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Information Processing Policy

HOTEL OBELISCO guarantees the protection of rights such as Habeas Data, privacy, privacy, good name and image, for this purpose

GENERAL AND POSTULATED PRINCIPLES
This policy applies to all holders of personal information that is used and / or is in the databases of the company BASILIO KLONIS Y CIA S.A. hereinafter HOTEL OBELISCO and its subsidiaries and branches, who acts as responsible for the processing of personal data.

HOTEL OBELISCO guarantees the protection of rights such as Habeas Data, privacy, privacy, good name and image, for this purpose all actions will be governed by principles of good faith, legality, computer self-determination, freedom and transparency.

LEGAL FOUNDATION
Article 15 of the Political Constitution of Colombia establishes that any person has the right to know, update and rectify the personal data that exists about them in a database or files of public or private entities. Likewise, it orders those who have personal data of third parties to respect the rights and guarantee provided for in the Constitution when this kind of information is collected, processed and circulated.

Statutory Law 1581 of October 17, 2012 establishes the minimum conditions for the legitimate processing of personal data of customers, employees and any other natural person. Subparagraph (k) of article 17 of said law obliges those responsible for the processing of personal data to “adopt an internal manual of policies and procedures to ensure adequate compliance with the law and especially for the attention of inquiries and complaints.”

Article 25 of the same law establishes that data processing policies oblige those responsible for them and that their ignorance will result in penalties. Additionally, it indicates that said policies cannot guarantee a level of treatment lower than that established in Law 1581 of 2012.

That Decree 1377 of 2013 defines the information that must contain at least the information processing policies.

HOTEL OBELISCO is committed to respecting and guaranteeing the rights of its customers, employees, suppliers and third parties in general. That is why it adopts the following manual of policies and procedures for the treatment of information, of obligatory application in all the activities that involve, totally or partially, the collection, storage, use, circulation and transfer of that information.

These policies are mandatory and strictly enforced for HOTEL OBELISCO, as responsible, as well as all third parties that act on behalf of the Company, or who, without acting on behalf of HOTEL OBELISCO, process personal data at their disposal as managers.

Both the person in charge and those in charge, understand, employees, contractors and third parties must observe and respect these policies in the fulfillment of their functions and / or activities even after the termination of legal, commercial, labor or any other type of links. Similarly, they undertake to maintain strict confidentiality in relation to the data processed.

Any breach of the obligations and, in general, of the policies contained in this document should be reported to: [email protected]

1. INFORMATION OF HOTEL OBELISCO

The company responsible for the processing of personal data:

Corporate name: BASILIO KLONIS Y CIA S.A.
Address: Avenida Colombia No. 4 Oeste-49
Nit. 800128709-6
Correspondence address: Avenida Colombia No. 4 Oeste-49
Email: [email protected]
Telephone: +57 (2) 8933019
2. CONCEPTS

Authorization: Prior, express and informed consent of the Holder to carry out the Processing of personal data.
Database: Organized set of personal data that is the object of Treatment.
Personal data: Any information linked or that may be associated with one or more specific or determinable natural persons.
Person in charge of the Treatment: Natural or legal person, public or private, that by itself or in association with others, performs the Processing of personal data on behalf of the Person Responsible for the Treatment.
Responsible for the Treatment: Natural or legal person, public or private, that by itself or in association with others, decides on the basis of data and / or the Treatment of the data.
Owner: Natural person whose personal data is subject to Treatment.
Treatment: Any operation or set of operations on personal data, such as the collection, storage, use, circulation or deletion.
Queries: Request of the personal information of the Holder that rests in any database used by HOTEL OBELISCO on which it has the obligation to provide to the Holder or its successors, all the information contained in the individual registry or that is linked to the identification of the Headline.
Claims: Request for correction, update or deletion of the information contained in a database used by HOTEL OBELISCO, or request for alleged breach of any of the duties contained in Law 1581 of 2012, made by the Holder or its successors.
Public data: It is the data that is not private or sensitive. They are considered public data, among others, data relating to the marital status of people, their profession or trade and their status as merchant or public servant. By their nature, public data may be contained, among others, in public records, public documents, official gazettes and newsletters and duly enforced judicial sentences that are not subject to reservation.

