Privacy policy and treatment of personal data

Name or corporate name: BLOCK FACTORING S.A.S.

TAX IDENTIFICATION NUMBER: 901.376.146-9

Address: Bogotá D.C.

Address: Carrera 14 N° 76-26 OFC 504

Name of Person Responsible: GESSE CARLOS DE MORAES AGUIAR

E-mail:blockfactoring@gmail.com

Manager’s phone number: 322 7900927

We care deeply about your privacy and keeping the personal information you share with us secure. For your peace of mind, we will never sell or share your information with third parties unrelated to our operations.

If you would like to learn more, please review our security policies below:

WHO ARE WE?

We are BLOCK FACTORING S.A.S, identified with NIT 901.376.146-0, domiciled in the city of Bogota and incorporated under the laws of the Republic of Colombia, and one of our priorities is to respect the privacy of our users and keep safe the information and personal data we collect.

BLOCK FACTORING S.A.S. recognizes the importance of security, privacy and confidentiality of personal data of our employees, customers and users, which are provided through the site https://www.alameda.co/, or any of its channels, such as Facebook, Instagram, among others and we are committed to the protection and proper handling of it.

BLOCK FACTORING S.A.S. AGREEMENTS

The Company, in the development of its corporate purpose, enters into agreements and contracts with individuals, which include clauses that ensure at least the same level of protection as this document.

PURPOSE OF THIS PRIVACY POLICY

This document contains the policy of treatment of information and personal data of BLOCK FACTORING S.A.S., and its purpose is to make known what kind of information is collected, for what purposes, what is the use that will be given to it, when it will be shared and how it will be protected.

Likewise, this document incorporates the rights of the holders of such information, as well as the procedures or mechanisms available to them to exercise them.

By visiting and/or using and/or registering on our portal, by entering into our contracts, you expressly agree to the processing of personal data collected through the website https://getbfm.com (hereinafter the “Website”) in accordance with the terms and conditions set forth in this privacy policy (hereinafter the “Privacy Policy”).

You can visit the site and browse without having to provide personal data. During your visit to the site, you will remain anonymous and at no time will we be able to identify you, unless you have an account on the site and log in with your user name and password.

The Web Site may change domain or deactivate at any time and according to the internal reorganization processes of BLOCK FACTORING S.A.S., changes that will be announced in a timely manner to our customers and users.

All of our contracts incorporate a clause reflecting acceptance of our company’s data protection policy.

INFORMATION AND PERSONAL DATA TO BE PROCESSED

BLOCK FACTORING S.A.S. may collect information and other personal data from our customers and users, which may include, but is not limited to, the following:

Name and surname.

Type and identification number.

3. Address and place of residence.
4. Gender and date of birth (age).
5. Marital Status.
6. Landline and Cell Phone (personal or work).
7. E-mail (personal or business).
8. Fax.
9. Details of your comments, complaints, claims, recommendations.
10. Information and personal data collected through surveys, focus groups or other market research methods.
11. Data collected through cookies and web beacons: IP address, GPS location, type of device used to access the Website, type of browser, operating system, time of access to the Website, time spent browsing the Website, web pages visited, information consulted.

The information and data collected as a result of the different operations or relationships established by virtue of the use of the Web Site and the services offered therein, may be stored or processed in our own or contracted servers located in Colombia or in other countries, which is understood to be authorized by our customers and users when accepting this Privacy Policy document.

Additionally, BLOCK FACTORING S.A.S. is authorized by the acceptance of this security policy to collect, store, share and compare with different national administrative authorities of control and surveillance.

SENSITIVE DATA.

Sensitive data are understood as those that affect the privacy of the holder or whose improper use may generate discrimination, such as those that reveal racial or ethnic origin, political orientation, religious or philosophical convictions, membership in trade unions, social organizations, 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, 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 still or moving images, fingerprints, photographs, iris, voice, facial or palm recognition, etc.

