Policy for the treatment of
personal information
UNIBOL PAPER BAG FACTORY S.A.S. is a company committed to compliance with the Colombian regulations, respect for the fundamental rights enshrined in the Political Charter and, in particular, the proper handling of personal data, information that the owners of the same, as employees, customers, suppliers, contractors or under any other link with UNIBOL S.A.S. have given us, with their due authorization, for the fulfillment of the activities of the company or the development of joint activities, have given us, with their due authorization, for the fulfillment of the company’s activities or the development of joint activities.
In accordance with the above and as responsible for the use of personal data provided to UNIBOL S.A.S. we give compliance with Law 1581 of 2012 on Protection of Personal Data and its Regulatory Decree No. 1377 of 2013, enacting the following Policy of Treatment of Information:
1. Recipients of the Information Processing Policy
The Information Processing Policy applies to all holders of personal information (personal data) that is used and/or is found in the databases of UNIBOL S.A.S.
2. Principles governing the Treatment of Information
The collection and processing of personal data will be carried out respecting the general and special rules and the authorization given by the owner of the same, such as the principles enshrined in Article 4 of Law 1581 of 2012, such principles being the following:
a) Principle of legality.
b) Principle of finality.
c) Principle of freedom.
d) Principle of truthfulness or quality.
e) Principle of transparency.
f) Principle of restricted access and circulation.
g) Safety principle.
h) Principle of confidentiality.
3. Name or company name and contact details of the person responsible for the processing of the information.
UNIBOL PAPER BAG FACTORY S.A.S
Web: https://www.unibol.com.co
Office: Administrative Assistant
Email: master@unibol.com.co
Phone: (575) 336 67 00 – (575) 336 6712
Fax: (575) 336 6797
Autopista al Aeropuerto Km.7
Soledad (Atl), Colombia
4. The treatment to which the personal information will be submitted and its purpose.
The data collected by UNIBOL S.A.S. will be processed for the following purposes:
a. To advance the relevant steps for the development of the pre-contractual, contractual and post-contractual stage with UNIBOL S.A.S., with respect to any of the products offered by the company.
b. To advance the pertinent steps for the development of the pre-contractual, contractual and post-contractual stage with UNIBOL S.A.S., for the contracting of services or goods required by the company.
c. To comply with Colombian law and the orders of judicial or administrative authorities.
d. To make invitations to events, offer products or services and, in general, to carry out all activities associated with the corporate purpose of UNIBOL S.A.S. or the existing or future business relationship with UNIBOL S.A.S.
e. Manage procedures (requests, complaints, claims) before UNIBOL S.A.S.
f. Conduct satisfaction surveys regarding the products of UNIBOL S.A.S.
g. To carry out marketing and/or promotion activities of products or services of UNIBOL S.A.S. or its related companies or third parties with whom UNIBOL S.A.S. has entered into commercial alliances, and such activities may be carried out directly by UNIBOL S.A.S. or its related companies or with the support of third parties, with whom will share my personal information.
h. To disclose, transfer and/or transmit personal data inside and outside the country, to computer media in the cloud, as well as to third parties as a result of a contract, law or lawful link that requires it.
i. Access and consult personal data contained in databases or files of any Private or Public Entity (such as, among others, Ministries, Administrative Departments, the DIAN, the Prosecutor’s Office, the Courts, tribunals and High Courts) whether national, international or foreign.
j. Report, access and consult personal data, including financial and credit information, which is stored or contained in databases or files of credit bureaus, such as CIFIN and DATACRÉDITO; this power entails reporting the birth, development, modification, termination and fulfillment of obligations contracted or to be contracted, the existence of unpaid debts or the improper use of contracted services.
k. Transfer or transmit personal data to companies related to UNIBOL S.A.S.
l. To carry out procedures or formalities before entities that are part of the Social Security Health System (Pension, Health, ARL), entities of prepaid medicine or insurance companies.
m. To carry out procedures or formalities related to the shareholders of the company.
n. To create databases for the purposes described in this authorization. o. The treatment and use canbe given through any existing or future means.
5. The rights of the holder of the personal information.
Law 1581 of 2012, establishes the rights of the holder of personal data:
a. To know, update and rectify their personal data with respect to the Data Controllers or Data Processors. This right may be exercised, among others against partial, inaccurate, incomplete, fractioned, misleading, or those whose treatment is expressly prohibited or has not been authorized;
b. Request proof of the authorization granted to the Data Controller, except when is expressly exempted as a requirement for the Processing, in accordance with the provisions of Article 10 of this law;
c. To be informed by the Data Controller or the Data Processor, upon request, regarding the use that has been made of their personal data;
d. File before the Superintendence of Industry and Commerce complaints for violations of the provisions of this law and other rules that modify, add or complement it;
e. To revoke the authorization and/or request the deletion of the data when the principles, rights and constitutional and legal guarantees are not respected in the Processing. The revocation and/or deletion will proceed when the Superintendence of Industry and Commerce has determined that in the Processing the Controller or Processor has incurred in conduct contrary to this law and the Constitution;
f. Access free of charge to your personal data that have been subject to Processing.
