This Privacy Policy aims to provide the necessary and sufficient information to the different stakeholder groups of QBO CONSTRUCTORES S.A.S. regarding the Processing of Personal Data and, in general, to all individuals whose Personal Data the Company collects and processes (hereinafter the “Data Subject(s)”). Likewise, it seeks to establish the guidelines that ensure the protection of Personal Data subject to Processing and the rights of Data Subjects, setting the criteria for the collection, storage, use, circulation, and deletion of the personal information collected.
RESPONSIBLE PARTY INFORMATION bdqbo@qbo.co
This Policy regulates and establishes the general guidelines and principles for the protection and Processing of Personal Data within QBO CONSTRUCTORES, thereby strengthening the level of trust between the Data Controller and Data Subjects with respect to the collection, recording, management, transfer, exchange, and Processing of personal data carried out by QBO in the ordinary course of its business activities.
This Personal Data Processing and Protection Policy shall apply to all databases and/or files that include Personal Data subject to Processing by QBO CONSTRUCTORES as the Data Controller, and its scope covers:
2.1 The manner in which the respective Data Subjects authorize or prohibit QBO CONSTRUCTORES from using, managing, transferring, exchanging, and processing their personal information and data.
2.2 The personal information and data that QBO CONSTRUCTORES collects, captures, stores, uses, discloses, circulates, compiles, manages, processes, transmits, and exchanges through its website, email accounts, physical and digital correspondence and files, contact points, and databases in general.
2.3 The rights of Data Subjects with respect to the use, management, and processing of their personal information and data by QBO CONSTRUCTORES.
2.4 The purposes for which QBO CONSTRUCTORES collects, captures, stores, uses, discloses, circulates, compiles, manages, processes, transmits, and exchanges the personal information and data of individuals who consent to authorize the management and processing of such data.
2.5 The ways in which QBO CONSTRUCTORES will use, manage, and process the personal information and data for which the respective Data Subjects have granted such authorization.
2.6 The security measures adopted by QBO CONSTRUCTORES to generally protect the personal information and data of Data Subjects.
2.7 The channels, means, mechanisms, systems, and methods through which Data Subjects may exercise and enforce their rights as holders of personal information and data used, managed, and processed by QBO CONSTRUCTORES.
As a Data Subject whose personal information and data may be used, managed, and processed by QBO CONSTRUCTORES, YOU must read this Privacy and Personal Data Processing Policy carefully and attentively. It is also recommended that you read QBO CONSTRUCTORES’ Personal Data Management and Processing Manual, all of which are available at the link /privacy-policy/ on the website https://www.qbo.co/, where YOU may access and learn all the specific rules governing QBO CONSTRUCTORES’ activities related to the use, management, and processing of personal information and data.
Additionally, as a Data Subject whose personal information and data may be used, managed, and processed by QBO CONSTRUCTORES, you are advised to read and familiarize yourself with the legal regulations governing habeas data and personal data protection, including, but not limited to: Article 15 of the Political Constitution, Law 1266 of 2008, Law 1581 of 2012, Regulatory Decrees 1727 of 2009 and 2952 of 2010, and Partial Regulatory Decree No. 1377 of 2013.
Given that QBO CONSTRUCTORES’ privacy and personal data processing policies contained in this document are periodically updated, YOU must always check the update date located at the beginning of this document to verify that you are reading the latest version. If YOU have authorized the use, management, and processing of your personal information and data, upon your request, we will send you by email all modified versions of this Privacy and Personal Data Processing Policy so that YOU may determine, based on changes to the policy, whether to maintain or revoke the authorization granted to QBO CONSTRUCTORES to collect, capture, store, use, disclose, circulate, compile, manage, and process your personal information and data. When YOU authorize these activities, you will also authorize the sending of updates to the respective QBO CONSTRUCTORES Privacy and Personal Data Processing Policy to your email address.
When YOU provide, send, communicate, or make available your personal information and data to QBO CONSTRUCTORES through our contact points, website, email accounts, or other means of correspondence, we will have sent you via email or displayed this document to you through any available means, including our website. This shall mean that YOU agree to, accept, consent to, and expressly, unambiguously, and in advance authorize QBO CONSTRUCTORES to use, manage, and process the personal information and data of which YOU are the owner and which are sent, collected, and/or captured by QBO CONSTRUCTORES, since YOU expressly and unambiguously acknowledge that you have read, understood, and accepted the terms set forth herein and the terms of this Privacy Policy, and consequently grant and consent to the aforementioned authorizations for the use, management, and processing of your personal information and data by QBO CONSTRUCTORES under the present terms. If YOU do not agree, you have the option of not providing any personal information and, in general, of refraining from submitting personal information and data to our email accounts, website, and other contact points. YOU also have the right to expressly and unambiguously inform us that you do not grant QBO CONSTRUCTORES your authorization and consent for the use, management, and processing of your personal information and data. The authorization YOU grant us also includes authorization for the aforementioned personal information and data to be used, managed, and processed, under the terms of this Privacy Policy, by any natural or legal persons that QBO CONSTRUCTORES may designate as responsible for such use, management, and processing, and/or in general by persons to whom QBO CONSTRUCTORES grants access to said personal information and data, including document management and storage companies.
