Get to know our solutions

Personal Data Processing Policy LSV Technology Services Colombia S.A.S.

TABLE OF CONTENTS

 

1. PRINCIPLES OF ACTION ON THE PROTECTION OF PERSONAL DATA ................ 4

2. OWNER OF PERSONAL DATA......................................................................................... 5

2.1 Status as a Personal Data Subject................................................................................... 5

2.2 Rights of Personal Data Subjects....................................................................... 6

2.3 Persons who may exercise the Owner's right.............................................................. 6

2.4 Data processing of children and adolescents ..................................................... 6

2.4.1 Rights of children and adolescents Holders of personal data .......................... 7

2.5 Data processing in relation to financial, credit, commercial, service and third-country information. .................................................................................... 7

3. PROCEDURE FOR AUTHORISING DATA SUBJECTS TO PROCESS THEIR PERSONAL DATA............................................................................................................................ 7

3.1 Collection of personal data............................................................................................ 7

3.2 Authorisation of the processing of personal data................................................................. 8

3.3 Second consent to the processing of personal data .................................................. 8

3.4 Extension of the Authorization for the Processing of Personal Data........................................ 8

3.5 Purpose of processing personal data ...................................................................... 8

3.6 Cases in which LSV TECH SAS may share the personal data of the holders......... 9

3.7 Time limitations or validity of the processing of personal data....................... 9

4. PERSONAL DATA PROCESSING POLICIES.............................................................10

4.1 Responsible for the Processing of Personal Data..............................................................10

4.2 Personal Data Processor.......................................................................10

4.3 Duties of Data Processors..........................................................11

4.4 Procedure for reporting material changes to Data Processing Policies 12

4.5 Processing of personal data:................................................................12

4.5.1 Audience...............................................................................................................................12

4.5.2 Semi-Private.......................................................................................................................12

4.5.3 Private.............................................................................................................................12

4.5.4 Sensitive............................................................................................................................12

4.6 Data Processing Authorized Persons.............................................................13

4.7 Levels of protection of personal data..................................................................... 13

4.7.1 Permanent and Restricted Custody...................................................................................13

4.8 Effective Date of the Personal Data Processing Policy ............... 15

5. PROCESSING OF PERSONAL DATA IN THE AREA OF AUDIOVISUAL, ADVERTISING AND COMMUNICATIONS............................................................................................................................15

5.1 Authorisation to take images (video and photographs).....................................................15

5.1.1 Authorisation for events, facilities or areas that have video surveillance............... 15

5.1.2 Purpose of processing photos and/or images as personal data........................ 16

5.1.3 Authorisation for particular activities.......................................................................16

5.1.4 Custody of the authorization...............................................................................................16

5.2 Technological and advertising media ........................................................................... 16

6. PROCESSING OF PERSONAL DATA AND IMPLEMENTATION OF SAGRILAFT.....17

7. EXERCISE OF THE RIGHTS OF DATA SUBJECTS............................................. 17

7.1 Means of dissemination so that the owner is aware of the privacy notice and the processing policies....................................................................................................................................... 17

7.2 Persons or areas responsible for dealing with the rights of data subjects....................18

7.3 Procedure for holders to exercise their rights .................................... 18

7.3.1 Procedure for consultations...........................................................................................18

7.3.2 Grievance Procedure...........................................................................................19

7.4 Terms of Response..........................................................................................................20

7.4.1 Consultations........................................................................................................................... 20

8. SECURITY MEASURES APPLIED TO THE PROCESSING OF PERSONAL DATA.................. 20

 

 

1. 0. INTRODUCCION

 

LSV TECHNOLOGY SERVICES COLOMBIA SAS hereinafter LSV TECH SAS in compliance with Law 1581 of 2012 "by which general provisions for the protection of personal data are dictated" and the rules that regulate and modify the matter, with this document implements the Personal Data Processing Policy, hereinafter the Policy, for the knowledge of all our clients, debtors and people related to the commercial management carried out by LSV TECH SAS. and its corporate purpose enshrined in the Chamber of Commerce.

