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Treatment Policy Protection of Personal Data

Below you will find our Data Protection Policy for the Hotel Santa Barbara Real

Name of the Company: INVERSIONES Y CONSTRUCCIONES NUEVO MILENIUM S.A.S (hereinafter HOTEL SANTA BARBARA REAL)

Address: Calle 127 No 7 – 89 de Bogotá D.C.
Email: [email protected]
Telephone: +57 (1) 629 0944

First article. Definitions

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. The “databases” will have such condition regardless of the medium in which they are contained, which may be physical, electronic, manual, automated, computer tools, etc.
PERSONAL DATA: any information linked or that may be associated with one or more determined or determinable natural persons.
OWNER: natural person whose personal data is being processed.
TREATMENT: 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 the person in charge, addressed to the owner for the treatment of his personal data, by means of which he is informed about the existence of the information treatment policies that will be applicable to him, the way of accessing to them and the purposes of the treatment that is intended to be given to personal data.
PUBLIC DATA: is the data that is not semi-private, private or sensitive. Public data are considered, among others, data related to the civil status of people, their profession or trade and their status as a merchant or public servant. By their nature, public data may be contained, among others, in public records, public documents, gazettes and official gazettes and duly executed judicial decisions that are not subject to reservation.
SENSITIVE DATA: sensitive data means those that affect the privacy of the owner or whose improper use may generate their discrimination, such as those that reveal racial or ethnic origin, political orientation, religious or philosophical convictions, membership of unions, social or human rights organizations 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.
TRANSFER: the data transfer takes place when the person responsible and / or in charge of the treatment of personal data, located in Colombia, sends the information or personal data to a recipient, who in turn is responsible for the treatment and is inside or outside from the country.
TRANSMISSION: processing of personal data that involves the communication thereof within or outside the territory of the Republic of Colombia when it is intended to carry out a treatment by the person in charge on behalf of a single controller.

Second Article. Beginning

In the development, interpretation and application of Law 1581 of 2012, the following guiding principles will be applied harmoniously and comprehensively:

PRINCIPLE OF PURPOSE: the treatment must obey a legitimate purpose in accordance with the Constitution and the Law, which must be informed to the owner.
PRINCIPLE OF FREEDOM: the treatment can only be exercised 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 releasing consent.
PRINCIPLE OF VERACITY OR QUALITY: the information subject to treatment must be truthful, complete, exact, updated, verifiable and understandable. The treatment of partial, incomplete, fractional or misleading data is prohibited.
TRANSPARENCY PRINCIPLE: in the treatment, the owner’s right to obtain from the data controller or the data processor, at any time and without restrictions, information about the existence of data concerning him must be guaranteed.
PRINCIPLE OF ACCESS AND RESTRICTED CIRCULATION: the treatment is subject to the limits derived from the nature of personal data, from the provisions of the law and the Constitution. In this sense, the treatment can only be done by people authorized by the owner and / or by the people provided by law. Personal data, except public information, may not be available on the internet or other means of mass communication or disclosure, unless access is technically controllable to provide restricted knowledge only to the holders or authorized third parties.
SECURITY PRINCIPLE: the information subject to treatment by HOTEL SANTA BARBARA REAL, must be handled with the technical, human and administrative measures that are necessary to grant security to the records, avoiding their adulteration, loss, consultation, use or unauthorized access or fraudulent.
PRINCIPLE OF CONFIDENTIALITY: SANTA BARBARA REAL HOTEL is obliged to guarantee the reservation of information, even after the end of its relationship with any of the tasks that comprise the treatment, being able to only supply or communicate personal data when it corresponds to the development of activities authorized by law.
Third Article. Rights that assist the Holder of the Information
The owner of the personal data will have the following rights:
to. Know, update and rectify your personal data in front of HOTEL SANTA BARBARA REAL in its capacity as data controller. This right may be exercised, among others, against partial, inaccurate, incomplete, fractional data that is misleading, or those whose treatment is expressly prohibited or has not been authorized.
b. Request proof of authorization granted to HOTEL SANTA BARBARA REAL except when expressly excepted as a requirement for treatment (cases in which authorization is not necessary).
c. To be informed by HOTEL SANTA BARBARA REAL, upon request, regarding the use that has been made of their personal data.
d. Submit complaints to the Superintendency of Industry and Commerce for infractions of the provisions of Law 1581 of 2012 and other regulations that modify, add to or complement it.
and. Revoke the authorization and / or request the deletion of the data when the treatment does not respect the principles, rights and constitutional and legal guarantees.
F. Free access to your personal data that has been processed.

