Privacy Policy

I. INTRODUCTION

POLICIES FOR THE PROCESSING OF PERSONAL DATA AND HABEAS DATA PROMOTORA HOTEL SAN FERNANDO PLAZA S.A.

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PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. committed to the values of respect, subjection to legality, confidentiality, availability, integrity and adequate management of information and especially with the conviction in the guarantee of fundamental rights through this preparation and proposal, it intends to comply to Law 1266 of 2008 and Law 1581 of 2012, regulated by Decree 1377 of 2013, within which the need to adopt a Manual of policies and procedures that guarantee compliance with said law is highlighted, taking into account the consultations and claims that arise from the owner of the personal data.

In literals d) and e) of Article 3 of Law 1581 of 2012, mention is made of the person in charge and responsible for the treatment, Compliance PROMOTORA HOTEL SAN FERNANDO PLAZA S.A., with these two qualities simultaneously and in many of the databases. that are handled, is responsible for all information on personal data and is obliged to safeguard it in the manner established in this law.

Current technologies must allow Companies and/or Entities to efficiently manage, exploit and store personal information that is used to fulfill their corporate and business objectives, only for the purposes for which it is linked and for this reason PROMOTER HOTEL SAN FERNANDO PLAZA Joint Stock Company, whose main purpose is the following activities: the exploitation of real estate developments, intended for hotels, warehouses, apartments; commercial operations of hotels, travel agencies, leasing and disposal of real estate and personal property.

In its development, the company may execute all acts or contracts that are convenient or necessary for the full fulfillment of its corporate purpose and that have direct relationship with the mentioned object. To achieve this objective, the Company may carry out, among others, by way of illustration but not limitation: will carry out the following activities:

a). Opening and promotion of new markets and the consolidation of existing ones.

b). Marketing, diversification and consolidation of the offer.

c). Commercially represent and agency national and foreign companies.

d). Participation in investment projects related to its corporate purpose. and

e). Acquire, possess, use, lease, manage, construct and dispose of all types of property, movable and immovable, take them under any title and establish other real or personal rights with respect to them.

f). Distribute, import, export or acquire in any capacity, goods, fixtures, implements, machinery, equipment and raw materials related to its activity or necessary for its development.

g). Dispose of, tax and generally manage the assets that make up its corporate assets.

h). Giving or receiving money on a mutual basis, with or without interest, but not in a habitual or massive manner.

i). Constitute, create, issue, accept, endorse and circulate all types of securities and credit documents, civil or commercial, and real, personal or exchange guarantees.

j). Establish attorneys, agents and special or general, judicial or extrajudicial representatives and represent national and foreign companies and entrepreneurs.

k). Hire, in any capacity, the services of natural or legal persons and professionals at your service.

l). Constitute, under the appropriate legal form, consortia or associations in the country or abroad with national or foreign firms, to carry out any activity or work inherent to its object.

m). Merge the social enterprise with other similar or complementary ones.

n). Participate in all types of offers, contests, tenders, offers, auctions, individually or jointly with natural or legal persons, public or private, foreign or mixed. either

o). Celebrate and execute the contract for opening credit, discounts, joint accounts and all types of operations with banking, credit, financial establishments, insurance companies and other national or foreign persons.

p). Invest your cash surpluses and reserves available in the market, either in certificates of deposit or other credit securities or carrying out any operation with authorized financial entities.

q). Be the owner of intellectual and industrial property rights and dispose of them in any capacity.

r). Build, organize, manage and acquire in any capacity the lands, spaces and terrain necessary for the development of the corporate purpose.

s). Take both national and international, commercial and development credits. PARAGRAPH: The company may become a guarantor, co-debtor or guarantor of third party obligations, offering its own assets as collateral when the General Assembly decides to authorize it, as long as the act reports a direct benefit to the company; complies with the provisions of the law that deals with HABEAS DATA and PERSONAL DATA.

The fundamental right to HABEAS DATA must guarantee citizens the power of decision and control that assists them over the information, use and destination of their personal data.

The right to the protection of the personal data of each owner extends from knowing who keeps said data and what use is being given to it, to defining who has the possibility of consulting it.

The law attributes the power to each owner to consult, modify, delete and resume said information, and develops the guarantees and instruments to guarantee the validity of the fundamental right.

The purpose of this Manual is to enshrine the internal policies that must be established in compliance with Law 1581 of 2012 and that, due to our status as those in charge and responsible for the processing of personal data, we must implement and organize in order to fully comply with the provisions contemplated in the law.

