Processing of Personal Data

ABOUT US?

ALTAIR INGENIERIA S.A.S. is a Colombian company certified under ISO standards 9001, OHSAS 18001 and with the Certification of the Colombian Security Council under the RUC guide, with experience of more than 27 years in project management, the audit, consulting and training in the petroleum industries, gas, energy and in general the productive sector of Latin America.

It has a division called ALTAIR GLOBAL BUSINESS, that provides virtual office services, furnished and meeting room. The experience of several years working for multiple and varied companies, together with the privileged location of our offices, allows ALTAIR to offer a service with great benefits for all entrepreneurs, the independents, investors who seek to develop new companies in Colombia and in general for all those who want offices at low costs, all included, that allows them to focus all their energies on their business.

I. APPLICATION AND REGULATORY FRAMEWORK

With the issuance of this Policy, the internal regulations of ALTAIR GLOBAL BUSINESS are established., for the treatment of information and personal data of its visitors, customers, suppliers and employees; at the same time, seeks to disseminate and safeguard the rights that these people have in front of the company to know and / or request the update, rectification or elimination of the information collected in the databases.
This Policy will be applicable in all communication channels, promotion and advertising that the company establishes from time to time for these purposes.
Our Privacy Policy has been drawn up in order to allow ourselves under self-regulation parameters to process personal data that respects all the rights and guarantees regarding privacy of the holders about whom we process personal data.. It was the Constitution of Colombia that in its Article 15 has established as a constitutional right to the protection of your personal data; Likewise through the Law 1581 of 2012 and regulatory decrees 1377 of 2013 Y 886 of 2014 - Today contained in the chapters 25 Y 26 of the sole decree 1074 of 2015, of the Commerce sector, Industry and Tourism, the general data protection framework was developed in Colombia.

II. DEFINITIONS

Notice of Privacy: It is the physical document, electronic or in any other format, generated by ALTAIR GLOBAL BUSINESS / ALTAIR INGENIERIA S.A.S. that has been made available to the Holder for the Treatment of their Personal Data, which communicates to the Owner the information regarding the existence of the Personal Data Treatment Policies that will be applicable, the way to access them and the characteristics of the Treatment that is intended to give the Personal Data.
Database: They consist of an organized set of Personal Data that are subject to Treatment, and includes physical and electronic files.
Personal Data: Any information linked or that may be associated with one or more specific or determinable natural persons [1]. The "personal data" should then be understood as information related to a natural person (individually considered person).
Sensitive data: Aquel dato que afecta la intimidad del Titular o cuyo uso indebido puede generar su discriminación, such as those that reveal racial or ethnic origin, political orientation, religious or philosophical convictions, union membership, 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, to sex life and biometrics [2].
In charge of the treatment: ALTAIR GLOBAL BUSINESS / ALTAIR INGENIERIA S.A.S. acts as the person in charge of the processing of personal data in the cases, that by himself or in association with others, carry out the processing of personal data on behalf of a data controller.
Responsible for the treatment: ALTAIR TRAINING / ALTAIR INGENIERIA S.A.S. acts as the person responsible for the processing of personal data against all personal data on which it decides directly, in compliance with its own legally recognized functions
Headline: Natural person whose personal data are subject to Treatment.
The rights of the holders established by law may be exercised by the following persons:
By the Holder, who must prove their identity sufficiently by the different means made available by the person in charge.
For his successors in title, who must prove such quality.
By the representative and / or attorney of the Holder, previous accreditation of representation or empowerment.
By stipulation in favor of another or for another.
Treatment: It is any operation or set of operations on Personal Data that ALTAIR TRAINING performs / ALTAIR INGENIERIA S.A.S. or those in charge of the treatment on behalf of the company such as the collection, storage, use, circulation or suppression.
Transfer: It consists of sending the Personal Data to a recipient who, at the same time, is responsible for the Treatment in the terms of the Law 1581 of 2012.
Transmission: It is the communication of Personal Data to the Person in Charge of Treatment, inside or outside the territory of the Republic of Colombia, with the purpose of carrying out a Treatment by the Person in Charge of Treatment on behalf of ALTAIR GLOBAL BUSINESS / ALTAIR INGENIERIA S.A.S.
Data protection officer: He is the person within ALTAIR GLOBAL BUSINESS / ALTAIR INGENIERIA S.A.S., whose function is to monitor and control the application of the Personal Data Protection Policy, under the guidance and guidelines of the general management. This will designate the Data Protection Officer.
The previous definition refers to a role or function that an official must perform within ALTAIR GLOBAL BUSINESS / ALTAIR INGENIERIA S.A.S.

