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Privacy Policy

 

PERSONAL DATA PROTECTION POLICY – MASSY MOTORS RENTALS S.A.S

Your privacy is very important to MASSY MOTORS RENTALS S.A.S

For this reason, we have prepared an Information Treatment Policy (the “Policy”) that informs you how we treat your personal information.

Thank you for reviewing our personal data protection practices.

  1. PRESENTATION

MASSY MOTORS RENTALS S.A.S (“MMR”), company domiciled at Av.3 Norte No. 34-46, telephone (2) 485 3999, is respectful of the personal data and information provided by its clients current, past and potential employees and suppliers interested and/or related to the services offered (the Holders). This Information Treatment Policy (the “Policy”) establishes the purposes, measures and procedures of our databases, as well as the mechanisms that the Holders have to know, update, rectify, delete the data provided or revoke the authorization that is granted together with the knowledge of this Policy. This text has been created by MASSY MOTORS RENTALS S.A.S as part of the processes adopted to comply with current legislation on data protection, especially Law 1581 of 2012 (and other regulations that modify, add, complement or develop it), to Decree 1377 of 2013, Sole Regulatory Decree 1074 of 2015, among other applicable and related ones.
In this Policy you will find the corporate and legal guidelines under which MASSY MOTORS RENTALS S.A.S processes your data, the purpose, your rights as Holder, as well as the internal and external procedures for the exercise of such rights.

  1. DEFINITIONS

The expressions used in initial capital letters in this Policy will have the meaning given to them here, or the meaning that the applicable law or jurisprudence gives them, as said law or jurisprudence is modified from time to time.

  1. Authorization </ u>”: It is the prior, express and informed consent of the Owner to carry out the Processing of her Personal Data. </ li>
  2. Database”: It is the organized set of Personal Data that are subject to Treatment, electronic or not, whatever the modality of its formation, storage, organization and access.</ li>
  3. Personal Data”: Is any information of any kind, linked or that can be associated with one or several specific or determinable natural or legal persons.
  4. Public Data”: It is the Personal Data qualified as such according to the mandates of the law or the Political Constitution and that which is not semi-private, private or sensitive. Data relating to the Civil Registry of persons, their profession or trade, their quality as a merchant or public servant and those that can be obtained without reservation are public, among others. Due to its nature, public data may be contained, among others, in public records, public documents, official gazettes and bulletins, duly executed judicial decisions that are not subject to reservation.
  5. Sensitive Data”: It is the Personal Data that affects the intimacy of the Holder or whose improper use can generate discrimination, such as those that reveal union affiliations, racial or ethnic origin, orientation political, religious, moral or philosophical convictions, membership in trade unions, social, human rights organizations 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 , sex life, and biometric data.
  6. Data Processing Manager”: Is the 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.
  7. Authorized”: It is the Company and all the people under the responsibility of the Company, who by virtue of the Authorization and these Policies have legitimacy to Process the Personal Data of the Owner. The Authorized includes the gender of the Authorized.
  8. Authorization”: It is the legitimacy that expressly and in writing through a contract or document that takes its place, grants MMR to third parties, in compliance with the applicable Law, for the Processing of Personal Data, converting such third parties into Persons in Charge of the Treatment of the Personal Data delivered or made available.
  9. Data Controller”: Is the natural or legal person, public or private, that by itself or in association with others, decides on the Database and/or the Treatment of the data. Personal Data.
  10. Holder” of the Personal Data: It is the natural or legal person to whom the information that rests in a Database refers, and who is the subject of the right of habeas data.</ li>
  11. Transmission”: It is the Processing of Personal Data that implies the communication of the same within or outside the territory of the Republic of Colombia when its purpose is to carry out a Treatment by the Processor by Responsible account.
  12. Transfer”: The transfer of data takes place when the Person in Charge and/or Person in Charge of the Processing of personal data, located in Colombia, sends the information or personal data to a receiver, who in turn, is Responsible for Treatment and is inside or outside the country.
  13. Personal Data Processing”: It is any systematic operation and procedure, electronic or not, that allows the collection, conservation, ordering, storage, modification, relationship, use, circulation, evaluation, blocking , destruction and in general, the processing of Personal Data, as well as its transfer to third parties through communications, consultations, interconnections, assignments or data messages.

For the understanding of the terms that are not included in the previous list, you must refer to the current legislation, especially Law 1581 of 2012, Decree 1377 of 2013, and Single Regulatory Decree 1074 of 2015, giving the meaning used in said norm to the terms of whose definition there is any doubt.
MASSY MOTORS RENTALS S.A.S proceeds with the collection and processing of certain Personal Data to fulfill purposes related to the corporate purpose and business of the Company. The Personal Data collected are those strictly necessary to fulfill said purposes, which are.

