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Privacy Policy

Personal information processing policy

In compliance with the provisions contained in article 15 of the Political Constitution, Law 1581 of 2012, Regulatory Decree 1377 of 2013, and other regulations that modify, add, complement or develop it, the company Padova SAS, hereinafter PADOVA SAS, is committed With respect and guarantee of the rights of its clients, suppliers, employees and third parties in general, it announces the policies and procedures for the processing of personal data that are stored and guarded in our database, which are mandatory. in all activities that involve, totally or partially, the collection, storage, use, circulation and/or transfer of said information.

This Personal Information Processing Policy is mandatory for Padova SAS, as manager, as well as for all allied companies, subsidiaries or that are part of its business group.

Legal framework

This Personal Information Treatment Policy has its regulatory basis in Article 15 of the Political Constitution, in Law 1581 of 2012, Regulatory Decree 1377 of 2013, which provide:

  • Political Constitution, Article 15. “All people have the right to their personal and family privacy and to their good name, and the State must respect them and ensure they are respected. Likewise, they have the right to know, update and rectify the information that has been collected about them in data banks and in files of public and private entities.

In the collection, processing and circulation of data, freedom and other guarantees enshrined in the Constitution will be respected.

Correspondence and other forms of private communication are inviolable. They can only be intercepted or recorded by court order, in the cases and with the formalities established by law.

For tax or judicial purposes and for cases of inspection, surveillance and intervention of the State, the presentation of accounting books and other private documents may be required, in the terms established by law.”

  • Statutory Law 1581 of 2012 “By which general provisions are issued for the protection of personal data.”
  • Regulatory Decree 1377 of 2013 “By which Law 1581 of 2012 is partially regulated.”

GENERAL INFORMATION ABOUT PADOVA SAS, AS PROCESSOR OF PERSONAL DATA PROCESSING

Company name: PADOVA SAS

NIT: 900.958.501-5

Address: Cali, Valle del Cauca, Colombia

Telephone: 3744007

Email: atencioncliente@padova.com.co

Website: www.pepapombo.com

Purpose of the personal data processing policy

The purpose of the Personal Data Processing Policy is to develop and make known to the general public the corporate and legal guidelines under which PADOVA SAS processes personal data, the purpose of the treatment, the rights that assist the users. holders, as well as the internal and external procedures that exist for the exercise of such rights before PADOVA SAS, among others.

Legal definitions

For the purposes of the execution of this policy and in accordance with legal regulations, the following definitions will be applicable:

-Authorization: Prior, express and informed consent of the Owner to carry out the Processing of personal data;

-Database: Organized set of personal data that is subject to processing;

-Holder: Natural person whose personal data is the subject of Processing, whether client, supplier, employee, or any third party who, due to a commercial or legal relationship, provides personal data to PADOVA SAS;

-Processing: Any operation or set of operations on personal data, such as collection, storage, use, circulation or deletion;

-Personal data: Any information linked or that can be associated with one or several specific or determinable natural persons;

-Public data: It is data that is not semi-private, private or sensitive. Public data are considered, among others, data relating to the marital status of people, their profession or trade, and their status as a merchant or public servant. Due to its nature, public data may be contained, among others, in public records, public documents, official gazettes and bulletins and duly executed judicial rulings that are not subject to confidentiality;

-Sensitive data: Sensitive data is understood to be data that affects the privacy of the Owner or whose improper use may generate discrimination, such as data that reveals racial or ethnic origin, political orientation, religious or philosophical convictions, membership in 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;

-Transfer: The transfer of data takes place when the Controller and/or Processor of personal data, located in Colombia, sends the information or personal data to a recipient, who in turn is Responsible for the Treatment and is located within or outside the country;

-Transmission: Processing of personal data that involves the communication of the same within or outside the territory of the Republic of Colombia when its purpose is to carry out a Processing by the Processor on behalf of the Controller.

When a term used is defined in this Information Processing Policy, reference will be made to that definition. Likewise, when a term used is not expressly defined in this document or in the applicable Law, the literal meaning of the stipulations will apply, provided that such interpretation is consistent with the purpose of the Information Processing Policy.

Principles that govern the actions of confections and investments Pepa SA in the processing of personal data

The principles that govern the Processing of Personal Data by PADOVA SAS are the following:

-Principle of legality: the Processing of personal data is a regulated activity that must be subject to the provisions of Law 1581 of 2012, Decree 1377 of 2013 and the other provisions that develop them.

