Personal data processing policy

SQDM

SQDM S.A.S., a company in charge of consulting and software development in the development of its commercial activity, collects, stores and uses personal information of its customers, employees, suppliers, and natural persons who may 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 performs such 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.

In order to protect and ensure that the holders of personal data are duly treated, SQDM S.A.S. issues this Personal Data Treatment Policy in compliance with the relevant regulations and the principles of legality, purpose, freedom, truthfulness or quality, access and restricted circulation, security and confidentiality as set forth in the Statutory Law 1581 of 2012.

 

I. OBJECT
The Personal Data Treatment Policy of SQDM S.A.S. seeks to guarantee the right to Habeas Data of the natural persons who delivered their personal data to the company for the due treatment (Use, collection, suppression, storage and circulation) according to the purpose informed in the given authorization.

 

II. IDENTIFICATION OF THE PERSON RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA

SQDM S.A.S. as responsible for the processing of personal data, is a company incorporated by private document dated July 26, 2005, document registered in the Chamber of Commerce of Bogota on November 17, 2006, under number 01090709 of Book IX, company identified with NIT 900038222-8 and Commercial Registration 01653082 of November 17, 2006.

SQDM S.A.S. has designated 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 governing the matter, as well as the policies established for that purpose within SQDM S.A.S.

 

III. SCOPE OF THE INFORMATION PROCESSING POLICY

According to Law 1581 of 2012, the holder of personal data is understood as the “natural person whose personal data is subject to processing”, therefore the policy of SQDM S.A.S. 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 those that affect the privacy of the Holder or whose improper use can generate discrimination such as; racial or ethnic origin, political orientation, religious convictions, among others) of the holders of personal data.

 

IV. PERSONAL DATA SUBJECT TO PROCESSING AND PURPOSE OF THE DATA.
SQDM S.A.S. treats the personal data indicated below according to the database and according to the purposes indicated in the following table:

  PERSONAL INFORMATION PURPOSE
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, location, date of birth, age, etc.

1. Contact for marketing of all products and services offered by the company.
2. Invitation to all types of events related to the promotion of the company’s products and services (technical, advertising and commercial information), as well as the launching of new services.

SUPPLIERS Name, telephone, address, e-mail.

 

 

1. Contact for remittance and payment of invoices and other documents related to the contractual obligations framed within the relationship with the company.
2. Preparation of internal reports on the supplier’s compliance with its obligations.
WORKERS Names, surnames, type and number of identity document, sex, city and home address, landline telephone, cell phone, e-mail, marital status, nationality, fingerprint, photo, personal and business location data, HR. Photo, resume, work and/or family references, medical fitness concept, disciplinary / judicial record. 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 employees).
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 on 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 may exercise in accordance with Law 1581 of 2012, are the following:

1. To know, update and rectify their personal data with respect to the Data Controllers or Data Processors. This right may be exercised against partial, inaccurate, incomplete, incomplete, fractioned, misleading data, or data whose processing is expressly prohibited or has not been authorized.
2. Request proof of the authorization granted to the Data Controller, except when expressly exempted as a requirement for the processing, in accordance with the provisions of Article 10 of Law 1581 of 2012.
3. To be informed by the Data Controller or the Data Processor, upon request, regarding the use that has been made of the holder’s personal data.
4. To file before the Superintendence of Industry and Commerce complaints for violations of the provisions of this 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 treatment does not respect the constitutional and legal principles, rights and guarantees.

The revocation and/or suppression will proceed when the Superintendence of Industry and Commerce has determined that in the treatment the Responsible or Entrusted have incurred in conducts contrary to this law and the constitution.Access free of charge to their personal data that have been processed.

 

VI. AREA RESPONSIBLE FOR HANDLING QUERIES AND COMPLAINTS
In SQDM S.A.S. the area responsible for the attention of requests, queries and claims will be the Data Protection Officer through the following channel of attention to the holder of the personal data:

ATTENTION VIA E-MAIL

Our personal data protection officer will respond to any inquiry, 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 successors in title may request the consultation of their personal data through the channels described in the previous chapter.

Inquiries by email must contain at least: i) the complete identification of the owner, ii) the personal data to be consulted, iii) address, iv) email, v) in case of being successors attach the respective document that proves it. The consultation will be attended by SQDM S.A.S., in a maximum term of ten (10) working days from the date of receipt of the email or physical document. When it is not possible to attend the consultation within such term, SQDM S.A.S. will inform the interested party expressing the reasons for the delay and will indicate the date on which the request will be attended within a maximum of five (5) working days following the expiration of the first term.

When the consultation is not clear, is not understood, or does not meet the necessary requirements to develop a response by SQDM S.A.S., the company will inform the holder or assignee to resubmit the consultation no later than within five (5) business days following 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 owner or assignee has abandoned the request.

In the event that the person who receives the claim is not competent to resolve it, he/she will transfer it to the corresponding person within a maximum term of two (2) business days and will inform the interested party of the situation.

Thus, the maximum term to attend the consultation will be fifteen (15) business days, provided that within ten (10) business days following the receipt of the consultation by any means provided for this purpose, the holder is informed of the reason for the delay, otherwise the maximum term will be ten (10) business days.

 

VIII. COMPLAINT PROCEDURE
When the holder or assignee considers that the information contained in our database should be subject to correction, authorization, deletion or revocation of authorization, he/she may file a claim to the attention channels provided for such purpose in the previous chapter.

This claim must contain at least: i) complete identification of the owner, ii) description of the facts giving rise to the claim, iii) address, iv) e-mail address, v) accompanying documents that the owner or assignee wishes to assert.

If the claim is incomplete, SQDM S.A.S. will require the interested party within five (5) working days from the receipt of the claim to correct the faults. After two (2) months from the date of the requirement, without the applicant submitting the required information, SQDM S.A.S. will understand that the owner or assignee has withdrawn the claim.

SQDM S.A.S. will respond to the claim within a maximum period of fifteen (15) business days from the day following the date of receipt. When it is not possible to address the claim within that period, the interested party will be informed of the reasons for the delay and the date on which the claim will be addressed within eight (8) business days following the expiration of the first term.

The holders of personal data are informed that the deletion or revocation of authorization for data processing will not proceed when the holder has a legal or contractual duty to remain in the database of SQDM S. A. S. S.

 

IX. TIME LIMITATIONS ON THE PROCESSING OF PERSONAL DATA
According to Decree 1377 of 2013, SQDM S.A.S. may only collect, store, use or circulate the personal data of an individual, for the time that is reasonable and necessary, according to the purposes that justified the treatment, taking into account the provisions applicable to the matter in question and the administrative, accounting, fiscal, legal and historical aspects of the information.  Once the purpose or purposes of the processing have been fulfilled, and notwithstanding legal regulations to the contrary, SQDM S.A.S. shall proceed to the deletion of the personal data in its possession.

As an exception to the above, SQDM S.A.S. may retain personal data when required to comply with a legal or contractual obligation.

 

X.VALIDITY OF THE INFORMATION PROCESSING POLICY.
This treatment policy developed by the company SQDM S.A.S. is effective as of October 10, 2016. Date of Update April 20, 2020.

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