Privacy notice and data treatment policy

NOTICE OF PRIVACY

In compliance with the General Regime of Habeas Data, regulated by Law 1581 of 2012 and its regulatory Decrees; the company ANALYTIC BOARD SAS identified with NIT. 900.363.185-6 and email address  https://www.analyticboard.com/  as a company that stores and collects personal and business data, and as RESPONSIBLE, must inform you of the following:

The personal data requested during navigation on the website  https://www.analyticboard.com/ , subdomain or domains related to it, will be treated according to the purposes related to the corporate purpose of the Company and especially to respond to concerns raised through this channel; and send information that is considered of interest through electronic newsletters. The requested personal and contact data will be kept in a company database while a contractual or legal relationship with the owner of the information is maintained.

As the owner of the information, you have the rights to know, update, and rectify your personal data; request the revocation of the authorization and/or request the deletion of the data when in the treatment carried out the principles, rights and constitutional and legal guarantees are not respected; and free access to your personal data subject to Treatment.

In case you want to present Queries, Complaints or Claims, you can make the request to the following email   comercial@ingeniosolido.com  or in person at the following address Carrera 15 # 7A-49, Medellin, Antioquia.

POLICY OF TREATMENT AND PROTECTION OF PERSONAL DATA.

In compliance with the provisions of Statutory Law 1581 of 2012 and its Regulatory Decrees, the company establishes the General and Special Policies applicable to the Treatment and Protection of Personal Data in the organization.

1. IDENTIFICATION OF THE RESPONSIBLE:

ANALYTIC BOARD SAS, a commercial company identified with NIT 900.363.185-6, is constituted as a Colombian company, whose corporate purpose is to create and design the best way to visualize and communicate the value of data, it is not enough to have data, to extract them , by analyzing them. The true value of data is generated when business users take action, this is where data visualization bridges the gap between data (Statistics, math, software) and business decisions and this is where we do our work.

● PHYSICAL ADDRESS: Carrera 15 #7A-49, Medellín, Antioquia.

● WEB PAGE:  https://www.analyticboard.com/

● EMAIL:  comercial@ingeniosolido.com

2. OBJECTIVE

This Policy establishes the general guidelines for the protection and processing of personal data within the company, thus allowing the level of trust between the person in charge and the Holders to be strengthened in relation to the processing of their information; Inform the Holders of the purposes and transfers to which their personal data are subjected and the mechanisms and forms for the exercise of their rights.

 

3. SCOPE

This Policy for the Treatment and Protection of Personal Data will be applied to all databases and/or files that include personal data that are subject to treatment by ANALYTIC BOARD SAS, as the person responsible for the treatment of personal data.

 

4. DEFINITIONS

● Habeas Data: The right that every person has to know, update and rectify the information that has been collected about them in files and data banks of a public or private nature.

● Personal data: Any information linked or that can be associated with one or several specific or determinable natural persons.

● Database: Organized set of personal data that is subject to treatment.

● Treatment: Any operation or set of operations on personal data, such as collection, storage, use, circulation or deletion.

● Authorization: Prior, express and informed consent of the Holder to carry out the processing of personal data.

● Privacy notice: It is the physical, electronic document or in any other format known or to be known, which is made available to the Owner in order to inform about the processing of their personal data.

● Holder: Natural person whose personal data is subject to treatment.

● Successor in title: Person who by succession or transmission acquires the rights of another person.

● Data Controller: Natural or legal person, public or private, that by itself or in association with others, decides on the database and/or data processing.

● Data Processor: Natural or legal person, public or private, who, by itself or in association with others, processes personal data on behalf of the data controller.

