Personal Data Processing

15.Protection of Personal Data: I authorize KONCET SAS to process my personal data in accordance with Law 1581 of 2012 and the Data Policy established by it, the content of which is available at the following link: https://www.koncetsas.com/proveedores-y-clientes Recognize that this processing is carried out for purposes related to commercial activities, training, and technical training related to the services included in the KONCET SAS portfolio. Likewise, I have been informed by KONCET SAS that within the mentioned activities, photographs may be taken and these may be used in print or virtual media for their dissemination and promotion, which I accept voluntarily.

 

TERMS OF USE

 The contents of the web pages of KONCET S.A.S and its brands in Colombia, have been created with the purpose of providing information about the company to its users. Therefore, the information related to products for marketing, as well as information related to the business, financial matters, directed at shareholders, or of any other kind, will have a general and indicative character, and is subject to possible changes.

Given that the information is indicative and not promotional in nature, in the event of any discrepancy between the prices or conditions shown on the website and the prices or conditions listed or marketed in the market, it should be understood that the current values and conditions correspond to those of the market offers, so that such divergences cannot be considered as deceptive advertising.

KONCET S.A.S advises that the information contained on this website is intended to guide the user, who in turn
acknowledges and accepts that they use the Internet at their own risk, and hereby release KONCET S.A.S, to their
officials and/or executives from any civil or criminal liability arising from the use of the Internet

"In case of any concerns or need for information, you may visit the offices of KONCET S.A.S located at Calle 55 A No.72-61, Bogotá, Colombia.

KONCET S.A.S does not acknowledge any responsibility for any information not contained on this website, and therefore, not created by KONCET S.A.S,regardless of whether it is a website that fraudulently uses the name of KONCET S.A.S, with the understanding that any other page using said name is infringing on the company's intellectual property rights.

KONCET S.A.S is not responsible for potential security errors that may occur as a result of using computers infected with computer viruses or the consequences that may arise from the malfunction of the browser or the use of outdated versions thereof.

Specifically, it does not acknowledge any responsibility for the information contained on third-party websites connected by links to the website of KONCET S.A.S, Therefore, it shall not be liable at any time to the user or third parties for damages and losses related to Internet use when the failure is due to the user's failure to follow proper instructions, fortuitous events or force majeure, malicious acts of a third party, or malfunctions in computer systems or communication systems, or any similar event beyond the control of KONCET S.A.S

The trademarks, patents, designs, and/or industrial models, commercial notices, appearing on this website are the property of KONCET S.A.S

No information and material from the sites may be copied, distributed, printed, licensed in any way, modified, published, reproduced, sold, transmitted, used to create a work different from the purpose of this page, or for derivative works or used for public or commercial purposes, except with the prior and express consent of KONCET SAS, which must be in writing and comply with all legal requirements by KONCET SAS

The reproduction, copying, use, distribution, marketing, public communication, or any other unauthorized activity that may be carried out with the information contained on this website and is done without the authorization of KONCET SAS, will be considered an infringement in terms of laws related to Industrial Property and Copyright and related rights.

Likewise, any violation of the Intellectual Property and/or Industrial Property rights owned by KONCET or its related companies or officials are acts constituting violations of criminal and civil regulations on the subject and will be pursued and punished by the authorities, including the corresponding seizure of materials, precautionary measures, and imprisonment if necessary."

KONCET is the owner of all copyright rights to all documents, audio material or audiovisual material, software, or any other material susceptible to copyright, incorporated into this website, and KONCET is the sole authorized party to copy, modify, reproduce, use, and market the resulting material

The unauthorized use of the material contained on this website may also constitute unfair competition and will result in civil and criminal liability for the party who engages in it.

In any case of dispute that may arise from the application of the services offered by KONCET S.A.S In any case of dispute that may arise from the application of the services offered by through its website, or from the interpretation or application of the general conditions, as well as with regard to the laws applicable to the specific case, it shall be understood that the laws of the Republic of Colombia shall apply, and the jurisdiction of the judges of the Republic of Colombia shall be observed. Therefore, the user expressly waives any other jurisdiction that might correspond to them by reason of their nationality or domicile.