III. PURPOSE OF THE PROCESSING OF PERSONAL DATA

Visitors, clients and suppliers: The databases generated from the personal data provided by our visitors, clients and suppliers, will be used in the following activities:
Sending information about news in courses, company and / or industry programs and trainings.
Report on advertising campaigns, informative or promotional.
Conduct market research on trends and consumption habits.
Evaluate the quality of our services and the level of customer satisfaction.
Carry out directly or through its parent company, affiliates or subsidiaries or third-party business allies promotional activities, marketing or advertising.
Advertise loyalty programs or campaigns with benefits.
Transmit and / or transfer personal data to its parent company, affiliates or subsidiaries or third party allies linked through commercial relationships with the company on a national or international level.
All those activities that are consistent with the purpose of the company and that are suitable for carrying out marketing and advertising activities.
These activities may be carried out through physical mail, electronic, text messages via cell phone (SMS/MMS) or by any other technological means of communication.
The acceptance of this Personal Data Treatment Policy by its Holders, It entails the authorization to carry out the treatment of the same, partially the total, including collection, storage, recording, use, circulation, prosecution, suppression, transmission and / or transfer to third countries of the data provided, for the execution of activities related to the products purchased, accounting records, correspondence, credit card processing and verification, debit and other payment instruments, identification of fraud and prevention of money laundering and financing of terrorism and other criminal activities and / or for the operation of loyalty and loyalty programs.
Employees:
The information collected is used to carry out an analysis process, evaluation and selection of personnel to work in the company.
-The employee(a), authorizes ALTAIR GLOBAL BUSINESS / ALTAIR INGENIERIA S.A.S. to process the personal data provided in the development of the employment relationship, during the entire time of permanence in the entity and after the relationship has ended as long as there is a legal or contractual conservation duty on the part of ALTAIR GLOBAL BUSINESS / ALTAIR INGENIERIA S.A.S..
-The authorization for the processing of personal data is granted by the employee within what is described in this Personal Data Protection Policy, that is known and conforms to what is prescribed by law 1581 of 2012.
-Similarly, the employee(a) what, without being empowered to do so, destroy, damage, erase, deteriorate, alter or delete computer data, or an information processing system or its parts or logical components, may be criminally denounced for the crime of computer damage. Likewise, the employee(a) what, without being empowered to do so, for your own benefit or that of a third party, get, compile, subtract, offer, sale, swap, send, buy, intercepts, disclose, modify or use personal codes, personal data contained in files, files, databases or similar media, may be reported for the conduct of violation of personal data. The breach of these Personal Data Protection Policies adopted and published by ALTAIR GLOBAL BUSINESS will be considered a serious offense. / ALTAIR INGENIERIA S.A.S. becoming a cause for suspension or termination of the employment contract. (In all cases the employee(a) You can make use of your Habeas Data rights (Know, update and rectify your information) with the exception of what is established in the law.

IV. RIGHTS OF THE HOLDERS OF PERSONAL DATA

The Holders of the Personal Data registered in the Databases of ALTAIR GLOBAL BUSINESS / ALTAIR INGENIERIA S.A.S., As mentioned in the Law and its decrees, they have the following rights:
Know, update and rectify your personal data. These rights may be exercised, among others, against partial Personal Data, inaccurate, incomplete, fractionated, misleading, or those whose Treatment is expressly prohibited or has not been authorized;
Request proof of the Authorization granted to ALTAIR GLOBAL BUSINESS / ALTAIR INGENIERIA S.A.S. except when expressly excepted as a requirement for the Treatment, in accordance with the provisions of article 10 of the law 1581 of 2012;
Be informed about the use that has been given to your Personal Data by ALTAIR GLOBAL BUSINESS / ALTAIR INGENIERIA S.A.S., or the person in charge of the treatment, upon request;
By claim submitted pursuant to Art. 15 of the law 1581 of 2012, You can request the revocation of the authorization and / or request the deletion of the Personal Data when the principles are not respected in the Treatment, constitutional and legal rights and guarantees or at any time provided that the owner does not have a legal or contractual duty to remain in the databases of ALTAIR GLOBAL BUSINESS / ALTAIR INGENIERIA S.A.S. and in accordance with the procedure indicated in numeral IV., of this Policy.
Access for free at least once a month, to your personal data that have been subject to Treatment.

