TREATMENT POLICY
OF PERSONAL DATA
LATIN AMERICAN SUMMIT + CTG - UCEP

1 REACH

This personal data protection policy is applicable to all databases and / or files that contain personal data that are subject to treatment by UNIÓN COLOMBIANA DE EMPRESAS PUBLICITARIAS -UCEP, as the organizing entity of + Cartagena, its contractors, strategic allies or employees.

2. IDENTIFICATION OF THE RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA

The UCEP, a non-profit trade association, with address at calle 99 # 7ª-77, office 401 of the city of Bogotá DC Email ucep.ucep@outlook.com and the company in charge of data processing, (Ángela Vélez Digital Strategic Communication SAS, ucepcol@gmail.com). Phone (+571) 6110011

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3. DEFINITIONS

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

Privacy Notice: Verbal or written communication generated by the Responsible Party, addressed to the Owner for the Treatment of their Personal Data, through which they are informed about the existence of the Information Treatment Policies that will be applicable, the way to access to the same and the purposes of the Treatment that is intended to give the personal data.

Database: Organized set of Personal Data that is subject to Treatment.

Personal Data: Any information linked or that may be associated with one or more specific or determinable natural persons.

Responsible for the Treatment: Natural or legal person, public or private, that by itself or in association with others, carries out the Treatment of Personal Data on behalf of the Responsible for the Treatment. In the events in which the Responsible Party does not act as the Manager of the Database, it will be expressly identified who will be the Manager.

Responsible for the Treatment: Natural or legal person, public or private, that by itself or in association with others, decides on the Database and / or the Treatment of the data.

Terms and Conditions: general framework in which the conditions for participants in promotional or related activities are established.

Owner: Natural person whose Personal Data are subject to Treatment.

Treatment: Any operation or set of operations on Personal Data, such as the collection, storage, use, circulation or deletion.

Transfer: The data transfer takes place when the Responsible and / or Person in Charge of the Treatment 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: Processing 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 Person in Charge on behalf of the Responsible.

4. TREATMENT

THE UCEP, acting as Responsible for the Treatment of Personal Data, for the proper development of activities related to the dissemination, marketing and promotion of participations of attendees and commercial alliances of or for the Summit + Cartagena, collects, stores, uses, circulates and deletes Personal Data corresponding to natural persons with whom it has or has had a relationship, such as, without the enumeration implying limitation, workers and relatives of these, shareholders, consumers, clients, distributors, suppliers, creditors and debtors.

5. PURPOSE

Personal Data are processed by THE UCEP for the following purposes:

5.1. To send information to its workers, contractors, affiliates, and potential market of the Summit + Cartagena;

5.2. For the strengthening of relationships with its affiliates, companies, individuals and legal entities of the advertising sector, among others, by advertising agencies, media agencies without considering the transmission medium, advertisers, BTL companies, academia and students of the same sectors; National or international associations or organizations to which they belong, by sending relevant information, taking requests and handling Petitions, Complaints and Claims (PQR's), evaluating the quality of their service and inviting and information on events organized or sponsored by the association, among others, but especially the Latin American summit "+ Cartagena"

5.3. For the interaction with its suppliers, for the fulfillment of its legal obligations with its workers;

5.4. To consolidate a timely and quality supply with its Suppliers, through the invitation to participate in selection processes, the evaluation of compliance with their obligations and the invitation to events organized or sponsored by THE UCEP, among others;

5.5. To verify the balances of your creditors during the operation and performance of + Cartagena;

5.6. For the determination of pending obligations, the consultation of financial information and credit history and the report to information centers of unfulfilled obligations, with respect to its debtors; insofar as they relate to the operation and realization of + Cartagena.

5.7. To improve, promote and develop its services and those of its affiliates;

5.8. For marketing activities, statistics, research and other purposes that do not contravene current legislation in Colombia;

5.9. For the attention of judicial or administrative requirements and the fulfillment of judicial or legal mandates;

5.10. To eventually contact, via email, or by any other means, people with whom he has or has had a relationship, such as, without the enumeration implying limitation, workers and relatives of these affiliates, consumers, public authorities; equivalent national and international associations, distributors, suppliers, creditors and debtors, as well as other interest groups, for the aforementioned purposes.

5.11. To be used by commercial allies authorized by THE UCEP, for the purpose of promoting their relationship with + CTG for a term of 3 months, from September 2020 to November 2020, inclusive.

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6. RIGHTS OF THE HOLDERS OF PERSONAL DATA

The natural persons whose Personal Data are subject to Treatment by THE UCEP, have the following rights, which they can exercise at any time:

6.1. Know the Personal Data on which THE UCEP is carrying out the Treatment. Similarly, the Owner may request at any time that their data be updated or rectified, for example, if they find that their data is partial, inaccurate, incomplete, fractioned, misleading, or those whose Treatment is expressly prohibited or not. has been authorized.