 

DATA POLICY

This policy is aimed at complying with the provisions set forth in paragraphs D, E, and K of Article 17 of Law 1581 of 2012, and thereby ensuring the proper processing of personal data collected and included in the databases managed by KONCET S.A.S for the development of its activities within its corporate purpose.

It is established as the policy of KONCET S.A.S to comply with the regulations and principles contained in the aforementioned law, which are applicable to personal data that are recorded and subject to processing by KONCET S.A.S. Until such time as the company is governed by the regime of personal data protection established by this law, its regulatory decrees, and other regulations that complement, modify, or repeal it.

1. Purpose

The purpose of this policy is to comply with the constitutional right that all individuals have to know, update, and rectify personal information collected about them in databases or records related to Article 15 of the Political Constitution, as well as the right to information established in Article 20 of the same.

Likewise, some definitions related to terms necessary for the correct application of the aforementioned policies are provided, along with the principles on which the collection and processing of personal data are based. Likewise, the personal contact data of users, when they are to be used for marketing or advertising purposes as a result of alliances or agreements, will be processed following the provisions of the Law.

1. Definitions

For the application of the rules and procedures established in this policy, the definitions established in articles 3 and 5 of Statutory Law 1581 of 2012 are assimilated.

• Authorization: Prior, express, and informed consent of the Data Subject to carry out the Processing of personal data.
• Database: Organized set of personal data that is subject to Processing
• Personal data: Any information linked to or that can be associated with one or more specific or determinable natural persons
• Data Processor: Natural or legal person, public or private, who, on their own or in association with others, processes personal data on behalf of the Data Controller
• Data Controller: Natural or legal person, public or private, who, on their own or in association with others, decides on the database and/or the processing of data.
• Data Subject: Natural person whose personal data is subject to Processing.
• Processing: Any operation or set of operations on personal data, such as collection, storage, use, circulation, or deletion.

1. Scope

This policy applies to clients, suppliers, employees, and others associated with the economic activity of KONCET S.A.S.

For all purposes, the following aspects are defined in accordance with Decree 1377 of 2013

• Business Name: KONCET S.A.S
• Location and Address: Calle 55 A No. 72-61 Normandía Bogotá
• Email: proveedores@koncetsas.com
• Phones: 6017061153-3194642276

1. Principles for the Processing of Personal Data"

KONCET S.A.S will apply the following specific principles, which constitute the rules to be followed in the collection, handling, use, processing, storage, and exchange of personal data

• Principle of Purpose The Processing of data required by KONCET S.A.S will comply with the legitimate purpose of activities aimed at fulfilling its corporate purpose, within the framework of the Constitution and the Law.
• Principle of Freedom:KONCET S.A.S. ensures that the collection and processing of personal data collected in its databases will only be carried out with the prior, express, and informed authorization of the data subject, and it also commits not to disclose the collected personal data without the authorization of the data subject.
• Principle of Truthfulness or Quality: The information subject to processing by KONCET S.A.S will be provided by each of the individuals and is considered truthful, complete, accurate, up-to-date, verifiable, and understandable.
• Principle of Transparency: KONCET S.A.S ensures to data subjects that they may obtain, upon written request, information about the data stored in the databases that are being processed from the Data Controller or the Data Processors.
• Principle of Security: KONCET S.A.S will take all necessary technical, human, and administrative measures to provide security to the records, preventing their alteration, loss, consultation, use, or unauthorized or fraudulent access.
• Principle of Confidentiality: All individuals involved in data processing KONCET S.A.S must ensure the confidentiality of the information during and after the completion of their relationship with any of the tasks involved in processing.

1. Privacy Notice

KONCET S.A.S commits to regulate the collection, storage, processing, management, transfer, transmission, and protection of the information received through different information collection channels, all within the framework of current legal regulations, in accordance with the provisions contained in Statutory Law 1581 of 2012, Decree 1377 of 2013, and other related regulations, which establish general provisions for the protection of personal data.

The owners of the personal data provided to the entity accept the processing of this data and authorize its use when they provide it to us through different means or when they navigate on our website in accordance with the terms of this policy.

 

PROCEDURE

1. Authorization

For authorization, the storage, consultation, use, exchange, transmission, transfer, and processing of personal data require the free, express, and informed consent of the Data Subject."