The manual includes the basic aspects of a regulatory nature and independent annexes and procedural outlines that allow authorization.

PROMOTORA HOTEL SAN FERNANDO PLAZA S.A., respectively; It has its address at Carrera 42 A NRO. 1-15 MEDELLÍN, ANTIOQUIA, COLOMBIA, Email: ventas@hotelsanfernandoplaza.com, telephone (4) 4445353, website: http://www.hotelsanfernandoplaza.com/

II. PURPOSE

PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. Through this policy, it formalizes the processing of personal data applicable to activities with guests, users, clients, suppliers, providers, employees, distributors, and in general, any natural person who owns the personal data that appears registered in our databases. data and those of our employees, for the fulfillment of the corporate purpose of the Entity and specifically to:

(i) Comply with the obligations contracted by virtue of the contracts and commercial relationships entered into;

(ii) Provide information about our products and services;

(iii) Carry out commercial, social and informational events or promotions for our guests, suppliers, clients, employees, distributors and other third parties;

(iv), carry out campaigns, studies, promotions or contests of a commercial, social, marketing, advertising or execution of our corporate purpose;

(v) Loyalty programs and data updates for clients, guests, suppliers, employees, distributors and other third parties;

(vi) inform about changes to our products, prices or services;

(vii) send portfolio account statements;

(viii) evaluate the quality of our products and/or services through satisfaction surveys;

(ix) carry out collection activities, collection, consultations, verifications, control and authorization of payment methods.

(x) PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. may take the fingerprint, obtain images from security cameras or use other authorized biometric mechanisms of its clients, guests and/or, suppliers, employees, distributors and other third parties and manage them in order to validate their identity in the management of the products and/or services that they acquire with the company.

(xi) PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. may deliver the personal data of its clients, guests, suppliers, employees, distributors and other third parties to entities located in Colombia or abroad, whether public or private, as long as: They are companies or entities with which PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. is related by shareholding links, or is its parent, subsidiary or operated company; or the delivery of personal data has as its purpose the structuring, design and implementation of product and/or service offers, or in general additional value proposals to those PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. is able to offer autonomously, or Its purpose is to facilitate the development of the corporate purpose of PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. by outsourcing your processes, such as physical or digital archiving, collection, risk management, software development, guest contact, market research, preparation of statistical analysis, development of commercial and/or social strategies, marketing, research studies. social impact, participation in social inclusion programs of the state, establishment of new channels of care, and other related and related purposes.

Likewise, the personal data of clients, employees, guests, providers or any other person about whom personal data is held will be used by PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. in order to adequately carry out all its processes, in the development of the aforementioned activities and to comply with the regulations related to Habeas Data and protection of personal data. The data provided by the Employees and/or service providers to PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. will have the purpose of advancing the selection process for internal hiring. Likewise, these data may be used by PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. during the employment relationship or provision of services or strategic linkage through contracts and/or agreements; with the purpose of enhancing the skills of linked employees through courses, training, workshops, etc., and to incorporate them into the different welfare processes and benefit plans. Likewise, the personal data of Employees, service providers, guests, clients, users, managers or associates in general, will be used by PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. In order to adequately carry out all its credit risk analysis processes and comply with the regulations related to Habeas Data Financiero, PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. may also obtain the personal data of its employees and service providers for the purposes of providing employment or service references, affiliation or strategic linkage.

PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. may deliver the personal data of its employees and service providers linked by employment, by service or by alliance used in the different contracts and agreements; a Entities located in Colombia or abroad as long as: They are companies or Entities with which PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. is related by shareholding links, or is its parent, subsidiary or operated company; or the delivery of personal data has as its purpose the structuring, design and implementation of benefits and wellness or selection plans, outsourcing of the physical or digital file or in general additional value proposals to those PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. is capable of offering autonomously, or has the purpose of facilitating the development of the employee and the administration of the information of PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. by outsourcing their processes.