3. PRINCIPLES

The following principles will be taken into account by HOTEL OBELISCO, in the process of personal data management:

Legality regarding data processing: The Treatment referred to in Law 1581 of 2012, is a regulated activity that must be subject to what is established in it and in the other provisions that develop it.
Purpose and Treatment: The Treatment must obey a legitimate purpose in accordance with the Constitution and the Law, which must be informed to the Holder.
The Treatment and purpose of the information of the Personal data collected by BASILIO KLONIS & CIA. S.A. – HOTEL OBELISCO DE CALI, have the following purposes:

a) Store and process in order to deliver, offer and / or sell products, services, solutions and any other data required for the provision of the contracted service.

b) Operation and registration activities that are required in commercial activities.

c) Conduct surveys, statistics, invitations and market research.

d) Receive publicity in print or through electronic means, telemarketing, use the different services of their corresponding Websites, send to the Holder the notification of offers, notices and / or promotional messages.

e) Transfer the data to third parties, affiliates or subsidiaries under the criteria required by law.

f) Billing, Collect portfolio and carry out administrative and judicial and judicial collection.

g) Respond to control agencies.

h) This personal data will be stored for ten years.

If a new need is required, it must be included in the privacy notice and incorporate an annex to this manual.

Freedom: The Treatment can only be exercised with the prior, express and informed consent of the Holder. Personal data may not be obtained or disclosed without prior authorization, or in the absence of a legal or judicial mandate that relieves consent.
Truthfulness or quality: The information subject to Treatment must be truthful, complete, accurate, updated, verifiable and understandable. Processing of partial, incomplete, fractional or error-inducing data is prohibited.
Transparency: In the Treatment, the right of the Holder to obtain from HOTEL OBELISCO, or the Treatment Manager, at any time and without restrictions, information about the existence of data concerning him must be guaranteed.
Access and restricted circulation: The Treatment is subject to the limits derived from the nature of personal data, the provisions of Law 1581 of 2012 and the Constitution. In this sense, the Treatment may only be done by persons authorized by the Holder and / or by the persons provided for in the Law.

Personal data, except public information, may not be available on the Internet or other means of dissemination or mass communication, unless access is technically controllable to provide restricted knowledge only to Holders or third parties authorized under the Law.

Security: The information subject to Treatment by the Person in Charge of the Treatment or Person in Charge of the Treatment, must be handled taking the technical, human and administrative measures that are reasonable to grant security to the records trying to avoid their adulteration, loss, consultation, use or access. Authorized or fraudulent.
Confidentiality: All persons involved in the Processing of personal data that do not have the nature of public are obliged to guarantee the reservation of the information, even after the end of their relationship with any of the tasks included in the Treatment, being able to only supply or communication of personal data when this corresponds to the development of the activities authorized in the Law and in the terms thereof.

4. TREATMENT TO WHICH THE DATA AND ITS PURPOSE WILL BE SUBMITTED.

The processing of personal data will be contained in the Privacy Policy and Use of personal information of each of the holders of the information for which HOTEL OBELISCO will be responsible, the treatment that will be applied to the information will be:

Personal data will be collected, stored, used and circulated only for as long as necessary and reasonable in accordance with the purposes for which authorization is requested.
Communications with commercial content will never expose the email information of all customers.
Our database will not be shared or used with third parties for commercial purposes.
5. RIGHTS OF THE HOLDERS.

In accordance with the provisions of article 8 of Law 1581 of 2012 and decree 1377 of 2013, the holder of personal data has the following rights vis-à-vis the company HOTEL OBELISCO

a) Know, update and rectify your personal data in front of HOTEL OBELISCO, as the person responsible for the processing;

b) Request proof of authorization granted to HOTEL OBELISCO in its capacity as Responsible for the Treatment;

c) Be informed by HOTEL OBELISCO upon request, regarding the use you have given to your personal data;

d) File complaints with the Superintendence of Industry and Commerce for violations of the provisions of Law 1581 of 2012, once the consultation or claim process has been exhausted before the Treatment Manager;

e) 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 Treatment; The revocation and / or deletion will proceed when the Superintendence of Industry and Commerce has determined that in the Treatment the Responsible or Responsible have incurred in conduct contrary to law 1581 of 2012 and the Constitution;

f) Access free of charge to your personal data that have been subject to Treatment.

6. ACCESS, CONSULTATION AND CLAIM PROCEDURES

Law 1581 of 2012 provides every person with personal data with a series of guarantees, of legal powers vis-à-vis the person responsible for personal data, which guarantees him the power of decision and control he has over the information that concerns him, such as Your right to the protection of it. In addition, they act as a complement to the duty of the person responsible for complying with the obligations imposed on it by the Law, allowing him to identify those cases in which the treatment may not be adjusted to them.

