Privacy policies

PERSONAL DATA PROCESSING POLICY

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

1. IDENTIFICATION OF THE RESPONSIBLE

IMAGE AND PRESS SAS., with NIT 900353048-2, whose main purpose is the following activities:

Public relations

Communication strategies, free press and advertising
Media monitoring
Media analysis
Alliances with government entities and NGOs
Spokesperson training and visualization
Work shops
Press conferences
Spokesperson Media Tour
Corporate dissemination and press campaigns

Events

Conventions
Academic events
Product launch
BTL campaigns
Corporate and marketing events

Digital marketing

Communication strategies
Web content
Style correction
Public relations campaigns
Social media manager
SEO Positioning
Storytelling
Technical and editorial optimization of websites
Free Press
Graphic design
Writing and editing of books
Web and online store design
e-PR: campaigns with influencers
Web projects
Blog creation
Mail marketing

Business consulting

Marketing studies
Business conferences and
Strategic Alliances

Corporate communication

Internal and external communication
Risk management and crisis management
Social responsibility campaigns
Editorial content development
Brand: Branding, naming, corporate identity, storytelling and storydoing.
Audiovisual production

Sale of videos and photos

Sale Image&Press gift voucher

Any of the activities referred to in this corporate purpose may be carried out both nationally and internationally, either directly or through or with the help of third parties. in development and to fulfill its main corporate purpose, it may deploy the necessary mechanisms for access to its own resources that have the purpose of developing the corporate purpose, mainly through leverage activities, sale of the originated portfolio and linking shareholders with economic rights to society; Likewise, it may carry out treasury operations with its surplus liquidity, participate in other companies, participate in merger or spin-off processes or any type of administrative or managerial reorganization.

You may also enter into any guarantee agreement, whether in the country or abroad and in general all businesses, acts and operations directly related to the corporate purpose and all those whose purpose is to exercise rights and comply with legal or commercial obligations. , derived from the existence and activities of the company.

2. OBJECTIVE

This Policy establishes the general guidelines for the protection and processing of personal data within the agency, thus allowing us to strengthen the level of trust between the Controller and Owners in relation to the processing of their information. Inform the Owners 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 Personal Data Treatment and Protection Policy will be applied to all databases and/or files that include personal data that are subject to processing by IMAGE & PRESS SAS as responsible for the processing of personal data.

4. DEFINITIONS

Habeas Data: The right of every person 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 processing.

Processing: 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 Owner to carry out the processing of personal data.

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

Owner: Natural person whose personal data is processed.

Incumbent: Person who, by succession or transmission, acquires the rights of another person.

Responsible for the Treatment: Natural or legal person, public or private, who alone or in association with others, decides on the database and/or the processing of the data.

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

5. GUIDING PRINCIPLES APPLICABLE REGARDING PERSONAL DATA

In terms of personal data protection, the following guiding principles will apply:

Principle of legality in matters of data processing: The processing referred to in the Habeas Data Law is a regulated activity that must be subject to what is established in it and in the other provisions that develop it.

Principle of purpose: The treatment must obey a legitimate purpose in accordance with the Constitution and the Law, which must be informed to the Owner.

Principle of freedom: Treatment can only be carried out with the prior, express and informed consent of the Owner. Personal data may not be obtained or disclosed without prior authorization or in the absence of a legal or judicial mandate that requires consent.

Principle of truthfulness or quality: The information subject to processing must be truthful, complete, exact, updated, verifiable and understandable. The processing of partial, incomplete, fragmented or misleading data is prohibited.

Principle of transparency: In the treatment, the right of the Owner to obtain from the person responsible for the treatment or the person in charge of the treatment, at any time and without restrictions, information about the existence of data that concerns him or her must be guaranteed.

Principle of restricted access and circulation: The 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 Owner and/or by the persons provided for in the Law. Personal data, except public information, may not be available on the Internet or other means of dissemination or mass communication. unless access is technically controllable to provide knowledge restricted only to the Owners or authorized third parties in accordance with the Law.

