PRIVACY, PERSONAL DATA TREATMENT, AND PROTECTION POLICY
FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S. is responsible for the personal data and information provided by its clients, suppliers, contractors, collaborators, and visitors (hereinafter, the Holders). The Privacy Policy hereunder sets forth the purposes, measures, and procedures of FLÓREZ & ASOCIADOS ASESORES JURÍDICOS SAS databases, as well as the mechanisms with which the Holders must know, update, rectify, suppress the data provided or revoke the authorization granted with the acceptance of the Privacy Policy herein. The acceptance of proposals, the entering into agreements with FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S., the completion of forms, the access to the services of website www.florezlegal.com (hereinafter, the Website), the entrance to FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S.’S facilities, and/or the express or unequivocal acceptance of the policy hereunder implies the acceptance of the Owners of this Privacy Policy and their authorization for the use and other treatment described herein.
I. DEFINITIONS
For the purposes of the Privacy Policy hereunder, the following terms are understood as follows:
Database:Organized set of personal data subject to treatment. For the purposes of the document herein, database is understood as that that contains information of the Holders.
Personal Data: Any information linked to or associated with one or several determined or determinable individuals.
Public Data:Non-semi private, private, or sensitive Personal Data. Among other, these are data relative to the civil status of people, their profession or trade, and their capacity as business person or public servants. By nature, Public Data may be contained in public records and documents, among other.
Private Data:It is the data that due to its intimate or reserved nature is only relevant for the Holder.
Sensitive Personal Data:Sensitive Data is understood as those that affect the privacy of the Holder or whose undue use could affect the privacy of the Holder or potential to generate discrimination.
Semi Private Personal Data:These is the data that do not have an intimate, reserved, or public characteristic, and whose knowledge or disclosure may interest not only the Holder, but a group of people or society in general. In this case, its Treatment requires the specific authorization of the Holder of the information. For example: financial data, data related to relations with social security entities (EPS, AFP, ARL, compensation funds).
Encargado del Tratamiento: Persona natural o jurídica, pública o privada, que por sí misma o en asocio con otros, realice el Tratamiento de Datos Personales por cuenta del Responsable del Tratamiento (FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S.).
Responsible for the Treatment: Public or private individual or entity that by itself or in association with others performs the Treatment of Personal Data on behalf of the Responsible for the Treatment (FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S.).
Holder:Individual whose Personal Data is subject to Treatment. For the purposes of the document herein, FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S.’s Holders, suppliers, contractors, employees, clients, users and visitors are understood as such.
Treatment:Any operation or set of operations on Personal Data, such as collection, storage, use, circulation or deletion.
II. RESPONSIBLE OF THE TREATMENT OF DATA
The responsible for the Treatment of Personal Data and other information of the Holders are FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S., tax identification number 900.372.208 – 5, with domicile and address at Carrera 7 # 76-35, office 502 A, Bogota, Colombia, telephone 6403188, email This email address is being protected from spambots. You need JavaScript enabled to view it..
III. PURPOSE AND TREATMENT
3.1. Purpose
The purposes for which FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S. will treat Holders’ personal data are:
a) Complying with service agreements with clients
b) Managing all the information necessary for the fulfillment of tax and commercial registry, corporate, and accounting information of FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S.
c) Complying with internal processes of FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S. on the management of suppliers and contractors
d) Making the relevant payments to suppliers and maintaining business relationships
e) Socialization of policies, projects, programs, and organizational changes
f) Control and preservation of the safety of the individuals, property, and information of FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S.
g) Performing processes within FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S. for development or operational purposes and/or systems administration
h) Using personal data for marketing of new services or products of FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S.
i) Promoting FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S. before other clients or future users of the service based on the experience acquired with the client, respecting professional secrecy, at all times
j) Suggesting products or services (including those of third parties) that FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S. considers that may be of the Holder’s interest
k) Making contact as potential client to keep he/she/it informed, and offering our services or improving the existing ones
l) Evaluating the level of satisfaction of our services and Website; carrying out studies on preferences and services of interest of the Holder
m) Maintaining communication with the Holder
n) Answering questions, complaints, claims, comments, or suggestions regarding the products and/or services offered by FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S.
o) Carrying out the process of filing, updating systems, protection, and custody of the information and databases of FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S.
