PERSONAL DATA PROCESSING AUTHORIZATION AND PRIVACY POLICY

AEIOTU FOUNDATION

By accepting this policy or entering this website, I accept as the Owner of my Personal Data the Treatment of these by FUNDACIÓN CARULLA AEIOTU , its strategic allies, subsidiaries and parent companies in order to comply with the functions and obligations, coming from various operations carried out through electronic commerce. I accept that my Personal Data will be used for statistical purposes, marketing, contact, sending documentation, information, promotions, events of FUNDACIÓN CARULLA AEIOTU , or its allies or notifications, among others, unless I expressly or verbally state that it is delete, rectify or delete my Personal Data from their Databases through the mechanisms established in their policy.

 

Below, you will find the privacy and personal data treatment policy that FUNDACIÓN CARULLA AEIOTU has adopted, applying and complying with the obligations of Law 1581/2012, Decree 1377/2013, and other regulations that modify or add it. This policy is adopted because for FUNDACIÓN CARULLA AEIOTU it is very important to take care of your Personal Data, it is our purpose to fulfill the obligations that we have in front of them and in front of you as the Owner of the same.

FUNDACIÓN CARULLA AEIOTU , guarantees the rights of privacy, intimacy and good name in the treatment of your Personal Data, and consequently all our actions will be based on the principles of legality, purpose, freedom, truthfulness or quality, transparency, access and restricted circulation, security and confidentiality.

All people who, in the exercise of our commercial activities, provide us with any type of information or Personal Data, will be able to know, update and rectify it, that is, to exercise their habeas data rights, this is the main objective of our policy.

RESPONSIBLE FOR PERSONAL DATA

The person responsible for the personal data will be the FUNDACIÓN CARULLA AEIOTU brand, with its companies legally incorporated in the Republic of Colombia. Located mainly in Bogotá DC, to communicate with us and exercise your habeas data rights you can write to us by email: mercadeo@aeiotu.org

 

WHAT DO THE FOLLOWING TERMS MEAN IN THIS DOCUMENT?

  1. Personal Data (s): is any information linked or that may be associated with one or more natural persons.

  2. Private Data (s): it is the data that due to its intimate or reserved nature is only relevant for the Holder of the data.

  3. Public Data (s): these are the data relating to a person's marital status, profession or trade and the status of a merchant or public servant of a person. These data can be obtained and offered without any reservation and regardless of whether they refer to general, private or personal information.

  4. Semi-private data (s): it is the data that is not intimate, reserved, or public, whose knowledge or disclosure may interest not only its Holder but also a certain sector or group of people or politics in general, such as data financial and credit of commercial activity.

  5. Sensitive Data (s): are the data that affect the privacy of the Holder or whose improper use may generate discrimination, such as those that reveal racial or ethnic origin, political orientation, religious or philosophical convictions, membership to unions, social organizations, human rights organizations or that promote the interests of any political party, among others.

  6. Authorization: it is the prior, express and informed consent of the Holder for FUNDACIÓN CARULLA AEIOTU to carry out the Processing of their Personal Data.

  7. Database: it is the organized set of Personal Data that is subject to Treatment.

  8. Responsible for the Treatment: it is the natural or legal person, public or private, that by itself or in association with others, carries out the Treatment of your Personal Data on behalf of and on behalf of FUNDACIÓN CARULLA AEIOTU .

  9. Responsible for the Treatment: it is FUNDACIÓN CARULLA AEIOTU by itself or in association with others, it is the one that decides on the Database and / or the Treatment of Personal Data.

  10. Owner: you are the natural person whose Personal Data you are providing to FUNDACIÓN CARULLA AEIOTU and will be subject to Treatment;

  11. Treatment: is any operation or set of operations on your Personal Data, such as the collection, storage, use, circulation or deletion.

AUTHORIZATION

In compliance with the provisions of Law 1581 of 2012 and its Regulatory Decree 1377 of 2013, FUNDACIÓN CARULLA AEIOTU , a legally constituted foundation, governed under the laws of the Republic of Colombia, identified with the tax identification number NIT 860.006.648-1 , with main domicile in the city of Bogotá DC of the Republic of Colombia. (hereinafter " FUNDACIÓN CARULLA AEIOTU ", adopts this Policy for the Treatment of Personal Data (hereinafter "The Policy"), which will be informed to all holders of the data collected or that in the future are obtained through the email: mercadeo@aeiotu.org

 

All Treatment must be preceded by obtaining the Authorization. For this, the Company, its workers and Authorized third parties must refrain from collecting and Processing Personal Data if the Holder has not signed the respective Authorization. In addition, they should keep a copy of this Authorization for future reference.

