Data processing policy or
confidential information
REAL ESTATE SERVIPARAMO SAS, a commercial company established under the laws of the Republic of Colombia, hereinafter REAL ESTATE, in order to develop the fundamental right contained in article 15 of the Political Constitution, by virtue of which “all people have the right to their personal, family privacy and their good name and the state must respect them and make them respected. Likewise, they have the right to know, update and rectify the information that has been collected about them in the data banks and files of public and private entities.” Likewise, obeying the instructions provided in statutory law 1581 of 2012, we proceed to communicate the policy for the treatment of confidential information communicated by our suppliers and clients, which is governed by the constitutional and legal precepts in force and the following clauses.
1.- Unequivocal Acceptance Behaviors Information Management:
The owner grants unconditional and irrevocable authorization to INMOBILIARIA SERVIPARAMO for the treatment, collection, storage, use, circulation and deletion of personal confidential information or of the commercial company that it represents when transmitted via email, postal mail, filling out physical forms and /or deliver personal, commercial, accounting, financial, technical documents to any representative of INMOBILIARIA SERVIPARAMO SAS. This information will be treated and stored in accordance with the confidential information treatment policy of INMOBILIARIA SERVIPARAMO SAS.
2.- Responsible for Information Management:
INMOBILIARIA SERVIPARAMO SAS (hereinafter INMOBILIARIA SERVIPARAMO, a commercial company incorporated under the laws of the Republic of Colombia, identified with NIT 900404597-4, with main address in the city of Barranquilla – Colombia on Vía 40 # 75 – 95, telephone: 018000115030, judicial notification email: aldocasalins@yahoo.es will be responsible for the management of confidential information revealed by the owner.
3.- Definitions:
For the purposes and interpretation of this policy, the definitions contained in statutory law 1581 of 2012 will apply.
4.- Ways of Obtaining Information by the Owner:
INMOBILIARIA SERVIPARAMO obtains personal data in the following activities, without the following list being exclusive:
- Data collection through the customer service line.
- Capturing information from suppliers.
- Collection of client portfolio in its business units.
- Capturing information through the website.
- Payroll information and personnel management.
- Execution of contracts.
- Fairs and congresses.
During the execution of these activities or others where the collection of personal data occurs, the report, disclosure, use, consultation, elimination or deletion, forwarding, transfer, transmission, administration, access, conservation, storage, archive, analysis, copy , processing, and inclusion of said personal data within the databases on its server or that of a third party both in Colombia and abroad INMOBILIARIA SERVIPARAMO must comply with the provisions of the Political Constitution of Colombia, in statutory law 1581 of 2012 and in regulatory decree 1377 of 2013. Therefore, you will obtain prior authorization from the owner.
INMOBILIARIA SERVIPARAMO will use the information collected for the execution of its corporate purpose and also to carry out the following activities without its enunciation having a restrictive nature:
- Attention to the request of authorities.
- Customer registration.
- Credit risk analysis, security studies of clients, suppliers and users.
- Contract compliance.
- Sending correspondence, emails, telephone contact with your clients, suppliers, workers and users.
- Staff pick.
- Consultation and reporting to credit risk centers legally constituted in Colombia.
- Collection management.
5.- Validity of the Databases:
The databases will be valid as long as the commercial company INMOBILIARIA SERVIPARAMO SAS is in force.
6.- Rights of the Owners of the Databases:
The owners of the databases will have the rights contained in the Political Constitution of Colombia, and current Colombian legislation. In application of the terms of the law, INMOBILIARIA SERVIPARAMO assumes the role of data controller when it collects, stores, uses, circulates, deletes, or transfers data of the owners in any of its company activities, whether by itself or through third parties. The rights that assist the owners are:
- Know, update, modify, correct, delete your personal data from those responsible for the treatment. This right is limited only to partial, inaccurate, incomplete, fragmented, misleading data, or data whose processing has not been authorized.
- Request proof of data use authorization.
- Be informed of the use of your personal data.
- Present complaints in accordance with the Law for violations of the provisions of the current law that regulates the processing of personal information in databases.
- Revoke authorization.
- Free access to your personal data.
7.- Processing of Sensitive Data and Personal Data of Children and Adolescents:
SERVIPARMO will not collect data related to children and/or adolescents. The sensitive data collected from its employees will be used for the sole and exclusive purposes of managing the employment relationship with the company and to comply with the legal, contractual and conventional labor, social security and/or occupational health obligations in force and/or or completion thereof. These data are managed by the personnel management area of INMOBILIARIA SERVIPARAMO.
8.- Attention to Queries, Requests and Claims:
INMOBILIARIA SERVIPARAMO will allow the data owner free access to their information when required to make queries, as well as to guarantee the right of the owners to submit complaints and requests for correction, updating or deletion of data. INMOBILIARIA SERVIPARAMO will also allow access to the following people:
- Data owner.
- successors of the owner of the data.
- Public and/or administrative entities.
- By court order or by a third party authorized by the owner or the law.
- By stipulation in favor of another.
INMOBILIARIA SERVIPARAMO will allow queries, requests and claims in writing at the judicial notification address at VIA 40 # 75 – 95 in the city of Barranquilla, telephone: 018000115030, judicial notification email: aldocasalins@yahoo.es. The owner may fill out the form and send the request, complaint or claim which will be answered within a period of 10 business days, in accordance with the provisions of article 14 of law 1581 of 2012.
