DATA TREATMENT POLICY OF +CTG AS AVATAR
LATIN AMERICAN SUMMIT +CTG - UCEP
This policy of protection of personal data is applicable to all databases and / or files containing personal data that are subject to treatment by the COLOMBIAN UNION OF ADVERTISING COMPANIES -UCEP, as an organizing entity of + Cartagena, its contractors, strategic allies or employees.
2. IDENTIFICATION OF THE PERSON RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA
The UCEP, a non-profit association, with address at 99 # 7ª-77, office 401, Bogota DC, Email and the company in charge of data processing, (Ángela Vélez Comunicación Estratégica Digital SAS, email@example.com). Telephone (+571) 6110011.
Authorization: Prior, express and informed consent of the Holder to carry out the Processing of Personal Data.
Privacy Notice: Verbal or written communication generated by the Responsible, directed to the Owner for the Processing of Personal Data, through which you are informed about the existence of the Information Processing Policies that will be applicable, the way to access to them and the purposes of the Treatment that is intended to give personal data.
Database: Organized set of Personal Data that is subject to Treatment.
Personal Data: Any information linked to or associated with one or several natural persons determined or determinable.
Responsible for the Treatment: Natural or legal person, public or private, who by itself or in association with others, performs the Processing of Personal Data on behalf of the Treatment Responsible. In those events in which the Responsible Party does not act as the Data Base Manager, the person in charge will be explicitly identified.
Responsible for the Treatment: Natural or legal person, public or private, that by itself or in association with others, decides on the Database and / or the Treatment of the data.
Terms and Conditions: general framework in which the conditions for participants of promotional or related activities are established.
Holder: Natural person whose Personal Data is subject to Treatment.
Treatment: Any operation or set of operations on Personal Data, such as collection, storage, use, circulation or deletion.
Transfer: The transfer of data takes place when the person in charge and / or in charge of the processing of personal data, located in Colombia, sends the information or personal data to a receiver, who in turn is responsible for the treatment and is inside or outside from the country.
Transmission: Processing of Personal Data that implies the communication of the same within or outside the territory of the Republic of Colombia when it is intended to carry out a Treatment by the Manager on behalf of the Responsible Party.
The UCEP, acting as the Person in Charge of the Processing of Personal Data, for the adequate development of the activities related to the dissemination, marketing and promotion of participations of assistants and commercial alliances of or for the summit + Cartagena, collects, stores, uses, circulates and suppresses Personal Data corresponding to natural persons with whom it has or has had a relationship, such as, without the enumeration meaning limitation, workers and their relatives, shareholders, consumers, customers, distributors, suppliers, creditors and debtors.
The Personal Data is subject to Treatment by the UCEP with the following purposes:
5.1. For the sending of information to its workers, contractors, affiliates, and potential market of the summit + Cartagena;
5.2. To strengthen relations with its affiliates, companies, individuals and legal entities of the advertising sector integrated among others, by advertising agencies, media agencies without considering the medium of transmission, advertisers, BTL companies, academia and students of the same sectors; national or international associations or organizations to which they belong, by sending relevant information, taking requests and handling Petitions, Complaints and Claims (PQR's), evaluating the quality of their service and invitation and information about events organized or sponsored by the association, among others, but especially from the Latin American summit "+ Cartagena"
5.3. For the interaction with its suppliers, for the fulfillment of its legal obligations with its workers;
5.4. To consolidate an opportune and quality supply with its Suppliers, through the invitation to participate in selection processes, the evaluation of compliance with its obligations and the invitation to events organized or sponsored by the UCEP, among others;
5.5 For the verification of balances of your creditors during the operation and realization of + Cartagena;
5.6. For the determination of pending obligations, the consultation of financial information and credit history and the report to reporting centers of unfulfilled obligations, with respect to its debtors; as soon as they are related to the operation and realization of + Cartagena.
