Data Protection and Processing Policies

NUTRITIOUS ORIGIN FRUITS & SEEDS, through this policy, and in exercise of the obligation to guarantee the protection of the rights to HABEAS DATA, PRIVACY, PRIVACY, GOOD NAME and IMAGE of natural and/or legal persons, By virtue of the provisions of article 13 of Decree 1377 of 2013, it establishes the general guidelines to comply with the provisions of Law 1581 of 2012 and Decree 1377 of 2013.

The purpose of this information management and personal data processing policy is to communicate what information is required, requested, what its purpose is, why and how it is used, when it is shared if necessary and how it is protected. personal data, as well as the rights of the owners to know, update, delete or rectify said information and the procedures to access it and request its deletion.



This policy will apply to all those natural and/or legal persons who, in one way or another, provide their personal and possibly sensitive data to FRUTOS & SEMILLAS ORIGIN NUTRITIVO.



LEGAL FRAMEWORK:

This Policy is governed by the constitutional and legal framework listed below:

Political Constitution, article 15
Law 1266 of 2008
Law 1581 of 2012
Regulatory decrees 1727 of 2009, 2952 of 2010 and 1377 of 2013
Jurisprudential Line of the Constitutional Court T 164 of 1994, SU 089 of 1995, C 1011 of 2008 and C 748 of 2011.
MANAGER AND RESPONSIBLE FOR DATA PROCESSING:

In order to comply with the law and this data processing and collection policy, FRUTOS & SEMILLAS ORIGIN NUTRITIVO, acts as CONTROLLER for the processing of Personal Data.



COMPANY NAME: FRUITS & SEEDS NUTRITIONAL ORIGIN

ADDRESS: CL 85 # 48 – 01 BLOCK 25 LOCAL 9 ITAGÜÍ, ANTIOQUIA

PBX: 604 604 99 42

E-MAIL: contacto@frutosysemillas.com

WEBSITE /URL: www.frutosysemillas.com

However, the above FRUITS & SEEDS ORIGIN NUTRITIVE reserves the right to have more managers at any time according to its commercial relationships. If the above occurs, all right holders will be informed of the substantial change in the policy.

On the other hand, the Administrative Area of FRUITS & SEEDS ORIGIN NUTRITIVE will be responsible for responding to requests, queries, claims, complaints or for the exercise of the rights of the Owner of the personal information. The owner may communicate through the contact channels and telephone numbers provided in section 1 of this Manual.

FRUITS & SEEDS ORIGIN NUTRITIVE reserves the right to make modifications or updates to this Personal Data Processing Policy at any time, to address legislative developments, internal policies or new requirements for the provision or offering of its services or products.

DEFINITIONS:

In accordance with current legislation on the matter, the following definitions are established, which will be applied and implemented with the application of hermeneutical criteria systematically and comprehensively, in accordance with technological advances and with technological neutrality, in addition to the application of rights. related fundamentals.

a) Authorization:
Prior, express and informed consent of the Owner to carry out the Processing of personal data.

b) Database:
Organized set of personal data that is subject to Processing.

c) Personal data:
Any information linked or that can be associated with one or more specific or determinable natural persons.

d) Person in Charge of Treatment:
Natural or legal person, public or private, who, by themselves or in association with others, carries out the Processing of personal data on behalf of the Data Controller.

e) Responsible for the Treatment:
Natural or legal person, public or private, who alone or in association with others, decides on the database and/or the Processing of the data.

f) Data Officer:
Person within the organization who has the responsibilities of coordinating, promoting and supervising compliance with the rules on the protection of personal data. This person is the one who, in the name and on behalf of the person responsible, resolves the queries and claims that the information holders make.

g) Owner:
Natural person whose personal data is the subject of Processing.

h) Treatment:
Any operation or set of operations on personal data, such as collection, storage, use, circulation or deletion.

