Personal Data Processing Policy of Conservas Delcasino S.A.S.

Through this document, CONSERVAS DELCASINO S.A.S. establishes the Data Protection Manual - DPM, according to the development of its corporate purpose, the services provided and the users of the same.

This document is linked to the general terms and conditions of operation of the CONSERVAS DELCASINO S.A.S. platform, and therefore forms an integral part of the operating policies of the same.

For all legal purposes, the party responsible for the provision of the service CONSERVAS DELCASINO S.A.S., a commercial company domiciled in the city of Bogotá D.C. in the Republic of Colombia, identified with NIT No. 830053180- 6 hereinafter THE COMPANY, is the owner of the property rights derived from the development, production, distribution and marketing of all kinds of food products, raw materials, containers and packaging for the same and other related or complementary acts with the same corporate purpose and is who through its team is responsible for providing each of the services offered through it. In case of any inconvenience, doubt or suggestion with the use of the CONSERVAS DELCASINO S.A.S. platform or this Data Protection Manual, you can send an email with the request and contact details to the email address [email protected]

1. SCOPE:

This personal data processing policy of CONSERVAS DELCASINO S.A.S., hereinafter "THE COMPANY", shall be applicable to all databases and/or files containing personal data that are processed by THE COMPANY.

2. REGULATORY FRAMEWORK:

  • Political Constitution of Colombia, Article 15.
  • Law 1581 of 2012, which issued the General Regime for the Protection of Personal Data.
  • Decrees regulating Law 1581 of 2012.
  • Circulars and other provisions of the Superintendency of Industry and Commerce.
  • Constitutional Court Ruling C-748 of 2011 by which the Draft Statutory Law on Personal Data Protection was declared constitutional. Judge Jorge Ignacio Pretelt Chaljub, (06 October 2011).
  • Constitutional Court. Judgment T-020 of 2014. Judge Luis Guillermo Guerrero Pérez. (27 January 2014).
  • Constitutional Court. Judgment T-238 of 2018. Judge Gloria Stella Ortiz Delgado (26 June 2018).
  • Constitutional Court. Sentence C-094 of 2020. Judge Alejandro Linares Cantillo (03 March 2020).

3. POLICY DEVELOPMENT:

CONSERVAS DELCASINO S.A.S. integrates in all its actions the respect for the protection of personal data, which is why it will request, from the moment the data is entered, authorisation for the use of the information it receives.

CONSERVAS DELCASINO S.A.S. ensures compliance with the principles established in the Law and will attend in their actions and handling of personal data information the purposes arising therefrom. CONSERVAS DELCASINO S.A.S. will implement the strategies and actions necessary to give effect to the right enshrined in the Statutory Law 1581 of 2012 and other regulations that complement, modify or repeal it. CONSERVAS DELCASINO S.A.S. will inform all its users about the rights arising from the protection of personal data.

4. TARGET AUDIENCE:

This regulation shall apply to and thereby bind the following persons:

  • Legal representative.
  • Managers, internal personnel of CONSERVAS DELCASINO S.A.S., who have custody of and deal with databases.
  • Suppliers and natural or legal persons who provide their services to CONSERVAS DELCASINO S.A., under any type of contractual modality, by virtue of which any processing of personal data is carried out.
  • Clients who make use of the services offered by THE COMPANY and the processing of these will be handled by the SIIGO system.
  • Other persons with whom there is a legal relationship of a statutory or contractual nature, among others.
  • Public and private persons in their capacity as users and data subjects.
  • Such other persons as may be provided for by law.