IN GENERAL; PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. will obtain and manage the personal data provided to it by its clients, affiliates, providers, employees, guests, directors, users and in general any natural person for whom it has personal data, for the purposes resulting from the development of its corporate purpose, as a Company. Anonymous, with the following activities as its main objective: the exploitation of real estate developments, intended for hotels, warehouses, apartments; commercial operations of hotels, travel agencies, leasing and disposal of real estate and personal property. In carrying out the same, the company may execute all acts or contracts that are convenient or necessary for the full fulfillment of its corporate purpose and that have a direct relationship with the aforementioned object. To achieve this objective, the Company may carry out, among others, by way of illustration but not limitation: will carry out the following activities:

a). Opening and promotion of new markets and the consolidation of existing ones.

b). Marketing, diversification and consolidation of the offer.

c). Commercially represent and agency national and foreign companies. d). Participation in investment projects related to its corporate purpose. and). Acquire, possess, use, lease, manage, construct and dispose of all types of property, movable and immovable, take them under any title and establish other real or personal rights with respect to them. F). Distribute, import, export or acquire in any capacity, goods, fixtures, implements, machinery, equipment and raw materials related to its activity or necessary for its development.

g). Dispose of, tax and generally manage the assets that make up its corporate assets. h). Giving or receiving money on a mutual basis, with or without interest, but not in a habitual or massive manner.

i). Constitute, create, issue, accept, endorse and circulate all types of securities and credit, civil or commercial documents and guarantees real, personal or exchange.

j). Establish attorneys, agents and special or general, judicial or extrajudicial representatives and represent national and foreign companies and entrepreneurs.

k). Hire, in any capacity, the services of natural or legal persons and professionals at your service.

l). Constitute, under the appropriate legal form, consortia or associations in the country or abroad with national or foreign firms, to carry out any activity or work inherent to its object.

m). Merge the social enterprise with other similar or complementary ones.

n). Participate in all types of offers, contests, tenders, offers, auctions, individually or jointly with natural or legal persons, public or private, foreign or mixed. either

o). Celebrate and execute the contract for opening credit, discounts, joint accounts and all types of operations with banking, credit, financial establishments, insurance companies and other national or foreign persons.

p). Invest your cash surpluses and reserves available in the market, either in certificates of deposit or other credit securities or carrying out any operation with authorized financial entities.

q). Be the owner of intellectual and industrial property rights and dispose of them in any capacity.

r). Build, organize, manage and acquire in any capacity the lands, spaces and terrain necessary for the development of the corporate purpose.

s). Take both national and international, commercial and development credits. PARAGRAPH: The company may become guarantor, co-debtor or guarantor of third party obligations, offering its own assets as collateral when the General Assembly decides to authorize it, as long as the act reports a direct benefit to the company.

The above activities may be carried out through physical mail, email, landline telephone, website, cell phone or mobile device, via text message, fax, social networks, surveys or through any other widely known means of communication, giving compliance with the provisions of current regulations.

PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. may process the personal data provided by its guests, clients, Suppliers and other Third Parties for the purposes of:

(i) verifying compliance with the Entity's policies regarding the selection and contracting of suppliers;

(ii) verify adequate compliance with the obligations;

(iii) satisfy the legitimate interests derived from the relationship that is established or is planned to be established; (iv) provide or obtain commercial and/or financial references;

(v) manage and operate the contracted product or service, which includes, among other aspects, the management and accounting record of the operations that are carried out during the validity of any legal relationship, as well as all those that are carried out for its termination, closure or liquidation thereof;

(vi) document the existing relationship and verify the execution and compliance of the respective contract; (vii) verify and confirm identity and contact;

(viii) send commercial information about the products and/or services that PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. lends in development of its corporate purpose;

(ix) adopt measures aimed at preventing illegal activities; and

(x) deliver the personal data of its guests, clients, employees, providers, associates, suppliers and Third Parties to entities located in Colombia or abroad, whether public or private, as long as: They are companies or entities with which PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. is related by shareholding links, or is its parent, subsidiary or operated company; or the delivery of personal data has as its purpose the structuring, design and implementation of product or service offers, or in general additional value proposals to those that PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. is capable of offering autonomously, or has the purpose of facilitating the development of the corporate purpose of PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. by outsourcing your processes, such as physical or digital filing, collection, risk management, software development, contact with guests, clients, employees, suppliers, associates, providers, operators, people with whom you have agreements and contracts, market research, preparation of statistical analysis, development of commercial and social strategies, marketing, social impact studies, establishment of new service channels, and other related and related purposes.

Likewise, the personal data of clients, employees, service providers, guests, suppliers, and natural persons with whom there are alliances established in contracts and/or agreements, operators, distributors, third parties and, in general, any natural person who owns the personal data that appear registered in the databases will be used by PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. in order to adequately advance all its processes in the execution of the provision of health services aimed at the community and thus comply with this manual and law 1266 of 2008, statutory law 1581 of 2012 and its regulatory decrees.

