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Personal Data

Procedural Manual

LA VIE COLOMBIA S.A.S., a company domiciled in Medellín, located at the address Calle 15 N° 35 – 1 Edificio C34 of 401, is a company committed and responsible for the privacy and security of the Personal Data of its employees, shareholders, suppliers, clients , distributors, business allies, related companies, users, contractors, consultants, advisors, subscribers, former employees, former contractors and others, information that has been collected by this company by virtue of the development of its corporate purpose, for administrative, commercial relations, civil, labor, among others; Under the terms of Law 1581 of 2012 and Decree 1377 of 2013, the following “PRIVACY AND PERSONAL DATA PROTECTION POLICY” has been adopted, in which all persons directly or indirectly related to this company and which Personal Data information is currently included in our database or those data that are entered in the future by any of the information collection means that the company LA VIE COLOMBIA S.A.S. provides, they will be able to know the procedure for collecting, preserving and processing Personal Data, as well as the rights, guarantees and procedures to make them effective:

DEFINITIONS OF YOUR INTEREST:

Personal data: Any information linked or that can be associated with several specific or determinable natural persons.

Database: Set of personal data organized systematically for subsequent processing.

Authorization: Express, prior and informed consent of the owner of the personal data, to carry out treatment.

Processing: Operations or activities that can be carried out with personal data, including: collection, use, copy, transfer, transmission or deletion.

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.

PURPOSE OF THE PROCESSING OF PERSONAL DATA

The information provided by the owner will be included in our database and will be used:

For suppliers:

Carry out purchasing activities for goods and services.

Notification of cancellation of obligations to the company’s suppliers, among other types of communications by LA VIE COLOMBIA S.A.S.

Evaluate the quality of the products and services supplied by this company.

For customers:

Provide our services and products.

Use the information for the purpose of promoting our products, services and offers, by physical means or through our website, or other means used for this purpose.

Send commercial information about the products and services offered by the company, through different media, previously authorized by the owner.

Sending communications related to our products, services, offers, promotions, alliances, studies, contests, among others.

Inform about new products or services that are directly related to the contracts or services acquired by the owner.

Evaluate the quality of the products and services supplied by this company.

Carry out collection activities in relation to obligations contracted by the owner.

Conduct internal studies on marketing and user consumption behaviors.

PROCESSING OF PERSONAL DATA

LA VIE COLOMBIA S.A.S. is responsible for the processing of the Personal Data of its employees, shareholders, suppliers, clients, distributors, business allies, related companies, users, contractors, consultants, advisors, subscribers, former employees, former contractors and others, for this reason it will act in compliance of the obligations arising from this condition. Thus, this treatment may be extended to its Subsidiaries and may additionally be entrusted to those who represent the company or to whom it may hire for the exercise of its representation or development of its corporate purpose, who must act in accordance with the procedures and policies. of personal data protection, which for this purpose were designed and implemented by the company LA VIE COLOMBIA S.A.S.

The processing of Personal Data must be carried out in the terms and scope of the authorization issued by the Owner of the Personal Data or in the terms established in current legislation for this purpose.

RESPONSIBLE FOR

PROCESSING OF PERSONAL DATA

LA VIE COLOMBIA S.A.S. company identified with NIT 901.388.728-7 established by private document dated June 18, 2020, registered in the Chamber of Commerce of Medellín on June 19, 2020, in book 9 under No. 11773, domiciled in Medellín, and with the following communication channels:

 

Calle 15 N° 35 – 1 Building C34, Office 401, Medellín

Telephone: 604 3585085

Whatsapp: 3044502008

Email address: facturas@onehalf.com.co

Website: onehalf.com.co

Responsible: Administrative Area.

FORM IN WHICH PERSONAL DATA IS OBTAINED

We can carry out the collection and storage activities of Personal Data through physical mail, electronic mail, mobile devices, web pages or through any known digital or similar communication mechanism or through the voluntary and direct provision that the owner of the Personal Data delivered to the company by LA VIE COLOMBIA S.A.S., through the different mechanisms mentioned above.

PERSONAL DATA THAT ARE STORED BY LA VIE COLOMBIA S.A.S.

The personal data stored by the company LA VIE COLOMBIA S.A.S. They depend on the direct or indirect relationship that the owner has with the company, for which it may be necessary to obtain from the owner his name, address, telephone number, residence address, email, date of birth, professional activity, position, employer, among others, information that will be used for the purpose described in this privacy and personal data protection policy.

DUTIES OF THE RESPONSIBLE FOR PERSONAL DATA.

Effectively provide guarantees to the Owner of the Personal Data to exercise their rights in accordance with Law 1581 of 2012 and Decree 1377 of 2013 and other regulatory standards.

Request and keep proof of the respective authorization issued by the Owner of the Personal Data for the processing of your data.

Inform the Owner of the Personal Data about the purpose for processing their data and the protection policies that have been adopted for them.

Maintain Personal Data according to the purpose for which it was collected and under appropriate security conditions, which aim to avoid adulteration, loss, consultation, use or unauthorized access by persons other than the information.

Update Personal Data in accordance with the indications or requests that are required by the owner of the information.

Rectify Personal Data when it is provided or described incorrectly.

Process and respond to queries and claims in the terms indicated by Law 1581 of 2012 and Decree 1377 of 2013.

Adopt an internal manual of policies and procedures to guarantee the proper treatment of Personal Data.

