This policy applies to all holders of personal information that is used and/or found in the databases of the company UNIKAPITAL SAS, and in its subsidiaries and branches (if any), who acts as data controller. Personal information. HOTEL GRANADA REAL guarantees the protection of rights such as Habeas Data, privacy, intimacy, good name and image, for this purpose all actions will be governed by principles of good faith, legality, computer self-determination, freedom and transparency.
1. Legal basis
Article 15 of the Political Constitution of Colombia establishes that any person has the right to know, update and rectify the personal data that exists about them in data banks or files of public or private entities. Likewise, it orders those who have personal data of third parties to respect the rights and guarantees provided for in the Constitution when this type of information is collected, processed and circulated.
Statutory Law 1581 of October 17, 2012 establishes the minimum conditions to carry out the legitimate processing of personal data of clients, employees and any other natural person. Literal k) of article 17 of said law obliges those responsible for the processing of personal data to "adopt an internal manual of policies and procedures to guarantee adequate compliance with the law and, in particular, to respond to queries and complaints."
Article 25 of the same law establishes that data processing policies are binding on those responsible for them and that ignorance will result in sanctions. Additionally, it points out that these policies cannot guarantee a level of treatment lower than that established in Law 1581 of 2012.
That Decree 1377 of 2013 defines the information that information processing policies must contain at a minimum.
HOTEL GRANADA REAL is committed to respecting and guaranteeing the rights of its clients, employees, suppliers and third parties in general. For this reason, it adopts the following manual of information processing policies and procedures, which must be applied in all activities that involve, in whole or in part, the collection, storage, use, circulation and transfer of that information.
These policies are mandatory and strict compliance for HOTEL GRANADA REAL, as responsible, as well as all third parties who act on behalf of the Company, or who, without acting on behalf of HOTEL GRANADA REAL, process personal data at its disposal as processors.
Both the person in charge and those in charge, that is, employees, contractors and third parties, must observe and respect these policies in the fulfillment of their functions and/or activities even after legal, commercial, labor or any kind of relationship has ended. Likewise, they undertake to maintain strict confidentiality in relation to the data processed.
Any breach of the obligations and, in general, of the policies contained in this document must be reported to: comercial@hotelgranadareal.com.co
1. INFORMATION FROM HOTEL GRANADA REAL, entity responsible for processing the information.
The company responsible for processing personal data:
• Company name: UNIKAPITAL SAS
• Address: Avenida 8ª norte No. 15AN-31
• Nit. 900.441.307-2
• Correspondence address: Avenida 8ª norte No. 15AN-31
• Email: marketing@hotelgranadareal.com.co
• Telephone:572 6614920
2. Concepts
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 Treatment.
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, carries out the Processing of 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 the subject of Treatment.
Processing: Any operation or set of operations on personal data, such as collection, storage, use, circulation or deletion.
Inquiries: Request for the Owner's personal information that resides in any database used by HOTEL GRANADA REAL on which it has the obligation to provide the Owner or his successors in title, all the information contained in the individual record or that is linked to the identification of the Owner.
Claims: Request for correction, updating or deletion of the information contained in a database used by HOTEL GRANADA REAL, or request for alleged breach of any of the duties contained in Law 1581 of 2012, made by the Owner or his successors in title.
Public data: This is data that is not 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.
3. Principles
The following principles will be taken into account by HOTEL GRANADA REAL, in the process of managing personal data:
– Legality regarding data processing: The processing referred to in Law 1581 of 2012 is a regulated activity that must be subject to what is established in it and in the other provisions that develop it.
– Purpose and Treatment: The Treatment must obey a legitimate purpose in accordance with the Constitution and the Law, which must be informed to the Owner.
The Treatment and purpose of the information in the HOTEL GRANADA REAL databases are related solely and exclusively to commercial purposes (commercial proposals, account statements, collection accounts, invoices). The additional information provided by the Client and/or Supplier to HOTEL GRANADA REAL, by virtue of the commercial relationship that links them, will be kept in our Database.
– 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.
– Veracity or quality: The information subject to Treatment must be true, complete, exact, updated, verifiable and understandable. The Processing of partial, incomplete, fragmented or misleading data is prohibited.
– Transparency: In the Treatment, the right of the Owner to obtain from HOTEL GRANADA REAL, or the Data Processor, at any time and without restrictions, information about the existence of data that concerns him or her must be guaranteed.