Data subjects may give their authorization to KONCET S.A.S for the processing of their data, through any physical document, electronic means, data message, Internet, websites, or any other format that allows for subsequent consultation, or through a suitable technical or technological mechanism that allows for the expression or obtaining of consent. The authorization will be generated by KONCET S.A.S and will be made available to the data subject in advance and prior to the processing of their personal data.

1. Procedures for Inquiries and Claims"

To exercise these rights, the data subject can do so through the following means:

1. Email to: administrativa@koncetsas.com
2. Address: calle 55 a No 72 61 Bogotá Colombia.

Stating the following:

• Type of procedure you wish to perform: Know, request, inquire, update, rectify, or delete.
• Name and ID number of the requester.
• Contact phone number
• Contact email address or mailing address for the response.

 

RIGHTS

1. Rights of the data subjects

In accordance with Article 8 of Statutory Law 1581 of 2012, the data subject shall have the following rights:

• To know, request consultation, update, and rectify their personal data at KONCET S.A.S As the Data Controller and Data Processor
• Request proof of the authorization granted to KONCET S.A.S
• Be informed by KONCET S.A.S regarding the use it has made of your personal data.
• Submit complaints to the Superintendency of Industry and Commerce for violations of the provisions of Statutory Law 1581 of 2012, once the consultation or claim process as indicated in said Law has been exhausted.
• Revoke the authorization and/or request the deletion of the data when the processing does not respect constitutional and legal principles, rights, and guarantees.

1. Sensitive Data

The data subject has the right to choose not to provide any sensitive information requested by KONCET S.A.S, which may include, among others, data about their racial or ethnic origin, membership in unions, social or human rights organizations, political or religious beliefs, sexual life, biometric data, or health-related information.

1. Data of Minors

The provision of personal data of minors is optional and must be provided by parents, legal guardians of the minor, or with their authorization.

 

DUTIES

1. of the data controller

KONCET S.A.S will appoint a person responsible for the administration of databases containing personal information and will ensure compliance with the following duties listed below, without prejudice to other provisions provided for by law and others governing its activity:

• Ensure the Data Subject's full and effective exercise of the right to habeas data at all times
• Keep the authorizations granted by the Data Subjects in physical or digital format
• Properly inform the Data Subject about the purpose of data collection and their rights granted by the authorization provided.
• Maintain the information under the necessary security conditions to prevent its alteration, loss, consultation, unauthorized or fraudulent use, or access
• Rectify the information when it is incorrect and communicate the relevant information to each data processing manager.

1. The information processors

KONCET S.A.S and any of the data processors who assume the role of data processors for personal data under their custody must comply with the following duties, without prejudice to other provisions established by law and those governing their activities:

• Ensure that the Data Subject has, at all times, the full and effective exercise of the right to Habeas Data.
• Maintain the information under the necessary security conditions to prevent its alteration, loss, consultation, unauthorized or fraudulent use, or access
• Timely update, rectify, or delete data in accordance with the terms stipulated in Law 1581 of 2012.
• Update any changes in the information reported by data subjects within (15) business days from its receipt
• Process inquiries and claims filed by data subjects within the terms established in Law 1581 of 2012

1. Information Security and Security Measures

In accordance with the security principle established in the current regulations, KONCET S.A.S will implement the technical, human, and administrative measures necessary to ensure the security of the records, preventing the alteration, loss, unauthorized or fraudulent access, consultation, use, or disclosure of personal data registered in the databases.

 

RESPONSIBLE PARTIES AND DATA PROCESSORS

1. Responsible for Information Processing:

General Manager

1. Database Registrar

Administrative Director

1. Managers of each database

 

Types of data	Management in charge	Position of the Person in Charge
Payroll – Employees (payroll)	Human Resources	Human Resources Manager
Suppliers	Purchases	Purchasing Manager
Our clients	Sales	Sales Assistant
Business contacts	Customer Service	Contact Center Manager
Visitors	Human Resources	Security Manager

 

This policy comes into effect on June 8, 2017. The databases will remain valid for as long as KONCET S.A.S maintain commercial activities in Colombia.