6.2. Request proof of the authorization granted to THE UCEP for the Processing of your Personal Data.

6.3. Be informed by THE UCEP, upon request, regarding the use that it has given to your Personal Data.

6.4. Submit complaints to the Superintendency of Industry and Commerce for violations of the provisions of the Law on Protection of Personal Data.

6.5. Request the UCEP to delete your Personal Data and / or revoke the authorization granted for the Treatment thereof, by submitting a claim, in accordance with the procedures established in paragraph 11 of this Policy. However, the request for the 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, nor while the relationship between the Owner and THE UCEP, by virtue of which your data was collected.

6.6. Free access to your Personal Data subject to Treatment.

7. AREA RESPONSIBLE FOR THE IMPLEMENTATION AND OBSERVANCE OF THIS POLICY

The UCEP is in charge of the development, implementation, training and observance of this Policy. For this purpose, all its officials and contractors who participate in acts of Personal Data Processing in the different areas of THE UCEP, are obliged to report these Data Bases to the General Secretariat of the UCEP and to transfer it immediately. , of all requests, complaints or claims that they receive from the Personal Data Holders.

The General Secretariat of the UCEP is the area responsible for the attention of requests, queries, complaints and claims before which the Holder of the information may exercise their rights to know, update, rectify and delete the data and revoke the authorization.

8. AUTHORIZATION

THE UCEP must request prior, express and informed authorization from the Holders of the Personal Data on which it is required to carry out the Treatment.

8.1. Prior authorization means that consent must be granted by the Holder, at the latest at the time of the collection of Personal Data.

8.2. Express authorization means that the consent of the Holder must be explicit and concrete, open and non-specific authorizations are not valid. The Holder is required to express his willingness to authorize THE UCEP to process his Personal Data.

This manifestation of the will of the Holder can be given through different mechanisms made available by THE UCEP, such as:

  • In writing, for example, by filling out an authorization form such as that indicated in Annex 1.

  • Orally, for example, in a telephone conversation or in a video conference.

Through unequivocal behaviors that allow to conclude that you granted your authorization, for example, through your express acceptance of the Terms and Conditions of an activity within which the authorization of the participants is required for the Treatment of their Personal Data.

IMPORTANT: In no case will THE UCEP assimilate the Holder's silence to unequivocal conduct.

Whatever the mechanism used by the UCEP, it is necessary that the authorization be kept in order to be consulted later.

8.3. Informed Authorization means that at the time of requesting the consent of the Holder, he must be clearly informed:

  • The Personal Data that will be collected.

  • The identification and contact details of the Responsible and the Person in Charge of Treatment.

  • The specific purposes of the Treatment that is intended to be carried out, that is: how and for what the collection, use, and circulation of Personal Data will be done.

  • What are the rights you have as the Owner of Personal Data; For this purpose, see numeral 6 of this Policy.

  • The optional nature of the answer to the questions that are asked, when these relate to sensitive data or the data of girls, boys and adolescents.

9. SPECIAL PROVISIONS FOR THE TREATMENT OF PERSONAL DATA OF A SENSITIVE NATURE.

In accordance with the Personal Data Protection Law, data of a sensitive nature are those that affect privacy or whose improper use may generate discrimination, such as those related to:

  • Racial or ethnic origin.

  • Political orientation.

  • Religious / philosophical convictions.

  • Membership of trade unions, social organizations, human rights organizations or political parties.

  • Health.

  • Sex life.

  • Biometric data (such as fingerprint, signature, and photo).

The Treatment of Personal Data of a sensitive nature is prohibited by law, unless there is express, prior and informed authorization from the Holder, 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, THE UCEP must:

  • Inform the Holder that because it is sensitive data, he is not obliged to authorize its Treatment.

  • Inform the Holder which of the data that will be processed are sensitive and the purpose of the Treatment.

IMPORTANT: No activity may be conditioned on the Holder providing sensitive Personal Data.

10. SPECIAL PROVISIONS FOR THE PROCESSING OF PERSONAL DATA OF CHILDREN AND ADOLESCENTS

According to the provisions of Article 7 of Law 1581 of 2012 and Article 12 of Decree 1377 of 2013, THE UCEP will only carry out the Treatment, that is, the collection, storage, use, circulation and / or deletion of Personal Data corresponding to children and adolescents, as long as this Treatment responds to and respects the best interests of children and adolescents and ensures respect for their fundamental rights.

Once the above requirements have been fulfilled, the UCEP must obtain the Authorization of the legal representative of the child or adolescent, prior to the exercise of the minor's right to be heard, an opinion that will be valued taking into account the maturity, autonomy and ability to understand the matter.

11. PROCEDURE FOR ATTENTION AND RESPONSE TO REQUESTS, CONSULTATIONS, COMPLAINTS AND CLAIMS OF THE HOLDERS OF PERSONAL DATA

The Holders of the Personal Data that are being collected, stored, used, circulated by THE UCEP, 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 Personal Data Protection Law:

11.1. ATTENTION AND RESPONSE TO REQUESTS AND INQUIRIES:

What does the procedure consist of?

