Personal Data Protection Policy Tool-be De Colombia SAS
Personal Data Protection Policy Tool-be De Colombia SAS
TOOL-BE DE COLOMBIA SAS (hereinafter TOOL-BE®), a legally constituted company, identified with NIT No. 900639346 - 1, in response to its interest in informing users about the processing of their personal data, is allowed to formulate this text in order to comply with current regulations and define the framework for dealing with queries and complaints about the processing of personal data that it collects and manages, in accordance with STATUTORY LAW 1581 OF 2012 and its decrees. regulations.
The right to Habeas Data, in accordance with the law, is 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, seeking to guarantee all citizens the decision-making power and control over your personal information. In this sense, TOOL-BE® proceeds to define these policies taking into account that for the development of its work, it must collect and have access to personal data as responsible and in charge. By virtue of this policy, TOOL-BE® undertakes to make use of the data based on a responsible treatment of personal information, for the collection, storage and development of any activity in which personal data is included. Likewise, TOOL-BE® recognizes the rights that each user has to know, update, rectify and revoke their personal data from the company's databases.
OBJECT
TOOL-BE®, through this document, establishes the mandatory guidelines and policies that will guarantee the protection of the personal data of the holders, as well as the purpose of collecting the information, the rights of the holders, the area responsible for dealing with the complaints and claims, and the procedures that must be exhausted to know, update, rectify and delete the information by the owners.
DEFINITIONS
For the purposes of this policy, the following legal definitions must be taken into account:
RESPONSIBLE FOR THE TREATMENT
It is established that the entity responsible for the processing of personal data is the company TOOL-BE DE COLOMBIA SAS, identified with NIT. Nº 900639346 - 1, with main address in the City of Medellín, at the address: Carrera 47 b # 17 a sur 42 with web page: http://tool-be.com/; email: info@tool-be.com, and with information treatment policy available at : http://tool-be.com/politica_de_datos
AREA OF APPLICATION
This document applies to all personal databases that are in the possession of TOOL-BE®, and will be applicable to personal data registered in any database that makes them susceptible to Treatment by TOOL-BE® with the limitations and restrictions that the law itself establishes, and provided that it is not public information.
BEGINNING
The TOOL-BE® personal data management policy will be governed by the following principles:
- a) Principle of legality in terms of data processing: The processing of personal data is regulated by national law and is a regulated activity that must be subject to what is established in it and in the other provisions that develop it.
- b) Principle of purpose: The Treatment must obey a legitimate purpose in accordance with the Constitution and the Law, which must be informed to the Holder.
- c) Principle of freedom: Treatment can only be exercised with the prior, express and informed consent of the Holder. Personal data may not be obtained or disclosed without prior authorization, or in the absence of a legal or judicial mandate that relieves consent.
- d) Principle of veracity or quality: The information subject to Treatment must be truthful, complete, exact, updated, verifiable and understandable. The Processing of partial, incomplete, fragmented or misleading data is prohibited.
- e) Principle of transparency: In the Treatment, the right of the Holder to obtain from the Treatment Manager or the Treatment Manager, at any time and without restrictions, information about the existence of data that concerns him or her must be guaranteed.
- f) Principle of restricted access and circulation: Treatment is subject to the limits derived from the nature of personal data, the provisions of the law and the Constitution. In this sense, the Treatment can only be done by persons authorized by the Owner and/or by the persons provided for by law.
Personal data, except public information, may not be available on the Internet or other means of disclosure or mass communication, unless access is technically controllable to provide restricted knowledge only to the Holders or third parties authorized by law.
- g) Principle of security: The information subject to Treatment by the Person Responsible for Treatment or Person in Charge of Treatment, must be handled with 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.
- h) Principle of confidentiality: All persons involved in the Processing of personal data that are not of a public nature are obliged to guarantee the confidentiality of the information, even after the end of their relationship with any of the tasks that the Treatment comprises. , being able to only supply or communicate personal data when this corresponds to the development of the activities authorized in this law and in the terms thereof.