5. DEFINITIONS

  • PRIVACY NOTICE: Verbal or written communication generated by THE COMPANY, addressed to the holder for the processing of his/her personal data, by means of which he/she is informed of the existence of the information processing policies that will be applicable to him/her, how to access them and the purposes of the processing that is intended to be given to the personal data.
  • AUTHORISATION: Prior, express and informed consent of the holder to carry out the processing of personal data.
  • DATA BASE: Organised set of personal data that is the subject of processing.
  • AUTOMATED DATABASE: The organised set of personal data that are created, processed and/or stored by means of computer programmes or software.
  • NON-AUTOMATED DATABASE: An organised set of personal data that is created, processed and/or stored manually, in the absence of computer programmes or software.
  • TRANSFER OF DATA: Processing of data that involves its disclosure to a person other than the data subject or other than the person who is entitled to be the transferee.
  • CUSTODIAN OF THE DATABASE: The natural person who has custody of the personal database within THE COMPANY.
  • PERSONAL DATA: Any information linked or capable of being linked to one or more specific or identifiable natural persons.
  • PRIVATE PERSONAL DATA: This is a category of personal data that is only relevant to its owner, which could include photographs, videos, data related to their lifestyle, among others.
  • SEMI-PRIVATE PERSONAL DATA: This is a category of personal data that is not of an intimate, reserved or public nature and whose knowledge is of interest to the holder and to a certain sector or group of persons or to society in general, among which could be financial and credit data, address, telephone, e-mail, among others.
  • PUBLIC PERSONAL DATA: This is a category of personal data that, qualified as such in the Law, is not semi-private, private or sensitive, among which could be found data relating to the marital status of individuals, their profession or trade, their status as a trader or public servant and those that can be obtained without any reservation, among others.
  • PERSON IN CHARGE OF PROCESSING: Natural or legal person, public or private, who by himself or in association with others, carries out the processing of personal data on behalf of the controller.
  • PERSON RESPONSIBLE FOR THE PROCESSING: Natural or legal person, public or private, who by himself or in association with others, decides on the database and/or the processing of the data.
  • HABEAS DATA: The fundamental right of every person to know, update, rectify and/or cancel the information and personal data that has been collected and/or processed in the COMPANY's databases, in accordance with the provisions of the Law and other applicable regulations.
  • OWNER: Natural person whose personal data is the subject of processing.
  • PROCESSING: Any operation or set of operations on personal data, such as collection, storage, use, circulation or deletion.
  • SENSITIVE DATA: Information that affects the privacy of the holder or whose improper use may lead to discrimination, such as those that reveal racial or ethnic origin, political orientation, religious or philosophical convictions, membership of trade unions, social organisations, human rights organisations or that promote the interests of any political party or that guarantee the rights and guarantees of opposition political parties; as well as data relating to health, sex life and biometric data, among others, still or moving image capture, fingerprints, photographs, iris, voice, facial or palm print recognition, etc.
  • TRANSFER OF DATA: The communication of data for processing by a processor under a contract or on behalf of the controller.
  • TRANSFER OF DATA: This is the sending of personal information by the data controller to a recipient, who, on receiving the information, will also be the data controller, assuming his or her obligations regarding the information.
  • CONTENTS. It involves all forms of information or data that are disclosed on the website, including: texts, images, photos, logos, designs, animations.

6. TREATMENT AND PURPOSE TO WHICH THE DATA PROVIDED BY THE OWNER WILL BE SUBMITTED:

CONSERVAS DELCASINO S.A.S. will only collect from its users the data that is necessary, relevant and not excessive for the established purpose.

The personal data of the owners of CONSERVAS DELCASINO S.A.S. will be processed for the following purposes:

  • Invitations to events;
  • Offer new products or services;
  • Manage the processing of requests, complaints or claims;
  • To carry out activities related to its corporate purpose.

In addition to the above general purposes, the following purposes shall be pursued with each respective information base:

INFORMATION ON SUPPLIERS:

  • For creation in the accounting system;
  • Know the type of company name for tax purposes and magnetic media;
  • Registration of bank accounts for transfer payments;
  • To know the physical location of the company for inspection visits by the quality area;
  • To know the soundness of the company with its financial statements;
  • Clarify on the form the credit term granted by the supplier;
  • Sending purchase orders to registered e-mail addresses;
  • Notifications by CONSERVAS DELCASINO S.A.S. to the supplier concerning closures and opening hours among others;
  • Invitations to events and offering new products or services;
  • Manage the processing of requests, complaints and claims.

CUSTOMER INFORMATION:

  • Implement marketing strategies;
  • Create the client in the accounting system for tax and magnetic media reporting purposes and everything related to the DIAN;
  • Important notices that arise during the business relationship such as opening hours, collective holiday closures, minimum order times and others;
  • Approval of appropriations;
  • Commercial, customer service and portfolio management purposes;
  • Invitations to events and offering new products or services;
  • Manage the processing of requests, complaints and claims.

INFORMATION ON EMPLOYEES:

  • Custody of CVs and supports.
  • Necessary official communications with employees;
  • Recognition or social and/or work activities established by THE COMPANY;
  • Evidentiary purposes in disciplinary and/or judicial proceedings;
  • Production of Carnet.
  • Photographs and videos of the company's activities.

7. PRINCIPLES:

  • LEGALITY: The processing of personal data will be carried out in accordance with the applicable legal provisions.
  • PURPOSE AND UTILITY: The processing of personal data must obey a legitimate purpose and must be subject to the provisions of the Political Constitution and the Law. The owner will be informed in a clear, comprehensive, sufficient and prior manner about the information that is provided.
  • NECESSITY: This refers to the fact that the processing of this data fulfils the purpose for which it is handled.
  • FREEDOM: Personal data may only be processed with the prior, express and informed consent of the data subject. Personal data will not be obtained or disclosed without prior authorisation or in the absence of a legal or judicial mandate exempting consent.
  • TRUTH OR QUALITY: The information subject to the processing of personal data shall be truthful, complete, accurate, up-to-date, verifiable and comprehensible.
  • TRANSPARENCY: THE COMPANY guarantees the holders of personal data the right of access and knowledge of the information of a personal nature that is being processed in accordance with the provisions of the Law.
  • ACCESS AND CIRCULATION: In accordance with the provisions enshrined in the law, the data processed by THE COMPANY will have restricted access and circulation in accordance with the nature of the data and with the authorisations given by the Data Subject.
  • RESTRICTED CIRCULATION: This means that the flow of information must be directly related to the purpose, while restricting mass access to information, with the exception of data of a public nature.
  • SECURITY: Personal data subject to processing will be handled by adopting all security measures necessary for their preservation and proper use.
  • CONFIDENTIALITY: All employees working at THE COMPANY are obliged to keep confidential all personal information to which they have access in the course of their work at THE COMPANY.