V. CONSULTATION AND CLAIMS PROCEDURE

ALTAIR GLOBAL BUSINESS / ALTAIR INGENIERIA S.A.S. guarantees the right of consultation, supplying people who act in exercise of this right, all the information contained in your individual record or that is linked to the identification of the Holder.
The interested party may send their request to the email address protecciondatos@altairgb.com or by submitting the written request at our offices located on Calle 93 #11A-28 office 601, in the city of Bogotá D.C.
In any case, regardless of the mechanism implemented to attend to query requests, They will be attended to in a maximum term of ten (10) business days from the date of receipt. In case of impossibility to attend the consultation within said term, We will inform the interested party before the expiration of the 10 days, stating the reasons for the delay and indicating the date on which your inquiry will be addressed, which in no case may exceed five (5) business days following the expiration of the first term.
We also guarantee the right to claim, to databases for correction, update or deletion, o cuando adviertan el presunto incumplimiento de cualquiera de los deberes contenidos en la Ley 1581 of 2012 y demás normas aplicable. El reclamo será tramitado bajo las siguientes reglas:
If the claim received does not have complete information that allows it to be processed, such as, the holder's identification, the description of the facts that give rise to the claim, the direction, and accompanying the documents that you want to enforce, the claimant will be required within five (5) days after receipt to correct the faults. After two (2) months from the date of the request without the applicant submitting the required information, It will be understood that you have withdrawn the claim.
If for any reason ALTAIR GLOBAL BUSINESS / ALTAIR INGENIERIA S.A.S. you receive a complaint directed to another organization, will transfer to whoever corresponds in a maximum term of two (2) working days and will inform the claimant of the situation.
Received the claim in full, will include in the database maintained by ALTAIR GLOBAL BUSINESS / ALTAIR INGENIERIA S.A.S. a legend that says "claim in process" and the reason for it, in a term no longer than two (2) business days. Said legend must be kept until the claim is decided..
The maximum term to attend the claim will be fifteen (15) business days counted from the day following the date of receipt. When it is not possible to attend to it within said term, the interested party will be informed before the expiration of said period 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.
Special rules for the exercise of the rights of the holders: The request for rectification, Update or deletion must be submitted through the means enabled by ALTAIR GLOBAL BUSINESS / ALTAIR INGENIERIA S.A.S. indicated in the privacy notice and in this document, and contain, As minimum, the next information:
Name, Owner's address and means of contact to receive the answer as a telephone, email, residence address.
Documents proving the identity or representation of your representative.
The clear and precise description of the personal data with respect to which the owner seeks to exercise any of the rights.
In case of other elements or documents that facilitate the location of personal data.
ALTAIR GLOBAL BUSINESS / ALTAIR INGENIERIA S.A.S., has the obligation to rectify and update at the request of the owner, the information on it that turns out to be incomplete or inaccurate, de conformidad con el procedimiento y los términos arriba señalados. Al respecto se tendrá en cuenta lo siguiente:
ALTAIR GLOBAL BUSINESS / ALTAIR INGENIERIA S.A.S. You have full freedom to enable mechanisms that facilitate the exercise of this right.
Data Suppression. The owner has the right, at all times, to request ALTAIR GLOBAL BUSINESS / ALTAIR INGENIERIA S.A.S., the suppression (elimination) of your personal data when:
Consider that they are not being treated according to the principles, Duties and obligations provided for in the Law 1581 of 2012.
They are no longer necessary or relevant for the purpose for which they were collected.
The period necessary to fulfill the purposes for which they were collected has been exceeded.
This deletion implies the total or partial elimination of personal information in accordance with what is requested by the owner in the records, files, databases or treatments carried out by ALTAIR GLOBAL BUSINESS / ALTAIR INGENIERIA S.A.S.. The owner must warn that the right of cancellation is not absolute and the person in charge can deny the exercise of the same when:
The request to delete the information will not proceed when the owner has a legal or contractual duty to remain in the database..
The elimination of data that hinders judicial or administrative actions related to tax obligations, investigation and prosecution of crimes or updating administrative sanctions.
The data that are necessary to protect the legally protected interests of the owner; to take action in the public interest, or to comply with an obligation legally acquired by the owner.
In case the cancellation of personal data is appropriate, ALTAIR GLOBAL BUSINESS / ALTAIR INGENIERIA S.A.S., you must operationally perform the deletion in such a way that the deletion does not allow the recovery of the information. It should also be taken into account that in some cases certain information must remain in historical records due to compliance with the legal duties of the organization, so its deletion will deal with the active treatment of the same and in accordance with the request of the owner..