In consideration of the above, LSV TECH SAS. adopts the Policy taking into account the following principles of action in harmony with the Personal Data Protection Law:

 

1. PRINCIPLES OF ACTION ON THE PROTECTION OF PERSONAL DATA

With regard to the processing of personal data contained in its databases or files, LSV TECH SAS. It will act taking into account the following guidelines:

 

• You will obtain prior authorisations from the data subjects for the processing of your personal data, as well as the necessary authorisations to share their information with third parties, where applicable.
• The authorisation will contain information about the purposes of the processing of personal data, purposes that will be previously informed to the owner. LSV TECH SAS. It will process the data in accordance with the purposes informed to the owner.
• It will require the necessary authorisations from the owners of the information in the event that they authorise a third party to access their personal data incorporated into the Entity's databases or files.
• It will request from the data subjects the necessary information that is required in accordance with the purposes of the processing and in accordance with the requirements that arise from the relationship that binds them to the Entity.
• It will share the personal data of data subjects contained in its databases and files when required by competent authorities.
• It will retain the holders' information for the time required by law. In any case, the data will be kept for as long as the relationship between the owner and the Entity is in force and until the latter revokes it in accordance with the authorisation given by the owner of the personal data.

• It will require the third parties in charge of the processing of the information and with whom the Entity enters into agreements by virtue of which the personal data of the owners are shared, to have security and confidentiality measures for the handling of the information.

  • It will require that in the event that a third party provides it with the owner's personal data, that third party has the required authorization that allows it to share the information with the Entity.
  • It will provide the data subjects and third parties authorised by them with the information in a clear and express manner. In this sense, it will implement measures that allow it to identify the personal data it has, the purposes of the processing and the use that has been given to it.
  • It will limit and control access to the information of the holders. It will establish access controls by the Entity's officials and impose disciplinary sanctions on officials who omit or fail to comply with this policy, as well as the procedures that regulate it.
  • It will diligently attend to the queries and claims presented by the owners of the information in a term that in any case will not exceed those provided for by law. Likewise, it will inform the owners about their rights and will keep the data of the responsible area available to deal with their queries and claims.
  • It will publish the principles of action in the field of personal data protection so that they are known by the owners of the personal data."

   In accordance with the LSV TECH SAS. presents the Policy.

   

1. 0. INTRODUCCION

 

LSV TECHNOLOGY SERVICES COLOMBIA SAS hereinafter LSV TECH SAS in compliance with Law 1581 of 2012 "by which general provisions for the protection of personal data are dictated" and the rules that regulate and modify the matter, with this document implements the Personal Data Processing Policy, hereinafter the Policy, for the knowledge of all our clients, debtors and people related to the commercial management carried out by LSV TECH SAS. and its corporate purpose enshrined in the Chamber of Commerce.

In consideration of the above, LSV TECH SAS. adopts the Policy taking into account the following principles of action in harmony with the Personal Data Protection Law:

 

1. PRINCIPLES OF ACTION ON THE PROTECTION OF PERSONAL DATA

With regard to the processing of personal data contained in its databases or files, LSV TECH SAS. It will act taking into account the following guidelines:

 

• You will obtain prior authorisations from the data subjects for the processing of your personal data, as well as the necessary authorisations to share their information with third parties, where applicable.
• The authorisation will contain information about the purposes of the processing of personal data, purposes that will be previously informed to the owner. LSV TECH SAS. It will process the data in accordance with the purposes informed to the owner.
• It will require the necessary authorisations from the owners of the information in the event that they authorise a third party to access their personal data incorporated into the Entity's databases or files.
• It will request from the data subjects the necessary information that is required in accordance with the purposes of the processing and in accordance with the requirements that arise from the relationship that binds them to the Entity.
• It will share the personal data of data subjects contained in its databases and files when required by competent authorities.
• It will retain the holders' information for the time required by law. In any case, the data will be kept for as long as the relationship between the owner and the Entity is in force and until the latter revokes it in accordance with the authorisation given by the owner of the personal data.

• It will require the third parties in charge of the processing of the information and with whom the Entity enters into agreements by virtue of which the personal data of the owners are shared, to have security and confidentiality measures for the handling of the information.

