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legal notice

 

Please read this document carefully. It constitutes the Legal Notice that regulates the access, navigation and use of the website located at the URL www.remogroup.com.co/privacypolicy


Access, browsing and use of the website implies express and unreserved acceptance of all the terms of this Legal Notice. By accepting this Privacy Policy, the user is informed and gives his free, informed, specific and unequivocal consent for the personal data provided through the website to be processed byREMO GROUP SAS., hereinafterROWING.

Its observance and compliance will be enforceable with respect to any person accessing, browsing or using the website. If you do not agree with the above terms, do not access, browse or use the website.


Purpose and scope of application

 

In compliance with the provisions of Law 1581 of 2012, and the provisions of Chapter 3 and paragraph of Article 10 of Decree 1377 of 2013, in order to inform all persons whose personal data are in our databases, and taking into account the impossibility of requesting authorization on an individual basis, informs that it makes use of the alternative mechanism established in the aforementioned numeral and states that the personal data included in its databases have been collected for the development of various procedures directly related to its corporate purpose._cc781905-5cde- 3194-bb3b-136bad5cf58d_

The data registered in our databases are, among others: public information, such as address, telephone numbers, e-mails and date of birth. In any case, at any time the owner of the information may revoke their consent and exercise their right to the deletion of personal data enshrined in Law 1581 of 2012. 

REMO, domiciled in Medellin, Colombia, is responsible for the processing of personal data. According to our personal data processing policies, the mechanisms through which we make use of these are safe and confidential, because we have the appropriate technological means to ensure that they are stored in such a way as to prevent unwanted access by third parties, and in the same order we ensure the confidentiality of the same.

data controller

 

Company name: REMO GROUP SAS
Address: Carrera 65 # 7 - 102 (Medellín, Antioquia).
E-mail: operaciones@remogroup.com.co 
Telephone: (604) 3616509 
Website: www.remogroup.com.co

REMO GROUP SAS Personal Data Processing Policies and Procedures Manual

REMO in compliance with the legal provisions governing the processing of personal data, Statutory Law 1581 of 2002 and its Regulatory Decree 1377 of 2013, adopts this policy for the processing of personal data, which will be informed to all holders of the data collected or in the future obtained in the exercise of corporate, commercial or labor activities, consequently all its actions will be governed by the principles of legality, purpose, freedom, truthfulness or quality, transparency, access and restricted circulation, security and confidentiality.
 

Obligation to provide the data.


The data requested in the forms on the website are generally mandatory (unless otherwise specified in the required field) to fulfill the established purposes. Therefore, if they are not provided or are not provided correctly, they cannot be fulfilled, notwithstanding the fact that you can freely view the contents of the Website.


All persons who, in the course of different commercial or work activities, among others, whether permanent or occasional, may provideROWINGWith any type of information or personal data, may be informed of it, update it and rectify it.

1.General Provisions

DEFINITIONS.For the purposes of this manual and in accordance with the provisions of Article 3 of Law 1581 of 2012, and other concordant rules, it is understood by:

  • Authorization:Prior, express and informed consent of the Data Subject to carry out the Processing of personal data.

  • Habeas date:Autonomous and independent fundamental right enshrined in Article 15 of the Political Constitution of Colombia and developed by Law 1581 of 2012, which gives individuals the right to know, update and rectify the information that has been collected about them in data banks and files of public and private entities.

  • Privacy Notice:Physical, electronic or any other format document, generated by the Controller, which is made available to the Data Subject for the Processing of his/her personal data, which communicates to the Data Subject the information regarding the existence of the information Processing policies that will be applicable to him/her, the way to access them and the characteristics of the Processing intended to be given to the personal data.

  • Database:Organized set of personal data that is subject to Processing.

  • Personal dates:Any information linked or that may be associated to one or several determined or determinable natural persons.

  • Public date:Data qualified as such according to the provisions of the Law or the Political Constitution and that which is not semi-private, private or sensitive. Public data includes, among others, data relating to the marital status of individuals, their profession or trade, their status as merchants or public servants, and data that may be obtained without any reservation whatsoever. By their nature, public data may be contained, among others, in public records, public documents, official gazettes and bulletins, duly executed judicial decisions that are not subject to confidentiality.

  • Private Data:Data that, due to its intimate or reserved nature, is only relevant to the Data Owner.

  • Sensitive Data:Data that affects the privacy of the Data Subject or whose improper use may generate discrimination, such as those that reveal racial or ethnic origin, political orientation, religious or philosophical convictions, membership in trade 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, sex life and biometric data.

  • Semi-private data:Semi-private data is data that is not of an intimate, reserved or public nature and whose knowledge or disclosure may be of interest not only to its owner but also to a certain sector or group of persons or to society in general.

  • 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 the Processing of the data.

  • Data Controller:Natural person whose personal data is the object of Processing.

  • processing:Any operation or set of operations on personal data, such as collection, storage, use, circulation or deletion.

  • Transmission:Processing of personal data that involves the communication of such data within or outside the territory of the Republic of Colombia when its purpose is the performance of a Processing by the Processor on behalf of the Controller.

