This Policy outlines the measures taken by Efamaa SAS to secure your Personal Data, as well as the procedures followed for the collection, use, and disclosure of such data.
Information of the Data Controller
Efamaa SAS
9011178799
Cra. 7 #156-80, Torre 3 Oficina 1805, Bogotá – Colombia
+57 601 743-2271
Esael Angel
Esael Angel
contacto@efamaa.com
www.efamaa.com
Application and Regulatory Framework
Based on Article 15 of the Colombian Constitution, Law 1581 of 2012, and Regulatory Decrees 1377 of 2013 and 886 of 2014 (now contained in Chapters 25 and 26 of the Single Decree 1074 of 2015), which develop the general framework for data protection in Colombia, Efamaa SAS has implemented this Personal Data Processing Policy, which will govern all areas of the company and third parties entrusted with the processing of the provided personal data. This is to respect the rights and guarantees of data subjects regarding privacy and to comply with applicable regulations.
MANDATORY COMPLIANCE
This Policy is mandatory and must be strictly followed by all employees, contractors, and third parties acting on behalf of Efamaa SAS (including its Data Processors). All must observe and respect this Policy in the performance of their duties. In cases where there is no employment relationship, a contractual clause must be included requiring those acting on behalf of Efamaa SAS to comply with this Policy. Non-compliance will result in labor sanctions or contractual liability, without prejudice to the obligation to compensate for damages caused to data subjects or the company due to improper processing of Personal Data. For all purposes, this Policy will serve as an internal manual of policies and procedures, as well as an information processing policy, as provided in Articles 17 (literal k), 18 (literal f), and 25 of Law 1581 of 2012.
Glossary of Terms
Companies with which Efamaa SAS shares one or more shareholders.
Physical, electronic, or any other format document containing the prior, express, and informed consent granted by the Data Subject for the processing of their Personal Data by Efamaa SAS.
An organized set of Personal Data subject to processing, including physical, electronic, and automated files.
According to the classification established in the Personal Data Protection Law, distinguished by the degree of confidentiality required for its processing.
Information that affects the privacy of the Data Subject or whose misuse could lead to discrimination (e.g., data on racial origin, political orientation, religious beliefs, health data, among others).
A natural or legal person who, independently or in association, processes Personal Data on behalf of Efamaa SAS.
The person designated by Efamaa SAS whose primary function is to protect the Personal Data of data subjects, monitor compliance with this Policy, and process requests for the exercise of rights.
Efamaa SAS, which acts in relation to the data subjects whose personal data it decides to process.
A natural person whose Personal Data is subject to processing.
Any operation or set of operations performed on Personal Data, whether automated or not, such as collection, recording, organization, storage, consultation, use, disclosure, among others.
Processes through which Personal Data is communicated or sent to a third party, either within or outside the national territory, as long as the Law permits it.
Any incident involving the destruction, loss, alteration, unauthorized disclosure, or illegal access to Personal Data.
Principles for Personal Data Processing
Purpose of Personal Data Processing
The purposes for which Personal Data is collected by Efamaa SAS will be established in the Authorization granted by the Data Subject. By way of example, the following purposes may be authorized:
The processing will be carried out to comply with legal and regulatory obligations in labor, tax, and social security matters, among other administrative and internal management activities.
The processing will be aimed at preventing illegal activities, evaluating profiles, verifying information, and other purposes related to recruitment.
Rights of Personal Data Subjects
Duties of Efamaa SAS as Data Controller
Authorization for Personal Data Processing
Sensitive Personal Data
In general, Efamaa SAS does not process Sensitive Data, except in exceptional cases where:
Consultation Procedure
1.1 Guaranteed Rights:
Efamaa SAS guarantees the Data Subject the right to consult the information contained in their individual record and any other information linked to their identification, in accordance with the law.
1.2 Responsible for Handling Consultations:
The Privacy Officer of Efamaa SAS will be responsible for receiving and processing consultation requests.
1.3 Means to Submit Consultations:
1.4 Response Times:
Requests will be processed within a maximum term of ten (10) business days from receipt. In case of impossibility, the interested party will be informed before the expiration of the term, indicating the reasons and the new response date (which will not exceed five (5) additional business days).
2.1 Guaranteed Rights Through the Claims Procedure:
Efamaa SAS guarantees the Data Subject the right to request the correction and updating of their Personal Data, as well as to revoke the Authorization or request the deletion of their Personal Data, provided that legal parameters are met.
2.2 Responsible for Handling Claims:
The Privacy Officer of Efamaa SAS will be responsible for receiving and processing claims, in accordance with current regulations.
2.3 Means and Requirements to Submit Claims:
The claim must contain, at a minimum:
2.4 Deadlines and Additional Procedures:
2.5 Personal Data Deletion Procedure:
If the deletion of Personal Data is appropriate in accordance with the claim, Efamaa SAS will carry out the deletion in such a way that the information is not recoverable, except when legal retention obligations require certain data to remain in historical records.
International Transmission or Transfer of Personal Data
When Efamaa SAS carries out an international transmission or transfer of Personal Data, it will only do so when:
Acceptance of the Personal Data Processing Policy
The Data Subject accepts the processing of their Personal Data in accordance with the terms of this Policy. Efamaa SAS may continue processing Personal Data for the described purposes, as long as the right to revoke or delete such authorization is not exercised.
Privacy Officer
In accordance with current regulations, Efamaa SAS has designated a Privacy Officer, who will be responsible for:
The Privacy Officer is:
National Database Registry
Efamaa SAS will proceed to register its Databases and this Policy in the National Database Registry administered by the Superintendency of Industry and Commerce, in accordance with the provisions of the Circular and other applicable regulations.
Personal Data Breach or Risk in Administration
In the event of any breach of Personal Data or risk in its administration, Efamaa SAS will immediately inform the Superintendency of Industry and Commerce, in accordance with the provisions of the Personal Data Protection Law.
Scope and Purpose of Granted Authorizations
The term of the authorizations for the use of Personal Data will be understood as the duration of the commercial relationship or association with Efamaa SAS, or while the corresponding services are provided, unless regulations require their retention for longer periods.
Validity of the Policy
This Policy is effective as of August 20, 2020, and will remain in force indefinitely, as long as Efamaa SAS maintains activities that require the processing of Personal Data. Data Subjects are advised to periodically review this Policy on the website www.efamaa.com, where any modifications will be published.
The most recent modification of this Policy is as of June 13, 2024. Any changes will be communicated to Data Subjects in a timely manner.
Efamaa SAS
Legal Representative and Privacy Officer:
Esael Angel
Let's talk about your project and how we can help you achieve your goals. Fill out the form below and we'll get back to you as soon as possible.
Phone fijo:+57 601 743-2271
Whatsapp:+57 312 248 7805
Email: contacto@efamaa.com
Customer service: sac@grupoefamaa.com
Address:Cra. 7 #156-80, Torre 3 Oficina 1805 Bogotá - Colombia
OfficeHours:
Monday to Friday 8am to 6pm. , Saturday 8am to 12pm.