CCG Data Processing Policy
Cuberos Cortés Gutiérrez Abogados S.A.S., a Firm domiciled in Bogotá at Carrera 12 No. 71 – 33, with email firstname.lastname@example.org and phone number (57-1) 2102915, informs Owners of Personal Data processed by the Firm of its Data Processing Policy, in compliance with Law 1581 of 2012 and Decree 1377 of 2013.
Authorization: Prior, express and informed consent of the Owner to carry out the processing of Personal Data;
Database: Organized set of Personal Data subject to processing;
Personal Data: Any information linked or that may be associated with one or more determined or determinable natural persons;
Data Processor: Natural or legal person, public or private, who by itself or in association with others, performs the processing of Personal Data on behalf of the Data Controller;
Data Controller: Natural or legal person, public or private, who by itself or in association with others, decides over the Database and/or the processing thereof;
Owner of Personal Data: Natural person whose Personal Data is subject to processing;
Data Processing: Any operation or set of operations performed on Personal Data, such as the collection, storage, use, circulation or deletion thereof.
2. Purposes of Data Processing
Any Personal Data processed by the Firm will be strictly subject to the purposes indicated below:
Management of all necessary information for the fulfillment of tax obligations and the commercial, corporate and accounting records of the Firm.
Compliance with service agreements concluded with clients.
Definition of information about our services that we consider may be of interest to our clients.
Control and prevention of fraud and money laundering, including, but not limited to consultation on restrictive lists, and all the necessary information required by SARLAFT.
Data transmission to third parties with whom Personal Data Transmission agreements have been concluded, for commercial, administrative, operational or marketing purposes.
Electronic processing of any type of information related to a particular client or business in order to fulfill the relevant services.
Other purposes as determined by the Data Controller in the process of obtaining Personal Data, as previously informed to the Owners of Personal Data at the time of collection.
Cuberos Cortés Gutiérrez will process any Personal Data of a financial nature only when necessary to carry out billing, portfolio, collection and payment processes for services effectively provided, and for the electronic or physical submission of invoices.
3. Rights of Owners of Personal Data
In accordance with Law 1581 of 2012, Owners of Personal Data have the following rights:
Know, update and rectify their Personal Data with the Data Controller or Data Processor. This right may be exercised, among others, against partial, inaccurate, incomplete, fractional, misleading data, or data whose processing is expressly prohibited or has not been authorized;
Request proof of authorization granted to the Data Controller, except when expressly excepted as a requirement for Data Processing, in accordance with the provisions of Article 10 of the aforementioned law;
Be informed by the Data Controller or Data Processor, upon request, regarding the use made of their Personal Data;
Submit complaints to the Superintendency of Industry and Commerce for breaches of the provisions of the aforementioned law and further regulations that modify, add to or complement it;
Revoke the authorization and/or request the deletion of data when the principles, rights and constitutional and legal guarantees are not respected during Data Processing. Such revocation and/or suppression will proceed should the Superintendency of Industry and Commerce determine that during the processing, the Data Controller or Data Processor has incurred in a conduct contrary to law and the Constitution;
Free access to any processed Personal Data.
4. Data Protection Area
The Firm has designated Ms. María Yolanda Moreno and Mr. Pablo Correal Zambrano as responsible persons for the reception and attention of requests, complaints, claims and queries of all kinds related to Personal Data Processing.
Contact details of the Data Protection Area are:
Address: Carrera 12 No. 71-33 Bogotá
Email: email@example.com and firstname.lastname@example.org
Phone: (57-1) 2102915
5. Procedures to exercise the rights of Owners of Personal Data
Any query or claim related to the processing of the Personal Data of Owners must be submitted via email. Cuberos Cortés Gutiérrez will resolve such requests within ten (10) business days from the date they are received.
The consent granted by the Owner may be revoked at any time, by means of prior written notice addressed to the Data Protection Area and submitted to the aforementioned email addresses, in the terms established by Law 1581 of 2012.
6. Information Security
Cuberos Cortés Gutiérrez has implemented the necessary technical, human, and administrative security measures at its disposal to ensure confidentiality and prevent adulteration, loss, consultation, and unauthorized or fraudulent use or access of the collected data, which shall be processed pursuant to this Data Processing Policy.
This policy is effective as of February 1, 2016.
Any processed Personal Data will remain in our Database, in accordance with the temporality and necessity principles established by the Constitutional Court, that is, for as long as necessary for the fulfillment of the purposes established in this policy.
Cuberos Cortés Gutiérrez reserves the right to make any modifications or updates to this Data Processing Policy at any time and taking into account the modification, development and/or further regulation of the current rules on Personal Data Processing. Notwithstanding the foregoing, Cuberos Cortés Gutiérrez will communicate to its clients, vendors and employees via its website, email or any other means, any such modifications made to this Data Processing Policy.