Privacy Policy

For ALLEYCORP SUR S.A.S, identified with NIT: 901.497..747-4, located at Carrera 17 No. 93-47 apartment 202, Bogotá and with e-mail for these purposes legal@alleycorpsur.com ,taking into account its status as responsible for the processing of personal data, committed to the security of personal information of its users, customers, suppliers, contractors, employees and the general public, and in order to strictly comply with current regulations on the protection of Personal Data, especially as established in the Statutory Law 1581 of 20121, Decree 1377 of 2013 and other provisions that modify, clarify, add or complement them, ALLEYCORP SUR presents the Processing Policy on Personal Data Protection (hereinafter the “Policy”) of ALLEYCORP SUR in relation to the collection, use and transfer of such data, in accordance with the authorization granted by the Data Controllers.

ALLEYCORP SUR , taking into account that for the development of its corporate purpose, it must collect and carry out various forms of processing of personal information of its various stakeholders, undertakes to: (i) comply at all times with current regulations on personal data protection; (ii) guarantee the exercise of the rights of habeas data of all holders of personal data contained in its databases and files; (iii) develop technical, legal and organizational controls and measures, aimed at establishing security conditions, in order to prevent access, loss, adulteration and fraudulent use of the data on which it holds the status of Data Controller. ALLEYCORP SUR, in compliance with the constitutional right to Habeas Data, only collects Personal Data, when previously authorized by the Data Subject, directly or through third parties, implementing for such purpose, clear measures on confidentiality and privacy of Personal Data, which will be defined below.

ALLEYCORP SUR is committed to adopting security and quality standards so that the information provided by the Data Controller is only processed for the specific purposes for which it was collected, by virtue of the existing legal or contractual authorization. In this Policy, ALLEYCORP SURdetells the general guidelines that are taken into account in order to protect the Personal Data of the Data Controllers, such as the purpose of the collection of information, the rights of the Data Controllers, the area responsible for dealing with queries, complaints and claims about the processing of personal data collected and handled, as well as the procedures that must be exhausted to know, update, rectify and delete the information.

