1. GENERAL
This policy regulates the protection of personal data and establishes the legal guarantees that ALGRANEL S.A. must comply with. for the due treatment of said information, in compliance with the provisions of Law 1581 of 2012, Decree 1377 of 2013 and Decree 886 of 2014..
This personal data protection policy applies to all officials of ALGRANEL S.A., to the owners of the data and to those responsible for the treatment thereof, as well as to all the processes of the organization whose development involves the use of personal data.
2. DEFINITIONS
- AUTHORIZATION: Informed consent of the Owner to carry out the Processing of personal data
- PRIVACY NOTICE: Verbal or written communication generated by the Responsible, addressed to the Owner for the Treatment of your personal data, through which you are informed about the existence of the Information Processing policies that will be applicable, the way of accessing 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.
- PRIVATE DATA: It is the data that due to its intimate or reserved nature is only relevant to the person who owns the data.
- PUBLIC DATA: It is the data qualified as such according to the mandates of the Law or the Political Constitution and all those that are not semi-private or private. The data relating to the civil status of people, their profession or trade and their status as a merchant or public servant are public, among others. By their nature, these may be contained, among others, in public records, public documents, gazettes and official gazettes and duly executed judicial decisions that are not subject to reservation.
- SENSITIVE DATA: Information that affects the privacy of the person or whose improper use may generate their discrimination, such as those that reveal racial or ethnic origin, political orientation, religious or philosophical convictions, membership of unions, social organizations, 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 data related to health, sexual life and biometric data.
- RESPONSIBLE FOR THE TREATMENT: Person who decides on, among others, the collection and purposes of the treatment.
- DATA HOLDER: It is the natural person whose data is subject to Treatment.
- TREATMENT: Any operation or set of operations on personal data such as collection, storage, use, circulation or deletion.
3. PRINCIPLES
The following principles will govern the use of personal data by ALGRANEL S.A .:
- LEGALITY: The processing of personal data in Colombia is a regulated activity, therefore, the handling of the same must be carried out within the legal framework established by the competent authorities.
- PURPOSE: The processing of personal data must obey a legitimate purpose, in accordance with the Constitution and the law, which must be informed to the owner so that he expresses his consent.
- FREEDOM: The processing of personal data in ALGRANEL S.A. will be carried out with the prior, express and informed consent of the owner. Personal data may not be obtained, processed or disclosed without the authorization of the owner, unless a legal or judicial mandate relieves their consent.
- QUALITY OR VERACITY OF THE DATA: It is the responsibility of the owner of the personal information that this is true, complete, verifiable, understandable, accurate and updated..
- TRANSPARENCY: In the processing of personal data, the right of the holder to obtain and know from the person in charge and / or in charge of the treatment, at any time and without restrictions, information about the existence of data concerning him or her will be guaranteed.
- ACCESS AND RESTRICTED CIRCULATION: The personal data delivered to ALGRANEL S.A. They will be used only for a legitimate purpose, depending on the nature of the data and with the prior authorization of the owner. The owner, with his authorization, will empower ALGRANEL S.A. in the same way, to the transfer and transfer of your personal data for the purposes mentioned in this document to processors. The personal data in the custody of ALGRANEL SA, except for those classified as public information, may not be available on the Internet or in any other mass dissemination medium, unless the access is technically controllable and secure, and said access is intended to provide a Knowledge restricted only to the holders or authorized third parties in accordance with the provisions of the law and the principles that govern the matter. The events in which by express legal provision there must be disclosure of such data in mass media such as the Internet are excepted from the above.
- DATA SECURITY: ALGRANEL S.A. will adopt the technical, human and administrative measures that are necessary to guarantee security in order to avoid adulteration, loss, consultation, use or unauthorized or fraudulent access.
- CONFIDENTIALITY: ALGRANEL S.A. and all persons involved in the processing of personal data, have a professional obligation to save and maintain the reservation of such data, except for legal exceptions. This obligation subsists even after the relationship that gave rise to the collection and treatment of the data. ALGRANEL S.A. will implement, in its contractual relationships, data protection clauses in this regard.
- SPECIAL PROTECTION OF SENSITIVE DATA: ALGRANEL S.A. will not collect or process personal data exclusively linked to political ideologies, religious beliefs, sexual life, ethnic origin, and biometric data, unless expressly authorized by the owner or by express legal provision.
