This policy applies to all databases and the personal data contained therein, with respect to whose processing FUNDACIÓN SOLIDARIDAD NETWORK COLOMBIA (hereinafter, the Foundation) is responsible within the contextual framework of Ley 1581 de 2012 and any other regulations that supplement, amend, complement, or implement it. For the purposes of this policy, the terms set forth below shall have the following meanings:

 

1. Definitions

Authorization. Prior, express, and informed consent of the data subject to carry out the processing of personal data.

Privacy notice. Verbal or written communication addressed to the data subject of the personal information (user) by which the Data Controller (us) informs the data subject about the existence of the information processing policies applicable to them, the manner of accessing such policies, and the purposes of the Processing intended for the personal data. The privacy notice shall be used only in the event that the entity’s privacy policy cannot be made available to data subjects.

Database. An organized set of personal data that is subject to Processing.

Personal data. Any information linked to, or that may be associated with, one or more specific or identifiable natural persons (users). In order to comply with its legal and contractual obligations, the Data Controller (us) requires the processing of personal data, including that of its staff, clients, suppliers, and third parties in general, to whom the provisions set forth in Ley 1581 de 2012, its implementing and complementary decrees, and, consequently, this policy are applicable.

Public Personal Data. Data that may be consulted by any person directly, without the data subject’s consent. Example: identification (cédula) number, first and last names, profession or occupation, etc.

Private Personal Data. Data that is relevant only to its data subject. Example: home address and telephone number.

Semi-Private Personal Data. Data that, in addition to being of interest to the person, may be of interest to the data subject in a certain sector or group of persons. Example: date and place of birth.

Sensitive Personal Data. Data that affects the data subject’s privacy or whose improper use may give rise to their 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 organizations that promote the interests of any political party or that safeguard the rights and guarantees of opposition political parties; data relating to health and to sexual life; and biometric data.

Data Processor. A natural or legal person, public or private, who, on their own or in association with others, carries out the processing of personal data on behalf of the Data Controller.

Project or program. Any project or program that involves an information-gathering activity by the organization and/or its partners.

Data Controller. A natural or legal person, public or private, who, on their own or in association with others, decides on the database and/or the processing of the personal data.

Data subject. A natural person whose personal data is subject to Processing. (User)

Processing. Any operation or set of operations on personal data, such as collection, storage, use, circulation, or deletion.

Transfer. Occurs when the Data Controller, located in Colombia, sends personal information to a recipient, located within or outside the country, who in turn is the Data Controller of such information.

Transmission. Occurs when the Data Controller, located within or outside the country, shares personal information for its Processing by the Data Processor located within or outside the country.

 

2. How do they obtain personal data?

The Foundation obtains your personal data in various ways. For example, when you access our website or our virtual classrooms. From there we can identify: your name, IP address, place of connection and, on occasion, telephone number and email address.

If you have contacted us, your personal data may also be processed. When you communicate with our reception office by email or telephone, or if you sign up for our email newsletter. In this case we process your email address, first and last names, contact number, etc.

We may also process your data that you share online with us, for example, through our social media. This allows us to offer you specific and relevant information, through advertisements and marketing activities.

 

3. What personal data is collected?

As Data Controller, FUNDACIÓN SOLIDARIDAD NETWORK COLOMBIA, in the course of its activities, may collect personal information from:

✔ Staff members

✔ Suppliers and contractors

✔ Representatives of partner companies

✔ Agricultural producers

Likewise, it may collect from the data subjects certain data, including the following:

✔ Public data: first names, last names, type of identification, marital status, age, sex, work experience, educational level, judicial and/or disciplinary records.

✔ Semi-private data: date and place of birth, location of the farm, hectares, type of crop.

✔ Private data: home address, telephone number and email address, family data, place and date of birth, signature, financial and asset data, and economic activity.

✔ Sensitive data: organizations to which the data subject belongs, biometric data, etc.

✔ Other data: particular tastes and/or interests, interaction data (for example, cookies on our website that improve your user experience), among others.

From the foregoing list of personal data, the Foundation will collect only those considered necessary for the purposes for which they are to be processed in each of its activities or projects/programs.

 

4. For what purpose do they collect personal data?

At the time of requesting your authorization, the purposes of the data processing are:

4.1. Educational and research processes

• Maintaining contact with attendees of workshops and focus groups
• Maintaining contact with participants of virtual courses
• Sending information considered to be of interest to attendees and participants in educational and research processes
• Sharing it with partner companies or other members of Solidaridad Network within and outside Colombian territory
• Control, historical, and statistical purposes

4.2. Processes related to projects/programs

• Defining baseline indicators
• Validating the behavior of variables over time
• All objectives related to sustainable development
• Performing analyses and drawing up statistics
• Sharing it with partner companies and Solidaridad Network organizations in statistical form
• Offering credit options
• Handling petitions, complaints, and claims
• Responding to requirements from authorities

The Foundation processes your personal data confidentially. We ensure that appropriate technical and management measures are carried out to protect your personal data.