Security principle: The information subject to processing by the data controller or data processor referred to in the Habeas Data Law must be handled with the technical, human and administrative measures that are necessary to provide security to the records, avoiding their adulteration, loss, unauthorized or fraudulent consultation, use or access.

Principle of confidentiality: All persons involved in the processing of personal data that are not public in nature are obliged to guarantee the confidentiality of the information, even after their relationship with any of the tasks included in the processing has ended, and may only supply or communicate personal data when this corresponds to the development of the activities authorized in the Law and in the terms thereof.

6. RIGHTS OF THE OWNERS

The Holders of personal data will enjoy the following rights, and those granted to them by Law:

Know, update and rectify your personal data in front of the person responsible for 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 processing is expressly prohibited or has not been authorized.

Request proof of the authorization granted to the person responsible for the treatment except when it is expressly excepted as a requirement for the treatment, in accordance with the provisions of article 10 of the Law.

Be informed by the person responsible for the treatment or the person in charge of the treatment, upon request, regarding the use that has been given to your personal data.

Submit complaints to the Superintendency of Industry and Commerce for violations of the provisions of the Law and other regulations that modify, add or complement it.

Revoke the authorization and/or request the deletion of the data when the processing does not respect the constitutional and legal principles, rights and guarantees. The revocation and/or deletion will proceed when the Superintendency of Industry and Commerce has determined that in the processing the person responsible or in charge has engaged in conduct contrary to the Law and the Constitution.

Access free of charge to your personal data that has been processed.

7. AUTHORIZATION OF THE OWNER 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 IMAGE & PRESS SAS will collect prior and informed authorization from the Owner, which may be obtained by any means that may be subject to for later consultation.

7.1 Events in which authorization is not necessary

The authorization of the Owner will not be necessary when it comes to:

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

Public data

Medical or health emergency cases

Processing of information authorized by Law for historical, statistical or scientific purposes

Data related to the Civil Registry of Persons

8. DUTIES OF IMAGE & PRESS SAS AS CONTROLLER FOR THE PROCESSING OF PERSONAL DATA

IMAGE & PRESS SAS, as responsible for the processing of personal data, will fulfill the following duties:

Guarantee to the Holder at all times the full and effective exercise of the right of habeas data.

Request and keep, under the conditions provided for in the Law, a copy of the respective authorization granted by the Owner.

Duly inform the Owner about the purpose of the collection and the rights granted to him by virtue of the authorization granted.

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

Guarantee that the information provided to the Data Processor is true, complete, accurate, updated, verifiable and understandable.

Update the information, communicating in a timely manner to the Data Processor, all the news regarding the data that you have previously provided and adopt the other necessary measures so that the information provided to it remains updated.

Rectify the information when it is incorrect and communicate the pertinent information to the Data Processor.

Provide the Data Processor, as applicable, only data whose processing is previously authorized in accordance with the provisions of this Law.

Demand that the Data Processor at all times respect the security and privacy conditions of the Owner's information.

Process queries and claims made in the terms indicated in Statutory Law 1581 of 2012.

Adopt an internal manual of policies and procedures to guarantee adequate compliance with the Law and, especially, to respond to queries and complaints.

Inform the Data Processor when certain information is under discussion by the Owner, once the claim has been submitted and the respective process has not been completed.

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

Inform the data protection authority when violations of security codes occur and there are risks in the administration of the Owners' information.

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

SPECIFIC POLICIES FOR THE PROCESSING OF PERSONAL DATA.

9.1 Processing of personal data of Employees

IMAGE & PRESS SAS collects the personal data of its Workers , which are classified by the agency as reserve, and will only be revealed by the agency with the express authorization of the owner or when a Competent Authority requests it.