5.7. To improve, promote and develop its services and those of its affiliates;
5.8. For marketing activities, statistics, research and other purposes that do not contravene the current legislation in Colombia;
5.9. For the attention of judicial or administrative requirements and the fulfillment of judicial or legal mandates;
5.10. To eventually contact, via email, or by any other means, people with whom you have or have had a relationship, such as, without the enumeration meaning limitation, workers and family members of these affiliates, consumers, public authorities; national and international equivalent associations, distributors, suppliers, creditors and debtors, as well as other interest groups, for the aforementioned purposes.
6. RIGHTS OF THE PERSONAL DATA HOLDERS
Natural persons whose Personal Data are subject to Treatment by the UCEP, have the following rights, which may be exercised at any time:
6.1. Know the Personal Data on which the UCEP is performing the Treatment. In the same way, the Holder can request at any time, that their data be updated or rectified, for example, if they find that their data are partial, inaccurate, incomplete, fractioned, misleading, or those whose Treatment is expressly prohibited or not. has been authorized.
6.2. Request proof of the authorization granted to LA UCEP for the Treatment of your Personal Data.
6.3. To be informed by the UCEP, upon request, regarding the use that this has given to your Personal Data.
6.4. Submit to the Superintendence of Industry and Commerce complaints for infractions of the provisions of the Law on Protection of Personal Data.
6.5. Request to the UCEP the suppression of your Personal Data and / or revoke the authorization granted for the Treatment of same, by submitting a claim, in accordance with the procedures established in number 11 of this Policy. However, the request for suppression of the information and the revocation of the authorization will not proceed when the Holder of the information has a legal or contractual duty to remain in the Database and / or Archives, or while the relationship between the Holder and the UCEP, by virtue of which their data were collected.
6.6. Access free of charge to your Personal Data object of Treatment.
7. AREA RESPONSIBLE FOR THE IMPLEMENTATION AND OBSERVANCE OF THIS POLICY
The UCEP is responsible for the development, implementation, training and enforcement of this Policy. For this purpose, all of its officers and contractors who participate in Personal Data Processing events in the different areas of the UCEP, are obliged to report these Databases to the General Secretariat of the UCEP and to transfer it to it immediately. , of all the requests, complaints or claims received by the Personal Data Holders.
The General Secretariat of the UCEP is the area responsible for the attention of requests, queries, complaints and claims before which the holder of the information may exercise their rights to know, update, rectify and delete the data and revoke the authorization.
The UCEP must request prior, express and informed authorization to the Holders of the Personal Data on which it requires to carry out the Treatment.
8.1. Prior authorization means that the consent must be granted by the Holder, at the latest at the time of the collection of Personal Data.
8.2. Express authorization means that the Holder's consent must be explicit and specific, open and non-specific authorizations are not valid. It is required that the Holder declares its willingness to authorize the UCEP to carry out the Treatment of their Personal Data.
This manifestation of the Holder's will can occur through different mechanisms made available by the UCEP, such as:
In writing, for example, filling out an authorization form as indicated in Annex 1.
Orally, for example, in a telephone conversation or video conference.
Through unambiguous conducts that allow concluding that he granted his authorization, for example, through his express acceptance to the Terms and Conditions of an activity within which the authorization of the participants is required for the Treatment of his Personal Data.
IMPORTANT: In no case will the UCEP assimilate the Holder's silence to unequivocal conduct.
Whatever the mechanism used by the UCEP, it is necessary that the authorization be kept in order to be consulted later.
8.3. Informed Authorization means that at the time of requesting the consent of the Holder, it must be clearly informed:
The Personal Data that will be collected.
The identification and contact information of the Responsible and the Person in Charge of the Treatment.
The specific purposes of the Treatment that is intended to be carried out, that is: how and for what the collection, use and circulation of Personal Data will be done.
What are your rights as a Personal Data Holder; for the purpose, see section 6 of this Policy.
