Data Processing Policy

ROYALTY WORLD INC SAS
NIT. 900.918.489-3

DATA PROCESSING POLICY

LEGAL REGULATIONS AND SCOPE OF APPLICATION
In accordance with the provisions of Law 1581 of 2012, Regulatory Decrees 1377 of 2013 and 886 of 2014 immersed in the single Decree 1074 of 2015 Chapters 25 and 26 and complementary provisions; the entity ROYALTY WORLD INC SAS, is obliged to generate internal policies for the processing of personal data, including the following aspects:

  • Collection, storage, use, circulation, deletion and final disposal of personal data, as well as obtaining authorization to manage them.
  • Access, correction, conservation and elimination of personal information.
  • Responsible, appropriate use, under standards and security protocols of the use and storage of information.
  • Generate a portal or space for complaints, complaints and claims (PQRs)

The above proposing a scheme of transparency and protection of personal data.

OBJETIVE

This policy provides general parameters for the proper handling of the processing of personal data complying with legal requirements and mandatory compliance for the company ROYALTY WORLD INC SAS.

DEFINITIONS

For the purposes of executing this policy correctly and based on the current regulations, the following definitions will be applied:

Authorization: Prior, express and informed consent of the Holder to carry out the processing of personal data.
Database: Organized set of personal data that is subject to treatment.
Owner: Natural or legal person whose personal data are subject to treatment.
Treatment: Any operation or set of operations on personal data,
such as collection, storage, use, circulation or deletion.

Personal data: Any information linked to or associated with one or more determined or determinable natural persons.
Public Data: It is the data that is not semi-private, private or sensitive. They are considered public data, among others, data relating to the civil status of persons, their profession or trade and its quality as a merchant or public servant. By its nature, public data may be contained, between others, in public registers, public documents, gazettes and official bulletins and judicial sentences duly executed that are not subject to reservation.
Sensitive data: Those that affect the privacy of the owner or whose improper use can generate their 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 promotes interests of any kind political party or that guarantee the rights and guarantees of political parties of opposition as well as data related to health, sexual life and biometric data.
Transparency: It takes place when the person in charge and / or in charge of the treatment 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 the country.
Responsible for the Treatment: Natural or legal person, public or private, which by itself same or in association with others, perform the processing of personal data on behalf of the responsible for the Treatment.
Responsible for the Treatment: Natural or legal person, public or private, which by itself or in association with others, decide on the basis of data and / or the treatment of data.
Data Protection: The official within the entity ROYALTY WORLD INC SAS, whose function is to monitor, control and monitor the application of this policy and report any incident or violation of personal data

PRINCIPLES APPLICABLE TO DATA PROCESSING

ROYALTY WORLD INC SAS, will fully apply the following principles that are guidelines to follow for the collection, treatment, use, storage, circulation, deletion and final disposal of personal data:

Legality in data processing: The treatment of personal data regulated and subject to the provisions of Law 1581 of 2012 in Decree 1377 of 2013 and the other provisions.

Purpose: To obey a legitimate purpose in accordance with the Constitution and the Law, which must be informed to the Holder.

Freedom: The Treatment can only be exercised with the prior, express and informed consent of the Holder. Personal data may not be obtained or disclosed without prior authorization, or in the absence of legal or judicial mandate that relieves consent.

Veracity or quality: The information subject to Treatment must be truthful, complete, accurate, updated, verifiable and understandable. The processing of partial, incomplete, fractioned or misleading data is prohibited.

Transparency: In the Treatment must guarantee the right of the Owner to obtain from the person responsible for the Treatment or the Person in Charge of the Treatment, at any time and without restrictions, information about the existence of data concerning him.

Access and restricted circulation: The Treatment is subject to the limits that derive from the nature of personal data, the provisions of the law and the Constitution. In this sense, the Treatment can only be done by persons authorized by the Holder and / or by the persons provided for in this law.

Personal data, except public information, may not be available on the Internet or other means of dissemination or mass communication, unless the access is technically controllable to provide restricted knowledge only to the Holders or authorized third parties in accordance with this law.

Security: The information subject to Treatment by the person in charge of the Treatment or in charge of the Treatment, must be handled with the technical, human and administrative measures that are necessary to grant security to the records avoiding their adulteration, loss, consultation, use or unauthorized access or fraudulent;

Confidentiality: All persons involved in the processing of personal data that do not have the nature of public are obliged to guarantee the reservation of information, even after the end of their relationship with any of the tasks involved in the treatment, being able to only supply or communication of personal data when this corresponds to the development of the activities authorized in this law and in the terms thereof.

