Data Protection Manual
* General principles and postulates
CONFECCIONES BRUSSI, company dedicated to the design, preparation, production, marketing and distribution of clothing, guarantees data protection and data privacy, good name, image, privacy. For that purpose, all actions will be governed by principles of good faith, legality, computer self-determination and transparency.
CONFECCIONES BRUSSI, in the exercise of its activities with clients, digital community, suppliers and collaborators including commercial and labor, whether permanent or occasional; BRUSSI can provide any type of information or personal data that is handled by the company. Will be responsible for having the database updated
* Legal framework
Political Constitution, article 15.
Law 1266 of 2008
Law 1581 of 2012
Regulatory Decrees 1727 of 2009 and 2952 of 2010, and partial Regulatory Decree No. 1377 of 2013 and Regulatory Decree 886 of 2014. Judgments of the Constitutional Court C – 1011 of 2008, and C – 748 of 2011.
This Personal Data Protection manual will apply to all Databases and / or Files that contain Personal Data of customers, suppliers and collaborators that are subject to treatment by BRUSSI CONFECTIONS.
IDENTIFICATION OF THE RESPONSIBLE PARTY FOR THE PROCESSING OF PERSONAL DATA
CONFECCIONES BRUSSI,Identified with NIT number: 7.926.111-5, with address at Cra. 34 N. 5 – 44 of the city of Bogotá D.C., Colombia. Email firstname.lastname@example.org, telephone 3214769726, is responsible for the processing of personal data and sensitive personal data and in general any natural person and of whom it has information.
- Authorization: Prior, express and informed consent of the Holder to carry out the Processing of Personal Data.
- Database: Organized set of Personal Data that is the object of Treatment.
- Personal Data: Any information linked or that may be associated with one or more specific or determinable natural persons.
Responsible for the Handling: Natural or legal person, public or private, that by itself or in association with others, decides on the Database and / or the Data Processing.
Terms and Conditions: general framework in which the conditions for the participants of promotional or related activities are established.
Owner: Natural person whose Personal Data is subject to Treatment.
- Handling: Any operation or set of operations on Data
- Personal, such as collection, storage, use, circulation or
Transfer: The data transfer 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 Treatment and is inside or outside from the country.
Transmission: Treatment of Personal Data that implies the communication of the same within or outside the territory of the Republic of Colombia when it is intended to carry out a Treatment by the Manager on behalf of the Responsible.
CONFECCIONES BRUSSI, acting as Responsible for the Processing of Personal Data, for the proper development of their commercial activities, as well as for strengthening their relationships with third parties, collects, stores, uses, circulates and deletes Personal Data corresponding to natural persons with whom they have or has had a relationship, without this meaning limitation collaborators and their relatives, shareholders, customers, suppliers.
The Personal Data are processed by CONFECCIONES BRUSSI for the following purposes:
- To send information to your collaborators.
- For the provision of health services to employees.
- For the recognition, protection and exercise of the rights of shareholders of CONFECCIONES BRUSSI
- For the strengthening of relations with customers, suppliers and collaborators, by sending relevant information, sending proposals, the attention of Petitions, Complaints and Claims, the evaluation of the quality of the administration, and the invitation to organized events or sponsored byCONFECCIONES BRUSSI
- For the verification of balances of its customers, suppliers and collaborators.
- For the determination of outstanding obligations, the consultation of financial information and credit history and the report to centrals of information of unfulfilled obligations, regarding their debtors.
- To improve, promote and develop its products and those of its client companies, suppliers and collaborators worldwide.
- For marketing, statistics, research and other commercial purposes that do not contravene current legislation in Colombia.
- For the attention of judicial or administrative requirements and the fulfillment of judicial or legal mandates.
- To contact, by email, or by any other means, natural persons with whom you have or have had a relationship, such as, without the enumeration signifying limitation, customers, suppliers, collaborators and family members of collaborators, for the aforementioned purposes .
