Data processing policy

Identification of the person responsible:

In accordance with articles 15 and 20 of the Political Constitution of Colombia, Law 1581 of 2012, Regulatory Decree 1377 of 2013 and all other regulations that complement or modify them, ALCE LEATHER BASIC SAS will act as responsible for the treatment of the personal data by virtue of the collection carried out on the owners of the information.
Identification of the person responsible:
ALCE LEATHER BASICS SAS commercial company, identified with Nit. 901.627.328, domiciled at Cross Business Center office 505 Poblado, Medellín, Antioquia. Telephone: +57 3225017800 and email info@alceleather.com
Aim:
The objective of this personal data protection policy is to guarantee the confidentiality of information and the security of the data of clients, suppliers, collaborators and third parties from whom ALCE LEATHER BASICS SAS has obtained information and personal data, in accordance with the established guidelines. by the Data Protection Law.
Legal framework:
This personal data protection policy complies with the provisions of articles 15 and 20 of the Political Constitution of Colombia, Law 1581 of 2012, Regulatory Decree 1377 of 2013 and all other regulations that complement or modify them.
Definitions:
In accordance with the regulations on the protection of personal data, the following terms will be defined:

Authorization: Prior, express and informed consent of the Owner to carry out the processing of personal data.

Databases: Organized set of personal data that is subject to processing.
Habeas data: Fundamental right of every person to know, update, rectify and/or cancel the information and personal data that have been collected and/or processed in public or private databases, in accordance with the provisions of the law and others. applicable regulations.
Personal data: Any information linked or that can be associated with one or more specific or determinable natural persons.
Data Processor: Natural or legal person, public or private, who, by themselves or in association with others, processes personal data on behalf of the person responsible for data processing.
Data Controller: Natural or legal person, public or private, who, by themselves or in association with others, decides on the database and/or the processing of personal data.
Owner: Natural person whose personal data is processed.
Data processing: Any operation or set of operations on personal data, such as collection, storage, use, circulation or deletion.
Privacy notice: Verbal or written communication generated by the person responsible, addressed to the owner for the processing of personal data, through which he or she is informed about the existence of the information processing policies that will be applicable to the way of accessing the information. themselves and the purposes of the treatment that is intended to be given to personal data.
Public Data: It is data that is not semi-private, private or sensitive. Public data are considered, among others, data relating to the marital status of people, their profession or trade, and their status as a merchant or public servant. Due to its nature, public data may be contained, among others, in public registries, public documents, official gazettes and bulletins, and duly executed judicial rulings that are not subject to reservations.
Sensitive data: Sensitive data is understood to be data that affects the privacy of the owner or whose improper use may lead to discrimination, such as data that reveals racial or ethnic origin, political orientation, religious or philosophical convictions, membership in unions, social organizations, human rights organizations or that promote the interests of any political party or that guarantee the rights and guarantees of opposition political parties, as well as data related to health, sexual life and biometric data.
Transfer: The transfer of data takes place when the person responsible and/or in charge of the processing of personal data, located in Colombia, sends the information or personal data to a recipient who in turn is the person responsible for the treatment and is located inside or outside from the country.
Transmission: Processing of personal data that involves communicating it within or outside Colombian territory when its purpose is to carry out processing by the person in charge on behalf of the person responsible.
Personal database: It is any organized set of personal data.
Automated database: Organized set of personal data, which are created, processed and/or stored through computer programs or software.
Non-automated database: Organized set of personal data, created, processed and/or stored manually.
Transfer of data: Processing of personal data that involves its transfer to a person other than the owner of the data or other than the person authorized as transferee.
Custodian of the database: This is the natural person who has custody of the personal database within ALCE LEATHER BASICS SAS.

Beginning:

ALCE LEATHER BASICS SAS, has incorporated into the data protection policy, the general principles on personal data protection established in article 4 of Law 1581 of 2012.

