Privacy Policy and Personal Data Processing

1. SCOPE

This Personal Data Protection Policy applies to all Databases and/or Files containing Personal Data that are subject to Processing by DOCMANAGER SOLUTIONS SAS, hereinafter THE COMPANY.

2. IDENTIFICATION OF THE DATA CONTROLLER

DOCMANAGER SOLUTIONS SAS, Carrera 47 A # 96-41, Office 403, Bogotá, Colombia.

3. DEFINITIONS

Authorization: Prior, express and informed consent of the Data Subject to carry out the Processing of Personal Data.

Privacy Notice: Verbal or written communication issued by the Data Controller and addressed to the Data Subject regarding the Processing of their 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 identifiable natural persons.

Data Processor: Natural or legal person who carries out the Processing of Personal Data on behalf of the Data Controller.

Data Controller: Natural or legal person who decides on the Database and/or the Processing.

Data Subject: Natural person whose Personal Data is subject to Processing.

Processing: Any operation performed on Personal Data.

Transfer: Sending of data to another Data Controller, inside or outside the country.

Transmission: Processing of Personal Data by a Data Processor on behalf of the Data Controller.

4. PROCESSING

THE COMPANY, acting as Data Controller, collects, stores, uses, circulates and deletes Personal Data of employees, shareholders, customers, suppliers, creditors and debtors.

5. PURPOSE

• Sending information to employees and their families.
• Managing relationships with customers and consumers.
• Assessing service quality.
• Determining outstanding obligations.
• Marketing, statistical and research activities.
• Responding to judicial or administrative requests.

6. RIGHTS OF DATA SUBJECTS

• To know, update and rectify their Personal Data.
• To request proof of the authorization granted.
• To be informed about how their data is used.
• To file complaints with the Superintendence of Industry and Commerce (Superintendencia de Industria y Comercio).
• To request the deletion of their data or revoke the authorization.
• To access their data free of charge.

7. RESPONSIBLE AREA

The COMMERCIAL DEPARTMENT is responsible for implementing and handling requests related to Personal Data.

8. AUTHORIZATION

THE COMPANY will request prior, express and informed authorization for the Processing of Personal Data.

9. SENSITIVE DATA

The Processing of sensitive data is prohibited unless the Data Subject has given express authorization.

10. DATA OF CHILDREN AND ADOLESCENTS

Data will only be processed where the best interests of the minor are respected.

11. PROCEDURE FOR REQUESTS AND CLAIMS

Requests may be sent to info@docm.co or to the company's physical address.

12. INFORMATION OBTAINED PASSIVELY

Cookies may be used without directly collecting Personal Data.

13. SECURITY

THE COMPANY implements technical, human and administrative measures to protect Personal Data.

14. TRANSFER AND TRANSMISSION

Data may be transferred or transmitted under contracts that guarantee its protection.

15. APPLICABLE LAW

This policy is governed by the Colombian legislation in force.

16. EFFECTIVE DATE

This Policy has been in effect since October 25, 2016.