2. Principles for the Processing of Personal Data

REMO, in the processing of personal data will respect the principles established in the applicable regulations:

  • Principle of legality in the processing of data:The processing of personal data is a regulated activity that must be subject to the provisions of current regulations.

  • Principle of purpose:The processing must obey a legitimate purpose in accordance with the Constitution and the Law, which must be informed to the Data Subject.

  • Principle of freedom:Processing may only be carried out with the prior, express and informed consent of the Data Subject. Personal data may not be obtained or disclosed without prior authorization, or in the absence of legal or judicial mandate that relieves the consent.

  • Principle of truthfulness or quality:The information subject to Processing must be truthful, complete, accurate, updated, verifiable and understandable. The processing of partial, incomplete, fractioned or misleading data is prohibited.

  • Principle of transparency:The right of the Data Subject to obtain from the Data Controller or the Data Processor, at any time and without restrictions, information about the existence of data concerning him/her, must be guaranteed in the Processing.

  • Principle of restricted access and circulation:Processing is subject to the limits derived from the nature of the personal data, the provisions on Habeas Data and the Constitution. In this sense, the Processing may only be carried out by persons authorized by the Holder and/or by the persons provided for in the regulations in force. 

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 Law 1581 of 2012.

 

  • Safety Principle:The information subject to Processing by the Data Controller or Data Processor referred to in this manual, shall be handled with the technical, human and administrative measures necessary to provide security to the records avoiding their adulteration, loss, consultation, use or unauthorized or fraudulent access .

  • 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 involved in the processing, and may only provide or communicate personal data when this corresponds to the development of the activities authorized in the data protection regulations.

3. Rights of Data Subjects and Duties of Data Processors

Rights:The Data Controller shall have the following rights, which will be informed byROWINGat the time of obtaining your authorization:

 

  • To know, update and rectify their personal data against the Data Controllers or Data Processors. This right may be exercised, among others against partial, inaccurate, incomplete, incomplete, fractioned, misleading, or those whose processing is expressly prohibited or has not been authorized.

  • Request proof of the Authorization granted to the Data Controller, except when expressly exempted as a requirement for the Processing, in accordance with the provisions of Article 10 of Law 1581 of 2012.

  • To be informed by the Data Controller or the Data Processor, upon request, regarding the use given to their personal data.

  • To revoke the authorization and/or request the deletion of the data whenROWINGdoes not respect the principles, rights and constitutional and legal guarantees. The revocation and/or deletion will proceed when the Superintendence of Industry and Commerce has determined that the data controller or processor has engaged in conduct contrary to the law and the Constitution.

  • Access free of charge to your personal data that have been subject to Processing Access free of charge to your personal data that have been subject to Processing.

 

PARAGRAPH:The Holder of the information has the right to file before the Superintendence of Industry and Commerce complaints for infringements to the provisions of the applicable regulations on Habeas Data. For this purpose, it must comply with the procedural requirement referred to in Article 16 of Law 1581 of 2012, consisting of having exhausted the consultation process or claim beforeROWING.


Duties: ROWING, as the Data Controller, complies with the following duties:

  • Guarantee to the Data Subject, at all times, the full and effective exercise of the right of habeas data.

  • To keep the information under the security conditions necessary to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access.

  • Ensure that the information provided to the Data Processor is truthful, complete, accurate, current, verifiable and understandable.

  • Update the information, communicating in a timely manner to the Data Processor, all developments with respect to the data previously provided and take other necessary measures to ensure that the information provided to this is kept up to date.

  • Rectify the information when it is incorrect and communicate the relevant information to the Data Processor.

  • Require the Data Processor at all times to respect the conditions of security and privacy of the data subject's information.

  • Process queries and claims made under the terms set forth in Articles 14 and 15 of Law 1581 of 2012 and in this manual.
    Inform the Data Processor when certain information is under discussion by the Data Subject, once the claim has been filed and the respective process has not been completed.

  • Inform at the request of the Data Subject about the use given to his/her data. 

  • Inform the data protection authority when there are violations to the security codes and there are risks in the administration of the information of the owners.

  • Comply with the instructions and requirements issued by the Superintendence of Industry and Commerce regarding habeas data.

4. Authorization of the Data Subject

Without prejudice to the exceptions provided for in this policy and the law, the processing will require the prior and informed authorization of the data subject, which must be obtained by any means that may be subject to subsequent consultation.ROWINGshall keep proof of compliance with the authorization and when requested by the data subject, provide a copy of it. If sent the request for authorization of the holder by any means is not answered by the owner of the information within thirty (30) days of receipt or if it is not possible to know the date of receipt, the date of shipment, it is understood that the holder has accepted such authorization. The authorization of the Holder shall not be necessary in the case of:

  • Information required by a public or administrative entity in the exercise of its legal functions or by court order; 

  • Data of a public nature; 

  • Cases of medical or health emergency; 

  • Processing of information authorized by law for historical, statistical or scientific purposes; 

  • Data related to the Civil Registry of Persons.