Data classified as sensitive may be used and processed when:

1. a) The Data Subject has given his/her explicit authorization to such processing, except in those cases where the law does not require the granting of such authorization.
2. b) The processing is necessary to safeguard the vital interest of the holder and he/she is physically or legally incapacitated. In these events, the legal representatives must grant their authorization.
3. c) The processing is carried out in the course of legitimate activities and with due guarantees by a foundation, NGO, association or any other non-profit organization, whose purpose is political, philosophical, religious or trade union, provided that they refer exclusively to its members or to persons who maintain regular contacts by reason of their purpose. In these events, the data may not be provided to third parties without the owner’s authorization.
4. d) The Processing refers to data that are necessary for the recognition, exercise or defense of a right in a judicial proceeding.
5. e) The processing has a historical, statistical or scientific purpose. In this event, the measures leading to the suppression of the identity of the Data Subject or the data is dissociated, i.e., the sensitive data is separated from the identity of the Data Subject and is not identifiable or it is not possible to identify the person who is the Data Subject of the sensitive data or data.

In addition to the above, BLOCK FACTORING S.A.S. complies with the following obligations:

1. a) Inform the holder that since it is sensitive data, he/she is not obliged to authorize its processing.
2. b) Inform the holder explicitly and in advance, in addition to the general requirements of the authorization for the collection of any type of personal data, which data subject to processing are of a sensitive nature and the purpose of the processing, and obtain the express consent.
3. c) Not to make any activity conditional on the holder providing sensitive personal data (unless there is a legal or contractual cause to do so).

Likewise, BLOCK FACTORING S.A.S, adheres to the general rule according to which the processing of sensitive data is prohibited by law, except in the following cases:

1. a) When the Data Subject has expressly authorized the Processing.
2. b) When the law does not require the granting of such authorization.
3. c) When the Processing is necessary to safeguard the vital interest of the Data Subject.
4. d) When the Processing is carried out by a foundation, NGO, association or any non-profit organization, whose purpose is political, philosophical, religious or trade union.
5. e) The processing is necessary for the recognition, exercise or defense of a right in a legal proceeding.
6. f) The Processing obeys a historical, statistical or scientific purpose. In this case, the identities of the Data Subjects must be suppressed.

VERACITY OF THE INFORMATION

BLOCK FACTORING S.A.S presumes, under the principle of good faith, that all information provided is true and corresponds to reality, so it will not perform verifications on the identity of the customer and/or user, or on the data provided by each of them. By virtue of the above, BLOCK FACTORING S.A.S will not be liable for any damage or injury arising from or in connection with the lack of veracity, validity, sufficiency or authenticity of the information, including damages that may be due to homonymy or impersonation.

The above without prejudice that blocks FACTORING S.A.S. or third parties authorized by it, verify information provided by customers and/or users in relation to medical prescriptions for devices on measure for visual and eye health.

TERM OF STORAGE OF THE INFORMATION AND DATA COLLECTED.

The information provided to BLOCK FACTORING S.A.S. by its users or customers may remain stored for a term of up to 10 years from the last time such information was entered or required for the development of operations between the user and/or customer and BLOCK FACTORING S.A.S. The above in order to allow the Web Site to comply with its obligations in tax, fiscal and accounting matters, as well as before state bodies responsible for the development of inspection and surveillance activities.

INFORMATION OF MINORS.

Minors (children and adolescents under 18 years of age) may not be users of the products and services offered by BLOCK FACTORING S.A.S., to the extent that it is not possible to verify that they act through their parents, or with due authorization from them.

In any case, BLOCK FACTORING S.A.S, in case of possessing information of minors will ensure the proper use of their personal data, ensuring that the processing of their data respects the best interests of them and their fundamental rights.

PURPOSES OF THE PROCESSING OF PERSONAL DATA

The information and personal data that will be processed will be used for the following purposes, which are necessary for the existence, maintenance, and fulfillment of the legal relationship between the customer and/or user and BLOCK FACTORING S.A.S.

Main purposes

1. To enable you to create, use, customize and take advantage of the available functionalities.
2. To identify you for customer service purposes, as well as for the processing of requests referred to in this Privacy Policy.
3. To inform you about changes and/or updates to the Website, the Terms and Conditions and this Privacy Policy.
4. To evaluate the quality and functionality of the goods and services provided by BLOCK FACTORING S.A.S.
5. To make a list of users and keep a file on each user.

