PERSONAL DATA PROTECTION AND PRIVACY POLICY OF ADN SOFTWARE SAS

1. GENERAL AND IDENTIFICATION OF THE PERSON RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA

ADN SOFTWARE SAS located in Medellín, Colombia.  Would like to inform that it has kept in its data bases information about its suppliers, contractors, employees, temporary staff and clients, among others (hereinafter referred to as Holders); the personal data has been provided by the users through different means or mechanisms. In compliance with the current legal provisions on the protection of personal data, ADN SOFTWARE hereby expresses the terms and conditions of the treatment and administration of the data, its privacy policy, and the procedures for data holders to exercise their rights. established under the laws of protection of personal data in Colombia.

In accordance with the above, and with our interest in protecting privacy in the development of your rights to access, have knowledge of, modify, update, rectify, delete and / or revoke your personal data.

2. ABOUT YOUR PERSONAL DATA

In the development of the principles of finality and freedom, the collection of the data made  by our company will be limited to that personal data that is relevant and suitable for the purpose for which it is collected or required in accordance with the regulations in force.

3. INFORMATION SECURITY

ADN SOFTWARE takes all reasonable precautions and measures from a technical, administrative and organizational nature to ensure the security of personal data of the users, mainly those intended to prevent alteration, loss and treatment or unauthorized access. The application of security measures is intended to ensure the preservation, confidentiality, integrity, and availability of data.

4. STORAGE OF YOUR PERSONAL DATA

ADN SOFTWARE will request the the data owners they deem necessary for the development of their corporate objectives, as well as those required by national regulations. In some cases, you may request additional and sensitive information which will be freely and voluntarily delivered by the data holder. The personal data provided by our users will be stored in a database that for greater security is found on a server or manually, both instruments rest in a safe place, are physically protected and only authorized personnel can access to them and therefore to the personal data of our users.

5. PURPOSE OF DATA PROCESSING

The information provided by our users is required to be collected, stored, used, processed, circulated, shared, reproduced, adapted, extracted, synthesized, processed with or without the help of technology for the following purposes:

a) Maintain a direct communication for the hiring of its services.
b) Creation and development of businesses and business management.
c) Maintain direct communication in the development of projects under contract.
d) Sending invitations, correspondence, gifts, and any other business courtesies.
e) Referrals for market research, in order to measure the quality of our services and their constant improvement.
f) Keep the information updated for EPS, ARL, Compensation Funds, Pension Funds, etc.
g) Sending certifications, summons to company employees. That is, with administrative, commercial and advertising purposes that allow us to develop our corporate objective.

6. KNOWLEDGE, UPDATING AND RECTIFICATION OF PERSONAL INFORMATION OF USERS

At any time, the users may request ADN SOFTWARE the one responsible for personal data, to provide information about the data, to update it, to rectify it, and may include new data if desired, delete it or exclude it from the database, unless, the data is absolutely necessary for the provision of the service to which it is registered and wants to remain in it, otherwise it will be removed and / or deactivated.

7. RIGHTS OF THE PERSONAL DATA HOLDER

The users are informed of the rights that are offered on the laws of the protection of personal data as listed below:

  • Have knowledge of, update and rectify your personal data in front of those responsible for the handling or in charge of the handling. This right may be exercised, among others, against partial, inaccurate, incomplete, fragmented, misleading data, or those whose treatment is expressly prohibited or has not been authorized.
  • Request proof of the authorization granted to the person responsible for the handling, except when expressly excepted as a requisite for the treatment, in accordance with the provisions of the legislation.
  • To be informed by the controller or the person in charge of the handling, upon request, regarding the use he has given to his or her personal data.
  • Present before the Superintendent of Industry and Commerce, or any entity in charge of complaints for infractions to the provisions of this law and the other regulations that modify, add or complement it.
  • Revoke the authorization and / or request the deletion of the data when the handling does not respect the principles, rights and constitutional and legal guarantees. The revocation and / or suppression will proceed when the Superintendent of Industry and Commerce has determined that in the handling the person in charge or in charge has partaken in conducts contrary to this law and the constitution.
  • Access free of charge to your personal data when it has been processed.