For the exercise of rights, who may act in accordance with the provisions of article 14 of Law 1581 of 2012 and decree 1377 of 2013 are the following persons: the holders, the successors, their representative or proxy or the persons who act in favor of another or for another.

When the request is made by a person other than the owner and it is not proven that it acts on behalf of the person, it will be deemed not submitted.

HOTEL OBELISCO has an administrative infrastructure destined, among other functions, to ensure due attention to requirements, requests, queries, complaints and claims related to data protection, in order to guarantee the exercise of the rights contained in the Constitution and the law , especially the right to know, update, rectify and delete personal information; as well as the right to revoke the consent granted for the processing of personal data.

CONSULTATIONS, CLAIMS, COMPLAINTS
For inquiries, complaints, complaints or for the exercise of the rights that assist you as the owner of information (Personal Data), you can contact “HOTEL OBELISCO. ([email protected])

Also, you can call the customer service line (572) 8933019 from Monday to Friday from 8:00 a.m. at 6:00 p.m .; Saturdays from 8 a.m.: at 12:00 m.

7. EXERCISE OF RIGHTS

7.1. Right of access
The power of disposition or decision that the owner has about the information that concerns him, necessarily implies the right to access and know if his personal information is being processed, as well as the scope, conditions and generalities of said treatment. In this way, HOTEL OBELISCO guarantees the holder his right of access in three ways:

a) The first implies that the holder can know the effective existence of the treatment to which their personal data are subjected.
b) The second, that the holder can have access to their personal data that is in the possession of the person in charge.
c) The third, supposes the right to know the essential circumstances of the treatment, which translates into the duty of HOTEL OBELISCO to inform the owner about the type of personal data processed and each and every one of the purposes that justify the treatment.

HOTEL OBELISCO guarantees the right of access when, prior accreditation of the identity of the owner or personality of its representative, the detail of personal data is made available free of charge through electronic means that allow direct access to the Holder to them.

7.2. Queries
HOTEL OBELISCO guarantees the right of consultation, providing to the people who act in exercise of this right, all the information contained in the individual registry or that is linked with the identification of the Holder.

For the attention of requests for consultation of personal data, HOTEL OBELISCO guarantees that there are electronic and telephone communication means.

In any case, regardless of the mechanism implemented for the attention of requests for consultation, they will be attended within a maximum term of ten (10) business days from the date of receipt. When it is not possible to attend the query within said term, the interested party will be informed before the expiration of the ten (10) business days, expressing the reasons for the delay and indicating the date on which his query will be attended, which in no case may exceed five (5) business days following the expiration of the first term.

7.3. Claims
HOTEL OBELISCO guarantees the right to claim, to the databases for correction, updating or deletion, or when they warn of the alleged breach of any of the duties contained in Law 1581 of 2012 and other applicable regulations. The claim will be processed under the following rules:

If the claim received does not have complete information that allows it to be processed, that is, with the identification of the Holder, the description of the facts that give rise to the claim, the address, and accompanying the documents that are to be enforced, it will be required to interested within five (5) business days after receipt to rectify the failures. After two (2) months from the date of the request without the applicant submitting the required information, it will be understood that the claim has been withdrawn.
If under any circumstances HOTEL OBELISCO receives a claim that should not actually be directed against it, it will transfer to the appropriate party within a maximum period of two (2) business days and inform the interested party of the situation.
Once the complete claim has been received, a legend that says “claim in process” and the reason for it will be included in the database maintained by HOTEL OBELISCO, within a term not exceeding two (2) business days. This legend must be maintained until the claim is decided.
The maximum term to handle the claim will be fifteen (15) business days from the day following the date of receipt. When it is not possible to attend it within said term, the interested party will be informed before the expiration of the aforementioned term, the reasons for the delay and the date on which his claim will be addressed, which in no case may exceed eight (8) business days following the expiration of the first term.

7.4 Implementation of procedures to guarantee the right to file claims.
The request for rectification, update or deletion must be submitted through the means enabled by HOTEL OBELISCO indicated in the privacy notice and in this document, and contain, at a minimum, the following information:

1) The name, address of the holder and means of contact to receive the answer such as telephone, email, residence address.
2) Documents proving the identity or representation of your representative.
3) The clear and precise description of the personal data in respect of which the holder seeks to exercise any of the rights.
4) If necessary, other elements or documents that facilitate the location of personal data.