III. DEFINITIONS

For the purposes of this policy, the definitions established by current regulations are listed below:

Authorization: Prior, express and informed consent of the Owner to carry out the processing of personal data.
Database: Organized set of personal data that is subject to processing.
Personal Data: Any information linked or that can be associated with one or several specific or determinable natural persons.
Data Processor: Natural or legal person, public or private, who, by themselves or in association with others, processes personal data on behalf of the data controller.
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.
Owner: Natural person whose personal data is processed.
Processing: Any operation or set of operations on personal data, such as collection, storage, use, circulation or deletion.
Privacy notice: Verbal or written communication generated by PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. addressed to the owner of the personal data, in which he is informed of the existence of the information processing policies that will be applicable to him, the way to access them and the purposes of the treatment that is intended to be given to the personal data.
Public data: It is related to the marital status of the people, their profession or trade and their quality as a merchant or public servant; those that by their nature are not subject to protection.
Sensitive data: Sensitive data is understood to be data that affects the privacy of the owner or whose improper use may lead to discrimination, such as data that reveals racial or ethnic origin, political orientation, religious or philosophical convictions, membership in unions. , social organizations, human rights organizations or that promote the interests of any political party or that guarantee rights, as well as data related to health, sexual life, and biometric data.
Transfer: The transfer of data takes place when PROMOTORA HOTEL SAN FERNANDO PLAZA S.A., located in Colombia, sends the information or personal data to a recipient, who in turn is the Controller and is located inside or outside the country.
Transmission: Processing of personal data that involves their communication within or outside the territory.

IV. RIGHTS OF CHILDREN AND ADOLESCENTS.

Respect for the prevailing rights of children and adolescents will be ensured in the treatment.

The processing of personal data of children and adolescents is prohibited, except for those data that are public in nature, or authorization is obtained from their representative for the respective registration as hotel guests and for due affiliation to EPS and compensation funds.

PROMOTORA HOTEL SAN FERNANDO PLAZA S.A., will act with the greatest diligence and care in the treatment of children, children and adolescents in the case of obtaining the data for hotel regulation and registration taking into account its corporate purpose.

It is the task of the State and educational entities of all types to provide information and train legal representatives and guardians on the possible risks that children and adolescents face regarding the improper processing of their personal data, and to provide knowledge about the responsible and safe use by children and adolescents of their personal data, their right to privacy and protection of their personal information and that of others.

V. PRINCIPLES

In accordance with the law, PROMOTORA HOTEL SAN FERNANDO PLAZA S.A., will act in all collection, handling and deletion of personal data in accordance with the principles that must be followed in all Personal Data Processing and protection of the HABEAS DATA law, they are :

Legality: For the processing of personal data, PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. will be subject to the provisions of the Law and other provisions.
Purpose: PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. will inform the owner of the purpose of the processing given to personal data, which must be legitimate in accordance with the constitution and the law.
Freedom: The processing of personal data will only be carried out by PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. with the prior, express and informed consent of the owner; or by legal or judicial mandate.
Veracity or Quality: The information subject to processing of personal data must be true, complete, exact, updated, verifiable and understandable. The processing of partial, incomplete, fragmented or misleading data is prohibited.
Transparency: PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. guarantees the owner the right to obtain, at any time and without restrictions, information about the existence of their data.
Access and Restricted Circulation: The treatment that PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. will give personal data, will be subject to the provisions established in the law and the Constitution. Personal data may not be available on the Internet or in other means of dissemination or mass communication, except those that are public in nature or those in which access is technically controllable to provide restricted knowledge to the owner or authorized third parties.
Security: The information subject to processing by PROMOTORA HOTEL SAN FERNANDO PLAZA S.A., will be protected through the use of technical, human and administrative measures that provide security to the records, avoiding their adulteration, loss, consultation, unauthorized or fraudulent use or access.
Confidentiality: Persons involved in the processing of personal data that are not public in nature are obliged to guarantee the confidentiality of the information provided, even after their relationship with any of the tasks included in the processing has ended.

For the purposes of this policy, the owners of personal data will be understood as guests, distributors, employees, service providers, clients, users, suppliers and, in general, any natural person who owns the personal data that appears registered in the databases. data of PROMOTORA HOTEL SAN FERNANDO PLAZA S.A.