NATURE OF PERSONAL INFORMATION COLLECTED
This personal data processing policy refers to the information that allows the owner to be identified or identifiable. This personal information includes, among others, and in the particular case of TOOL-BE®, your name, company where you work, medium to which you belong, identification number, telephone number, email address, city of residence, among others. others . Additionally, information may also be collected from different sources including, without limitation, public databases and information from third parties to whom you have given your permission to share information. This type of information that may be obtained from said sources includes, name, age, address, telephone number, position, city of residence, among others.
PURPOSE OF TOOL-BE® WITH DATABASES
TOOL-BE® is a company dedicated primarily to helping turn any adult in charge of children in their first 1000 days of life into their first and best educator for life. TOOL-BE® is a simple and revolutionary system based on movement, music and games to help children in the integral and harmonic development of their body; offers different and ingenious activities and games to be done together with the children, at home or anywhere, among others.
The company requires, for the development of its object and its relations with third parties, understood by these users, employees, suppliers, followers, creditors, among others, to constantly collect data for various purposes. In this understanding, users agree to provide the requested information for the following purposes:
- Transfer partial or total data or information to their companies, allied entities and/or between projects represented by TOOL-BE®.
- Maintain contact to inform you about services, newsletters, event programming, campaigns, and content related to the activities that it develops within its corporate purpose, in order to maintain a close and reliable link with each one.
- Extend the information obtained in the terms of the habeas data law, to the companies with which it contracts the services of capture, storage and management of its previous databases the due authorizations that it obtains in that sense, understanding in any case that This authorization is given by accepting the collection and processing of data.
- Classify, order, separate the information provided by the owner of the data.
- Carry out research, compare, verify and validate the data obtained in due form with data management centers of any kind.
- Obtain, store, compile, exchange, update, collect, process, copy, fix, reproduce and/or dispose of the data or partial or total information of those owners who grant the due authorization in the terms required by the Law and in the formats that it deems appropriate for each case, understanding in any case that this authorization is given when accepting the collection and processing of data.
- Send gifts, advertising material, merchandising, advertising items.
- Carry out activities for administrative, commercial, promotional, informative, marketing and sales purposes.
- Perform searches for a closer knowledge with all your followers, customers, suppliers, employees and linked third parties.
- Prepare market studies, georeferencing activities and statistical studies.
- Comply with the legal obligations of information to the administrative entities, as well as to the competent authorities that require it.
- Register for statistical, measurement, control and performance improvement purposes, the information regarding the actions carried out by its users; this includes and is not limited to visits to the TOOL-BE® website, the time spent on them, the links selected, the search terms entered and any other action you take to connect with the company.
- Share with third parties that collaborate with the company and that, in order to fulfill their functions, must access the information to some extent, such as messaging service providers, public or private entities, among others. On some occasions, personal information may be shared with related companies and/or with associated third-party companies to carry out the development of the company's purpose, information may also be shared if the company believes that it is reasonably necessary to protect itself or any of its users. or the general public. With the exception of what is described above, the company will never disclose Personal Information to any third party for marketing and/or advertising purposes, unless you have given your express consent for such purposes, in any case, the same will be understood to be granted with the acceptance of the terms of this policy by registering on this website.
- Any other purpose that may result in the development of the relationship between TOOL-BE® and the User Owner of personal data.
SUPPLY OF INFORMATION
In relation to the provision of information by the holder, the following considerations must be taken into account:
The owner has the right not to provide sensitive information requested by TOOL-BE® related, among others, to data on their racial or ethnic origin, data related to sexual life, health and biometric data, that is, those that allow identifying a person by their physical features, voice, movement, such as: photos, fingerprints, signatures, etc., or data related to their religious or philosophical conviction, as well as political orientation.
TOOL-BE® recommends its users to refrain from sending information of a sensitive nature that is not necessary to establish their relationship with the company.
The provision of personal data of minors is optional and must be done with the authorization of the parents or legal representatives of the minor in writing.