Paragraph 1. Rectification and Update of Data. HOTEL OBELISCO has the obligation to rectify and update at the request of the owner, the information of the latter that is found to be incomplete or inaccurate, in accordance with the procedure and the terms indicated above. In this regard, the following shall be taken into account:

HOTEL OBELISCO has full freedom to enable mechanisms that facilitate the exercise of this right.

Paragraph 2. Data Suppression. The owner has the right, at all times, to request HOTEL OBELISCO to delete (delete) their personal data when:

Consider that they are not being treated in accordance with the principles, duties and obligations set forth in Law 1581 of 2012.
They are no longer necessary or relevant for the purpose for which they were collected.
The period necessary for the fulfillment of the purposes for which they were collected has been exceeded.
When I deem it convenient.
This deletion implies the total or partial elimination of personal information as requested by the owner in the records, files, databases or treatments carried out by HOTEL OBELISCO It is important to take into account that the right of cancellation is not absolute and the The person responsible may deny the exercise thereof when:

The request for deletion of the information will not proceed when the holder has a legal or contractual duty to remain in the database.
The elimination of data hinders judicial or administrative actions related to tax obligations, the investigation and prosecution of crimes or the update of administrative sanctions.
The data is necessary to protect the legally protected interests of the holder; to perform an action based on the public interest, or to fulfill an obligation legally acquired by the holder.
In case of cancellation of personal data, HOTEL OBELISCO must operate the deletion in such a way that the deletion does not allow the recovery of the information.

7.5. Revocation of Authorization
The holders of personal data may revoke the consent to the processing of their personal data at any time, as long as a legal provision does not prevent it.

There will be two (2) modalities in which the revocation of consent can occur. The first, on the totality of the consented purposes, that is, that HOTEL OBELISCO must stop treating the owner’s data completely; the second, may on certain types of treatment, such as for market research.

Therefore, it will be necessary for the holder at the time of submitting the request for revocation of consent to HOTEL OBELISCO indicate in it if the revocation he intends to perform is total or partial. In the partial revocation must indicate with which treatment the holder is not satisfied.

There will be cases in which the consent, due to its necessary nature in the relationship between the holder and the person responsible for the fulfillment of a contract, cannot be revoked by legal provision.

7.6. Complaint procedure before the Superintendence of Industry and Commerce:
The Holder or Candidate may only file a complaint with the Superintendence of Industry and Commerce once the consultation or claim process has been exhausted before HOTEL OBELISCO, in accordance with the aforementioned procedure.

8. DUTIES OF OBELISCO HOTEL

Duties of HOTEL OBELISCO when it works as Responsible for the processing of personal data.

All those obliged to comply with this policy must keep in mind that it is the responsibility of HOTEL OBELISCO to fulfill the duties that the law imposes in this regard. Therefore, they must act in such a way that they fulfill the following obligations:

8.1. Duties of HOTEL OBELISCO regarding the data holder
Request and keep, under the conditions provided in this policy, a copy of the respective authorization granted by the holder.
Clearly and sufficiently inform the holder about the purpose of the collection and the rights that assist him by virtue of the authorization granted.
Guarantee the holder, at all times, the full and effective exercise of the right to habeas data, that is, to know, update or rectify his personal data.
Inform at the request of the owner about the use given to their personal data.
To process the queries and claims made in the terms indicated in this policy.
8.2. Duties of HOTEL OBELISCO regarding the quality, security and confidentiality of personal data
Observe the principles of truthfulness, quality, security and confidentiality in the terms established in Colombian legislation.
Keep the information under the necessary security conditions to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access.
Update information when necessary.
Rectify personal data when appropriate.

8.3. Duties of HOTEL OBELISCO when performing the treatment through a Manager
Provide the person in charge of the processing only the personal data that he is authorized to supply to third parties.
Ensure that the information provided to the person in charge of the treatment is truthful, complete, accurate, updated, verifiable and understandable.
Communicate in a timely manner to the person in charge of the treatment all the news regarding the data that he has previously provided and take the other necessary measures so that the information provided to him is kept updated.
Inform in a timely manner to the person in charge of the treatment the rectifications made on the personal data so that he / she makes the pertinent adjustments
Require the person in charge of the treatment, at all times, to respect the security and privacy conditions of the owner’s information.
Inform the person in charge of the treatment when certain information is under discussion by the owner, once the claim has been submitted and the respective procedure has not been completed.

