Personal data processing and privacy policy

1. OBJECT. LINTERNA VERDE (hereinafter "the Entity"), identified with the NIT 901.196.678-2, domiciled in Bogota, will treat personal data in accordance with this policy. For this reason, and in compliance with its legal duties, LINTERNA VERDE as responsible for the processing of personal data, informs you of its Privacy Policy regarding the processing of personal data that may be collected in the course of its activities.

2. SCOPE. This policy applies to all personal information recorded in the databases of LINTERNA VERDE by its petitioners, as well as its employees and collaborators.

3. PROCESSING OF PERSONAL DATA. The collection, processing and subsequent use of personal data by LINTERNA VERDE will be carried out in accordance with the provisions of Law 1581 of 2012, Decree 1074 of 2015 and other applicable rules. 

4. PURPOSE OF THE PROCESSING OF PERSONAL DATA. In general, LINTERNA VERDE will treat the personal data of its petitioners, employees and collaborators for the following purposes:

1. Manage requests, complaints and claims.
2. To carry out communication activities, such as invitations to events, press releases, information produced, offering of services, and any other matter that allows the development of the Entity's purpose.
3. Analyze, evaluate and generate statistical data on the Entity's activities.
4. Conduct satisfaction surveys on the services offered by the Entity.
5. To take the necessary steps for the corporate purpose of the Entity in matters related to the execution of contracts with the holders of the information.
6. Provide contact information to internal teams or third parties with whom the Entity has a contractual relationship for the development of activities in the exercise of its corporate purpose.
7. Contact the holder by telephone and electronic means to conduct surveys, studies or confirmation of personal data necessary for the execution of a contractual relationship. 
8. Contact the holder to send account statements, reports or invoices in connection with the obligations of the contract entered into between both parties.
9. Comply with the labor obligations of the Entity by virtue of the contracts entered into with the holders in accordance with the law or the agreement between both parties.
10. Transfer data to third parties established abroad with which the Entity has entered into data processing contracts when it is necessary to deliver them in order to fulfill the purpose of a contract entered into with the holder.
11. To register the data of the holders of the information.
12. To carry out audits and manage our systems and databases.
13. Collect data for the fulfillment of the duties that, as Responsible for the information and personal data, correspond to the Entity.
14. Collect sensitive data through forms for the development of the Occupational Health and Safety Management System of the Entity.

5. RIGHTS OF HOLDERS OF PERSONAL DATA. The holders of personal data have the rights recognized by the applicable regulations, which will be guaranteed by LINTERNA VERDE and are described below:

1. Access free of charge to the data provided that have been processed. 
2. Know, update and rectify your information in case of partial, inaccurate, incomplete, fractioned, misleading, or those whose treatment is prohibited or has not been authorized. 
3. Request proof of the authorization granted. 
4. To file complaints before the Superintendence of Industry and Commerce (SIC) for violations of the provisions of the regulations in force. 
5. To revoke the authorization or request the deletion of the data, provided that there is no legal or contractual obligation that prevents the deletion of the data.
6. Refrain from answering questions about sensitive data. 

6. ATTENTION TO REQUESTS, INQUIRIES AND COMPLAINTS. The administrative area of LINTERNA VERDE is responsible for resolving requests from holders to enforce their rights. The holder or his assignees may enforce the exercise of their rights by e-mail to contacto@linternaverde.co. In any case, the communication addressed to the exercise of such rights, must include the following information of the holder and / or his (s) successor (s): name, surname, and number of Citizenship Card or any other valid document that proves their identity and petition in which the request is made.

7. PROCEDURE FOR THE EXERCISE OF CONSULTATIONS. LINTERNA VERDE will resolve the queries within a maximum period of ten (10) working days from the day after receiving it. If it is not possible to meet the request within this term, the Entity will inform the reasons for the delay and the date on which it will be attended, which will not be more than five (5) additional business days after the expiration of the first term.

8. PROCEDURE FOR THE EXERCISE OF CLAIMS. LINTERNA VERDE will resolve the claims within a maximum period of fifteen (15) working days from the day after receiving it. When it is not possible to address the claim within that period, the interested party will be informed of the reasons for the delay and the date on which the claim will be addressed, which in no case may exceed eight (8) working days following the expiration of the first term.

Any claim must contain a description of the facts giving rise to the claim, the address of notification, and the documents to be asserted, as attachments to the claim. In the event that the claim is incomplete, the Entity will contact the holder within five (5) business days following the receipt of the claim so that the faults may be corrected within the following two (2) months. If the claim is not completed within such term, it will be considered as withdrawn.

PARAGRAPH. In accordance with Article 16 of Law 1581 of 2012, the Holder and/or its assignees may file complaints with the Superintendence of Industry and Commerce only after having made the claim directly to LINTERNA VERDE and the terms of response described in this section expire or a response is received by the Entity, whichever occurs first.

9. AUTHORIZATION. In order to fully comply with this policy, LINTERNA VERDE, requires free, prior, express and duly informed authorization from the owners of the data and for this purpose has provided suitable mechanisms to ensure for each case that it is possible to verify the granting of the same. This authorization may be recorded in any medium, whether a physical or electronic document or in any format that guarantees its subsequent consultation. Such authorization is a statement that informs the owner of the data the following information:

1. The person responsible or in charge of collecting the information.
2. Data collected.
3. The purposes of data processing.
4. The procedure for exercising the rights of access, correction, updating or deletion of data.

10. EFFECTIVENESS. This policy is effective as of its publication date, that is, December 11, 2023. The databases in which the personal data will be recorded will be valid for as long as the information is kept and used for the purposes described in this policy. Personal data will be kept as long as their deletion is not requested by the interested party and as long as there is no legal duty to keep them. In case of contractual employment relationships, the data will be kept for as long as such relationships are in force. 

PARAGRAPH. LINTERNA VERDE reserves the right to make, at any time, modifications, updates or changes it deems appropriate in the terms of this Policy for the Processing of Personal Data and Privacy and, prior to its implementation, request the appropriate authorizations when such changes involve the inclusion of new purposes of treatment or changes in the identity of the Responsible.