  • It will require that in the event that a third party provides it with the owner's personal data, that third party has the required authorization that allows it to share the information with the Entity.
  • It will provide the data subjects and third parties authorised by them with the information in a clear and express manner. In this sense, it will implement measures that allow it to identify the personal data it has, the purposes of the processing and the use that has been given to it.
  • It will limit and control access to the information of the holders. It will establish access controls by the Entity's officials and impose disciplinary sanctions on officials who omit or fail to comply with this policy, as well as the procedures that regulate it.
  • It will diligently attend to the queries and claims presented by the owners of the information in a term that in any case will not exceed those provided for by law. Likewise, it will inform the owners about their rights and will keep the data of the responsible area available to deal with their queries and claims.
  • It will publish the principles of action in the field of personal data protection so that they are known by the owners of the personal data."

   In accordance with the LSV TECH SAS. presents the Policy.

   

2. OWNER OF PERSONAL DATA

 

2.1 Status as a Personal Data Subject

It is the natural or legal person whose personal data are subject to the LSV TECH SAS database, which is subject to this Personal Data Processing Policy, which, for the specific case, will be all the people who have a LSV TECH SAS product or service with the entity. a commercial or employment relationship, as well as their attorneys-in-fact, legal representatives, co-debtors and/or guarantors. In specific cases, LSV TECH SAS has several groups of personal data subjects, which are: customers, suppliers, workers, natural persons, legal entities, debtors, creditors.

2.2 Rights of Personal Data Subjects

a. Know, update and rectify your personal data vis-à-vis the Data Controllers or Data Processors. This right may be exercised, among others, in the case of partial, inaccurate, incomplete, fragmented, misleading data, or data whose Processing is expressly prohibited or has not been authorised.

b. Request proof of the authorization granted to the Data Controller, except when expressly excepted as a requirement for the Processing, in accordance with the provisions of Article 10 of Law 1581 of 2012.

c. To be informed by the Data Controller or the Data Processor, upon request, regarding the use of your personal data

d. Submit complaints to the competent authority for violations of the provisions of this law and the other regulations that modify, add or complement it.

e. Revoke the authorisation and/or request the deletion of the data when the Processing does not respect the principles, rights and constitutional and legal guarantees. The revocation and/or suppression will proceed when the Superintendence of Industry and Commerce has determined that in the Processing the responsible party or Processor has incurred in conduct contrary to said law and the Constitution.

f. Access free of charge to your personal data that has been subject to Processing.

 

2.3 Persons who may exercise the Owner's right

The rights may be exercised by the following persons:

 

• Holders must provide sufficient proof of their identity by presenting an identity document.
• The successors or heirs who must prove their status with the civil birth records to prove kinship.

• By the legal representative or attorney-in-fact with the presentation of the original power of attorney.

Personal Data Processor

 

It will be the entity LSV TECH SAS and those persons who represent the rights of the entity, to whom it contracts, assigns its obligations or its contractual position in any capacity, as well as the entities with which LSV TECH SAS establishes commercial alliances from which products or services are offered, who will be subject to the terms and procedures established in this Policy, as a safeguard of the fundamental rights of the Data Subjects who are part of the LSV TECH SAS Database.

 

4.2.1 Custody of Data: The HUMAN TALENT AND ADMINISTRATIVE AREA will be in charge of permanent custody.

 

Duties of Data Controllers

to. Guarantee to the Holder, at all times, the full and effective exercise of the right of habeas data. b. Request and keep, under the conditions provided for in this law, a copy of the respective

authorization granted by the Owner.

c. Duly inform the Data Subject about the purpose of the collection and the rights to which he/she is entitled by virtue of the authorisation or

d. To keep the information under the necessary security conditions to prevent its adulteration, loss, consultation, unauthorized or fraudulent use or access.

d. Ensure that the information provided to the Data Processor is truthful, complete, accurate, up-to-date, verifiable and understandable

and. Update the information, communicating in a timely manner to the Data Processor, all the news regarding the data previously provided and adopt the other necessary measures to keep the information provided to the latter updated.

g. Rectify the information when it is incorrect and communicate the pertinent information to the Data Processor.

h. Provide the Data Processor, as the case may be, only with data whose Processing is previously authorized in accordance with the provisions of this law.

i. Require the Data Processor to respect the security and privacy conditions of the Client's information at all times.

j. To process queries and claims made in the terms indicated herein.

k. Adopt an internal manual of policies and procedures to ensure proper compliance with this law and, in particular, to respond to queries and

l. Inform the Data Processor when certain information is under discussion by the Data Controller, once the claim has been submitted and the respective procedure has not been completed

m. Inform, at the request of the Owner, about the use made of their data.

n. Inform the data protection authority when there are violations of security codes and there are risks in the management of the Holders' information.