8.4. Duties of HOTEL OBELISCO regarding the Superintendence of Industry and Commerce
Inform you of possible violations of security codes and the existence of risks in the administration of the information of the owners.
Comply with the instructions and requirements issued by the Superintendence of Industry and Commerce.
8.5. Duties of HOTEL OBELISCO when it works as Person in charge of the processing of personal data.

If HOTEL OBELISCO carries out the data processing on behalf of another entity or organization (Responsible for the treatment), it must fulfill the following duties:

Establish that the person responsible for the treatment is authorized to supply HOTEL OBELISCO with the personal data that will be treated as Manager.
Guarantee the holder, at all times, the full and effective exercise of the right of habeas data.
Keep the information under the necessary security conditions to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access.
Timely update, rectify or delete the data.
Update the information reported by those responsible for the treatment within five (5) business days from the date of receipt.
To process the consultations and claims made by the owners in the terms indicated in this policy.
Register in the database the legend “claim in process” in the manner established in this policy.
Insert in the database the legend “information in judicial discussion” once notified by the competent authority about legal proceedings related to the quality of personal data.
Refrain from circulating information that is being controversial by the holder and whose blockade has been ordered by the Superintendence of Industry and Commerce.
Allow access to information only to persons authorized by the owner or authorized by law for that purpose.
Inform the Superintendence of Industry and Commerce when there are violations of security codes and there are risks in the administration of the information of the owners.
Comply with the instructions and requirements issued by the Superintendence of Industry and Commerce.

9. SPECIAL REQUIREMENTS FOR THE PROCESSING OF PERSONAL DATA OF CHILDREN, GIRLS AND TEENAGERS

The processing of personal data of children and adolescents is prohibited, except in the case of data of a public nature, in accordance with the provisions of article 7 of Law 1581 of 2012 and when said Treatment complies with the following parameters and requirements :

That responds and respects the best interests of children and adolescents.
That respect for their fundamental rights be ensured.
Once the above requirements have been met, the legal representative of the child or adolescent will grant prior authorization to exercise the child’s right to be heard, an opinion that will be assessed taking into account the maturity, autonomy and ability to understand the matter.
All Responsible and Responsible involved in the processing of personal data of children and adolescents, must ensure the proper use of them. For this purpose, the principles and obligations established in Law 1581 of 2012 and the decrees that modify it must be applied.
The family and society must ensure that the Responsible and Responsible for the Processing of personal data of minors comply with the obligations established in Law 1581 of 2012 and the decrees that modify it.

10. INTERNATIONAL TRANSFER OF PERSONAL DATA

When sending or transferring data to another country, it will be necessary to have the authorization of the owner of the information that is being transferred. Unless the law says otherwise, the existence of such authorization to carry out the international circulation of data is a necessary budget. In this sense, before sending personal data to another country, those obliged to comply with this policy must verify that there is prior, express and unequivocal authorization of the holder that allows them to transmit their personal data.

This transfer of personal data is made only to third parties with whom HOTEL OBELISCO has a contractual, commercial and / or legal link.

11. PRIVACY NOTICE

HOTEL OBELISCO, hereinafter and to whom the rights are assigned, informs you that the privacy notice for the processing of your personal data can be consulted on the website www.hotelobeliscocali.com
12. MODIFICATION AND / OR UPDATE OF THE INFORMATION PROTECTION POLICY

Any substantial change in the Treatment policies will be communicated in a timely manner to the owners of the data through the usual means of contact and / or through:

HOTEL OBELISCO Website www.hotelobeliscocali.com

Email sent to the headlines, for the headlines that do not have access to electronic media, the communication will be made by certified mail and otherwise will be published in a newspaper of wide circulation.
Communications will be sent at least ten (10) days before implementing the new policies and / or substantial updating of the same.

13. VALIDITY OF PERSONAL INFORMATION PROCESSING POLICIES

These policies apply as of November 30, 2018.

As a general rule, the term of authorizations on the use of personal data by the owners is understood as the term of the business relationship or the link to the service and during the exercise of the company’s corporate purpose.

The authorizations on the data of the holders may terminate at their will at any time. If the person is an active client of HOTEL OBELISCO, their data may not be used for anything other than the provision of the product or service and for the offer of subsequent renewals when the service has this modality.

When the terms of the privacy policies and use of personal information of any of the services or products contracted by a holder, change in essence, as a rule, in the services that have the option of renewal, the new authorization will be obtained in this . For all other cases, authorization will be obtained in the manner established for each privacy policy or notice or through the usual means of contact between the company and the owners.