Data Processing Policy

INFORMATION HANDLING POLICY

BUSINESS CORPORATION SAS, identified with NIT: 900.341.678-0, domiciled at 15th Avenue No. 112-09 IN 1 L 1, Bogotá D. C, in compliance with its legal obligations contained in the Political Constitution, Law 1581 of 2012, Regulatory Decree 1377 of 2013, Decree 886 of 2014, and other related regulations, develops and implements this INFORMATION HANDLING POLICY.

DEFINITIONS:

For the elaboration, development, and implementation of this policy, the legal definition (Contained in Article 3 of Law 1581 of 2012) of the following terms is required:

a) Authorization: Prior, express, and informed consent of the Data Subject to carry out the Processing of personal data; b) Database: Organized set of personal data that is the subject of Processing; c) Personal Data: Any information linked or that can be associated with one or more specific natural persons; d) Public Data: Data classified as such according to the mandates of the law or the Political Constitution, which is not semi-private, private, or sensitive. Among others, civil status, profession or occupation, commercial or public servant status, and data that can be obtained without any reservation are public. e) Semi-private Data: Data that is not of an intimate, reserved, or public nature and whose knowledge or disclosure may be of interest not only to the Data Subject but also to a certain sector of people or society in general, such as financial and credit information. f) Private Data: Data that, due to its intimate or reserved nature, is relevant only to the Data Subject. g) Sensitive Data: Data that affects the privacy of the Data Subject or whose improper use may lead to discrimination and/or affect their integrity. h) Data Processor: Natural or legal person, public or private, who, on their own or in association with others, carries out the Processing of personal data on behalf of the Data Controller; i) Data Controller: Natural or legal person, public or private, who, on their own or in association with others, decides on the database and/or the Processing of data; j) Data Subject: Natural person whose personal data is the subject of Processing; k) Processing: Any operation or set of operations on personal data, such as collection, storage, use, circulation, or deletion. l) Privacy Notice: Notice through a physical, electronic document or in any other format generated by the Data Controller and made available or made known to the Data Subject for the Processing of their Personal Data.

DATA CONTROLLER:

In accordance with Article 13 of Decree 1377 of 2013, the following contact information is made public.

Email addresses: info@automovilesrentacar.com – Information collection channel and attention to data subjects

Website www.automovilesrentacar.com – Information collection channel and attention to data subjects.

Physical address: 15th Avenue No. 112-09 IN 1 L 1, Bogotá D. C, Colombia

Mobile Number: 3115148771, 3108036658, 3007861564 – Information collection channel and attention to data subjects

Landline: (+57) 6081749, (+57)6371503 – Information collection channel and attention to data subjects

The personal data that may eventually be collected, shared, used, or in general processed through WhatsApp will comply with data protection principles, internal labor regulations, current legislation, and strictly with this policy and the corresponding internal manual.

PROCESSING AND PURPOSE:

BUSINESS CORPORATION SAS is a legal entity dedicated to 1. acquiring, alienating, including leasing, administering, and leasing all kinds of movable and immovable property. 2. renting motor vehicles and agricultural and industrial machinery. 3. buying, selling, exporting, importing, and renting vehicles of all kinds, new and used. 4. the administration for third parties of vehicles, machinery, real estate, as well as the provision of preventive and corrective maintenance services for such assets and other activities of ground motor transport. The company may create affiliation, credit, and financing systems for the various services it provides to the public. 5. acquiring, alienating, and encumbering any title, all kinds of movable and immovable property, corporeal and incorporeal chattels, urban or rural, as well as leasing them, subleasing them, and entering into mortgages or any other form of possession or administration contracts. 6. investment in real estate at any title; or any lawful commercial or civil activity.

