SQDM S.A.S, a company in charge of carrying out consultancy and software development in the development of its commercial activity, collects, stores and uses personal information from its customers, employees, suppliers, and natural persons that could have a contractual or legal relationship with the company.
SQDM S.A.S. is aware of the implications of the Processing of Personal Data and therefore carries out this activity in accordance with the principles and guidelines contained in the Statute for the Protection of Personal Data (Law 1581 of 2012), the decrees that regulate it and the guide for the implementation of the principle of proven responsibility of the Superintendence of Industry and Commerce.
With a view to protecting and ensuring that the holders of personal data have their information properly processed, SQDM S.A.S. issues this Personal Data Processing Policy in compliance with the relevant regulations and the principles of legality, purpose, freedom, truthfulness or quality, restricted access and circulation, security and confidentiality referred to in Statute Law 1581 of 2012.
SQDM S.A.S.’s Personal Data Treatment policy seeks to guarantee the right to Habeas Data of individuals who have provided their personal data to the company for the proper treatment (Use, collection, deletion, storage and circulation) in accordance with the purpose informed in the authorization given.
II. IDENTIFICATION OF THE PERSON RESPONSIBLE FOR PROCESSING PERSONAL DATA
SQDM S.A.S., as the party responsible for processing personal data, is a company incorporated by means of a private document dated July 26, 2005, a document registered with the Chamber of Commerce of Bogotá on November 17, 2006, under number 01090709 of Book IX, a company identified with Tax Identification Number 900038222-8 and Commercial Registration Number 01653082 dated November 17, 2006.
SQDM S.A.S has appointed within its structure, a Personal Data Protection Officer according to the provisions of the Guide for the Implementation of the Principle of Demonstrated Responsibility of the Superintendence of Industry and Commerce. The Personal Data Protection Officer assumes the function of protecting personal data within the company, in compliance with the regulations that govern this matter, as well as the policies established for this purpose within SQDM S.A.S.
III. SCOPE OF THE INFORMATION PROCESSING POLICY
In accordance with Law 1581 of 2012, the holder of personal data is understood to be the “natural person whose personal data is the object of processing”. Therefore, SQDM S.A.S. policy focuses on personal data from natural persons.
The coverage of these policies covers all employees, customers, suppliers of SQDM S.A.S., as well as potential customers with whom the company maintains communication.
Within the company there is no treatment (collection, storage, use, circulation or suppression) of sensitive data (understanding sensitive data as that which affects the privacy of the Data Subject or whose improper use may generate discrimination such as; racial or ethnic origin, political orientation, religious beliefs, among others) of the Data Subject.
IV. PERSONAL DATA THAT CAN BE PROCESSED AND THE PURPOSE OF THE DATA.
SQDM S.A.S. processes the personal data indicated below according to the database and according to the purposes indicated in the following table
|CUSTOMERS||Names, last name, type of identification, identification number, date and place of issue, marital status, signature, nationality, electronic signature, position held, telephone numbers, office address, e-mail, other identification documents, place, date of birth, age, etc.||
1. Contact for marketing of all products and services offered by the company.
|SUPPLIERS||Name, phone, address, email.
|1. Contact for sending and paying invoices and other documents related to the contractual obligations within the relationship with the company.
2. Preparation of internal reports on the fulfillment of obligations by the supplier.
|WORKERS||Names, last names, type and number of identity card, sex, city and home address, landline phone, cell phone, email, marital status, nationality, fingerprint, photo, personal and business location data, HR. Photo, resume, work and/or family references, concept of medical aptitude, disciplinary/judicial background.||In addition to the legal and contractual obligations arising from the contract.
1. Promotion of social welfare activities within the company (Information on loans, credits and other promotions that the company may offer to its workers).
2. Contact for promotion of all products and services offered by the company.
3.Use of image by the company for social welfare, marketing or social responsibility activities, both internally and externally, including in social networks.
V. RIGHTS OF THE HOLDERS OF PERSONAL DATA
SQDM S.A.S informs the owners of the processing of personal data that the rights they can exercise in accordance with Law 1581 of 2012, are the following
1. To know, update and rectify their personal data in relation to the persons responsible for the processing or in charge of the processing. This right may be exercised against partial, inaccurate, incomplete, fractioned, or misleading data, or data whose processing is expressly prohibited or has not been authorized.