The purposes for which the personal data of the agency's employees are used will be:

Comply with the obligations imposed by the Colombian Labor Law on employers, or the orders issued by the competent Colombian authorities.
Issue certifications related to the relationship of the data owner with the agency.
Comply with the obligations imposed on the agency as an employer, in relation to Occupational Health and Safety standards, and the so-called Occupational Health and Safety Management System (SGSST).
Manage the functions carried out by workers.
Consult memos or calls for attention.
Develop and apply the disciplinary process.
Contact family members in emergency cases.
Payroll, payment and accounting processes
Fiscal and judicial reports and other reports required by the authorities.
In accordance with the provisions of External Circular 008 of 2020 of the Superintendence of Industry and Commerce, the data collected to comply with biosafety protocols will only be used for the purposes indicated by the Ministry of Health and Social Protection, and will only be used. They will be stored for the reasonable time necessary to comply with said protocols. Once the purpose of the Personal Data Processing has been fulfilled, the organization will automatically delete the data collected.

IMAGE & PRESS SAS stores the personal data of its employees, including those obtained during the selection process, and keeps them in a folder identified with the name of each of them.

This folder will only be accessed and processed by the Human Resources Area, for the purpose of managing the contractual relationship between IMAGE & PRESS SAS and the employee.

IMAGE & PRESS SAS will store sensitive data of its workers. For the purposes of this processing, the respective authorization is collected, which in any case will be express and optional, clearly indicating the sensitive data subject to processing and its purpose.

Additionally, the agency processes Sensitive Personal Data of its workers such as the data of their minor children, with the sole purpose of registering them as beneficiaries of the social security and parafiscal system. For the purposes of this Treatment, the respective authorization is collected, which in any case will be express and optional, clearly indicating the sensitive personal data subject to processing and the purpose thereof.

Likewise, it will have high security systems for the management of sensitive data and its reservation, with the understanding that such sensitive data will only be used by IMAGE & PRESS SAS for the aforementioned purposes.

Once the employment relationship has ended, IMAGE & PRESS SAS will proceed to store all the personal data obtained from the selection process and the documentation generated in the development of the employment relationship, in a central file with restricted access, subjecting the information to measures at all times. and adequate security levels, given that employment information may contain sensitive data.

In any case, the information will not be processed for a period of more than twenty (20) years from the termination of the employment relationship or in accordance with the legal or contractual circumstances that make the handling of the information necessary.

9.3 Processing of personal data of candidates or applicants for selection processes.

IMAGE & PRESS SAS collects the personal data of its applicants and stores them in a database which is classified by the agency as reserved, and will only be revealed with the express authorization of the owner or when a Competent Authority requests it.

The purposes for which the personal data of IMAGE & PRESS SAS applicants are used will be:

Carrying out procedures for the personnel selection process.

Sending communications programmed by the agency, to carry out different selection tests.
Corroborate the information provided by the applicant during the selection process.

General connection of each applicant.

In any case, the information will not be processed for a period longer than the duration of the applicant's relationship with the agency, and the additional time required in accordance with the legal or contractual circumstances that make the handling of the information necessary. .

9.4 Processing of personal data of Clients

IMAGE & PRESS SAS collects the personal data of its Clients and stores them in a database which is classified by the agency as reserve, and will only be revealed with the express authorization of the owner or when a Competent Authority requests it.

The purposes for which the personal data of IMAGE & PRESS SAS Clients are used will be:

Carrying out procedures for the pre-contractual, contractual and post-contractual stages.

Sending invitations to events scheduled by the agency.

Corroborate any requirement that arises in the development of the concluded contract.

Comply with the purpose of the concluded contract.

Verify cases in which there is non-compliance by any of the parties.

General linkage of each client.

Carry out customer loyalty activities and marketing and public relations operations.

Information about the agency's product offering.

In any case, the information will not be processed for a period greater than the duration of the client's relationship with the agency, and the additional time required in accordance with the legal or contractual circumstances that make the handling of the information necessary. .

9.5 Processing of personal data of Prospective clients:

IMAGE & PRESS SAS collects personal data from participants in surveys carried out for statistical and commercial purposes, with which it seeks to find or establish marketing strategies for its clients.