-Principle of purpose: The purpose of the Treatment must be legitimate, and informed to the owner.

-Principle of reasonable limit: The storage and processing of personal data will be limited to what is essentially necessary to fulfill the previously specified purposes of the business relationship, as well as the fulfillment of the purposes authorized by the Owner.

-Principle of freedom: personal data can only be processed with the prior, express and informed consent of the Owner or by legal or judicial mandate.

-Principle of truthfulness: the information must be true, complete, accurate, updated, verifiable and understandable.

-Principle of transparency: the right of the Owner to obtain information about their personal data whose Processing is carried out by PADOVA SAS must be guaranteed.

-Principle of Access and restricted circulation: Treatment may only be carried out by persons authorized by the Owner or by the persons provided for in the Law.

-Principle of Security: the information must be managed with the necessary measures to provide security to the records and prevent their adulteration, loss, consultation, use or unauthorized or fraudulent access.

-Principle of Confidentiality: personal data that is not public in nature is reserved and can only be provided in the terms of the Law.

-Principle of Systematic Incorporation: the principles of Personal Data Protection will be implemented in all processes and procedures of the commercial activity of PADOVA SAS

Rights that assist the owners of personal data

Know, update and rectify your personal data with those responsible for the Treatment or Data Processors. This right may be exercised, among others, against partial, inaccurate, incomplete, fragmented, misleading data, or those whose Processing is expressly prohibited or has not been authorized;

Request proof of the authorization granted to the Data Controller except when it is expressly excepted as a requirement for the Treatment, in accordance with the provisions of article 10 of this law;

Be informed by the Data Controller or Data Processor, upon request, regarding the use that has been given to your personal data;

Submit complaints to the Superintendency of Industry and Commerce for violations of the provisions of this law and other regulations that modify, add or complement it;

Revoke the authorization and/or request the deletion of the data when the processing does not respect constitutional and legal principles, rights and guarantees. The revocation and/or deletion will proceed when the Superintendence of Industry and Commerce has determined that in the Treatment the Controller or Processor has engaged in conduct contrary to this law and the Constitution;

Free access to your personal data that has been processed.

Authorization for the processing of personal data

PADOVA SAS, acting as Data Controller, has adopted procedures to request, no later than at the time of collection of your personal data, your authorization for the Processing thereof and inform you of the personal data that will be collected as well as all the specific purposes of the Treatment for which your consent is obtained.

It will be understood that the Owner has granted PADOVA SAS Authorization for the Processing of their personal data when this is expressed: (i) in writing; (ii) orally; or (iii) through unequivocal conduct of the Owner that allows it to be reasonably concluded that he granted PADOVA SAS the respective authorization. In no case will silence be understood as unequivocal behavior.

Notwithstanding the foregoing, the authorization of the Owner will not be necessary when it comes to: (i) Information required by a public or administrative entity in the exercise of its legal functions or by court order; (ii) Data of a public nature; (iii) Cases of medical or health emergency; (iv) Processing of information authorized by law for historical, statistical or scientific purposes; and (v) Data related to the Civil Registry of Persons.

Revocation of authorization and/or deletion of data

The Owner of the personal data may at any time request PADOVA SAS, as Controller, to delete their personal data and/or revoke the authorization that has been granted for the Treatment thereof, by submitting a claim, in accordance with the provisions of article 15 of Law 1581 of 2012.

Notwithstanding the above, we warn that the request to delete the information and/or revoke the authorization will not proceed when, as the Owner of the personal data, you have a legal or contractual duty by virtue of which it must remain in the PADOVA database. SAS

Purpose of processing personal data

PADOVA SAS will process personal data for the following purposes:

Carry out, through any means, directly or through third parties, marketing activities, promotion and/or advertising of our own or of third parties, sales, billing, collection management, collection, programming, technical support, market intelligence, improvement of the service, verifications and queries, control, behavior, habit and enabling of payment methods, fraud prevention, as well as any other related to our products and services, current and future, for the fulfillment of contractual obligations and our corporate purpose.

Generate optimal communication in relation to our services, products, promotions, billing and other activities.

Evaluate the quality of our products and services and carry out studies on consumer habits, preference, purchase interest, product testing, concept, service evaluation, satisfaction and others related to our services and products.

Provide assistance, service and technical support for our products and services.

Carry out the necessary steps to comply with the obligations inherent to the services provided by PADOVA SAS.