Likewise, it is necessary that, in the subscription of the respective authorization, the owner authorizes the company, its workers and authorized third parties to consult the employability databases and social security form.

OBLIGATIONS OF THE AEIOTU FOUNDATION AS RESPONSIBLE FOR YOUR DATA

FUNDACIÓN AEIOTU will use your information solely and exclusively to comply with the functions and obligations, arising from various operations carried out through electronic commerce, as well as with the legal relationships that exist with our employees, managers and collaborators. In turn, you will have this information for statistical purposes, marketing, contact, customer service, sending documentation, information, promotions, own events or those of our allies or notifications, among others, unless you expressly or verbally state that it is delete, rectify or delete your data from our Database.

When carrying out any type of activity with FUNDACIÓN CARULLA AEIOTU , either in person or through electronic means, you must expressly or tacitly express your consent to the handling of your information. The consent must be free, prior, express and informed on your part as the Owner of the Personal Data for the Treatment thereof, except in the cases expressly authorized by law.

You can express your authorization as follows: (i) verbally at the time of purchase, (ii) in writing, and (iii) when you accept the terms and conditions of commercial relationships.

AUTHORIZATION IS NOT NECESSARY FOR THE TREATMENT OF YOUR PERSONAL DATA IN THE FOLLOWING CASES:

  • When said information is required by a public or administrative entity in the exercise of its constitutional or legal functions.

  • When there is a court order that orders it.

  • In the event of medical and / or health emergencies.

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

  • Data related to the civil registry of Persons.

  • Others established by law.

RIGHTS AS A PERSONAL DATA HOLDER

  • Know, update, rectify and request the elimination of your Personal Data from the FUNDACIÓN CARULLA AEIOTU Database

  • Be informed of the uses that are being given to your Personal Data.

  • File complaints and claims with the corresponding entities and with the CARULLA AEIOTU FOUNDATION receive a clear and complete response.

  • Revoke the authorization provided to FUNDACIÓN CARULLA AEIOTU for the Processing of your Personal Data.

  • Others established by law.

DUTIES OF THE AEIOTU FOUNDATION TO YOUR PERSONAL DATA

  • Request authorization for the processing of your Personal Data and inform you of the use that will be given to it.

  • Recognize the exercise of the fundamental right of habeas data.

  • Use the information in conditions of maximum security to prevent its loss, manipulation, adulteration or fraudulent use.

  • Update or rectify the information when you request it.

  • Others established by law.

HOW CAN I EXERCISE MY HABES DATA RIGHTS BEFORE THE AEIOTU FOUNDATION?

  • You must follow the procedure that we explain below:

  • Address your request to the AEIOTU FOUNDATION or its Managers by email sent to: mercadeo@aeiotu.org identify yourself fully as the Owner of Personal Data, describing in detail the facts that are giving rise to your request and attaching the documents you want.

  • If FUNDACIÓN CARULLA AEIOTU evidences that your request is incomplete, a request for additional information will be made within five (5) calendar days after receipt of your request to complete your request. If after two (2) months from the date of the request by FUNDACIÓN CARULLA AEIOTU , without submitting the additional information, it will be understood that you have withdrawn your request.

  • The maximum term to respond to your request will be fifteen (15) business days from the day following the date that FUNDACIÓN CARULLA AEIOTU received your request. When for FUNDACIÓN CARULLA AEIOTU it is not possible to meet your request within said term, the reasons for the delay and the date on which it will respond to your request will be reported, which in no case may exceed eight (8) business days following the expiration of the foreground.

  • You can only file a complaint with the Superintendency of Industry and Commerce once you have exhausted the direct application process before the CARULLA AEIOTU FOUNDATION as Responsible or Person in Charge of the Processing of your Personal Data.

