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In accordance with the Political Constitution of Colombia, Law 1581 of 2012, Regulatory Decree 1074 of 2015, and other complementary regulations, this Personal Data Protection and Processing Policy (hereinafter referred to as the “POLICY”) establishes how TRIANA, URIBE & MICHELSEN LTDA. (hereinafter referred to as “TUM”), a properly established commercial society in Colombia, identified with the NIT 830.001.432 – 4, located in the city of Bogotá, D.C. and with offices at Calle 93B No. 12 – 48 P. 4, email address protecciondatos@tumnet.com and telephone number (57 1) 601 96 60, collects and processes your personal data (hereinafter referred to as the “Personal Data”).
Definitions
For the interpretation of the POLICY, we ask you to consider the following definitions:
In order to comply with the obligations and activities described in section 3 of the POLICY, TUM directly collects the following data, which are non-sensitive Personal Data:
TUM will process your Personal Data, that is, with respect to them, it will carry out activities such as collection, storage, use, circulation or suppression, in order to fulfill the normal development of the object of our company and our relationship with you. Within this purpose, we will process your Personal Data for:
3.1. Processing of Personal Data prior to the start of an employment relationship
The purposes of the processing of the Personal Data provided by those interested in participating in a selection process and the personal information obtained in said process are limited to: (i) the collection, classification, storage, use and archiving of personal data; (ii) the delivery of the information to third parties in charge of selection processes; (iii) the verification, comparison, evaluation of the job and personal competencies of the prospects regarding TUM’s selection criteria; (iv) keeping a record of the candidates who applied and those who were discarded in the selection process; v) scheduling interviews and administering tests to applicants; vi) evaluating the selection tests directly or through third parties; vii) reporting the overall results of the selection process; (viii) consulting and evaluating all the information about the applicant that is stored in legally established judicial or security databases, of a state or private nature, national or foreign.
3.2. Processing of Personal Data during the term of an employment relationship
The purposes of the processing of the Personal Data provided by TUM’s employees are limited to: (i) the collection, classification, storage, archiving of personal data; (ii) compliance with the obligations derived from the labor contract entered into with the Data Owner; (iii) compliance with legal obligations in the area of social security and non-tax contributions; (iv) processing of incapacities, permits or licenses; (v) providing information to judicial and administrative authorities, when judicial and/or administrative orders are issued in that sense; (vi) delivering information to internal or external auditors, attorneys and potential investors or buyers in case of sale of the company or the inclusion of new shareholders, if required; (vii) delivering information to third parties that are verifying work references; (viii) issuing employment certificates; (ix) complying with all the obligations derived from the contractual relationship and its termination; (x) the normal development of the contractual relationship.
3.3. Processing of Personal Data of suppliers
The purposes of the processing of personal data provided by TUM’s suppliers are: (i) to collect, store and classify the information provided by suppliers for the proper management of the commercial relationship; (ii) to comply with the legal and contractual obligations derived from the commercial relationship; (iii) to contact the supplier; (iv) to make the corresponding payments; (v) to keep records of the commercial transactions; (vi) to evaluate the supplier’s performance; (vii) to resolve claims or disputes that may arise; (viii) to provide information to internal or external auditors, attorneys and potential investors or buyers in case of sale of the company or the inclusion of new shareholders, if required; (ix) to comply with all the obligations derived from the contractual relationship and its termination; (x) the normal development of the commercial relationship.
3.4. Treatment of customer personal data
The purposes of the treatment of personal data provided by TUM’s customers are: (i) to have the personal information provided by our customers at the time of signing contracts, in order to comply with the obligations derived from them; (ii) to present offers and quotations; (iii) to carry out evaluations and/or surveys related to the level of satisfaction of our customers in relation to the products and services we offer and provide; (iv) to carry out analysis and customer profiling that allows us to define products and services that meet their needs; (v) to send legal and commercial communications related to the products and services we offer and provide; (vi) to carry out market research and consumption habits, statistical analysis and customer behavior reports; (vii) for the normal development of the contractual relationship.
3.5. Treatment of Financial Personal Data:
TUM will only process your Financial Personal Data when this information is necessary to carry out billing, portfolio, collection and payment processes for the products and services provided by and/or for TUM, and for the sending of invoices either electronically, physically or by any means agreed upon with you and in the cases previously established in this POLICY.
3.6. Treatment of Personal Data of Minors:
In compliance with the law, TUM will proceed to carry out the Processing of Personal Information of children, respecting their best interest and ensuring, in all cases, respect for their fundamental rights and minimum guarantees.
In all events in which it is necessary to process Personal Information of minors, TUM will obtain the Authorization of their legal representatives, who for this purpose are father and/or mother or guardian.
3.7. General
TUM collects your Personal Data through various information sources such as personal or work electronic messages, through the website www.tumnet.com or physical correspondence, by existing information in TUM’s databases according to the procedure established in Decree 1377 of 2013, in its article 10, through voice messages, information archived on computers and electronic devices of TUM, fax systems, internet access, correspondence or through any other electronic device for communications and any other technological resource.
TUM will only use personal data within the use that you have authorized, and will only transmit it to customers or third parties when necessary as a result of TUM’s ordinary operations and to judicial and administrative authorities when required by a judicial or administrative order. TUM will protect and safeguard the personal data received at its address, limiting its use and disclosure to the authorized purpose.
In accordance with article 8 of Law 1581 of 2012, TUM informs you that you have the following legal rights:
If you have any questions, inquiries or complaints related to your personal data, you can contact the TUM Data Protection Officer at the email address protecciondatos@tumnet.com (hereinafter the “Data Protection Officer”). You can exercise your right to know, update, rectify or delete your personal data and revoke the consent given to TUM for the treatment of your personal data before this person or area of TUM.
TUM takes effective, appropriate and reasonable measures to protect your personal data from loss, misuse, unauthorized access, disclosure, alteration and destruction.
Any question or inquiry regarding your personal data collected and processed by TUM, will be received by the TUM Data Protection Officer, for which you should send a written description of your inquiry to the email address protecciondatos@tumnet.com.
The TUM Data Protection Officer will resolve your question or inquiry within ten (10) business days from the date the question or inquiry is received. If it is not possible for the TUM Data Protection Officer to respond to your claim within the aforementioned term, the TUM Data Protection Officer will let you know the situation and explain the reason for the delay. In any case, the TUM Data Protection Officer will respond to you within five (5) business days following the expiration of the initial ten (10) business days term.
The consent given by you may be revoked at any time, by means of prior notice, written and signed, addressed to the TUM Data Protection Officer, at the aforementioned electronic address, in the terms established by the Law.
If you consider that the information contained in TUM’s database is subject to correction, updating or deletion, or if you consider that TUM is not complying with its obligations established in Law 1581 of 2012, you must file a complaint with TUM, addressed to the Data Protection Officer, which will be treated according to the procedure established in article 15 of Law 1581 of 2012.
This Policy will go into effect on July 1, 2017 and your Personal Data will remain in TUM’s database until it serves the purpose for which it was collected, or the specified time period ends as required by law.