 

5. For how long do they retain personal data?

The Foundation retains the least amount of information possible and only stores the personal information collected for the time required to fulfill the purposes described in this Privacy Policy, in the authorization for the processing of data, and/or to comply with our legal obligations under applicable law.

If the data subject revokes their consent to use the information, the Foundation will retain the information in the event that a contractual relationship with the data subject is maintained and/or for the period of time required to comply with our legal obligations.

Data subjects may submit petitions, inquiries, and/or claims regarding their personal data processed by the Foundation through the following mechanisms:

• By sending an email to: correo@correo.org
• Directly at the offices located at Calle 79A #8 – 63 Piso 6, Bogotá, Colombia

 

6. Will they share personal data with third parties?

The Foundation never sells your personal data to third parties. However, it may share the information collected in accordance with the entity’s needs (i) with third parties for the provision of services to the Foundation, including the maintenance and development services for our applications; (ii) with our associated companies or affiliates; (iii) with other partners with whom the Foundation shares activities or implements projects.

In addition, we may use suppliers’ information systems, in which the supplier also has access to the system in which your personal data is processed.

In all cases, we ensure that these third parties comply with good safeguards in the area of privacy and security by entering into data processing agreements with them. A data processing agreement establishes how your privacy is protected.

If it is required or compelled to comply by a judicial, administrative, or arbitration order to transfer, transmit, share, or disclose the information to a governmental authority, only the requested information will be supplied, and reasonable efforts will be made to prevent unauthorized disclosure and/or transfer of such information, as well as to obtain confidential treatment of any undisclosed information in accordance with applicable law.

 

7. What do we commit to when we collect your data?

The Foundation, as Data Controller, complies with the following obligations, without prejudice to the other provisions set forth in Ley 1581 de 2012 and in others that govern its activity:

7.1. We guarantee the Data subject (you), at all times, the full and effective exercise of the right of habeas data.

7.2. We request and retain your data, under the conditions provided for by law, a copy of the respective authorization granted by you in the cases where it is necessary.

7.3. We inform the Data subject (you) about the purpose of the collection and the rights that you are entitled to by virtue of the authorization granted in the cases where it is necessary.

7.4. We keep the information under the security conditions necessary to prevent its alteration, loss, or unauthorized or fraudulent consultation, use, or access.

7.5. We guarantee the Data subject (you) that the information supplied to the Data Processor is truthful, complete, accurate, up to date, verifiable, and comprehensible.

7.6. We update the information, communicating in a timely manner to the Data Processor all developments regarding the data previously supplied to it, and adopt the other measures necessary so that the information supplied to it is kept up to date.

7.7. We rectify the information when it is incorrect and communicate what is pertinent to the Data Processor.

7.8. We require the Data Processor at all times to respect the security and privacy conditions of the Data subject’s information.

7.9. We process the inquiries and claims filed under the terms set forth in the law.

7.10. We adopt an internal manual of policies and procedures to guarantee adequate compliance with the law and, in particular, for the handling of inquiries and claims.

7.11. We inform the data protection authority when violations of the security codes occur and there are risks in the administration of the Data subjects’ information.

7.12. We comply with the instructions and requirements issued by the Superintendencia de Industria y Comercio.

 

8. What are your rights as the owner of the information?

The Data subject (you) of the personal data has the following rights:

8.1. To know, update, and rectify your personal data vis-à-vis the Data Controller. This right may be exercised with respect to data that is partial, inaccurate, incomplete, fragmented, or misleading, or data whose Processing is expressly prohibited or has not been authorized.

8.2. To request proof of the authorization granted to the Data Controller, except where it is expressly exempted as a requirement for the Processing.

8.3. To be informed by the Data Controller, upon request, regarding the use that has been made of your personal data.

8.4. To file complaints before the Superintendencia de Industria y Comercio for infringements of the provisions of the personal data protection law and the other rules that amend, supplement, or complement it.

8.5. To revoke the authorization and/or request the deletion of the data when the principles, rights, and constitutional and legal guarantees are not respected in the processing. The revocation and/or deletion shall proceed only when the Superintendencia de Industria y Comercio has determined that, in the Processing of the information, the Data Controller has engaged in conduct contrary to the law and the Constitution.

8.6. To access, at least once a month free of charge, your personal data that has been subject to Processing by the Data Controller.