In the case of minors (boys, girls and adolescents), their legal representatives will have the power to authorize or not the processing of their personal data. In the processing of this data, respect for the prevailing rights of minors such as privacy and protection of personal information will be ensured.

VII. AUTHORIZATION

For the processing of personal data by PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. The prior, informed and express authorization of the Owner is required, which must be obtained by any written, physical or electronic means that may be subject to subsequent consultation; without prejudice to the exceptions provided by law.

PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. At the time of requesting authorization from the Owner, you must inform them clearly and expressly of the purpose for which the personal data is collected, the processing to which their personal data will be subjected, the rights of the owner and the means through which they can exercise them.

For the purposes of protecting the Habeas Data law, PROMOTORA HOTEL SAN FERNANDO PLAZA S.A., will have prior authorization and notification to the owner, in order to be reported to the Entities CIFIN, DATACREDITO and PROCREDITO.

The personal data information may be provided by PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. to the owner, his successors in title, legal representative and/or attorney-in-fact, or third parties authorized by the latter or by law, as well as public or administrative entities in the exercise of legal functions or by court order.

PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. may continue with the processing of the data contained in its databases for the purpose indicated in this policy, without prejudice to the right of the owner to exercise their right at any time and request the deletion of the data.

VIII. RIGHTS

The owner of the personal data and/or, as applicable to the holder of the credit obligation acquired with PROMOTORA HOTEL SAN FERNANDO PLAZA S.A., will have the right to:

Know, update and rectify your personal data against PROMOTORA HOTEL SAN FERNANDO PLAZA S.A., 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.
Request PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. proof of the authorization granted for the processing of your personal data, except for the exceptions provided for by law.
Be informed by PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. upon request, about the use given to your personal data.
Submit inquiries to PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. and file complaints with the entity in charge of the protection of personal data.
Request the revocation and/or deletion of your personal data when PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. engages in conduct contrary to the law and the Constitution.
Access free of charge and unlimited personal data that is subject to processing.

IX.OBLIGATIONS

The owner of the personal data must keep their information updated and guarantee, at all times, to PROMOTORA HOTEL SAN FERNANDO PLAZA S.A., its veracity. PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. will not be responsible, in any case, for any type of liability derived from the inaccuracy of the information provided by the owner.

X. RESPONSIBLE AND IN CHARGE OF PERSONAL DATA PROCESSING

PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. will be responsible for the processing of personal data.

The Operational Management will be the area in charge of processing personal data, on behalf of PROMOTORA HOTEL SAN FERNANDO PLAZA S.A., who will be provided with information on each guest, employee, provider, operator, associate, client, supplier and in general. any natural person from whom personal information has been collected and rests in a database.

The official in charge of said area will keep a report from the database and will be in charge of the following functions:

Know this policy and apply it where appropriate.
Send a communication via email to each Director, employee or person who within the Company handles or has handled any type of personal data of the members of the Company, in the sense that they inform the Department in charge of the name and email address. email of users of whom they have personal data. Prepare, direct, commission and/or delegate to others the establishment of the measures that must be taken in commercial contracts and formats or forms that deal with credits or personal data.
Prepare, direct, commission and/or delegate to others the establishment of the measures that must be taken in employment contracts.
Inform the owner about the purpose of data collection and guarantee the exercise of the rights granted to him by virtue of the authorization granted.
Keep a copy of the respective authorization granted by the owner of the personal data.
Guarantee that the information subject to processing is true, complete, exact, updated, verifiable and understandable.
Rectify the owner's information when it is incorrect.
Only use personal data that has been obtained through authorization, unless it is not required.
Respect the security and privacy conditions of the owner's information.
Update, rectify or delete personal data within five (5) business days from receipt.
Allow access to information only to authorized people.
Comply with the instructions and requirements issued by the competent administrative authority.
Sign confidentiality agreements with those who handle information related to the processing of personal data.
Timely process queries and claims made by the owners of personal data.
The others enshrined in the law.
The Operational Management of PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. must ensure that for each incorporation of a new worker, knowledge of this Policy and the documents that complement it are required. PROMOTORA HOTEL SAN FERNANDO PLAZA S.A., will make all contractual and legal adjustments so that the contracts, confidentiality agreements, contractual clauses and other documents include compliance by Employees, guests, Managers, Suppliers, Related Contractors and others. Third parties; in addition to seeking to obtain express authorization from each owner for the Management of personal data.