 

Fourth Article. Duties of Hotel Santa Barbara Real

By virtue of this policy of treatment and protection of personal data, the following are the duties of HOTEL SANTA BARBARA REAL:

to. Guarantee the holder, at all times, the full and effective exercise of the right of habeas data.
b. Request and keep a copy of the respective authorization granted by the owner.
c. Properly inform the owner about the purpose of the collection and the rights that assist him under the authorization granted.
d. Keep the information under the necessary security conditions to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access.
and. Rectify the information when it is incorrect and communicate the pertinent.
F. Process inquiries and claims made by the holders.
g. Inform the data protection authority when there are violations of the security codes and there are risks in the administration of the information of the holders.
h. Comply with the requirements and instructions issued by the Superintendency of Industry and Commerce on the subject in particular.
i. Inform at the request of the owner about the use given to their data.
j. Guarantee that the information is truthful, complete, exact, updated, verifiable and understandable.
k. Update the information, thus attending to all the news regarding the data of the owner. Additionally, all necessary measures must be implemented so that the information is kept up to date.
l. Respect the security and privacy conditions of the owner’s information.
m. Identify when certain information is under discussion by the owner.
n. Only use data whose treatment is previously authorized in accordance with the provisions of law 1581 of 2012.

Article Fifth. Events in which the Authorization of the Personal Data Holder is not necessary

The authorization of the owner of the information will not be necessary in the case of:

to. Information required by a public or administrative entity in the exercise of its legal functions or by court order.
b. Data of a public nature.
c. Cases of medical or sanitary emergency.
d. Processing of information authorized by law for historical, statistical or scientific purposes.
and. Data related to the Civil Registry of people.

Sixth Article. Legitimation for the Exercise of the Owner’s Right

The rights of the holders may be exercised by the following persons:

 

to. By the owner, who must prove his identity sufficiently by the different means that HOTEL SANTA BARBARA REAL makes available to him.
b. By the holder’s successors (in the cases that the latter is missing due to death or disability), who must prove such quality.
c. By the representative and / or attorney of the owner, after accreditation of the corresponding representation or power.
d. By stipulation in favor of another or for another.
and. The rights of children and adolescents will be exercised by the people empowered to represent them.

Seventh Article. Treatment to which the data and its purpose will be subjected

The information collected is used to process, confirm, fulfill and provide the services and / or products purchased, directly and / or with the participation of third party suppliers of products or services, as well as to promote and advertise our activities, products and services, carry out transactions, make reports to the different national or international administrative control and surveillance authorities, police authorities or judicial authorities, banking entities and / or insurance companies, for internal and / or commercial administrative purposes such as market research, audits, reports accounting, statistical analysis, billing, and offering and / or recognition of benefits of our loyalty programs.

By accepting this POLICY OF TREATMENT PROTECTION OF PERSONAL DATA, our guests, visitors, customers, users and suppliers, in their capacity as owners of the data collected, authorize the HOTEL SANTA BARBARA REAL to carry out the treatment, in whole or in part, including the collection, storage, recording, use, circulation, processing, deletion, for the execution of activities related to the services and products purchased, such as making reservations, modifications, cancellations and changes thereof, refunds, attention of inquiries, complaints and claims, payment of compensation and indemnities, accounting records, correspondence, processing and verification of credit, debit and other payment instruments, fraud identification and prevention of money laundering and other criminal activities and / or for the operation of the loyalty programs and other purposes indicated in e This document.
The foregoing, without prejudice to other purposes that have been reported in this document and in the terms and conditions of each of the products and services of each of our business units.

We warn that third-party providers, such as reservation system providers, travel agencies, call centers, banks, insurance companies, etc., may be involved in these activities. Additionally, our travelers, clients and users, in their capacity as holders of the collected data, by accepting this privacy policy, authorize us to:

to. Use the information received from them, for the purposes of marketing their products and services, and the products and services of third parties with which HOTEL SANTA BARBARA REAL maintains a business relationship.
b. Supply personal data to the control and surveillance authorities of
police or judicial, by virtue of a legal or regulatory requirement and / or use or disclose this information and personal data in defense of your rights and / or your assets as such defense is related to the products and / or services contracted by your travelers , clients and users.
c. Allow access to information and personal data to auditors or third parties hired to carry out internal or external audit processes of the commercial activity that we carry out.
d. Consult and update personal data, at any time, in order to keep this information updated.
and. Contract with third parties the storage and / or processing of information and personal data for the proper execution of contracts concluded with us, under the standards of security and confidentiality to which we are bound.

Article Eighth. Personal data of children and adolescents

The treatment of personal data of children and adolescents is prohibited except in the case of data of a public nature, and when said treatment meets the following parameters and / or requirements:

 

a) that they respond to and respect the best interests of children and adolescents.
b) that respect for their fundamental rights is ensured.
c) that there is authorization from the parent or guardian of the child or adolescent.

