POLICY FOR HANDLING, ADMINISTRATION AND TREATMENT OF PERSONAL DATA IN COMPLIANCE WITH LAW 1581 OF 2012 AND ITS REGULATORY DECREE 1377 OF 2013

1. PURPOSE.

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This policy is issued in compliance with Law 1581 of 2012, Decree 1377 of 2013 and regulations that modify or add to the personal data protection regime and seeks to guarantee that Comercial Alpa SAS (Comercial Alpa) in its capacity as responsible for managing personal information, treat it in strict compliance with the applicable regulations, guaranteeing the rights that the holders of the information have.

2. RESPONSIBLE.

Company name: Comercial Alpa SAS
Address: Cra 51 No 9C Sur 85 Multcentro Guayabal Ofi 601.
City: Medellin
Email: info@alpa.co
Telephone: (574) 362 0080
Responsible Area: Administrative

3. VALIDITY OF THE POLICY.

This policy becomes effective on July twenty-six (26), 2013.

4. TREATMENT TO WHICH THE DATA WILL BE SUBJECTED.

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In the exercise of its corporate purpose, Comercial Alpa carries out the processing of personal data of its employees, employees of its contractors, suppliers, customers and users of its products, an activity that it executes directly, or by contractors or agents in charge of it. Likewise, in compliance with applicable legislation and corporate policies, Comercial Alpa may require to transmit or transfer said data to its parent companies, affiliates and/or foreign subsidiaries. 

In development of the principles of purpose and freedom, the collection of personal data by Comercial Alpa will be limited to those personal data that are pertinent and adequate for the purpose for which they are collected or required in accordance with current regulations. Except in the cases expressly provided by law, personal data may not be collected without the authorization of the owner. In compliance with the Alpa Commercial Law, it does not collect or store data on children and adolescents. 

Comercial Alpa has the obligation to maintain the confidentiality of the personal data being processed and may only disclose them at the express request of the surveillance and control entities and authorities that have the legal power to request it and will allow at all times and free of charge to know, update and correct the personal information of the holder in accordance  with article 8 of Law 1581 of 2012.

Data processing includes the collection, storage, administration, use, transfer, transmission and destruction, in the manner permitted by law and is carried out with the following specific purpose for each case:

a) Treatment of personal data of employees and former employees: It is carried out to comply with the labor obligations in charge of Comercial Alpa, such as payroll payments, payments and reports to the general system of social security in health, attention to consultations, requests, requests, actions and claims, made by  the owner of the information or by his heirs, or by entities of the general social security health system to which the owner is or has been linked.

b) Treatment of personal data of employees of contractors, who provide services in Comercial Alpa facilities: Allow Comercial Alpa to comply with the contractual obligations under its charge, such as assignment and control of technological elements, materials, equipment, income identification, monitoring of compliance with obligations by contractors, attention to eventual emergencies, response attention to queries, petitions, requests, actions and claims, made by  the Holder of the information or by his heirs.

c) Treatment of personal data of natural person suppliers: Allows the fulfillment of contractual obligations in charge of Comercial Alpa, such as payment of fees, payment reports, reports or interactions that by law or by internal policies it has the obligation to carry out, attention of queries, requests, requests, actions and claims, made by  the owner of the information or by his legitimate beneficiaries.

d) Processing of personal data of customers who are natural persons: The processing of personal data of customers who are natural persons is for the purpose of Comercial Alpa being able to comply with the contractual obligations under its charge, such as billing, payment reports or interactions that by law or by internal policies, it has the obligation to carry out, attention to queries, requests, requests, actions and claims, made by the owner of the information or by their heirs.

e) Product Users: The processing of this data allows Comercial Alpa  to comply with its obligations in terms of product quality, for the effective attention of consumer queries and claims and as statistical information.