The request for deletion of information and revocation of authorization will not proceed when the owner of the data has a legal or contractual duty to remain in the databases of INMOBILIARIA SERVIPARAMO.
9.- Reception of Questions, Complaints, Claims and Queries:
For PQR received by physical means or by email: The Single Format for Receiving Requests, Complaints and Claims will be adopted and implemented, which must be downloaded from the SERVIPARAMO website. The form must be sent by postal mail to VIA 40 # 75 – 95 in the city of Barranquilla, or to the following email: aldocasalins@yahoo.es. Response times will be ten (10) business days for inquiries and fifteen (15) business days for claims.
b) Reception of queries, requests and complaints through the Call Center: Once the Operator hears the user's request, they must request their authorization to receive their personal data, but not before giving them the right to consult the published Privacy Notice. on the SERVIPARAMO company website www.serviparamo.com.co The queries, requests and claims received by this means will be processed by the company and its response will be given in writing to the notification address provided by the owner. Response times will be ten (10) business days for inquiries and fifteen (15) business days for claims.
c) Request for knowledge, updating and rectification of personal data: This will apply to partial, inaccurate, incomplete, fragmented, misleading data, or those whose processing is expressly prohibited or has not been authorized by the owner. The request made by the owner in this regard must be sent by postal mail to VIA 40 # 75 – 95 in the city of Barranquilla, or to the following email: aldocasalins@yahoo.es Response times will be ten (10) business days for inquiries and fifteen (15) business days for claims.
d) Request to revoke the authorization and/or request the deletion of the data: This will proceed at the request of the Owner (except in cases where the law expressly states that it is not applicable) or when the Superintendence of Industry and Commerce so determines, after verification. of non-compliance by INMOBILIARIA SERVIPARAMO with the constitutional and legal principles, rights and guarantees. Response times will be ten (10) business days for inquiries and fifteen (15) business days for claims.
e) Claims for inaccuracy or breach of obligations: The owner or his successors who consider that the information contained in a database must be corrected, updated or deleted, or when they consider that a breach of any of the duties has occurred. contained in Law 1581 of 2012, may submit a claim to INMOBILIARIA SERVIPARAMO by postal mail to VIA 40 # 75 – 95 in the city of Barranquilla, or to the following email: aldocasalins@yahoo.es Said claim will be processed under the following rules:
- The claim will be made through a request addressed to INMOBILIARIA SERVIPARAMO, with the identification of the owner, the description of the facts that give rise to the claim, the address, and accompanying the documents that you want to assert. If the claim is incomplete, the interested party will be required within five (5) days following receipt of the 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 abandoned the claim. In the event that the person receiving the claim is not competent to resolve it, he or she will forward it to the appropriate person within a maximum period of two (2) business days and will inform the interested party of the situation.
- Once the complete claim is received, a legend that says “claim in process” and the reason for it will be included in the database within a period of no more than two (2) business days. Said legend must be maintained until the claim is decided. 3. The maximum term to address the claim will be fifteen (15) business days counted from the day following the date of receipt. When it is not possible to address the claim within said term, the interested party will be informed of the reasons for the delay and the date on which their claim will be addressed, which in no case may exceed eight (8) business days following the expiration of the first term. When there is a claim, INMOBILIARIA SERVIPARAMO must inform the third parties with whom it has shared the personal data that is the subject of the claim, that said claim exists and is being processed. In addition to the above, you must insert the legend into the database “information in judicial discussion” once notified by the competent authority about judicial processes related to the quality of personal data; While the information is being disputed by its owner before the authority, INMOBILIARIA SERVIPARAMO will not be able to circulate it with third parties.
10.- Privacy Committee:
In order to comply with the provisions of Law 1581 of 2012 and its regulatory decree 1377 of 2013, the Privacy Committee is created. This committee is made up of the Director of Contracting and Legal Affairs of Serviparamo SAS, the Director of Human Management of Serviparamo SAS, the portfolio coordinator of Serviparamo SAS and the Chief Privacy Officer of Contracting and Legal Affairs of Serviparamo SAS. Its functions are the following:
- Provide mechanisms so that processes and controls are designed to ensure the protection of personal data, seeking to safeguard the request for authorization for the processing of personal data, compliance with the information processing policy, compliance with the policies of each area on habeas data, the operation of the consultation and response methods on requests associated with personal data, including its deletion.
- Resolve queries from the Computer Incident Response Group and the different areas of the company regarding the processing of personal data.
- Request modifications to the internal processes of the different areas of the company in order to keep them aligned with the habeas data standards and the Information Treatment Policy of INMOBILIARIA SERVIPARAMO.
- Study the authorization requests from the different areas of the company to share personal data captured by INMOBILIARIA SERVIPARAMO with third parties.
- Define the training and training programs, along with their periodicity, that are required by the staff and contractors of INMOBILIARIA SERVIPARAMO.
- Review the results of internal and external audits carried out on the processing of personal data and establish action plans based on their results. The Privacy Committee will meet every 6 months or whenever required. The person in charge of making the calls for meetings is the Privacy Officer.
11.- Update of this Policy:
INMOBILIARIA SERVIPARAMO reserves the right to update this Policy when required in accordance with its internal procedures and exercise of its activities. When it is updated, it must be informed through appropriate means to the owners of the data contained in its databases, prior to its implementation.
12.- Date of entry into force of the Policy:
The update of this policy is published on January 18, 2023 by INMOBILIAIRA SERVIPARAMO on the website of the company SERVIPARAMO SAS www.serviparamo.com.co