To establish the criteria for the collection, storage, use, circulation and suppression of personal data processed by PROYECTO MÁS COLOMBIA S.A.S., identified with NIT 901.474.539 – 1 through its website www.mascolombia.com, in order to guarantee the rights of habeas data of the respective holders of personal data, which was recognized by the Political Constitution of Colombia in its article 15, whose protection was regulated by Law 1581 of 2012 and the Single Decree 1074 of 2015.
The Treatment Policy aims to protect the constitutional right of Habeas Data that all persons have to know, update, and rectify the information that has been collected and stored by MÁS COLOMBIA through its website www.mascolombia.com, as well as the other rights, freedoms and constitutional guarantees referred to in Articles 15 and 20 of the National Constitution.
Database: Organized set of personal data that are subject to processing and may be physical or electronic.
User: The natural person who makes use of MÁSCOLOMBIA’s webpage, which allows him/her to access its content (free or paid).
Personal data: Any information linked or that can be associated to a specific person, such as name or identification number, or that can make it determinable, such as physical features.
Public data: This is one of the existing types of personal data. Public data includes, among others, data relating to the marital status of individuals, their profession or trade, and their status as merchants or public servants. Due to their 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.
Private data: Personal data that, due to its intimate or reserved nature, is relevant to the Data Subject.
Semi-private data: Personal data known and of interest both for the owner and for a certain sector of people or for society in general, so it is not of an intimate, reserved or public nature.
Sensitive data: Data that affect the holder’s privacy or may lead to discrimination, i.e., data that reveal racial or ethnic origin, political orientation, religious or philosophical convictions, membership in trade unions, social organizations, human rights organizations, as well as data relating to health, sex life, and biometric data, among others.
Data Processor: Natural or legal person, public or private, who by himself or in association with others, performs the Processing of personal data on behalf of the Data Controller.
Data Controller: Natural or legal person, public or private, who by himself or in association with others, decides on the database and / or data processing.
Processing: Any operation or set of operations on personal data, such as collection, storage, use, circulation or deletion.
Transfer: This is the operation performed by the controller or processor of personal data, when he/she sends the information to another recipient, which, in turn, becomes responsible for the processing of such data.
MÁS COLOMBIA, subject to the constitutional and legal provisions, shall be governed in its role as responsible for the processing of personal data by the guiding principles that the Colombian legal system has provided in this matter, these are, according to Article 4 of Law 1581 of 2012:
– Principle of legality regarding data processing: MÁSCOLOMBIA will manage its databases for which it is responsible in full compliance with the constitutional and legal postulates that regulate the matter.
– Principle of purpose: The purpose for which the personal data is managed and processed shall be in full compliance with the law; it shall be legitimately used for the development of the commercial, operational and/or administrative activities of the Company.
– Principle of freedom: MÁSCOLOMBIA will only process those data for which it has consent or those which, without consent, the law authorizes them to process.
-Principle of truthfulness or quality: MÁSCOLOMBIA will constantly ensure the storage and processing of truthful, current and accurate information; likewise, permanent measures will be implemented to update the data stored, trying not to process partial, incomplete, fractioned or misleading data, which is expressly prohibited by law.
– Principle of transparency: MÁSCOLOMBIA will have a communication mechanism where the owners of the data may at any time obtain information about the personal data that are processed by this company and exercise their rights under Article 15 of the Colombian Constitution (Right to Habeas Data).
– Principle of access and restricted circulation: Control and restriction of stored data is guaranteed, especially those data that by their nature require special treatment (sensitive data, children and adolescents), so that only those who have the proper authorization will have access to them.
– Security principle: Necessary and appropriate measures shall be taken for the protection of the data stored not only by MÁSCOLOMBIA as data controller but also by any person in charge of the processing of such data.
– Confidentiality principle: MÁSCOLOMBIA will guarantee the confidentiality of the information stored and will provide or communicate it only when it corresponds to the development of the activities authorized by law.
In full development of the provisions of Article 15 of the Political Constitution of Colombia and its regulatory standards, the holder of the personal data is entitled to the following Rights:
Right to know: The holder of the data has the Right to know what personal data about him/her is held by the data controllers and/or data processors.
Right to update: The owner of the data has the Right to permanently update the data that are processed by the data controller and/or data processor in order to ensure that they are adjusted to reality and allow an optimal quality of information.
Right to rectify: The owner of the data has the right to rectify the personal data that the person responsible and/or in charge of the treatment is treating for finding it wrong.
Right to delete: The owner of the data has the right to remove the data from the databases processed by the data controller and/or data processor at the time he/she so desires.
Right to revoke the authorization: The owner of the personal data has the right to revoke the authorization initially granted for the processing of the data by the data controller. This revocation may be total or partial as the owner so wishes, and provided that he/she is informed of such situation in a timely manner.
The holder of the personal data will have the right to decide whether or not to answer the questions asked when they deal with sensitive data or data of children and adolescents, as provided in paragraph “b” of article 12 of law 1581.
In no case will personal data be processed without the prior, express and informed consent of the owner, as provided in article 9 of law 1581.
MÁSCOLOMBIA recognizes the ownership over the personal data and therefore, will use the personal data for the fulfillment of the purposes expressly authorized by the owner or by the regulations in force.