6.     Obligations of the CARULLA FOUNDATION when it acts as Manager or Operator of the Processing of Personal Data

to)  Guarantee the Holder, at all times, the full and effective exercise of the right to habeas data.

b)  Keep the information under the necessary security conditions to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access.

c)  Timely update, rectify or delete the data in the terms of the Law.

d)  Update the information reported by the Treatment Managers within five (5) business days from receipt.

and)  Process the queries and claims made by the Holders in the terms indicated in the Law.

F)  Adopt an internal manual of policies and procedures to guarantee adequate compliance with the Law and, especially, for the attention of the procedures for inquiries and claims by the Holders.

g)  Register in the database the legend "claim in process" in the manner in which it is regulated in the Law.

h)  Insert in the database the legend "information in judicial discussion" once notified by the competent authority about judicial processes related to the quality of personal data.

i)  Refrain from circulating information that is being controversial by the Holder and whose blocking has been ordered by the Superintendency of Industry and Commerce.

j)  Allow access to information only to people who can have access to it.

k)  Inform the Superintendency of Industry and Commerce when there are violations of the security codes and there are risks in the administration of the information of the Holders.

l)  Comply with the instructions and requirements issued by the Superintendency of Industry and Commerce

7.     Purposes of the Treatment

The purposes of the Personal Data Processing carried out by the CARULLA FOUNDATION are the following:

7.1        Personal Data of children and adolescents linked to the CARULLA FOUNDATION and / or the AEIOTU PROGRAM.

to)  Carry out the process of selection, linking and unlinking of children and adolescents to the Carulla Foundation and / or the AEIOTU Program.

b)  Launch and operate the educational method for early childhood AEIOTU Program.

c)  Carry out the necessary monitoring of the educational and development process of children and adolescents.

d)  Issue Certificates, Minutes, Reports and any document related to the relationship, performance, psychological, physical and / or emotional state of the child.

and)  Notify legal representatives and / or guardians about the development, performance, performance, psychological, physical and / or emotional state of the child.

F)  Notify family members in case of emergencies during their stay at the facilities.

g)  Make use of the data to obtain statistics, parameters or other types of measurements in order to increase efficiency and improve the operation of the AEIOTU Program.

h)  Publication of images, photographs and videos in communication media and social networks in order to promote the services and products offered by the CARULLA FOUNDATION.

i)  Carry out transmission and / or transfer of personal data for the operation and provision of services provided by the CARULLA FOUNDATION and in the implementation and operation of the AEIOTU Program.

j) Analyze, process, evaluate, treat or compare the information provided for the monitoring, development and / or improvement, both individual and general, of conditions of services provided by the CARULLA FOUNDATION and / or in development of the AEIOTU Program, administration, security or attention, as well as for the implementation of marketing plans, campaigns, special benefits and promotions.

k)  Carry out the transfer of personal data to the competent entity when situations arise that threaten or endanger the life and integrity of the children benefiting from the aeioTU program so that the proper management of the case is carried out.

7.2        Personal Data of Third Parties Linked to the CARULLA FOUNDATION and / or the AEIOTU Program

to)  Development of service proposals offered by the CARULLA FOUNDATION .

b)  Realization and execution of contracts between FUNDACIÓN CARULLA and third parties.

c)  Customer service and marketing.

d)  Carry out billing procedures for services provided by the CARULLA FOUNDATION to third parties.

and)  Proposals and follow-up to allies and / or donors of the CARULLA FOUNDATION .

F)  Launch and operate the educational method for early childhood AEIOTU Program.

g)  Analyze, process, evaluate, treat or compare the information provided for the monitoring, development and / or improvement, both individual and general, of conditions of services provided by the CARULLA FOUNDATION and / or in development of the AEIOTU Program, administration, security or attention , as well as for the implementation of marketing plans, campaigns, special benefits and promotions.

h)  Publication of images, photographs and videos in communication media and social networks in order to promote the services and products offered by the CARULLA FOUNDATION

i) Carry out transmission and / or transfer of personal data for the operation and provision of services provided by the CARULLA FOUNDATION and in the implementation and operation of the AEIOTU Program.