5. RIGHTS OF THE HOLDERS. 

The Holders of personal data have the following rights:

 a) Know, update and rectify your personal data in front of the Treatment Managers or Treatment Managers. This right may be exercised, among others, against partial, inaccurate, incomplete, fragmented, misleading data, or those whose treatment is expressly prohibited or has not been authorized. 

b) Request proof of the authorization granted to the Treatment Manager except when expressly excepted as a requirement for treatment, in accordance with the provisions of article 10 of Law 1581 of 2012. 

c) Be informed by the Treatment Manager or the Treatment Manager, upon request, regarding the use that has been given to their personal data.

d) Submit complaints to the Superintendence of Industry and Commerce for violations of the provisions of the law and other regulations that modify, add or complement it.

e) 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 treatment. The revocation and/or deletion will proceed when the Superintendence of Industry and Commerce has determined that in the treatment the person in charge or in charge has incurred in conduct contrary to the Constitution and the law.

f) Free access to your personal data that has been subject to Treatment.

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6. PROCEDURE FOR THE EXERCISE OF RIGHTS BY HOLDERS.

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Holders of personal data should direct their queries, requests or claims to the email info@alpa.co

a. Queries: Comercial Alpa must respond to queries within a term of ten (10) business days from the date it was received. When it is not possible to comply  with this time, the interested party must be informed, stating the reasons for the delay and the date on which the query will be answered within a term not exceeding five (5) days.

b. Claims: The owner or successor in title who considers that the information contained in a database should be corrected, updated or deleted, or when he notices the alleged breach of any of the duties contained in the law or in this policy, may present a claim to Comercial Alpa which will be processed under the following rules:

i) The claim will be formulated through a request addressed to the Treatment Manager or the Treatment Manager, to the email info@alpa.co with the identification of the owner, the description of the facts that give rise to the claim, the address, and accompanying the documents that you want to assert. If the claim is incomplete, Comercial Alpa will require the interested party within five (5) days after receiving it 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 the claim has been withdrawn. 

ii) Once the complete claim is received, a legend will be included in the database that says "claim in process"   and the reason for it, within a term not exceeding two (2) days skillful. Said legend must be kept until the claim is decided.

iii) The maximum term to address the claim will be fifteen (15) business days from the day following the date of receipt. When it is not possible to address the claim within said term, the interested party will be informed of the reasons for the delay and the date on which his claim will be addressed, which in no case may exceed eight (8) business days following the expiration of the first finished.

iv) The holder or successor in title may file a complaint with the Superintendency of Industry and Commerce, once they have exhausted the query or claim process before the Data Controller or Processor.

c. Revocation of the authorization and/or deletion of the data:

The Holders may at any time request Comercial Alpa to delete their personal data and/or revoke the authorization granted for their treatment, by submitting a claim, in accordance with the provisions of article 15 of Law 1581 of 2012, decree 1377 of 2013 and the procedure indicated in this policy.

If the respective legal term has expired, Comercial Alpa has not deleted the personal data, the owner will have the right to request the Superintendence of Industry and Commerce to order the revocation of the authorization and/or the deletion of the personal data.

Notwithstanding the foregoing, personal data must be kept when required to comply with a legal or contractual obligation.

7. TEMPORARY LIMITATIONS ON THE PROCESSING OF PERSONAL DATA.

Comercial Alpa may only carry out the processing of personal data for as long as is reasonable and necessary, in accordance with the purposes that justified the processing, in accordance with the provisions applicable to the matter in question and the administrative, accounting, fiscal, legal and historical information.

Once the purpose or purposes of the treatment have been fulfilled or the maximum legal period in which Comercial Alpa has the obligation to keep the personal data has expired, Comercial Alpa or the Person in Charge of the Treatment will proceed to delete the personal data in their possession.

Comercial Alpa and those in charge of the Treatment must document the procedures for the treatment, conservation and deletion of personal data in accordance with the provisions applicable to the matter in question, as well as the instructions given in this regard by the Superintendency of Industry and Commerce. .