DUTIES OF THE DATA CONTROLLER
As TOOL-BE® data controller, you have the following duties:
- Guarantee the holder, at all times, the full and effective exercise of the right of habeas data.
- Request and keep, under the conditions provided in STATUTORY LAW 1581 OF 2012 and its regulatory decrees , a copy of the respective authorization granted by the Holder.
- Designate an area that assumes the function of personal data protection, which will process the requests of the owners.
- Insert in the database the legend "claim in process" and the reason for it, within a term not exceeding two business days following receipt of the complete claim, when this request is made by a holder.
- Refrain from circulating information that is being controversial by the owner and whose blocking has been ordered by the Superintendence of Industry and Commerce.
- Duly inform the owner about the purpose of the collection and the rights that assist him by virtue of the authorization granted.
- Keep the information under the necessary security conditions to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access.
- Guarantee that the information provided to the Treatment Manager is true, complete, accurate, updated, verifiable and understandable.
- Adopt an internal manual of policies and procedures to guarantee adequate compliance with this law and, in particular, for dealing with queries and claims.
- Update the information, communicating in a timely manner to the Person in Charge of the Treatment, all the news regarding the data that you have previously provided and adopt the other necessary measures so that the information provided to it is kept up to date.
- Rectify the information when it is incorrect and communicate what is pertinent to the Treatment Manager.
- Provide the Person in Charge of Treatment, as the case may be, only data whose Treatment is previously authorized in accordance with the provisions of STATUTORY LAW 1581 OF 2012 and its regulatory decrees.
- Require the Treatment Manager at all times to respect the security and privacy conditions of the owner's information.
- Process the queries and claims formulated in the terms indicated in the STATUTORY LAW 1581 OF 2012 and its regulatory decrees.
- Inform the Person in Charge of Treatment when certain information is under discussion by the owner, once the claim has been filed and the respective procedure has not been completed.
- Inform at the request of the owner about the use given to their data.
- Inform the Superintendency of Industry and Commerce when there are violations of the security codes and there are risks in the administration of the information of the holders.
- Comply with the instructions and requirements issued by the Superintendence of Industry and Commerce.
- Insert in the database the legend "information under judicial discussion" once notified by the competent authority about judicial processes related to the quality or details of the personal data.
- Allow access to information only to authorized persons.
RIGHTS OF THE INFORMATION HOLDER
Holders of personal data have the right to:
- Know, update and rectify personal data against TOOL-BE®, or exercise the right against whoever has received the data as a result of their transfer.
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.
- Request proof of the authorization granted to TOOL-BE®, except when expressly excepted as a requirement for Treatment.
- To be informed by TOOL-BE®, or by the Person in Charge of the treatment, upon request, regarding the use that they have given to personal data.
- Submit complaints to the Superintendency of Industry and Commerce for violations of the personal data protection regime.
- Revoke the authorization and/or request the deletion of personal data when the principles, rights and constitutional and legal guarantees are not respected in the treatment.
- Free access to the personal data that has been subject to Treatment.
- Ask about the retention and deletion times of the information, update the data.
PROCEDURES
The query and claim procedures that the holder must initiate according to their interest or need are defined below.
The area in charge within TOOL-BE® to deal with queries and complaints is the CAT Coordination Area (Tool-be® Family Support Center).
Email: info@tool-be.com . Address: Carrera 47 b # 17 to south 42.
- File the query in writing at the address: Carrera 47 b # 17 a sur 42 or email: info @tool-be.com .
- File the query through the web page of the Website http://tool-be.com/ .
When making your consultation request, you must present the following documents:
- If it is the Holder: Attach a copy of the identity document (CC, TI, CE or passport).
- If it is the successor in title: Identity document, civil registration of death of the Holder, document that proves the capacity in which he acts and the number of the holder's identity document.
- If it is a legal representative and/or proxy: Valid identity document, power of attorney that authorizes it for the procedure and the number of the holder's identity document.
The query will be answered within a maximum term of ten (10) business days counted from the filing date.