4. RIGHTS OF THE DATA HOLDERS
The owners of the personal data contained in databases that are located in the information systems of ALGRANEL S.A., have the rights described herein in compliance with the fundamental guarantees enshrined in article 8 of law 1581 of 2012:
- Know, update and rectify your personal data in front of the Treatment Managers or Treatment Managers. This right may be exercised, among others, against partial, inaccurate, incomplete, fractional data that is misleading, or those whose Treatment is expressly prohibited or has not been authorized..
- Request proof of the authorization granted to the Responsible for the Treatment except when expressly excepted as a requirement for the Treatment, in accordance with the provisions of article 10 of Law 1581 of 2012.
- Be informed by the Treatment Manager or the Treatment Manager, upon request, regarding the use that has been given to your personal data.
- Present before the Superintendence of Industry and Commerce complaints for infractions to the provisions of this law and the other regulations that modify, add or complement it.
- 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 Superintendency of Industry and Commerce has determined that in the Treatment the Responsible or Person in Charge has incurred in conduct contrary to the law and the Constitution.
- Free access to your personal data that has been processed.
- Have access to this Manual and its modifications in a timely manner, prior to their implementation.
The exercise of these rights will be free and unlimited by the owner of the personal data, without prejudice to legal provisions that regulate the exercise of the same. After verification of your identity, the information requested by the owner may be provided by any means, including electronic, as required by the owner and in accordance with the provisions of this policy. The information must be easy to read, without technical barriers that impede access, and must fully correspond to the information contained in the entity’s database.
5. DUTIES OF THOSE RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA
ALGRANEL S.A., abides by the rights described herein in compliance with the provisions of article 17 of law 1581 of 2012:
- Guarantee the holder, at all times, the full and effective exercise of their right of habeas data.
- Request and keep a copy of the respective authorization granted by the owner.
- Properly inform the owner about the purpose of the collection and the rights that assist him by virtue of the authorization granted.
- Keep the information under the necessary security conditions to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access.
- Guarantee that the information stored corresponds to that provided by the owner, based on the idea that it is truthful, complete, accurate, updated, verifiable and understandable.
- Update the information, communicating in a timely manner to the person in charge of the treatment, all the news regarding the data that has previously been provided and adopt the other necessary measures so that the information supplied to it is kept updated.
- Rectify the information when it is incorrect and communicate the pertinent to the person in charge of the treatment.
- Provide the person in charge of the treatment, according to the case, only data whose treatment is previously authorized.
- Require the data processor at all times, respect for the security and privacy conditions of the owner’s information.
- Process inquiries and claims formulated in the terms indicated in this policy.
- Adopt an internal manual of policies and procedures to guarantee compliance with the law and especially for the attention of queries and complaints.
- Inform the person in charge of the treatment when certain information is under discussion by the owner, once the claim has been presented and the respective procedure has not been completed.
- Inform at the request of the owner about the use given to their data.
- Inform the data protection authority when there are violations of the security codes and there are risks in the management of the information of the holders.
- Comply with the instructions and requirements issued by the Superintendence of Industry and Commerce.
6. SPECIFIC POLICIES FOR THE PROCESSING OF PERSONAL DATA.
6.1. Related Personal Data of Clients
ALGRANEL S.A. will only collect the data that is necessary, pertinent and not excessive to comply with the provisions of the conditions for the provision of services agreed with the clients.
The purposes for which the personal data of clients will be used are:
- Communication in the different stages of the provision of services.
- Inform about new services or modifications to existing ones.
- Contractual, commercial, customer service purposes, among others directly related to the name of ALGRANEL S.A. and the type of legal relationship it has with the owner of the data.
- Carrying out surveys on satisfaction with the services provided by ALGRANEL S.A.
- The prevention and control of money laundering and the financing of terrorism.
ALGRANEL S.A. may collect personal data from the transportation and inspection service providers of their clients, taking into account the characteristics of the services that they will perform at the facilities of ALGRANEL S.A.
Customer data is kept and managed under the responsibility of ALGRANEL S.A.
6.2. Personal Data related to the Management of Human Resources.
There will be independent databases for the processing of personal data, before, during and after the employment relationship.
6.2.1. Data processing before the contractual relationship.
ALGRANEL S.A. It will inform the people selected to participate in a selection process, the rules applicable to the treatment of personal data provided by the interested party, as well as those that are obtained during the selection process.
