GRUPO KALLPASAPA LTDA.
Razón social: GRUPO KALLPASAPA LTDA.
Tax ID (Nit): 900.161.936-3
Address: Carrera 9ª No. 113-35, Bogotá D.C.
Phone: (+57) 317 502 6246
Email: [email protected]
LEGAL REGULATIONS AND SCOPE OF APPLICATION:
This Personal Data Processing Policy is developed in accordance with the provisions of the Political Constitution, Law 1581 of 2012, and Regulatory Decree 1074 of 2015. It will be applied by KALLPASAPA GROUP regarding the collection, storage, use, and circulation of all activities involving the processing of personal data.
DEFINITIONS:
For the purposes of implementing this policy and in accordance with legal regulations, the following
definitions shall apply:
· Database: An organized set of personal data subject to internal processing by the company for administrative purposes.
· Public, private, and sensitive data will be treated responsibly and in accordance with the Habeas Data law when required. However, Kallpasapa Group strictly uses databases for internal purposes.
· Processor and data controller: A natural or legal person, public or private, who, either alone or in association with others, processes personal data on behalf of the data controller.
· Data subject: A natural person whose personal data is subject to processing.
·Processing: Any operation or set of operations performed on personal data, such as collection, storage, use, circulation, or deletion.
PURPOSE OF PERSONAL DATA COLLECTION AND PROCESSING:
KALLPASAPA GROUP may use personal data for the following purposes:
· Execute the existing contractual relationship with clients, suppliers, and employees, including the payment of contractual obligations.including the payment of contractual obligations.
· Proveer los servicios y/o los productos requeridos por sus usuarios;
· Provide services and/or products requested by users.
· Conduct internal studies on consumption habits.
· Carry out the selection, evaluation, and hiring process.
· Register information of employees and/or pensioners (active and inactive)
the databases of KALLPASAPA GROUP LTD.
Any personal data provided will only be used for the specified purposes. KALLPASAPA GROUP LTD will not sell, license, transmit, or disclose the information unless:
· There is explicit authorization to do so.
· It is necessary to enable contractors or agents to provide the requested services.
· It is necessary to provide our services and/or products.
· It is required or permitted by law.
The processing of personal data at KALLPASAPA GROUP LTD is governed by the following principles:
The processing of personal data at KALLPASAPA GROUP LTD is governed by the following principles:
· Purpose principle: The processing of collected personal data must serve a legitimate purpose.
· Freedom principle: Processing can only be carried out with the prior, express, and informed consent of the data subject. Personal data cannot be obtained or disclosed without prior authorization, except in cases where it is mandated by law or court order.
· Accuracy or quality principle: Processed information must be truthful, complete, accurate, up-to-date, verifiable, and understandable. Partial, incomplete, fragmented, or misleading data will not be processed.
· Transparency principle: The data subject has the right to obtain information about the existence of data concerning them from KALLPASAPA GROUP LTD at any time and without restrictions.
· Restricted access and circulation principle: Processing is subject to limits derived from the nature of personal data, the provisions of this law, and the Constitution. Personal data, except for public information and the information authorized by the data subject, cannot be made available on the Internet or other means of mass disclosure or communication unless access is technically controllable to provide restricted knowledge only to the data subjects or authorized third parties.
· Principio de seguridad: La información sujeta a Tratamiento por parte de GRUPO KALLPASAPA LTDA se deberá proteger mediante el uso de las medidas técnicas, humanas y administrativas que sean necesarias para otorgar seguridad a los registros evitando su adulteración, pérdida, uso o acceso no autorizado o fraudulento;
· Principle of confidentiality: All individuals involved in the processing of personal data are obligated to ensure the confidentiality of the information, even after the relationship involving the processing activities has ended.
FIRST PARAGRAPH: In the event that sensitive personal data is collected, the Data Subject may refuse to authorize its processing.
RIGHTS OF DATA SUBJECTS WHOSE PERSONAL
DATA IS PROCESSED BY GRUPO KALLPASAPA LTDA:
Data subjects, either directly or through their representative and/or attorney or legal successor, may exercise the following rights regarding the personal data that is subject to processing by GRUPO KALLPASAPA LTDA:
· Right to update, rectify, and delete: You may request the updating, rectification, and/or deletion of the personal data subject to processing, in order to fulfill the purposes of the processing;
· Right to request proof of authorization: except in cases where, according to current legal regulations, authorization is not required to carry out the processing;
· Right to be informed about the use of personal data;
Right to lodge complaints with the Superintendence of Industry and Commerce for infringements of current regulations on the processing of personal data;
Right to demand compliance with orders issued by the Superintendence of Industry and Commerce.
