1. OBJECTIVE
This document establishes the Personal Data Treatment Policies of MANUFACTURAS ELIOT S.A.S. (hereinafter, the Company), in compliance with the provisions of Law 1581 of 2012 and Decree 1377 of 2013, and it describes the mechanisms through which the Company ensures proper handling of personal data collected in its databases, in order to allow the holders to exercise the right of Habeas Data.
2.SCOPE
This policy applies to all personal information recorded in the company’s personal databases, collected through the following means i) commercial or professional relationship with the Client, Supplier and Contractors, ii) Visitors and other third parties in which MANUFACTURAS ELIOT SAS acts as RESPONSIBLE.
3.RESPONSIBLE
•Data Protection Officer
4.4. DEFINITIONS AND ABBREVIATIONS
•Authorization: Prior, express and informed consent of the Data Subject to carry out the Processing of personal data.
•Database: Organized set of personal data that is subject to Processing.
•Personal data: Any information linked or that may be associated to one or several determined or determinable natural persons.
•Processor: Natural or legal person, public or private, who by himself or in association with others, performs the Processing of personal data on behalf of the Controller.
•Controller: Natural or legal person, public or private, who by himself or in association with others, decides on the database and/or the Processing of the data.
•Data Subject: Natural person whose personal data is the object of Processing.
•Processing: Any operation or set of operations on personal data, such as collection, storage, use, circulation or deletion.
•Principle of legality: The processing of personal data is a regulated activity that must be subject to the provisions of the law and other provisions that develop it.
•Principle of purpose: Processing must obey a legitimate purpose in accordance with the Constitution and the Law, which must be informed to the Data Subject.
•Principle of freedom: Processing may only be carried out with the prior, express and informed consent of the Data Subject. Personal data may not be obtained or disclosed without prior authorization, or in the absence of legal or judicial mandate that relieves the consent.
•Principle of truthfulness or quality: The information subject to processing must be truthful, complete, accurate, updated, verifiable and understandable. The processing of partial, incomplete, fractioned or misleading data is prohibited.
•Principle of transparency: The right of the Data Subject to obtain from the Data Controller or the Data Processor, at any time and without restrictions, information about the existence of data concerning him/her, must be guaranteed in the Processing.
•Principle of restricted access and circulation: Processing is subject to the limits derived from the nature of the personal data, the provisions of the law and the Constitution. In this sense, the Processing may only be carried out by persons authorized by the Holder and/or by the persons provided for by law.
Personal data, except for public information, may not be available on the Internet or other
means of dissemination or mass communication, unless access is technically controllable to provide restricted knowledge only to the Holders or third parties authorized by law.
•Security Principle: The information subject to processing by the Data Controller or Data Processor shall be handled with the technical, human and administrative measures necessary to provide security to the records avoiding their adulteration, loss, consultation, use or unauthorized or fraudulent access.
•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 involved in the processing, and may only provide or communicate personal data when it corresponds to the development of the activities authorized by law and under the terms of the same.
5.POLICIES
MANUFACTURAS ELIOT S.A.S, recognizes that personal information is valuable and we take all reasonably necessary measures in accordance with legal requirements, in order to protect such information and prevent its loss, adulteration, unauthorized use or access while it is in our care. Notwithstanding the foregoing, the visitor should be aware that Internet security measures are not infallible.
5.1.Responsible
MANUFACTURAS ELIOT S.A.S is a legal entity under private law, domiciled in Bogota, with Nit. 860.000.452 – 6, whose contact details are as follows:
•Address: Calle 18A N.º 69B-06
•Telephone: 4055252
•E-mail: datos.personales@patprimo.co
5.2.Information Collected
In order to make purchases through our website or sign up to receive our Newsletter, we require you to provide us with certain information that includes some personal data such as: name and surname, document number or valid identification in the national territory, physical contact information to make shipments (telephone number, address, address and email) additionally to proceed with payments on our platform you must provide us with the information corresponding to your credit or debit card (credit card number, security code, name of the card holder, expiration date). You can always choose not to give us this information, but in general certain information about you is required to shop on our website or in our physical stores. Additionally, you may provide us with your information through feedback, comments and suggestions by voluntarily participating in surveys and/or answering questions sent via e-mail, in the physical store or from the website.
