PERSONAL DATA MANAGEMENT POLICY - Lean Tech

This policy reflects the type of information that PERFILES Y SOLUCIONES TECNOLÓGICASS.A.S., (hereinafter the "Company"), collects, stores, uses, transmits, treats, and transfers, as well as the purposes of its treatment, and the general guidelines that will be applied to guarantee the adequate treatment of any personal information.

PARTY RESPONSIBLE FOR THE PROCESSING OF ANY PERSONAL DATA

 

COMPILED DATA

As a Private User, we collect your personal data in order to provide you with a better service. To create an account, you must provide us with information such as your first name, middle initial, last name and surname, email address, telephone number, as well as a password.

In the same way, you can also include your academic data, work experience and skills, your location, a photograph, and additionally, you can upload your resume in Word or PDF format in Spanish or English in your profile. We store information associated with the results of your psychometric tests, audio recordings, tracking records of use of our web portal, and the duration of your activity on our portal.

As a Business User, in order to create an account on our Web Portal and use our services, you must provide us, with the identification data of the company, and the contact data of the person who will act on behalf of the company. These data are a name and surname, an email address, and a password.

As an Employee, in order to be linked as an employee of PERFILESY SOLUCIONES TECNOLÓGICAS S.A.S.,, it is necessary that you provide us with your identification data, such as full name, type, and number of identifying document; contact data, such as a cellphone number and/or landline number, an address, or residence address, an email address, a contact person, a relative or person in a relationship with the contact person, gender, date of birth, age, level of education, as well as all information related to academic levels, work experience, marital status, place of birth, nationality, number of children if any, information related to your military record, healthcare provider (EPS), pension fund (AFP), benefits compensation fund, ARL, blood type, name of the bank, and bank account number and type of account, apparel, and footwear sizes, and in general any additional information important to the employment relationship. In the event that the information to be collected is of a sensitive nature, wewill let you know in advance, announcing that it will not be mandatory to provide said, requested information.

As a Contractor/Supplier/Client/Lessor/whether a natural or legal person, we collect contact information, such as landline and/or mobile phone numbers, a business or legal notification address, physical address, email address, type and number of identity, bank certification and in general all the data related to the respective certificate of existence and legal representation, commercial registration certificate and/or RUT and additionally any information related to the purpose of the contract.

 

DATA TREATMENT AND PURPOSE POLICY

PERFILES Y SOLUCIONES TECNOLÓGICAS S.A.S., will inform the owners of the information regarding the treatment that will be given to said information, and about the purposes thereof, in the respective privacy Notices through which it disseminates the existence of these personal data Treatment Policies.

Ingeneral, PERFILES Y SOLUCIONESTECNOLÓGICAS S.A.S., will treat the collected information in the followingmanner:

  • Private User and Business User Information: (i) will be used to carry out the development of the company's corporate purpose; (ii) develop commercial and promotional campaigns; (iii) conduct satisfaction surveys; (iv) store such information in a database and keep a measurement for statistical purposes of those accessing the company's website and applying to job offers; (v) store a database and carry out analytics for statistical purposes of those entering the company's website seeking the provision or supply of services offered by PERFILES YSOLUCIONES TECNOLÓGICAS S.A.S; (vi) such information will be used for contact purposes in order to celebrate eventual commercial or carry out labor relations, depending on the user; (vii) the other uses will involve those reserved for PERFILESY SOLUCIONES TECNOLÓGICASS.A.S, under its privacy policy.
  • Employee Information: (i) will be used to issue, publish, transmit, disseminate, and promote the welfare activities developed by PERFILES Y SOLUCIONES TECNOLÓGICAS S.A.S to the labor community of the company, and through the different social networks that PERFILES Y SOLUCIONES TECNOLÓGICAS S.A.S., uses for advertising guidelines, as well as for radio or television commercials; (ii) to keep the contact information updated;(iii) to verify owner data; (iv) information will be used to build and update work history; (v) to verify and manage leaves of absence, and information related to disabilities and health conditions by the insurance entities of the social security system in health and pension fund entities.
  • Contractor/Supplier/LessorInformation: (i) will be used for the execution of the respective contracts or purchase orders;(ii) used in order to carry out the fulfillment of its tax and accounting obligations; (iii) to execute the due diligence requested by the Superintendency of Companies (Superintendencia de Sociedadesen el capítulo X de su Circular Externa); (iv) it will be used for commercial, promotional and informative purposes; (v) to treat and respond to requests, complaints, claims, reports, suggestions and/or extend congratulatory messages.
  • ShareholderInformation: We collect the data of the shareholders of the company in order to have sufficient information to carry out calls for ordinary or extraordinary meetings of the General Assembly of Shareholders, for the report of exogenous information addressed to the tax and national customs entities (DIAN), and to carry out the due diligence requested by the Superintendency of companies (Superintendencia de Sociedades en el capítulo X de su CircularExterna).