The optional nature of the answer to the questions that are asked, when they are about sensitive data or about the data of children and adolescents.
9. SPECIAL PROVISIONS FOR THE TREATMENT OF PERSONAL DATA OF SENSITIVE NATURE.
In accordance with the Law of Protection of Personal Data, data of a sensitive nature are considered those that affect privacy or whose improper use can generate discrimination, such as those related to:
Racial or ethnic origin.
Religious / philosophical convictions.
Membership of unions, social organizations, human rights organizations or political parties.
Biometric data (such as fingerprint, signature and photo).
The Treatment of Personal Data of a sensitive nature is prohibited by law, unless there is express, prior and informed authorization of the Holder, among other exceptions enshrined in Article 6 of Law 1581 of 2012.
In this case, in addition to complying with the requirements established for the authorization, the UCEP must:
Inform the Owner that because it is sensitive data is not required to authorize its Treatment.
Inform the Owner of the data that will be subject to Treatment are sensitive and the purpose of the Treatment.
IMPORTANT: No activity may be conditioned to the Holder providing sensitive Personal Data.
10. SPECIAL PROVISIONS FOR THE PROCESSING OF PERSONAL DATA OF CHILDREN AND ADOLESCENTS
According to the provisions of Article 7 of Law 1581 of 2012 and Article 12 of Decree 1377 of 2013, the UCEP will only carry out the Treatment, that is, the collection, storage, use, circulation and / or deletion of Personal Data corresponding to children and adolescents, as long as this Treatment responds and respects the best interests of children and adolescents and ensures respect for their fundamental rights.
Once the above requirements have been met, the UCEP must obtain the Authorization of the legal representative of the child or adolescent, after exercising the minor's right to be heard, an opinion that will be evaluated taking into account the maturity, autonomy and ability to understand the matter.
11. PROCEDURE FOR ATTENTION AND RESPONSE TO PETITIONS, CONSULTATIONS, COMPLAINTS AND CLAIMS OF PERSONAL DATA HOLDERS
The Holders of Personal Data that are being collected, stored, used, put into circulation by the UCEP, may at any time exercise their rights to know, update, rectify and delete information and revoke the authorization.
For this purpose, the following procedure will be followed, in accordance with the Personal Data Protection Law:
11.1. ATTENTION AND RESPONSE TO REQUESTS AND CONSULTATIONS:
What is the procedure?
The Holder or his successors, may request to the UCEP, through the means indicated below:
Information about the Personal Data of the Owner that is subject to Treatment.
Request proof of the authorization granted to LA UCEP for the Treatment of your Personal Data.
Information regarding the use that has been given by the UCEP to your personal data.
Means enabled for the submission of petitions and consultations:
The UCEP has arranged the following means for the reception and attention of requests and consultations, all of which allow to keep proof of them:
Application submitted to the email:
Attention and response by the UCEP:
The requests and consultations will be attended within a maximum term of ten (10) business days from the date of receipt of the same. When it is not possible to attend the request or query within said term, the interested party will be informed, stating the reasons for the delay and indicating the date on which their request or consultation will be addressed, which in no case may exceed five (5) business days following the expiration of the first term.
11.2. ATTENTION AND RESPONSE TO COMPLAINTS AND CLAIMS:
What is the procedure?
The Holder or his successors, may request to the UCEP, through a complaint or claim submitted through the channels indicated below:
The correction or update of the information.
The suppression of your Personal Data or the revocation of the authorization granted for the Treatment of same.
That the alleged breach to any of the duties contained in the Law of Protection of Personal Data is corrected or corrected.
The request must contain the description of the facts that give rise to the complaint or claim, the address and contact information of the applicant, and must be accompanied by the documents you want to enforce.