The Holder or his successors in title may request the UCEP, through the means indicated below:

  • Information on the Personal Data of the Holder that are subject to Treatment.

  • Request proof of the authorization granted to THE UCEP for the Processing of your Personal Data.

  • Information regarding the use that has been given by THE UCEP to your personal data.

Means enabled for the presentation of petitions and inquiries:

THE UCEP has provided the following means for the reception and attention of requests and inquiries, all of which allow us to keep proof of them:

Requests and inquiries will be answered within a maximum term of ten (10) business days from the date of receipt. When it is not possible to attend the request or query within said term, the interested party will be informed, stating the reasons for the delay and indicating the date on which their request or query will be attended, which in no case may exceed five (5) business days following the expiration of the first term.

11.2. ATTENTION AND RESPONSE TO COMPLAINTS AND CLAIMS:

What does the procedure consist of?

The Holder or his successors in title, may request the UCEP, through a complaint or claim presented through the channels indicated below:

  • The correction or updating of the information.

  • The deletion of your Personal Data or the revocation of the authorization granted for the Treatment of the same.

  • That the alleged breach of any of the duties contained in the Personal Data Protection Law be remedied or corrected.

The request must contain the description of the facts that give rise to the complaint or claim, the address and contact information of the applicant, and must be accompanied by the documents that are to be asserted.

Means enabled for the presentation of complaints and claims:

THE UCEP has provided the following means for the reception and attention of complaints and claims, all of which allow us to keep proof of their presentation:

Attention and response from THE UCEP:

If the complaint or claim is presented incomplete, the UCEP must require the interested party within five (5) days following receipt of the complaint or claim to correct the faults. After two (2) months from the date of the request, without the applicant submitting the required information, it will be understood that the complaint or claim has been withdrawn.

In the event that whoever receives the complaint or claim is not competent to resolve it, it will transfer it to the administration; within a maximum term of two (2) business days and will inform the interested party of the situation.

Once the complaint or complete claim is received, a legend that says "claim in process" and the reason for it will be included in the Database, within a term of no more than two (2) business days. Said legend shall be kept until the complaint or claim is decided.

The maximum term to address 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 business following the expiration of the first term.

12. INFORMATION OBTAINED IN A PASSIVE FORM

When the services contained within the websites of LA UCEP are accessed or used, it may collect information passively through information management technologies, such as "cookies", through which information is collected about of the hardware and software of the equipment, IP address, type of browser, operating system, domain name, access time and the addresses of the websites of origin; Through the use of these tools, no personal data is directly collected from users. Information about the pages that the person visits most frequently on these websites will also be collected in order to know their browsing habits. However, the user of the websites of LA UCEP has the possibility of configuring the operation of "cookies", according to the options of their internet browser.

13. SECURITY OF PERSONAL DATA

The UCEP, in strict application of the Principle of Security in the Treatment 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 THE UCEP is limited to having the appropriate means for this purpose. THE UCEP does not guarantee the total security of your information nor is it responsible for any consequence derived from technical failures or improper entry by third parties to the Database or File in which the Personal Data subject to Treatment by THE UCEP rests. and its Managers. The UCEP will 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.

14. TRANSFER, TRANSMISSION AND DISCLOSURE OF PERSONAL DATA

THE UCEP may deliver the Personal Data to third parties not linked to THE UCEP when: a. In the case of contractors in the execution of contracts for the development of the activities of the UCEP in relation to + Cartagena and in its capacity as organizer; b. By transfer to any title of any business line to which the information relates. C. For the purposes of promotion and marketing and other registration and participation processes in the + Cartagena summit. C. The personal data referred to in this policy and the responsibilities and ownership thereof may be transferred by THE UCEP to a third party, who in turn may act as the organizer of the Summit + Cartagena. In that case, the corresponding entity will adopt the corresponding policy and update those responsible for handling and processing the data.

In any case, in the contracts for the transmission of Personal Data, which are signed between THE UCEP and those in charge of the Processing of Personal Data, it will be required that the information be treated in accordance with this Personal Data Protection Policy and the following will be included obligations in the head of the respective Manager:

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  • Give Treatment, on behalf of THE UCEP to Personal Data in accordance with the principles that protect them.

  • Safeguard the security of the databases in which Personal Data is contained.

  • Keep confidentiality regarding the Treatment of Personal Data.

15. APPLICABLE LEGISLATION

This Personal Data Protection Policy, the Privacy Notice and the Authorization Form that is part of this Policy as Annex 1, are governed by the provisions of current legislation on the protection of Personal Data referred to in Article 15 of the Political Constitution of Colombia, Law 1266 of 2008, Law 1581 of 2012, Decree 1377 of 2013, Decree 1727 of 2009 and other regulations that modify, repeal or replace them.

16. VALIDITY

This Personal Data Protection Policy is in force since January 1, 2017 and replaces the one previously published on the UCEP website and in force to date.