SQDM SAS, a company in charge of consulting and developing software in the development of its commercial activity, collects, stores and uses personal information of its clients, employees, suppliers, and natural persons who 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 said activity in accordance with the principles and guidelines contained in the Statute for the Protection of Personal Data, the decrees that regulate it, and the guide for the implementation of the principle of responsibility.
In order to protect and ensure the owners of personal data a due treatment of their information, 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, access and restricted circulation, security, and confidentiality.
The Personal Data Treatment policy of SQDM S.A.S. seeks to guarantee the right to Habeas Data of the natural persons who gave their personal data to society for proper treatment (Use, collection, deletion, storage, and circulation) in accordance with the purpose informed in the authorization given.
SQDM S.A.S. As the person responsible for the processing of personal data, it is a company incorporated by means of a private document dated July 26, 2005, a document registered in the Bogotá Chamber of Commerce on November 17, 2006, under number 01090709 of Book IX, identified company with NIT 900038222-8 and Commercial Registration 01653082 of 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 Superintendency 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 the matter, as well as the policies established for this purpose within SQDM S.A.S.
III. SCOPE OF THE INFORMATION PROCESSING POLICY
The owner of personal data is understood to be the “Natural person whose personal data is subject to treatment”, therefore the policy of SQDM S.A.S focuses on personal data from natural persons.
The coverage of these policies covers all employees, clients, suppliers of SQDM S.A.S., as well as potential clients with whom the company maintains communication.
Within the company, there is no treatment (Collection, storage, use, circulation, or deletion) of sensitive data (understanding sensitive data as those that affect the privacy of the Owner or whose improper use may generate discrimination such as; racial or ethnic origin, political orientation, religious convictions, among others) of the holders of personal 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:
Names, surname, type of identification, identification number, date and place of issue, marital status, Signature, nationality, electronic signature, position held, telephone numbers, office address, email, other identification documents, place, date of birth, age, etc.
1. Contact for marketing of all products and services offered by the company.
2. Invitation to all kinds 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.
Name, telephone, address, email.
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 fulfillment of obligations by the supplier.
Names, surnames, type and number of identity document, gender, city and home address, landline, cell phone, email, marital status, nationality, fingerprint, photo, personal and business location data, HR. Photo, resume, work and/or family references, medical fitness concept, disciplinary/judicial history.
In addition to the legal and contractual obligations derived 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 on social networks.
SQDM S.A.S informs the owners of the processing of personal data that the rights they can exercise are the following:
The revocation and/or deletion will proceed when the Superintendency of Industry and Commerce has determined that in the treatment the Responsible or Person in Charge have incurred in conduct contrary to this law and the constitution. Access free of charge to your personal data that have been subject to treatment.
SAW. AREA RESPONSIBLE FOR THE ATTENTION OF INQUIRIES AND CLAIMS
At SQDM S.A.S, the area responsible for handling requests, queries, and claims will be the Data Protection Officer through the following channel of attention to the owner of personal data:
ATTENTION VIA EMAIL
Our personal data protection officer will attend to any query, concern, complaint or claim, at the following address: HabeasData@sqdm.com according to the parameters established in the following chapter.
VII. CONSULTATION PROCEDURE
The owners of personal data or their successors in title may request that their personal data be consulted through the channels described in the previous chapter.
Consultations by email must contain at least: i) the complete identification of the owner, ii) the personal data that want to be consulted, iii) address, iv) email, v) in case of being successors, attach the respective document that proves it. The query will be attended by SQDM S.A.S., within a maximum term of ten (10) business days from the date of receipt of the email or the physical document. When it is not possible to attend the query within said term, SQDM S.A.S. will inform the interested party stating the reasons for the delay and will indicate the date on which their request will be dealt with within a maximum time of five (5) business days following the expiration of the first term.
When the query is not clear, is not understood, or does not meet the requirements to develop a response by SQDM SAS, the company will inform the owner or the successor in title to submit the query no later than 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 successor in title has desisted from the consultation.
If the person who receives the claim is not competent to resolve it, he or 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, then, the maximum term to attend the query will be fifteen (15) business days, as long as within ten (10) business days following receipt of the query by any means provided for it the owner is informed of the reason. of the delay, otherwise, the maximum term will be ten (10) business days.
VIII. CLAIM PROCEDURE
When the owner or successor in title considers that the information contained in our database should be subject to correction, authorization, deletion, or revocation of the authorization, he may submit a claim to the service channels provided for this purpose in the previous chapter.
This claim must contain at least: i) the complete identification of the owner, ii) description of the facts that give rise to the claim, iii) address of the home, iv) email, v) accompanying the documents that the owner or successor in title wants to enforce.
If the claim is incomplete SQDM S.A.S. will require the interested party within five (5) business 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, SQDM S.A.S. understands that the owner or successor in title has withdrawn from the claim.
SQDM S.A.S. will respond to the claim within a maximum term of 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 without exceeding eight (8) business days following the expiration of the first term.
The owners of personal data are informed that the deletion or revocation of authorization for data processing will not proceed when the owner has a legal or contractual duty to remain in the database of SQDM S. A. S.
SQDM S.A.S. You may only collect, store, use or circulate the personal data of an individual, for as long as is reasonable and necessary, following the purposes that justified the treatment, taking into account the provisions applicable to the matter in question and the aspects administrative, accounting, tax, legal and historical information. Once the purpose or purposes of the treatment have been fulfilled and without prejudice to legal regulations that provide otherwise, SQDM S.A.S. You must proceed to the deletion of the personal data in the possession of it.
As an exception to the above, SQDM S.A.S. may keep personal data when required to fulfill a legal or contractual obligation.
This treatment policy was developed by the company SQDM S.A.S. It begins its validity from October 10, 2016. Update Date April 20, 2020.
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