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

4.3 Duties of Data Processors

a. Guarantee the Owner, at all times. the full and effective exercise of the right of habeas data.

b. Preserve the information under the necessary security conditions to prevent its adulteration, loss, consultation, unauthorized or fraudulent use or access.

c. To carry out the timely updating, rectification or deletion of the data under the terms of this

d. Update the information reported by the Data Controllers within five (5) business days from its receipt.

e. To process the queries and claims made by the Holders in the terms indicated in this law.

f. Adopt an internal manual of policies and procedures to ensure proper compliance with this law and, in particular, for the attention of queries and claims by the Holders.

g. Register in the database the legends "claim in process" in the manner regulated by this law.

h. Insert in the database the legend "information in judicial discussion" once notified by the competent authority about legal proceedings related to the quality of the personal data.

i. Refrain from circulating information that is being disputed by the Owner and whose blocking has been ordered by the Superintendence of Industry and Commerce

j. Allow access to information only to persons who may have access to it. Inform the Superintendence of Industry and Commerce when violations of the

k. security codes and there are risks in the management of the Holders' information.

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

 

 

4.4 Procedure for reporting material changes to the Data Processing Policies

LSV TECH SAS as responsible and in charge of the processing of Personal Data will inform customers, suppliers and workers of substantial modifications to the Policy, through messages with the content of the modified Policy, published on the company's website and/or e-mails sent to the e-mails of the Account Holders.

 

4.5 Processing of personal data:

LSV TECH SAS presents below the Special Treatment for each type of personal data, in order to protect the fundamental right of the Data Subjects.

 

4.5.1      Public

These are all those data that the National Law or Constitution will determine as such, but they are not semi-private or private data, as an example are the data related to the civil status of people, their profession or trade, the quality of public servant or employee. The processing of this type of data will be that provided for by law, which will be applied by the Responsible Party and the Person in Charge of the Database.

 

4.5.2      Semi-Private 

It is a piece of information that is not reserved, intimate or public, the disclosure of which may be of special interest to a sector of people, such as economic activity and profession. The Data Controller and Processors will keep this type of personal data in permanent custody and it will be delivered to third parties at the request of the competent authority or person authorized by the Data Subject.

 

4.5.3      Private 

It is personal data of intimate or reserved quality, as an example are: identification number, home address, telephone and cell phone numbers, emails, place of work and related, as well as credit behavior and banking information. The Data Controller and Processors will keep this type of personal data in permanent custody and it will be delivered to third parties at the request of the competent authority or person authorized by the Data Subject.

 

4.5.4      Sensitive 

These are data that affect the privacy of the Data Controller and whose improper use may lead to discrimination, such as: racial or ethnic origin, political orientation, religious or philosophical convictions, membership of trade unions, political organizations, social organizations or human or animal rights, as well as data related to health, orientation and sex life. and biometrics. In particular, the Data Controller and Database Managers will keep this type of personal data in permanent and restricted custody, and the personal data will be handed over to third parties at the request of the competent authority or person authorized by the Data Subject. LSV TECH SAS only requests biometric data from its customers and employees, so in the data processing authorisation, customers and workers clearly and expressly authorise LSV TECH SAS to process sensitive data.

 

4.6 Data Processing Authorised Persons

 LSV TECH SAS, as responsible and in charge of the database, has decided to appoint within the company the positions that may consult the personal data of the Data Subjects in accordance with this Processing Policy, in order to comply with the ordinary business of our entity. For customers and suppliers, the authorized charges are:

AUTHORIZED CHARGES

GENERAL MANAGER

ADMINISTRATIVE MANAGEMENT

HUMAN TALENT

For the personal data of the entity's employees, access will be for the following positions:

 

AUTHORIZED CHARGES

GENERAL MANAGER

ADMINISTRATIVE MANAGEMENT

HUMAN TALENT

The above positions may authorize subordinate positions to access the personal database of customers and suppliers according to the role or position held.