 

9. Cookie policy

The Foundation makes use of cookies for its websites. A cookie is a small file embedded in the website pages that is sent to you through your browser and stored on your computer. Our website uses these cookies to make logging in more convenient. The cookies will save your settings and preferences.

You can disable cookies in your browser, but this may affect the functionality of the websites or access to the virtual classroom.

You have the right to request a review, correction, or complete deletion of your information from our files. To do so, send a written request to the channel for handling petitions, inquiries, and claims.

In order to prevent abuse or fraud, we may ask you to identify yourself appropriately before taking action.

If you are requesting a review of your information, you must send us a copy of the cookie in question. You can only delete the cookie files from your computer yourself because they are stored on your local device. Consult your browser’s instructions before doing so.

Cookies can never be used to access private information on your computer or to track passwords. Nor can they be used to infect a computer with a virus (trojan). They are completely safe and have been an industry-wide standard for most websites in the world since the 1990s.

 

10. Handling of Petitions, Inquiries, and Claims

The Foundation, through the communications area, will handle all petitions, inquiries, complaints, and/or claims of the data subjects of the information, related to the rights established in the law to know, update, rectify, and delete their personal data.

10.1. Petitions and inquiries

In accordance with Article 14 of Ley 1581 de 2012, petitions and inquiries will be handled within a maximum term of ten (10) business days counted from the date of receipt of the same.

When it is not possible to handle the inquiry within such term, the interested party will be informed, stating the reasons for the delay and indicating the date on which the inquiry will be handled, which in no case may exceed the five (5) business days following the expiration of the first term.

10.2. Claims

In accordance with Article 15 of Ley 1581, when the Data subject or their successors consider that the information contained in a database must be corrected, updated, or deleted, or when they detect the alleged failure to comply with any of the duties contained in the law, they may file a claim before the Data Controller or the Data Processor.

The claim shall be made by means of a written request addressed to the Data Controller or to the Data Processor, with the identification of the Data subject, the description of the facts that give rise to the claim, the address, and accompanied by the documents to be relied upon.

If the claim is incomplete, the interested party will be required, within the five (5) days following receipt of the claim, to remedy the deficiencies.

After two (2) months have elapsed from the date of the request, without the applicant submitting the required information, it shall be understood that they have withdrawn the claim.

In the event that the person who receives the claim is not competent to resolve it, they shall refer it to the appropriate party within a maximum term of five (5) business days and will inform the interested party of the situation.

Once the complete claim is received, a notation reading “claim in process” and the reason for it shall be included in the database, within a term of no more than five (5) business days. Such notation must be maintained until the claim is decided.

The maximum term to handle the claim shall be fifteen (15) business days counted from the day following the date of its receipt. When it is not possible to handle the claim within such term, the interested party will be informed of the reasons for the delay and the date on which their claim will be handled, which in no case may exceed the eight (8) business days following the expiration of the first term.

10.3. Channels for handling inquiries and claims:

• By sending an email to: correo@correo.org
• Directly at the offices located at Calle 79A #8 – 63 Piso 6, Bogotá, Colombia

 

11. Current regulations

This Information Processing Policy is governed by the provisions of Ley 1581 de 2012, implementing Decreto 1377 de 2013, and other rules that amend them.

 

12. Changes to the privacy policy

The Foundation reserves the right to review and/or modify this Information Processing Policy at any time. The Foundation will publish on its website any change to this Policy. When substantial modifications are made to this Policy, this fact will be communicated to the data subjects of the information, and the date on which the new Policy will take effect will be indicated.

 

13. Effective period

This policy takes effect as of the month of January 2023. The personal data processed by the Foundation will remain in the Foundation’s databases until they fulfill the purpose for which they were collected.

 

14. Applicable law and jurisdiction

This Privacy Policy shall be governed by and interpreted in accordance with the laws of Colombia, and any doubts or disputes that arise from it shall be resolved by the courts of Colombia, Departamento de Cundinamarca, ciudad de Bogotá.

 

Information Processing

 

1. Copyright and property rights

The Foundation is the holder of the intellectual property rights. It authorizes the full reproduction of the texts, images, documents, and multimedia content, provided that the integrity of the same is preserved and that it is cited in accordance with the Creative Commons 4.0 License. Attribution-NonCommercial-NoDerivatives 4.0 International.

For inquiries about the reproduction of information, please contact Solidaridad Network Colombia at correo@correo.org

 

2. Inaccuracies

The Foundation would appreciate receiving notification of any inaccuracy on its website or training platform.

Report any inaccuracies, broken links, or suggestions for improvement by writing to: correo@correo.org

The information and suggestions to improve the website, or any notification that the Foundation receives, will be considered non-confidential by the Foundation and intended to be used freely by the Foundation without the need for any additional consent.