PREAMBLE.- AUTONOMIC S.A.S. In pursuance of the provisions of Law 1581 of 2012, and Regulatory Decree 1377 of 2013, implements its Manual of Policies for the Treatment and Protection of Personal Data.

 

CHAPTER I

GENERAL FEATURES

 

FIRST: AUTONOMIC S.A.S. will implement all the actions within its power to comply with the protection and processing of personal data for which it is responsible or in charge, especially to protect the rights to privacy, intimacy and good name and the rights to know, update and rectify the data of the owners collected in their own databases or processed on behalf of third parties. Therefore, this manual applies both to the protection of personal data currently processed and those that may be processed in the future, as well as to the processing of the data of employees, customers, suppliers and contractors.

SECOND: PRINCIPLES. In the processing of personal data carried out by AUTONOMIC S.A.S., all the principles enshrined in Title II, Article 4 of the General Regime for the Protection of Personal Data, Law 1581 of 2012 and the regulations that develop and complement it, apply.

THIRD: CONSULTATION OF THE PERSONAL DATA PROCESSING POLICY. This policy is available to the owners of the personal data by the appropriate means of disclosure available to AUTONOMIC S.A.S. identified with the NIT 901.118.213-9 as responsible or in charge of the processing of personal data and at its headquarters located at Calle 67 No. 52 - 20 of the city of Medellín, telephone 4442637 email [email protected]

FOURTH: PROCESSING OF PERSONAL DATA. The processing of personal data is done in accordance with the terms and scope of the authorization given by the owner or in application of the special rules when appropriate legal exceptions to do so is required.

FIFTH: RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA. AUTONOMIC S.A.S. acts as RESPONSIBLE for the processing of personal data by virtue of the collection it makes directly from the data of the owners, in order to i) maintain labor relations with its workers, drafting of employment contracts, links to the social security system and payment of salaries and social benefits. Likewise to keep the staff constantly trained in the different issues related to their activity, in preparation for the performance of their duties; ii) to carry out the development of its corporate purpose, as an employment management and placement agency; iii) to pay its financial, labor and contractual obligations, iv) to provide information to customers and users regarding the services they provide in development of their corporate purpose, for which they can send information electronically, or make telephone or personal contact with the owners; v) to submit commercial proposals for the sale of products and services to natural or legal persons; vi) to process petitions made by requests, complaints or claims by the users or clients; vii) to attend to the administrative requirements of district, departmental or national entities; viii) to respond to the requirements made by judges of the Republic, conciliators, arbitrators and other entities with judicial functions, derived from judicial actions that are promoted by or against AUTONOMIC S.A.S. For this purpose, it has obtained the prior, informed and explicit consent of the owners of the data and of those responsible for the processing of personal data, thus guaranteeing the rights to data protection.

SIXTH: RIGHTS OF THE DATA OWNER. In accordance with the provisions of current regulations applicable to data protection, the following are the rights of the owners of personal data: . Access, know, update, rectify and delete your personal data from AUTONOMIC S.A.S. in his capacity as data controller or person in charge of data processing. . Request proof of authorization granted by the owner of the data or by the person in charge of the processing of personal data to AUTONOMIC S.A.S. for data processing, by any valid means. . Be informed by AUTONOMIC S.A.S., upon request, regarding the use you have given to your personal data. . Present to the Superintendence of Industry and Commerce, complaints for violations of the provisions of Law 1581 of 2012, prior to consultation or request before AUTONOMIC S.A.S. . Revoke the authorization or request the deletion of the data when the Constitutional and legal principles, rights and guarantees are not respected in the Treatment. . Free access to your personal data that has been processed by AUTONOMIC S.A.S., as the person responsible for or in charge of the processing of personal data.

These rights may be exercised by:

  1. The owner of personal data.

  2. The successors of the owner of the personal data.

  3. The representative and/or proxy of the owner of the personal data.

SEVENTH: CONFIDENTIALITY AND SECURITY OF THE DATABASES. AUTONOMIC S.A.S. puts all the human, technical and technological resources within its reach, doing its best, to provide security and confidentiality to the personal data for which it is responsible or in charge of the processing.

Regarding confidentiality, AUTONOMIC S.A.S. undertakes to sign confidentiality agreements with third parties at events where agreements are made to share personal data for the offer of value-added services of legal, commercial and services.