Article Ninth. Persons to whom the information can be provided

The information that meets the conditions established by law may be provided to the following persons:

to. To the holders, their successors in title (when those are missing) or their legal representatives.
b. To public or administrative entities in the exercise of their legal functions or by court order.
c. To third parties authorized by the owner or by law.

Article Tenth. Authorization

The collection, storage, use, circulation or suppression of personal data by HOTEL SANTA BARBARA REAL requires the free, prior, express and informed consent of the owner thereof. HOTEL SANTA BARBARA REAL, in its capacity as responsible for the processing of personal data, has had the necessary mechanisms to obtain the authorization of the owners, guaranteeing in any case that it is possible to verify the granting of said authorization.

With the aforementioned authorization, the client accepts the policies and conditions established in this document.

Article Eleven First. Form and Mechanisms to grant authorization

The authorization of the owner of the information will appear in each of the channels and data collection mechanisms of HOTEL SANTA BARBARA REAL. Thus, it may appear in a physical, electronic document or in any other format that guarantees subsequent consultation. The authorization will be issued by the owner prior to the processing of their personal data, in accordance with the provisions of Law 1581 of 2102.

With the consent procedure, it is guaranteed that the owner of the personal data has been informed, both the fact that their personal information will be collected and used for certain and known purposes, and that they have the option of knowing any changes to them. and the specific use that has been made of them. The above in order for the owner to make informed decisions regarding their personal data and control the use of their personal information.

Article Twelfth. Storage procedure for Personal Data Information

HOTEL SANTA BARBARA REAL will adopt adequate and sufficient technical and administrative measures that allow the care and conservation of the personal data of the owners, avoiding their adulteration, loss, consultation, use or unauthorized or fraudulent access. Similarly, the implementation of these measures will allow the preservation of the authorization granted by the holders of personal data for the treatment thereof.

HOTEL SANTA BARBARA REAL will adopt all the mechanisms to keep the information confidential and will abstain from using the information for purposes other than those expressly authorized by the owner. Notwithstanding the foregoing, the client assumes the risks derived from delivering this information in a medium such as the Internet, which is subject to various variables – third-party attacks, technical or technological failures, among others. HOTEL SANTA BARBARA REAL will make its best technological effort to guarantee the security of the personal information of all its clients and / or users, using reasonable and current security methods to prevent unauthorized access, to maintain the accuracy of the data and guarantee the correct use of information.

Article Thirteen. Procedure for the use and circulation of information

For the event in which third parties outside the HOTEL SANTA BARBARA REAL require to validate, rectify or confirm information corresponding to the personal data of the holders contained in the HOTEL SANTA BARBARA REAL databases, the authorization will be required for the supply of the information. prior and express to the owner to operate the transfer. HOTEL SANTA BARBARA REAL will refrain from using the information provided by the owners for marketing purposes other than its specific programs and services.

Article Fourteen. Procedure for Answering Questions

Holders may request the SANTA BARBARA REAL HOTEL to consult their personal data. This request must be made in writing to the email: [email protected], specifying the type of information you want to consult, name, surname, citizenship card, telephone and email to which the corresponding information will be sent.

HOTEL SANTA BARBARA REAL will send the owner the information consulted, which will be made up of a list of all the information that is linked to the owner’s identification in the database. The consultation will be attended within a maximum term of fifteen (15) business days, counted from the day following the date of receipt of the same. When it is not possible to attend the query within said term, the interested party will be informed, stating the reasons for the delay and indicating the date on which his query will be answered, which in no case may exceed eight (10) business days following the expiration of the first term. The consultation will be attended in writing and will not generate cost for the owner.

Article Fifteen. Procedure for the suppression, correction or updating of information

Holders may at any time request the SANTA BARBARA REAL HOTEL to delete, correct or update their personal data and / or revoke the authorization granted for the treatment thereof, by filing a claim as follows:
to. The claim will be made by communication addressed to the email: [email protected] with the identification of the owner, the description of the facts that give rise to the request, the address and accompanied by the documents that support the request if applicable.
b. If the claim is incomplete, the SANTA BARBARA REAL HOTEL will require the owner within five (5) business days after receiving the request to correct the failures. After two (2) months from the date of the request, without the owner presenting the required information, it will be understood that he has withdrawn the claim.
c. Once the complete claim has been received, a legend will be included in the database that says “claim in process” and the reason for it, an activity that must be carried out in a term not exceeding two (2) business days. Said legend must be kept until the claim is decided.
d. The maximum term to attend the claim will be fifteen (15) business days counted from the day following the date of its receipt. When it is not possible to attend the claim within said term, the interested party will be informed of the reasons for the delay and the date on which their claim will be addressed, which in no case may exceed eight (8) business days after the expiration of the first finished.

Article Sixteenth. Temporality of the Processing of Personal Data

The information provided by customers and users allows