5. RIGHTS OF THE HOLDERS

The Owners of personal data will enjoy the following rights, and those granted by law:

a) Know, update and rectify your personal data in front of the person in charge of the treatment or those in charge of the treatment. This right may be exercised, among others, against partial, inaccurate, incomplete, fragmented, misleading data, or those whose treatment is expressly prohibited or has not been authorized;

b) Request proof of the authorization granted to the Data Controller except when expressly excepted as a requirement for processing, in accordance with the provisions of article 10 of the law;

c) Be informed by the person in charge of the treatment or the person in charge of the treatment, upon request, regarding the use that has been given to their personal data;

d) Submit complaints to the Superintendence of Industry and Commerce for violations of the provisions of the law and other regulations that modify, add or complement it;

e) Revoke the authorization and/or request the deletion of the data when the principles, rights and constitutional and legal guarantees are not respected in the treatment. The revocation and/or deletion will proceed when the Superintendence of Industry and Commerce has determined that in the treatment the Responsible or Manager has incurred in conduct contrary to the law and the Constitution;

f) Free access to your personal data that has been processed.

6. AUTHORIZATION OF THE HOLDER OF PERSONAL DATA

Without prejudice to the exceptions provided for in Statutory Law 1581 of 2012, as a general rule in the processing of personal data, ANALYTIC BOARD SAS, will collect the prior and informed authorization of the Holder, which may be obtained by any means that may be object of subsequent consultation.

7.1 Events in which authorization is not required

The authorization of the Holder will not be necessary in the case of:

a) Information required by a public or administrative entity in the exercise of its legal functions or by court order;

b) Data of a public nature;

c) Cases of medical or health emergency;

d) Treatment of information authorized by law for historical, statistical or scientific purposes;

e) Data related to the Civil Registry of Persons.

7. DUTIES OF ANALYTIC BOARD SAS AS RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA

ANALYTIC BOARD SAS as responsible for the processing of personal data, will fulfill the following duties:

a) Guarantee the Holder, at all times, the full and effective exercise of the right of habeas data.

b) Request and keep, under the conditions provided by law, a copy of the respective authorization granted by the Holder.

c) Duly inform the Holder about the purpose of the collection and the rights that assist him by virtue of the authorization granted.

d) Keep the information under the necessary security conditions to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access.

e) Guarantee that the information provided to the person in charge of the treatment is truthful, complete, exact, up-to-date, verifiable and understandable.

f) 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.

g) Rectify the information when it is incorrect and communicate what is pertinent to the person in charge of the treatment.

h) Provide the person in charge of processing, as the case may be, only data whose processing is previously authorized in accordance with the provisions of this law.

i) Require the Treatment Manager at all times to respect the security and privacy conditions of the Holder's information.

j) Process queries and claims formulated in the terms indicated in Statutory Law 1581 of 2012.

k) Adopt an internal manual of policies and procedures to ensure adequate compliance with the law and, in particular, for dealing with queries and claims.

l) Inform the Person in Charge of the treatment when certain information is under discussion by the Owner, once the claim has been filed and the respective procedure has not been completed.

m) Inform at the request of the Owner about the use given to their data

n) Inform the data protection authority when there are violations of the security codes and there are risks in the administration of the Holders' information.

o) Comply with the instructions and requirements issued by the Superintendency of Industry and Commerce.

 

8. Treatment of personal data of clients:

ANALYTIC BOARD SAS collects the personal data of its clients and stores them in a database which is qualified by the Company as reserved, and will only be disclosed with the express authorization of the owner or when a Competent Authority requests it.

The purposes for which the personal data of ANALYTIC BOARD SAS clients are used will be:

a) Process of control and accounting record of the obligations contracted with the clients.

b) Compliance with tax and legal aspects before public and regulatory entities.

c) Compliance with contractual obligations, for which the information may be transferred to third parties, such as financial entities, allied third parties, notaries, lawyers, etc.

d) Compliance with judicial decisions and administrative, legal, fiscal and regulatory provisions.

e) Transmission of information and personal data in audit processes.

f) Administrative management for the execution of the pre-contractual, contractual and post-contractual stages.