TRANSFER OF PERSONAL DATA

BLOCK FACTORING S.A.S. may transfer your data when so required by the authorities authorized for such purpose, in order to validate the information provided, or when the transfer is necessary or legally required for the safeguarding of public interest, or for the procurement or administration of justice; when the transfer is necessary for the recognition, exercise or defense of a right in a judicial process, and when the transfer is necessary for the maintenance or fulfillment of a legal relationship between the responsible and the holder.

COOKIES

Cookies are small pieces of information that are sent by the Web Site to your browser and stored on your computer’s hard drive and are used to determine your preferences when you connect to services on our sites, as well as to track certain behaviors or activities carried out by you within our sites.

Your browser can be set not to accept cookies, but this may restrict your use of the Web Site and limit your experience on the Web Site. The use of cookies does not contain or affect personal or private data and does not pose a risk of viruses. For more information about cookies, go to http://www.allaboutcookies.org.

SECURITY

To safeguard the information you provide us, BLOCK FACTORING S.A.S. has established policies, procedures and standards of information security, which aim to protect and preserve the integrity, confidentiality and availability of the information, regardless of the medium or format where it is located, its temporary or permanent location or the way in which it is transmitted. In this sense, we rely on technological security tools and implement industry-recognized security practices, which include: transmission and storage of sensitive information through secure mechanisms, such as encryption, use of secure protocols, securing technological components, restricting access to information to authorized personnel only, information backup, secure software development practices, among others.

In any contract or link that BLOCK FACTORING S.A.S. establishes with third parties in which the handling or use of the information or data collected is involved, for example, with the companies in charge of transporting the products to the customer, a confidentiality commitment is incorporated that details their commitments for the protection, care, security and preservation of the confidentiality, integrity and privacy of the same.

INQUIRIES

The Holders or their assignees may consult the personal information contained in any of the Company’s databases. The Company or the Data Controller or Data Processor shall provide them with all the information contained in the individual record or that is linked to the identification of the Data Subject.

The consultation shall be formulated by the Holders or their successors in title in writing, addressed to the following Contact:

[blockfactoring@gmail.com], mentioning sufficient information to identify the required data of the Holder.

The company shall record the date of receipt of the same and shall be responsible for processing it.

The consultation will be answered within a maximum term of ten (10) working days from the date of receipt thereof. When it is not possible to attend the consultation within such term, the interested party shall be informed, stating the reasons for the delay and indicating the date on which the consultation will be attended, which in no case may exceed five (5) business days following the expiration of the first term.

PROCEDURE FOR THE EXERCISE OF THE RIGHTS OF THE HOLDERS OF THE INFORMATION

Customers and users of BLOCK FACTORING S.A.S have the possibility and the right to access the data and information collected and stored by BLOCK FACTORING S.A.S or in any means of contact, as well as to exercise their rights as holders of such information and data, under the terms of the rules of data protection that are applicable to them and as set forth in this Privacy Policy.

For the case of personal data in Colombia, the procedures for the exercise of the rights of the holders shall be as provided in Law 1581 of October 17, 2012 “Whereby general provisions are issued for the protection of personal data”.

Customers and users have the right to consult and know what use is being made of the information obtained from them. Similarly, in the event that the data or information is incomplete or inaccurate, the user or customer may rectify them, and if he considers that they are not being used in accordance with the legal provisions on the subject, or contrary to the provisions of this privacy policy, he may cancel such data and information from BLOCK FACTORING S.A.S.

To enforce their rights, customers and users may exercise their rights to know, update, rectify and delete their personal data by sending their request to the email gesse.aguiar@gmail.com coordinated by the area in charge (Customer Service), in accordance with this Privacy Policy, or you may contact our telephone line +57 1 344 1300, through written communication sent to our registered office Cra. 14, #76-26, Bogota, Colombia.