TREATMENT OF DATABASE CLASSIFICATION

ROYALTY WORLD INC SAS classified its databases in the following way.

Workers Database
Manual and automated database containing data of natural persons linked directly to ROYALTY WORLD INC SAS, complying with the legal and regulatory provisions. In this database, private, public, sensitive and minor information is incorporated. The treatment of these data for purposes other than the obligations arising from the employment relationship, will require prior authorization from the Owner or Legal Representative of our entity.

Database of Contractors and Suppliers
Manual and automated databases that contain data of Natural and Legal persons who maintain a contractual or commercial link with ROYALTY WORLD INC SAS, complying with the legal and regulatory provisions. In this database, private, public, sensitive and minor information is incorporated. The treatment of these data for purposes other than the maintenance of the contractual or commercial relationship requires the Holder’s authorization.

Customer database
Manual and automated databases that contain data of Natural and Legal persons who maintain a contractual or commercial link with ROYALTY WORLD INC SAS, complying with the legal and regulatory provisions. In this database, private, public, sensitive and minor information is incorporated. The treatment of these data for purposes other than the maintenance of the contractual or commercial relationship requires the Holder’s authorization.

APPLICATION FOR AUTHORIZATION TO PERSONAL DATA HOLDER

ROYALTY WORLD INC SAS, responsible for Data Processing, adopts procedures to request the Holder authorization with free consent to the processing of their personal information and inform them of the data that will be collected and the purpose of the treatment. This procedure will be done; a) in writing b) verbally c) electronic; Exceptions in cases expressly authorized by law, such as: Information required by a public or administrative entity in the exercise of its legal functions or by court order, public data, cases of medical or sanitary emergency, treatment of information authorized by the law for historical, statistical or scientific purposes and data related to the Civil Registry of Persons.

PURPOSE OF DATA PROCESSING

The authorization for the processing of personal data allows ROYALTY WORLD INC SAS to collect, store, use, circulate, delete, update and transmit in order to allow an adequate development of its corporate purpose and keep the necessary information to comply with duties. legal, mainly accounting, corporate and labor.

With the information collected, ROYALTY WORLD INC SAS can perform activities, sales, billing, collection management, collection, programming, technical support, service improvement, verification and consultation, control, behavior, fraud prevention, send to physical, electronic mail, cellular or mobile device, via text messages (SMS and / or MMS) or through any other analogous and / or digital means of communication created or to be created, commercial, advertising or promotional information about the products and / or services, events and / or promotions of commercial type or not of these, to develop the process of selection, evaluation, and labor linkage, to support internal or external audit processes; register the information of employees and / or pensioners (active and inactive), supply, share, send or deliver your personal data to subsidiaries, affiliated companies, or subordinates of ROYALTY WORLD INC SAS located in Colombia or any other country in the event said companies require the information for the purposes indicated here.

RIGHT OF PERSONAL DATA HOLDERS

The Holders whose data are subject to treatment by ROYALTY WORLD INC SAS and who, in accordance with the provisions of article 8 of law 1581 of 2012, may:

to. Know, update and rectify your personal data in front of the ROYALTY WORLD INC SAS or the Data Handlers. This right may be exercised, among others, against partial, inaccurate, incomplete, fractioned, error-inducing data, or those whose Treatment is expressly prohibited or has not been authorized.

b. Request proof of the authorization granted to ROYALTY WORLD INC SAS, unless expressly excepted as a requirement for the Treatment.

c. Be informed by ROYALTY WORLD INC SAS or the Manager, upon request, regarding the use of your personal data.

d. Submit to the Superintendency of Industry and Commerce complaints for infractions of the provisions of the Data Protection Act and other regulations that modify, add or supplement.

and. Revoke the authorization and / or request the deletion of the data when the Treatment 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 ROYALTY WORLD INC SAS or the Person in Charge has incurred in conducts contrary to the Law of Data Protection and other norms that modify, add or complement it.

