HABEAS DATA INFORMATION MANAGEMENT POLICY

OBJECT

Regulate the policies and procedures that will be applicable in the handling of personal data information by VIVIR BIEN CIA CONSTRUCCIONES LTDA, according to the provisions contained in Law 1581 of 2012 and Decree 1377 of 2013.

RESPONSIBLE FOR THE TREATMENT

Company name: LIVING WELL – COMPAÑIA DE CONSTRUCCIONES LTDA Nit. 900076069

Main office: Cra. 15 N 4-50 Edificio Molinos de Aragón Local 101

Telephones: 310 442 6003 – 320 727 6216 – (036) 315 4630

Website: vivirbiencia.com

Email: ventas@vivirbiencia.com posventas@vivirbiencia.com

SCOPE

This manual is applicable to the personal data of natural persons registered in the databases related to Suppliers, Potential Suppliers, Clients and Users of VIVIR BIEN CIA CONSTRUCCIONES LTDA, which are susceptible to treatment. It will apply to personal data that is collected and managed by VIVIR BIEN CIA CONSTRUCCIONES LTDA. If in the future, other legal persons become part of VIVIR BIEN CIA CONSTRUCCIONES LTDA, the manual will apply to those.

DEFINITIONS

For the application of the rules and procedures established in this manual, and in accordance with the provisions of article 3 of Statutory Law 1581 of 2012, it shall be understood as:

  • Authorization: Prior, express and informed consent of the Owner to carry out the Processing of personal data.
  • Database: Organized set of personal data that is subject to Treatment. Privacy Notice: Physical, electronic or any other format document, generated by the person responsible for the Treatment that is made available to the Owner for the Treatment of their personal data. Through this, the Holder of the information is informed of the existence of the applicable policies for the treatment of their personal data, together with the way to access them and the characteristics of the treatment of personal data.
  • Personal data: Any information linked or that can be associated with one or several specific or determinable natural persons, such as name and surname, identity document, age, address, region, country, city, postal code, landline telephone number, telephone number, etc. mobile phone, address, email address, advertising preferences, consumer preferences, channel preferences, complaints and claims, service news, basic and personal data, contact data, demographic data, taste data, preferences and habits.
  • 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 racial or ethnic origin, political orientation, religious or philosophical convictions, membership of unions, organizations social, 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.
  • Treatment Manager: Natural or legal person, public or private, that by itself or in association with others, performs the Processing of personal data on behalf of the Treatment Manager.
  • Responsible for the Treatment: Natural or legal person, public or private, that by itself or in association with others, decides on the database and/or the Treatment of the data.
  • Owner: Natural person whose personal data is subject to Treatment.
  • Treatment: Any operation or set of operations on personal data, such as the collection, storage, use, circulation or deletion of data, in any known or future technology.

BEGINNING

The principles that are stated below constitute the general parameters by which the provisions of this manual regarding the personal data of the people to whom the processing of their data is applicable will be applied:

  • Principle of purpose: The Processing of personal data by VIVIR BIEN CIA CONSTRUCCIONES LTDA must obey a legitimate purpose, which must be informed to the Owner.
  • Principle of freedom: The Processing of personal data may only be exercised with the prior, express and informed consent of the Owner of the information. Personal data may not be obtained or disclosed without prior authorization, or in the absence of a legal or judicial mandate that relieves consent.
  • Principle of veracity or quality: The information subject to Treatment must be true, complete, exact, updated, verifiable and understandable. The Processing of partial, incomplete, fractional or misleading data is prohibited.
  • Principle of transparency: In the Treatment, the right of the Holder to obtain from VIVIR BIEN CIA CONSTRUCCIONES LTDA, at any time and without restrictions, information about the existence of data that concerns him must be guaranteed.
  • Principle of access and restricted circulation: Personal data, except for public information, may not be available on the Internet or other means of dissemination or mass communication, unless access is technically controllable to provide restricted knowledge only to the Holders or authorized third parties.
  • Principle of security: The information subject to Treatment by VIVIR BIEN CIA CONSTRUCCIONES LTDA, must be handled with the technical, human and administrative measures that are necessary to grant security to the records avoiding their adulteration, loss, consultation, use or unauthorized access or fraudulent.
  • Principle of confidentiality: All persons involved in the Processing of personal data that are not of a public nature are obliged to guarantee the confidentiality of the information, even after the end of their relationship with any of the tasks included in the Treatment.

DATA PROCESSING

The information collected by VIVIR BIEN CIA CONSTRUCCIONES LTDA in the provision of its services and in general in the development of its corporate purpose, is mainly used to identify, maintain a record and control of the Suppliers, Potential Suppliers, Clients and Users of VIVIR BIEN CIA CONSTRUCCIONES LTDA and are collected and stored for the purposes listed below.