LIMIT ON RETENTION OF PERSONAL INFORMATION

PERFILES Y SOLUCIONES TECNOLÓGICAS S.A.S., will keep the personal data for the duration of the contractual or commercial relationship with the respective person,or with the person they represent or with whom they are related, as well as for the time necessary to comply with the legal obligations of the Company. In general terms, the personal data collected by the Company will be kept for the termlegally applicable to the type of personal data collected, and according to thedatabase to which it belongs, namely:

  •  Labor/Work-Related Data (Employees): kept during the term of the contractual relationship, plus twenty (20) additional years. 
  • Commercial and Accounting Data (BusinessUsers/Private Users/ Lessors/Shareholders/Contractors/Suppliers): kept during the term of the civil or commercial relationship, and for ten (10) more years.

TRANSFER OF INFORMATION

The Company will transfer its Employees and Private Users to BusinessUsers information in order to comply with the contractualobligations of PERFILES Y SOLUCIONES TECNOLÓGICAS S.A.S., which will be expressly accepted by the owners of the information in the respective Notices of Privacy. The Company will cause the holders of the information to be informed regarding the treatment policies that the respective Business Users will apply to the transferred data.

INFORMATION OWNERSHIP RIGHTS

As the owner of the personal data provided to the Company, you have the following rights:

  1. To know, update and rectify your personal data against that held by the Company. This right may be exercised, among others, against partial, inaccurate, incomplete, fragmented, misleading data, or the treatment of those items which are expressly prohibited or have not been authorized;
  2. To request proof of the authorization granted to the Company, except for data whose treatment does not require authorization, under the terms of the applicable legislation;
  3. To be informed by the Company, upon request, regarding the use that has been given to your personal data;
  4. To Submit complaints to the Superintendency of Industry & Commerce (Superintendencia de Industria y Comercio) for violations of the provisions of these Data Processing Policies or the law;
  5. To revoke the authorization and/or request thedeletion of the data when the principles, rights, and constitutional and legalguarantees are not respected in the treatment. The revocation and/or suppression will proceed when the Superintendenceof Industry & Commerce (Superintendencia de Industria y Comercio) hasdetermined that in the treatment the Company has engaged in conduct contrary tothe law or the Political Constitution; 
  6. To gain free access to your personaldata which has been processed, all of which willbe supplied through a media source.

 

INFORMATION RELATING TO MINORS

If you are aminor, we ask you not to provideinformation or personal data, since PERFILES Y SOLUCIONES TECNOLÓGICAS S.A.S., doesnot collect or process personal information of minors under eighteen (18) yearsof age.

SENSITIVE/CONFIDENTIAL INFORMATION

Unless specifically requestedor called on you by the Companyto provide such information,we ask that you do not submit, and do not disclose, sensitive personal data. Ininstances where we may request or call on you to provide confidential orsensitive information, we will do so with your express priorconsent. The owner has the right to choose not to provide any sensitive informationrequested by PERFILES Y SOLUCIONESTECNOLÓGICAS S.A.S., related, among others,to data on their racial or ethnicorigin, membership in trade unions, social or human rightsorganization affiliation, political, religious convictions, sexual preferences,biometrics or health data, unless they are required for the exercise of legalfunctions or when there is an administrative order or judicial authority incharge.

VIDEO SURVEILLANCE

For security purposes and compliance with itsobligations, PERFILES Y SOLUCIONESTECNOLÓGICAS S.A.S., uses various means of video surveillance installed indifferent internal and external sites of our facilities or offices. At theentrance to our facilities, the corresponding privacy notices will be posted,where the purpose of processing the data collected by said means is established, and the sensitive nature of said information is noted,as well as the voluntary nature of providing it.