In the treatment and protection of personal data, MÁSCOLOMBIA shall have the following duties, without prejudice to others provided for in the provisions that regulate or come to regulate this matter:
a) To know, update and rectify its personal data before MÁSCOLOMBIA in its capacity as data controller. This right may be exercised, among others, against partial, inaccurate, incomplete, fractioned, misleading data, or data whose processing is expressly prohibited or have not been authorized.
b) Request proof of the authorization granted to MÁSCOLOMBIA, except when expressly exempted as a requirement for the processing.
c) To be informed by MÁSCOLOMBIA, upon request, regarding the use made of its personal data.
d) File complaints before the Superintendence of Industry and Commerce for infringements to the provisions of Law 1581 of 2012 and other regulations that modify, add or complement it.
e) To revoke the authorization and/or request the deletion of the data when the processing does not respect the principles, rights and constitutional and legal guarantees.
f) Access free of charge to their personal data that have been subject to processing.
This policy applies to all personal information registered in the databases coming from MÁSCOLOMBIA’s website, www.mascolombia.com, who acts as the party responsible for the processing of personal data.
The party responsible for the processing of the data established herein shall be PROYECTO MÁS COLOMBIA S.A.S., identified with NIT 901.474.539 – 1, with its main domicile at Carrera 55 No 66-17 in Bogotá D.C., Republic of Colombia. Page www.mascolombia.com, e-mail gerencia@mascolombia.com.
8.1. USERS: MÁS COLOMBIA will use the information provided to:
Notwithstanding the exceptions provided by Law, in the processing of personal data of the holder, the prior and informed authorization of the holder is required, which must be obtained by any means that may be subject to subsequent consultation.
MÁS COLOMBIA, in accordance with the terms set forth in the Law, generated a privacy notice in which it informs the owners that they may exercise their right to the processing of personal data, through the web page www.mascolombia.com.
1. Definition: Cookies are a small data file created by the website visited and stored in the browser or device used by those who contain small amounts of information that are sent between MÁS COLOMBIA’s web server and the USER’s browser and this information is stored in the browser’s memory. The purpose of this process is that the visited web site can check the cookie in a future connection of the user and use it.
2. Method of Obtaining and Types of Cookies: Cookies are obtained by MÁS COLOMBIA at the moment the USER enters the web page www.mascolombia.com, as well as when he/she authenticates with a USER account, if applicable, and may be either its own or from third parties. The Cookies used by the web page are the following:
3. Disabling Cookies: The USER may disable the use of cookies within MÁS COLOMBIA through the configuration of the browser used to access it, however, this could affect the normal operation of the web page and the experience he/she will have of it. The disabling or blocking will depend on the browser used by the USER, for which he/she must review the configuration of the same and proceed according to the options provided by the same.
1. Consultations. The owners or their successors in title may consult the personal information of the owner contained in any database of MÁS COLOMBIA.
The holder may send their questions or queries related to their personal data collected and processed by MÁS COLOMBIA to the following channels of attention:
| CITY | ADDRESS | |
| Bogotá D.C. | Carrera 5 No. 66-17 | contacto@mascolombia.com |
MÁS COLOMBIA will solve your concern or query within ten (10) business days from the date it received it. When it is not possible to answer the consultation within such term, the interested party shall be informed before the expiration of the 10 days, stating the reasons for the delay and indicating the date on which the consultation will be answered, which in no case may exceed five (5) business days following the expiration of the first term.
2. Claims. The holder (or its assignees) who considers that the information contained in any database should be corrected, updated or deleted, or when they notice the alleged breach of any of the legal duties, may file a claim through any of the following channels of attention:
| CITY | ADDRESS | |
| Bogotá D.C. | Carrera 5 No. 66-17 | contacto@mascolombia.com |
The claim must contain at least: The identification of the holder of the personal data, the description of the facts that give rise to the claim, the address of the holder, and must be accompanied by the documents they wish to assert. If this information is not included, the interested party will be required within five (5) days of receipt to correct the faults. After two (2) months have elapsed from the date of the requirement without the applicant submitting the required information, it shall be understood that the claim has been withdrawn.
Once the complete claim has been received, a legend stating “CLAIM IN PROCESS” and the reason for the claim will be included in the database maintained by MÁS COLOMBIA, within a term not exceeding two (2) business days. Said legend shall be maintained until the claim is decided.
The maximum term to address the claim shall be fifteen (15) business days from the day following the date of receipt. When it is not possible to attend it within said term, the interested party shall be informed before the expiration of said term the reasons for the delay and the date on which the claim will be attended, which in no case may exceed eight (8) business days following the expiration of the first term.
3. Deletion. The right to suppression of data is not absolute, MÁS COLOMBIA may deny it when:
The period of validity of the databases will be the same as the period of validity of PROYECTO MÁS COLOMBIA S.A.S., except for those databases whose purpose is for a specific one-time activity and their validity will be until the end of said activity.
This policy is effective from the time of its publication. When the terms of the privacy policy change in substance, as a general rule, a new authorization will be obtained in the form established through the usual means of contact between the company and the owners. Any substantial change in the treatment policies, will be communicated in a timely manner to the owners of the data through the usual means of contact and / or through the web www.mascolombia,com and email sent to the owners.
