March 12, 2019

Data policy

INFORMATION TREATMENT POLICIES

PREAMBLE

SATLOCK LOGISTICA Y SEGURIDAD S.A.S, (SATLOCK S.A.S) society identified with NIT 900.449.459-1 and domiciled in the city of Cali (Valle del Cauca - Colombia - South America), E-mail: info@satlock.com, telephone: (57 1) 343 6565, in compliance with the provisions of the Political Constitution articles 15 and 20, Statutory Law 1581 of 2012, Decree 1377 of 2013, and other concordant norms, by which general provisions are dictated for the protection of personal data, has adopted this Privacy Policy and Personal Data Protection which regulates the collection, storage, treatment, administration, transfer, transmission and protection of that information received from third parties, customers, suppliers, workers and collaborators through the different information collection channels.

The purpose of this policy is to inform about the treatment and purpose to which the personal data contained in our databases will be submitted, the rights of the owners, the person in charge and the procedure to deal with queries or claims for the treatment of personal data.

CHAPTER I.

THE PROCESSING AND PURPOSE TO WHICH THE PERSONAL DATA WILL BE SUBMITTED..

Due to the different contractual relations SATLOCK S.A.S. collects and treats personal data whose main purpose is to comply with the Company's corporate purpose, especially all activities inherent to carrying out its main activity, administrative, operational and commercial management, as well as contractual monitoring; training; providing required products and services; evaluating the quality of our products and services; informing about changes in our products or services; informing about new products or services that are related or not to what has been contracted; sharing, including the transfer and transmission of your personal data to third parties abroad or in the national territory for purposes related to the contract; complying with obligations arising from the contractual relationship; handling and complying with Social Security rules, including the transfer of my information to third parties as required; contacting my family, economic dependents and/or beneficiaries in case of emergency; performing internal control of my personal knowledge and skills; reporting on various activities that may be of interest to our customers, employees, collaborators and suppliers.

The owner is responsible for the information provided to SATLOCK S.A.S. which must be truthful, complete, accurate, verifiable and up to date. The holder guarantees the authenticity of all data provided to SATLOCK S.A.S.

The above treatment and purpose shall include those data that have been collected prior to the publication of this data treatment policy and those that are currently being processed.

The holder who does not wish his or her data to be subject to any of the treatments expressed in this document may at any time inform SATLOCK S.A.S. through the means and procedures contained in this Policy to revoke the authorisation for such treatment. In any case, the aforementioned purposes do not apply to all contractual relations.

CHAPTER II.

RIGHTS OF THE HOLDER OF THE PERSONAL DATA..

SATLOCK S.A.S., in compliance with the provisions of Decree 1377 of 2013, informs the holder of the rights that assist him in accordance with the provisions of Article 8 of Law 1581 of 2012:

  • Know, update and rectify their personal data against SATLOCK S.A.S. This right may be exercised, among others against partial data, inaccurate, incomplete, fractionated, misleading, or those whose treatment is expressly prohibited or has not been authorized;
  • Request proof of the authorization granted to SATLOCK S.A.S. except when expressly exempted as a requirement for Treatment, in accordance with the provisions of Article 10 of Law 1581 of 2012;
  • Be informed by SATLOCK S.A.S. Upon request, regarding the use you have made of your personal data;
  • Submit complaints to the Superintendency of Industry and Commerce for infractions of the provisions of this law and other regulations that modify, add to or complement it;
  • Revoke the authorization and/or request the deletion of the data when the Treatment does not respect the principles, rights and constitutional and legal guarantees. The revocation and/or suppression will proceed when the Superintendence of Industry and Commerce has determined that in the Treatment SATLOCK S.A.S. has incurred in conduct contrary to the Constitution and Law 1581 of 2012;
  • Access, free of charge, to your personal data that have been processed.

Pursuant to the provisions of Article 9 of Decree No. 1377 of 2013, the request for deletion of information and revocation of authorization shall not proceed when the Holder has a legal or contractual duty to remain in the database.

It is clear to SATLOCK S.A.S. at all times that personal data are the property of the persons to whom they refer and that only they can decide about them. SATLOCK S.A.S. will use them only for those purposes consented to by the Proprietor and in any case respecting the current regulations on the protection of personal data.

ON THE RIGHT OF ACCESS.

In accordance with article 21 of Regulatory Decree 1377 of 2013, SATLOCK S.A.S. shall at all times guarantee the right of access that the Registrant or its Beneficiaries have, provided that the identity of the Holder is accredited to the Company or, failing that, the legitimacy to exercise the rights of the Holder to access and know what information is being processed by SATLOCK S. shall be demonstrated.A.S. The exercise of this right will guarantee the Holder or his representative to consult, free of charge, their personal data that are the object of Processing by SATLOCK S.A.S. At least once every calendar month, as well as every time there are substantial modifications to the Information Processing Policies that motivate new consultations.

CHAPTER III.

RESPONSIBLE FOR ANSWERING QUERIES AND/OR COMPLAINTS REGARDING THE PROCESSING OF PERSONAL DATA.