EIGHTH: AUTHORIZATION FOR USE OF PERSONAL DATA. As the RESPONSIBLE party for the processing of personal data, AUTONOMIC S.A.S. obtains clear, prior, expressed, informed and free from defects authorization from the data owners, by means of forms, data collection formats, electronic forms and other means which it has or may have at its disposal for that purpose. Likewise, as the person in charge of data processing, AUTONOMIC S.A.S. obtains the authorization of those responsible after certifying the authorization of the owners, within the agreement to share personal data.

NINTH: AUTHORIZATION AND CONSENT OF THE OWNER. AUTONOMIC S.A.S., will request the owners of the personal data for their authorization and will inform the purpose in advance for the processing of their personal data, except in the following cases:

  1. Information required by a public or administrative entity in the exercise of its legal functions or by court order;

  2. Data of a public nature;

  3. Medical or health emergency cases;

  4. Treatment of information authorized by law for historical, statistical or scientific purposes;

  5. Data related to the Civil Registry of Persons.

TENTH: MEANS TO GRANT THE AUTHORIZATION. AUTONOMIC S.A.S., will obtain authorization by different means, including physical and electronic documents, data messages, Internet, Websites, or in any other format that in any case allows the consent of the owner through unequivocal conduct. Through such conduct, it is concluded that if the owner or the person entitled to do so had not provided the authorization, the data would not have been stored or captured in the database. The authorization will be requested by AUTONOMIC S.A.S., prior to the processing of personal data.

ELEVENTH: REVOCATORY OF THE AUTHORIZATION. The owners of personal data may at any time revoke the authorization granted to AUTONOMIC S.A.S., for the treatment of your personal data or request the deletion or removal of the same, as long as it is not prevented by a legal or contractual provision. AUTONOMIC S.A.S. establishes simple mechanisms that allow the owner to revoke his authorization or request the deletion of his personal data, at least by the same means by which he granted it.

For the above, it should be taken into account that the revocation of consent can be expressed in a complete manner in relation to the authorized purposes, and therefore AUTONOMIC S.A.S. must cease any data processing activity, and partially in relation to certain types of processing, in which case it will be these that will cease the processing activities. In the latter case, AUTONOMIC S.A.S. may continue to process personal data for those purposes for which the owner had not revoked his consent.

TWELFTH: GUARANTEES OF THE RIGHT OF ACCESS. To guarantee the right of access of the owner of the data, AUTONOMIC S.A.S. will make the respective personal data available through any suitable means, including electronic means that allow the owner direct access to them.

THIRTEENTH: TREATMENT TO WHICH THE DATA WILL BE SUBMITTED AND ITS PURPOSE. The treatment of the data of the owners with whom AUTONOMIC S.A.S. has established a relationship as RESPONSIBLE or as person IN CHARGE of the data processing, to promote the products and services that are derived from the exploitation of its corporate purpose, promote alliances, acquire goods and services, will do so based on the requirements of law 1581 of 2012 and law 1266 of 2008 as applicable, and in general for the fulfillment of its corporate purpose. In any case, personal data may be collected and processed to:

  1. Maintain labor relations with their workers, drafting of employment contracts, linking to the social security system and payment of salaries and social benefits. Likewise, to keep the personnel in constant training regarding the different issues related to their activity, preparation for the performance of their duties.

  2. Make the payment of your financial, labor and contractual obligations.

  3. Provide information to users and customers against the services provided in the development of its corporate purpose, for which it can send information by eletronic means, or make telephone or personal contact with the owners.

  4. Present commercial proposals for the sale of products and services to natural or legal persons.

  5. Process requests made by petitions, complaints or claims made by users or customers.

  6. Attend the administrative requirements of the district, departmental or national entities.

  7. Respond to the requirements made by judges of the Republic, conciliators, arbitrators and other entities with judicial functions, derived from judicial actions that are promoted by or against AUTONOMIC S.A.S.

  8. Offer the owners of the data commercial, product and service information in general, provided by AUTONOMIC S.A.S.

  9. Develop the corporate purpose of AUTONOMIC S.A.S., according to its bylaws.

  10. Share with allied companies, associates, branches, franchises, affiliates and subsidiaries and third parties with whom agreements have been signed to share personal data for the offer of value-added services of a commercial, financial and service nature.

  11. Make national or international transmission or transfer of data with allied companies, suppliers and others that are required for the development of its corporate purpose.