6. Authorization for the processing of personal information
In compliance with the provisions of Regulatory Decree 1377 of 2013, UNIBOL S.A.S. requests ratification and authorization, to all holders of personal information that has been and will be collected by UNIBOL S.A.S. for the use of their personal information and the continuity in its treatment, including that which has been collected with prior to the entry into force of the aforementioned decree as that which is collected after its entry into force.
If within 30 business days following the publication of the Information Processing Policy, the holder of the personal information does not manifest by any means before UNIBOL S.A.S. the suppression of their personal data, it is understood, according to Law 1581 of 2012 and the Regulatory Decree 1377 of 2013, that UNIBOL S.A.S. may continue with the processing of personal information, under the terms and conditions set forth in the aforementioned rules and under the rules of the Information Processing Policy.
Notwithstanding the above, at any time, even after the expiration of the aforementioned term, the owner of the information may request UNIBOL S.A.S. to delete his/her personal data or revoke the aforementioned authorization.
For personal information that is collected after the entry into force of the Decree Regulatory 1377 of 2013, UNIBOL S.A.S. makes available to the holder of the personal information the format Authorization for the Processing of Personal Information, which is requested to be filled out and sent to UNIBOL S.A.S. in those cases in which the holder of the information wishes to freely grant UNIBOL S.A.S. its authorization for the processing of personal information. The format Authorization for the Processing of Personal Information will be sent electronically. In addition, the holder of the information may issue his/her authorization using the different means that UNIBOL S.A.S. has available for this purpose.
7. Sensitive information and information related to children and adolescents.
UNIBOL S.A.S. will not request information of sensitive data, which are defined in art. 5 of the Law 1581 of 2012.
If UNIBOL S.A.S. should require sensitive data, they will request and treat them in strict compliance with the Law 1581 of 2012 and requesting prior, express and clear authorization from the owner.
Similarly, UNIBOL S.A.S. will not request information regarding children and adolescents, as it is a prohibition of the Law 1581 of 2012, except in the cases excepted therein.
If UNIBOL S.A.S. should require data of children and adolescents, UNIBOL S.A.S. will request and process them with in strict compliance with Law 1581 of 2012 and requesting prior, express and clear authorization from the legal representative of the owner.
8. Validity of the Authorization for the Processing of Personal Information
The Authorization for the Treatment of Personal Information will be in force during the same time in which UNIBOL S.A.S. exercises or develops its corporate purpose.
The Information Processing Policy may be modified by UNIBOL S.A.S., at any time and in compliance with Law 1581 of 2012 or the rule that regulates the matter, entering into force such modifications from its publication. The modifications will be published on the website of UNIBOL S.A.S. or will be communicated by electronic means.
9. Procedure for complaints and claims or to exercise the rights established in Law 1581 of 2012.
UNIBOL S.A.S., following the rules of the Personal Data Protection Law, establishes the following
procedure:
The owner of the data may submit his request, complaint or claim specifying the following data:
a. First and last names,
b. Contact information (physical and/or electronic address and contact telephone numbers),
c. Means to receive a response to your request, d. Reason(s)/fact(s) giving rise to the claim,
e. Description of the right you wish to exercise before UNIBOL S.A.S.,
f. Signature, identification number and fingerprint.
g. Attach a copy of the holder’s identity document. When the request is made by a successor, attorney-in-fact and/or representative of the holder, he/she must prove such capacity.The owner of the data must attach the documents supporting his request and/or violation of his rights that he wishes to assert.
The request, complaint or claim should be addressed to UNIBOL S.A.S. headquarters.
Incomplete petitions, complaints and claims or with any type of inconsistencies, may be corrected within five (5) days following the receipt of the filing.
If after two (2) months from the initial filing of the complaint or claim, the applicant has not completed the required information, it will be understood that the claim has been withdrawn.
Once the completed claim is received, it will be marked in the database with a legend that says “claim in processing” and the reason for it, within a period not exceeding two (2) business days.
Such marking will be maintained until the request, complaint or claim is resolved.
If the person or area that receives the claim is not competent to resolve it, he/she will transfer it to the corresponding person within a maximum term of two (2) business days and will inform the interested party of the situation.
The response times will be:
a. The consultations of the personal information of the Holder contained in the database of UNIBOL S.A.S. will be answered within a maximum period of ten (10) working days from the date of receipt of the same.
When it is not possible to attend the consultation within such term, the interested party will be informed, expressing the reasons for the delay and indicating the date on which the consultation will be attended, which in no case may exceed the five (5) working days following the expiration of the first term.
b. Claims and complaints will be addressed within fifteen (15) business days from the day following the date of receipt. When it is not possible to address the claim within such term, the interested party will be informed of the reasons for the delay and the date on which the claim will be addressed, which in no case may exceed eight (8) business days following the expiration of the first term.
c. Requests, other than those referred to in paragraph a) above, shall be dealt with within fifteen (15) business days from the day following the date of receipt. When it is not possible to attend the claim within such term, the interested party shall be informed of 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.The Owner of the information or assignee may file a complaint before the Superintendence of Industry and Commerce once he/she has exhausted the consultation or complaint process before UNIBOL S.A.S., according to the procedure mentioned above.
10. Date of Publication of the Information Processing Policy
This Information Processing Policy is updated and published through electronic and/or physical media , as of August 17, 2016.