Privacy policies and processing of personal data



This personal data processing policy is prepared in accordance with the provisions of the Political Constitution, Law 1581 of 2012, Regulatory Decree 1377 of 2013 and other complementary provisions and will be applied by  ONE CONNECTION DIGITAL  regarding the collection, storage, use, circulation, deletion and all those activities that constitute processing of personal data.



For the purposes of the execution of this policy and in accordance with legal regulations, the following definitions will be applicable: a) Authorization: Prior, express and informed consent of the Owner to carry out the Processing of personal data; b) Privacy notice: Physical, electronic document or any other format generated by the Controller that is made available to the Owner for the processing of their personal data. In the Privacy Notice, the Owner is informed of the information regarding the existence of the information processing policies that will be applicable, the way to access them and the purpose of the treatment that is intended to be given to personal data; c) Database: Organized set of personal data that is subject to Processing; d) Personal data: Any information linked or that can be associated with one or several specific or determinable natural persons; e) Public data: It is the data classified as such according to the mandates of the law or the Political Constitution and that which is not semi-private, private or sensitive. Public are, among others, data relating to the marital status of people, their profession or trade, their status as a merchant or public servant and those that can be obtained without any reservation. Due to its nature, public data may be contained, among others, in public records, public documents, official gazettes and bulletins; f) Private data: It is the data that, due to its intimate or reserved nature, is only relevant to the owner; g) Sensitive data: Sensitive data is understood to be data that affects the privacy of the Owner or whose improper use may generate discrimination, such as data that reveals racial or ethnic origin, political orientation, religious or philosophical convictions, membership of unions, social organizations, 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; h) Data Processor: Natural or legal person, public or private, who, by themselves or in association with others, carries out the Processing of personal data on behalf of the Data Controller; i) 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; j) Owner: Natural person whose personal data is the subject of Treatment k) Treatment: Any operation or set of operations on personal data, such as collection, storage, use, circulation or deletion thereof.



ONE CONNECTION DIGITAL may use personal data to: a) Execute the existing contractual relationship with its clients, suppliers and workers, including the payment of contractual obligations; b) Provide the services and/or products required by its users; c) Inform about new products or services and/or changes in them; d) Evaluate the quality of the service; e) Carry out internal studies on consumer habits; f) Send to physical, electronic mail, cell phone or mobile device, via text messages (SMS and/or MMS) or through any other analog and/or digital means of communication created or to be created, commercial, advertising or promotional information about the products and/or services, events and/or promotions of a commercial or non-commercial nature, in order to promote, invite, direct, execute, inform and in general, carry out campaigns, promotions or contests of a commercial nature or advertising, advanced by  ONE CONNECTION DIGITAL and/or by third parties; g) Develop the selection, evaluation, and job placement process; h) Support internal or external audit processes; i) Register the information of employees and/or clients (active and inactive) in the databases of  ONE CONNECTION DIGITAL: i) Those indicated in the authorization granted by the data owner or described in the respective privacy notice, as the case may be; j) Provide, share, send or deliver your personal data to affiliated, linked, or subordinate companies of  ONE CONNECTION DIGITAL located in Colombia or any other country in the event that said companies require the information for the purposes indicated here. j) Provide, share, send or deliver your personal data to affiliated, linked, or subordinate companies of  ONE CONNECTION DIGITAL located in Colombia or any other country in the event that said companies require the information for the purposes indicated here. (i) there is express authorization to do so; (ii) is necessary to allow contractors or agents to provide the entrusted services; (iii) is necessary in order to provide our services and/or products; (iv) it is necessary to disclose it to entities that provide marketing services on behalf of ONE CONNECTION DIGITAL or to other entities with which there are joint market agreements; (v) the information is related to a merger, consolidation, acquisition, divestiture, or other corporate restructuring process; (vi) that is required or permitted by law.  ONE CONNECTION DIGITAL may subcontract to third parties for the processing of certain functions or information. When the processing of personal information is actually outsourced to third parties or personal information is provided to third-party service providers, ONE CONNECTION DIGITAL warns said third parties about the need to protect said personal information with appropriate security measures, the use of the information is prohibited. for your own purposes and you are requested not to disclose personal information to others.