7.3         Personal Data of Suppliers and Contractors

to)  Carry out processes of negotiation, selection and linking of suppliers and contractors.

b)  Make consignments and payments for services provided by suppliers and contractors.

c)  Launch and operate the educational method for early childhood AEIOTU Program.

d)  Analyze, process, evaluate, treat or compare the information provided for the monitoring, development and / or improvement, both individual and general, of conditions of services provided by the CARULLA FOUNDATION and / or in development of the AEIOTU Program, administration, security or attention , as well as for the implementation of marketing plans, campaigns, special benefits and promotions.

and)  Carry out transmission and / or transfer of personal data for the operation and provision of services provided by the CARULLA FOUNDATION and in the implementation and operation of the AEIOTU Program.

7.4        Personal Data of Participants in Selection Processes and Employees

to)  Carry out the selection, hiring and dismissal process of personnel.

b)  Celebrate the corresponding employment contract between the Owner and the staff, if chosen.

c)  Celebrate the corresponding employment contract between the Owner and the CARULLA FOUNDATION.

d)  To comply with the labor obligations of the CARULLA FOUNDATION , such as: affiliation to the Social Security System and payment of contributions, affiliation to the Compensation Fund and payment of contributions, payment to the DIAN of the amounts withheld, income certificates and withholdings, labor certificates requested by the Holder, and / or any information required by a national entity or authority that requires Personal Data, in accordance with current regulations.

and)  Make payroll payments in the bank account indicated by the Holder.

F)  If applicable, for the contracting of life insurance and medical expenses or for the granting of any other benefit that derives from the employment relationship with FUNDACIÓN CARULLA .

g)  Publication of images, photographs and videos in communication media and social networks in order to promote the services and products offered by the CARULLA FOUNDATION

h)  To notify family members in case of emergencies during their stay at the CARULLA FOUNDATION facilities .

i)  Launch and operate the educational method for early childhood AEIOTU Program.

 

Additionally, FUNDACIÓN CARULLA will provide Personal Data to companies linked to FUNDACIÓN CARULLA , such as parent companies and subsidiaries located in Colombia or any other country in accordance with the provisions contained in point 8 of this Policy.

8     Transfer and Transmission of Personal Data

In the Transfer and Transmission of Personal Data, the CARULLA FOUNDATION will comply with the following rules:

8.1        Transfer of Personal Data

The Transfer of Personal Data to countries that do not provide adequate levels of data protection is prohibited. Notwithstanding the foregoing, the CARULLA FOUNDATION may carry out data transfer when:

 

to)  The Holder has granted his express and unequivocal authorization for the transfer.

b)  Exchange of medical data is carried out, when required by the Holder's Treatment for health or public hygiene reasons.

c)  Bank or stock transfers are made, in accordance with the applicable legislation.

d)  Transfers agreed upon within the framework of international treaties to which the Republic of Colombia is a party are made, based on the principle of reciprocity.

and)  Transfers necessary for the execution of a contract between the Owner and the Data Controller are made, or for the execution of pre-contractual measures as long as the Owner's authorization is obtained.

F)  Transfers legally required are made to safeguard the public interest, or for the recognition, exercise or defense of a right in a judicial process.

8.2         Transmission of Personal Data

In the Transmission of Personal Data carried out by the CARULLA FOUNDATION as Responsible for the Treatment, it will comply with the provisions established in article 25 of Decree 1377 of 2013, regarding the contract for the transmission of personal data that it enters into with the Treatment Managers.

9.     Area Responsible for the Attention of Requests, Queries and Claims

The / The Communications Area - email protecciondatos@aeiotu.org of FUNDACIÓN CARULLA will be responsible for the attention of requests, queries, claims and complaints to ensure the exercise of the rights of the Owner of the Personal Data subject to Treatment by FUNDACIÓN CARULLA .

Procedure to Exercise the Rights of the Holder of Personal Data

9.1     Procedure for access and consultation

The Owner of the Personal Data, or any of the persons authorized in accordance with the provisions of point 4, may consult the information that resides in the databases of FUNDACIÓN CARULLA , for which they must formulate the corresponding request to the following email protection data @ aeiotu.org

 

To prevent unauthorized third parties from accessing the personal information of the Data Owner, it will be necessary to first establish the identification of the Owner. When the request is made by a person other than the Owner and it is not proven that it acts on his behalf, it will be deemed not submitted.

 

The query will be answered within a maximum term of ten (10) business days from the date of receipt. When it is not possible to attend the query within said term, the interested party will be informed, stating the reasons for the delay and indicating the date on which the query will be attended, which in no case may exceed five (5) business days following the expiration of the first term.

