Processing of personal data

Treatment of personal data: TREATMENT POLICY MITECNI.CO COMPAÑÍA NACIONAL DE SISTEMAS S.A.S.
In accordance with the provisions of Law 1581 of 2012 Data Protection Law, this Privacy Policy is issued in the following terms:

RESPONSIBLE FOR PERSONAL DATA
The legal person responsible for your personal data and therefore for the database in which they are located is Mitecni.co Compañía Nacional de Sistemas S.A.S.
For the purposes of this Treatment Policy, “Mitecni.co Compañía Nacional de Sistemas S.A.S.” has designated the administrative office with address at Calle 16 # 19-48 Of. 2907 in Bucaramanga (Santander), to attend to requirements related to users, to the Human Management Area to attend to requests related to collaborators and to the Purchasing Area those related to suppliers.

INFORMATION COLLECTED
Personal data collected through the Contract entered into between you as a user, worker, contractor or supplier and Mitecni.co Compañía Nacional de Sistemas SAS To do so, you must voluntarily and freely provide your true, non-sensitive personal identification data, such as They are: name, surnames, identification, telephone, physical and electronic address and other necessary data that may be requested at the time of contracting any of our services or entering into any type of contract and data that may be collected during the execution of the same.

TREATMENT AND PURPOSE
The data collected by Mitecni.co Compañía Nacional de Sistemas S.A.S. They will be treated with the appropriate degree of protection required by law and in this sense, the data controller undertakes to treat the data with the exclusive purpose for which they were collected. Mitecni.co National Systems Company S.A.S. collects data from its users for the following purposes.
1. Identify you as a user of our services and carry out the necessary steps for its best provision.
2. Offer you information related to our products, services, offers, promotions, alliances, contests, content, as well as those of our related companies.
3. Sending information corresponding to the account statement.
4. Contact the user to schedule visits specific to the provision of the service.
5. Inform about new products or services related to the contract(s) or acquired(s).
6. Report changes to our products or services.
7. Evaluate the quality of the service.
8. Carry out internal studies on consumption habits.
9. Exchange of information with other providers for the prevention and control of fraud
10. Creation of Interactive Profile and/or Web Page.
11. Commercial and promotional purposes by Mitecni.co Compañía Nacional de Sistemas S.A.S. and their allies.
12. Consult, report, process, request and disclose to the Financial Information Centers managed by the Colombian Banking and Financial Institutions Association, or to any other entity that handles or administers databases for the same purposes, all information regarding their business behavior.
Mitecni.co National Systems Company S.A.S. collects data from its workers, collaborators, contractors and suppliers for the following purposes:
1. Comply with the law.
2. Execute and fulfill the contracts.
3. Support the selection of candidates, training and promotion of staff.
4. Quality control of the services provided by Mitecni.co Compañía Nacional de Sistemas S.A.S..
PRINCIPLES FOR TREATMENT
1. Principle of legality: The treatment given to personal data is adjusted to the parameters established by Law.
2. Principle of purpose: The personal data subject to treatment by Mitecni.co Compañía Nacional de Sistemas S.A.S. They will be used only for the purposes described above.
3. Principle of transparency: The Data Controller guarantees the Rights of the owner at any time and without restrictions. In this way, it is of great importance to clearly inform the data that is collected and the treatment thereof.
4. Principle of security: The information subject to treatment by Mitecni.co Compañía Nacional de Sistemas S.A.S. has the measures required by law according to the quality of the data and in order to avoid its adulteration, loss, consultation, use or unauthorized or fraudulent access.
5. Principle of confidentiality: All persons involved in the Processing of personal data are obliged to guarantee the confidentiality of the information, even after the end of their relationship with any of the tasks included in the Processing, being able to only supply or communicate of personal data when this corresponds to the development of the activities authorized by the Law or by the owner of the data.

SECURITY MEASURES
The security measures adopted by Mitecni.co Compañía Nacional de Sistemas S.A.S. they comply with information security measures in order to avoid unauthorized access, use, modification or loss of personal data provided for by law. All databases, owned by Mitecni.co Compañía Nacional de Sistemas S.A.S. Regardless of the quality of the data, they have basic security measures, these measures are increased according to the quality of the data.

RIGHTS OF THE DATA HOLDER
You as the owner of the data collected by Mitecni.co Compañía Nacional de Sistemas S.A.S. You can make use of the following rights:
1. Right of Access: It is the right that every person has to know if their personal data are being processed, are included in the database, what purpose and origin they have, as well as the transfers made or planned to third parties. To exercise your right, you may submit a request to the Data Controller or through the contact channels already specified.
It is important to highlight that you will be able to consult your personal data free of charge at least once every calendar month and whenever there are substantial changes to the Information Processing Policies. When the query is made more than once a month Mitecni.co Compañía Nacional de Sistemas S.A.S. As the owner of the database, you can charge the costs of shipping, reproduction and if certification of documents is required.
2. Right to Update and Rectification: It is the right that you have as the owner of the data to update and correct the personal data found in the databases owned by Mitecni.co Compañía Nacional de Sistemas SAS, when these have changed or when there is an error, are inaccurate or incomplete. To do this, you must also submit a request for information that must contain, in addition to what is indicated in the previous point on access to personal data, the modifications to be made and provide the documentation that supports your request.
3. Right of Deletion: It is the right that you as a user have to delete your personal data in the databases owned by Mitecni.co Compañía Nacional de Sistemas SAS, in the following cases: (i) when the treatment of the data same does not comply with the provisions of the Data Protection Law (Law 1581 of 2012) as long as the Superintendence of Industry and Commerce has determined that in the Treatment the Responsible or Manager have incurred in conduct contrary to the law and (ii) by virtue of the free and voluntary request of the Holder of the data, as long as there is no legal or contractual obligation that imposes on the Holder the duty to remain in the aforementioned database.
The deletion results in the blocking of your data, this means that the data is kept only at the disposal of competent authorities, for security purposes and to meet the possible responsibilities arising from the treatment.
4. Filing of complaints: As the owner of personal data, you have the right to file complaints with the Superintendence of Industry and Commerce for infractions associated with the use of your personal data, as long as you have exhausted the process of querying or claiming before Mitecni.co Compañía National Systems SAS.