FOURTEENTH: UPDATE OF THE DATABASES. AUTONOMIC S.A.S. will update databases permanently, in accordance with the provisions of Law 1581 of 2012.

FIFTEENTH: DATA PROCESSING OF CHILDREN, GIRLS AND ADOLESCENTS. When processing personal data, AUTONOMIC S.A.S. will ensure that the prevailing rights of minors (children and adolescents) are respected. In the event of collecting them, they will comply with the provisions of article 7 of Law 1581 of 2012.

SIXTEENTH: TRANSFERS OF DATA FOR TREATMENT BY NATIONAL AND INTERNATIONAL THIRD PARTIES. AUTONOMIC S.A.S. may transmit or transfer partially or totally the personal data to third parties in the country or abroad, in development of its corporate purpose, for which it requests authorization from the owner and implements the necessary actions for compliance with the legal precepts of Colombia, by signing agreements to share personal data.

 

CHAPTER II

PROCEDURES

 

SEVENTEENTH: The procedures described below can only be exercised by the owner, his successors or representatives, provided that identity or representation is previously accredited.

EIGHTEENTH: PROCEDURE FOR THE EXERCISE OF THE RIGHT OF THE OWNERS OF PERSONAL DATA. In all procedures, the owner or his representatives must provide the following information: Name, surname, type of identification and number, NIT, citizenship card, address, telephone and city, copy of the RUT.

NINETEENTH: PROCEDURE FOR CONSULTATION ON THE PROCESSING OF DATA BY ITS OWNERS. AUTONOMIC S.A.S. provides the appropriate means for consultation, by the owners of the personal data, about the processing of their data, which will be informed within the forms or via email for the collection of personal data.

The terms to resolve the consultations will be ten (10) business days from the date of receipt of the same, in accordance with the provisions of article 14 of Law 1581 of 2012.

TWENTIETH: PROCEDURE TO CORRECT, UPDATE, RECTIFY OR DELETE DATA. AUTONOMIC S.A.S., in compliance with the General Regime for the Protection of Personal Data, will proceed to correct, update, rectify or delete personal data at the request of the owner or their representative, under the terms indicated in the PROCEDURE FOR THE EXERCISE OF THE RIGHT OF THE PERSONAL DATA OWNERS.

The procedure will be that established in article 15 of Law 1581 of 2012 and indicated below:

  1. The claim will be formulated by means of a request addressed to AUTONOMIC S.A.S., with the identification of the owner, the description of the facts that give rise to the claim, the address, and accompanying the documents that support the request. If the claim is incomplete, the interested party will be required within five (5) days after receipt of the claim to correct the deficiencies. 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 the person receiving the claim is not competent to resolve it, they shall notify the corresponding party within a maximum of two (2) business days and inform the interested party of the situation.

  2. Upon receipt of the completed claim, a legend stating “claim in process” and the reason for the claim will be included in the database within two (2) business days. This legend must be maintained until the claim is decided.

  3. The maximum term to attend the claim 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 attended to, which in no case may exceed eight (8) business days following the expiration of the first term. AUTONOMIC S.A.S. will train those in charge to deal with inquiries and complaints about the procedural formalities indicated by the law.

Paragraph. AUTONOMIC S.A.S. will not access the request made by the owner or his representative of deletion of personal data, when there is a legal or contractual duty for personal data to remain in the respective database.

TWENTY-FIRST: PROCEDURE TO REVOKE THE AUTHORIZATION GIVEN TO AUTONOMIC S.A.S. TO TREAT PERSONAL DATA. The owner of the personal data or their representative, may revoke the authorization given for the processing of their personal data, by submitting a request addressed to the person in charge of the treatment or to the person in charge of it in the terms of the PROCEDURE FOR THE EXERCISE OF THE RIGHT OF THE OWNERS OF PERSONAL INFORMATION.

TWENTY-SECOND: GUARANTEES OF THE RIGHT OF ACCESS. AUTONOMIC S.A.S. guarantees the owner of the data the right of access, making the respective personal data available in detail and free of charge through suitable means for their purpose.

TWENTY-THIRD: VALIDITY OF THE POLICY. This policy is effective from the date of its publication and supersedes any other institutional provisions to the contrary. Anything not provided for in this manual will be regulated according to the General Regime for the Protection of Personal Data in force in Colombia.

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