  1. EMPLOYEES

MASSY MOTORS RENTALS S.A.S proceeds with the processing of personal data of its employees for purposes related to the development of its corporate purpose, the execution of the contract, payment of contractual obligations, inclusion of information in databases of the Responsible, reporting to authorities, employee performance monitoring, compliance with labor obligations, in greater detail the purposes of the treatment correspond to:

  • Personnel management, payment of contractual obligations and execution of the employment contract.
  • Report to judicial and/or administrative authorities in accordance with requirements given.
  • Support in internal/external audit processes.
  • Registration of employee information in the company database for circulation purposes in the facilities and use of technological tools.
  • For purposes of security or fraud prevention and/or anti-corruption practices.
  • Delivery and authorization of the processing of your personal data to third parties in charge, in accordance with the provisions of the applicable law, when necessary for the continuity of the business or use of technological tools that are in favor of efficiency, processes, costs , interconnectivity of company areas, among others. The Processor will offer adequate protection measures and may or may not be domiciled in Colombia according to the nature of the service.
  • Transfer of Personal Data inside and outside of Colombia to maintain the continuity of the business and corporate purpose of MASSY MOTORS RENTALS S.A.S, as well as in the event of a merger, consolidation, sale of shares, acquisition, divestiture or other restructuring process.
  • Any other purpose that results in the development of the contract or the relationship between the employee and MASSY MOTORS RENTALS S.A.S.
  • Any other purpose in accordance with the authorization that the employee has granted in favor of the Company.
  • Perform audits, data analysis, and research to improve products, services, and communications with customers, employees, suppliers, shareholders, and other stakeholders

All of the above is related to the fulfillment of obligations in charge of MASSY MOTORS RENTALS S.A.S as an employer in favor of the well-being, continuity of the employee and correct execution of the employment relationship. It is also related to the development of the corporate purpose of the company.

  1. SUPPLIERS AND CUSTOMERS

MASSY MOTORS RENTALS S.A.S proceeds with the processing of personal data of its suppliers and customers for purposes related to the development of its corporate purpose, the execution of the contract, payment of contractual obligations, inclusion of information in Responsible data, reporting to authorities, obtaining a record of those who provide services and sell products for payments and tax processes. In greater detail, the purposes of the treatment correspond to:

  • Management of collections and payments, billing and compliance with the contract signed with MASSY MOTORS RENTALS S.A.S.
  • Sending information to government or judicial entities at their express request.
  • Support in internal/external audit processes.
  • Sending/Receiving messages for commercial, advertising and/or customer service purposes as long as it is intrinsically related to the existing business relationship.
  • Registration of customer and supplier information in the MASSY MOTORS RENTALS S.A.S database, as appropriate.
  • Contact for sending information related to the contractual, commercial and mandatory relationship that takes place.
  • For purposes of security or fraud prevention and/or anti-corruption practices.
  • Delivery and authorization of the processing of your personal data to third parties in charge, in accordance with the provisions of the applicable law, when necessary for the continuity of the business or use of technological tools that are in favor of efficiency, processes, costs , interconnectivity of company areas, among others. The Processor will offer adequate protection measures and may or may not be domiciled in Colombia according to the nature of the service.
  • Transfer of Personal Data inside and outside of Colombia to maintain the continuity of the business and corporate purpose of MASSY MOTORS RENTALS S.A.S, as well as in the event of a merger, consolidation, sale of shares, acquisition, divestiture or other restructuring process.
  • Any other purpose that results in the development of the contract or the relationship between the supplier/client and MASSY MOTORS RENTALS S.A.S.
  • Any other purpose in accordance with the authorization that the supplier/client has granted in favor of the Company.
  • Send important notifications such as lists of vehicles that have news or faults, or communications about changes in our terms, conditions and information treatment policies
  • Create, develop, operate, deliver, and improve our products, services, content, and advertising.
  • Carry out the control and prevention of fraud and money laundering, including, but not limited to, consultation on restrictive lists, and all the necessary information required for the SARLAFT.
  • In the event of a merger, acquisition or sale of MMR, we may transfer some or all of the personal information we have in our databases to the relevant third party in any of the aforementioned transactions.
  • Maintain and process by computer or other means known or to be known, any type of information received from the client in order to provide the relevant services and products.
  • Monitor through video surveillance systems, for purposes related to security, the activities carried out at the points of sale owned or managed by the company.
  • Monitor and use the images captured through video surveillance systems in order to control and inspect the development and performance of work activities in the space or workplace of company employees.

We also inform you that, in your capacity as supplier and/or client, your personal data is only collected for the identification of your position, trade, profession or merchant quality, for which they respond to being of a public nature, not being required. your prior, express and informed consent. In any case, even if it is of a public nature, you have the right to be informed of the purpose of the treatment and are empowered to exercise the rights that protect you as the owner of personal data.

If you provide us with Personal Data, whether as an employee, supplier and/or customer, this information will be used only for the purposes indicated here, and we will not proceed to sell, license, transmit or disclose it outside of MASSY MOTORS RENTALS S.A.S. Unless (i) you expressly authorize us to do so, (ii) it is necessary to allow our contractors or agents to perform the services we have entrusted to them, (iii) in order to provide you with our products or services, ( iv) is disclosed to entities that provide marketing services on our behalf or to other entities with whom we have joint marketing agreements, or (v) as required or permitted by law.
In cases where subcontracting with third parties is necessary for the processing of your personal information or we provide your personal information to third party service providers, we warn said third parties about the need to protect said personal information with appropriate security measures, we prohibit them from using your personal information for their own purposes and we prevent them from disclosing your personal information to others.