Validity and application:

The personal data protection policy will have an indefinite validity, in accordance with the duration of the corporate purpose of ALCE LEATHER BASICS SAS.
It will apply to the processing of databases in which ALCE LEATHER BASICS SAS is responsible for the personal data of the owners of the information.
Any situation that is not provided for in the policy will be regulated in accordance with the applicable regulations on personal data protection.
ALCE LEATHER BASICS SAS may update this personal data protection policy at any time in accordance with applicable regulations and notifying the owner of the changes made.
Duties of ALCE LEATHER BASICS SAS as responsible and in charge of processing personal data.
In accordance with article 17 of Law 1581 of 2012 ALCE LEATHER BASICS SAS will have the following duties as responsible and in charge of data processing:

Responsible

Guarantee the holder, at all times, the full and effective exercise of the right of habeas data.
Request and keep, under the conditions provided for in this law, a copy of the respective authorization granted by the owner.
Duly inform the owner about the purpose of the collection and the rights granted to him by virtue of the authorization granted.
Maintain the information under the security conditions necessary to prevent its adulteration, loss, consultation, unauthorized or fraudulent use or access.
Guarantee that the information provided to the data processor is true, complete, accurate, updated, verifiable and understandable
Update the information, communicating in a timely manner to the person in charge of the treatment, all the news regarding the data that you have previously provided and keep it updated.
Rectify the information when it is incorrect and inform the person in charge of the treatment.
Provide the processor only with data whose processing is previously authorized by the owner of the personal data.
Demand from the person in charge of processing personal data the security and privacy of the information of the owner of personal data.
Process queries and claims made in the terms indicated by Law 1581 of 2012.
Adopt policies to guarantee compliance with regulations, especially for handling queries and complaints.
Inform the Data Processor when certain information is under discussion by the owner.
Inform at the request of the owner about the use given to their data.
Inform the data protection authority when violations of security codes occur and there are risks in the administration of the owners' information.
Comply with the requirements and instructions issued by the Superintendence of Industry and Commerce.

Duties of the person in charge of processing personal data:

Guarantee the holder, at all times, the full and effective exercise of the right of habeas data
Maintain the information under the security conditions necessary to prevent its loss, adulteration, consultation, unauthorized or fraudulent use or access.
Timely update, rectify or delete the owner's data.
Update the information reported by the person responsible for data processing within five (05) business days from receipt.
Process queries and claims made by the owners of the information.
Guarantee adequate compliance with regulations on personal data protection issues, especially in queries and claims made by the owners.
Refrain from circulating information that is being controversial by the owner and whose blocking has been ordered by the Superintendence of Industry and Commerce and inform the owner when violations or risks arise regarding the information of the owners.
Comply with the requirements and instructions issued by the Superintendence of Industry and Commerce.

Purposes of personal data processing:

Establish communication channels with the owner of the personal data through any communication channel that is authorized by the owner.
Grant incentives to the owner of personal data, with the purpose of promoting sales, bonuses, discounts, or any other activity associated with customer loyalty.
Carry out transactional behavior studies, with the purpose of executing strategies for the service offering of ALCE LEATHER BASICS SAS, third parties or future allies.
Execute customer service procedures.
Carry out personal data update campaigns and commercial campaigns.
Promote and coordinate strategic campaigns of the service offering of ALCE LEATHER BASICS SAS
Provide commercial information for the execution of contractual relationships acquired by ALCE LEATHER BASICS SAS
Consult, report, process and disclose all information that refers to the financial, commercial and service behavior of the information owner, to any information operator or entity for commercial and credit services purposes.
Consult, evaluate and analyze the information of the owner of the information to control money laundering and terrorist financing.

Rights of the data owner:

Access, know, update, rectify and delete your personal data in front of ALCE LEATHER BASICS SAS in its capacity as responsible for the processing of personal data.
Request proof of the authorization granted to the person responsible for the processing of personal data.
Be informed by the person responsible and/or the person in charge of processing personal data about the use that has been given to your personal data.
Submit complaints to the Superintendency of Industry and Commerce for infringements by the person responsible or in charge of processing personal data.
Revoke the authorization and/or request the deletion of personal data when the constitutional and legal principles, rights and guarantees are not respected in their processing. The revocation will only proceed when so determined by the Superintendence of Industry and Commerce.