5.3.Security of Personal Data
MANUFACTURAS ELIOT S.A.S incorporates various physical, electronic and administrative procedures, systems and standards to safeguard the confidentiality of your personal data and protect personal information from loss, alteration or destruction. Access to your personal data is restricted. Only employees who need access to your personal data to perform a specific job are allowed access to it. In addition, all our employees are required to respect confidentiality and information security policies. Finally, the servers where MANUFACTURAS ELIOT S.A.S. stores your personal data are kept in a secure environment and comply with security standards.
5.4.Treatment
The information contained in the company’s databases is subject to different forms of treatment, such as collection, exchange, transmission or transfer, updating, processing, reproduction, compilation, storage, use, systematization and organization, all of them partially or totally in compliance with the purposes set forth herein.
In compliance with legal duties, the company may provide personal information to judicial or administrative entities.
5.5.Minors
MANUFACTURAS ELIOT S.A.S. understands the importance of protecting minors, especially in virtual environments such as the Internet. Our site is not directed to minors, who may not register and create electronic accounts, and on whom information may not be collected or received in any case, thus ensuring compliance with legal requirements.
5.6.Purpose
The information collected by MANUFACTURAS ELIOT S.A.S. has the following purpose:
•Fulfill and enforce obligations between the Company and the data owner, such as warranty and after-sales service, among others;
Evaluate preferences, experiences about products and consumption habits;
•Deliver information to manufacturers and/or importers about the products purchased for quality analysis;
•Customer loyalty;
•Carry out business intelligence actions, customer prospecting and market trends.
•To allow the proper development of its corporate purpose by carrying out all administrative, financial and marketing activities directly related to the ordinary course of business.
•Communicate information on orders placed, advertising and marketing information about the products and services offered, brokered or marketed by the Company, through physical, digital and new information technologies, such as social networks and/or instant messaging and/or virtual platforms associated with the personal data communicated (such as email and/or cell phone number); about products or services that MANUFACTURAS ELIOT S. A.S offers or comes to offer in the market, or those offered by its subsidiaries or strategic allies, according to the channel you choose to contact you.
•To use my information so that MANUFACTURAS ELIOT S.A.S. may transmit or transfer it to related companies and/or any third party that may be required in the development of the purposes mentioned herein and/or when required by any state entity.
•Use my information so that MANUFACTURAS ELIOT S.A.S. can make statistical reports.
5.7.Authorization of law 2300 of 2023 “Right to privacy of consumers”
I expressly authorize in a free, prior, voluntary and duly informed manner MANUFACTURAS ELIOT S.A.S, identified with NIT 860.000.452 – 6, located in the city of Bogotá (hereinafter “the company”), to contact me through short text messages (SMS) and/or WhatsApp and/or emails and/or phone calls, according to the contact channel I choose, and/or any other channel that MANUFACTURAS ELIOT S. A.S. has and previously informs for this purpose, in order to make collection efforts and/or send me commercial and/or advertising information, related to campaigns, promotions, contests, invitations to third party events, evaluate the quality of the products purchased, conduct market research or studies, marketing of products, among others.
I declare that in case of not choosing one or any of the means of contact provided by MANUFACTURAS ELIOT S.A.S, the Company understands that I have authorized to be contacted
by any means within the frequency and schedules established by law, finally, I declare that I have been informed of this modification.
5.8.Your Rights and Actions to Withdraw/Corrections
It is our obligation to provide you with the appropriate mechanisms so that you may review your personal information and request any of the following actions, if you so require.
In accordance with the provisions of Article 8 of Law 1581 of 2012, the holders may:
•Know, update and rectify their personal data against the company or the Processors. This right may be exercised, among others, against partial, inaccurate, incomplete, fractioned, misleading data, or data whose processing is expressly prohibited or has not been authorized.
•Request proof of the authorization granted to the Company, except when expressly exempted as a requirement for the Processing, in accordance with the provisions of Article 10 of Law 1582 of 2012.
•To be informed by the Company or the Data Processor, upon request, regarding the use that has been made of their personal data.
•File complaints before the Superintendence of Industry and Commerce for violations of the provisions of Law 1581 of 2012 and other rules that modify, add or supplement it.
•To revoke the authorization and/or request the deletion of the data when the processing does not respect the principles, rights and constitutional and legal guarantees. The revocation and/or deletion will proceed when the Superintendence of Industry and Commerce has determined that the Company or the Data Processor has incurred in conduct contrary to Law 1581 of 2012 and the Constitution.
•Access free of charge to your personal data that have been subject to processing.
5.9.Obligations of MANUFACTURAS ELIOT S.A.S, shall:
•Guarantee the Holder, at all times, the full and effective exercise of the right of habeas data.
