CRA 14 #22-31, OFICINA 6 ARMENIA, QUINDÍO

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PRIVACY POLICY AND TREATMENT OF PERSONAL DATA

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  • PRIVACY POLICY AND TREATMENT OF PERSONAL DATA

In this Privacy Policy and Treatment of Personal Data Armadillo Botanics SAS informs the holders of personal data of the data it collects in the different business activities it develops, the purposes of collection, the treatment to which said data is subject and the procedures with which we guarantee that the holders make effective the rights on their personal data.

  1. REGULATORY BACKGROUND

This personal data information processing policy is developed in compliance with articles 15 and 20 of the Political Constitution; of articles 17 literal k) and 18 literal f) of Statutory Law 1581 of 2012, by which general provisions for the Protection of Personal Data (LEPD) are issued; and article 13 of Decree 1377 of 2013, by which the previous Law is partially regulated, as well as Law 1266 of 2008.

  1. RESPONSIBLE FOR DATA PROCESSING

The person responsible for processing the databases covered by this policy is Armadillo Botanics SAS , hereinafter “ Armadillo Botanics ”, whose contact details are as follows:

 

Address:                                 Armenia, Quindío

Address:                                 Calle 10 N # 14-27

Email:             info@armadillobotanics.com

Phone:                                   300.334.0023

Website:                                 www.armadilloBotanics.com

  1. OBJECT

Define the guidelines to guarantee the protection of personal data or any other type of information that is used or rests in the databases and files of Armadillo Botanics , guaranteeing the constitutional right that all people have to know, update and rectify the information that had been collected about them in databases or files in accordance with the regulations in force in this regard.

  1. SCOPE

This policy and the procedures contained in this document will be applicable to all personal data registered in databases and files that are subject to treatment by Armadillo Botanics .

  1. DEFINITIONS

In accordance with the third article of the LEPD and the third article of Decree 1377 of 2013, the following concepts are defined as follows:

Authorization: Prior, express and informed consent of the Holder to carry out the processing of personal data.

Database: Organized set of personal data that is subject to treatment.

Cookies: A cookie is a small text file that is entered into the computer the first time a web page is visited, on each computer there is a folder intended to store all the cookies that are entered.

Open data: Are all primary or unprocessed data, which are in standard and interoperable formats that facilitate their access and reuse, which are in the custody of public or private entities that perform public functions and that are made available of any citizen, freely and without restrictions, so that third parties can reuse them and create services derived from them.

Personal data: Any information linked or that can be associated with one or more specific or determinable natural persons.

Public data: That data that is not semi-private, private or sensitive. Data relating to the marital status of individuals, their profession or trade and their quality as a merchant or public servant are considered public data. Due to its nature, public data may be contained, among others, in public records, public documents, official gazettes or bulletins, and duly enforced judicial decisions that are not reversed.

Private Data: It is the data that due to its intimate or reserved nature is only relevant for the Holder.

Semi-private data: Semi-private data is data that is not of an intimate, reserved, or public nature and whose knowledge and disclosure may be of interest not only to its owner but to a certain sector or group of people, or to society in general, such as financial and credit data. .

Sensitive data: Sensitive data is understood to be that which affects the privacy of the Holder or whose improper use may generate discrimination, such as those that reveal racial or ethnic origin, political orientation, religious or philosophical convictions, membership in trade unions, social or human rights organizations or that promote the interests of any political party or that guarantee the rights and guarantees of opposition political parties, as well as data related to health, sexual life, and biometric data.

in charge of the treatment: Natural or legal person, public or private, that by itself or in association with others, carries out the treatment of personal data on behalf of the person in charge of the treatment.

Claim: Request for correction, update or deletion of the information contained in a database used by Armadillo Botanics , or request for alleged breach of any of the duties contained in Law 1581 of 2012, made by the owner or his successors in title.

Responsible for the treatment: Natural or legal person, public or private, that by itself or in association with others, decides on the database and/or the treatment of the data.

Holder: Natural person whose personal data is subject to treatment.

Treatment: Any operation or set of operations on personal data, such as collection, storage, use, circulation or deletion.

Privacy notice: Verbal or written communication generated by the person in charge, addressed to the Owner for the treatment of their personal data, through which they are informed about the existence of the information treatment policies that will be applicable, the way to access to them and the purposes of the treatment that is intended to give personal data.