Update Right:
Power of the data owner to update their personal data when they have changed.

j) Right of Rectification:
It includes the right of the data owner to request the modification of data that turns out to be inaccurate, incomplete or non-existent.

k) Right of Cancellation:
This right includes the right of the data owner to cancel his or her personal data or delete it when it is excessive, not relevant, or the processing is contrary to the rules, except in those cases contemplated as exceptions by law.

l) Right to Revocation of Consent:
The owner of the personal data has the right to revoke the consent or authorization that enabled FRUTOS & SEMILLAS ORIGIN NUTRITIVO, for a treatment for a certain purpose, except in those cases contemplated as exceptions by law and/or that is necessary in a specific context. specific contractual framework.

m) Right to Oppose:
This right includes the right of the data owner to oppose the processing of his or her personal data, except in cases where such right is not applicable by legal provision or because it violates general interests that are superior to individual interests.

GUIDING PRINCIPLES:

In the development, interpretation and application of the law and this policy, the following principles will be applied in a harmonious and comprehensive manner:

a)Principle of legality in matters of data processing: The processing referred to in the law is a regulated activity that must be subject to what is established in it and in the other provisions that develop it;
b) Principle of purpose: The Treatment must obey a legitimate purpose in accordance with the Constitution and the Law, which must be informed to the Owner;
c)Principle of freedom: Treatment can only be carried out with the prior, express and informed consent of the Owner. Personal data may not be obtained or disclosed without prior authorization, or in the absence of a legal or judicial mandate that requires consent;
d)Principle of truthfulness or quality: The information subject to Treatment must be truthful, complete, exact, updated, verifiable and understandable. The Processing of partial, incomplete, fragmented or misleading data is prohibited;
e)Principle of transparency: In the Treatment, the right of the Owner to obtain from the Data Controller or the Data Processor, at any time and without restrictions, information about the existence of data that concerns him or her must be guaranteed;
f)Principle of restricted access and circulation: Treatment is subject to the limits derived from the nature of the personal data, the provisions of the law and the Constitution. In this sense, the Treatment can only be carried out by people authorized by the Owner and/or by the people provided for by law;

Personal data, except public information, may not be available on the Internet or other means of dissemination or mass communication, unless access is technically controllable to provide knowledge restricted only to the Owners or authorized third parties in accordance with this law;

g)Principle of security: The information subject to Treatment by the Data Controller or Data Processor referred to in the law must be handled with the technical, human and administrative measures that are necessary to provide security to the records, avoiding their adulteration. , unauthorized or fraudulent loss, consultation, use or access;
h)Principle of confidentiality: All persons involved in the Processing of personal data that are not public in nature are obliged to guarantee the confidentiality of the information, even after their relationship with any of the tasks included in the Processing has ended. being able to only supply or communicate personal data when this corresponds to the development of activities authorized by law and in its terms.
PUBLIC DATA:

It is the data that is not semi-private, private or sensitive. Public data are considered, among others, data relating to the marital status of people, their profession or trade and their status as a merchant or public servant. Due to its nature, public data may be contained, among others, in public records, public documents, official gazettes and bulletins, and duly executed judicial rulings that are not subject to confidentiality.

SENSITIVE DATA:

Sensitive data is understood to be data that affects the privacy of the owner or whose improper use could lead to discrimination, such as data that reveals racial or ethnic origin, political orientation, religious or philosophical convictions, membership in unions, social organizations, of human rights or that promote the interests of any political party or that guarantee the rights and guarantees of opposition political parties as well as data related to health, sexual life and biometric data, among others, the capture of a still image or on the move, fingerprints, photographs, iris, voice, facial or palm recognition, etc.