WE. REVOCATION AND / OR SUPPRESSION OF THE AUTHORIZATION

The owners of the personal data can revoke the authorization granted in favor of the Person in charge of the Treatment on their personal data, anytime, by filing a claim in accordance with the procedure established in the Law 1581 of 2012 and / or in any other standard that adds it, modify or repeal. The request for deletion of the information and the revocation of the authorization will not proceed in cases in which the clients, ALTAIR GLOBAL BUSINESS suppliers and employees / ALTAIR INGENIERIA S.A.S., have a legal or contractual duty to remain in the database.
It is important to bear in mind that the revocation may be requested on all or part of the data that comprise the authorization granted in this Information Treatment Policies document - Privacy Notice, but not with respect to the data regulated under the Law 1266 of 2008 and / or any other standard that adds it, modify or repeal, as well as neither, it is reiterated, respecto de aquéllos casos en los que el asociado o proveedor tenga un deber legal o contractual de permanecer en la base de datos.

VII. INTERNATIONAL TRANSFER OF PERSONAL DATA

In the event that data is sent or transferred to another country, the authorization of the owner of the information that is being transferred must always be obtained.. Unless the law says otherwise, the existence of said authorization is a necessary presupposition to carry out the international circulation of data. In this sense, before sending personal data to another country, Those obliged to comply with this policy must verify that they have prior authorization, express and unequivocal of the owner who allows the transmission of their personal data.
Said transfer of personal data is made only to third parties with whom ALTAIR GLOBAL BUSINESS / ALTAIR INGENIERIA S.A.S., have a contractual relationship, commercial and / or legal.

VIII. ACCEPTANCE OF THE POLICIES FOR THE TREATMENT OF PERSONAL INFORMATION

The visitor, client, supplier and employee of ALTAIR GLOBAL BUSINESS / ALTAIR INGENIERIA S.A.S. accept the processing of your personal data, in accordance with the terms of this document and ALTAIR GLOBAL BUSINESS / ALTAIR INGENIERIA S.A.S. You can continue to process the data for the purposes described, si no ejercen su derecho de revocar o suprimir.

IX. DATA PROTECTION OFFICER

According to the article 23 decree 1377 of the 2013, Every person in charge and in charge must designate a person or area that "assumes the function of protection of personal data" and that "will process the requests of the holders, for the exercise of the rights referred to by law 181 of the 2012 and this decree.
The function of the data protection officer or the area in charge of data protection in the organization is to ensure the effective implementation of the policies and procedures adopted by it to comply with the regulations, as well as the implementation of good personal data management practices within the company.
The data protection officer will have the task of structuring, design and administer the program that allows the organization to comply with the regulations on the protection of personal data, as well as setting the controls for that program, its evaluation and permanent review.[3]

X. NATIONAL REGISTRY OF DATABASE

According to Art. 25 of the law 1581 and its regulatory decrees, ALTAIR GLOBAL BUSINESS / ALTAIR INGENIERIA S.A.S. You must register your databases together with this Personal Data treatment policy in the National Database Registry administered by the Superintendency of Industry and Commerce in accordance with the procedure stipulated by Circular 002 of 2015.

XI. VALIDITY AND UPDATING OF POLICIES

The initial Policy was published on 26 November 2019 and was made available to the owners through the website: link
La actualización de la política rige a partir del 1 de diciembre del 2019 por un término de diez (10) years and will be available to the owners through the same website mentioned.
As a rule, The term of the authorizations on the use of personal data is understood as the term of the commercial relationship or of the relationship with the company and during the exercise of the company's corporate purpose.
The authorizations of the holders may terminate at their will at any time. If the person is an active client of ALTAIR INGENIERIA S.A.S. Your data may not be used for a purpose other than the provision of the product or service and for the offer of subsequent renewals when the service has this modality.
When the terms of the privacy policies of any of the services or products contracted by a holder, change in the essential, as a rule, In the services that have the renewal option, the new authorization will be obtained.. For all other cases, Authorization will be obtained in the manner established for each privacy policy or notice or through the usual means of contact between the company and the owners.
Any substantial change in the Treatment policies, It will be communicated in a timely manner to the owners of the data through the usual means of contact and / or through:
The website https://altairgb.com/
Email sent to holders
For holders who do not have access to electronic media or those who cannot be contacted, will be communicated through open notices on the website or at the company headquarters.
Communications will be sent at least, ten (10) days before implementing the new policies and / or substantial update of the same.