  • Provide the services and/or products acquired directly or with the participation of third parties.
  • Use the data for marketing activities such as communication, dissemination and promotion campaigns or product offerings and other activities derived from the strategic units of the same company.
  • Make reports with the different administrative authorities of national control and surveillance, police or judicial authorities, financial entities and / or insurance companies.
  • Internal administrative and/or commercial purposes such as: market research, audits, accounting reports, statistical analysis or billing, satisfaction surveys, offering or recognition of benefits typical of our loyalty program and after-sales service.
  • Transmission and/or transfer to third countries of the data provided, for the execution of activities related to the services and products purchased, whether they are servers, or security certificates, etc.
  • accounting records.
  • Correspondence.
  • Identification of fraud and prevention of money laundering and other criminal activities.
  • relationship as contractor, supplier
  • Reports to risk centers for breach of financial obligations derived from the commercial relationship.

RIGHTS OF THE HOLDER OF THE INFORMATION

In accordance with article 8 of Statutory Law 1581 of 2012, the Holder of personal data has the following rights:

  • Know, update and rectify your personal data, VIVIR BIEN CIA CONSTRUCCIONES LTDA in its capacity as Responsible and Processor.
  • Request proof of the authorization granted to VIVIR BIEN CIA CONSTRUCCIONES LTDA.
  • To be informed by VIVIR BIEN CIA CONSTRUCCIONES LTDA regarding the use that has been given to your personal data.
  • Submit complaints to the Superintendency of Industry and Commerce for violations of the provisions of Statutory Law 1581 of 2012, having exhausted the consultation or claim process as indicated in the aforementioned Law.
  • Revoke the authorization and/or request the deletion of the data when the Treatment does not respect the constitutional and legal principles, rights and guarantees.
  • Free access to your personal data that have been processed.

HOLDER AUTHORIZATION

The collection, storage, use, and circulation of personal data by VIVIR BIEN CIA CONSTRUCCIONES LTDA, requires the free, prior, express and informed consent of the Owner thereof. Without prejudice to the exceptions provided by law, the prior, express and informed authorization of the Owner is required for processing, which must be obtained by any means that can be subject to subsequent consultation and verification. When it comes to the collection of sensitive data VIVIR BIEN CIA CONSTRUCCIONES LTDA, the following requirements must be met: The authorization must be explicit. The Holder must be informed that he is not obliged to authorize the processing of said information. The Owner must be explicitly and previously informed which of the data that will be processed are sensitive and the purpose thereof.

CASES IN WHICH AUTHORIZATION IS NOT REQUIRED

The Owner’s authorization will not be necessary in the case of: Information required by a public or administrative entity in the exercise of its legal functions or by court order. Data of a public nature. Cases of medical or health urgency. Treatment of information authorized by law for historical, statistical or scientific purposes. Data related to the Civil Registry of People.

TAKING THE AUTHORIZATION.

The authorization can consist of a physical or electronic document, data message, website, in any other format that allows guaranteeing its subsequent consultation, or through an appropriate technical or technological mechanism, which allows expressing or obtaining consent via click or double click. , through which it can be unequivocally concluded that if the Holder had not acted, the data would never have been captured and stored in the database. The authorization will be generated by VIVIR BIEN CIA CONSTRUCCIONES LTDA and will be made available to the Owner in advance and prior to the processing of their personal data.

PROOF OF AUTHORIZATION

VIVIR BIEN CIA CONSTRUCCIONES LTDA will use the mechanisms it currently has, and will implement and adopt the tending and necessary actions to maintain records or suitable technical or technological mechanisms of when and how authorization was obtained from the Holders of personal data for the treatment of the themselves. To comply with the foregoing, physical files or electronic repositories may be established directly or through third parties hired for this purpose.

NOTICE OF PRIVACY

The Privacy Notice is the physical, electronic document or in any other format known or to be known, which is made available to the Owner for the processing of their personal data. Through this document, the Holder is informed of the information regarding the existence of the information processing policies that will be applicable to him, the way to access them and the characteristics of the treatment that is intended to be given to personal data.

ACCESS TO INFORMATION

Taking into account that the power to dispose of or decide on personal data is at the head of the Holder of the information, this power necessarily implies the right of the holder to access and know the personal information that is being processed, including in this aspect the scope, conditions and generalities of the treatment.

Taking into account the foregoing, this right is guaranteed at the head of the Holder, which includes.

  1. Knowledge of the existence of the processing of your personal data.
  2. Access to your personal data.
  3. The circumstances of the processing of personal data.

INFORMATION CONSULTATION

In accordance with article 14 of Statutory Law 1581 of 2012, the Holders or their successors in title may consult the personal information of the Holder that rests in any database. Based on this, this right is guaranteed by providing them with all the information contained in the individual record or that is linked to the identification of the Owner.

Depending on the nature of the personal database, the query will be managed by the area responsible for attending to it within VIVIR BIEN CIA CONSTRUCCIONES LTDA.