9.2        Procedure to request updating, correction, deletion, revocation of the authorization or to file a claim

The Holder, or any of the persons authorized in accordance with the provisions of point 4, who consider that the information contained in the databases of the CARULLA FOUNDATION should be subject to correction, updating or deletion, or when they notice the alleged breach of Any of the duties contained in Law 1581 of 2012, Decree 1377 of 2013 or any regulation that complements or modifies it, may file a claim with the CARULLA FOUNDATION , which will be processed in accordance with the following rules:

 

to)  The claim will be formulated by means of a request that will be sent to the following email protecciondatos@aeiotu.org and you can download the query / claim or complaint form at the following link www.aeiotu.org.

b)  To prevent unauthorized third parties from accessing the personal information of the Data Owner, it will be necessary to first establish the identification of the Owner. When the request is made by a person other than the Owner and it is not proven that it acts on his behalf, it will be deemed not submitted.

 

The request must contain the following information:

 

  1. The identification of the Holder.

  2. Contact information (physical and / or electronic address and contact telephone numbers).

  3. The documents that prove the identity of the Holder, or the representation of his representative.

  4. The clear and precise description of the personal data with respect to which the Holder seeks to exercise any of the rights.

  5. The description of the facts that give rise to the claim.

  6. The documents that you want to enforce.

  7. Signature, identification number and fingerprint.

c)  If the claim is incomplete, the CARULLA FOUNDATION will require the interested party within five (5) days following receipt of the claim to correct the faults. 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.

d)  If the Area that receives the claim is not competent to resolve it, it will transfer it to the appropriate person within a maximum term of two (2) business days and will inform the interested party of the situation.

and)  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 not exceeding two (2) business days. Said legend must be kept until the claim is decided.

f) 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 addressed, which in no case may exceed eight (8) business days following the expiration of the first finished.

10.     Data Suppression

The Holder has the right, at all times, to request the CARULLA FOUNDATION to suppress (delete) their personal data when:

 

to)  Consider that they are not being treated in accordance with the principles, duties and obligations provided in Law 1581 of 2012, Decree 1377 of 2013 and the other regulations that complement or modify them.

b)  They are no longer necessary or relevant for the purpose for which they were collected.

c)  The period necessary for the fulfillment of the purposes for which they were collected has been exceeded.

 

This deletion implies the total or partial elimination of personal information in accordance with what is requested by the Holder in the records, files, databases or treatments carried out by the CARULLA FOUNDATION.

The right of deletion is not absolute and the Controller may deny the exercise of it when:

to)  The Holder has a legal or contractual duty to remain in the database of the

CARULLA FOUNDATION.

b)  The deletion of Personal Data hinders judicial or administrative actions related to tax obligations, the investigation and prosecution of crimes or the updating of administrative sanctions.

c)  The Personal Data is necessary to protect the legally protected interests of the Holder, to carry out an action based on the public interest, or to comply with an obligation legally acquired by the Holder.

eleven.     Revocation of the Authorization.

The Holder of the personal data may revoke the consent to the Processing of their personal data at any time, as long as a legal provision does not prevent it.

The Holder of the personal data may revoke the consent to the Processing of their personal data at any time, as long as a legal provision does not prevent it.

The Holder of the personal data may revoke the consent to the Processing of their personal data at any time, as long as a legal provision does not prevent it.

12.     Security of the information.

In development of the security principle, the CARULLA FOUNDATION has adopted reasonable technical, administrative and human measures to protect the information of the Holders and prevent adulteration, loss, consultation, use or unauthorized or fraudulent access. Access to personal data is restricted to its Holders and the CARULLA FOUNDATION will not allow access to this information to third parties under conditions other than those announced, except for an express request from the Holder of the data or legitimate persons in accordance with the regulations. national. Notwithstanding the foregoing, the CARULLA FOUNDATION will not be responsible for any action tending to infringe the security measures established for the protection of Personal Data.

13.     Validity of the Policy.

The Policy applies as of October 18, 2016. As a general rule, the term of authorizations on the use of personal data is understood to be valid for the term of the commercial relationship or of the connection to the foundation and during the exercise of the object social of it.