PERSONAL DATA PROCESSING POLICY

Responsible

The person responsible for the processing of personal data is ULTRACOM IT S.A.S, a legally constituted company, identified with NIT. 900.038.708-5, with address in the city of Medellín and email: negocios@ultracom.com.co. In the same way, you will be responsible for protecting the security and good management of your personal data.

Authorization of the owner

For the processing of personal data, the prior and informed authorization of the Holder is required, which must be obtained by any means that can be subject to subsequent consultation.

The authorization meets these requirements when it is manifested:

Written
Oral form
Through unequivocal behavior of the owner that allows a reasonable conclusion that he granted the authorization.

The Owner’s authorization will not be necessary in the case of:

Information required by a public or administrative entity in the exercise of its legal functions or by court order.
Data of a public nature;
Cases of medical or health urgency;
Treatment of information authorized by law for historical, statistical or scientific purposes.
Data related to the Civil Registry of People, their profession or trade and their quality as a merchant or public servant.

Rights of holders

The owner of the personal data is assisted by the following rights:

  1. Know, update and rectify your personal data against ULTRACOM IT S.A.S.
  2. Request proof of the authorization granted except when expressly excepted as a requirement for treatment.
  3. Submit complaints to the Superintendence of Industry and Commerce for violations of the personal data protection regulations.
  4. Revoke the authorization and/or request the deletion of the data when the Treatment does not respect the constitutional and legal principles, rights and guarantees.
  5. The owners may at any time request ULTRACOM IT S.A.S., the deletion of their personal data and / or revoke the authorization granted for the treatment of these.
  6. Access the personal data that has been processed free of charge once a month or whenever there are substantial changes to the policies.
  7. Be informed by the Entity or the Treatment Manager, upon request, regarding the use that has been given to the data.

Protection of children and adolescents

The processing of personal data of children and adolescents is prohibited, except in the case of data of a public nature, and when such processing meets the following requirements:

  1. Respond to and respect the best interests of children and adolescents.
  2. Ensure respect for their fundamental rights.

Sensitive Data

It is that data that affects the privacy of the owner or whose improper use can generate discrimination, as well as data related to health, sexual life and biometric data.

The processing of sensitive data is prohibited, except when:

  1. The Holder of his explicit authorization to said Treatment, except in cases where the granting of said authorization is not required by law.
  2. The Treatment is necessary to safeguard the vital interest of the Holder and he is physically or legally incapacitated. In these events, legal representatives must grant their authorization.
  3. The Treatment refers to data that is necessary for the recognition, exercise or defense of a right in a judicial process..
  4. The Treatment has a historical, statistical or scientific purpose. In this event, the measures leading to the suppression of the identity of the Holders must be adopted.

Special authorization of sensitive personal data

By provision of the law, the delivery of sensitive data is clearly optional, ULTRACOM IT S.A.S. will inform their owners that they are not obliged to deliver them or authorize their treatment.

In case of obtaining authorization of sensitive data, ULTRACOM IT S.A.S. will keep them under security measures that guarantee their confidentiality.

Transfer and transmission of personal data

ULTRACOM IT S.A.S. podrá transmitir o realizar transferencia de datos personales a terceros bajo niveles adecuados de protección y en cumplimiento de obligaciones operativas y/o contractuales para su debido tratamiento, siempre en desarrollo de su objeto social.

Para la transferencia o transmisión se deberá tener acuerdo previo sobre la entrega de los datos, dicho acuerdo deberá versar, como mínimo, sobre los siguientes aspectos.

  1. Alcance del tratamiento.
  2. El tratamiento o actividades que el Encargo o Responsable realizara sobre los datos personales.
  3. Las obligaciones de las partes frente al Titular o el encargado frente al responsable.

Respecto al Encargado, este deberá cumplir con los siguiente:

 

  1. Tratar los datos personales a nombre del responsable y de conformidad con las disposiciones legales y de la presente política.
  2. Implementar las medidas necesarias que garanticen razonablemente su seguridad.
  3. Guardar confidencialidad respecto de los datos y el tratamiento que se le dan a estos.

Procedures to deal with claims, queries and incidents

Owners can exercise the rights they have over their personal data in accordance with the following procedures:

CLAIMS

If you as the owner, successor in title or legal representative and consider that the information contained in a database should be subject to correction, updating, deletion and/or revocation of the authorization granted for the treatment of these, you must file a claim with the responsible or in charge of the treatment, which will be processed under the following procedure:

  1. The claim will be formulated by means of a request sent to the email of the Responsible.
  2. The maximum term to address the claim will be 10 business days from the day following the date of receipt in full, extendable for up to 5 more business days after notifying the claimant of the reasons for the delay in the response..

INQUIRIES

The Holders or authorized persons may consult the personal information, which rests in any database for which ULTRACOM IT S.A.S. is responsible or in charge. for this you must provide:

  1. Names and surnames of the Holder and/or his representative and/or successors in title.
  2. Contact details of the Holder and/or his representative and/or successors in title.
  3. Information and scope of which it is intended to consult.
  4. Request addressed to the Responsible, in accordance with this policy.

The ownership or authorization is validated and that the request is made in due form, it will be answered within a period of no more than 5 business days, extendable up to 3 more business days, prior communication of the reasons for the delay in the response to the applicant.

INCIDENTS

The information must be notified immediately to the person in charge of ULTRACOM IT S.A.S. understanding this but not limited to any suspicious events, weaknesses or policy violations.

The incident must be managed in a timely manner, evaluating and determining whether or not they are incidents that must be managed.