8. MODIFICATIONS TO THE PRIVACY POLICY:

ADN SOFTWARE reserves the right to modify its privacy policy and the processing of personal data at any time and in a unilateral manner. Any change will be published and announced; however, previous versions of this Privacy Policy and personal data protection will be retained. The continuous use of the services or not dissociation of the same by the owner, after notification of the new privacy policy, constitutes the acceptance of it.

9. VALIDITY OF THE PERSONAL DATA PROCESSING AUTHORIZATION:

The user accepts and acknowledges that this authorization will be valid from the moment it was accepted and during that time ADN SOFTWARE exercises the activities of its corporate objectives.

10. ATTENTION OF CONSULTATIONS AND CLAIMS

For the attention of queries, claims, complaints or for the exercise of the rights of the users, you may contact ADN SOFTWARE at contacto@adnsoftware.com.co or file your query or claim at the main ADN SOFTWARE office, located at 32F street # 81 – 38, Medellin, Colombia; the petitioner will be given an answer within the terms established by law in the case of inquiries and complaints, respectively; for this purpose, the request must contain all the necessary data and applicable to the right of petition to guarantee the timely and effective response. In addition, it must contain a clear and precise description of the personal data with respect to which the user seeks to exercise any of the rights.

Every request, to be processed, must be presented by the Holder or by his legal representative; therefore, ADN SOFTWARE reserves the right to verify the identity of the petitioner by any means. Regardless of the mechanism used for the filing of requests for consultation, they will be handled according to the terms of the law.

Requests to update, correct, rectify or delete the data will be answered within the terms indicated by law. When it is not possible to attend it within said term, the interested party will be informed before the expiration of said period of time of the reasons for the delay and the date on which his claim will be handled, as established by the rules for these requests.

11. SENSITIVE DATA

It is the data that affects the privacy of the user or whose misuse can generate discrimination, such as those that reveal racial or ethnic origin, political orientation, religious or philosophical beliefs, membership of unions, social organizations, human rights or that promotes the interests of any political party or that guarantees the rights and guarantees of opposition political parties as well as data related to health, sex life and orientation and biometric data.

The handling of sensitive data is prohibited, except when due to legal requirements or due to the legal exercise of the running of business activities, and when one or more of the following requirements are exhausted:

a) The user has given his or her explicit authorization to said handling, except in the cases that by law, the granting of said authorization is not required.

b) The Treatment is necessary to safeguard the vital interests of the user and should he or she be physically or legally incapacitated. In these events, legal representatives must grant their authorization.

c) The Treatment is carried out in the course of legitimate activities and with due guarantees by a foundation, NGO, association or any other non-profit organization, whose purpose is political, philosophical, religious or union, provided that it refers exclusively to its members or to people who maintain regular contact because of their purpose. In these events, the data can not be provided to third parties without the authorization of the user.

d) The handling refers to data that is necessary for the recognition, exercise or defense of a right in a judicial process.

e) The handling has a historical, statistical or scientific purpose. In this event, the measures leading to the suppression of identity of the users must be adopted.

In the handling of sensitive personal data, when said handling is possible according to the exceptions cited above contained in the law and concordant norms, the following obligations must be fulfilled:

1. Inform the user that because it is sensitive data, he or she is not required to authorize its handling.

2. To inform the user explicitly and in advance, in addition to the general requirements of the authorization for the collection of any type of personal data, which of the data that will be subject to handling that is sensitive and the purpose of the handling, as well as obtaining its express consent

Rights of children and adolescents

In the handling, respect for the prevailing rights of children and adolescents will be ensured. The processing of personal data of children and adolescents is prohibited, except for those data that are of a public nature, and when the law allows it for the purpose of the development and effectiveness of their rights.