Personal Data Processing Policies

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PERSONAL DATA PROCESSING POLICIES

TREATMENT

The information contained in the company’s databases is subject to different forms of treatment, such as: collection, exchange, custody, deletion, transfer, transmission, update, processing, copy, compilation, storage, use, systematization and organization, partially or totally in compliance with the purposes set forth herein.

SENSITIVE DATA

Sensitive data means those data whose misuse may affect the privacy of the Holder or generate discrimination, including but not limited to information related to racial or ethnic origin; political orientation; religious or philosophical convictions; membership to unions, social organizations, as well as data related to health, sexual life and biometrics. Therefore, the Holder is not required to Authorize their processing.

PURPOSE

The information collected by MANUFACTURAS ELIOT S.A.S. has the purpose of allowing the proper development of its object as a company dedicated to manufacturing, dressmaking and marketing at national and international level of textile products and clothing. In addition, the company keeps the necessary information to comply with legal duties, mainly in accounting, corporate, and labor matters. Information on clients, suppliers, partners and employees, current or past, is stored in order to facilitate, promote, allow or maintain labor, civil and business relationships.

a. Purpose of Processing Clients and Vendors Data

MANUFACTURAS ELIOT S.A.S. may Process the personal information about its Clients for the purpose of supporting contracted or agreed business relationships, and/or supply goods and services to MANUFACTURAS ELIOT S.A.S., in accordance with its corporate purpose. For this reason, contracts entered into with Clients or Vendors will be governed by the provisions of this Policy or will include a clause regulating the Processing of the information accessed hereof.
As mentioned above, the data collected will have the following purposes:

•  Stay informed, by any means, on products or services that    MANUFACTURAS ELIOT S.A.S. offers or may offer in the market, or those offered by its subsidiaries or strategic allies.

•  Inform and participate in the advertising and/or promotional activities of MANUFACTURAS ELIOT S.A.S. through any means, to current or future clients and suppliers, including those with whom the business relationship has ended.

•  Perform all administrative, financial and marketing procedures directly related to the ordinary course of business.

•  Transmit or transfer the information, when required by a duly authorized state entity or third party.

•  Access, consult, report, compare and evaluate the information in databases of credit rating agencies, financial, judicial records or private security companies.

•  Prepare and/or publish statistics reports.

•  Contact the client or provider by any means, so that MANUFACTURAS ELIOT S.A.S. may fulfill its corporate purpose and carry out the ordinary course of business.

•  Store the fulfillment or breach of the obligations, where all the data referring to the current and past behavior vis-avis the financial sector and, in general vis-a-vis the fulfillment of my obligations is fully recorded.

b. Purpose of Processing Employees and Former Employees Data.

MANUFACTURAS ELIOT S.A.S. shall Process the personal information of its employees along with its family nucleus, in order to fulfill the obligations that rise from the respective labor relations. Such obligations include, among others, payroll payments, granting benefits, performance evaluations, improvement of training programs, biometric data, among others.
Likewise, MANUFACTURAS ELIOT S.A.S. may collect personal information from applicants who submitted their data for the selection processes to be able to carry out the respective process of hiring personnel. Additionally, MANUFACTURAS ELIOT S.A.S. may store indefinitely the information of those who were candidates for these processes and use it in future personnel selection processes. Therefore, it is understood that any person who submits a resume though any means in order to apply as a candidate to work with MANUFACTURAS ELIOT S.A.S., understands and authorizes the Processing of his or her personal data.
MANUFACTURAS ELIOT S.A.S. will have a file in which the personal data of all Employees who have terminated their employment relationship will be stored indefinitely. This file will have the purpose of: (i)Serve as the basis for the issuance of labor certificates referred to in Article 57, numeral 7 of the Colombian Labor Law, at the request of Former Employees or their assignees; (ii) Serve as the basis for granting work references to potential Employers of the former employee; and/or (iii) the information stored in this file may be studied, analyzed and used by MANUFACTURAS ELIOT S.A.S. in order to consider the Former Employee in the processes of hiring personnel.

On the other hand, MANUFACTURAS ELIOT S.A.S., on the occasion of events, trainings or other activities performed, may record audios, videos or take photos of employees during development of the events. This information may be used by MANUFACTURAS ELIOT S.A.S. in newsletters, reports, internal publications, and in general, in any activity, even when the employee has stopped working with MANUFACTURAS ELIOT S.A.S.

c. Purpose of Processing Visitors’ Data:

MANUFACTURAS ELIOT SAS, shall collect, store and process the personal data of visitors, such as: personal information, photographs, videos, registration of entry, route in the facilities and exit, in order to surveil physical security and facilitate access to different departments of our company.