 

4.7 Levels of protection of personal data

LSV TECH SAS has implemented two levels of personal data protection within the entity:

 

4.7.1      Permanent and Restricted Custody

Permanent and restricted custody implies continuous control of access to the Database that stores the semi-private, private and sensitive personal data of the Holders, and restricted since with the use of passwords it will be possible to know the content of the databases. Custody that will be exercised by the following Area:

AUTHORIZED CHARGES

HUMAN TALENT AND ADMINISTRATIVE AREA

For access to the Database, the persons representing the aforementioned positions may issue permanent or temporary authorization to other positions through the assignment of access keys to the Database, in order for those positions to fulfill their functions, the following positions that may be authorized are:

AUTHORIZED CHARGES

HUMAN TALENT AND ADMINISTRATIVE AREA

The persons who represent the above positions will be subject to the confidentiality agreement entered into with LSV TECH SAS , this policy and the rules that regulate, modify or add to the Protection of Personal Data, they will also refrain from disseminating, copying, commenting and any activity of written, verbal or digital disclosure about the personal data contained in the databases without prior authorization of the Owner or by order given by authority with the exception of information that must be disclosed within LSV TECH SAS for the fulfillment of the purpose of the entity.

 

4.8 Effective Date of the Personal Data Processing Policy

 The Personal Data Processing Policy of LSV TECH SAS will be effective as of its promulgation.

5. PROCESSING OF PERSONAL DATA IN THE AREA OF AUDIOVISUAL, ADVERTISING AND COMMUNICATIONS

 

 5.1 Authorisation to take images (video and photographs)

 5.1.1 Authorisation for events, facilities or areas with video surveillance

 In order to comply with the legal provisions for the processing of private data such as image, LSV TECH SAS has provided privacy notices at the entrance of auditoriums, parks and any place where events or any type of activities carried out by LSV TECH SAS are held. Therefore, at the beginning of each presentation, an informative slide, poster or any other means must be included to provide information about the capture of the image and the purposes of processing.

 Once the owner attends the events held by LSV TECH SAS , it will be understood that they authorize to be photographed or videotaped, including the attendees or guests, in which case the processing of their image will have the purpose of using said records in different means of dissemination such as television broadcasts, internet and other written publications related to the events that we promote in the development of our corporate purpose and our marketing strategy. Institutional communication aimed at bringing the company closer to the public. Given that with the presence and permanence in this event it could be part of such registrations, which is why this policy will apply.

FIRST PARAGRAPH: Authorization for the processing of private data such as images or any other type of personal data may be obtained by any means that may be subject to subsequent consultation, including a written or oral statement or through "unequivocal conduct by the owner that allows a reasonable conclusion to be drawn that the authorization has been granted."

 SECOND PARAGRAPH: LSVTECH SASis exonerated and is not responsible for the processing of data carried out by third parties attending the different events or activities carried out by LSV TECH SAS

5.1.2 Purpose of processing photos and/or images as personal data

The purpose of the audiovisual processing, and of the photos and/or images as personal data, will be used to carry out campaigns, advertising and everything related to the communications area of LSV TECH SAS for as long as it so provides, unless the owner expressly requests that the processing of their image ceases.

 5.1.3      Authorisation for particular activities

 Among the activities that LSV TECH SAS carry out are those in which third parties participate, whose image can be captured by video or photograph. The area in charge of data processing will manage the owner's authorisation for the use of their image, guaranteeing its safekeeping. It is important to mention that the image of employees, users, customers and suppliers does not require additional authorization, since LSV TECH SAS is covered in the contracts and in the commercial registration form, respectively.

 Finally, in each case, an analysis must be carried out on the image that will be kept by LSVTECH SAS., given that, if it has copyright implications, the author's consent must also be obtained to make use of it.

5.1.2 Purpose of processing photos and/or images as personal data

The purpose of the audiovisual processing, and of the photos and/or images as personal data, will be used to carry out campaigns, advertising and everything related to the communications area of LSV TECH SAS for as long as it so provides, unless the owner expressly requests that the processing of their image ceases.

 

5.1.4      Custody of the authorisation

Each area of LSV TECH SAS that actively processes personal data must ensure that the authorisation for the processing of the data is safeguarded and stored. Likewise, they must be made available to the Superintendence of Industry and Commerce or the Data Protection Officer in the event that they require it.