COMPLAINT ABOUT THE INFORMATION

In accordance with article 15 of Statutory Law 1581 of 2012, the Holder or his successors in title who consider that the information contained in a database must be subject to correction, updating or deletion, or when they notice the alleged breach of any of the duties contained in Statutory Law 1581 of 2012, may file a claim which will be processed under the following rules:

  1. The claim will be formulated by communication made by the owner or its originators addressed to VIVIR BIEN CIA CONSTRUCCIONES LTDA responsible or the person in charge of the Treatment, which must include the information indicated in article 15 of Statutory Law 1581 of 2012. If the claim is incomplete, the interested party will be required within five (5) days following receipt of the claim to correct the failures. After two (2) months from the date of the request, without the applicant submitting the required information, it will be understood that he has withdrawn the claim. In any case, if the communication is addressed to VIVIR BIEN CIA CONSTRUCCIONES LTDA and does not have the quality to respond to the communication, VIVIR BIEN CIA CONSTRUCCIONES LTDA, without the need to communicate it to the person making the claim, will inform the company of it. that you should answer.
  2. In the event that VIVIR BIEN CIA CONSTRUCCIONES LTDA receives a claim that it is not competent to resolve, it will notify the appropriate person within a maximum term of two (2) business days and inform the interested party of the situation.
  3. 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 term of no more than two (2) business days. Said legend must be maintained until the claim is decided.
  4. The maximum term to address the claim will be fifteen (15) business days 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.

At any time and free of charge, the natural person Owner of the personal data or his representative may request the rectification, update or deletion of his personal data after proving his identity, such request must be submitted through the provided means indicated in the notice privacy and must contain at least the following information:

  1. The name and address of the Holder or representative or any other means to receive the response to your request.
  2. The documents that prove the identity or representation of the Owner of the personal data.
  3. The clear and precise description of the personal data and the facts that give rise to the claim.
  4. The documents that you want to assert in the claim.

The deletion implies the total or partial elimination of personal information as requested by the Owner, from the records, files and databases or treatments carried out by VIVIR BIEN CIA CONSTRUCCIONES LTDA.

REVOCATION OF AUTHORIZATION

The holders of personal data may revoke consent to the processing of their personal data at any time, as long as it is not prevented by a legal or contractual provision. For this, VIVIR BIEN CIA CONSTRUCCIONES LTDA must establish simple and free mechanisms that allow the Holder to revoke her consent, at least by the same means by which it was granted.

It should be taken into account that there are two (2) modalities in which the revocation of consent can be given. The first, can be about all the consented purposes, that is, that VIVIR BIEN CIA CONSTRUCCIONES LTDA must completely stop processing the data of the Holder; the second, can occur on certain types of treatment, such as for advertising or market research purposes. With the second modality, that is, the partial revocation of consent, other purposes of the treatments that the person in charge, in accordance with the authorization granted, can carry out and with which the Holder agrees, are kept safe.

PROCEDURE REQUIREMENT

The Holder may only file a complaint with the Superintendency of Industry and Commerce once the consultation or claim process has been exhausted before VIVIR BIEN CIA CONSTRUCCIONES LTDA.

DUTIES OF VIVIR BIEN CIA CONSTRUCCIONES LTDA IN ITS CAPACITY AS RESPONSIBLE AND IN CHARGE OF DATA PROCESSING.

It is noted that the personal data subject to processing are the property of the persons to whom they refer and they are empowered to dispose of them. Based on the foregoing, it will only use personal data in accordance with the purposes established in the Law and respecting the provisions of Statutory Law 1581 of 2012, in accordance with article 17 of Statutory Law 1581 of 2012, they undertake to comply 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. Carry out, in the terms provided in articles 14 and 15 of Statutory Law 1581 of 2012, updating, rectifying or deleting the data.
  4. Process the queries and claims made by the owners in the terms indicated in article 14 of Statutory Law 1581 of 2012.
  5. Keep the information under the necessary security conditions to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access.
  6. Insert in the databases the legend “information under judicial discussion” once notified by the competent authority about judicial processes related to the quality or details of the personal data.
  7. Inform the Superintendence of Industry and Commerce when there are violations of security codes and there are risks in the administration of the information of the holders.
  8. Process queries and claims made by the owners of the information.
  9. Comply with the instructions and requirements issued by the Superintendence of Industry and Commerce.
  10. Apply the rules that regulate Statutory Law 1581 of 2012.

SECURITY OF THE INFORMATION

In development of the security principle established in Statutory Law 1581 of 2012, VIVIR BIEN CIA CONSTRUCCIONES LTDA will implement additional technical, human and administrative measures, if required, that are necessary to grant security to the records, through which their tampering, loss, consultation, use or unauthorized or fraudulent access.

  • REGISTRATION OF DATABASES
    VIVIR BIEN CIA CONSTRUCCIONES LTDA, in its capacity as Responsible and In Charge of Treatment, must proceed to the registration of the bases in the terms indicated by Colombian regulations.
  • ACCEPTANCE
    The holders of the information accept the treatment of their personal data in accordance with the terms of this Manual, at the time of providing their data.
  • VALIDITY
    This General Privacy Policy is effective from the date of its publication.

AUTHORIZATION

The terms of this PRIVACY POLICY are in addition to our TERMS AND CONDITIONS OF USE. By using this site, you signify your acceptance of this privacy policy and terms and conditions. If you do not agree to this policy, please do not use our Site. Your continued use of the Website means that you agree with our Privacy Policies and the way in which VIVIR BIEN CIA CONSTRUCCIONES LTDA S.A.S. collects and processes the Personal Information that you provide to us as described in this document.