The processing of said data is prohibited in FRUTOS & SEMILLAS ORIGIN NUTRITIVE, unless expressly authorized by the owner and, furthermore, in the cases of article 6 of law 1581 of 2012, provided that it is subject to the following conditions:

The owner is informed that since it is sensitive data, he is not obliged to authorize its processing.
The owner is informed explicitly and in advance, in addition to the general requirements of the authorization for the collection of any type of personal data, which of the data that will be processed are sensitive and the purpose of the Treatment.
No activity may be conditioned on the Owner providing sensitive personal data, except for what is related to employment information required by FRUITS & SEEDS ORIGIN NUTRITIVE.

COLLECTION OF PERSONAL DATA:

In development of the principles of purpose and freedom, the collection of data must be limited only to those personal data that are relevant and appropriate so that FRUTOS & SEMILLAS ORIGIN NUTRITIVE can have an adequate development of its corporate purpose and in accordance with the purpose for the which are collected or required in accordance with current regulations. Except in cases expressly provided for by law, personal data may not be collected without authorization from the Owner.

At the request of the competent authority, FRUITS & SEEDS ORIGIN NUTRITIVE, must provide a description of the procedures used for the collection, storage, use, circulation and deletion of information, as well as a description of the purposes for which the information is collected and an explanation about the need to collect the data in each case.

Deceptive or fraudulent means may not be used to collect and process personal data.

AUTHORIZATION:

FRUITS & SEEDS ORIGIN NUTRITIVE, must adopt procedures to request, no later than at the time of collection of your data, the authorization of the Owner for the Treatment of the same and inform you of the personal data that will be collected, as well as all the specific purposes. of the Treatment for which consent is obtained.

Personal data found in publicly accessible sources, regardless of the means by which it is accessed, understood as those data or databases that are available to the public, can be processed by any person as long as its nature, are public data.

In the event of substantial changes in the content of the Treatment policies referred to in this data processing policy and the purpose of the Processing of personal data, which may affect the content of the authorization, FRUITS & SEEDS ORIGIN NUTRITIVE , you must communicate these changes to the Owner before or at the latest at the time of implementing the new policies. In addition, you must obtain a new authorization from the Owner when the change refers to the purpose of the Treatment.

MEANS AND MANIFESTATIONS TO GRANT THE AUTHORIZATION:

The authorization may consist of physical documents, electronic media, data messages, Internet, Websites, in any other format that guarantees subsequent consultation, or through an appropriate technical or technological mechanism that allows expressing or obtaining consent via click or double click, through which it can be concluded unequivocally that if the owner had not behaved, the data would never have been captured and stored in the database. The authorization may also be generated by FRUTOS & SEMILLAS ORIGIN NUTRITIVE and will be made available to the owner in advance and prior to the processing of his or her personal data.

TYPES OF DATABASE PROCESSING

The Databases that FRUITS & SEEDS ORIGIN NUTRITIVE process, in order to fulfill its mission and purposes are:

WORKERS, SUPPLIERS, CUSTOMERS, PHYSICAL CUSTOMERS and SHAREHOLDERS.
These databases have been built and continue to be built, with the authorization of the legal and natural persons who own the information. FRUITS & SEEDS ORIGIN NUTRITIVE has various alternatives in order to obtain authorizations from those who gradually become linked or related to it, for this it has designed electronic and lithographic formats that are delivered or made available to people upon first contact or definition of beginning of relationship.

The information that FRUITS & SEEDS NUTRITIOUS ORIGIN requests or may request is: Name, NIT and/or citizenship card, Physical Address, WEB address, Email(s), Social Networks, Landline telephone number(s). ), Cell Phone Number(s), nationality, level of education, work or business activity.

FRUITS & SEEDS NUTRITIONAL ORIGIN, DOES NOT collect, store, use or circulate sensitive data in the terms of the law, such as those that reveal racial or ethnic origin, political orientation, religious or philosophical convictions, membership in unions, organizations social, human rights or that promote the interests of any political party or that guarantee the rights and guarantees of opposition political parties, as well as data related to health, sexual life, and biometric data of natural people ( natural person) .

In any case, when FRUITS & SEEDS ORIGIN NUTRITIVE receives information from potential workers, collaborators or service providers, it may require information aimed at verifying competencies, training, skills and experience.