Authorization for use of personal data:

CUEROS VÉLEZ SAS, acting as responsible for the processing of personal data, obtains from the owner of the personal data, authorization for the processing of their data in a clear, express, prior, informed and free manner. For the above, ALCE LEATHER BASICS SAS will inform the owner of the purpose for which the processing of their data will be provided, except in cases expressly authorized by Law 1581 of 2012, regulated in Article 10.

Mechanisms for collecting personal data:

ALCE LEATHER BASICS SAS collects the owner's personal data as follows:

Virtual: Through websites and official accounts on social networks.
Written: Through information provided in documents and/or recruitment forms of our own or third parties.

Data processing of children and adolescents:

In the processing of personal data, ALCE LEATHER BASICS SAS, as responsible for the processing of personal data, will take the necessary measures to comply with article 52 of Law 1480 of 2011. In addition, it will ensure respect for the rights of children. and adolescents in the processing of personal data.
All information and communication content that is intended to influence the consumption decisions of children and adolescents may not lead to error, deception or confusion.
The rights of children and adolescents will be exercised by the people who are empowered to represent them.

Security measures:

ALCE LEATHER BASICS SAS will adopt physical, logical and administrative security measures in order to protect the owner's data. These measures will be cataloged depending on the criticality of the personal data processed.
ALCE LEATHER BASICS SAS will have documentary management and information protection models to comply with its obligations regarding the care and custody of data.
Procedures for the exercise of the rights that the owner has regarding data processing:
In order for the owner of the data and/or the interested party to exercise the rights established in the Law, ALCE LEATHER BASICS SAS will adopt the following procedure:
The owner of the data or the person interested in exercising one of the rights established in the Law must prove this condition in writing by attaching their identity document. This communication may be provided physically or digitally and must be addressed to the main address of ALCE LEATHER BASICS SAS or to the email info@alceleather.com The request must contain the following information:

Name and identification of the owner of the personal data and their representatives, if applicable.
Request, complaint or claim made in a concrete, precise and reasonably founded manner.
Physical and/or electronic address for notifications.
Physical and/or electronic address for notifications.

The owner may make inquiries and/or complaints to ALCE LEATHER BASICS SAS. Each procedure will be explained below.

CONSULTATION:

Its purpose is for the owner to know the information processed by the person responsible for processing personal data. Likewise, request a copy of the authorization given to the processing of personal data.
The query will be answered within a period of ten (10) business days from the date of receipt of the query. When it is not possible to attend to the query within said term, the interested party will be informed, expressing the reasons for the delay and indicating the date on which their query will be attended to, which in no case may exceed five (5) business days following the expiration of the first term.

CLAIM:

It is filed by the owner of the personal data, with the purpose that the person responsible for the treatment corrects, updates or deletes the stored data. Likewise, when it considers that there is a breach by the Responsible Party of its duties.
ALCE LEATHER BASICS SAS will have a period of five (05) business days to validate the request. If it is incomplete, the owner or interested party will be informed so that they can complement their claim. Once the owner has complemented his request or claim, ALCE LEATHER BASICS SAS will proceed to respond to the request, within a period of fifteen (15) business days.
If after two (2) months, the owner of the information or the interested party has not complemented the claim, it will be understood as withdrawal.
When it is not possible to address the claim within said term (15 business days), the interested party will be informed of the reasons for the delay and the date on which their claim will be attended to, which in no case may exceed eight (8) business days. following the expiration of the first term.
ALCE LEATHER BASICS SAS will document and store the requests made by the owners of the information and/or interested parties in the exercise of any of the rights, as well as the responses to such requests.
Transfer and transmission of personal data for processing by third parties:
ALCE LEATHER BASICS SAS, as responsible for the processing of personal data, may transfer or transmit the data it stores to third parties, national or foreign, with whom it will sign agreements or transfer contracts, so that these third parties carry out some specific work on the data. data of the owners. All of the above, prior authorization from the owner of the information and in compliance with the regulatory provisions on this matter.

Media:

Any questions the owner may have about his or her information or personal data or if he or she wishes to make a request for information, may do so by emailing ALCE LEATHER BASICS SAS info@alceleather.com and calling +57 3225017800 in the city of Medellín.