The policies outlined below apply to the Processing of Personal Data controlled by Team Foods Colombia S.A. and / or Grasas S.A. (hereinafter referred to as “the Companies”), regarding customer, supplier, employee and general third party Personal Data.
Article 1 Applicable regulations: This Policy is governed by the considerations set forth under articles 15 and 20 of the Political Constitution of Colombia, Law 1581 of 2012 “By which the general provisions for personal data protection are outlined”, and SECTION 25 of Decree 1074 of 2015 “By which Law 1581 of 2012 is partially regulated”.
Article 2. Scope of Application: This Policy shall apply to Personal Data managed by the Companies and which are subject to Data Processing.
Article 3. Purpose: The purpose of this Policy is to comply with the obligations stipulated under literal k) Article 17 of Law 1581, 2012, as well as regulating the procedures for collection, handling and processing of Personal Data collected by the the Companies.
Article 4. Contact Information: Team Foods Colombia S.A. is domiciled at Calle 45a Sur No. 56 – 21, Bogota D.C., Colombia and may be contacted at the aforementioned address or email firstname.lastname@example.org
Article 5. Definition: For the purposes of this Processing of Personal Data Policy, it shall be defined as:
Authorization: Prior, explicit and informed consent of the Holder of the Personal Data to execute the
Processing of Personal Data.
Database: Organized set of Personal Data subject to processing .
Personal Data: Any information that may be associated with one or more specific or determinable natural persons. Some examples of Personal Data are as follows: name, citizenship ID details, address, email, telephone number, marital status, health related data, fingerprint, salary, assets, among others.
Public Personal Data: Refers to Personal Data which is not Semi-Private, Private or Sensitive in nature.
Public data, among others, is data concerning people’s marital status, their profession or trade and their commercial/trading status or public employee.
Private Personal Data: Refers to data, which due to its intimate or reserved nature, is only relevant to Holder of the same.
Semi-private Personal Data: Personal Data which is not intimate, reserved, nor public in nature and which information or disclosure may be of interest not only to its Holder but also to a certain segment or group of people or to society in general, for example, the compliance and non-compliance with financial obligations or data concerning affiliations with the social security system.
Sensitive Personal Data: Information which involves the privacy of the Holder or which improper use may produce discrimination, such as racial or ethnic origin, political orientation, religious or philosophical convictions, membership of unions, social organizations, human rights or the promoting interests of any political party or which guarantees the rights and opposition of political parties as well as data related to health, sexual life and biometric data, among others; capture of images or images in movement, fingerprints, photographs, iris, voice, facial or palm recognition, among others.
Responsible for the Processing : Natural person or company, public or private, independently or in association with others, perform the Processing of Personal Data on behalf of the Responsible Party .
Claim: Request from the Holder of the Data or the persons duly authorized by the same or by Law, to correct, update or delete their Personal Data or to revoke the authorization as set forth under Law.
Responsible for the Processing : Natural Person or legally established company, public or private, that individually or in association with others, make decisions in terms of database and / or the Processing of data.
Holder: Natural person whose Personal Data is subject to Processing .
Transfer: The Transfer of Personal Data takes place when the Responsible and / or Person in Charge of the Processing of Personal Data, located in Colombia, sends the information or Personal Data to a recipient, who in turn is Responsible for the Processing located in Colombia or abroad.
Diffusion: Processing of Personal Data which implies communication of the same in the Republic of Colombia or abroad, when the purpose is to perform personal data processing by the Manager on behalf of the Responsible party.
Processing : Any Personal Data operation or set of operations such as collection, storage, use, circulation or deletion.
Article 6. Principles applicable to the Processing of Personal Data: For the Processing of Personal Data, the Companies shall apply the principles outlined below, which establish the instructions to be followed within the Processing of Personal Data:
Legality: The Processing of Personal Data must be performed in accordance with the applicable legal provisions (Statutory Law 1581 of 2012 and its regulatory decrees).
Purpose: The Personal Data collected must be used for a specific and explicit purpose which must be informed to the Holder or as set forth under Law. The Holder must be informed clearly, sufficiently and in advance about the purpose of the information provided.
Voluntary authorization: The collection of Personal Data may only be exercised with prior, explicit and informed authorization of the Holder.