It is the responsibility of the workers of PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. to report any incident of information leak, computer damage, violation of personal data, commercialization of data, use of personal data of children or adolescents without the relevant authorization, impersonation of identity, or conduct that may violate a person's privacy, or that has indications that they are being used for criminal and/or unauthorized purposes.

XII.COLLECTION AND HANDLING OF PERSONAL DATA BY PROMOTORA HOTEL SAN FERNANDO PLAZA S.A.

This policy will be applicable in cases in which PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. request the completion of link requests, surveys or forms by telephone, digitally or in person, as well as event attendance forms, without prejudice to the particular conditions that apply in each case.

From the moment the owner of the personal data authorizes PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. for the collection and processing of your personal data, these may be used in the development of your commercial and work activities.

PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. may use the owner's personal data such as email address, physical email address and/or landline or cell phone number to send advertising related to its offer of products and services, and contact him for events and other activities.

In any case, depending on the activity carried out, PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. will clearly inform the owner of the personal data of the mechanisms made available to them to know, update, modify and delete their data, as well as to revoke the authorization granted.

XII. PRIVACY, CONFIDENTIALITY AND SECURITY OF PERSONAL DATA

PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. will guarantee the owners of the information the privacy, confidentiality and security of the data delivered, avoiding adulteration, loss, consultation, unauthorized or fraudulent use or access by third parties.

PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. Applying the principle of autonomy, it reserves the right to maintain and classify as confidential the information that resides in its databases.

PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. will adopt the necessary technical, human and administrative measures to provide security to personal data, avoiding its adulteration, loss, unauthorized or fraudulent consultation, use or access.

PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. states that some of its portals may contain links to third-party web pages, over which it has no control.

management or control, for this reason, it is not responsible for the content, privacy policies, security and/or handling of personal data established therein, it being the obligation of the owner of the personal data to know on the respective portals, policies related to the protection and processing of your information.

On the PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. website. Instructions will be established under absolute security so that each user or owner of personal data interacts with them and submits their requests to PROMOTORA HOTEL SAN FERNANDO PLAZA S.A., regarding any type of correction, modification and/or deletion.

XIII. AREA OF APPLICATION

The Policies will be applicable to the databases that are under the administration of PROMOTORA HOTEL SAN FERNANDO PLAZA S.A., or are likely to be known by it by virtue of commercial relationships or in the development of its corporate purpose that must be applied to the databases. other entities that are part of the society to which it belongs, commercial alliances, agreements or advertising events, both of PROMOTORA HOTEL SAN FERNANDO PLAZA S.A., and of its operators. In the first case, PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. will act as Responsible, in other cases it may have the status of Manager or Responsible, depending on whether it receives them from a third party or collects them itself.

Likewise, it will be applicable when the data processing is carried out in Colombian territory. As well as, when the person responsible or in charge of the treatment does not reside in Colombia but by virtue of international standards or treaties, Colombian legislation is applicable.

XIV. RIGHT OF HABEAS DATA

Art.15 of the C.P. establishes the right that all people have to know, update and rectify the information that has been collected about them in databases or files of both public and private entities.

Likewise, and in accordance with Ruling C-748 of 2011 of the Constitutional Court, this right includes other powers such as authorizing processing, including new data, excluding or deleting it from a database or file.

This right was developed in a jurisprudential manner from 1991 to 2008, in which the Special Law of Habeas Data was issued, which regulates what has been called “financial habeas data”, understood as the right that every individual to know, update and rectify their personal commercial, credit, and financial information contained in public or private information centers, whose function is to collect, process and circulate this data in order to determine the level of financial risk of its Owner. . This Special Law considers both natural and legal persons as the Owner of the information.

Subsequently, on October 17, 2012, Law 1581 “General Protection of Personal Data” was issued, which develops the right of Habeas Data from a broader perspective than the financial and credit perspective mentioned above. In such a way, any owner of personal data has the power to control the information that has been collected about him or herself in any database or file, managed by private or public entities. Under this General Law, the natural person is the owner.

XV. NATIONAL REGISTRY OF POLICIES AND/OR DATABASES

It is the public directory of databases subject to processing that operate in the country, and will be free to consult for citizens.

PROMOTORA HOTEL SAN FERNANDO PLAZA S.A., will register its policies and/or databases with the competent administrative authority, at the time and place established by it.