The processing of personal data in ONE CONNECTION DIGITAL will be governed by the following principles: a) Principle of purpose: The Processing of the personal data collected must obey a legitimate purpose, which must be informed to the Owner; b) 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; c) Principle of truthfulness or quality: The information subject to Treatment must be truthful, complete, exact, updated, verifiable and understandable. The Processing of partial, incomplete, fragmented or misleading data will not be carried out; d)Principle of transparency: In the Treatment, the right of the Owner to obtain from ONE CONNECTION DIGITAL at any time and without restrictions, information about the existence of data that concerns him or her must be guaranteed; e)Principle of restricted access and circulation: Treatment is subject to the limits derived from the nature of the personal data, the provisions of this law and the Constitution. Personal data, except public information, and the provisions of the authorization granted by the data owner, may not be available on the Internet or other means of dissemination or mass communication, unless access is technically controllable to provide restricted knowledge only. to the Owners or authorized third parties; f) Security principle: The information subject to Processing by ONE CONNECTION DIGITAL must be protected through the use of the technical, human and administrative measures that are necessary to provide security to the records, preventing their adulteration, loss, consultation, use or unauthorized or fraudulent access; g) Principio de confidencialidad: Todas las personas que intervengan en el Tratamiento de datos personales están obligadas a garantizar la reserva de la información, inclusive después de finalizada su relación con alguna de las labores que comprende el Tratamiento. FIRST PARAGRAPH: In the event that sensitive personal data is collected, the Owner may refuse to authorize its Treatment.



The holders of personal data themselves or through their representative and/or attorney-in-fact or their successor in title may exercise the following rights, with respect to the personal data that is subject to processing by ONE CONNECTION DIGITAL: a) Right of access: By virtue of which you can access the personal data that is under the control of ONE CONNECTION DIGITAL, for the purposes of consulting them free of charge at least once every calendar month, and whenever there are substantial modifications to the Information Treatment Policies that motivate new queries; b) Right to update, rectification and deletion: Under which you may request the updating, rectification and/or deletion of the personal data being processed, in such a way that the purposes of the processing are satisfied; c) Right to request proof of authorization: except in events in which, according to current legal regulations, authorization is not required to carry out the treatment; d) Right to be informed regarding the use of personal data; e) Right to file complaints with the Superintendency of Industry and Commerce: for violations of the provisions of current regulations on the processing of personal data; f) Right to require compliance with orders issued by the Superintendence of Industry and Commerce. FIRST PARAGRAPH: For the purposes of exercising the rights described above, both the owner and the person who represents him or her must demonstrate their identity and, if applicable, the capacity by virtue of which they represent the owner. SECOND PARAGRAPH: The rights of minors will be exercised through the people who are authorized to represent them.



All those obliged to comply with this policy must keep in mind that ONE CONNECTION DIGITAL is obliged to comply with the duties imposed by law in this regard. Consequently, the following obligations must be met: A. Duties when acting as responsible: (i) Request and keep, under the conditions provided in this policy, a copy of the respective authorization granted by the owner. (ii) Inform the owner clearly and sufficiently about the purpose of the collection and the rights granted to him by virtue of the authorization granted. (iii) Inform at the request of the owner about the use given to their personal data (iv) Process queries and claims formulated in the terms indicated in this policy (v) Ensure that the principles of truthfulness, quality, security and confidentiality in the terms established in the following policy (vi)-Preserve the information under the security conditions necessary to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access. (vii) Update information when necessary. (viii) Rectify personal data when appropriate. B. Duties when acting as Personal Data Processor. If you process data on behalf of another entity or organization (Data Controller), you must comply with the following duties: (i) Establish that the Data Controller is authorized to provide the personal data that will be processed as Processor (ii) Guarantee the holder, at all times, the full and effective exercise of the right of habeas data. (ii) Garantizar al titular, en todo tiempo, el pleno y efectivo ejercicio del derecho de hábeas data. (iv) Timely update, rectify or delete the data. (v) Update the information reported by the Data Controllers within five (5) business days from receipt. (vi) Process queries and claims made by the owners in the terms indicated in this policy. (vii) Registrar en la base de datos la leyenda “reclamo en trámite” en la forma en que se establece en la presente política. (ix) Insert into the database the legend “information under judicial discussion” once notified by the competent authority about judicial processes related to the quality of personal data. (x) Refrain from circulating information that is being controversial by the owner and whose blocking has been ordered by the Superintendency of Industry and Commerce. (xi) Allow access to the information only to people authorized by the owner or empowered by law for this purpose. (xii) Inform the Superintendency of Industry and Commerce when violations of security codes occur and there are risks in the administration of the owners’ information. (xiii) Comply with the instructions and requirements issued by the Superintendency of Industry and Commerce. C. Duties when you carry out the treatment through a Processor (i) Provide the Data Processor only with personal data whose processing is previously authorized. For the purposes of the national or international transmission of data, a contract for the transmission of personal data must be signed or contractual clauses agreed upon as established in article 25 of decree 1377 of 2013. (ii) Guarantee that the information provided to the Data Processor is true, complete, accurate, updated, verifiable and understandable. (iii) Communicate 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. (iv) Inform the Data Processor in a timely manner of the rectifications made to the personal data so that he or she can proceed to make the pertinent adjustments. (v) Demand that the Data Processor, at all times, respect the security and privacy conditions of the owner’s information. (vi) 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. D. Duties regarding the Superintendence of Industry and Commerce (i) Inform you of possible violations of security codes and the existence of risks in the administration of the owners’ information. (ii) Comply with the instructions and requirements issued by the Superintendence of Industry and Commerce.