RIGHTS OF PERSONAL DATA HOLDERS
Natural persons whose Personal Data are subject to Processing by CONFECCIONES BRUSSI, have the following rights, which they can exercise at any time:
- Know the Personal Data about which CONFECCIONES BRUSSI is performing the handling. Similarly, the Holder may request at any time, that their data be updated or rectified, for example, if they find that their data is partial, inaccurate, incomplete, fractionated, misleading, or those whose Treatment is expressly prohibited or not has been authorized.
- Request proof of authorization granted to CONFECCIONES BRUSSI for the Treatment of your Personal Data.
- Be informed by CONFECCIONES BRUSSI, upon request, regarding the use it has given to your Personal Data.
- File complaints with the Superintendence of Industry and Commerce for violations of the provisions of the Law on Protection of Personal Data.
- Request to BRUSSI CONFECTIONS the deletion of your Personal Data and / or revoke the authorization granted for the Treatment of them, by submitting a claim, in accordance with the procedures established within this manual. However, the request for deletion of the information and the revocation of the authorization will not proceed when the Holder of the information has a legal or contractual duty to remain in the Database and / or Files, or while the relationship between the Holder and BRUSSI CONFECTIONS, under which their data were collected.
- Access your processed Personal Data for free.
RESPONSIBLE FOR THE IMPLEMENTATION AND OBSERVANCE OF THIS POLICY
The administrative area is responsible for the development, implementation, training and enforcement of this manual. For this purpose, all officials who carry out the Processing of Personal Data in the different areas of BRUSSI CONFECTIONS, are obliged to report these Databases to the area in charge and to transfer to it immediately, all the requests, complaints or claims that they receive from the Holders of Personal Data. The rights of the owners of the databases will be served by the following contact channels:
- Email: email@example.com
- Main address: Cra. 34 N. 5 – 44 Bogotá.
- Telephone to No. 321 4769726
The collaborators of CONFECCIONES BRUSSI at the head of the database manager will manage queries and / or complaints through the administrative area of the company.
SPECIAL PROVISIONS FOR THE TREATMENT OF PERSONAL DATA OF SENSITIVE NATURE.
In accordance with the Law on Protection of Personal Data, those data that affect privacy or whose improper use can generate discrimination, such as those related to:
- Racial or ethnic origin.
- Political orientation.
- Religious / philosophical convictions.
- Belonging to unions, social organizations, human rights organizations or political parties.
- Sex life.
- Signature and photo.
The Processing of Personal Data of a sensitive nature is prohibited by law, unless there is express, prior and informed authorization of the Owner, among other exceptions enshrined in Article 6 of Law 1581 of 2012.
In this case, in addition to complying with the requirements established for authorization, BRUSSI CONFECTIONS must:
- Inform the Holder that because they are sensitive data, they are not obliged to authorize their Treatment.
- Inform the Holder which of the data that will be subject to Treatment are
- Sensitive and the purpose of the Treatment.
IMPORTANT: No activity may be conditioned on the Holder providing sensitive Personal Data.
SPECIAL PROVISIONS FOR THE PROCESSING OF PERSONAL DATA OF CHILDREN, GIRLS AND TEENAGERS
As provided by Article 7 of Law 1581 of 2012 and article 12 of Decree 1377 of 2013, CONFECCIONES BRUSSI will only carry out the handling, that is, the collection, storage, use, circulation and / or deletion of Personal Data corresponding to children and adolescents, as long as this Treatment responds and respects the best interests of children and teenagers and ensure respect for their fundamental rights.
Once the above requirements have been met, BRUSSI CONFECTIONS must obtain the Authorization of the legal representative of the child or adolescent, after exercising the child’s right to be heard, an opinion that will be assessed taking into account the maturity, autonomy and ability to understand the matter.