g) Creation of the client in the platforms or software of the Company

h) Guarantee the provision of development, production and marketing services for software projects.

i) Guarantee compliance with the rights that correspond to them by virtue of Law 1581 of 2012.

j) Carry out commercial prospecting and marketing activities.

k) Evaluate customer service and conduct satisfaction surveys.

l) Share the information with allied third parties that collaborate with the company, considering that for the fulfillment of their assignments they must access the information to some extent, which will also be subject to the obligations of confidentiality, information management and data protection. to which this company is subject.

m) Process the requests, complaints or claims established directly by the client through the customer service channels.

n) Contact the client through physical and electronic means – email, SMS or chat to send information of interest or related to the contractual relationship, invite him to training or with the portfolio of services.

o) Maintain commercial contact with the Company, even after the termination of the contractual relationship.

p) Consult as good business practice or legal obligation, Clinton and UN background, in order to prevent money laundering and financing of terrorism.

q) INCLUDE THE OTHERS THAT YOU CONSIDER ARE MISSING

In any case, the information will not be processed for a period greater than the duration of the contractual relationship between the client and the Company, and the additional time required in accordance with the legal or contractual circumstances that make it necessary to handle the data. information.

8.1 Processing of personal data of Prospective Clients:

ANALYTIC BOARD SAS has a registry of Prospective Clients, whose information has been collected by the Company with the prior express authorization of the Holder through events or through the completion of quotation requests by them. ANALYTIC BOARD SAS stores said information in a database which is qualified by the company as reserved, and will only be disclosed with the express authorization of the owner or when a Competent Authority requests it.

The purposes for which the personal data of the Prospective Clients of ANALYTIC BOARD SAS are used will be:

a) Sending invitations to events scheduled by the company.

b) Send information about projects offered by the company to interested people.

c) Verify compliance with the requirements established by the Company to access a project, agreement or contract.

d) Carry out commercial prospecting activities and marketing operations.

e) To process the queries, complaints or claims presented by the holders.

f) To make management reports and internal statistics.

g) Guarantee the exercise of your Habeas Data right (Queries, complaints and claims about updating, correcting, deleting or deleting data).

In any case, the information will not be processed for a period greater than that agreed with the prospect through an authorization to use their personal data counted from its collection in accordance with the legal or contractual circumstances that make the handling of data necessary. information.

9. PROCEDURE FOR THE ATTENTION OF INQUIRIES, CLAIMS AND REQUESTS, AND MECHANISMS TO EXERCISE THE RIGHTS OF THE HOLDERS

The Holder, his successors in title, his representative and/or proxy, or whoever is determined by stipulation in favor of another; You can exercise your rights by contacting us through written communication addressed to the administrative area in charge of the protection of personal data in the company. The communication may be sent to the following email:  comercial@ingeniosolido.com  or through written communication filed at the following address: Carrera 15 #7A-49 , Medellin, Antioquia.

12.1 Queries

The personal information of the Holder that resides in the databases of ANALYTIC BOARD SAS may be consulted and the company will be in charge of supplying all the information contained in the individual record or that is linked to the identification of the applicant.

Once the query is received by the company, it will be answered within a maximum term of ten (10) business days from the date of receipt of the query.

When it is not possible to attend the query within said term, the interested party will be informed, stating the reasons for the delay and indicating the new date on which such query will be attended, which in no case may exceed five (5) business days following upon expiration of the first term.

12.2 Claims

When it is considered that the information contained in an ANALYTIC BOARD SAS database should be corrected, updated or deleted, or when the alleged breach of any of the duties contained in the Habeas Data Law is noticed, a claim may be filed before ANALYTIC BOARD SAS which will be processed under the following rules:

1. The claim will be made by written communication addressed to ANALYTIC BOARD SAS with the identification of the Holder, the description of the facts that give rise to the claim, the address, and accompanying the documents that you want to assert.

