Personal data processing policy
Pursuant to the provisions of the Political Constitution, Law 1581 of 2012 (Habeas Data), its regulatory decree 1377 of 2013 and other provisions and complementary rules, LAMINAS Y EMPAQUES S.A.S ( hereinafter LAMIEMPAQUES S.A.S), develops and adopts this policy for the processing of personal data, regarding the collection, storage, use, circulation, rectification, deletion and other activities that constitute processing of personal data, thus protecting the right to privacy, personal and family intimacy and good name. In this way LAMIEMPAQUES S.A.S, states that any activity that requires the collection and storage of data, will be developed under the principles of legality, confidentiality, truthfulness, transparency, security and restricted access and circulation.
All persons who, at any time, in the development of different contractual, commercial, informative, labor and other activities, have provided us with personal data or any type of personal information, may know, update and ratify the information that LAMIEMPAQUES S.A.S. has collected about them in databases or files. The information is given or registered freely and voluntarily.
1. IDENTIFICATION OF THE DATA CONTROLLER INFORMATION
LAMIEMPAQUES S.A.S, is a company located in the city of Itagui- Antioquia, its main activity is the manufacture and marketing of sheets, packaging, advertising material for promotion at the point of sale, auto parts, agribusiness and all those plastic products that are made by extrusion processes, thermoforming, printing, stamping, sealing and other processes of transformation of plastic resins.
Address: Calle 51 No 40-180 Itagui, Antioquia.
Contact Phone Number: 377.70.80
E-mail: [email protected]
2. DEFINITIONS
For the purposes of the application of this policy and in accordance with current legislation on the subject, the following definitions shall be taken into account:
- Authorization: Prior, express and informed consent of the Data Subject to carry out the Processing of personal data.
- Privacy notice: Verbal or written communication generated by the responsible party, addressed to the holder for the processing of personal data, through which he/she is informed about the existence of the information processing policies that will be applicable, the way to access them and the purposes of the processing that is intended to be given to the personal data.
- Data Base: Organized set of personal data that is subject to Processing.
- Personal data: Any information linked or that can be associated to one or several determined or determinable natural persons.
- Public data is data that is not semi-private, private or sensitive. Public data includes, among others, data relating to the marital status of individuals, their profession or trade, and their status as merchants or public servants. By their nature, public data may be contained, among others, in public records, public documents, official gazettes and bulletins, and duly executed court rulings that are not subject to confidentiality.
- Sensitive Data: Data that affect the privacy of the Data Subject or whose improper use may generate discrimination, such as those that reveal racial or ethnic origin, political orientation, religious or philosophical convictions, membership in trade 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.
- Data Processor: 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 Controller. In the events in which the Controller does not act as the person in charge of the database, the person in charge shall be expressly identified.
- Data Controller: Natural or legal person, public or private, who by himself or in association with others, decides on the database and/or the processing of the data.
- Data Subject: Natural person whose personal data is the object of processing.
- Processing: Any operation or set of operations on personal data, such as collection, storage, use, circulation or deletion.
- Data transfer: It takes place when the Controller and/or Processor of personal data, located in Colombia, sends the information or personal data to a recipient, which in turn is the Data Controller and is located inside or outside the country.
- Transmission: Processing of personal data that involves the communication of such data within or outside the territory of the Republic of Colombia when its purpose is the performance of a Processing by the Processor on behalf of the Controller.
3. RIGHTS OF THE HOLDER OF THE PERSONAL DATA
In accordance with the current legal regulations, the holder of the information shall have the following rights:
- To know, update and rectify their personal data against the Data Controllers or Data Processors of partial, inaccurate, incomplete, fractioned, misleading, or those whose processing is expressly prohibited or has not been authorized.
- Request proof of the authorization granted to the Data Controller. Notwithstanding the foregoing, the authorization will not be necessary when: 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 emergency; processing of information authorized by law for historical, statistical or scientific purposes and data related to the Civil Registry of Persons.
- To be informed by the Data Controller or the Data Processor, upon request, regarding the use that has been made of their personal data.
- File complaints before the Superintendence of Industry and Commerce for violations to the law of habeas data (law 1581 of 2012).
- To revoke the authorization and/or request the deletion of the data when the principles, rights and guarantees are not respected in the processing.
- Access free of charge to your personal data that have been subject to Processing.