FIRST PARAGRAPH: In order to exercise the aforementioned rights, both the data subject and the person representing them must prove their identity and, if applicable, the capacity under which they represent the data subject.
SECOND PARAGRAPH: The rights of minors will be exercised by the individuals authorized to represent them.
DUTIES OF GRUPO KALLPASAPA LTDA:
All individuals obligated to comply with this policy must bear in mind that GRUPO KALLPASAPA LTDA is obligated to fulfill the duties imposed by law in this regard. Therefore, the following obligations must be met:
Duties when acting as data controller:
· Request and keep, under the conditions established in this policy, a copy of the respective authorization granted by the data subject.
· Clearly and sufficiently inform the data subject about the purpose of the collection and the rights granted to them by virtue of the authorization granted.
· Inform the data subject of their request regarding the use of their personal data.
· Process inquiries and complaints in accordance with the terms specified in this policy.
· Ensure that the principles of truthfulness, quality, security, and confidentiality are complied with as established in the following policy.
· Preserve the information under the necessary security conditions to prevent tampering, loss, or unauthorized access.
· Update the information when necessary.
· Rectify personal data when appropriate.
Duties regarding the Superintendence of Industry and Commerce:
· Report any potential security breaches and the existence of risks in the management of the data subjects' information.
· Comply with the instructions and requirements issued by the Superintendence of Industry and Commerce.
PERSON OR DEPARTMENT RESPONSIBLE FOR HANDLING REQUESTS, INQUIRIES, AND COMPLAINTS WHERE THE DATA SUBJECT CAN EXERCISE THEIR RIGHTS TO ACCESS,
UPDATE, RECTIFY, AND DELETE DATA, AND REVOKE CONSENT:
At GRUPO KALLPASAPA LTDA, the person or department responsible for handling requests, inquiries, and complaints where the data subject can exercise their rights to access, update, rectify, and delete data, and revoke consent is the administrative department. You can make inquiries via telephone at the fixed number in Bogotá
5200621, or contact us via email at [email protected].
PROCEDURE FOR DATA SUBJECTS TO EXERCISE THEIR RIGHTS TO ACCESS, UPDATE, RECTIFY, DELETE INFORMATION, AND REVOKE CONSENT:
The rights of data subjects can be exercised by the following authorized individuals in accordance
with Article 20 of Decree 1377 of 2013:
· The data subject, who must prove their identity.
· The data subject's heirs, who must prove such status.
· The representative and/or legal proxy of the data subject, after proving representation or power of attorney.
· A third party by stipulation or for the benefit of another.
To exercise your rights to access, update, rectify, delete information, and revoke consent, you must contact the responsible person or department in writing, as stated in the previous section. Additionally, according to Articles 14 and 15 of Law 1581 of 2012, you have the right to submit inquiries and complaints, for which the following
procedure must be followed.
If it is an inquiry, it will be addressed within a maximum period of ten (10) business days from the date of receipt. If it is not possible to address the inquiry within this period,
the interested party will be informed, stating the reasons for the delay and indicating the date by which the inquiry will be addressed, which in no case shall exceed five
(5) business days following the expiration of the initial period.
In the case of filing a complaint, it must be submitted in writing and directed to the responsible person or department, as
explained in the previous section. If the recipient of the complaint is not competent to resolve it, they will transfer it to the appropriate authority within a maximum period of two (2) business days
and inform the interested party of the situation.
The complaint should include your identification, a description of the facts giving rise to the complaint, your address, and any supporting documents. If the complaint is incomplete, the interested party will be requested to rectify the shortcomings within five (5) days following the receipt of the complaint. If, after two (2) months from the date of the request,
the applicant fails to provide the requested information, it will be considered as withdrawal of the complaint.
Once the complete complaint is received, a note stating "complaint in progress" and the reason for it will be included in the database within a maximum period of two (2) business days. This note must be kept until the complaint is resolved.
The maximum period for addressing the complaint will be fifteen (15) business days from the day following the date of its receipt. If it is not possible to address the complaint within this period, the interested party will be informed of the reasons for the delay and the date by which the complaint will be addressed, which in no case shall exceed eight (8) business days following the expiration of the initial period. If you require any additional information, please let us know. Si requiere cualquier información adicional no dude en hacérnoslo saber.
Grupo Kallpasapa Ltda
Domicile: Bogotá D.C.
Address: Carrera 9A No 113-36
Phone: 6012132390
Email: [email protected]
EFFECTIVE DATE OF THE INFORMATION PROCESSING POLICY AND DATABASE RETENTION PERIOD:
For these purposes, the present policy comes into effect as of October 18th, 2016.
Sincerely,
ADMINISTRATIVE AND FINANCIAL MANAGER