PROCEDURE FOR ATTENTION AND RESPONSE TO PETITIONS, CONSULTATIONS, COMPLAINTS AND CLAIMS OF PERSONAL DATA HOLDERS
The Holders of the Personal Data that are being collected, stored, used, put into circulation by CONFECCIONES BRUSSI, may at any time exercise their rights to know, update, rectify and delete information and revoke the authorization.
For this purpose, the following procedure will be followed, in accordance with the
The Holder or his successors may request THE COMPANY, through the following channels:
- Email: firstname.lastname@example.org
- Main address: Cra. 34 N. 5 – 44 Bogotá.
- Telephone to No. 321 4769726
- If the complaint or claim is presented incomplete, CONFECCIONES BRUSSI must require the interested party within five (5) days after the receipt of the complaint or claim to remedy the failures. After two (2) months from the date of the request, without the applicant submitting the required information, it will be understood that he has withdrawn from the complaint or claim.
In the event that whoever receives the complaint or claim is not competent to resolve it, they will transfer to the administrative area of CONFECCIONES BRUSSIwithin a maximum period of two (2) business days and inform the interested party of the situation.
Once the complete complaint or claim is received, it will be processed within a term not exceeding two (2) business days.
The maximum term to deal with the complaint or claim will be fifteen (15) business days from the day following the date of receipt.
When it is not possible to address the complaint or claim within said term, the interested party will be informed of the reasons for the delay and the date on which the complaint or claim will be addressed, which in no case may exceed eight (8) days Skills following the expiration of the first term.
INFORMATION OBTAINED IN PASSIVE FORM
When accessing or using the services contained within the websites ofCONFECCIONES BRUSSI, it may collect information passively through information management technologies, such as “cookies”, through which information is collected about the hardware and software of the equipment, IP address, type of browser, system operational, domain name, access time and addresses of the websites of origin; Through the use of these tools, Personal Data of users is not collected directly. Information will also be collected about the pages that the person visits most frequently on these websites in order to know their browsing habits. However, the user of the CONFECCIONES BRUSSI websites has the possibility of configuring the operation of the “cookies”, according to the options of his internet browser.
SECURITY OF PERSONAL DATA
CONFECCIONES BRUSSI, in strict application of the Principle of Security in the Processing of Personal Data, will provide the technical, human and administrative measures that are necessary to grant security to the records avoiding their adulteration, loss, consultation, use or unauthorized or fraudulent access. The obligation and responsibility of CONFECCIONES BRUSSI is limited to having the adequate means for this purpose. CONFECCIONES BRUSSI does not guarantee the total security of your information nor is it responsible for any consequence derived from technical failures or from improper entry by third parties to the Database or File in which the Personal Data Subject to handling by CONFECCIONES BRUSSI and its Managers.
CONFECCIONES BRUSSwill require the service providers it hires to adopt and comply with the appropriate technical, human and administrative measures for the protection of Personal Data in relation to which said providers act as Managers.
TRANSFER, TRANSMISSION AND DISCLOSURE OF PERSONAL DATA
CONFECCIONES BRUSSI may disclose to its linked suppliers worldwide, the Personal Data on which it carries out the Treatment, for its use and Treatment in accordance with this Personal Data Protection Policy.
CONFECCIONES BRUSSI may deliver the Personal Data to third parties not linked to THE COMPANY when: a. They are contractors in execution of contracts for the development of the activities of CONFECCIONES BRUSSI
- By transfer to any title of any line of business with which the information relates.
In any case, in the contracts of transmission of Personal Data, which are signed between CONFECCIONES BRUSSI and the Managers or Suppliers for the Processing of Personal Data, the information will be required to be treated in accordance with this Personal Data Protection Policy and the following obligations will be included at the head of the respective Person in Charge:
- Give Treatment, in the name of CONFECCIONES BRUSSI to Personal Data according to the principles that protect them.
- Safeguard the security of databases that contain Personal Data. Keep confidentiality regarding the Processing of Personal Data.
This Personal Database Protection Manual is effective as of October 20, 2016.