•Request and keep, under the conditions set forth in Law 1581 of 2012, a copy of the respective authorization granted by the Data Subject.
•Duly inform the Data Subject about the purpose of the collection and the rights he/she has by virtue of the authorization granted.
•Keep the information under the security conditions necessary to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access.
•To guarantee that the information provided to the person in charge is truthful, complete, accurate, updated, verifiable and understandable.
•Update the information, communicating in a timely manner to the Data Processor, all developments with respect to the data previously provided and take other necessary measures to ensure that the information provided to this is kept up to date.
•Rectify the information when it is incorrect and communicate the relevant information to the Data Processor.
•To provide the Data Processor, as the case may be, only data whose processing is previously authorized in accordance with the provisions of Law 1581 of 2012.
•To demand from the Data Processor, at all times, respect for the security and privacy conditions of the Data Subject’s information.
•To process the queries and claims formulated in the terms set forth in Law 1581 of 2012.
•Adopt an internal manual of policies and procedures to ensure proper compliance with law 1581 of 2012 and especially for the attention of queries and claims.
•Inform the Data Controller when certain information is under discussion by the Data Subject,
once the claim has been filed and the respective process has not been completed.
•Inform at the request of the Data Subject about the use given to his/her data.
•Inform the data protection authority when there are violations to the security codes and there are risks in the administration of the information of the Data Subject.
•Comply with the instructions and requirements given by the Superintendence of Industry and Commerce.
5.10.Person or Area Responsible
Any request, complaint or claim related to the handling of personal data, in application of the provisions of Law 1581 of 2012 and Decree 1377 of 2013, should be sent to:
Contact
•Company: MANUFACTURAS ELIOT S.A.S.
•Department: BOGOTÁ D.C.
•Address: Calle 18A N.º 69B-06
•E-mail: datospersonales@patprimo.com.co
•Telephone: 4055252
5.11.Procedures for Presentation and Response to Queries, Complaints and Claims
Claims must be formulated in writing or by e-mail, according to the information contained in this document, and must contain, at least, the following information:
•Identification of the Holder.
•Description of the facts giving rise to the claim.
•Address of the holder.
•Documentation to be submitted as evidence.
If the claim is incomplete, the interested party will be required within five (5) days following receipt of the claim to correct the faults. After two (2) months from the date of the request, if the applicant does not submit the required information, it will be understood that the claim has been abandoned.
In the event that the person receiving the claim is not competent to resolve it, he/she will transfer it to the appropriate person within a maximum term of two (2) business days and will inform the interested party of the situation.
Once the complete claim has been received, a legend will be included in the database stating “claim in process” and the reason for the claim, within a term not exceeding two (2) business days. Such legend shall be maintained until the claim is decided. The maximum term to attend the claim shall be fifteen (15) business days from the day following the date of its receipt. When it is not possible to address the claim within such term, the interested party shall be informed of the reasons for the delay and the date on which the claim will be addressed, which in no case may exceed the following eight (8) working days following the expiration of the first term.
5.12.Validity of the Database
The Personal Information Processing Policies of MANUFACTURAS ELIOT S.A.S are effective as of June (1), 2017. MANUFACTURAS ELIOT S.A.S reserves the right to modify them, under the terms and with the limitations provided by law. The databases administered by the Company will be maintained indefinitely, while it develops its object, and as long as necessary to ensure compliance with obligations of a legal nature, particularly labor and accounting, but the data may be deleted at any time at the request of the holder, as long as this request does not contravene a legal obligation of MANUFACTURAS ELIOT S.A.S or an obligation contained in a contract between MANUFACTURAS ELIOT S.A.S. and The Holder.
5.13.Cookie Management and Authorization
Cookies are specific types of information that a website transmits to the hard drive of the User’s computer for record-keeping purposes. Cookies can serve to facilitate the use of a Web site by saving passwords and preferences while the User is browsing the Internet. The use of cookies can be disabled or enabled at any time by the Consumer.
We use Cookies to facilitate the navigation of consumers on our website, also to know how they interact within our platform and to be able to display advertising based on their browsing habits.
Please note that cookie preferences must be configured for each browser and that by refusing to accept a cookie you will not be able to gain access to different types of information offered by our website.
All information collected through cookies is treated as non-personal information, however, there is the possibility that the condition of this change, by the use of data that allow the profiling of the user, in this case the express acceptance will be requested.
