DATA PROTECTION POLICY

POLICY AND PROCEDURES MANUAL FOR PERSONAL DATA PROTECTION OF EMPLOYEES, CUSTOMERS, AND STAKEHOLDERS OF ATELIER 17.56

This policy is issued in compliance with the law and any regulations that modify or add to the personal data protection regime. It aims to ensure that ATELIER 17.56, as the responsible entity for handling personal information, processes it in strict accordance with applicable regulations, guaranteeing the rights of the data subjects.


  1. INFORMATION OF THE DATA CONTROLLER

The company responsible for the processing of personal data is:

  • Company Name: ATELIER 17-56
  • Address: Calle 29 #17-56, Montería, Córdoba, Colombia
  • Email: info@atelier1756.com
  • Phone: (+57) 319 608 0736

  1.  DATA PROCESSING AND PURPOSE

In the exercise of its corporate purpose, ATELIER 17.56 processes personal data of its employees, suppliers, customers, and users of its products. Additionally, in compliance with applicable legislation, ATELIER 17.56 may need to transmit or transfer such data to specified platforms and/or security systems implemented by it.

In line with the principles of purpose and freedom, ATELIER 17.56 will limit the collection of personal data to what is relevant and necessary for the purpose for which it is collected or required in accordance with current regulations. Except in cases expressly provided for by law, personal data cannot be collected without the data subject's authorization.

Personal data is collected, stored, organized, used, circulated, transmitted, transferred, updated, rectified, suppressed, deleted, and managed according to the purpose or purposes of each type of processing, as indicated in section 3 of this Policy.


2.1 Processing of Personal Data of Children and Adolescents

The processing of personal data of children and adolescents that is of a public nature will comply with the following parameters and requirements:

  1. a) It must respond to and respect the best interests of the children and adolescents.
  2. b) It must ensure the respect of their fundamental rights.
  3. c) The opinion of the minor should be considered when they have the maturity, autonomy, and capacity to understand the matter.

Once these requirements are met, the legal representative of the child or adolescent may grant authorization for processing, after the child's right to be heard is exercised, with their opinion being considered according to their maturity, autonomy, and capacity to understand the matter.


2.2 Processing of Sensitive Data

ATELIER 17.56 will strictly observe the legal limitations on the processing of sensitive data, ensuring that:

  1. a) The data subject has given explicit authorization for such processing, except in cases where the law does not require such authorization.
  2. b) The processing is necessary to safeguard the vital interest of the data subject and they are physically or legally incapacitated. In these cases, the legal representatives must give their authorization.
  3. c) The processing is carried out in the course of legitimate activities with appropriate guarantees by a foundation, NGO, association, or any other non-profit organization with a political, philosophical, religious, or trade union purpose, provided it relates exclusively to its members or to persons who maintain regular contact with it in relation to its purpose. In these cases, the data may not be provided to third parties without the data subject's authorization.
  4. d) The processing relates to data that is necessary for the recognition, exercise, or defense of a right in a judicial process.
  5. e) The processing has a historical, statistical, or scientific purpose. In this case, measures must be adopted to suppress the identity of the data subjects.

  6.  PURPOSES OF PROCESSING

The purposes of the personal data processing carried out by ATELIER 17.56 are as follows:

  • Execution of contracts signed with ATELIER 17.56.
  • Customer service and marketing.
  • Sending information related to legal and regulatory updates of interest to ATELIER 17.56 customers.
  • Recording statistical information about ATELIER 17.56 customers.
  • Recording information about contractor employees providing services to ATELIER 17.56.
  • Compiling contractual and service statistics.
  • Communication, consolidation, organization, updating, control, accreditation, assurance, statistical analysis, reporting, maintenance, interaction, and management of actions, information, and activities related to suppliers, contractors, and their employees with ATELIER 17.56.
  • Execution of employment contracts.
  • General communication, registration, training, authorization, and management of activities or actions involving employees and their families with ATELIER 17.56.
  • Accessing, consulting, comparing, and evaluating all information about the data subjects stored in the databases of any legitimately constituted credit, financial, judicial, or security risk centers, whether state or private, national or foreign.
  • Investigating, verifying, and validating the information provided by the data subjects, with any information ATELIER 17.56 legitimately possesses.
  • Offering ATELIER 17.56 products or services.

If ATELIER 17.56 is unable to process the data by itself, it may transfer the collected data for processing by a third party, after notifying the data subjects. The third party will be responsible for processing and must ensure appropriate confidentiality and security conditions for the transferred information.


  1.  RIGHTS OF DATA SUBJECTS

In accordance with Article 8 of Law 1581 of 2012 and Decree 1377 of 2013 of Colombia, data subjects have the following rights:

  1. a) Know, update, and rectify their personal data with ATELIER 17.56 as the Data Controller. This right can be exercised with respect to partial, inaccurate, incomplete, or fragmented data that induces error, or data whose processing is expressly prohibited or unauthorized.
  2. b) Request proof of the authorization granted to ATELIER 17.56 as the Data Controller, except when expressly exempted as a requirement for processing, in accordance with Article 10 of Law 1581 of 2012 of Colombia (or the regulations that amend, add, complement, modify, or repeal it), or when the continuity of processing is provided for as per numeral 4 of Article 10 of Decree 1377 of 2013 of Colombia.
  3. c) Be informed by ATELIER 17.56, upon request, about the use given to their personal data.
  4. d) File complaints with the Superintendence of Industry and Commerce for violations of Law 1581 of 2012, after having exhausted the consultation or claim process with ATELIER 17.56.
  5. e) Revoke the authorization and/or request the deletion of the data when the processing does not respect constitutional and legal principles, rights, and guarantees. The revocation and/or deletion will proceed when the Superintendence of Industry and Commerce has determined that the Data Controller or Data Processor has engaged in conduct contrary to the law and the Constitution.
  6. f) Access their processed personal data for free.

  7.  RESPONSIBLE AREA FOR HANDLING REQUESTS, INQUIRIES, AND COMPLAINTS

The Administrative and Financial Management Area of ATELIER 17.56 will be responsible for handling requests, inquiries, complaints, claims, or for exercising the rights of the data subjects.


  1.  PROCEDURE TO EXERCISE THE RIGHTS OF THE DATA SUBJECT

6.1 Procedure for Access and Inquiry

Data subjects, or their successors, may inquire about the information in ATELIER 17.56's databases by submitting the corresponding request to the company's email.