– Restricted access and circulation: Treatment is subject to the limits derived from the nature of the personal data, the provisions of Law 1581 of 2012 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 in the 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 the Law.
– Security: The information subject to Treatment by the Data Controller or Data Processor must be handled taking reasonable technical, human and administrative measures to provide security to the records, trying to avoid their adulteration, loss, consultation, use or access. unauthorized or fraudulent.
– 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, and may only carry out provision or communication of personal data when this corresponds to the development of activities authorized in the Law and in the terms thereof.
4. Treatment to which the data will be subjected and its purpose
The processing of personal data will be contained in the Privacy Policy and Use of personal information of each of the owners of the information for which HOTEL GRANADA REAL will be responsible, the treatment that will be applied to the information will be:
Personal data will be collected, stored, used and circulated only for as long as is necessary and reasonable in accordance with the purposes for which authorization is requested.
Communications with commercial content will never expose email information for all customers.
Our database will not be shared or used with third parties for commercial purposes.
5. Right of owners
In accordance with the provisions of article 8 of Law 1581 of 2012 and decree 1377 of 2013, the owner of the personal data has the following rights against the company HOTEL GRANADA REAL
a) Know, update and rectify your personal data in front of HOTEL GRANADA REAL, in its capacity as data controller;
b) Request proof of the authorization granted to HOTEL GRANADA REAL in its capacity as Data Controller;
c) Be informed by HOTEL GRANADA REAL upon request, regarding the use that has been given to your personal data;
d) Submit complaints to the Superintendency of Industry and Commerce for violations of the provisions of Law 1581 of 2012, once the consultation or claim process has been exhausted before the Data Controller;
e) Revoke the authorization and/or request the deletion of the data when the Processing does not respect constitutional and legal principles, rights and guarantees; The revocation and/or deletion will proceed when the Superintendency of Industry and Commerce has determined that in the Treatment the Controller or Processor has engaged in conduct contrary to Law 1581 of 2012 and the Constitution;
f) Access free of charge to your personal data that has been processed.
6. Access, Consultation and Claim Procedures
Law 1581 of 2012 provides every person who owns personal data with a series of guarantees, legal powers against the person responsible for the personal data, which guarantee the power of decision and control that he or she has over the information that concerns him or her, such as their right to its protection. In addition, they act as a complement to the duty of the person responsible to comply with the obligations imposed by the Law, allowing them to identify those cases in which the treatment may not be in accordance with them.
To exercise the rights, those who may act in accordance with the provisions of article 14 of Law 1581 of 2012 and decree 1377 of 2013 are the following people: the owners, the successors in title, their representative or attorney-in-fact or the persons who act in favor of another or for another.
When the request is made by a person other than the owner and it is not proven that the request is acting on behalf of the owner, it will be considered not submitted.
HOTEL GRANADA REAL has an administrative infrastructure designed, among other functions, to ensure due attention to requirements, requests, queries, complaints and claims related to data protection, in order to guarantee the exercise of the rights contained in the Constitution and the law, especially the right to know, update, rectify and delete personal information; as well as the right to revoke the consent granted for the processing of personal data.
INQUIRIES, CLAIMS, COMPLAINTS
For queries, claims, complaints or for the exercise of the rights that assist you as the owner of information (Personal Data), you may contact “HOTEL GRANADA REAL” as follows:
You can contact: comercial@hotelgranadareal.com.co
Likewise, you can call the customer service line (572)6614920 from Monday to Friday from 8:00 am to 6:00 pm; Saturdays from 8 am: to 1:00 pm
7.3 Claims.
HOTEL GRANADA REAL guarantees the right to complain to the databases for correction, updating or deletion, or when they notice the alleged breach of any of the duties contained in Law 1581 of 2012 and other applicable regulations. The claim will be processed under the following rules:
If the claim received does not have complete information that allows it to be processed, that is, with the identification of the Holder, the description of the facts that give rise to the claim, the address, and accompanying the documents that you want to assert, the interested party within five (5) business days following receipt to correct any defects. 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 for any reason HOTEL GRANADA REAL receives a claim that should not actually be directed against it, it will forward it to the appropriate party within a maximum period of two (2) business days and will inform the interested party of the situation.
Once the complete claim is received, a legend that says "claim in process" and the reason for it will be included in the database maintained by HOTEL GRANADA REAL, within a period of no more than two (2) business days. Said legend must be maintained until the claim is decided.