The purposes for which the personal data contained in the participant surveys carried out by IMAGE & PRESS SAS are used will be:

Collect information that allows you to implement marketing campaigns.

Analysis of the information collected that allows the implementation of commercial statistics.

Analyze the profile of legal or natural persons in the development of commercial processes.

In any case, the information will not be processed for a period longer than the duration of the employment relationship with the employee and in accordance with the legal or contractual circumstances that make the handling of the information necessary.

9.6 Processing of personal data of Suppliers and contractors

IMAGE & PRESS SAS collects the personal data of its suppliers and contractors and stores them in a database which, although it is made up mostly of public data, is classified by the company as reserved, and which, in the case of Private data will only be revealed by the agency with the express authorization of the owner or when a Competent Authority requests it.

The purposes for which the personal data of IMAGE & PRESS SAS suppliers and contractors are used will be:

Sending invitations to contract and carrying out procedures for the pre-contractual, contractual and post-contractual stages.

Creation of the accounting record as an agency supplier.

Payment processes and their respective accounting.

Request, custody of social security reports required to process the payment.

Judicial, fiscal and other reports. The others specifically established in the authorizations granted by the suppliers and contractors themselves.

In accordance with the provisions of External Circular 008 of 2020 of the Superintendence of Industry and Commerce, the data collected to comply with biosafety protocols will only be used for the purposes indicated by the Ministry of Health and Social Protection, and will only be used. They will be stored for the reasonable time necessary to comply with said protocols. Once the purpose of the Personal Data Processing has been fulfilled, the organization will automatically delete the data collected.

IMAGE & PRESS SAS . It will only collect from its suppliers and contractors the data that is necessary, relevant and not excessive for the purposes of selection, evaluation and execution of the contract that may arise.

The collection of personal data of employees of suppliers and contractors by IMAGE & PRESS SAS will in all cases have the purpose of verifying the suitability and competence of the contractors and suppliers; That is, once this requirement has been verified, IMAGE & PRESS SAS will return such information to the supplier and contractors, except when its conservation is expressly authorized.

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

9.7 Processing of personal data of Shareholders:

IMAGE & PRESS SAS collects the personal data of its Shareholders and stores them in a database which is classified by the company as reserved, and which will only be revealed by the agency with the express authorization of the owner or when a Competent Authority so requires. I requested.

The purposes for which the personal data of the Shareholders are used will be:

Allow the exercise of the duties and rights derived from membership.

Allow sending invitations to events scheduled by the company

Issue certifications related to the relationship of the Owner with the company

In any case, the information will not be processed for a period greater than that established through the authorization granted by the shareholder to use their personal data starting from its collection in accordance with the legal or contractual circumstances that make the processing necessary. information management.

9.9 Processing of personal data of Journalists and Influencers

IMAGE & PRESS SAS collects the personal data of journalists and influencers and stores it in a database, which is classified by the company as confidential, and which will only be revealed by the agency with the express authorization of the owner or when an Authority Competently ask for it.

The purposes for which the personal data of journalists and influencers are used will be:

Sending invitations to contract and carrying out procedures for the pre-contractual, contractual and post-contractual stages.

Creation of the accounting record as contractors of the agency.

Payment processes and their respective accounting.
Request, custody of social security reports required to process the payment.

Judicial, fiscal and other reports.

The others specifically established in the authorizations granted by the suppliers and contractors themselves.

To send invitations to events scheduled by the agency.

Review of the social networks or media in which each journalist or influencer works, in order to validate the suitability and compliance with the contract or commercial agreement with the agency.

Send the respective information to the execution of the contract or commercial agreement.

Sending gifts from our clients.

In any case, the information will not be processed for a period longer than that established through the authorization granted by the shareholder to use their personal data starting from its collection in accordance with the legal or contractual circumstances that make the handling necessary. of the information.

