Personal Data Treatment Policy
This Policy for Treatment, management and protection of personal data of Arrubla Devis Asociados S.A.S. (hereinafter "Arrubla Devis") is in force as of June 2017 for the time necessary for the development of the purposes of the processing of personal data authorized by the owners, making it available to all interested parties as provided by Statutory Law 1581 of 2012 and its regulatory decrees.
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The personal data that is in the custody of Arrubla Devis, in its capacity as responsible and/or manager as the case may be, will be processed in compliance with the Colombian legal system and good practices related to the personal data protection regime. The purposes of the processing of personal data by Arrubla Devis are as indicated below:
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I. Employees, Former Employees and Candidates
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a) Carrying out selection and contracting processes;
b) Payment of payroll, contributions to social security, social benefits, management of employee files and other labor procedures necessary for the connection, execution and termination of the employment relationship;
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II. Current and former clients, prospective clients and people who have provided their contact information through the website and social networks
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a) Submission of proposals for the provision of services;
b) Development of contracted legal advisory and judicial representation activities, if applicable;
c) Response to related communications;
d) Billing process;
e) Sending advertising, commercial and marketing information, updates and legal bulletins, among other types of information of interest.
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III. Suppliers and contractors
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a) Contact and contracting of suppliers for the request of offers, quotations or contracting of the goods or services necessary for the development of the corporate purpose;
b) Registry of suppliers.
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IV. Video surveillance
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Management of security incidents within the facilities against people, goods, physical and technological infrastructure. It is expressly stated that all the material obtained through video surveillance at the Arrubla Devis facilities, and therefore the personal data collected, will be kept exclusively for a term of twenty-five (25) calendar days from its capture and will then be permanently deleted.
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V. Generals
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Manage the necessary information for the correct development of the corporate purpose of Arrubla Devis and comply with its corporate, tax, accounting obligations, among others.
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To achieve the purposes described above, Arrubla Devis may collect, preserve and store, directly or through third parties, one or more databases, whether physical or electronic. With the authorization granted for the processing of personal data, it is understood that Arrubla Devis will have the broadest powers to carry out such processing, in accordance with the law and the provisions of this policy, without prejudice to the rights of the owners.
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The holders of the information or legally authorized persons have the right to know, update and rectify their personal data, to be informed about the use that has been made of them, to request proof of the authorization granted, to revoke it and/or request the deletion of your data in the cases in which it is appropriate and to access them free of charge. They also have the right to file complaints with the Superintendence of Industry and Commerce for infringements of the regulations on Habeas Data and to exercise other pertinent actions.
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When it is required to make inquiries and claims, the following procedure must be kept in mind:
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Queries
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Queries about personal data must be submitted in writing by the owners or by legally authorized persons (demonstrating a legitimate interest) at the email or correspondence address indicated at the end of this policy. These will be resolved within a maximum term of ten (10) business days from the date of receipt.
However, when it is not possible to respond to the query within said term, the interested party will be informed before the expiration of ten (10) days, stating the reasons for the delay and indicating the date on which the request will be addressed, which in In no case may it exceed five (5) business days following the expiration of the first term.
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claims
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The owners or legally authorized persons (demonstrating a legitimate interest) who consider that the information contained in an Arrubla Devis database should be corrected, updated or deleted, or who notice an alleged breach of any of the duties contained in Law 1581 of 2012 or another rule that replaces or regulates it, may submit a written claim through any of the channels provided for this purpose; it must contain the following information:
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• Name and identification of the holder.
• The precise and complete description of the facts giving rise to the claim.
• The physical or electronic address to send the response and report on the status of the process.
• The documents and other evidence that is intended to be asserted.
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If the claim is incomplete, Arrubla Devis will require the interested party within five (5) business days of receipt to rectify the requirements. After two (2) months from the date of the request, without the petitioner presenting the requested information, it will be understood that he has withdrawn from it. Once the complete claim has been received, Arrubla Devis will include in the respective database a legend that accompanies the personal data that indicates "claim in process" and the reason for it, within a term of no more than two (2) business days. Said legend will remain until the claim is decided.
The maximum term to address the claim will be fifteen (15) business days from the day following the date of receipt, and if it is not possible to respond within said term, Arrubla Devis will inform the interested party of the reasons for the delay and the date on which it will be attended, without exceeding, in any case, eight (8) business days following the expiration of the first term.
To make requests, queries and claims, or to exercise your rights as the owner of personal data, you can contact the administrative management of Arrubla Devis through the landline 604 3229884, the email arrubladevis@arrubladevis.com or by email physical addressed to our offices located in the city of MedellÃn, at carrera 37 No. 2 Sur - 34 and in the city of Bogotá, at calle 70 Bis No. 4 - 54. The personal data collected will remain in our databases for the time necessary for the purposes established herein, without prejudice to the rights of the owners.
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