PERSONAL DATA PROCESSING POLICY

CHAPTER I
GENERAL
Article 1: THE COMPANY. COOPERATIVE COMPANY OF NATURAL FIBERS OF SANTANDER LTDA – ECOFIBRAS– As responsible for the processing of personal data, it establishes institutional guidelines for the execution of the different activities in which it is required to collect, store, use, circulate, and delete personal data. The company’s mission is in accordance with the principles of intimacy and privacy that are developed through the application of the fundamental right of habeas data.
Article 2: CONTACT. The contact details of the company are listed below:
Name: Empresa Cooperativa De Fibras Naturales De Santander LTDA – ECOFIBRAS-
Telephone: 7187436
Direction: Carrera 9 No. 9-43, Curití –Santander-.
Contact email: ecofibras@hotmail.com 
Article 3: DEFINITIONS: For the interpretation of this policy we share the following definitions:

1. Power of attorney or authorized: Person authorized by mandate by the client, worker or supplier of the company, to carry out a procedure related to their personal data, at the request of the person who authorizes it.

2. Authorization: Prior, unequivocal and informed consent of the data owner to carry out the processing of their personal information.

3. Database: Any organized set of personal data that allows access to the data according to certain criteria, whatever the form or modality of its creation, storage, organization and access.

4. Query: Request from the owner of the data or the persons authorized by it or by law to access the information that rests in any database, whether it is contained in an individual record or that is linked to the identification of the Owner.

5. Personal data: Any numerical, alphabetical, graphic, photographic, acoustic or any other type of information concerning determined or determinable natural persons.

6. Private data:They are related to the private sphere of people: merchants’ books, data contained in private documents, and personal contact data.

7. Public data: Any data that is not semi-private, private or sensitive. Public data is considered, among others, data related to the marital status of people, their profession or trade and their status as merchants or public servants. Due to its nature, public data may be contained, among others, in public records, public documents, official gazettes and bulletins, and duly executed court rulings that are not subject to confidentiality. Examples of this classification are the name, type and number of identity document, date of issuance of the document, gender, date of birth, marital status, affiliation, profession, and signature.

8. Semi-private data: Its access is subject to some degree of restriction and represents a topic of interest to a certain sector or group of people: financial or credit, academic, labor data, etc.

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

10. Treatment manager: The natural or legal person, public or private, or administrative body that, alone or jointly with others, processes personal data on behalf of ECOFIBRAS as a consequence of the existence of a legal relationship that delimits the scope of its action for the provision of a service. .

11. Identifiable person: Any person whose identity can be determined, directly or indirectly, through any information referring to their physical, physiological, mental, economic, cultural or social identity. A natural person will not be considered identifiable if such identification requires disproportionate timeframes or activities.

12. Supplier: Natural or legal person who contractually assumes before the company, with their own human and material resources or those of others, the commitment to execute all or part of the works or services subject to the project and the contract.

13. Legal representative: Person who acts on behalf of another, either on behalf of a natural person or a legal person, by virtue of the law, a public deed or a judgment.

14. Claim: Request from the owner of the data or the persons authorized by it or by law to correct, update, or delete their personal data or to revoke the authorization in the cases established by law.

15. Data owner: Natural person who owns the data on which ECOFIBRAS carries out any type of treatment.

16. Transfer: Sending personal data made by the person in charge or in charge from Colombia to a person in charge who is inside (national transfer) or outside the country (international transfer).

17. Transmisión: Tratamiento de datos personales que implica la comunicación de los mismos dentro (transmisión nacional) o fuera de Colombia (transmisión internacional) que tiene por objeto la realización de un tratamiento por el encargado, por cuenta del responsable.

18. Data treatment: Any operation or technical procedure, whether automated or not, that allows the collection, storage, use, circulation and deletion.

19. Fundamental rights: Those rights that prevail or are of greater importance over the rest must always be safeguarded and are intrinsic to the Human being.