Transfer: The transfer of data takes place when the person in charge and/or in charge of the treatment of personal data, located in Colombia, sends the information or personal data to a receiver, who in turn is responsible for the treatment and is inside or outside Colombia. from the country.

Transmission: Treatment of personal data that implies the communication of the same inside or outside the territory of the Republic of Colombia when its purpose is to carry out a treatment by the person in charge on behalf of the person in charge.

  1. CONDITIONS FOR DATA PROCESSING
  • Collection of personal data:

In development of the principles of purpose and freedom, the data collection carried out by Armadillo Botanics must be limited to those personal data that are pertinent and adequate for the purpose for which they are collected or required in accordance with current regulations. Except in the cases expressly provided for in the Law. When requesting authorization from the owner, Armadillo Botanics must inform you clearly and expressly of the Treatment to which your personal data will be subjected and its purpose.

  • Authorization of the Holder:

Armadillo Botanics carry out any personal data processing action, the prior and informed authorization of the owner is required, which must be obtained by any means that may be subject to subsequent consultation. Armadillo Botanicals will adopt the necessary procedures to request, at the latest at the time of data collection, the authorization of the owner for the treatment of the same and will inform the personal data that will be collected as well as all the specific purposes of the treatment for which it is obtained The consent.

Personal data found in publicly accessible sources, regardless of the means by which it is accessed, understood as those data or databases that are available to the public, may be processed by Armadillo Botanics as long as, by their nature, they are public data.

When sensitive data is collected, the owner will be informed that, since it is sensitive data, he is not obliged to authorize its treatment.

  • Revocation of the authorization and/or deletion of the data:

The holders may at any time request Armadillo Botanics , the partial or total deletion of their personal data and/or revoke the authorization granted for the treatment thereof, by submitting a claim through the form provided on the contact page. Armadillo Botanics , in accordance with the provisions of article 15 of Law 1581 of 2012. Armadillo Botanics will respond to the query and/or claim by the same means that it was formulated.

The request to suppress the information and the revocation of the authorization will not proceed when the owner has a legal or contractual duty to remain in the Armadillo Botanics database .

  • Queries:

The holders or their successors in title may consult the personal information of the holder that rests in the Armadillo Botanics database . For its part, Armadillo Botanics will provide the applicant with all the information contained in the individual record or that is linked to the identification of the owner.

For purposes of responding to queries, Armadillo Botanics has a term of ten (10) business days counted from the date of receipt thereof, which may be extended for up to five (5) business days by informing the interested party, expressing the reasons for the delay and indicating the date on which your query will be answered.

  • Claims:

The owner or his successors in title who consider that the information contained in a database 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, may file a claim before Armadillo Botanics , which will be processed within fifteen (15) business days following the date of receipt of the claim. When it is not possible to address the claim within said term, the interested party will be informed of the reasons for the delay and the date on which their claim will be addressed, which in no case may exceed eight (8) business days following the expiration of the first finished.

  1. INFORMATION THAT IS COLLECTED

Armadillo Botanics collects information and personal data at the time they are entered in the forms on the website, in the shopping cart on the website, in satisfaction surveys, as well as those provided by investors and suppliers, in which The owner freely informs his personal data, mainly those related to his name, email address, contact telephone number, residence address, among others.

Regarding the candidates and employees, Armadillo Botanics collects their personal data, resumes, academic and professional profiles, biometric data, photography, entrance and exit medical exams, personal data of the beneficiaries linked by the employee to the entities of the social security and other data necessary for the development of the employment relationship.

In the fields and in the offices, Armadillo Botanics uses video surveillance means, collects, stores and treats the recordings depending on their purpose .

Armadillo Botanics may request additional (sensitive) information, which may be provided by the owner in a free, voluntary, express and prior manner.