Notwithstanding the above, we may ask YOU to ratify these authorizations at specific sections of our contact points, website, and email accounts where YOU include or provide your personal information and data, and/or at the time of doing so. Additionally, we may request, through a prior, express, and written request via your email address, a specific and concrete authorization to use, manage, and process your personal information and data beyond the parameters and limits initially authorized and agreed upon, and for which YOU have not previously given your express prior consent.
Your authorization as the Data Subject will not be required in the cases specifically set forth by law, including:
“Personal Information” or “Personal Data” means all information that can be used to identify an individual and includes, among others, the following:
YOU authorize QBO CONSTRUCTORES to use, manage, and process your personal information and data provided and communicated through our contact points, email accounts, physical correspondence, and other means established by QBO CONSTRUCTORES for this purpose, which may include the personal information and data listed above.
QBO CONSTRUCTORES may also collect and capture, with your authorization as described above, aggregated or related information and data that is not of a personal nature because it cannot be used to identify and associate a specific individual.
The authorizations YOU grant as Data Subject, as referenced herein, include the possibility of transferring your personal data and information abroad, with the understanding that the foreign countries in which such personal data is used, managed, and processed may have regulations that do not provide the same level of protection and rights afforded under Colombian law.
QBO CONSTRUCTORES, or any party designated by QBO CONSTRUCTORES to collect or process your personal information and data, will not collect, manage, or process data considered sensitive, defined as data that affects the privacy of the Data Subject or whose improper use may lead to discrimination, such as racial or ethnic origin, political, religious, or philosophical orientation, among others. The only sensitive personal data that QBO CONSTRUCTORES will use and process are:
QBO CONSTRUCTORES does not collect personal information from children under the age of 13 and does not use such information if it is discovered to have been provided. To respect children’s privacy and comply with applicable legal standards, children under the age of 13 must not provide any personal information to QBO CONSTRUCTORES. We ask parents of such minors to supervise their children while online.
As a Data Subject, YOU have the right to:
Your requests for information, claims, complaints, rectification, modification, deletion, or updates will be processed free of charge and promptly by QBO CONSTRUCTORES and must contain at minimum the following:
QBO CONSTRUCTORES may use the personal information and data provided by YOU and for which authorization has been granted, in the following ways:
QBO CONSTRUCTORES will make its best efforts to maintain the physical, technical, and administrative security of its offices and information systems in order to prevent the loss, misuse, unauthorized access, disclosure, or modification of all personal information and data collected, used, managed, and processed by QBO CONSTRUCTORES, and for which YOU have granted the respective authorization.
While we strive to protect your personal information and data from the moment we receive it, it is not possible to guarantee this as an obligation of result, but rather of means, as the use, management, and transmission of data can never be guaranteed to be 100% secure.
The channels, means, mechanisms, systems, and methods through which users may exercise and enforce their rights as Data Subjects of personal information and data used, managed, and processed by QBO CONSTRUCTORES are as follows:
The contact information for QBO CONSTRUCTORES for all matters related to the use, management, and processing of personal information and data is:
Email: bdqbo@qbo.co
Through these contact points, the Data Subject of personal information and data used, managed, and processed by QBO CONSTRUCTORES may find, contact, and communicate with the designated administrative department and staff of QBO CONSTRUCTORES specifically assigned to handle matters related to the management and processing of personal information and data.
Through these contact points, and under the terms set forth in this document, YOU may submit to QBO CONSTRUCTORES all your requests for information, claims, complaints, rectification, modification, deletion, or updates relating to your personal information and data that are subject to use, management, and processing by QBO CONSTRUCTORES pursuant to your prior, express, and informed authorization.
YOU hereby state the following: “I consent to and authorize, in a prior, express, informed, and unambiguous manner, that my personal information and data delivered, communicated, and/or sent by me to QBO CONSTRUCTORES via physical mail, email, or other means of contact and communication, be collected, captured, stored, used, disclosed, compiled, circulated, exchanged, managed, and processed by QBO CONSTRUCTORES or persons designated by QBO CONSTRUCTORES, in accordance with the provisions of this document and/or authorization. I declare that I have read, understood, and approved this Personal Data Privacy and Processing Policy of QBO CONSTRUCTORES, the Internal Personal Data Management and Processing Manual, and the Privacy Notice of QBO CONSTRUCTORES, which have been sent to me via email and are available at the link /privacy-policy/ on the website https://www.qbo.co/.”
QBO CONSTRUCTORES reserves the right to modify this Personal Data Processing and Protection Policy at any time. However, any modification will be communicated in a timely manner to Data Subjects through the usual means of contact, with ten (10) business days’ notice prior to its entry into force.
In the event that a Data Subject disagrees with the new general or specific policy and has valid reasons constituting just cause to discontinue the authorization for Personal Data Processing, the Data Subject may request that the company remove their information through the channels indicated in Title V of this document. However, Data Subjects may not request the removal of their Personal Data when the company has a legal or contractual obligation to process such data.
CAMILO AVILA CARDENAS
QBO CONSTRUCTORES S.A.S.