If the claim is incomplete, the interested party will be required within five (5) days after receipt of the 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 claim has been withdrawn.

In the event that ANALYTIC BOARD SAS receives a Claim for which it is not competent to resolve it, the company will transfer it to the appropriate person within a maximum term of two (2) business days and will inform the Holder.

2. Once the complete claim is received, the company will include in the respective database a legend that says "claim in process" and the reason for it, within a term not exceeding two (2) business days. The company will keep said legend in the data object of discussion until the claim is decided.

3. The maximum term to address the claim will be fifteen (15) business days from the day following the date of receipt. When it is not possible to address the claim within said term, the company will inform the Holder of the reasons for the delay and the new date on which his claim will be addressed, which in no case may exceed eight (8) business days following the due date. of the first term.

MINIMUM CONTENT OF THE APPLICATION

The requests submitted by the owner in order to make a query or claim about the use and handling of their personal data must contain minimum specifications, in order to provide the owner with a clear and consistent response to what was requested. The application requirements are:

a) Be addressed to ANALYTIC BOARD SAS

b) Contain the identification of the Holder (Name and Identification Document).

c) Contain the description of the facts that motivate the query or claim.

d) The object of the request.

e) Indicate the notification address of the Holder, physical and/or electronic (e-mail).

f) Attach the documents that you want to assert. (Especially for claims)

In the event that the query or claim is presented in person, the Holder must express their request or claim in writing without any formality other than the requirements in the previous point.

12.3 Procedural requirement

The Holder, his successors in title, his representative and/or proxy, or whoever is determined by stipulation in favor of another; You can only file a complaint with the Superintendence of Industry and Commerce for the exercise of your rights once you have exhausted the Consultation or Claim process directly with the company.

12.4 Request for updating and/or rectification

ANALYTIC BOARD SAS will rectify and update, at the request of the owner, the information that is inaccurate or incomplete, in accordance with the procedure and the terms indicated above, for which the Owner must submit the request according to the channels provided by the company, indicating the update and rectification of the data and in turn must provide the documentation that supports such request.

13. Revocation of the authorization and/or deletion of the Data

The Holder may at any time revoke the consent or authorization given for the processing of their personal data, as long as there is no impediment enshrined in a legal or contractual provision.

Likewise, the Owner has the right to request ANALYTIC BOARD SAS at any time the deletion or elimination of their personal data when:

a) Consider that they are not being treated in accordance with the principles, duties and obligations set forth in current regulations.

b) They are no longer necessary or relevant for the purpose for which they were obtained.

c) The time necessary for the fulfillment of the purposes for which they were obtained has been fulfilled.

Such deletion implies the elimination of all or part of the personal information, in accordance with the request of the owner in the records, files, databases or treatments carried out by ANALYTIC BOARD SAS.

The right of cancellation is not absolute and therefore ANALYTIC BOARD SAS may deny revocation of authorization or elimination of personal data in the following cases:

a) The owner has a legal or contractual duty to remain in the database.

b) The elimination of data hinders judicial or administrative actions related to tax obligations, the investigation and prosecution of crimes or the updating of administrative sanctions.

c) The data is necessary to protect the legally protected interests of the owner; to carry out an action based on the public interest, or to comply with an obligation legally acquired by the owner.

14. MODIFICATION OF THE POLICIES

ANALYTIC BOARD SAS reserves the right to modify the Personal Data Treatment and Protection Policy at any time. However, any modification will be communicated in a timely manner to the owners of the personal data through the usual means of contact ten (10) business days prior to its entry into force.

In the event that a holder does not agree with the new General or special Policy and with valid reasons that constitute a just cause for not continuing with the authorization for the processing of personal data, the Holder may request the company to withdraw of your information through the channels indicated in Chapter 12. However, the Holders may not request the withdrawal of their personal data when the company has a legal or contractual duty to process the data.

15. VALIDITY

This Policy is effective as of April 2021.