10 INTERNATIONAL TRANSFER AND TRANSMISSION OF PERSONAL DATA

IMAGE & PRESS SAS currently does not carry out International Transmission or Transfer of personal data. In the event that the agency decides to carry out the International Transfer of personal data, in addition to having express and unequivocal authorization from the Owner, it will ensure that the action provides adequate levels of data protection and meets the requirements established in Colombia. by Statutory Law 1581 of 2012 and its regulatory decrees. On the other hand, when the agency decides to carry out International Data Transmission, it may do so without authorization from the owners, as long as it guarantees the security of the information, confidentiality and the conditions that regulate the scope of data processing, in accordance with the article 10 of Law 1581 of 2012.

11 DATA ABOUT BOYS, GIRLS AND ADOLESCENTS

IMAGE & PRESS SAS does not directly process the personal data of minors. However, in particular, the agency collects and processes the personal data of the minor children of its workers, with the sole purpose of complying with the obligations imposed by the Law on employers in relation to affiliations with the social security system. and parafiscal, and in particular to allow the enjoyment of children's fundamental rights to health and recreation.

In any case, IMAGE & PRESS SAS will collect, when appropriate, the respective authorization for their treatment, always keeping in mind the best interests of the minor and respect for the prevailing rights of children and adolescents.

12 PROCEDURE FOR ATTENDING QUERIES, CLAIMS AND PETITIONS, AND MECHANISMS TO EXERCISE THE RIGHTS OF THE OWNERS

The Owner, his successors, his representative and/or attorney, or whoever is determined by stipulation in favor of another may exercise their rights by contacting us through written communication addressed to the area in charge of the protection of personal data in the company. . The communication can be sent to the email: ip@imageandpress.com

12.1 Claims

When it is considered that the information contained in an IMAGE & PRESS SAS database must be corrected, updated or deleted, or when the alleged non-compliance with any of the duties contained in the Habeas Data Law is noted, claim before IMAGE & PRESS SAS which will be processed under the following rules:

The claim will be formulated by written communication addressed to IMAGE & PRESS SAS with the identification of the Owner, the description of the facts that give rise to the claim, the address, along with the supporting documents.

If the claim is incomplete, the interested party will be required within five (5) business days following receipt of the claim to correct the deficiencies. After two (2) months from the date of the request, without the applicant presenting the required information, it will be understood that the claim has been abandoned.

In the event that IMAGE & PRESS SAS receives a Claim for which it is not competent to resolve, the agency will notify the person who actually corresponds within a maximum period of three (3) business days and will inform the Owner.

The maximum term to address the claim will be fifteen (15) business days counted from the day following the date of receipt. When it is not possible to address the claim within said term, the agency will inform the Owner of the reasons for the delay and the new date on which the claim will be addressed.

12.3 Procedureability requirement

The Owner, his successors, his representative and/or attorney-in-fact, or whoever is determined by stipulation in favor of another; You may only file a complaint with the Superintendency of Industry and Commerce for the exercise of your rights once you have exhausted the Consultation or Claim process directly with the agency.

12.4 Request for update and/or rectification

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

12.5 Revocation of authorization and/or deletion of Data

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

Likewise, the Owner has the right to request IMAGE & PRESS SAS at any time:

Consider that they are not being treated in accordance with the principles, duties and obligations provided for in current regulations.

They have ceased to be necessary or relevant for the purpose for which they were obtained.

The time necessary to fulfill the purposes for which they were obtained has elapsed.

Such deletion implies the elimination of either total or partial personal information, in accordance with what is requested by the owner in the records, files, databases or treatments carried out by IMAGE & PRESS SAS.

The right of cancellation is not absolute and therefore IMAGE & PRESS SAS may deny revocation of authorization or deletion of personal data in the following cases:

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

The deletion of data hinders judicial or administrative actions linked to tax obligations, the investigation and prosecution of crimes or the updating of administrative sanctions.

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.

13 MODIFICATION OF POLICIES

IMAGE & PRESS 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 an owner 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 Owner may request the agency to withdraw it. of their information through the channels indicated in Chapter 12. However, the Owners may not request the withdrawal of their personal data when the agency has a legal or contractual duty to process the data.

14 VALIDITY

This Policy applies from January 2023