Means enabled for the presentation of complaints and claims:
The UCEP has arranged the following means for the reception and attention of complaints and claims, all of which allow to preserve proof of its presentation:
Application submitted to the email:
Attention and response by the UCEP:
If the complaint or claim is incomplete, THE UCEP must request the interested party within five (5) days after receiving the complaint or claim to correct the faults. After two (2) months from the date of the request, without the applicant submitting the required information, it will be understood that he has withdrawn the complaint or claim.
In case the person who receives the complaint or claim is not competent to resolve it, it will transfer it to the administration; within a maximum term of two (2) business days and inform the interested party of the situation.
Once the complaint or complete complaint has been received, a legend that says "claim in process" and the reason for it will be included in the Database, in a term not exceeding two (2) business days. This legend must be maintained until the complaint or claim is decided.
The maximum term to address the complaint or claim will be fifteen (15) business days from the day following the date of receipt. When it is not possible to address the complaint or claim within that term, the interested party will be informed of the reasons for the delay and the date on which the complaint or claim will be addressed, which in no case may exceed eight (8) days Skillful following the expiration of the first term.
12. INFORMATION OBTAINED PASSIVE
When accessing or using the services contained within the websites of the UCEP, it may collect information passively through technologies for the management of information, such as "cookies", through which information is collected about hardware and software of the equipment, IP address, browser type, operating system, domain name, access time and the addresses of the websites of origin; By using these tools, users' Personal Data is not collected directly. Information will also be collected about the pages that the person visits most frequently on these websites in order to know their browsing habits. However, the user of the websites of the UCEP has the possibility of configuring the operation of the "cookies", in accordance with the options of his Internet browser.
13. SECURITY OF PERSONAL DATA
The UCEP, in strict application of the Principle of Security in the Processing of Personal Data, will provide the technical, human and administrative measures that are necessary to grant security to the records avoiding their adulteration, loss, consultation, use or unauthorized or fraudulent access. The obligation and responsibility of the UCEP is limited to having the appropriate means for this purpose. The UCEP does not guarantee the total security of your information nor is it responsible for any consequence derived from technical failures or from undue entry by third parties to the Database or File in which the Personal Data subject to Treatment by the UCEP rests and its Managers. The UCEP will require the service providers that it contracts, the adoption and compliance with the technical, human and administrative measures appropriate for the protection of the Personal Data in relation to which said suppliers act as Managers.
14. TRANSFER, TRANSMISSION AND REVELATION OF PERSONAL DATA
The UCEP may deliver the Personal Data to third parties not linked to LA UCEP when: a. Are contractors in execution of contracts for the development of the activities of the UCEP in relation to + Cartagena and in its capacity as organizer; b. By transfer to any title of any line of business with which the information is related. C. For purposes of promotion and marketing and other registration processes and participation in the summit + Cartagena. C. The personal data referred to in this policy and the responsibilities and ownership thereof may be transferred by the UCEP to a third party, who may act as the organizer of the summit + Cartagena. In this case, the corresponding entity will adopt the corresponding policy and update those responsible for handling and processing the data.
In any case, in the contracts of transmission of Personal Data, which are signed between LA UCEP and those in Charge for the Processing of Personal Data, it will be required that the information be treated in accordance with this Personal Data Protection Policy and the following will be included. Obligations in the head of the respective Manager:
Give Treatment, in the name of the UCEP to the Personal Data according to the principles that protect them.
Safeguard the security of the databases in which Personal Data are contained.
Keep confidentiality regarding the Treatment of Personal Data.
15. APPLICABLE LEGISLATION
This Policy of Protection of Personal Data, the Privacy Notice and the Authorization Form that is part of this Policy as Annex 1, are governed by the provisions of the current legislation on protection of Personal Data referred to in Article 15 of the Political Constitution of Colombia, Law 1266 of 2008, Law 1581 of 2012, Decree 1377 of 2013, Decree 1727 of 2009 and other regulations that modify, repeal or replace them.
This Policy for the Protection of Personal Data is effective as of January 1, 2017 and replaces the one published previously on the UCEP web page and in force to date.