Veracity or Quality: The information subject to the Processing of Personal Data must be truthful, comprehensive, exact, updated, verifiable and understandable.
Transparency: Within the Processing of Personal Data, the Holder´s right to obtain, at any time and without restrictions, information about the existence of data concerning him/her must be guaranteed.
Access and restricted circulation: The Processing of Personal Data shall only be performed by the persons authorized by the Holder and / or as set forth under Law.
Safety: The Personal Data subject to Processing must be handled in accordance with all necessary safety standards in order to prevent loss, adulteration, consultation, use or unauthorized or fraudulent access.
Confidentiality: All employees that work in the Companies are obliged to keep Personal Data confidential, even after their employment or contractual relationship has ended.
Article 7. Authorization: The Processing of Personal Data by the Companies requires voluntary, prior, explicit and informed consent of the Holder.
Article 8. Form and mechanisms for granting Authorization: The Authorization may appear in any manner which guarantees its consequent consultation, specifically: i) in writing, ii) orally, or iii) by means of absolute authorization of the Holder which leads to reasonably conclusion that the Authorization was granted. In no case may silence be interpreted as absolute authorization.
Article 9. Proof of Authorization: The Companies shall keep necessary records or mechanisms in order to establish when and how the authorization was obtained from the Personal Data Holders for the processing thereof.
Article 10. Rights of the Holders: In accordance with the provisions of article 8 of Law 1581 of 2012, the Holder of Personal Data has the right to:
Article 11. Obligations of the Companies: The Companies recognize that the Personal Data is property of the people to whom they refer and that only they can decide in regards to the same. Therefore, the Companies shall use the Personal Data collected only for the purposes for which they are duly empowered to do so and recognizing, in any case, the current regulations on the Protection of Personal Data.
In accordance with the provisions of article 17 of Law 1581 of 2012, the Companies are obliged to comply with the following obligations :
granted by the Holder;
loss, consultation, use or unauthorized or fraudulent access;
in case of risks in the administration of the holders´ information.
Article 12. The privacy notice is a physical or electronic document, or in any other format made known to the Holder, before or at the time of collection of their Personal Data, and is the means by which information is informed in regards to Information Processing Policies which shall be applicable, the ways to access them and, in general, the purposes for which Personal Data has been obtained and the processing that the Companies proceed.
Article 13. Information processing. The Personal Data managed by the Companies shall be collected, used, stored, updated, transmitted and / or transferred, for the following purpose or purposes:
Regarding the Personal Data of our Clients and Suppliers:
Regarding the Personal Data of our candidates:
Regarding the Personal Data of our staff:
development of the same;
Article 14. The division responsible for access request, rectification, updating, data deletion or revocation of consent or Authorization granted for the Processing of Personal Data to any of the Companies, is the Legal and Corporate Affairs Vice Presidency, located at Calle 45a Sur No. 56 – 21, Bogota DC, Colombia, email Notifications@alianzateam.com
The Personal Data Protection Officer´s main functions is to ensure effective implementation of policies and procedures accepted by the Companies in order to comply with the Colombian System for the Protection of Personal Data, and to take charge of the structuring, design and administration of the Comprehensive Personal Data Management program.
The Company’s Personal Data Protection Officer shall:
permanent training activities for the staff;
Colombian System for the Protection of Personal Data, this Policy and those resulting from the
implementation of the Comprehensive Personal Data Management Program;
of the Companies´ terms and obligations under the Colombian System of Protection of Personal Data;
associated with the Processing of Personal Data;
of the Superintendence of Industry and Commerce;
of Databases and the Colombian System for Protection of Personal Data;
Personnel under his/her responsibility, and establish due compliance indicators for frequent compliance verification;
Colombian System for the Protection of Personal Data within the organization.
Article 15. Access Rights. The Holders of Personal Data processed by the Companies have the right to access their Personal Data and the details of said Processing, as well as to rectify and update the same if they are inaccurate or to request elimination when considered that they are disproportionate or unnecessary for its purposes or contrasting to the specific purpose processing.
Submission of requests and for the purpose of guaranteeing the herein referred to rights, enquires should be addressed to:
Team Foods Colombia S.A. Calle 45a Sur No. 56 – 21, Bogotá D.C.
Grasas S.A. Calle 45a Sur No. 56 – 21, Bogotá D.C.
