GET TO KNOW MORE

Our Data Processing Policy

Statutory Law 1581 – Protection of Personal Data:

Through External Circular No. 02 of November 3, 2015, the Superintendency of Industry and Commerce issued instructions to those responsible for the processing of personal data, private legal entities registered in the Chambers of Commerce and mixed economy companies, for the purposes of registering their databases in the National Database Registry – RNBD as of November 9, 2015.

The National Government, through Chapter 26 of Sole Decree 1074 of 2015, regulated the minimum information that the RNBD must contain and the terms and conditions under which the databases subject to the application of Law 1581 of 2012 must be registered in it. The Superintendency of Industry and Commerce, through Chapter 26 of Sole Decree 1074 of 2015, regulated the minimum information that the RNBD must contain and the terms and conditions under which the databases subject to the application of Law 1581 of 2012 must be registered in it. The Superintendency of Industry and Commerce, through Chapter 26 of Sole Decree 1074 of 2015, regulated the minimum information that the RNBD must contain and the terms and conditions under which the databases subject to the application of Law 1581 of 2012 must be registered in it. External Circular No. 02 of November 3, 2015 issued instructions to those responsible for the processing of personal data, private legal entities registered in the Chambers of Commerce and mixed-economy companies, for the purposes of registering their databases in the RNBD

In 2016, the registration in the RNBD of the databases of natural persons, public entities, other than mixed-economy companies, and private legal entities that are not registered in the Chambers of Commerce will be enabled, following the publication of the instructions that this Superintendency will issue for this purpose.

Política de Tratamiento de los Datos Personales

    1. Generalities

EQUM, identified with NIT 900.033.170-0, located at Carrera 7 No. 114-33, Scotiabank Building, Office 404, Bogotá, telephone 2542000, email info@equm.com.co, by virtue of its status as the controller of personal data obtained within the framework of its corporate purpose as a private legal entity, whose purpose is to offer professional services of financial tax consulting, transfer pricing, tax legal consulting and tax litigation; and in order to guarantee the protection of the rights of data holders, communicates the personal data processing policy.

    1. Constitutional and legal framework

Political Constitution, article 15, which establishes the right to a good name, habeas data, personal and family privacy, as well as the right to request, regarding personal data, its updating and rectification. • Law 1266 of 2008. • Law 1581 of 2012. • Decree 1727 of 2009. • Decree 2952 of 2010. • Decree 1377 of 2013. The processing of clients’ personal information will be carried out in accordance with the principles established and defined in the aforementioned regulations. The definitions of the concepts: authorization, databases, personal data, data processor, data controller, information owner, information source, information operator, processing, user, public data, semi-private data, private data, transmission, transfer, sensitive data, will be understood in accordance with the provisions of the regulations that regulate the matter.

    1. Processing

The Company’s collection, use, circulation and deletion of personal data and the processing thereof are for the following purposes:

      1. Providing the contracted professional services
      2. Promoting the professional services offered by the Company
      3. Holding and disseminating talks, forums and academic events developed by the Company
      4. Disseminating commercial agreements with third parties
      5. Authorization of data transfer to allied third parties
      6. Periodic updating of data by the Company
      7. Periodic sending of communications to the registered email address, related to the development of the corporate purpose and professional services offered by the Company.

When providing data to the Company, clients will expressly authorize the transfer of contact data to third parties.

    1. Rights of the owner

The owner of the data may use his legal powers in the Company’s databases subject to processing to:

      1. Know at any time the information stored about him/her;
      2. Request the rectification and updating of his/her data;
      3. Revoke the authorization for processing;
      4. To exercise before the competent authorities the actions derived from the non-compliance of the treatment policy described here;
      5. The others that are granted by the Constitution and the law.
    2. Area responsible for guaranteeing the rights of the owner

The area responsible for guaranteeing the rights of the owner of the data that are in the databases under the Company’s charge is the Administrative area. In the event that the owner considers that there has been an inappropriate use, the purposes described above have been breached or the legal mandates or their fundamental rights have been ignored, the procedure to be followed is the following:

      1. The owner of the data or his representative must submit a written communication stating his status, informing his interest and clearly expressing the grounds for his request.
      2. The request must be filed with the Company or sent to the email info@equm.com.co.
      3. The Company will proceed to respond within a maximum period of ten (10) business days.

It will indicate the measures adopted in order to safeguard the rights of the owner. The policy for processing the databases whose manager is the Company comes into effect as of the eighth (8) day of March of the year two thousand seventeen (2017).

EQUM Legal and Tax Consulting S.A.S.

Bogotá – Colombia