5. Manifestation of Authorization

The authorization to REMO for the processing of personal data will be granted by: 

 

  • The holder, who must prove his identity sufficiently by the various means made available byROWING.

  • The representative and / or attorney of the owner, upon proof of representation or power of attorney. 

  • Another in favor of or for whom the holder has stipulated.

 

PARAGRAPH:Public data, in accordance with the provisions of paragraph b) of Article 10 of Law 1581 of 2012, do not require authorization from the owner of the information.

6. Privacy Notice 

The Privacy Notice informs the Holder of the information regarding the existence of the information processing policies contained in this manual, as well as the characteristics of the processing that will be given to personal data, and shall contain at least the following information:
 

  • Identity, address and contact details of the Data Controller.

  • Type of processing to which the data will be submitted and its purpose.

  • General mechanisms provided by the Controller so that the Data Subject is aware of the information processing policy, informing the Data Subject how to consult the information processing policy.

PARAGRAPH: ROWINGwill keep the model of the Privacy Notice that was transmitted to the Data Controller as long as the processing of personal data is carried out, and the obligations arising therefrom endure.ROWINGmay use computer, electronic, or any other means it deems appropriate to store the model.

 

7. Processing to Which The Data Will Be Submitted And The Purpose For Which It Will Be Submitted


The processing of personal data of shareholders, employees, former employees, suppliers, contractors, or any person with whom REMO has established or establishes a relationship, permanent or occasional, will be carried out within the legal framework that regulates the matter. In any case, personal data may be collected and processed for the following purposes:

 

  • Make invitations to events, improve products and services or offer new products and all those activities associated with the existing business relationship or link or that which may come to have with the Responsible.

  • Send specific content according to the detected needs, improve or offer products and services.

  • Provide contact information and relevant documents to the sales force and/or distribution network, telemarketing.

  • To disclose, transfer and/or transmit my personal data as a consequence of a contract, law or lawful link that requires it for commercial, marketing and cross-selling purposes of the related companies. 

  • Manage the information in systems and/or technological platforms, transfer the information to companies that are part of the Responsible's business group.

8. Procedures 

For purposes of queries and complaints,ROWING, enabled the email operaciones@remogroup.com.co for users to consult the existence of personal information that is registered in the databases ofROWING, through this mail can consult the treatment that has been given to such information, know the purposes that justify this treatment and request the update, rectification or deletion of this personal data. The information must be provided in its entirety and proof of the effective attention to the consultation or claim must be kept. All queries must be answered within a term not exceeding ten (10) working days from the day the request is received, this being the first day of the term. If it is not possible to attend the consultation within the term indicated, the interested party who has the capacity to consult must be informed of the reasons for the delay and the date on which the consultation will be answered must be indicated. In any case, the new date may not be more than five (5) working days following the expiration of the ten (10) day termROWINGwill implement the necessary measures to ensure that access to information is allowed after verifying the identity of the interested party. Access will be granted free of charge, in a simple and expeditious manner. Likewise, the possibility of rectifying and updating the data will be allowed by written request or data message. 


On the other hand, all claims must be addressed within a maximum term of fifteen (15) working days from the day following the date of receipt. If it is not possible to respond to the claim within the indicated term, the interested party will be informed of the reasons and the date on which a response will be given. In any case, the new date cannot be more than eight (8) working days following the expiration of the fifteen (15) day term. 

 

The complete claim must contain, at least: 

Yo. Identification of the Holder and the claimant (in case it is not the same Holder). 
ii. Description of the facts that give rise to the claim. 
iii. Physical or electronic notification address.
iv. Documents and attachments that are intended to be asserted in the course of the claim. 
v. Request or object of the claim. 

If a claim is submitted but it is incomplete, that is to say, if it lacks essential elements to process it properly, within five (5) business days following the receipt of the claim, the interested party must be requested to correct the claim. If two (2) months elapse without the claimant correcting the claim, it shall be understood that the claim has been abandoned. If a claim is received but the company does not have the competence to resolve it, it shall be sent to the appropriate person within a term not exceeding two (2) business days and the interested party shall be informed of such situation.

When the deletion of data is requested, it may not be carried out when: 

Yo. It is a legal or contractual obligation to keep such data. 
ii. Retaining the data is essential to safeguard the interests of the Data Subject or the public interest. 
iii. The deletion hinders or obstructs the exercise of the functions of the administrative or judicial authorities. 

 

When the revocation of the authorization is requested, it is necessary that the interested party informs precisely whether the revocation is total or partial. The revocation of the authorization is partial when the interested party states that he/she wishes to revoke the Processing of personal data for certain specific purposes such as advertising, contests, consumer studies, etc. The revocation of the authorization is total when it is requested to stop the processing of personal data for all authorized purposes.

10. Validity and modification of this Privacy Policy.


This policy will apply from January 2022 and your Personal Data will be stored only for the time required by law, or for the fulfillment of the purposes that have been authorized by you.


This Policy may be amended byROWINGat any time. Notwithstanding the foregoing,ROWINGwill inform you, by such means as it deems appropriate, of any material change prior to such modification becoming effective.
 

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