The purpose of the delivery of the data supplied by those interested in the vacancies of ALGRANEL S.A. and the personal information obtained from the selection process is limited to participation in it; therefore, its use for different purposes as well as its storage after the selection process is closed is strictly prohibited.
6.2.2. Data processing during the contractual relationship.
ALGRANEL S.A. It will store the personal data obtained during the employee selection process in a folder identified with the name of each one of them.
The personal data of employees is kept exclusively for the fulfillment of the following purposes:
- Management of the contractual relationship.
- To comply with Colombian or foreign law and the orders of judicial, administrative authorities or private entities in the exercise of public functions.
- Issue certifications regarding the relationship of the data owner with the company.
The use of employee information for purposes other than the administration of the contractual relationship is prohibited, unless there is express authorization by the owner for a different use or there is an order from a competent authority, provided that such power lies therein. It will correspond to ALGRANEL S.A. evaluate the competence and effectiveness of the order of the competent authority, in order to prevent an unauthorized transfer of personal data.
6.2.3. Data processing after the contractual relationship has ended.
After the employment relationship, whatever the cause, ALGRANEL S.A. will proceed to store the personal data obtained from the selection process and documentation generated in the development of the employment relationship, in a central file, under the measures and security levels that guarantee the protection of the information and prevent its unauthorized use.
The personal data of former employees is kept exclusively for the fulfillment of the following purposes:
- Comply with Colombian or foreign law and the orders of judicial, administrative or private entities in the exercise of public functions.
- Issue certifications related to the relationship of the data owner with the company.
6.3. Treatment of personal data of Shareholders.
The data of the natural persons who come to have the status of shareholder of ALGRANEL S.A., are confidential. Consequently, access to such personal information will be carried out in accordance with the provisions of the Commercial Code and other regulations that regulate the matter.
The purposes for which the personal data of the shareholders will be used are the following:
- Allow the exercise of duties and rights derived from the quality of shareholder.
- Sending invitations to events scheduled by the Company.
- Issuance of certifications relating to the relationship of the data owner with the company.
6.4. Treatment of personal data of Board of Directors Members.
The data of natural persons who become members of the Board of Directors will be used for the following purpose:
- Allow the exercise of duties and rights derived from membership of the board of directors.
- Sending invitations to events scheduled by the Company.
- To comply with Colombian or foreign law and the orders of judicial, administrative authorities or private entities in the exercise of public functions.
6.5. Treatment of personal data of suppliers and contractors.
ALGRANEL S.A. will only collect the data that is necessary, pertinent and not excessive for the purpose of selection, evaluation and execution of the contract agreed with the supplier / contractor.
The purposes for which the personal data of suppliers and contractors will be used are:
- Sending invitations to hire.
- Management of the pre-contractual, contractual and post-contractual stages.
- Conformity assessment.
- The prevention and control of money laundering and the financing of terrorism.
ALGRANEL S.A. You may collect personal data of the employees of your suppliers or contractors according to the characteristics of the services that are contracted with the supplier or contractor.
When ALGRANEL S.A. Give your employees data to their suppliers, they must protect the personal data provided. ALGRANEL S.A. will verify that the requested data is necessary, pertinent and not excessive with respect to the purpose underlying the request for access to them.
6.6. Treatment of personal data of third parties.
This treatment applies to third parties whose activities must be carried out in the company’s facilities, such as shipping companies, transporters, visitors, authorities and inspection companies. ALGRANEL S.A. will only collect the data that is necessary, pertinent and not excessive taking into account the characteristics of the services that they provide to the clients of ALGRANEL S.A.
The purposes for which the personal data of suppliers will be used are:
- Authorization to enter and execute activities within the company’s facilities.
- Communication in the different activities in which they intervene.
- Comply with Colombian or foreign law and the orders of judicial, administrative or private entities in the exercise of public functions.
6.7. Delivery of personal data to the authorities
When ALGRANEL S.A. If you receive a request from a State authority for access and / or delivery of personal data that resides in company databases, the remission of the personal data provided will be recorded.
7. EXCLUSIONS
The authorization of the owner will not be necessary in the cases described in Article 10 of Law 1581 of 2012.
8. CONSULTATION, MODIFICATION OR SUPPRESSION OF PERSONAL DATA
The holders of the information may request at any time the consultation, correction, updating or deletion of the data that ALGRANEL S.A. have in your databases. Likewise, the owner may file a complaint for the alleged breach of any of the duties contained in Law 1581 of 2012, Decree 1377 of 2013 and in this policy. To do this, the owner must submit his request in writing to the email bta@algranel.com.co
The maximum term to attend to the request will be ten (10) business days from the date of its receipt. When it is not possible to meet the request or claim within said term, the interested party will be informed of the reasons for the delay and the date on which their request will be met, which in no case may exceed five (5) business days after expiration. of the first term.