PURPOSE OF THE PROCESSING OF PERSONAL DATA

ALLEYCORP SUR recognizes that the Data Subject is entitled to have a reasonable expectation of his/her privacy, taking into account, in any case, his/her responsibilities, rights and obligations to ALLEYCORP SUR. By virtue of the relationship established between you and ALLEYCORP SUR , we inform you that your personal data will be treated with complete confidentiality, only to the extent necessary to comply with the purpose for which consent was granted and that, the collection, use, circulation, transmission, transfer and, in general, any form of processing thereof, will be done in accordance with the following purposes: a). Candidates for a vacancy: the purposes listed below: a) To classify, store and file the personal data of the candidates of the selection processes; b) To verify and obtain references of natural and/or legal persons, provided by the candidates in resumes, forms, among others; c) To deliver or transmit the information to third parties in charge of the selection processes; d) To carry out selection, competency and skills tests, home visits, psychosocial evaluations, and all other evaluations deemed appropriate in order to identify the relevance of hiring the candidate; e) To comply with the legal duties to which the company is obligated; f) To send job offers; g) To carry out security studies, consultations in legally authorized databases, national and international lists for the control and prevention of fraud, prevention and control of money laundering, financing of terrorism and financing of the proliferation of weapons of mass destruction; h) To store in a physical and/or digital file or folder that will be identified with a code associated with said candidate; i) ALLEYCORP SUR will keep the information contained in the file or folder of the candidate for a vacancy for an indefinite period of time in order to meet the requirements of administrative authorities and internal audit requirements.Employees: ALLEYCORP SUR will use the personal data of its employees in accordance with the purposes listed below: a) Incorporate their personal data in the employment contract, modifications and additions thereto, as well as in other documents that are necessary to manage the employment relationship and obligations arising therefrom that are in charge of ALLEYCORP SURin its capacity as Data Controller of their personal data; b) Advance performance tests, skills and abilities, home visits, psychosocial evaluations and others deemed appropriate in order to identify the relevance of the employment relationship of the person; c) To develop a correct management of the labor relationship that links the holder of the personal data with ALLEYCORP SUR ; d) To have the personal data of the collaborators to incorporate them properly in the active and historical labor files of ALLEYCORP SURand keep them updated; e) To send internal communications related or not to their labor relationship; f) To manage the personal data so that ALLEYCORP SUR , as an employer, correctly complies with its obligations. For example: To advance the affiliations to which the worker is entitled by law before the Integral Social Security System (SSSI), family compensation funds and other matters related to social benefits, contributions, withholdings, taxes, labor disputes, as well as in case of contributions or payments to other entities where the collaborator has previously authorized the processing of their personal data; g) Manage the holder’s personal data and those of his or her family nucleus to carry out affiliation procedures with the health promoting entities -EPS-, family compensation funds, labor risk administrators -ARL-, and others necessary for ALLEYCORP SUR to comply with its duty as an employer; h) Respond to requests from the employee regarding the issuance of certificates, certificates and other documents requested to ALLEYCORP SUR in connection with the employment relationship; i) Promote their participation in programs developed by ALLEYCORP SUR aimed at the welfare and good working environment; j) Manage their personal data to ensure proper allocation of work tools (including IT tools such as email, computers, mobile devices, access to databases, etc.); k) Manage their personal data to ensure proper allocation of work tools (including IT tools such as email, computers, mobile devices, access to databases, etc.); l) Manage their personal data to ensure proper allocation of work tools (including IT tools such as email, computers, mobile devices, access to databases, etc.). ); k) Manage your personal data to ensure proper execution of the provisions of the Internal Labor Regulations, including disciplinary processes and relevant investigations; l) Verify data authenticity and safeguard the Company’s security, verify and report financial, banking or credit information to credit risk databases or of any other nature; m) Perform internal and external auditing processes; n)To carry out security studies, consultations in legally authorized databases, national and international lists for the prevention and control of money laundering, financing of terrorism and financing of the proliferation of weapons of mass destruction; o) To contact employees and collaborators to send information related to the contractual and obligatory relationship they have with ALLEYCORP SUR; p) Verification of disciplinary, judicial and police records; q) Knowing the health status of the person, including: results of laboratory tests, medical studies, medical diagnoses, general or specialized, psychological or psychiatric; r) Development of prevention and promotion programs for health and safety at work based on medical and occupational health information from the time of entry, as well as during the execution and completion of the assigned activities; s) Develop welfare programs and assignment of benefits defined by the Company. t) Transmit or transfer the information to a third party (called Responsible or Responsible, respectively) to carry out selection processes of people, conduct surveys, training, outsourced service of technological platforms and other activities that contribute to the development of the daily operation of ALLEYCORP SUR; u) Manage personal data to make the correct payment of payroll, including the realization of discounts for payments to third parties that the employee has previously authorized and make reports related to this process. Suppliers and/or Contractors: ALLEYCORP SUR will use the personal data of suppliers and/or contractors in accordance with the purposes listed below: a) To carry out the process of linking the supplier or contractor and develop a correct management of the contractual relationship; b) Collect, record and update your personal data in order to inform, communicate, organize, control, attend, accredit the activities in relation to your status as a supplier and/or third party related to ALLEYCORP SURand other associated procedures in charge of the Data Controller; c) Manage your data to carry out the different processes of payment of invoices and accounts receivable submitted to ALLEYCORP SUR and collection management under its responsibility; d) Evaluate