Keep the status of Personal Data updated when certain information is under discussion by the Owner.

Implement personal data security measures, following the instructions issued by the Superintendency of Industry and Commerce on the matter.

Comply with the instructions and requirements issued by the Superintendence of Industry and Commerce.

And in general, process personal data in accordance with the authorization given by its owners and in accordance with the purposes and purposes established in Law 1581 of 2012 and Regulatory Decree 1377 of 2013.

RIGHTS THAT ASSIST TO THE OWNER OF THE    PERSONAL DATA AND IN THEIR ABSOLUTE LACK, TO THEIR OWNERS.

In the terms of Law 1581 of 2012 and Decree 1377 of 2013, the rights granted to the owner of the Personal Data and in the absence of this, to his successors, are the following:

Right to consult your personal data free of charge and to know if it is being processed by the responsible company.

Right to request the updating, rectification and deletion of your personal data at any time.

Right to revoke at any time the authorization given to the person responsible for the processing of your personal data.

Right to request at any time proof that proves the existence of the authorization given to the person responsible for the processing of his personal data.

Right to present complaints to the Superintendency of Industry and Commerce for violations of the provisions of Law 1581 of 2012 and other regulations that modify, add or complement it.

Right to be informed by LA VIE COLOMBIA S.A.S. about the use of your Personal Data.

The other rights that assist you in the National Legislation.

MEANS BY WHICH THE OWNER AUTHORIZES THE PROCESSING OF HIS/HER PERSONAL DATA

The owners of the personal data must authorize the person responsible for their processing, through

the completion of the AUTHORIZATION FORM that is published on the website of the company LA VIE COLOMBIA S.A.S. and/or through the communication channels used by The Company to send said format or the conditions acceptance system implemented by LA VIE COLOMBIA S.A.S.

FORM IN WHICH THE OWNER OF THE PERSONAL DATA CAN EXERCISE THEIR RIGHTS

The owner of the information, who hereby issues authorization for the use of his or her Personal Data, may at any time access the data provided, as well as request its correction, update, delete or request the revocation of this authorization. , in the terms of Law 1581 of 2012 and Decree 1377 of 2013; The interested party may contact the offices of LA VIE COLOMBIA S.A.S. located at Calle 15 No. 35 – 1 Building C34, Office 401, Medellín, Colombia, or send an email to the email address facturas@onehalf.com.co

The request must contain, at least, the information identified below:

Owner identification

Description of the facts that give rise to the query, suggestion, claim or complaint

Application Terms

Address for notification.
RESOLUTION OF QUERIES AND CLAIMS FILED BY DATA OWNERS.

The Owners or their successors in title make queries or complaints about the Owner’s personal information that resides in the databases of LA VIE COLOMBIA S.A.S. through the following mechanisms:

Calle 15 N° 35 – 1 Building C34, Office 401, Medellín
Telephone: 604 3585085
Whatsapp: 3044502008
Email address: hi@onehalf.com.co
Website: onehalf.com.co

PROCEDURE.

LA VIE COLOMBIA S.A.S. will respond to the owners or their successors in queries regarding the personal information of the Owner that resides in their databases.

The query will be received exclusively through the channels of LA VIE COLOMBIA S.A.S. previously mentioned.

The query will be answered within a maximum period of ten (10) business days from the date of receipt. 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.

In the case of claims, the Owner or his successors who consider that the information contained in a database must be corrected, updated or deleted, or when they notice the alleged breach of any of the duties contained in this law, may present a claim through the channels offered by LA VIE COLOMBIA S.A.S. and will be resolved under the following terms and conditions:

The claim will be made through a request addressed to LA VIE COLOMBIA S.A.S. with the identification of the Owner, the description of the facts that give rise to the claim, the address, and accompanying the documents that you want 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 deficiencies. After two (2) months from the date of the request, without the applicant presenting the required information, it will be understood that he or she has abandoned the claim.

In the event that the person receiving the claim is not competent to resolve it, he or she will forward it to the appropriate person within a maximum period of two (2) business days and will inform the interested party of the situation.

Once the complete claim is received, a legend that says “claim in process” and the reason for it will be included in the database within a period of no more than two (2) business days. Said legend must be maintained until the claim is decided.
The term to address the claim will be fifteen (15) business days counted from the day following the date of receipt. When it is not possible to attend to the claim within said term, LA VIE COLOMBIA S.A.S. will inform the interested party of the reasons for the delay and the date on which their claim will be attended to, which may not exceed eight (8) business days following the expiration of the first term.

Procedural requirement. The Owner or successor in title may only file a complaint with the Superintendency of Industry and Commerce once the consultation or claim process has been exhausted before the Data Controller or Data Processor.

The request must contain, at least, the information identified below:

 

Owner identification
Description of the facts that give rise to the query, suggestion, claim or complaint
Application Terms
Address for notification

INTERNATIONAL TRANSFER AND TRANSMISSION OF PERSONAL DATA

The information and data provided may be transmitted and/or transferred to third countries, for the execution of activities related to the company.

ad and/or with the treatment described in these Policies.

For the international transfer and transmission of personal data, the provisions of article 26 of Law 1581 of 2012 and article 24 of Decree 1377 of 2013 will be observed.

This ‘PRIVACY AND PERSONAL DATA PROTECTION POLICY’ is published on April 11, 2022 and comes into effect from the day of its publication.