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MANUAL FOR PERSONAL DATA PROTECTION POLICIES AND PROCEDURES FOR ATELIER 17 - 56 EMPLOYEES, CLIENTS, AND INTERESTED PARTIES
This policy is issued in compliance with Decree 1377 of 2013 of Law 1581 of 2012, and norms that modify or add the personal data protection regime and seek to guarantee that ATELIER 17 - 56 , in its capacity as the person in charge of handling personal information, carries out its data treatment in strict compliance with the applicable regulations, guaranteeing the rights that the Holders of the data have.
The company responsible for processing the personal data is:
In order to exercise its corporate purpose, ATELIER 17 - 56 processes the personal data of its employees, suppliers, customers, and product users. Likewise, in compliance with the applicable legislation, ATELIER 17 - 56, may be required to transmit or transfer said data to the indicated platforms and/or to the security systems implemented by it.
In order to develop the principles of finality and freedom, the collection of personal data by ATELIER 17 - 56 will be limited to the personal data that is deemed relevant and appropriate for the purpose for which it is collected or required, in accordance with current regulations. Except in the cases that are expressly foreseen by the Law, personal data may not be collected without authorization from the Owner.
Personal data is collected, stored, organized, used, circulated, transmitted, transferred, updated, rectified, removed, deleted, and managed according to the purpose or purposes of each type of Data Treatment, as indicated in Section 3 of this Policy Manual.
2.1 Processing of the Personal Data of Girls, Boys, and/or Adolescents
The treatment of the Personal Data of children and/or adolescents which is public in nature will comply with the following parameters and requirements:
Once the aforementioned requirements have been fulfilled, the legal representative of the child or adolescent may grant authorization for the Data Treatment, after the minor has exercised his or her right to be heard, an opinion which must be taken into account considering the minor’s maturity, autonomy, and ability to understand the matter.
2.2 Treatment of Sensitive Data:
ATELIER 17 - 56 will strictly observe the legal limitations to the Treatment of Sensitive Data, for which it will ensure that:
The purposes of the Processing of Personal Data carried out by ATELIER 17 - 56 are the following:
In the event that ATELIER 17 - 56 is not in the capacity to carry out the treatment of data by its own means, it may transfer the collected data in order for it to be processed by a third party, after duly notifying the Holders of the collected data. The third party will then be in charge of the treatment of the data, and must guarantee suitable conditions of confidentiality and security of the information that has been transferred in order for it to be processed.
In accordance with the provisions of Article 8 of Law 1581 of 2012, and Decree 1377 of 2013, the Holder of Personal Data has the following rights:
The Administrative and Financial Management Area of ATELIER 17 - 56 will be responsible for the attention of requests, queries, claims, complaints, or for the exercise of the rights of the Holder of Personal Data.
6.1 Procedure for Access and Consultation.
The Data Holder, or his successors in title, may consult the information contained in the databases in possession of ATELIER 17 - 56, for which they must make the corresponding request via the company's email.
In order to prevent unauthorized third parties from accessing the personal information of the Data Holder, it will be necessary to previously establish the identification of the Holder. When the request is made by a person other than the Holder, and it is not proven that this person acts on behalf of the latter, the request will be considered as not filed.
The consultation will be attended within a maximum term of ten (10) business days starting from the date of reception. When it is not possible to attend the query within said term, the interested party will be informed, stating the reasons for the delay and indicating the date on which their query will be answered, which in no case may exceed five (5) business days following the expiration of the first term.
6.2 Procedure to Request the Updating, Correction, Removal, or Revocation of Authorization, or to File Claims
The Holder, or his successors, who consider that the information contained in ATELIER 17 - 56 databases must be subject to correction, updating, or removal, or in case notice the alleged breach of any of the duties contained in this law, may present a claim before ATELIER 17 - 56, which will be processed under the following rules, in accordance with Article 15 of Law 1581 of 2012:
(i) The identification of the Holder.
(ii) Contact details (physical and/or electronic address and contact telephone numbers).
(iii) The documents that prove the identity of the Holder or the representation of his representative.
(iv) The clear and precise description of the personal data over which the Holder seeks to exercise any of the rights.
(v) The description of the facts that give rise to the claim.
(vi) The documents that you want to assert.
(vii) Signature, identification number, and fingerprint.
(viii) Original filing.
6.3 Data Removal
The Holder of the Data has the right, at any time, to request ATELIER 17 - 56 to remove (delete) their personal data when:
(i) The request to delete the data will not proceed when the Holder has a legal or contractual duty to remain in the database.
(ii) The deletion of data hinders judicial or administrative actions related to tax obligations, the investigation and prosecution of crimes, or the updating of administrative sanctions.
(iii) The data is necessary in order to preserve the legally protected interests of the Holder, to carry out an action based on public interest, or to fulfill an obligation that was legally acquired by the Holder.
6.4 Revocation of Authorization.
The Holder of the Personal Data can revoke the consent to the Treatment of his or her personal Data at any time, as long as a legal provision does not prevent it.
In development of the principle of Security, ATELIER 17 - 56 has adopted reasonable technical, administrative, and human measures in order to protect the data of the Holders, and to prevent adulteration, loss, consultation, unauthorized use, or fraudulent access to the data. Access to personal data is restricted to its Holders and ATELIER 17 - 56 will not allow access to this information by third parties under other conditions than those announced herein, except for an express request from the Data Holder or legitimized persons, in accordance with national regulations. Notwithstanding the aforementioned, ATELIER 17 - 56 will not be responsible for any action tending to violate the security measures that were established for the protection of Personal Data.
Depending on the nature of the permanent or occasional relationships that any person holding personal data may have with ATELIER 17 - 56, all of their information may be transferred abroad, subject to applicable legal requirements, with the acceptance of this Policy, which expressly authorizes the transfer of personal data. The information will be transferred for all the relationships that may be established with ATELIER 17 - 56. Without detriment to the obligation to observe and maintain the confidentiality of the information, ATELIER 17 - 56 will take the necessary measures so that these third parties know and commit to observe this Policy, with the understanding that the personal information they receive can only be used for matters directly related to their own relationship with ATELIER 17 - 56, and only while it lasts, and cannot be used or destined for a different end or purpose.
ATELIER 17 - 56 may also exchange Personal Data with other governmental or public authorities (including, among others, judicial or administrative authorities, tax authorities, and criminal, civil, administrative, disciplinary, and fiscal investigation organisms), as well as third parties involved in their civil or legal proceedings, their accountants, auditors, lawyers, and other advisers and representatives, taking into account that it is necessary or appropriate in order to:
This Policy is effective as of April 23, 2020.
As a general rule, the term of the authorizations regarding the use of Personal Data is understood as the term of the commercial relationship or of the connection to the service, and during the exercise of the company's corporate purpose.