INQUIRIES AND CLAIMS

To make queries or requests to know, update,rectify, delete the data provided or revoke the authorization granted thereafter, the owner or his successors in the capacityof his/her title can use anyof the following communication channels:

NOTE: All inquiries received through theseoptions outside of the established Service Schedule will be handled on thefollowing work day.

 

To exercise the owner’s right in relationto their personal data, a written communication

must be sent in a physicalor electronic medium, which must contain thefollowing:

  1. Full namesand surnames of the owner of the data or their representative or proxy;
  2. Type and number of the applicant's identity document;
  3. Theelectronic or physical address where correspondence will be received and thetelephone number where the owner may be reached;
  4. The objectof the request and the reasons on which the request isbased;
  5. Photocopyof the identification document of the holderand his/her representative or proxy, when applicable;
  6. Authenticated documentthat accredits the representation of the owner, whenapplicable;
  7. The signatureof the petitioner or attorney, when applicable.

If the query or request is incomplete, PERFILES Y SOLUCIONES TECNOLÓGICAS S.A.S., willrequire the interested party, within five (5) days of receipt, to correct themistakes. After two (2) months from the date of the request, without thepetitioner submitting the requested and correctedinformation, it will be understood that he/she has withdrawn the respective query or request.

Once the query or completerequest is received,the Company will include, in the respective database, a legend that reads,"Request in process," with a status comment within a term notexceeding two (2) business days from its receipt in a complete form. Saidstatus will remain until the request is reviewed and a decision is reached.

QUERIES

All queries will be answered within a maximumterm of ten (10) business days, beginning from the day following the date of receipt. When it is not possible to handle the query within saidterm, the interested party will be informed, stating the reasons for the delay,and indicating the date on which his query will be handled, whichin no case may exceedfive (5) business daysfollowing the expiration of the first 10-day term.

CLAIMS

The holders or their successors in title, whoconsider that the information contained in a database of PERFILESY SOLUCIONES TECNOLÓGICAS S.A.S., must be subject to correction,update or deletion, or that warn of the allegedbreach of any of the duties containedin Law 1581 of 2012, maysubmit a request or claim before PERFILESY SOLUCIONES TECNOLÓGICAS S.A.S., in accordance with the mechanisms provided in this Data Processing Policy.

The maximum term period to address the claimwill be fifteen (15) business days from the day following the date of receipt.When it is not possible to address the claim within said term, the interestedparty will be informed of the reasons for the delay, and the date on which hisclaim will be addressed, which in no case may exceed eight (8) business daysfollowing the expiration of the first 15-day period.

DELETION OF DATA / REVOCATION OF AUTHORIZATION 

As long as the Superintendence of Industry& Commerce (Superintendencia de Industria y Comercio) has determined that in the treatment of personal information, the Company has engaged in conduct contrary to thisPolicy, the law and/or the Political Constitution; the owner of said personaldata, will have the right to request of PERFILES Y SOLUCIONES TECNOLÓGICAS S.A.S., to delete their personal data, orto revoke the authorization for its management and purpose; withoutoverlooking that the right of deletion or revocation is not an absolute right,and that the Company, as the entityresponsible for the processing of personal data, may deny or limit itsexercise when:

  • The owner of the data has thelegal or contractual duty to remainin the respective database; 
  • The elimination of data hinderson pending judicialor administrative actionsrelated to tax obligations, the investigation and prosecution of crimesor the updating of administrative sanctions;\
  • The data is necessary to protect the legallyprotected interests of the owner of information; to carry out an action basedon the public interest, or to comply with an obligation legally acquired by theowner.

Notwithstanding the foregoing, it will be guaranteedthat the data is used exclusively for the purpose requested, and theinformation is given the corresponding reservations.

VALIDITY AND MODIFICATIONS

This Policy is effective from its issuance.This Policy may be modified at any time, and its modifications will be made in accordance with current regulations. The Company will informthe holders of the information that a modification will be made to this Policy,in the event that said modification implies substantial changes, publishing theprojected modification text on the following web page: https://www.leangroup.com/solutions/leanstaffing for a term of ten (10) business days, prior tostarting the application process.

 

Date of Issuance: 11/30/2021