In accordance with the law FRUTOS & SEMILLAS ORIGIN NUTRITIVE can “collect, store, use or circulate personal data for as long as is reasonable and necessary, in accordance with the purposes that justified the treatment, taking into account the provisions applicable to the matter of in question and the administrative, accounting, fiscal, legal and historical aspects of the information (…). Notwithstanding the above, personal data must be retained when required to comply with a legal or contractual obligation."

CASES IN WHICH AUTHORIZATION IS NOT NECESSARY:

The authorization of the Owner will not be necessary when it comes to:

1.Information required by a public or administrative entity in the exercise of its legal functions or by court order;
2.Data of public nature;
3.Medical or health emergency cases;
4.Processing of information authorized by law for historical, statistical or scientific purposes;
5.Data related to the Civil Registry of Persons.
RIGHTS OF BOYS, GIRLS AND ADOLESCENTS:

At FRUTOS & SEMILLAS ORIGIN NUTRITIVE, the processing of data of minors, if required, will be carried out in a way that guarantees respect for the prevailing rights of children and adolescents.

However, it will not be the general policy of FRUTOS & SEMILLAS ORIGIN NUTRITIVE to process the personal data of children and adolescents, except for those data that are public in nature.

TO WHOM THE INFORMATION MAY BE PROVIDED:

The information that meets the conditions of law may be provided to the following people:

To the Owners, their successors or legal representatives;
To public or administrative entities in the exercise of their legal functions or by court order;
To third parties authorized by the Owner or by law.
REVOCATION OF AUTHORIZATION, UPDATE, MODIFICATION AND/OR DELETION OF DATA:

The Owner may at any time request FRUTOS & SEMILLAS ORIGIN NUTRITIVO to update, modify and/or delete their personal data and/or revoke the authorization granted for the Treatment thereof, by submitting a written claim or via e-mail. email, with express indication of your full name, identification number, the facts on which your request is based and in general in accordance with the provisions of article 15 of Law 1581 of 2012, communication addressed to the person responsible for compliance with this privacy policy. data treatment.

The request for deletion of information and revocation of authorization will not proceed when the Owner has a legal or contractual duty to remain in the database.

FRUITS & SEEDS ORIGIN NUTRITIVE has free and easily accessible mechanisms available to the Owner to submit the request for updating, modification and/or deletion of data or the revocation of the authorization granted.

If the respective legal term has expired, FRUTOS & SEMILLAS ORIGEN NUTRITIVO does not update, modify and/or delete 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 update, modification and/or deletion of personal data. For these purposes, the procedure described in article 22 of Law 1581 of 2012 will be applied.

DATA COLLECTED BEFORE THE ISSUANCE OF THE LEGAL RULES:

(Law 1581 of 2012, decree 1377 of 2013)

For data collected before the issuance of the legal regulations on habeas data referred to, the following will be taken into account:

FRUITS & SEEDS ORIGIN NUTRITIVE must request the authorization of the owners to continue with the Processing of their personal data in the manner provided for in the law and this data processing policy, either in writing or electronically, and will inform of all employees and third parties their information processing policies and how to exercise their rights, by publishing this data processing policy in their business establishment.
The company's institutional email and those that the person in charge designated at FRUITS & SEEDS ORIGIN NUTRITIVE has designated to ensure compliance and execution of this policy will be considered efficient communication mechanisms.