4. RIGHTS OF CHILDREN AND ADOLESCENTS
LAMIEMPAQUES S.A.S., protects in a special way the prevalent rights of children and adolescents, which is why the processing of their personal data is prohibited, except for those data that are of a public nature and when such processing meets the following requirements:
- That it responds to and respects the best interests of children and adolescents.
- To ensure respect for their fundamental rights.
Once the above requirements have been met, the legal representative of the child or adolescent will grant the authorization after the minor has exercised his or her right to be heard, an opinion that will be assessed taking into account the maturity, autonomy and capacity to understand the matter.
The family and society must ensure that those responsible for and in charge of the processing of personal data of minors comply with the obligations established in Law 1581 of 2012.
It is the task of the State and educational entities of all types to provide information and train legal representatives and guardians on the possible risks faced by children and adolescents regarding the improper processing of their personal data, and to provide knowledge about the responsible and safe use by children and adolescents of their personal data, their right to privacy and protection of their personal information and that of others.
5. REQUEST FOR AUTHORIZATION TO THE OWNER OF THE DATA
Prior to and/or at the time of collecting the information or personal data, LAMIEMPAQUES S.A.S, will make the respective request for authorization to the owner of the information, to collect and process the data, making known the purpose for which the information is requested, using for that purpose: automated technical means, written or oral, allowing to keep proof of authorization. such authorization shall be requested for the time that is reasonable and necessary to satisfy the needs that gave rise to the request for the data and in any case, in compliance with the legal provisions governing the matter.
6- TIME LIMITATIONS TO THE PROCESSING OF PERSONAL DATA.
LAMIEMPAQUES S.A.S. may only collect, store, use or circulate personal data for the time that is reasonable and necessary, according to the purposes that justified the treatment, taking into account the provisions applicable to the subject matter and the administrative, accounting, tax, legal and historical aspects of the information. Once the purpose or purposes of the processing have been fulfilled, and notwithstanding any legal provisions to the contrary, the personal data in its possession shall be deleted. Notwithstanding the foregoing, personal data must be retained when required for compliance with a legal or contractual obligation.
7. AREA RESPONSIBLE AND PROCEDURE FOR THE EXERCISE OF THE RIGHTS OF THE HOLDERS OF THE PERSONAL DATA
Management is the area responsible for dealing with requests, complaints and claims made by the owner of the information in exercise of the rights referred to in paragraph 3 of this policy, for such purposes, the owner of the personal data or whoever exercises his representation may send his request, complaint or claim from Monday to Friday from 7:30 a.m. to 6:00 p.m., to the following e-mail address [email protected]Call LAMIEMPAQUES S.A.S., Itagui-Antioquia phone number (4) 377.70.80 or send it to the following address corresponding to our offices
Calle 51 Nro. 40-180 Itagui Antioquia
The petition, complaint or claim must contain the identification of the Holder, the description of the facts that give rise to the claim, the address, and accompanying documents to be asserted. If the claim is incomplete, the interested party will be required within five (5) days after receipt of the claim to correct the faults. After two (2) months from the date of the requirement, without the applicant submitting the required information, it will be understood that the claim has been abandoned. The maximum term to address the claim will be fifteen (15) working days from the day following the date of receipt. When it is not possible to address the claim within such term, the interested party will be informed of the reasons for the delay and the date on which the claim will be addressed, which in no case may exceed eight (8) business days following the expiration of the first term.
8. INFORMATION SECURITY
In development of the security principle established in Law 1581 of 2012, LAMIEMPAQUES S.A.S. will adopt the technical, human and administrative measures necessary to provide security to the records avoiding their adulteration, loss, consultation, use or unauthorized or fraudulent access. The personnel who carry out the processing of personal data will execute the protocols established in order to guarantee the security of the information.
9. AUTHORIZATION AND CONSENT OF THE DATA SUBJECT
LAMIEMPAQUES S.A.S., requires the free, prior, express and informed consent of the owner of the personal data for the processing thereof, for which different means will be available, among which is the physical document, electronic, websites or any format that allows obtaining consent through the expression of the unequivocal will of the owner, his successors and / or legal representative who must prove such quality. The authorization of the holder for the processing of personal data will be requested by LAMIEMPAQUES S.A.S., prior to treatment. The company will keep proof of the authorization granted by the holder, for which it will have physical and magnetic files which will record the form and date on which it was obtained.
10. ENTRY INTO FORCE OF THE INFORMATION PROCESSING POLICY
This information processing policy is effective as of November 1, 2016 and will remain in force as long as necessary for the purposes established by law and described in the authorization document for the processing of personal data.
Sincerely yours,