 

5.2 Technological and advertising media

 The owner acknowledges the existence of a closed circuit television, and that its function consists of monitoring the facilities and events carried out by the person in charge and/or in charge in order to ensure the security and harmony of the establishment in such a way that the videos of the same enjoy full authenticity and evidentiary value.

 Telephone lines, both fixed and corporate, are the exclusive property of LSV TECH SAS., which is why the company reserves the right, with the prior authorization of the owner, to record and monitor such lines in order to advocate for the improvement and quality of the service.

Prior authorization of the owner, through the means established by law for this purpose, and once the private and/or personal data has been collected by LSV TECH SAS., it will be understood that they may be used in physical and digital publications, such as: magazines, press publications, internal and external communication campaigns; physical and digital media such as BTL and ATL communication; conventional media, such as social networks, instant messaging applications; and the different means of dissemination such as television broadcasts, the Internet and other written publications related to the events we promote in the development of our corporate purpose and our institutional communication, advertising and marketing strategy.

Written articles related to the events we promote in the development of our corporate purpose and our institutional communication, advertising and marketing strategy.

6. PROCESSING OF PERSONAL DATA AND IMPLEMENTATION OF SAGRILAFT

LSV TECH SAS., in order to ensure compliance with the SELF-CONTROL AND COMPREHENSIVE RISK MANAGEMENT REGIME LA/FT/FPADM AND REPORT OF SUSPICIOUS TRANSACTIONS TO THE UIAF, and in the identification, segmentation, qualification, individualization, control and updating of risk factors and risks associated with the probability that they may be used or may be provided as a means in activities related to money laundering, In accordance with the Law on Transparency and the Right of Access to Public Information (Law 1712 of 2014), there is a principle of maximum publicity, which provides that all information consigned by an authority in restrictive lists or databases intended for the prevention of illegal activities is of a public nature because this is essential in the context of the Transparency and the Right of Access to Public Information (Law 1712 of 2014). the protection of the general interest and national security. In this sense, and as a general rule, the registers intended for the prevention of ML/TF are of a public nature.

However, the use of this data must be governed by the guiding principles of data processing, such as: Principle of legality, purpose, freedom, veracity or quality, transparency, restricted access and circulation, security, confidentiality, necessity, usefulness, integrity, incorporation and expiration.

In this sense, LSV TECH SAS, as responsible and in charge of personal data in AML/CFT matters, has the obligation to apply the aforementioned principles, despite the fact that databases for the prevention of AML/CFT are partially excluded from the general personal data protection regime.

PARAGRAPH: The owner's information may not be provided to users or third parties when it ceases to serve the purpose of the database.

7. EXERCISING THE RIGHTS OF DATA SUBJECTS

7.1 Means of dissemination so that the Owner is aware of the Privacy Notice and the processing policies

LSV TECH SAS on its website: https://lsv-tech.com/ published the Notice of Privacy and Processing Policies for the knowledge of the Holders, which can be consulted at any time of the day free of charge.

7.2 Persons or areas responsible for the care of the rights of the holders

LSV TECH SAS has designated the Board of Partners, General Manager, Deputy Manager, Deputy Commercial Manager, Deputy Project Manager, Administrative Deputy Manager, Technical Director and Head of Human Talent as the area responsible for attending to the rights of Personal Data Holders.

7.3 Procedure for holders to exercise their rights

The company has indicated the following service channels so that Account Holders can exercise their rights.

• By written communication sent to the following addresses:

Postal Mail: Calle 32 # 26 – 13 Ed. Banco Popular 702 Barrio Centro. Cartagena D.T.– COLOMBIA.

Email: Administrative Area: administrativa@lsv-tech.com

Human Talent: talentohumano@lsv-tech.com

By verbal communication to the following telephone numbers:

PBX D.C.: 679 5305.

Cell: 321 8908936

 

7.3.1      Procedure for consultations

The Data Subjects and other authorized persons may make enquiries once a month free of charge, in order to obtain the information contained in the individual record of the LSV TECH SAS Database and a copy of the respective Authorization for the Processing of Personal Data, which may be made in writing or verbally in the above service channels.