The maximum term to address the claim will be fifteen (15) business days counted from the day following the date of receipt. When it is not possible to attend to it within said term, the interested party will be informed before the expiration of the aforementioned period of the reasons for the delay and the date on which their claim will be attended to, which in no case may exceed eight (8) business days following the expiration of the first term.
7.4 Implementation of procedures to guarantee the right to submit claims.
The request for rectification, update or deletion must be submitted through the means enabled by HOTEL GRANADA REAL indicated in the privacy notice and in this document, and contain, at a minimum, the following information:
1) The name, address of the owner and means of contact to receive the response such as telephone, email, residence address.
2) Documents that prove the identity or representation of your representative.
3) The clear and precise description of the personal data with respect to which the owner seeks to exercise any of the rights.
4) If necessary, other elements or documents that facilitate the location of personal data.
Paragraph 1. Rectification and Update of Data. HOTEL GRANADA REAL has the obligation to rectify and update, at the request of the owner, the latter's information that turns out to be incomplete or inaccurate, in accordance with the procedure and terms indicated above. In this regard, the following will be taken into account:
HOTEL GRANADA REAL has complete freedom to enable mechanisms that facilitate the exercise of this right.
Paragraph 2. Data Deletion. The owner has the right, at any time, to request HOTEL GRANADA REAL to delete (eliminate) their personal data when:
Consider that they are not being treated in accordance with the principles, duties and obligations provided for in Law 1581 of 2012.
They are no longer necessary or relevant for the purpose for which they were collected.
The period necessary to fulfill the purposes for which they were collected has been exceeded.
When it deems appropriate.
This deletion implies the total or partial elimination of personal information in accordance with what is requested by the owner in the records, files, databases or treatments carried out by HOTEL GRANADA REAL. It is important to keep in mind that the right of cancellation is not absolute and The person responsible may deny the exercise of the same when:
The request for deletion of information will not proceed when the owner has a legal or contractual duty to remain in the database.
The deletion of data hinders judicial or administrative actions linked to tax obligations, the investigation and prosecution of crimes or the updating of administrative sanctions.
The data is necessary to protect the legally protected interests of the owner; to carry out an action based on the public interest, or to comply with an obligation legally acquired by the owner.
If the cancellation of personal data is appropriate, HOTEL GRANADA REAL must carry out the deletion in such a way that the deletion does not allow the recovery of the information.
7.5 Revocation of Authorization.
The owners of personal data may revoke consent to the processing of their personal data at any time, as long as this is not prevented by a legal provision.
There will be two (2) modalities in which the revocation of consent can occur. The first, regarding all of the consented purposes, that is, that HOTEL GRANADA REAL must completely stop processing the owner's data; The second can cover certain types of processing, such as for market studies.
Due to the above, it will be necessary for the owner, when submitting the request to revoke consent to HOTEL GRANADA REAL, to indicate whether the revocation he intends to make is total or partial. In the partial revocation, you must indicate which treatment the owner does not agree with.
There will be cases in which consent, due to its necessary nature in the relationship between the owner and person responsible for the fulfillment of a contract, cannot be revoked by legal provision.
7.6. Complaints procedure before the Superintendency of Industry and Commerce:
The Owner or successor in title may only file a complaint with the Superintendency of Industry and Commerce once the consultation or claim process has been exhausted with HOTEL GRANADA REAL, in accordance with the aforementioned procedure.
8. Duties of HOTEL GRANADA REAL
Duties of HOTEL GRANADA REAL when acting as Responsible for the processing of personal data.
All those obliged to comply with this policy must keep in mind that it is the responsibility of HOTEL GRANADA REAL to comply with the duties imposed by law in this regard. Therefore, they must act in such a way that they comply with the following obligations:
8.1. Duties of HOTEL GRANADA REAL with respect to the owner of the data.
Request and keep, under the conditions provided in this policy, a copy of the respective authorization granted by the owner.
Inform the owner clearly and sufficiently about the purpose of the collection and the rights granted to him by virtue of the authorization granted.
Guarantee the owner, at all times, the full and effective exercise of the right of habeas data, that is, knowing, updating or rectifying their personal data.
Inform at the request of the owner about the use given to their personal data.
Process queries and claims made in the terms indicated in this policy.