The following information must be included in the application: i. Names and surnames; ii. Type and number of identification document; iii. Contact telephone number (landline and/or cell phone); iv. E-mail address;

1. Subject.

TYPE OF INFORMATION REGARDING EMPLOYEES AND SHAREHOLDERS

The Company recognizes that its Employees and shareholders are entitled to have a reasonable expectation of privacy, taking into account their responsibilities, rights and obligations to the Company.

By virtue of the relationship established between you and the Company, the Company collects, stores, uses and transfers personal data to companies located inside and outside Colombia. Such personal data and information include, among others:

1- Candidates

1. Name, identification, address, telephone number, date of birth, educational information, participation in recreational activities and sport.
2. Resume, education, experience, links with entities, links with companies.

2- Employees

1. Worker and Family Group: name, identification, address, telephone, name of wife and children, name and identification of children, medical history, social security affiliations, medical policy, age, date of birth, education information, health status, medications used, medical authorizations, participation in recreational activities and sports;
   b.Resume, education, experience, links with entities, links with companies;
   c. Salary and other payments;
   d. Balance of debts contracted with BLOCK FACTORING S.A.S. or libranza;
   e.Affiliations with payroll deduction;
   f. Pension contributions;
   g.Constitution and contributions to voluntary pension funds, food vouchers, etc.;
   h.Legal proceedings, seizure;
   i.Debts in favor of cooperatives;
   j.Authorizations for discounts;
   k.Information on affiliation to employee and union funds;
   l.Benefits during your entire working life;
   m.Employment contract;
   n. Changes in the employment contract;
   o. Relationship with previous employers; p. Work history of the worker;
   q. Payment of allowances and benefits;
   r.Beneficiaries of the employee for the payment of allowances and benefits;
   s. Affiliation with EPS, pension fund, ARL, compensation fund;
   t.Training received;
   u. Psychological evaluation report;
   v. Detail of the characterization;
   w.Demographic report of workers;
   x.Occupational medical history of the worker;
   y.Occupational accidents;
   z.Overtime;
   sign in and out
   bbFingerprint;
   Photographics record;
   ddUnion membership;
   ee. Annual competency evaluation

If the information collected includes sensitive data, BLOCK FACTORING S.A.S. will inform you of the quality of such sensitive data and the purpose of the processing, and will only be processed with prior, express, and informed consent. Since it is sensitive data, no one is obliged to authorize its treatment.

4. Use and purpose of the treatment

Personal data are used for:

1. Execution of the contract entered into with any of the Company.
   b. Payment of contractual obligations.
   c.Sending information to governmental or judicial entities by express request of the same.
   d. Support in external/internal auditing processes.
   sending/receiving messages for commercial, advertising and/or customer service purposes.
   f. Registration of information of candidates, customers, employees and suppliers in the Company’s database.
   g. Contact with candidates, customers, employees or suppliers to send information related to the contractual, commercial and obligatory relationship that may take place.
   h., commercial and obligatory collection of data for the fulfillment of the duties that the Company has as Responsible for the information and personal data.
   i.For security or fraud prevention purposes.
   j.To provide an effective customer service.
   k Any other purpose resulting in the development of the contract or the relationship between you and the Company.

If Personal data is provided, this information will be used only for the purposes stated herein, and we will not sell, license, transmit or disclose it outside the Company unless (i) you expressly authorize us to do so, (ii) it is necessary to enable our contractors or agents to perform the services we have entrusted to them, or (vi) as required or permitted by law.

In order to implement the purposes described above, personal data may be disclosed for the purposes set forth above to human resources personnel, managers, consultants, advisors and other persons and offices as appropriate.

We may outsource the processing of certain functions or information to third parties. When we do outsource the processing of your personal information to third parties or provide your personal information to third party service providers, we advise such third parties of the need to protect such personal information with appropriate security measures, prohibit them from using your personal information for their own purposes, and prevent them from disclosing your personal information to others.

Similarly, the Company may transfer or transmit (as appropriate) your personal data to other companies abroad for reasons of security, administrative efficiency and better service, in accordance with the authorizations of each of these persons. BLOCK FACTORING S.A.S. has taken the necessary measures for these companies to implement in their jurisdiction and according to the laws applicable to them, security standards and protection of personal data even similar to those provided for in this document and in general in the policy of the Company on the subject. In the case of transfer of personal data, the appropriate transfer contract shall be signed in accordance with the terms of Decree 1377/13.