 

  1. HOW THE INFORMATION IS USED – PURPOSES

Armadillo Botanics uses the personal data collected, among others, for the following purposes:

  1. Exercise your right to sufficiently know the Holder with whom you intend to establish relationships, provide services, and assess the present or future risk of the same relationships and services. Carry out the pertinent steps for the development of the pre-contractual, contractual and post – contractual stage, including electronic invoicing, regarding any of the products or services offered by it, including technological identity validation processes;
  2. Develop commercial and marketing activities, such as consumer analysis, customer profiling, brand traceability, delivery of benefits, advertising, promotions, offers, news, discounts, customer loyalty programs, market research, generation of campaigns and events , commercial partners or Entities Linked to Armadillo Botanics , fully identified;
  3. Implement relationship strategies with customers, suppliers, shareholders and other third parties with whom the Company has contractual or legal relationships;
  4. Manage queries, requests, requests, complaints and claims related to the services and products offered by Armadillo Botanics .
  5. Conduct satisfaction surveys.
  6. Disclose, transfer and/or transmit Personal Data inside and outside the country to third parties as a result of a contract, law or lawful link that requires it or to implement cloud computing services;
  7. Notify the owner about orders, dispatches or events related to the purchase of merchandise or the provision of services;
  8. Carry out statistical analysis, billing, offering and/or recognition of benefits, telemarketing, collections related to Armadillo Botanics ;
  9. Verify the identity of the holder, carry out security studies and/or apply security protocols in order to prevent and mitigate the risk of fraud, money laundering and/or financing of terrorism;
  10. Implement artificial intelligence programs or any other that technology and law allow;
  11. For security purposes, improvement of our service and the experience in the Company’s facilities, Personal Data may be used, among others, as evidence in any type of process, regarding the data (i) collected directly at the points of security, ( ii ) taken from the documents provided by people to the security personnel and ( iii ) obtained from the video recordings that are made inside or outside the Company’s facilities ;
  12. Know, store and process all the information provided by the Data Holders in one or several databases, in the format that it deems most convenient;
  13. Carry out all tax, accounting, fiscal and billing procedures;
  14. Make reports to the competent authorities.
  15. The data that is collected or stored about Armadillo Botanics employees through the completion of forms, by telephone, or with the delivery of documents (resumes, annexes) will be treated for everything related to labor matters of a legal or contractual nature. By virtue of the foregoing, Armadillo Botanics will use Personal Data for the following purposes: (1) To comply with laws such as, among others, labor law, social security, pensions, professional risks, family compensation funds (Integral System of Social Security) and taxes; (2) Comply with the instructions of the competent judicial and administrative authorities; (3) Implement labor and organizational policies and strategies.

The validity of the database will be the reasonable and necessary time to fulfill the purposes of the Treatment in each case, taking into account the provisions of Article 11 of Decree 1377 of 2013.

  1. RIGHTS OF THE HOLDER

The owner of the personal data will have the following rights:

  1. Know, update and rectify your personal data in front of Armadillo Botanics or in front of the person in charge of the designated treatment. 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.

 

  1. Request proof of the authorization granted to Armadillo Botanics , except when expressly excepted as a requirement for treatment, in accordance with the provisions of article 10 of Law 1581 of 2012.

 

  1. Be informed by Armadillo Botanics or by the person in charge of the designated treatment, upon request, regarding the use that has been given to your personal data.
  2. Submit complaints to the Superintendence of Industry and Commerce for violations of the provisions of Law 1581 of 2012 and other regulations that modify, add or complement it.
  3. Revoke the authorization and/or request the deletion of the data, when the Superintendence of Industry and Commerce has determined that in the treatment Armadillo Botanics has incurred in conduct contrary to Law 1581 of 2012 and the Constitution; or when there is no legal or contractual duty that imposes the duty to remain in the aforementioned database.
  4. Access free of charge under the conditions defined in this document, to your personal data that has been subject to Treatment.

 

  1. DUTIES OF ARMADILLO BOTANICS IN DATA PROCESSING

Armadillo Botanics , will fulfill the following duties:

  1. Guarantee the holder, at all times, the full and effective exercise of the right of habeas data.
  2. Request and keep, under the conditions provided by law, a copy of the respective authorization granted by the owner.
  3. Duly inform the owner about the purpose of the collection and the rights that assist him by virtue of the authorization granted.
  4. Take measures aimed at keeping the information under security conditions to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access.
  5. Take the measures so that the information provided to the person in charge of the treatment is true, complete, exact, updated, verifiable and understandable.
  6. 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.
  7. Rectify the information when it is incorrect and communicate what is pertinent to the person in charge of the treatment.
  8. Provide the person in charge of the treatment, as the case may be, only data whose treatment is previously authorized in accordance with the provisions of the law.
  9. Require the person in charge of the treatment at all times, respect for the security and privacy conditions of the owner’s information;
  10. Process queries and claims formulated in the terms indicated in the law;
  11. Adopt an internal manual of policies and procedures to guarantee adequate compliance with this law and, in particular, for the attention of queries and claims;
  12. Inform the person in charge of the treatment when certain information is under discussion by the owner, once the claim has been filed and the respective procedure has not been completed;
  13. Inform at the request of the owner about the use given to their data;
  14. Inform the data protection authority when there are violations of the security codes and there are risks in the administration of the information of the holders.
  15. Comply with the instructions and requirements issued by the Superintendence of Industry and Commerce.

 

  1. NATIONAL OR INTERNATIONAL TRANSFERS OF PERSONAL DATA

Armadillo Botanics may transfer data to other Data Controllers when authorized by the Owner of the information, by law or by an administrative or judicial mandate.

  1. NATIONAL OR INTERNATIONAL TRANSMISSIONS OF PERSONAL DATA

Armadillo Botanics may send or transmit data to one or more Managers located inside or outside the territory of the Republic of Colombia in the following cases:

  1. When you have authorization from the Holder.
  2. When, without authorization, there is a data transmission contract or the document that takes its place between the person in charge and the person in charge.

 

  1. VIDEO SURVEILLANCE

Armadillo Botanics uses various means of video surveillance installed in different internal and external sites of its facilities or offices. For this reason, it informs the general public about the existence of these mechanisms through the dissemination of video surveillance announcements on visible sites.

The information collected through this mechanism is used for security purposes, to improve our service and the experience in the Armadillo Botanics facilities , as well as as evidence in any type of process before any type of authority or organization.

The Company does not deliver the video recordings obtained to any third party, unless there is a court order or a competent authority or the law allows it.

  1. SECURITY MEASURES

Armadillo Botanics takes all reasonable precautions and measures of a technical, administrative and organizational nature to guarantee the security of the personal data of the owners, mainly those intended to prevent their alteration, loss and unauthorized treatment or access.

The security measures are applied both to the files and to the treatments.

The application of security measures is intended to ensure the conservation, confidentiality, integrity, and availability of data.

  1. USE OF COOKIES

We use “cookies” to obtain information when your Web browser accesses this Site. A “cookie” is an alphanumeric identifier that, through your Web browser, allows us to automatically collect certain data, such as pages visited, time of visit, Internet Protocol (IP) of your browser, type of browser, the nature of the device from which you are visiting the Service, etc. We may also collect information about your interaction with email messages, such as whether you opened, clicked, or forwarded a message. In the “help” section of your browser you can obtain information on how to turn off “cookies”. Our recommendation is that you keep it activated as this will allow you to take advantage of some features and facilities of our Site. In addition, “cookies” help us adjust our Site according to your needs, for example, to remember certain choices and thus make your navigation faster.

If you want to disable them, you can disable the use of “cookies” within your browser or use the anonymous browsing of your browser. We inform you that, in this case, some functionalities of our site could stop working correctly, such as:

  1. Assigned Digital Consultant.
  2. Saving of the shopping cart when closing the session.
  3. User reminder.
  4. Recommendation of personalized offers and promotions.
  1. MODIFICATIONS

Armadillo Botanicals reserves the right to modify these Information Treatment Policies, in whole or in part. In the event of substantial changes in the Information Treatment Policies referring to the identification of Armadillo Botanics and the purpose of processing personal data, which may affect the content of the authorization, Armadillo Botanics will communicate these changes to the owner at the latest at the time of implementing the new policies. Any change will be effective as soon as it is published on the website. Depending on the nature of the change, we may announce it through: (a) the home page of the website, or (b) an e-mail. In any case, the continued use of the Platform implies the acceptance by the User of these changes. If you do not agree with our current Privacy Policy, please refrain from using our page.

  1. VALIDITY

This Policy for the Treatment of Personal Data is effective as of November 12, 2021.

The databases in which the personal data will be recorded will have a validity equal to the time in which the information is maintained and used for the purposes described in this policy. Once these purposes are fulfilled and provided that there is no legal or contractual duty to keep your information, your data will be deleted from our databases.

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