HOLDERS’ RIGHTS

Pursuant to the provisions of article 8 of Law 1581 of 2012, holders may:

•  Know, update and rectify their personal data held by the company or the Managers. This right may be exercised, including but not limited to, partial inaccurate, incomplete, fractional data which may mislead, or those whose Processing are expressly prohibited or have not been authorized.

•  Request proof of authorization granted to the Company, except when expressly it is excepted as a requirement for Processing, pursuant to the provisions of article 10 of this law.

•  Be informed by the Company or the Manager, upon request, regarding the use they may have given to the holder’s personal data.

•  File complaints with the Superintendence of Industry and Commerce for offenses against the provisions of this law and the other regulations that modify, add or complement it.

•  Revoke the authorization and/or request the deletion of the data when the Constitutional and legal principles, rights and guarantees are not respected in the Processing. Revocation and/or deletion will be performed when the Superintendence of Industry and Commerce has determined that the Company or the Manager has incurred in conduct contrary to this law and the Constitution.

•  Access, free of charge, to their personal data that have been Processed.

RESPONSIBLE PERSON OR AREA

Any request, complaint or claim related to the handling of personal data, pursuant to the provisions of Law 1581 of 2012 and Decree 1377 of 2013, shall be sent to:

Company: MANUFACTURAS ELIOT S.A.S
Address: CLL 18 A NO 69 B 06, Bogota D.C.

Databases

VENDORS

DRESSMAKING CLIENTS

TEXTILE CLIENTS

EMPLOYEES AND FORMER EMPLOYEES

VISITORS

E-mail

proveedoreshabeasdata@patprimo.com.co

casaavedra@patprimo.com.co

yrodriguez@patprimo.com.co

erodriguez@patprimo.com.co

jrubiano@patprimo.co

Telephone

405 5252 ext. 505

405 5252 ext. 120

446 4300 ext. 136

321 456 9092

310 589 0105

PROCEDURES FOR ATTENDING REQUESTS, CONSULTATIONS AND CLAIMS

a. Petitions and Claims:

The holders or their assignees may consult the personal information of the Holder in the database of MANUFACTURAS ELIOT SAS, which shall answer to any request for consultation, correction, update or deletion. Said request or query must be submitted in writing or by email, according to the information contained in this document.

The consultations will be attended within ten (10) business days from the date of submission of the corresponding request. If it is not possible to attend the query within said term, the interested party will be informed, expressing the reasons for the delay and indicating the date on which the query will be attended, which in any case shall be solved within five (5) business days after the first term expiration.

b. Claims:

Claims shall be made in writing or by email, according to the information contained hereby, and shall contain at least the following information:

• Holder identification
• Description of the facts which give rise to the claim
• Holder address
• Documentation that the holder wants to submit as evidence.

If the claim is incomplete, the interested party will be summoned within five (5) days after the claim is received, to correct the failures. If after two (2) months from the date of the request the applicant has not submitted the required information, it will be understood that claimant has given up the claim.
If the person who received the claim is not competent to resolve it, he or she will transfer it to the corresponding party within a period of two (2) business days and will inform the interested party of the situation.
Once the complete claim is received, a sign saying “claim in process” and the reason for it will be included in the database, in a term not later than two (2) business days. Such sign shall be maintained until the claim is decided. The maximum term to attend the claim will be fifteen (15) business days after the date of submission. 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 the claim will be attended, which will be within eight (8) business days following the expiration of the first term.

VALIDITY OF THE DATABASE

The Personal Data Processing Policy of MANUFACTURAS ELIOT S.A.S. is effective as of August 10 (10), 2016. MANUFACTURAS ELIOT S.A.S. reserves the right to modify them, in the terms and with the limitations provided by law. The data may be deleted at any time at the request of their holder. However, the databases managed by the company will be maintained indefinitely, while developing its purpose, and as long as necessary to ensure compliance with legal obligations, particularly labor and accounting, once the purposes described here are met, the data will be removed from our database.

DEFINITIONS

To facilitate a better understanding of this Policy for the Processing of Personal Data, you may consult the definitions provided at Law 1581 of 2012 or rules that add or modify it.
Notwithstanding the above, we present a list of the following definitions:

a. CUSTOMER: Natural or legal person with whom MANUFACTURAS ELIOT S.A.S. has a business relationship.

b. EMPLOYEE: Natural person who provides personal services to MANUFACTURAS ELIOT S.A.S. under an employment contract.

c. FORMER EMPLOYEE: Natural person who provided personal services to MANUFACTURAS ELIOT S.A.S. under an employment contract that ended for any reason.

d. VENDOR: Natural or legal person who supplies goods and/or services to MANUFACTURAS ELIOT S.A.S. under a business relationship.

e. HOLDER: Natural person whose personal data is subject to Processing.

f. VISITOR: Any natural person who is located in any of the branches of MANUFACTURAS ELIOT S.A.S. and who does not have the capacity of Employee.