Team Foods Colombia S.A. email@example.com
Grasas S.A. firstname.lastname@example.org
These channels may be used by Personal Data Holders, or third parties to act on their behalf as authorized by law, in order to exercise the following rights:
a.Queries: The Holder may access his/her Personal Data free of charge. Thus, the holder may submit a request indicating the information required by means of any of the mechanisms indicated above. The request shall be answered by the Companies within a maximum term of ten (10) business days as of the date of receipt. When it is not possible to answer the request within said term, this circumstance shall be reported to the applicant, stating the reasons for the delay and indicating the date on which their query shall be answered, which in no case may exceed five (5) business days following the expiration of the first term.
The maximum term to meet this request shall be fifteen (15) business days as of the day following the date of receipt.
When it is not possible to answer the request within said term, this circumstance shall be reported to the applicant, stating the reasons for the delay and indicating the date on which their query shall be answered, which in no case may exceed five (8) business days following the expiration of the first term.
If the claim is incomplete, the interested party shall, within five (5) days after receiving it, correct the corresponding errors. If after two (2) months as of the date of the request, without the applicant submitting the required information, the claim shall be interpreted as a withdrawn claim. Once a complete claim has been received, a reference indicating “claim in process” and due reason shall be included in the Database, within a term not exceeding two (2) business days. Said reference must be preserved until the claim is decided upon.
First Paragraph. Rectification and update: When the claims are intended for rectification or update, the Holder must indicate the corresponding corrections and submit documentation that supports their request.
Second paragraph. Deletion: The deletion of Personal Data is performed by means of total or partial elimination of personal information as requested by the Holder, notwithstanding, the Companies may deny such request when the Holder has a legal or contractual duty to remain in the Database.
Article 16. Revocation of Authorization. Holders of personal data may revoke the Authorization previously granted at any time, except in those events in which a legal or contractual provision impedes such action. In any case, the Holder must indicate in his/her corresponding request if it is a full or partial revocation, the latter, when he/she requests to eliminate only some of the authorized data, the Holder must clearly indicate which data to be delete.
Article 17. Personal Data stored by the Companies shall be kept as long as required according to the purpose of the Processing and / or for the term required in order to comply with a legal or contractual obligation. The Companies have adopted measures for timely and safe elimination of their Personal Data, outlined in the Policies and Procedure Guidelines.
Article 18. Upon performing the corresponding commercial activity, the Companies process Sensitive Personal Data for specific purposes. The Companies shall only perform the Processing of sensitive Personal Data as long as it has been previously authorized by the corresponding Holder and shall handle them under safety and confidentiality standards in accordance with their nature.
In accordance with the above, the Companies have implemented administrative, technical and legal procedures as duly outlined in the Policies and Procedures Guidelines, which are mandatory for The Companies’ employees and, as applicable, their suppliers, associated companies and / or commercial allies.
However, it shall be notified that the collection of Sensitive Personal Data is not meant as a condition for accessing any of our products or services.
Article 19. In accordance with article 26 of Law 1581 of 2012, the Transfer of Personal Data of any kind to countries that do not provide adequate levels of data protection is prohibited. A country that offers an adequate level of data protection is considered when the standards set by the Superintendence of Industry and Commerce have been met. They may, however, never be less than those required by law 1581 of 2012.
This prohibition shall not apply when it refers to:
included, based on the principle of reciprocity;
or defense of a right within a judicial process.
Article 20. When the Companies send or transmit data to one or more Managers located within or outside the territory of the Republic of Colombia, they must establish contractual clauses or enter into a Personal Data Transmission contract in which, among others, as outlined below:
by the final user Data Controller.
The Companies shall not request Authorization when international transmission of data is protected by any of the exceptions provided within the Law and corresponding Regulatory Decrees.
Article 21 The Companies shall be responsible for the protection of Personal Data, shall process the requests of the Holders, and shall guarantee the exercise of the corresponding rights.
Article 22. Safety measures: Upon exercising the safety principles established under Law 1581 of 2012, the Companies shall undertake the necessary technical, human and administrative measures in order to guarantee the safety of the Personal Data subject to Processing, thus avoiding its adulteration, loss, consultation, use or unauthorized or fraudulent access.
Article 23. Validity: This Policy is effective as of June 1, 2017.