the services offered or rendered by the supplier and/or contractor; e) Fulfill any other legal obligation under the responsibility of ALLEYCORP SUR; f) Analyze financial, technical and any other aspects that allow ALLEYCORP SUR to identify the supplier’s compliance capacity; g) Comply with the obligations derived from the commercial relationship established with the supplier or contractor; h) Provide assistance and/or information of general and/or commercial interest to the supplier or contractor; i) Develop and implement selection processes, evaluation, preparation of responses to a request for information, prepare requests for quotations and proposals, and/or award contracts; j) Evaluate the quality of products and services offered or rendered to ALLEYCORP SUR; k) Use, if necessary, the personal data of the supplier’s collaborator in order to establish access controls to the logical or physical infrastructure of ALLEYCORP SUR; l) Administrar los datos de carácter personal para realizar pagos a proveedores, incluida la adminm) To carry out the control and prevention of fraud, money laundering and financing of terrorism; n) To send or provide information to the competent authorities, when so requested, or in the course of contractual disputes; o) To transfer information to administrative authorities that, by reason of their functions, so require in order to comply with the legal obligations in our charge; p) The Data Controller understands that its personal data and those of third parties that the supplier or contractor provides, such as authorized workers to carry out the management or service entrusted, references and commercial certifications, have the authorization of the owners to be delivered and treated in accordance with the purposes contemplated in this Policy. Clients, users and commercial prospects: ALLEYCORP SUR will use, directly or with the participation of third party suppliers of products or services, the personal data of commercial prospects in accordance with the purposes listed below: a) Register you as a client or user of ALLEYCORP SUR ; b) Evaluate you as a potential client or user of ALLEYCORP SUR ; c) Verify that the information provided is truthful; d) Evidence that your assets do not come from illicit activities; e) Consult and report your information in risk and credit information centrals; f) Inform you about the brands and products we market, as well as the promotional activities we carry out, all within the terms authorized by the respective legislation; g) Provide services according to the needs of the Holder; h) Collect, record and update your personal data in order to inform, communicate, organize, control, attend, accredit the activities in relation to your status as a customer or commercial prospect; i) Respond to requests or requests for information about our services; j) Send to the physical mail, email, cell phone or mobile device, via text messages (SMS and/or MMS) or via WhatsApp or Facebook Messenger or through any other analog and/or digital means of communication created or to be created, commercial, advertising or promotional information about products and/or services, events and/or promotions of a commercial nature, in order to promote, invite, direct, execute, inform and, in general, carry out campaigns, promotions or contests of a commercial or advertising nature, advanced directly by ALLEYCORP SUR and/or by third parties; j) To keep accounting, financial and statistical records and to carry out commercial management, collections and conservation of information and documents required by accounting standards; k) To perform statistical analysis of trends, consumption habits and consumer behavior; l) To share information with third parties and/or allied persons in charge for the fulfillment of the purposes described above; m) To comply with legal obligations. In some cases, we collect and use your personal information to comply with laws. Therefore, provided that it is a request that complies with the applicable legal requirements, binding and enforceable to ALLEYCORP SUR , and issued by a legitimate authority in the exercise of its functions, we may use your personal data to comply with laws, rules, regulations and / or judicial decisions; n) Preservation of the information for the terms established by law, especially with regard to the information in the books and papers of the merchant, which must be stored for a period of ten (10) years, as provided in Article 28 of Law 962 of 2005; o) Transfer the information collected to third parties with whom the company contracts the storage and management of personal data, under the standards of security and confidentiality to which ALLEYCORP SUR is obliged according to the relevant laws; p) Communicate and allow access to the personal data provided to third party providers of general support services and to natural or legal persons who are shareholders of ALLEYCORP SUR. The above in order to provide, facilitate and improve the quality of ALLEYCORP SUR’s service, to strengthen, improve and update the company’s strategy; q) Other purposes determined by ALLEYCORP SUR in the process of collecting information for processing and which are communicated to the Data Controllers at the time of collecting the personal data.Shareholders. ALLEYCORP SUR will use the personal data of shareholders in accordance with the purposes listed below: a) Administrative management: Collect the personal data provided to perform the registration of the shareholder and their activities within the company; b) Perform the registration of economic, accounting and tax management; c) Perform the issuance of certifications relating to the ownership of shares, as well as issuance of share certificates and others necessary for the proper development of the corporate purpose, subject to their authorization; d) Financial operations related to the payment of dividends, fees, and others related to role; e) Attention of consultations, petitions, requests, actions and claims, made by the Holder of the information or the persons authorized by this or the Law; f) In general for all the purposes necessary for the execution and development of the corporate purpose of these companies; g) To carry out any other purpose necessary for the development of the rights and duties inherent to their quality of shareholders; h) To determine the reliability of the shareholder and allow the suitability and background of the natural person or legal entity that pretends a link of interest in the same way; i) To carry out security studies, consultations in legally authorized databases, national and international lists for the prevention and control of money laundering, financing of terrorism and financing of the proliferation of weapons of mass destruction; j) External and internal audits; k) To attend requirements and make reports to the Inspection, Surveillance and Control entities. OTHER DATABASES: Notwithstanding the list of databases set forth herein, ALLEYCORP SUR may have other databases that will be duly registered with the Superintendence of Industry and Commerce.  The provisions of this Personal Data Processing Policy shall apply to any other databases that may exist.