DUTIES OF THE RESPONSIBLE AND IN CHARGE OF THE TREATMENT
The person in charge and those in charge of the treatment must comply with the following provisions set forth in Law 1581 of 2012, Law on Protection of Personal Data.
Responsible for Treatment
• Guarantee the Holder, at all times, the full and effective exercise of the right of habeas data;
• Request and keep, under the conditions set forth in this law, a copy of the respective authorization granted by the Holder;
• Duly inform the Holder about the purpose of the collection and the rights that assist him by virtue of the authorization granted;
• Keep the information under the necessary security conditions to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access;
• Guarantee that the information provided to the Treatment Manager is truthful, complete, accurate, up-to-date, verifiable and understandable;
• Update the information, promptly communicating to the Person in Charge of the Treatment, all the news regarding the data that has previously been provided and adopt the other necessary measures so that the information provided to it is kept up to date;
• Rectify the information when it is incorrect and communicate what is pertinent to the Treatment Manager;
• Provide the Person in Charge of Treatment, as the case may be, only data whose Treatment is previously authorized in accordance with the provisions of this law;
• Require the Treatment Manager at all times to respect the security and privacy conditions of the Holder’s information;
• Process queries and claims formulated in the terms indicated in this law;
• Adopt an internal manual of policies and procedures to ensure proper compliance with this law and, in particular, for dealing with queries and claims;
• Inform the Person in Charge of Treatment when certain information is under discussion by the Holder, once the claim has been submitted and the respective procedure has not been completed;
• Inform at the request of the Holder about the use given to his data;
• Inform the data protection authority when there are violations of the security codes and there are risks in the administration of the Holders’ information.
• Comply with the instructions and requirements issued by the Superintendence of Industry and Commerce.
Treatment Managers
• Guarantee the Holder, at all times, the full and effective exercise of the right of habeas data;
• Keep the information under the necessary security conditions to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access;
• Perform timely updating, rectification or deletion of data under the terms of this law;
• Update the information reported by the Treatment Managers within five (5) business days from its receipt;
• Process queries and claims made by the Holders in the terms set forth in this law;
• Adopt an internal manual of policies and procedures to ensure adequate compliance with the law and, in particular, for handling queries and claims by the Holders;
• Record in the database the legend “claim in process” in the manner in which it is regulated in this law;
• Insert in the database the legend “information under judicial discussion” once notified by the competent authority about judicial processes related to the quality of personal data;
• Refrain from circulating information that is being controversial by the Holder and whose blocking has been ordered by the Superintendence of Industry and Commerce;
• Allow access to information only to persons who may have access to it;
• Inform the Superintendency of Industry and Commerce when there are violations of the security codes and there are risks in the administration of the Holders’ information;
• Comply with the instructions and requirements issued by the Superintendence of Industry and Commerce.
Paragraph. In the event that the qualities of Treatment Manager and Treatment Manager concur in the same person, compliance with the duties provided for each one will be required.

ATTENTION OF PETITIONS, INQUIRIES AND CLAIMS, AND PROCEDURE
Mr. User, if you wish to make use of the rights that assist you, you can do so by the following means:
1. Communication sent to the person in charge of handling requests from Mitecni.co Compañía Nacional de Sistemas S.A.S. at the Administrative Headquarters Calle 16 # 19-48 Of. 2907 in Bucaramanga (Santander).
2. Via email [email protected]
3. Through the support system of the portal www.mitecni.co.
4. With our hotline +1-786-209-0303.
The procedure for the attention of the respective PQR will be the one foreseen in Resolution CRC 3066 of 2011.
Mr. worker, contractor or supplier, if you wish to make use of the rights that assist you, you can do so by means of a communication sent to the Responsible parties already established in these policies for the attention of requests, queries and claims of Mitecni.co Compañía Nacional de Sistemas S.A.S. at the Administrative Headquarters Calle 16 # 19-48 Of. 2907 in Bucaramanga (Santander). The procedure for attending to the respective request will be the one provided for in article 15 of Law 1581 of 2012.

APPLICATION
Our privacy policies apply to all databases owned by Mitecni.co Compañía Nacional de Sistemas S.A.S..

VALIDATION
The Treatment Policies established here come into effect on the day they are published on the website.
The Databases will be in force during the time that Mitecni.co Compañía Nacional de Sistemas S.A.S. develops its corporate purpose.
For more information related to the legal provisions of data protection, and those related to the claim procedures regarding them, we suggest you visit the website of the Superintendency of Industry and Commerce (www.sic.gov.co).
Mitecni.co National Systems Company S.A.S. reserves the right to modify the Treatment Policies at any time. Any modification will be communicated in a timely manner to the holders of the personal data; It will enter into force and will have effects before the clients from its publication in the corresponding channel.

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