In the exercise of these activities, the personal data collected through the channels of attention provided for this purpose will be included in the databases managed by BUSINESS CORPORATION SAS, which collects the information for consultation, processing, and use, with the specific objective of maintaining efficient and effective communication with all third parties with whom it maintains a legal or commercial relationship, with all that this implies and with the intention of allowing:

Conducting relevant actions for the development of the company’s corporate purpose in compliance with the object of the contract entered into with the data subject Properly providing its services. Offering products and services. Maintaining constant communication. Recording operations and activities for statistical and internal management control. Promoting the development and well-being of its clients and third parties with whom it has a relationship. Handling complaints, claims, and requests. Reporting and consulting credit and commercial information to risk centers such as CIFIN and DATACREDITO by data subjects, as the case may be. Sending and receiving communications from the legal entity or individual. Executing the existing contractual relationship with its clients, suppliers, contractors, and workers, including fulfilling contractual obligations such as payment. Conducting satisfaction surveys regarding the goods and services offered.

Likewise, our clients and providers of goods or services, and other individuals as data subjects, by accepting this policy, authorize:

Ordering, cataloging, classifying, dividing, or separating the supplied information. Using for internal or commercial administrative purposes such as: advertising strategy, preparation and presentation of quotations, commercial references, satisfaction surveys, payment collection or billing by the company. Promotion of the company’s products or services. Keeping historical records of the company and maintaining contact with data subjects. Verifying, checking, or validating the supplied data. Providing the collected information to third parties with whom the company may eventually contract for the storage and management of personal data, under the security and confidentiality standards established by law.

All types of data permitted by law will be collected, without prejudice to the special provisions on sensitive data and financial information.

Likewise, workers and applicants in selection processes, in their capacity as data subjects, authorize:

Including their personal data in a database to comply with labor, social security, and occupational risk laws and in general to execute and develop the respective contract.

DATA COLLECTION:

Employees will authorize the deposit into their bank accounts, in addition to the processing of data related to commercial and financial matters, always informed about the purposes.

In cases where BUSINESS CORPORATION SAS collects information considered by law as SENSITIVE DATA, the respective procedure will be carried out according to Decree 1377 of 2013, providing the express authorization of the data subject.

In the same way, for the collection and processing of other types of data, different from sensitive and public data, in compliance with the regulatory decree, authorization will be obtained either (i) in writing or (ii) through unequivocal actions by the data subject that reasonably conclude the grant of authorization. Under no circumstances will silence be deemed unequivocal conduct.

In cases where authorization is obtained in writing, it will be attached to an internal file of BUSINESS CORPORATION SAS for later consultation. In cases where data is provided through forms on the website www.automovilesrentacar.com or through any emails, the third party and data subject, through unequivocal actions, are authorizing the use and processing of this data. However, in all cases, the duty of information will be fulfilled, and a privacy notice will be available in cases where the treatment policy is not disclosed, easily accessible on the same website.

The authorization for the processing of third-party information (suppliers, members, allies, creditors, employees, former employees, the general public) by BUSINESS CORPORATION SAS includes the possibility of sending information through:

  • Emails
  • Text messages (SMS)
  • Phone calls (mobile or landline)
  • Physical mail.

Third parties authorize the sharing of their Personal Data with credit bureaus related to BUSINESS CORPORATION SAS solely and exclusively for the execution of any contract, with the respective report in case of default or the initial consultation for credit granting. However, the data subject can, through a simple communication, reject any type of communication with advertising, promotions, or offers. In addition to the above, BUSINESS CORPORATION SAS will share and transfer information only if obliged to do so by an administrative or judicial authority.

Furthermore, the information provided voluntarily by the data subject must be truthful and complete, and it will not be used, processed, or transferred beyond the limits allowed (Law 1581 of 2012 and Decree 1377 of 2013). At any time, data subjects can restrict the authorization they have granted for any type of treatment described in this policy or revoke it.

Data subjects acknowledge that the provision of their Personal Data is voluntary, and understanding that such information will become part of a file and/or database, which may be used by BUSINESS CORPORATION SAS on the terms and for the purposes established here.

The data processing activities will be carried out primarily by BUSINESS CORPORATION SAS and its employees, but it is clarified that they may be carried out by contractors who may have access to such information, without prejudice to the responsibility that data processors may have; the main responsible party remains BUSINESS CORPORATION SAS.