When it is not possible to attend the consultation within said term, you will be informed of the reasons for the delay and the date on which the consultation will be attended, which in no case may exceed five (5) business days following the expiration of the first term. .
The owner may access their personal data free of charge and the requested information may be provided by any means, including electronic means.
- File the claim in writing at the address: Carrera 47 b # 17 a sur 42 or email: info @tool-be.com
- File the claim through the web page of the Website http://tool-be.com/ .
When making your claim request, the owner must submit the following documents:
- If it is the Holder: Attach a copy of the identity document (CC, TI, CE or passport).
- If it is the successor in title: Identity document, civil death record of the holder, document that proves the capacity in which he acts and the number of the holder's identity document.
- If it is a legal representative and/or proxy: Valid identity document, power of attorney that authorizes it for the procedure and the number of the holder's identity document.
The request must indicate the intention to update, rectify or delete your personal information from the TOOL-BE® databases or revoke the authorization granted for the Processing of your personal data. Likewise, the request must be made clearly identifying your name, the number of your identity document and contact information (updated telephone number and email).
If the request is incomplete, you will be required within five (5) business days after receiving it to correct the faults. After two (2) months from the date of the request, without the owner submitting the required information, it will be understood that the claim has been withdrawn.
Once the complete application is received, it will be included in the database, in a term not exceeding two (2) business days, the legend "application in process" and the reason for it. Said legend will remain until the request is decided.
The maximum term to respond to the request will be fifteen (15) business days from the day following the date of receipt. When it is not possible to meet the request within said term, you will be informed of the reasons for the delay and the date on which the request will be met, which in no case may exceed eight (8) business days following the expiration of the first term. .
SECURITY OF THE INFORMATION
TOOL-BE® has adopted reasonable security measures to protect the information of the holders and prevent unauthorized access to their data or any unauthorized modification, disclosure or destruction of the same.
Access to personal data is restricted with access privileges and passwords to those employees, contractors, representatives and agents of the company in charge of data processing and who need to know them to perform their duties and develop the company's purpose.
TOOL-BE® does not allow access to information by third parties under conditions other than those announced, except at the express request of the owner of the data or legitimate persons, in accordance with national regulations.
Notwithstanding the foregoing, TOOL-BE® will not be responsible for computer attacks and, in general, any action that aims to violate the security measures established for the protection of personal data and information other than these, contained in its computer equipment or in those contracted with third parties.
TOOL-BE® does everything possible to ensure that its website and all data collection and storage tools are secure, but it is necessary that the owner refrain from: (i) creating accounts or filling out forms for other people without their authorization ; (ii) share your access data, if this applies; (iii) allow access to your account by third parties; (iv) send information that is not strictly necessary for the purposes contemplated in this policy or from third parties without your authorization; (v) provide false, incorrect or outdated information.
TOOL-BE®, reserves, in the events contemplated in the law and in its statutes and internal regulations, the power to maintain and catalog certain information that rests in its databases or databases, as confidential in accordance with current regulations, its statutes and regulations.
TOOL-BE®, will proceed, if applicable and in accordance with the current regulations and the regulations issued for this purpose by the National Government, to register its databases, before the National Registry of Databases ( RNBD) which will be administered by the Superintendence of Industry and Commerce. The RNBD is the public directory of databases subject to Treatment that operate in the country; and that it will be freely consulted by citizens, in accordance with the regulations issued by the National Government for this purpose.
PERIOD OF VALIDITY OF THE DATABASES AND THE POLICY
The TOOL-BE® databases will have a validity period that corresponds to the purpose for which their treatment was authorized or, failing that, fifty (50) years.
Additionally, this policy is effective as of October 24, 2019 and nullifies the regulations or special manuals that may have been previously adopted by TOOL-BE®.
MODIFICATION AND/OR UPDATING OF THE INFORMATION PROCESSING POLICY
TOOL-BE® informs that any substantial change to this policy will be communicated in a timely manner to the data owners through the usual means of contact.