Comply with the obligations contracted with our clients, allies, users, suppliers, their subsidiaries, distributors, subcontractors and other people directly or indirectly related to the corporate purpose of PADOVA SAS

Control and prevent fraud in all its forms.

Procedure for handling requests and queries related to personal information

The Owner of the personal data or whoever is duly authorized may:

Formulate requests and queries to know the personal information of the Owner that resides in PADOVA SAS

Request the update, modification, rectification or deletion of the Owner's data, when applicable in accordance with this Policy and the applicable Law.

Request a copy of the authorization granted by the Owner to PADOVA SAS to carry out the Processing of your Personal Data. These consultations can be made free of charge at least once every calendar month and each time there are substantial modifications to the Information Processing Policies that motivate new consultations. The Owner or whoever is authorized to do so may make inquiries to PADOVA SAS about the Owner's personal information through the following mechanisms:

By written means, addressed to the following address: Calle 19 # 1 -30 Cali, Valle del Cauca, Colombia.

Email to the address: atencioncliente@padova.com.co. The query will be answered within a maximum period of ten (15) business days from the date of receipt. When it is not possible to attend to the query within the aforementioned term, PADOVA SAS will inform the interested party, expressing the reasons and indicating the date on which their query will be attended, no later than within five (5) business days following the expiration of the foreground.

Procedure for handling complaints and revoking authorization for the processing of personal data

Through this procedure, the Owner or whoever is duly authorized may:

Revoke Authorization for Data Processing.

Submit complaints when you consider that there is an alleged breach of the duties of PADOVA SAS related to the Processing of Personal Data, in accordance with the provisions of these Policies or the Personal Data Protection Law.

Revocation of the Owner's Authorization for the Processing of Personal Data.

The Owner may revoke the authorization and request the deletion of their data in the following events:

By unilateral, free and voluntary decision of the Owner of the Personal Data, when there is no legal or contractual obligation that imposes on the Owner the duty to remain in the database; and

When the constitutional and legal principles, rights and guarantees are not respected, as long as the Superintendency of Industry and Commerce has determined that in the Treatment the Controller or Processor has engaged in conduct contrary to the regulations. The foregoing, without prejudice to the rules that PADOVA SAS must observe regarding document retention to comply with formal obligations. Consequently, PADOVA SAS will delete the data or suspend its use when necessary, respecting the rules on documentary conservation that apply to it.

The procedure for handling complaints about the Owner's personal data is as follows:

The Owner or whoever is duly authorized to do so may make claims to PADOVA S.AS. in relation to the Processing of your Personal Data, in the following events:

When you consider that the Owner's information contained in a database must be corrected, updated or deleted; o When you notice the alleged breach of any of the duties contained in the Data Protection Law.

The formulation of claims must be made through any of the following service channels:

By written means, addressed to the following address: Calle 19 # 1 – 30, Cali, Valle del Cauca, Colombia.; Email to the address: atencioncliente@padova.com.co

The claim presented by the Owner or by the person authorized to do so, must contain at least the following: (i) Identification of the Owner of the Personal Data; (ii) Description of the facts that give rise to the claim; (iii) Contact information and location of the Owner of the Personal Data (Address, telephone, cell phone, email, etc.); and (iv) The documents or evidence that support your claim. If the above information is not available, it will be understood that the claim is not complete.

If the claim is incomplete, PADOVA SAS will ask the interested party to correct the deficiencies or send the information or documentation required within five (5) business days following receipt of the claim by PADOVA SAS Two (2) months have elapsed since the date of the request, without the applicant presenting the required information, it will be understood that the claim has been abandoned and it will be filed.

PADOVA SAS has a period of fifteen (15) business days to address the claim, counted from the business day following the date of receipt at PADOVA SAS.

When it is not possible to address the claim within the aforementioned term, PADOVA SAS will inform the interested party of the reasons for the delay and the date on which their claim will be addressed, which may not exceed eight (8) business days following the expiration of the first term.

Area responsible for handling requests, queries and complaints

The Customer Service area of ​​PADOVA SAS is responsible for receiving requests, queries and claims from the Owner of Personal Data related to their rights to know, update, rectify and delete Personal Data and revoke the Authorization. Likewise, the Customer Service area will ensure the timely and appropriate response issued by each of the areas of PADOVA SAS to the requests, queries and claims of the Data Owners.

Validity of the personal information processing policy

This personal information processing policy applies as of October 5, 2020 and until such time as it is expressly revoked or modified.