To request proof of the authorization granted to the Data Controller, except when expressly exempted as a requirement for processing, in accordance with the provisions of Article 10 of Law 1581 of 2012.
3. To be informed by the Data Controller or the person in charge of the processing, upon request, regarding the use that has been given to the personal data of the holder.
4. To submit to the Superintendence of Industry and Commerce complaints for violations to the provisions of the present law and other regulations that modify, add or complement it.
5. To 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 processing.
The revocation and/or suppression will proceed when the Superintendence of Industry and Commerce has determined that in the treatment the person in charge has incurred in conduct contrary to this law and the constitution.
VI. AREA RESPONSIBLE FOR THE ATTENTION OF CONSULTATIONS AND CLAIMS
In SQDM S.A.S the area responsible for attending to requests, queries and complaints will be the Data Protection Officer through the following channel of attention to the owner of the personal data:
ATTENTION VIA E-MAIL
Our personal data protection officer will attend to any consultation, concern, complaint or claim, at the following address: HabeasData@sqdm.com according to the parameters established in the following chapter.
VII. CONSULTATION PROCEDURE
The holders of personal data or their assignees may request the consultation of their personal data through the channels described in the previous chapter.
E-mail queries shall contain at least: i) full identification of the owner, ii) the personal data to be queried, iii) address, iv) e-mail, v) in the event of successors, attaching the relevant document proving it. SQDM S.A.S. will answer the query within a maximum of ten (10) working days from the date of receipt of the e-mail or the physical document. When it is not possible to answer the query within this period, SQDM S.A.S. shall inform the interested party, stating the reasons for the delay and indicating the date when the request will be answered within a maximum of five (5) working days following the expiry of the first period.
When the query is not clear, is not understood, or does not meet the requirements necessary to develop a response by SQDM S.A.S., the company will inform the holder or the successor in title who will again submit the query within five (5) working days of the request by the company. After two (2) months from the date of the request, without the applicant submitting the required information, SQDM S.A.S will understand that the holder or successor in title has withdrawn from the consultation.
In the event that the person receiving the complaint is not competent to resolve it, he or she will notify the person concerned within a maximum of two (2) working days and inform the interested party of the situation.
Thus, the maximum term to attend the consultation will be of fifteen (15) working days, provided that within ten (10) working days after the reception of the consultation by any means provided for it, the owner is informed of the reason for the delay, otherwise the maximum term will be of ten (10) working days.
VIII. COMPLAINT PROCEDURE
When the holder or successor in title considers that the information contained in our database should be subject to correction, authorization, suppression or revocation of authorization, he/she may file a claim with the service channels provided for such purpose in the previous chapter.
This claim must contain at least: i) full identification of the holder, ii) description of the facts giving rise to the claim, iii) address, iv) e-mail, v) accompaniment of the documents that the holder or successor in title wishes to assert.
If the claim is incomplete, SQDM S.A.S. will require the interested party to correct the faults within five (5) working days of receiving the claim. After two (2) months from the date of the request, without the applicant presenting the required information, SQDM S.A.S. will understand that the holder or successor in title has withdrawn the claim.
SQDM S.A.S. shall respond to the claim within a maximum of fifteen (15) working days from the day following the date of its receipt. When it is not possible to attend to the claim within this period, the interested party shall be informed of the reasons for the delay and the date on which the claim will be attended to within eight (8) working days following the expiry of the first period.
The holders of personal data are informed that deletion or revocation of authorization for data processing shall not proceed when the holder has a legal or contractual duty to remain in SQDM S. A. S.’s database.
IX. TIME LIMITATIONS ON THE PROCESSING OF PERSONAL DATAIn accordance with Decree 1377 of 2013, SQDM S.A.S. may only collect, store, use or circulate the personal data of an individual, for as long as is reasonable and necessary, in accordance with the purposes that justified the treatment, taking into account the provisions applicable to the matter in question and the administrative, accounting, tax, legal and historical aspects of the information. Once the purpose or purposes of the treatment have been fulfilled, and without prejudice to any legal regulations that may provide otherwise, SQDM S.A.S. must proceed to delete the personal data in its possession.
As an exception to the above, SQDM S.A.S. may keep the personal data when this is required to fulfil a legal or contractual obligation.
X.VALIDITY OF THE INFORMATION TREATMENT POLICY.
This treatment policy developed by SQDM S.A.S. is effective as of October 10, 2016. Updated on April 20, 2020.
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También disponible en: Spanish