BUSINESS CORPORATION SAS is obligated to store and process the information provided by data subjects securely; therefore, precautions will be taken to protect this information against loss, misuse, adulteration, unauthorized or fraudulent access or use. For reasons beyond its control, BUSINESS CORPORATION SAS is not responsible for any consequences arising from the unauthorized access of third parties to the database and/or any technical failures in the operation and/or preservation of data in the information storage system. Likewise, it cannot guarantee the accuracy of personal data, and any liability arising from any inaccuracies will be attributed to the third party who provided such information.

BUSINESS CORPORATION SAS warns that it regularly does not collect information about the use of third-party systems that enter the website, such as IP; if the server or another intermediary collects any information of this nature or similar, BUSINESS CORPORATION SAS is not responsible for such activity.

Contractors (data processors) who may have access to the Personal Data recorded in the databases managed by BUSINESS CORPORATION SAS, due to any special assignment (data processor), are contractually obliged to store, process, protect, and keep such information confidential and may not process it for any other purpose than that contractually indicated by BUSINESS CORPORATION SAS. By accepting this Policy, the purposes described in this paragraph are accepted.

With the acceptance of this policy, the Data Subject expressly authorizes the transfer and transmission of Personal Information. The information will be transferred and transmitted, for all relationships that may be established with BUSINESS CORPORATION SAS, for the development of the corporate purpose.

RIGHTS OF THE DATA SUBJECTS:

BUSINESS CORPORATION SAS will facilitate to the data subjects their right to know, update, and rectify their personal data provided to the company; likewise, in cases provided by law, they may request authorization or be informed of the means by which it was granted, as well as information regarding the treatment given to their personal data.

By virtue of the law, data subjects are empowered to file complaints with the Superintendence of Industry and Commerce for breaches of the provisions of the law. To guarantee the rights of data subjects, they may revoke the authorization granted to BUSINESS CORPORATION SAS at any time or request the deletion of the data.

Data subjects enjoy all the rights provided by the Colombian Political Constitution, Law 1581 of 2012, Regulatory Decree 1377 of 2013, and, in general, all those established in the internal legal system or in international treaties signed and ratified by the Republic of Colombia. BUSINESS CORPORATION SAS complies with current legislation.

BUSINESS CORPORATION SAS will treat the data of minors with greater care that it may collect and enter into its databases for processing. The legal representatives of minors will grant the corresponding authorization with all the precautions.

ATTENTION TO DATA SUBJECTS:

All members, contractors, and employees of BUSINESS CORPORATION SAS are authorized and obliged to attend to requests, inquiries, and complaints about data processing and the respective authorization through any of the contact channels.

PROCEDURE TO EXERCISE THE RIGHTS OF DATA SUBJECTS:

The data subject who needs to know, update, rectify, delete information, or revoke authorization for the processing of personal data, or in general, exercise any right, may send a communication to the email info@automovilesrentacar.com, fill out the DATA PROTECTION REQUEST form at any of the offices of BUSINESS CORPORATION SAS nationwide, call the number 311-5148771, or send a written communication by any suitable means to BUSINESS CORPORATION SAS.

Once the request to exercise any right is received, BUSINESS CORPORATION SAS, through its members, contractors, or employees, will provide acknowledgment of the receipt of such request by the same means it was received, without prejudice to notifying it through other channels of attention.

After the request has been received and acknowledgment given to the data subject, BUSINESS CORPORATION SAS will process the request, inquiry, or complaint to protect the rights of the data subjects in accordance with the terms of the law, with the exceptions and conditions that may apply. The process will be carried out in less than ten business days from the moment the request is received by the data subject. In cases where additional information is needed, the deadline will be twenty days, and when such information depends on a third party, the deadline will be thirty business days.

TERM:

This information processing policy will come into effect on September 1, 2018, and will be valid until any changes are made. The policy will be published on the BUSINESS CORPORATION SAS website and will be sent upon request from any data subject or third party by email, upon a minimum request of 24 hours.

BUSINESS CORPORATION SAS has the authority to modify this policy at any time without prior notice. Any modification will come into effect and have effects on the related third parties from its publication on the corresponding channel. Consequently, data subjects who have provided personal data are recommended to visit and consult the website frequently in the corresponding module to be aware of these changes.

LEGAL REPRESENTATIVE:

BUSINESS CORPORATION SAS

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