When there is authorization for this purpose, MASSY MOTORS RENTALS S.A.S. will send the financial and credit information to Information Operators and/or Commercial Information Agencies, in accordance with Law 1266 of 2008.

MASSY MOTORS RENTALS S.A.S. will send the information to the governmental or judicial authorities that is stored in its databases, when there is an administrative act or a judicial order that so provides.

  1. PRINCIPLES FOR THE PROCESSING OF PERSONAL DATA.

MASSY MOTORS RENTALS S.A.S., in compliance with the provisions of Law 1581 of 2012, applies the principles of legality, purpose, freedom, truthfulness, transparency, access and restricted circulation, security and confidentiality.

  1. AUTHORIZATION FOR THE PROCESSING OF PERSONAL DATA.

Prior to the collection of any non-sensitive personal data, MASSY MOTORS RENTALS S.A.S. will have the personal data processing authorization referred to in article 9 of Law 1581 of 2012, and article 7 of Decree 1377 of 2013. The aforementioned authorization can be obtained in writing or by electronic means, where the Holder of the information authorizes MASSY MOTORS RENTALS S.A.S. to treat your personal data in accordance with the provisions of this document.

Notwithstanding the foregoing, MASSY MOTORS RENTALS S.A.S. will also collect and process the personal data that is required for the fulfillment of its legal and judicial obligations, in accordance with article 10 of Law 1581 of 2012.

  • CONSERVATION OF THE INFORMATION.

The information that rests in electronic and physical files will be located only in corporate computers for personal and exclusive use of persons authorized to process personal data within the organization.

  • RIGHTS OF THE INFORMATION HOLDER.

In accordance with article 8 of Law 1581 of 2012, the rights of the Holder of the information subject to treatment by MASSY MOTORS RENTALS S.A.S. are the following:

  1. Know, update and rectify your personal data against MASSY MOTORS RENTALS S.A.S. This right may be exercised, among others, against partial, inaccurate, incomplete, fractional, misleading data, or those whose Treatment is expressly prohibited or has not been authorized;
  2. Request proof of the authorization granted MASSY MOTORS RENTALS S.A.S. except when expressly excepted as a requirement for Treatment, in accordance with the provisions of article 10 of Law 1581 of 2012.</li >
  3. Be informed by MASSY MOTORS RENTALS S.A.S., upon request, regarding the use given to your personal data.
  4. Submit to the Superintendency of Industry and Commerce complaints for violations of the provisions of Law 1581 of 2012, Decree 1377 of 2013 and other regulations that modify, add or complement it.
  5. 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 suppression will proceed when the Superintendency of Industry and Commerce has determined that in the Treatment the Responsible or Person in Charge has incurred in conduct contrary to Decree 1377 of 2013, Law 1581 of 2012 and the Political Constitution.
  6. Free access to your personal data that has been processed, in accordance with the provisions of paragraph c of numeral 2 of article 12 of this document.
  1. PROCEDURE FOR THE EXERCISE OF YOUR RIGHTS AS THE HOLDER.

If you have questions about this Policy, or any concerns or complaints regarding the administration of the Policy, please contact us through any of the following means:

MASSY MOTORS RENTALS S.A.S

Av.3 North No. 34-46

Telephone (2) 485 3999 – 485 2727

In the case of exercise of complaint, rectification, update, query, or request for access or theft of data, you must send it to the Personal Data Protection Officer to the following email account: customer.service@alamo.co

Your request or request in relation to your personal data must be attended to within a maximum term of five (5) business days from the receipt of the request or request. For the correct and complete consideration of your request, request or claim, we ask you to provide the identity of the applicant, your identification number, the address of notifications/responses and the documents you want to assert.
If your request or request does not have sufficient data and facts that allow MASSY MOTORS RENTALS S.A.S to attend to it correctly and completely, it will be required within five (5) days following receipt of the request, request or claim to remedy its failures. After five (5) days have elapsed from the date of the request, if you as the applicant have not rectified as required, the company as the recipient of your request understands that you have withdrawn your request.

  1. MODIFICATION OF THIS POLICY.

This policy may be modified at any time, which is why we recommend that you review regularly or periodically through the contact details MASSY MOTORS RENTALS S.A.S, and the latest version of this Policy or the mechanisms to obtain a copy of it.

  1. This Policy will come into force as of March 1, 2019, for which it will be made known to the holders of the information by means of dissemination by the institutional email and website of MASSY MOTORS RENTALS S.A.S:

https://www.alamo.co/

Sign for proof of the above,
Felipe Gómez C.

General Manager

MASSY MOTORS RENTALS S.A.S