XVI. RIGHTS OF THE OWNERS

a) Contact PROMOTORA HOTEL SAN FERNANDO PLAZA S.A., through the established channels, which are indicated in the Data Privacy Notice, in order to know, update and rectify your personal data. This right may be exercised, among others, against partial, inaccurate, incomplete, fragmented, misleading data, or data whose processing is expressly prohibited or has not been authorized.

b) Request proof of the authorization granted to PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. except when, in accordance with the Law, the treatment being carried out does not require it.

c) Be informed by PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. regarding the use given to the personal data collected, upon request from the Owner submitted through the channels provided for such purposes.

d) Present complaints to the Superintendency of Industry and Commerce for violations of Law 1581 of 2012 and its regulatory decrees.

e) Revoke, in those cases that do not fall under Law 1266 of 2008, the authorization and/or request the deletion of the data when the Processing does not respect constitutional and legal principles, rights and guarantees.

f) Access free of charge, through the channels provided by PROMOTORA HOTEL SAN FERNANDO PLAZA S.A., to your personal data that has been processed.

PROMOTORA HOTEL SAN FERNANDO PLAZA S.A., through the Data Privacy Notice, will inform about the channels and procedures provided so that the owner can exercise their rights effectively.

XVII. INFORMATION SUPPLY CHANNELS

PROMOTORA HOTEL SAN FERNANDO PLAZA S.A., establishes the following communication channels with the owners:

Website: http://www.hotelsanfernandoplaza.com/
Email: operaciones@hotelsanfernandoplaza.com
Physical mail: Carrera 42 A NRO 1-15 MEDELLÍN.
Telephone line: (4) 444 5353

XVIII. INQUIRIES AND CLAIMS

Queries and complaints made to PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. They should be sent to the email: ventas@hotelsanfernandoplaza.com.

In case of additional information, the interested party may contact the telephone number (4) 4445353 or contact Carrera 42 A NRO 1-15 MEDELLÍN, ANTIOQUIA, COLOMBIA.

XIX. INQUIRIES

Queries made by the owner of the personal data or his successors in title will be attended to by PROMOTORA HOTEL SAN FERNANDO PLAZA S.A., within a maximum term of ten (10) business days from receipt of the respective request, which may be extended. for a maximum term of five (5) business days, PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. inform the interested party in advance.

XXI. CLAIMS

The owner or his successors who consider that the information contained in the database of PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. must be corrected, updated or deleted, or when they notice the alleged breach of any of the duties contained in the law or in this policy, you may file a claim, which will be processed under the following rules:

The claim will be formulated through a request addressed to operational management, with the identification of the Owner, the description of the facts that give rise to the claim, the address, and the attached documents that are required.
The maximum term to address the claim will be fifteen (15) business days counted from the day following the date of receipt, which may be extended for a maximum term of eight (8) business days, when it is not possible. address the claim within said term, and the operational management must inform the interested party of the reasons for the delay.
If the claim is incomplete, the interested party will be required within five (5) business days following receipt of the claim to correct the deficiencies. If two (2) months have elapsed from the date of the request, without the applicant presenting the required information, it will be understood that the claim has been abandoned.
If the person who receives the claim is not competent to resolve it, he or she will forward it to the area in charge within a maximum period of two (2) business days and will inform the interested party of the situation.
Before going to the entity in charge of monitoring compliance with the rules on the protection of personal data, the owner must initially process their claim with PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. through the means and channels provided for this purpose.

XXII. LEVEL OF SAFETY MEASURES APPLIED TO THE TREATMENT

PROMOTORA HOTEL SAN FERNANDO PLAZA S.A., has an area in charge, which ensures compliance with the requirements regarding information security.

It has been established that the contracts entered into with those in charge include clauses that clearly establish their duty to guarantee the security and privacy of the Owner's information.

XXIII. APPLICABLE LEGISLATION

Political Constitution of Colombia, articles 15 and 20.
Law 527 of 1999
Law 1266 of 2008.
Law 1273 of 2009.
Statutory Law 1581 of October 17, 2012.
Regulatory decrees 1727 of 2009, 2952 of 2010, 1377 of 2013 and 886 of May 13, 2014
Ruling C-748 of 2011 of the Constitutional Court

XXIV. ENTRY INTO EFFECT AND MODIFICATION

This policy will begin its validity on October 1, 2016 and will be valid while PROMOTORA HOTEL SAN FERNANDO PLAZA S.A. exercises its corporate purpose in Colombia, or until the law provides otherwise or differently.