CHAPTER II
OF THE PROCESSING OF PERSONAL DATA IN ECOFIBRAS

Article 4: GUIDING PRINCIPLES. The principles that guide the work team of the company, in the collection, storage, use, circulation and deletion of personal data are the following:

a) Principle of legality in the matter of Data Processing: The Treatment referred to in this policy is a regulated activity that must be subject to what is established in it and current legislation;

b) Principle of purpose: The Treatment must obey a legitimate purpose in accordance with the Constitution and the Law, which must be informed to the Holder;

c) Principle of freedom: The Treatment can only be exercised 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 relieves consent;

d) Principle of veracity or quality: The information subject to Treatment must be true, complete, exact, updated, verifiable and understandable. The Processing of partial, incomplete, fractional or misleading data is prohibited;

e) Principle of transparency: In the Treatment, the right of the Holder to obtain from the Treatment Manager or the Treatment Manager, at any time and without restrictions, must be guaranteed.
information about the existence of data concerning you;

f) Principle of restricted access and circulation: Treatment is subject to the limits derived from the nature of personal data, the provisions of current legislation and the Constitution. In this sense, the Treatment can only be done by persons authorized by the Owner and/or by the persons provided for in this law; Personal data, except for public information, 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 Holders or authorized third parties in accordance with current legislation;

g) Security principle: The information subject to Treatment by the Treatment Manager or Treatment Manager referred to in current legislation, must be handled with the technical, human and administrative measures that are necessary to grant security to the records avoiding their adulteration, unauthorized or fraudulent loss, consultation, use or access;

h) Principle of confidentiality: All persons involved in the Processing of personal data that are not of a public nature are obliged to guarantee the confidentiality of the information, even after the end of their relationship with any of the tasks that
includes the Treatment, and may only provide or communicate personal data when it corresponds to the development of activities authorized by law and under the terms of this policy.

Article 5: PURPOSES OF PERSONAL DATA. ECOFIBRAS uses the information provided by the holders of personal data to:

1. Carry out the promotion of the products made in the company.

2. Develop programs and plans for human talent, and safety and health at work.

3. Processing incapacities, permits or licenses of workers

4. Maintain communication with associates to carry out the different activities of the company.

5. Be treated by companies and/or insurance entities for the different risks of old age, health, labor and civil.

6. Submit reports about suppliers, customers and workers, to public and private entities that exercise control and surveillance activities over the company.

7. Carry out the administrative activities through which the accounting and financial movements of the company are established.

Article 6: RIGHTS OF HOLDERS. The holders of personal data whose information is processed by ECOFIBRAS, have the right to:

a. Know, update and rectify personal data. For this purpose, it is necessary to previously establish the identification of the person to prevent unauthorized third parties from accessing the data that does not take place.

b. Obtain a copy of the authorization granted by them as data owners, except for the reproduction costs necessary for this.

c. Know the use that ECOFIBRAS has given to the personal data of the owner.

d. Consult your personal data and make claims to safeguard the right to their protection following the guidelines established by law and in the terms of this policy.

e. Request the deletion of personal data when, within the framework of a judicial or administrative process, it has been declared that the processing of the information was carried out without respect for the constitution or the law.

f. Free access to your personal data. The information requested by the owner may be provided by any means that allows him to know it, including electronic means.

Article 7: RIGHTS THAT THE HOLDER CANNOT EXERCISE. In no case may the owner of the personal data revoke the authorization and request the deletion of the data, when there is a legal or contractual duty that imposes on ECOFIBRAS the obligation to keep their data in the database, and/or in the historical archive of the company.
First paragraph: Regarding inactive holders, it should be noted that the rules of the general social security system and the tax statute require the conservation of historical and accounting information for strictly legal terms, so it cannot be deleted on all occasions.
ARTICLE 8: CHANNELS OF COMMUNICATION: ECOFIBRAS has an email available for the communication that the holders of personal data wish to address, especially queries and claims related to data protection, in order to guarantee the exercise of the rights contained in the Constitution and the Law. The holders of personal data can submit their queries, requests and claims, to the email ecofibras@hotmail.com.

It should be noted that ECOFIBRAS will only send personal data for the purpose of the query, request or claim presented; to the following people:

1. The owner of the data, their successors in title or their legal representatives, as long as they prove this quality as mentioned in the definitions section of this document.

2. To the persons authorized by the owner of the data.

3. To persons authorized by judicial or legal order.

ARTICLE 9: EXERCISE OF RIGHTS BY THE HOLDER. The owners of the data will be able to know, update and rectify the personal information that rests in the ECOFIBRAS databases. The terms for their response will begin to count from the time that the company has effective knowledge of the owner’s request, imposing on it the charge of making your request by the established mail.
ARTICLE 10: CONSULTATION OF PERSONAL DATA. Queries will be answered within a maximum term of ten (10) business days from the day of receipt thereof. When it is not possible to attend to the query within said term, the interested party will be informed of the reasons, indicating the new date on which their query will be resolved, which will not be more than five (5) business days following the expiration of the first term.