In advance and/or at the time of collecting personal data, ONE CONNECTION DIGITAL will request the owner of the data for authorization to collect and process it, indicating the purpose for which the data is requested, using automated technical means for these purposes. , written or oral, that allow proof of the authorization and/or unequivocal conduct described in article 7 of Decree 1377 of 2013 to be preserved. Said authorization will be requested for the time that is reasonable and necessary to satisfy the needs that gave rise to the request for the data and, in any case, in compliance with the legal provisions that govern the matter.



In the event that ONE CONNECTION DIGITAL cannot make this information processing policy available to the owner of the personal data, it will publish the privacy notice attached to this document, the text of which will be kept for later consultation by the owner. of the data and/or the Superintendency of Industry and Commerce.



ONE CONNECTION DIGITAL may only collect, store, use or circulate personal data for as long as is reasonable and necessary, in accordance with the purposes that justified the treatment, taking into account the provisions applicable to the matter in question and the administrative aspects. , accounting, fiscal, legal and historical information. Once the purpose(s) of the processing have been fulfilled and without prejudice to legal regulations that provide otherwise, the personal data in its possession will be deleted. Notwithstanding the above, personal data must be preserved when required to comply with a legal or contractual obligation.



The ADMINISTRATIVE AREA of ONE CONNECTION DIGITAL will be responsible for addressing the requests, complaints and claims made by the data owner in exercise of the rights contemplated in section 5 of this policy, with the exception of that described in literal e). For these purposes, the owner of the personal data or whoever acts as his representative may send his request, complaint or claim from Monday to Friday from 7:00 a.m. to 5:00 p.m. to the email:


Call the ONE CONNECTION DIGITAL telephone line at 3003723986. The request, complaint or claim must contain the identification of the Owner, the description of the facts that give rise to the claim, the address, and accompanying the documents that you want to assert. If the claim is incomplete, the interested party will be required within five (5) 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 the person who receives the claim is not competent to resolve it, he or she will forward it to the appropriate person within a maximum period of two (2) business days and will inform the interested party of the situation. Once the complete claim is received, a legend that says “claim in process” and the reason for it will be included in the database within a period of no more than two (2) business days. Said legend must be maintained until the claim is decided. 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 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 term.



In accordance with the provisions of paragraph 3 of article 10 of Regulatory Decree 1377 of 2013, ONE CONNECTION DIGITAL will proceed to publish a notice in a widely circulated newspaper addressed to the holders of personal data for the purposes of publicizing this data processing policy. information and how to exercise their rights as owners of personal data housed in the ONE CONNECTION DIGITAL databases.



In development of the security principle established in Law 1581 of 2012, ONE CONNECTION DIGITAL will adopt the technical, human and administrative measures that are necessary to provide security to the records, preventing their adulteration, loss, consultation, unauthorized or fraudulent use or access. The personnel who process personal data will execute the established protocols in order to guarantee the security of the information.



This Personal Data Policy was created on March 17, 2017 and comes into force as of March 20, 2017. This Personal Data Policy was created on March 17, 2017 and comes into force as of March 20, 2017.





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