In the event that the consultation is made more than once a month, the Owner of the personal data will assume the costs corresponding to the sending of the requested information. LSV TECH SAS will keep a copy of the corresponding receipts in case of requirement from the Superintendence of Industry and Commerce.

Written and verbal enquiries must contain at least the following information:

 

• Name and identification of the Owner of personal data
•  Home address and/or e-mail address.
• Phone & Cell Numbers
• Reason for consultation: 

        – Information contained in the Database.

       – Copy of the Authorization for the Processing of Personal Data.

 

In the event that any of the above data is missing, the area responsible for the care will communicate within five (5) days following the receipt of the query to the interested party so that the missing data can be corrected, if two (2) months have elapsed since the request to the interested party and the interested party does not present a correction, the consultation will be deemed to have been withdrawn.

7.3.2      Procedure for complaintsThe Owners and other authorized persons may make claims with the aim of: correcting or updating the personal data contained in the LSV TECH SAS Database, and deleting or revoking the Authorization for the Processing of Personal Data when the contractual relationship has ended or in the cases provided for by the Personal Data Protection Law. Likewise, they may file complaints when they notice the alleged non-compliance of LSV TECH SAS with regard to the Processing of Personal Data.Written and verbal complaints must contain at least the following data:

 

• Name and identification of the Owner of personal data
•  Home address and/or e-mail address.
• Phone & Cell Numbers
• Reason for the claim:

 

✓ Correct or update the personal data contained in the LSV TECH SAS Database

✓ Delete or revoke the Authorization for the Processing of Personal Data.

✓ Claim for alleged non-compliance of LSV TECH SAS with regard to the Processing of Personal Data

✓ Facts that motivate the claim

In the event that any of the above data is missing, the area responsible for the attention will communicate within five (5) days following the receipt of the complaint to the interested party so that the missing data can be corrected, if two (2) months have elapsed since the request to the interested party and the interested party does not present a correction, the complaint will be understood to have been withdrawn. In the event that LSV TECH SAS is not competent to respond to the claim, the responsible area will be responsible for forwarding it to the appropriate party within a period of two (2) business days and will inform the Account Holder or interested party of the name of the responsible party with their respective contact details.

The area responsible for the attention to the Owner will include in the LS V TECH SAS Database in the individual record of the Owner a legend that says "claim in process" for knowledge of the charges that monitor the Base and those charges that are authorized to use the database.

7.4 Terms of Response

7.4.1      Consultations

Once the query has been received by the Account Holder or interested party, the area responsible for the service will have fifteen (15) business days from the day following receipt of the query to respond. If it is not possible to respond within the aforementioned term, the Account Holder or interested party will be informed in advance of the reasons for the delay and a new response date will be set, such date may not exceed five (5) business days following the expiration of the first term, however, if they are data which are of strict legal reserve and confidentiality such as the resources and financial statements handled by LSV TECH SAS They will only be informed by order of the competent authority specifically requesting this and the purpose for which it is being requested.

7.4.2      Complaints

Once the complaint has been received, the area responsible for the care will have fifteen (15) working days from the day following receipt of the query to respond. If it is not possible to respond within the aforementioned period, the Owner or interested party will be informed in advance of the reasons for the delay and a new response date will be set, such date may not exceed eight (8) business days following the expiration of the first term.

8. SECURITY MEASURES APPLIED TO THE PROCESSING OF PERSONAL DATA

In accordance with the principle of security established in current regulations, LSV TECH S.A. will adopt the technical, human and administrative measures that are necessary to provide security to the records, preventing their adulteration, loss, consultation, use or unauthorized or fraudulent access.

Information is protected through mechanisms that preserve its security, confidentiality, integrity and availability, using the following mechanisms:

a) To keep the information under the necessary security conditions to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access;

b) Protection of access to data through passwords and roles of different levels of authority

c) Ensuring the level of complexity of user passwords.

 

PARAGRAPH: Data transmission over the Internet or any wireless network cannot be guaranteed to be 100% secure. As a result, while we try to protect personal information, we cannot ensure or warrant infallibility in the security of our website.

any information that is transmitted to LSV TECH SAS., given that it is not exempt from computer attacks, so the owners will provide the personal data at their own risk in this regard.

The information will be processed in standardised databases and the staff who carry out the processing of the personal data will execute the established protocols in order to guarantee the security of the information.