p) Working on other purposes determined by the Responsible for the Treatment in processes for obtaining Personal Data for their treatment to comply with legal and regulatory obligations, as well as FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S.’s policies
3.2. Treatment of Personal Data
FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S. will treat the Holder’s personal data to fulfill the purposes described in the Privacy Policy herein. Within such treatments, FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S. can make the following:
a) Communication with the Holder for contractual, informative, or commercial purposes
b) Establishing communication between FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S. and the Holder for any purpose related to the purposes set forth in the policy hereunder, whether through calls, text messages, emails, and/or physical mail
c) Offering or informing the Holder about FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S.’s products and/or services that may be of interest, as well as providing general information via emails, as part of a novelty, communication, or news
d) If applicable, using the information to process claims, complaints, suggestions regarding the services offered by FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S.
e) Carrying out or implementing the acquisition, or offer of products or services by FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S.
f) Collecting information about the device being used to view or use the Website, such as IP address, or type of internet browser or operating system, and link it with personal information to ensure that the Website provides the best experience online
g) Evaluating the use of the Website (anonymous and comprehensively), as well as making statistics on the activities of the Holders, such as hours of visits, frequency of their visit, and website that transferred to the Website, so that the experience of the holders in the Website is personalized
h) Inviting and contacting the Holders to participate in conferences, workshops, and any other event developed by FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S.
i) Auditing, studying, and analyzing the information in the Databases to design commercial strategies, and increase and/or improve products and services offered FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S.
j) Combining Personal Data with information obtained from other partners or companies, or sending it to them to implement joint business strategies
k) Providing the information and Personal Data of the Holders to FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S.’s subsidiaries or affiliates, commercial allies, or other companies or individuals FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S. may commission to perform the processing of information and fulfill the purposes described in the policy herein
l) When the information must be disclosed, complying with laws, regulations, or legal processes ensuring compliance with the terms and conditions to stop or prevent fraud, attacks on FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S.’s safety or that of others; preventing technical problems, or protecting the rights of others, as required by the terms and conditions or the law
m) m) If applicable, consulting, storing, and using financial information obtained from third-party administrators of the Databases with prior specific authorization of the Holder of such consultation
n) Others described in the policy herein or allowed in the Law, as well as those necessary to fulfill the purposes described hereunder
IV. WAYS TO OBTAIN DATA AND DATA PROVIDED
FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S. may expressly request the Holders or collect from their behavior the data necessary to fulfill the purpose of the Databases, which are the following among other:
Name and last name
Identification number
Date of birth and age
Contact mailing address, neighborhood, and telephone number
Email
Firma
Signature
Needs and interests
Cargo que desempeña en la empresa o compañía para la cual trabaja
Company for which the client work
Position held in the company for which the client work
Accounting, financial, and credit information
Health promoter company
Any other information necessary to achieve the purposes described hereunder
Data may be provided explicitly to FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S. through admission or linking formats personally collected via their employees, service providers, or representatives obtained through consultation with third parties managing databases, or implicitly collected from the operations of analysis of target groups, acquisition of products or services offered by FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S., or from the behavior of the Holders, such as claims, requests for information, surveys, proposals, offers, visits to FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S. facilities; participation in projects, programs, and events, among other. FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S. only collects and/or treat data deemed Sensitive Data in cases allowed by the Law. For these cases, Holders are not obliged to provide the referred data or to authorize their treatment. Once these data is provided and the corresponding consent has been granted, the data will be collected and processed only for the purposes described in the Privacy Policy hereof.
V. COOKIES
FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S. uses cookies and other tools that automatically collect information from people when they use the Website, understanding that entering the Website is an unambiguous authorization behavior. The type of information that can be collected this way includes:
Information about uniform resource locator (URL)
Information about the browser used by the Holder
Details of the pages visited by the Holder
IP address
Clicks
Hyperlinks
Queries
Most internet browsers are set to accept cookies. The user can change this setting to block them or be alerted when they are being sent to their team.
VI. AUTHORIZATION FOR THE COLLECTION AND TREATMENT OF PERSONAL DATA AND OTHER INFORMATION
Through voluntary supply of any Personal Data as mentioned in the Privacy Policy herein and/or express verbal or written authorization, the Holder express or unequivocally authorizes FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S. to collect your Personal Data and any other information you may provide, as well as to process your Personal Data, in accordance with the Privacy Policy hereof and applicable legal regulations.
VII. CHANGES IN THE PRIVACY POLICY
Any change or substantial modification of the Privacy Policy hereunder shall be communicated in a timely manner to the Holders through a notice on the Website or via email.
