. PERSONAL DATA SECURITY
BITS AMERICAS S.A.S, in strict application of the Principle of Security in the Processing of Personal Data, will provide the technical, human and administrative measures that are necessary to provide security to the records, avoiding their adulteration, loss, consultation, unauthorized or fraudulent use or access. . The obligation and responsibility of BITS AMERICAS S.A.S is limited to having the appropriate means for this purpose. BITS AMERICAS S.A.S does not guarantee the total security of your information nor is it responsible for any consequence derived from technical failures or improper entry by third parties to the Database or File in which the Personal Data subject to Processing by BITS rests. AMERICAS S.A.S and its Managers. BITS AMERICAS S.A.S will require the service providers it contracts to adopt and comply with the appropriate technical, human and administrative measures for the protection of Personal Data in relation to which said providers act as Processors.
14. TRANSFER, TRANSMISSION AND DISCLOSURE OF PERSONAL DATA
BITS AMERICAS S.A.S may disclose to its related companies worldwide, the Personal Data on which it carries out the Treatment, for its use and Treatment in accordance with this Personal Data Protection Policy.
Likewise, BITS AMERICAS S.A.S may deliver Personal Data to third parties not linked to BITS AMERICAS S.A.S when: a. These are contractors in the execution of contracts for the development of the activities of BITS AMERICAS S.A.S; b. By transfer to any title of any line of business to which the information relates.
In any case, in the contracts for the transmission of Personal Data, which are signed between BITS AMERICAS S.A.S and the Persons in Charge of the Processing of Personal Data, it will be required that the information be treated in accordance with this Personal Data Protection Policy and the following obligations on the head of the respective Manager:
· Treat Personal Data in the name of BITS AMERICAS S.A.S in accordance with the principles that protect it.
· Safeguard the security of databases containing Personal Data.
· Maintain confidentiality regarding the Processing of Personal Data.
15. APPLICABLE LEGISLATION
This Personal Data Protection Policy, the Privacy Notice, the Video Surveillance Notice, the Email Notice, are governed by the provisions of current legislation on the protection of Personal Data referred to in Article 15 of the Political Constitution of Colombia, Law 1266 of 2008, Law 1581 of 2012, Decree 1377 of 2013, Decree 1727 of 2009 and other regulations that modify, repeal or replace them.
16. VALIDITY
This Personal Data Protection Policy described above will govern as of November 1, 2016. The databases subject to Treatment will be valid for the contractual term of the product plus the term established by law.