If the mechanisms mentioned in section 1 impose a disproportionate burden on FRUTOS & SEMILLAS ORIGIN NUTRITIVO or it is impossible to request consent from each Owner for the Processing of their personal data and inform them of the information Processing policies and the method of exercise its rights, FRUTOS & SEMILLAS ORIGEN NUTRITIVO may implement alternative mechanisms for the purposes set forth in paragraph 1, such as newspapers with wide national circulation, local newspapers or magazines, its own Internet pages, information posters, among others.
In order to establish when there is a disproportionate burden for FRUITS & SEEDS ORIGIN NUTRITIVE, its economic capacity, the number of owners, the age of the data, the territorial and sectoral scope of operation and the alternative communication mechanism to be used will be taken into account. , so that the fact of requesting consent from each of the Owners implies an excessive cost and that this compromises the financial stability of FRUTOS & SEMILLAS ORIGIN NUTRITIVO, the performance of its business activities or the viability of its programmed budget.

If within thirty (30) business days, counted from the implementation of any of the communication mechanisms described in paragraphs 1, 2 and 3, the Owner has not contacted FRUTOS & SEMILLAS ORIGIN NUTRITIVE to request the deletion of your personal data in the terms of the law and this policy, FRUTOS & SEMILLAS ORIGEN NUTRITIVO may continue to process the data contained in its databases for the purpose or purposes indicated in this document, without prejudice to the power that The Owner has to exercise his right at any time and request the deletion of the data.
In any case FRUITS & SEEDS ORIGIN NUTRITIVE declares to comply with all applicable provisions of Law 1581 of 2012 and Decree 1377 of 2013.
RIGHTS OF THE OWNERS:

The Owner of the personal data will have the following rights:

a) Know, update and rectify personal data regarding FRUTOS & SEMILLAS ORIGIN NUTRITIVE. This right may be exercised, among others, against partial, inaccurate, incomplete, fragmented, misleading data, or those whose Processing is expressly prohibited or has not been authorized;
b) Request proof of the authorization granted to FRUITS & SEEDS ORIGIN NUTRITIVE except when expressly excepted as a requirement for Treatment, in accordance with the provisions of article 10 of this law;
c) Be informed by FRUTOS & SEMILLAS ORIGIN NUTRITIVO, upon request, regarding the use that has been given to personal data;
d) Submit complaints to the Superintendency 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 processing does not respect the constitutional and legal principles, rights and guarantees by FRUTOS & SEMILLAS ORIGIN NUTRITIVE. The revocation and/or deletion will proceed when the Superintendence of Industry and Commerce has determined that in the Treatment of NUTRITIOUS ORIGIN FRUITS & SEEDS there has been conduct contrary to the law and the Constitution;
f) Access free of charge to personal data that has been processed.

CHANNELS OF ATTENTION TO INFORMATION HOLDERS:

TREATMENT OFFICER: Administrative assistant of NUTRITIOUS ORIGIN FRUITS & SEEDS.

ADDRESS: CL 85 # 48 – 01 BLOCK 25 LOCAL 9 ITAGÜÍ, ANTIOQUIA

PBX: 604 604 99 42

E-MAIL: contacto@frutosysemillas.com



PROCEDURE FOR THE EXERCISE OF THE RIGHTS OF THE DATA OWNER:

The exercise of rights enshrined in the Statutory Law on PERSONAL DATA PROTECTION may be exercised by INFORMATION HOLDERS, their attorneys or successors in title through the following mechanisms:

Sending a written communication to the address reported in the previous section of this Manual.
Sending an electronic communication to the email address reported in the previous section of this Manual.
In no case may a Holder use the verbal or telephone form in order to exercise the protection of a Right protected by Law 1581 of 2012, the purpose of this procedure is to maintain proof of the petition presented and have a certain date as of of which the terms provided for in the Law begin so that FRUITS & SEEDS ORIGIN NUTRITIVE provides a response to the request presented by the Owner.

Whatever the means chosen by the petitioner, they must indicate at least:

Name of the Information Owner
Physical address.
NIT or Citizenship Card.
Electronic address.
Telephone contacts
(if you have)
Condition in which he acts, if he does not do so directly, he must prove the corresponding power or capacity in which he acts.
Name of the RIGHT with respect to which it seeks protection and reasons supporting the request.

This Data Processing Policy comes into effect from the date of its publication.