Privacy Policy and Use of Information - Triario SAS

As a result of its business activity, TRIARIO SAS is responsible for and takes custody of its own personal data and that of its clients, natural persons that are stored and processed in databases destined for legitimate purposes, complying with applicable regulations in Colombia.

According to Colombian regulations, the PERSON RESPONSIBLE for the processing of personal data is understood to be a natural or legal person, public or private, who, by themself or in association with others, acts on the database and/or the treatment thereof. The MANAGER is the one who carries out the processing of personal data on behalf of the PERSON RESPONSIBLE.

The personal data that TRIARIO SAS captures and stores, either as a PERSON RESPONSIBLE and/or THE MANAGER according to the circumstances, will be treated in compliance with the principles and regulations stipulated in Colombian law, existing national legislation on the matter applicable to related companies located outside of Colombia, and personal data protection best practices.

For responsibility purposes in data management, we have defined stakeholders, among others, as and without being limited to: employees, suppliers, current and potential customers, shareholders and business partners.

The databases for which TRIARIO SAS is RESPONSIBLE will be treated according to the following general purposes:

1. For fulfilling the obligations and/or commitments derived from the relationships, contractual or not, that exist with each type of audience.
2. For fulfillingl legal obligations that involve personal data about its groups of interest.
3. For commercial management and relationships with its stakeholders.
4. For prospective analysis on trends and its stakeholders’ preferences in relation to goods and/or services.
5. To discover the prospective needs of its stakeholders in order to innovate and satisfy them.
6. To communicate information to its stakeholders about goods, services, publications, training events, business activities and advertising associated with its business activity, whether it offers goods and/or services.
7. To roll out corporate social responsibility activities for its stakeholders.
8. In each business process, according to the personal data collected and treatment to be carried out, the respective privacy notice will inform about the particular purposes of such treatments, without damaging the treatments authorized by law.
9. The personal data for which TRIARIO SAS acts as MANAGER will be treated according to the following general purposes. From now on we will refer the company as THE CLIENT, a natural or legal person, that has contractually granted TRIARIO SAS management of the database:
10. For fulfilling obligations and/or commitments derived from the existing relationships, contractual or not, that THE CLIENT has with each of its audiences.
11. For fulfilling legal obligations that involve personal data about THE CLIENT’s groups of interest.
12. For the commercial management and relationship of THE CLIENT with its stakeholders.
13. For prospective analysis on the trends and preferences of THE CLIENT’S interest groups in relation to their goods and/or services.
14. To find out the prospective needs of THE CLIENT’s interest groups in order to innovate and satisfy them.
15. To communicate THE CLIENT’s information to stakeholders about its goods, services, publications, training events, business activities and advertising associated with its business activity, be it for goods and/or services.
16. To roll out corporate social responsibility activities for THE CLIENT’S stakeholders.

In our capacity as MANAGERS, the data treatment and privacy policies that will govern the processing of said data will be those of THE CLIENT.

Navigation Data on the Website(s)

The navigation systems of TRIARIO SAS or THE CLIENT’s websites collect personal data. Due to its nature, the information received, captured or collected may allow association with third party data. This includes, but is not limited to: the connection IP address, the URL of origin and the one being visited, date and time of browsing, duration of the visit, clicks on pages, links and buttons, among others. This statistical information could be directly associated with the user or be anonymous, and will be used to exploreTRIARIO SAS’ stakeholders or THE CLIENT’s needs in order to innovate and satisfy them.

Cookies Policy

The websites of TRIARIO SAS, or those that have been created for or managed by THE CLIENT, use Cookies to record the aforementioned data. You can eliminate, reject or avoid the use of said cookies by deleting existing ones or configuring your browser to disable the JavaScript codes in your browser’s security settings.

When it comes to processing their personal data, any account holder or legitimately authorized person has the right to:

1. Exercise their right to habeas data consisting of knowing, updating, rectifying, opposing and canceling the information collected from them where appropriate. Give evidence of their consent.
2. Exercise legal actions regarding the protection of personal data and habeas data.

In order to exercise one’s right to habeas data, the owner of the personal data or a person who shows legitimate interest according to the stipulations of current regulations may do so by contacting TRIARIO SAS at habeas.data@triario.com, by visiting the web address http://lp.triario.co/habeas-data, or by writing to: Cr 43A 23 Sur 15 Oficina 201, Envigado, Antioquia, Colombia. Anyone exercising habeas data must provide the exact contact information requested in order to process and meet their request and roll out the charges to exercise their rights.

Once TRIARIO SAS receives the request, it will respond within the legal period of fifteen (15) business days, which may be extended for an additional eight (8) days upon notification.

According to this policy, the treatment of personal data carried out by TRIARIO SAS will be based on the standards, procedures and instructions adopted by the company, in compliance with the legislation applicable to protection of personal information.

Date created: September 29, 2016

Date updated: September 29, 2016