VIII. STORING PERSONAL DATA
The Holder expressly authorizes FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S. to store Personal Data as it may deem most safe and timely for the proper protection of the Holder’s data.
IX. SECURITY MEASURES FOR THE PROTECTION OF PERSONAL DATA AND OTHER INFORMATION
Security measures with which FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S. seek to protect the Holder’s data to prevent their loss, adulteration, use, and unauthorized access are critical to us. For this, FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S. diligently implements human, technical, and administrative measures reasonably available. The Holder expressly accepts this form of protection and declares that it considers it convenient and sufficient for all purposes.
X. RIGHTS OF HOLDERS
FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S. informs the Holders that, in accordance with current legislation, they have the right to know, update, rectify their information and/or revoke the authorization for treatment. These are the rights of the Holders as set forth in article 8 of Law 1581 of 2012: a) Knowing, updating, and rectifying Personal Data, b) Requesting proof of the authorization granted, c) Being informed regarding the use it has given to your Personal Data, upon request, d) Submitting complaints to the Industry and Commerce Superintendence Office for breaches to the provisions of the Law, e) Revoking the authorization and/or requesting the deletion of the data, and, f) Accessing your Personal Data subject of Treatment, free of charge.
10.1. Area responsible for petitions, inquiries, and complaints. The area responsible for processing petitions, inquiries, and complaints of the Holders to exercise their rights to know, update, rectify, and delete their data, and revoke their authorization is the administrative area of FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S., which may be contacted at This email address is being protected from spambots. You need JavaScript enabled to view it. and/or telephone number (+57 1) 6403188.
10.2. Procedure to exercise the rights. In the event the Holder wish to exercise his/her/its rights, he/she/it must send an electronic or physical mail message to the contact addresses set forth in the Privacy Policy herein. The procedure to be followed for such communications will be as follows:
10.2.1. Petitions and Inquiries on Personal Data. When the Holder of the data or his/her/its successors wish to consult the information in the Databases, FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S. shall respond the request within a maximum period of ten (10) business days. In compliance with the provisions of Law 1581 of 2012, when it is not possible to respond to the consultation in the said term, the Holder shall be informed. The reasons for the delay shall be expressed and the date on which the inquiry shall be addressed shall be included. The latter may not exceed five (5) business days following the expiry of the first term.
10.2.2. Revocation of authorization, withdrawal, or deletion from the Database, and claims on Personal Data. When the Holder of the data or his/her/its successors consider that the information contained in the Databases should be subject to correction, updating, or deletion, or when they notice the alleged breach of any of the duties contained in Law 1581 of 2012, they may present a claim against FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S., which will be processed under the following rules:
The claim shall be formulated by means of request addressed to FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S. with the identification of the Holders, description of the facts giving rise to the claim, address, and documents to be asserted. If the claim is incomplete, FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S. may require its completition from the interested party, five (5) days following the receipt of the claim at the latest to correct the faults. After two (2) months from the date of the request without the Holder submitting the required information, it shall be understood that the claim has been abandoned. In the event FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S. is not competent to resolve the claim, it shall be transferred to the relevant one in a maximum term of two (2) business days, and shall inform the Holder of the situation, which shall be relieved f any claim or liability for the use, rectification, or suppression of data.
Once the complete claim has been received, when it cannot be solved expeditiously, and provided that it is technically possible, a legend stating, “claim in process” and the reason thereof will be included in the database, no later than two (2) business days after. This legend must be maintained until the claim is decided.
The maximum term to address the claim shall be fifteen (15) business days from the day following the date of receipt. When this is not possible, the Holder shall be informed of the reasons for the delay and date on which the claim will be handled, which in no case may exceed eight (8) business days following the expiry of the first term. The withdrawal or deletion shall not proceed when there is a contractual duty to remain in FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S.’s database.
XI. CONTACT
Any questions or additional information shall be received and processed by sending them to the contact addresses set forth in the Privacy Policy herein.
XII. TERM OF VALIDITY OF THE DATABASE
FLÓREZ & ASOCIADOS ASESORES JURÍDICOS S.A.S.’s database, as well as Personal Data incorporate thereof shall be valid during the term necessary to comply with their purpose.
XIII. VALID LEGISLATION
Current national legislation on protection of personal data is contained in Law 1581 of 2012, Decree 1377 of 2013, and Law 1266 of 2008, and the rules that may modify or complement them.