SATLOCK S.A.S. has appointed the Customer Service Officer to receive requests from the holders in the exercise of the rights of access, consultation, rectification, updating, suppression and revocation referred to in Law 1581 of 2012, and thus to make effective the rights held by the holders.

In order to receive queries, claims, complaints about the treatment of your personal data or to exercise your rights as a user or client, you may contact SATLOCK S.A.S. at servicioalcliente@satlock.com, or by using the physical means made available in our main office located at Calle 86 # 27-51 in the city of Bogotá, as well as in Branches, Agencies or any commercial establishment owned by SATLOCK S.A.S. petitions will be received Monday through Friday from 8:00 a.m. to 12:00 p.m. and from 2:00 p.m. to 6:00 p.m.

CHAPTER IV.

PROCEDURE FOR MAKING QUERIES OR COMPLAINTS ABOUT THE PROCESSING OF PERSONAL DATA.

In order to attend in a timely manner and in accordance with the guidelines established in Articles 14 and 15 of Law 1581 of 2012, SATLOCK S.A.S. has defined the means by which the Holder or whoever is authorized pursuant to Article 20 of Regulatory Decree 1377 of 2013 may execute his rights.

The Holder of the personal data or who is Authorized will be able to accede, to consult or to claim, contacting us through the electronic mail servicioalcliente@satlock.com, communicating to our telephone line number (57 1) 343 6565, or in our main office, branches or agencies, in which you will find the formats previously established by us to receive your request. Any interested or affected person wishing to exercise any of the rights mentioned in this document may do so by written communication to SATLOCK S.A.S. The application shall be accompanied by his signature and a copy of his personal identification or similar document.

In order to timely respond to the request of the Registrant or Authorized Person, the request for consultation or claim shall contain at least the following information:

  •  Full Names or Company Name of the Holder.
  • Identity number of the Holder.
  • Owner's location data.
  •  Description of the facts that motivate the consultation, claim or revocation of the authorization.
  • Attachments (If required)
  • Means by which you wish to receive the reply.

When it is intended to revoke the authorization, the applicant must indicate whether it revokes all or part of the authorization, and the reasons for its decision.

If you are a person other than the Registrant, you must provide documents proving that you can act on his behalf, without this route.

SATLOCK S.A.S. shall have the terms established in Articles 14 and 15 of Statutory Law 1581 of 2012, which shall in any case be dealt with in the following manner:

When the holder carries out a CONSULTATION, it will be attended in a term of ten (10) working days counted from the date of receipt of the same one. In the event that it is not possible to attend the consultation within this term, SATLOCK S.A.S. will inform the petitioner of the reasons for the delay and the date on which the response will be received. In any case, the final date may not exceed five (5) business days following the expiration of the first term.

If the holder makes a CLAIM, it will be attended in a term of fifteen (15) working days counted from the day following the date of its receipt. In the event that it is not possible to attend the consultation within this term, SATLOCK S.A.S. will inform the petitioner of the reasons for the delay and the date on which the response will be received. In any case, the final date may not exceed eight (8) business days following the expiration of the first term.

In the event that the Registrant requests the partial or total deletion of the information, SATLOCK S.A.S. in its own right and in accordance with the provisions of Law 964 of 2005, article 28, shall keep all the documents and information that the Registrant, in a dead file, for as long as SATLOCK S.A.S. carries out the activities proper to its corporate purpose plus ten years, being able to use for this purpose, at the Company's option, its conservation on paper or in any technical, magnetic or electronic medium that guarantees its exact reproduction. The Dead Archive may only be consulted at the express request of a competent Judicial Authority.

CHAPTER V.

COMPLAINT TO THE SUPERINTENDENCY OF INDUSTRY AND COMMERCE

By express provision the owner or successor in title shall have the right to file a complaint with the Superintendence of Industry and Commerce once he has exhausted the process of consultation or claim before SATLOCK S.A.S. evidencing a lack of knowledge of his rights.

CHAPTER VI.

VALIDITY OF THE AUTHORISATION

The Holder of the data accepts and acknowledges that this authorisation will be in force from the moment it is accepted, or its acceptance is presumed, and for as long as SATLOCK S.A.S. carries out the activities inherent to its corporate purpose plus ten years, and may use for this purpose, at the discretion of SATLOCK S.A.S. It shall be kept on paper or by any technical, magnetic or electronic means which ensures its exact reproduction.

CHAPTER VII.

VALIDITY OF THE INFORMATION PROCESSING POLICY

The effective date of the Information Processing Policy shall be September 1, 2014 and the validity of the databases shall be indefinite. In any case the present document is published in the web page www.satlock.com and any significant modification will be informed to the Holder.

It is recommended that you visit and consult the SATLOCK S.A.S. website frequently. In the corresponding module, to know about the possible changes to the Data Protection Policies.

For more information regarding the legal provisions on data protection, and those related to the complaint procedures regarding them, we suggest visiting the website of the Superintendence of Industry and Commerce (www.sic.gov.co).

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