PROCEDURE FOR THE EXERCISE OF THE RIGHT TO HABEAS DATA

Data subjects may exercise their right to habeas data at any time and in an effective manner to guarantee their right of access, rectification, deletion and proof of authorization before ALLEYCORP SUR via email legal@alleycorpsur.com    

The following are the legally permitted ways to exercise the right of habeas data:

On your own behalf: you as the owner of personal data stored in databases and/or files of ALLEYCORP SUR , will have the right to know, update, access, rectify, delete, request proof of authorization granted, be informed regarding the use of your data, revoke the authorization granted.

Through a proxy: This right may be exercised by the interested party duly identified or by the proxy of the holder of the personal information, for which purpose the special or general power of attorney duly authenticated must be attached to the request.

Exercise of the right of minors: Minors must exercise their right to habeas data through the person who accredits their legal representation.

INQUIRIES AND COMPLAINTS PROCEDURES

1. Consultation Procedure: Data owners who wish to make inquiries must take into account that ALLEYCORP SUR, as Data Controller, will provide such persons with all the information contained in the individual record or that is linked to the identification of the data owner. The consultation will be formulated through the channels enabled by ALLEYCORP SUR and will be answered within a maximum term of fifteen (15) working days from the date of receipt of the request. When it is not possible to answer the query within such term, the interested party will be informed, stating the reasons for the delay and indicating the date on which the query will be answered, which in no case may exceed five (5) working days following the expiration of the first term, without prejudice to the provisions contained in special laws or regulations issued by the National Government, which may establish shorter terms, depending on the nature of the personal data.

1. Complaint Procedure: The Data Subject who considers that the information contained in a database of ALLEYCORP SUR should be corrected, updated or deleted, or when he/she notices the alleged breach of any of the duties contained in Law 1581 of 2012, may file a complaint with the Controller or the Data Processor, which will be processed under the following rules: The claim shall be formulated by means of a request addressed to the Data Controller or Data Processor, with the identification of the holder, the description of the facts giving rise to the claim and the address, accompanying the documents that he/she wishes to assert. If the claim is incomplete, the interested party will be required within five (5) days following 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, it will be understood that the claim has been abandoned. In the event that the person receiving the claim is not competent to resolve it, he/she will transfer it to the appropriate person within a maximum term of two (2) business days and will inform the interested party of the situation. Once the complete claim has been received, within a term no longer than two (2) business days, a legend will be included in the database stating “claim in process” and the reasons for the claim. Said legend shall be maintained until the claim is resolved in substance. The maximum term to attend the claim will be fifteen (15) working days from the day following the date of its receipt. When it is not possible to address the claim within such term, the interested party will be informed of the reasons for the delay and the date on which the claim will be addressed, which in no case may exceed eight working days following the expiration of the first term.

For purposes of contacting the responsible area within the Responsible for the purposes of this section, the Holders or any interested party may communicate through the following e-mail: legal@alleycorpsur.com