LSV TECHNOLOGY SERVICES COLOMBIA SAS..

NIT No. 900.744.615 – 7

Warning

LSVTECH SAShereby informs that it ONLY uses emails under the domain lsv-tech.com and any other e-mail regardless of its platform, it is NOT authorized for the processing of data or personal and/or commercial information.

6. 7.3.2      Grievance ProcedureThe Owners and other authorized persons may make claims with the aim of: correcting or updating the personal data contained in the Database of LSV TECH SAS., and delete or revoke the Personal Data Processing Authorization when the contractual relationship has ended or in the cases provided for by the Personal Data Protection Law. Likewise, they may file claims when they notice the alleged breach of LSV TECH SAS Written and verbal complaints must contain at least the following information:

    

   • Name and identification of the Owner of personal data
   •  Home address and/or e-mail address.
   • Phone & Cell Numbers
   • Reason for the claim:

    

   ✓ Correct or update the personal data contained in the LSV TECH SAS Database

   ✓ Delete or revoke the Authorization for the Processing of Personal Data.

   ✓ Claim for alleged non-compliance of LSV TECH SAS with regard to the Processing of Personal Data

   ✓ Facts that motivate the claim

   In the event that any of the above data is missing, the area responsible for the attention will communicate within five (5) days following the receipt of the complaint to the interested party so that the missing data can be corrected, if two (2) months have elapsed since the request to the interested party and the interested party does not present a correction, the complaint will be understood to have been withdrawn. In the event that LSV TECH SAS is not competent to respond to the claim, the responsible area will be responsible for forwarding it to the appropriate party within a period of two (2) business days and will inform the Account Holder or interested party of the name of the responsible party with their respective contact details.

   The area responsible for the attention to the Owner will include in the LS V TECH SAS Database in the individual record of the Owner a legend that says "claim in process" for knowledge of the charges that monitor the Base and those charges that are authorized to use the database.

   7.4 Terms of Response

   7.4.1      Consultations

   Once the query has been received by the Account Holder or interested party, the area responsible for the service will have fifteen (15) business days from the day following receipt of the query to respond. If it is not possible to respond within the aforementioned term, the Account Holder or interested party will be informed in advance of the reasons for the delay and a new response date will be set, such date may not exceed five (5) business days following the expiration of the first term, however, if they are data which are of strict legal reserve and confidentiality such as the resources and financial statements handled by LSV TECH SAS They will only be informed by order of the competent authority specifically requesting this and the purpose for which it is being requested.

   7.4.2      Complaints

   Once the complaint has been received, the area responsible for the care will have fifteen (15) working days from the day following receipt of the query to respond. If it is not possible to respond within the aforementioned period, the Owner or interested party will be informed in advance of the reasons for the delay and a new response date will be set, such date may not exceed eight (8) business days following the expiration of the first term.

   8. SECURITY MEASURES APPLIED TO THE PROCESSING OF PERSONAL DATA

   In accordance with the principle of security established in current regulations, LSV TECH S.A. will adopt the technical, human and administrative measures that are necessary to provide security to the records, preventing their adulteration, loss, consultation, use or unauthorized or fraudulent access.

   Information is protected through mechanisms that preserve its security, confidentiality, integrity and availability, using the following mechanisms:

   a) To keep the information under the necessary security conditions to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access;

b) Protection of access to data through passwords and roles of different levels of authority

c) Ensuring the level of complexity of user passwords.

 

PARAGRAPH: Data transmission over the Internet or any wireless network cannot be guaranteed to be 100% secure. As a result, while we try to protect personal information, we cannot ensure or warrant infallibility in the security of our website.

any information that is transmitted to LSV TECH SAS., given that it is not exempt from computer attacks, so the owners will provide the personal data at their own risk in this regard.

The information will be processed in standardised databases and the staff who carry out the processing of the personal data will execute the established protocols in order to guarantee the security of the information.

LSV TECHNOLOGY SERVICES COLOMBIA SAS..

NIT No. 900.744.615 – 7

Warning

LSVTECH SAShereby informs that it ONLY uses emails under the domain lsv-tech.com and any other e-mail regardless of its platform, it is NOT authorized for the processing of data or personal and/or commercial information.

 

GMANAGEMENT OF CHANGE.