ARTICLE 11: CLAIM ON PERSONAL DATA. Claims will be addressed within a maximum term of fifteen (15) business days from the day following the date of receipt thereof. The company may extend the response term in special cases by notifying the interested party. This new term will not exceed eight (8) business days.

If any claim is incomplete, the owner or interested party will be required within five (5) days of receipt thereof to correct the identified shortcomings. After two (2) months from the date of the request without the owner or interested party presenting the required information, it will be understood that the claim has been withdrawn, so the final file will be filed.

If the company is not competent to resolve a query or claim, it will respond within a term of no more than five (5) days counted from the receipt stating said situation. The term to respond to queries and claims will begin to run from when the company has effective knowledge of the owner’s request, imposing the burden of making the request through the established channels.

Article 12: CONTENT OF THE CONSULTATION OR CLAIM. Regardless of the channel that the holder chooses to present his request, it must be addressed to ECOFIBRAS and have at least the following requirements:

– Contain the identification of the Holder (name and identification document).

– Contain the description of the events that generated the query or claim.

– The object of the request

– Specify the notification address of the Holder, both physical and electronic (e-mail).

– Anexar los documentos que se quieren hacer valer (Especialmente para reclamos)

In the event that the query or claim is presented in person, the holder must put his request or claim in writing without any formality other than the requirements in the previous point.
Article 13: DISAGREEMENT WITH THE ANSWER. If the owner considers that the response does not meet his needs, he has a term of fifteen (15) business days from the receipt of the same to request that it be re-evaluated in cases in which it has been unfavorable to his interests.
CHAPTER III
ACCESS TO PERSONAL DATA BY AUTHORIZED THIRD PARTIES
Article 14: DUTY OF THE HOLDER. The owner must physically deliver to the company the proper authorization in which he authorizes a third party to consult, update or rectify his information. This requirement is for the sole purpose of protecting the access of information to unauthorized third parties.
Article 15: CONTENT OF THE AUTHORIZATION. The holder may present a letter that contains, in addition to the requirements indicated to present the query or claim, the following:

a. Identification of the authorizing holder

b. Copy of the holder’s citizenship card

c. Name and identification data of the authorized person.

d. Time for which you can consult, update or rectify the information (only once, for one year, for the duration of the legal relationship, or until further notice, etc.).

e. Voluntary and free character of authorization.

f. Signature of the owner of the data that authorizes the third party.

g. The authorization letter must contain the authenticated signatures.

Article 16: RESERVATION and CONFIDENTIALITY. For the communication of a disability or a calamity as well as for the request for a leave or unpaid leave by the employee, ECOFIBRAS guarantees the reserved and confidential nature of the data that justifies the request or communication.
CHAPTER IV
OF PERSONAL DATA COLLECTED THROUGH SECURITY CAMERAS

ARTICLE 17: VIDEO SURVEILLANCE.ECOFIBRAS uses various means of video surveillance in different internal sites of its headquarters, for security and administrative control purposes. Therefore, the existence of these mechanisms is reported through the visible dissemination of video surveillance announcements, strategically located for easy identification.

Video surveillance is used to guarantee the security of assets, facilities and personnel found in the company’s locations, as well as to monitor the conduct and development of the tasks of visitors and workers in their daily activities.

This information can be used as evidence in any type of internal process, before administrative or judicial authorities, subject to and compliance with the applicable regulations. It may also be used as evidence within internal disciplinary processes and in the surveillance of civil and commercial contracts that eventually come to be developed in the company’s craft activity.

CHAPTER V
FINAL PROVISIONS

Article 17: LEGAL RESTRICTIONS. In compliance with article 13 of Decree 1377 of 2013, this document is issued, which represents the personal data processing policy of ECOFIBRAS. Hence, the content of this document made available for reading by the community corresponds to the obligations required by the Colombian State in terms of protection of personal data, therefore it cannot be extended to other matters related to the administration of the company, unless personal data is processed in them.

Article 18: MODIFICATIONS. Any change, or substantial modification of this policy will be communicated to the owner through the appropriate means of communication, such as: email, and institutional communications. This communication will be sent ten (10) days prior to making the modification.

Article 19: VALIDITY. The validity of this policy starts from the month of July 2017.