Additionally, we inform you that once the need for processing your data ceases, they may be removed from the databases of BLOCK FACTORING S.A.S. or archived in secure terms in order to be disclosed only when required by law. Such data will not be deleted despite the request of the owner, when the conservation of the same is necessary for the fulfillment of an obligation or contract.

PROCESSING OF EMPLOYEES’ PERSONAL DATA

BLOCK FACTORING S.A.S. will process the personal data of its employees, as well as those who apply for vacancies, in three moments: before starting the execution of the contractual relationship, during the execution of the contract and after the termination of the employment relationship. 

Data processing before initiating the execution of the contractual relationship. BLOCK FACTORING S.A.S., will previously and expressly inform the persons interested in participating in a selection process carried out by the Company, the rules applicable to the processing of personal data provided by the interested party, as well as those obtained during the selection process. The company BLOCK FACTORING S.A.S., once the selection process is exhausted, will inform the negative result and will deliver to the non-selected persons the data provided unless they expressly authorize the total destruction of the information. The information obtained by BLOCK FACTORING S.A.S., regarding those who were not selected, the results of the psycho-technical tests and interviews, will be eliminated from its information systems, thus complying with the principle of purpose. When BLOCK FACTORING S.A.S. contracts the selection process with companies and / or persons outside the Company, in the respective contract to be signed, it must clearly state the treatment to be given by the third party and the purposes for which the personal information of the owners is provided. The purpose of the delivery of the data provided by those interested in the vacancies of BLOCK FACTORING S.A.S. and the personal information obtained from the selection process is limited to the participation in the same; therefore its use for different purposes is prohibited.

Treatment during the execution of the contract. BLOCK FACTORING S.A.S., is obliged to store personal data and personal information obtained as a result of the selection process of employees, in a folder identified with the name of each of them. Such folders, either physical and/or digital, will be treated by the human resources person of the company BLOCK FACTORING S.A.S., with the specific purpose of allowing the development of the labor relationship. The information of the employees will only be provided to third parties, by virtue of the order of a competent authority, in any other case, the disclosure of such personal data is prohibited.

After termination of the employment relationship. Upon termination of the employment relationship, whatever the cause, BLOCK FACTORING S.A.S., will proceed to store the personal data obtained from the selection process and documentation generated in the development of the employment relationship, in a file, subjecting such information to a higher level of security.

MODIFICATIONS TO THE PRIVACY POLICY

BLOCK FACTORING S.A.S. reserves the right, either for convenience, necessity, requirement or implementation of new legal provisions that demand it, to make at any time modifications or updates to the conditions and terms provided in this Privacy Policy.

These modifications will be available to the public through a notice on the Web Site, or through the last e-mail address provided.

AGREEMENTS.

BLOCK FACTORING S.A.S. frequently subscribes collaboration agreements with different public and private entities, local and national, who subscribe to these agreements and accept this policy assume the obligation to incorporate in their own policies and in the terms of their contracts all the necessary provisions to ensure users at least the same level of protection of this document and what the law determines.

ACCEPTANCE OF THIS PRIVACY POLICY

Users and/or customers, employees of BLOCK FACTORING S.A.S., accept the use and treatment that according to this privacy policy will provide BLOCK FACTORING S.A.S. to the information or data collected or obtained from them in the development of operations through the Website, when you click the button or function Accept.

I give my consent to BLOCK FACTORING S.A.S. to use my personal data for commercial purposes and for opinion polls. In particular, BLOCK FACTORING S.A.S will be authorized to analyze my interactions with the Company (the use of applications, social networks and personal data that I share with BLOCK FACTORING S.A.S) in order to send me personalized messages about projects of interest to BLOCK FACTORING S.A.S. BLOCK FACTORING S.A.S. may contact me by e-mail, text message, regular mail, applications or any other means of communication that I wish to use.

VALIDITY

This General Privacy Policy is effective as of the date of its publication.