F. Access free of charge to your personal data that has been subject to Treatment by ROYALTY WORLD INC SAS.

DUTIES OF THE PERSON RESPONSIBLE FOR THE DATABASE TREATMENT

ROYALTY WORLD INC SAS, acting as responsible party in the processing of personal data must:

to. Guarantee the holder, at all times, the full and effective exercise of the right of habeas data.

b. Request and keep a copy of the respective authorization granted by the owner, for the use and treatment of personal data.

c. Inform the Holder properly about the purpose of the collection and the rights that assist him, by virtue of the authorization granted.

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

and. Ensure that the information provided to the person in charge of processing is truthful, complete, accurate, updated, verifiable and understandable.

F. Update the information, communicating in a timely manner to the person in charge of processing, all the news regarding the data previously provided and adopt the other necessary measures so that the information provided to the latter is kept up-to-date.

g. Rectify the information when it is incorrect and communicate the pertinent to the person in charge of the treatment.

h. Provide the data processor, according to the case, only data whose treatment is previously authorized.

i. Process the queries and claims made.

j. Allow access to information only to people who can access it.

k. Inform at the request of the owner about the use given to their data.

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

AREA RESPONSIBLE FOR DATA PROCESSING AND ITS IMPLEMENTATION.

The Human Resources department of ROYALTY WORLD INC SAS is responsible for implementing, training and monitoring this Data Processing policy. Therefore, all officers of this company, are required to report their databases to the area immediately.

Next, identification of the person responsible in the Data Processing is related to the Manager or Legal Representative of the Company.

SOCIAL REASON: ROYALTY WORLD INC SAS
NIT: 900.087.605-4
ADDRESS: STREET 140 NO 12B 35 OFFICE 202
PBX: 308 3686
EMAIL: [email protected]

PROCEDURE FOR THE APPLICATION, RESPONSE OF PETITIONS, COMPLAINTS, CLAIMS AND CONSULTATION OF PERSONAL DATA.

The Personal Data Owners treated by ROYALTY WORLD INC SAS, have the right to access their Personal Data and the details of said Treatment, as well as to correct and update them if they are inaccurate or to request their elimination when they consider them to be excessive or unnecessary. for the purposes that justified their obtaining or opposing the Treatment of the same for specific purposes.
The way they have been implemented to guarantee the exercise of these rights, is by sending an email to the address [email protected] Or sent physical communication to the address: Cra 43 A # 5 A 113, Office 808.

to. Presentation, update and answer of queries: The Holders of the personal data that repose in the databases of ROYALTY WORLD INC SAS, will be able to consult the data that will supply the information in the terms foreseen in the applicable legislation. Any request for consultation, correction, updating or deletion must be submitted in writing or by email, in accordance with the information contained in this document.
The consultations will be attended within a term of ten (10) business days from the date of receipt of the respective request. When it is not possible to attend the consultation within said term, the interested party will be informed, stating the reasons for the delay and stating the date on which the consultation will be attended, which in no case may exceed five (5) business days following the expiration of the first term.

b. Claims and complaints: The Holders of the Personal Data will make their claim or complaint in writing or by email according to the information included in this document, and must contain the following information:

  • Identification of the Holder
  • Description of the facts that give rise to the claim
  • Address of the owner
  • Documentation that you want to present as proof

With the above information ROYALTY WORLD INC SAS will review whether the claim is complete or incomplete; if 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 request, without the applicant submitting the required information, it shall be understood that the claim has been abandoned.

In the event that the person receiving the claim is not competent to resolve it, it will notify the person concerned within a maximum period of two (2) business days and inform the interested party of the situation. Once the complete claim has been received, a legend that says “claim in process” and the reason thereof will be included in the database, in a term not exceeding two (2) business days. This legend must be maintained until the claim is solved.

The maximum term to attend the claim will be fifteen (15) business days counted from the day following the date of receipt. When it is not possible to address the claim within said term, the interested party will be informed of the reasons for the delay and the date on which his claim will be handled, which in no case may exceed eight (8) business days following the expiration.

VALIDITY

The Present Data Processing Policy of the Company ROYALTY WORLD INC SAS, is effective as of June 1, 2017.

ROYALTY WORLD INC SAS, may make modifications to the Data Processing Policy based on the efforts to comply with the obligations established by Law 1581 of 2012, regulatory decrees and other regulations that complement, repeal or modify the content of this document.

Therefore, any modification will be communicated and published through our email and at the ROYALTY WORLD INC SAS facilities.

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