Claims will be handled according to the provisions of Article 15 of Law 1581 of 2012.
The Contracting and Entities area will be in charge of handling all the requests that are made regarding data protection. These will be resolved in accordance with the provisions of Title V of Law 1581 of 2012.
9. AUTHORIZATION OF PROCESSING OF PERSONAL DATA
The holders of personal data may authorize by signing the “Privacy Notice” or by email used for the dissemination of the policy or the suggestion box located at each headquarters.
In case of not receiving a statement from the owner, after 30 business days of having been informed of the personal data processing policy, ALGRANEL S.A. understand that you are authorized to continue with the processing of personal data as specified, until the owner of the data expressly states otherwise.
10. VALIDITY
This personal data protection policy is effective as of its publication and is mandatory for all ALGRANEL S.A. employees.
ALGRANEL S.A. prohibits access, use, management, transfer, communication, storage and any other processing of personal data without the authorization of the owner thereof.
This information is published on our website www.algranel.com.co Contact Section.
ALGRANEL S.A.
Responsible: Contracting Area and Entities
Address: Carrera 13 # 63 – 39 Piso 12
Bogotá D.C. – Colombia
Email: bta@algranel.com.co
PBX: (571) 640 96 66
Fax: (571) 235 35 84
NOTICE OF PRIVACY
In compliance with the provisions of Law 1581 of 2012, Decree 1377 of 2013 and Decree 886 of 2014, ALGRANEL S.A. You are allowed to communicate that you have the Personal Data Protection Policy for the use, treatment and protection of personal data that you have obtained in the course of your activities.
This information is and will be used in the development of the functions of ALGRANEL SA, in its condition as a corporation, directly for the management of information for labor, legal, commercial purposes and for the development of its corporate purpose, the foregoing , in accordance with the personal data treatment policy, available for consultation on our website in the “Contact us” section
1. Identification of the Responsible.
Business name: ALGRANEL S.A.
Web page: www.algranel.com.co
Registered Office: Bogotá D.C. – Colombia
Address: Carrera 13 # 63 – 39 Piso 12
Email: bta@algranel.com.co
Telephone: (571) 640 96 66
2. Treatment and purpose.
The data provided by our clients and their suppliers (including but not limited to: Shipping Companies, Inspectorate Companies and Transporters) may be used by ALGRANEL S.A. for the development of its corporate purpose, for which collection, storage, copying, updating, ordering, classification, transfer, correction, verification and use for statistical purposes of the data provided is carried out.
The personal data of the suppliers and contractors will be used by ALGRANEL S.A. with the purpose that indicates the contractual relationship agreed between the parties.
With respect to the personal data of the Company’s workers, they may also be processed by ALGRANEL S.A in order to correctly manage the employment relationship.
3. Validity.
This authorization will be valid from the date of its acceptance and will remain in force until the owner of the information requests the revocation or deletion of it, the labor, commercial or contractual relationship between ALGRANEL and the owner of the personal data is terminated. and / or the applicable legal terms of retention of information expire.
4. Rights of the holders.
The holders of personal data, in accordance with the law, have the right to consult, modify, update and rectify their personal data in front of ALGRANEL SA, as well as to be informed about the use that has been made of their personal data, to revoke the authorization granted and / or request the deletion of the stored data, simply and free of charge. The holders of the information may exercise the rights established in Law 1581 of 2012, through the following means:
http://www.algranel.com.co/ In the section “Contact us”
Email: bta@algranel.com.co
Or by sending your communication to Carrera 13 # 63 – 39 Piso 12 in Bogotá
5. AUTHORIZATION OF PROCESSING OF PERSONAL DATA
The holders of personal data may authorize by signing the “Privacy Notice” or in writing by means of the email used for the dissemination of the policy or the suggestion box located at each site.
In the event of not receiving a statement from the owner, at the end of 30 working days of having been informed of the policy on the processing of personal data, ALGRANEL S.A. You will understand that you are authorized to continue processing information as specified, until the owner of the data expressly states otherwise, in accordance with the provisions of Article 10 of Decree 1377 of 2013.