8.2. Duties of HOTEL GRANADA REAL regarding the quality, security and confidentiality of personal data
Observe the principles of truthfulness, quality, security and confidentiality in the terms established in Colombian legislation.
Maintain the information under the security conditions necessary to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access.
Update information when necessary.
Rectify personal data when appropriate.
8.3. Duties of HOTEL GRANADA REAL when carrying out the treatment through a Manager
Provide the Data Processor only with the personal data that you are authorized to provide to third parties.
Guarantee that the information provided to the Data Processor is true, complete, accurate, updated, verifiable and understandable.
Communicate in a timely manner to the Data Processor all the news regarding the data that you have previously provided and adopt the other necessary measures so that the information provided to it is kept up to date.
Inform the Data Processor in a timely manner of the rectifications made to the personal data so that he or she can proceed to make the pertinent adjustments.
Require the Data Processor, at all times, to respect the security and privacy conditions of the owner's information.
Inform the Data Processor when certain information is under discussion by the owner, once the claim has been submitted and the respective process has not been completed.
8.4. Duties of HOTEL GRANADA REAL with respect to the Superintendence of Industry and Commerce
Inform you of possible violations of security codes and the existence of risks in the administration of the owners' information.
Comply with the instructions and requirements issued by the Superintendency of Industry and Commerce.
8.5. Duties of HOTEL GRANADA REAL when acting as Data Processor of personal data.
If HOTEL GRANADA REAL carries out data processing on behalf of another entity or organization (Controller), it must comply with the following duties:
Establish that the Data Controller is authorized to provide HOTEL GRANADA REAL with the personal data that it will process as Processor.
Guarantee the holder, at all times, the full and effective exercise of the right of habeas data.
Maintain the information under the security conditions necessary to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access.
Timely update, rectify or delete data.
Update the information reported by the Data Controllers within five (5) business days from receipt.
Process queries and claims made by the owners in the terms indicated in this policy.
Register in the database the legend “claim in process” in the manner established in this policy.
Insert the legend “information under judicial discussion” into the database once notified by the competent authority about judicial processes related to the quality of personal data.
Refrain from circulating information that is being controversial by the owner and whose blocking has been ordered by the Superintendency of Industry and Commerce.
Allow access to the information only to people authorized by the owner or empowered by law for this purpose.
Inform the Superintendency of Industry and Commerce when violations of security codes occur and there are risks in the administration of the owners' information.
Comply with the instructions and requirements issued by the Superintendency of Industry and Commerce.
9. International transfer of personal data
When data is sent or transferred to another country, it will be necessary to have the authorization of the owner of the information that is being transferred. Unless the law states otherwise, the existence of said authorization is a necessary presupposition to carry out the international circulation of data. In this sense, before sending personal data to another country, those obliged to comply with this policy must verify that they have the prior, express and unequivocal authorization of the owner that allows their personal data to be transmitted.
Said transfer of personal data is carried out only to third parties with whom HOTEL GRANADA REAL has a contractual, commercial and/or legal relationship.
10. Privacy Notice
HOTEL GRANADA REAL, hereinafter and to whom the rights are transferred, informs you that the privacy notice for the processing of your personal data can be consulted on the website https://www.hotelgranadareal.com.co
11. Modification and/or update of the data protection and information management policy
Any substantial change in the Treatment policies will be communicated in a timely manner to the data owners through the usual means of contact and/or through:
HOTEL GRANADA REAL website https://www.hotelgranadareal.com.co
Email sent to the holders, for holders who do not have access to electronic means the communication will be made by certified mail and failing that it will be published in a widely circulated newspaper.
Communications will be sent at least ten (10) days before implementing the new policies and/or substantial update thereof.
12. Validity of personal information processing policies.
These policies apply as of May 20, 2016
As a general rule, the term of authorizations on the use of personal data by the owners is understood to be the term of the commercial relationship or of the link to the service and during the exercise of the company's corporate purpose.
The authorizations on the data of the owners may be terminated at their will at any time. If the person is an active client of HOTEL GRANADA REAL, their data cannot be used for anything other than the provision of the product or service and for the offer of subsequent renewals when the service has this modality.
When the terms of the privacy policies and use of personal information of any of the services or products contracted by an owner change essentially, as a general rule, in the services that have the option of renewal, the new authorization will be obtained in this case. . For other cases, authorization will be obtained in the manner established for each privacy policy or notice or through the usual means of contact between the company and the owners.