8. RIGHTS OF THE HOLDER

The owners of the personal data contained in databases that are stored in the information systems of CONSERVAS DELCASINO S.A.S., have the rights described in this in compliance with the fundamental guarantees enshrined in the Political Constitution and the Law.

a. RIGHT OF ACCESS: This includes the right of the data subject to obtain all information regarding his or her own personal data, whether partial or complete, the processing applied to them, the purpose of the processing, the location of the databases containing his or her personal data and the communications and/or transfers made in respect of them, whether authorised or not.

b. RIGHT TO UPDATE: This includes the right of the data subject to update his or her personal data when they have undergone any change.

c. RIGHT OF RECTIFICATION: This includes the right of the data subject to modify data that proves to be inaccurate, incomplete or non-existent.

d. RIGHT OF CANCELLATION: This includes the right of the owner of the data to cancel their personal data or delete them when they are excessive, irrelevant or the processing is contrary to the rules, except in those cases provided for as exceptions by law or contractually agreed otherwise.

e. RIGHT TO RENEW CONSENT: The owner of the personal data has the right to revoke the consent or authorization that enables CONSERVAS DELCASINO S.A.S. for a treatment for a particular purpose, except in those cases provided for as exceptions by law or contractually agreed otherwise.

f. RIGHT OF OPPOSITION: This includes the right of the owner of the data to oppose the processing of personal data, except in cases where such right does not apply by law or because it violates general interests overriding the particular interest. CONSERVAS DELCASINO S.A.S., based on the legitimate rights argued by the owner of the personal data, will take the relevant decision.

g. RIGHT TO LODGE COMPLAINTS AND CLAIMS OR TO TAKE ACTION: The owner of the personal data has the right to file with the Superintendence of Industry and Commerce, or the entity that is competent, complaints and claims, as well as actions that are relevant to the protection of their data. Prior to this, he/she must have exhausted the exercise of his/her right before CONSERVAS DELCASINO S.A.S.

h. RIGHT TO GRANT AUTHORISATION FOR THE PROCESSING OF DATA: The owner of the data has the right to grant his/her authorisation, by any means that may be subject to subsequent consultation, to process his/her personal data at CONSERVAS DEL CASINO S.A.S.

Exceptionally, this authorisation shall not be requested in the following cases:

  • When required by a public or administrative body in fulfilment of its legal functions, or by court order;
  • In the case of data of a public nature;
  • Where the processing of information is authorised by law for historical, statistical or scientific purposes;
  • In the case of personal data relating to the civil registry of persons.

In these cases, although the consent of the data subject is not required, the other principles and legal provisions on the protection of personal data do apply.

9. DUTIES OF CONSERVAS DELCASINO S.A.S:

When CONSERVAS DELCASINO S.A.S., assumes the quality of directly responsible for the processing of the data of the data subjects, it shall comply with the following duties:

  • Guarantee to the holders, at all times, the full and effective exercise of the Constitutional right of Habeas Data;
  • Request and keep, under the conditions provided for in this policy, a copy of the respective authorisation granted by the holder;
  • Duly inform the data subject about the purpose of the collection and the rights he/she is entitled to by virtue of the authorisation granted;
  • Keep the information under the security conditions necessary to prevent its adulteration, loss, consultation, unauthorised or fraudulent use or access;
  • Ensure that the information provided to the data processor is true, complete, accurate, up to date, verifiable and comprehensible;
  • To update the information, communicating in a timely manner to the data processor all new developments with respect to the data previously provided and to adopt the other necessary measures to ensure that the information provided to the data processor is kept up to date;
  • Rectify the information where it is incorrect and communicate the relevant information to the data processor;
  • To provide the processor, as the case may be, only with data the processing of which has been previously authorised in accordance with the provisions of the law;
  • To require the data processor to respect at all times the conditions of security and privacy of the data subject's information;
  • To process queries and claims formulated under the terms set out in this regulation and in the law;
  • Adopt an internal manual of policies and procedures to ensure proper compliance with the law and especially for the attention of queries and complaints. CONSERVAS DELCASINO S.A.S. complies with this obligation through the adoption of this policy.
  • Inform the data processor of the circumstance that certain information is under discussion by the data subject, once the complaint has been lodged and the respective procedure has not been completed;
  • Inform at the request of the data subject about the use given to his or her data;
  • Inform the data protection authority when there are breaches of security codes and risks in the management of data subjects' information;
  • Comply with the instructions and requirements issued by the Superintendency of Industry and Commerce.

When CONSERVAS DELCASINO S.A.S. carries out the processing on behalf of a third party (data processor), or is legally obliged to provide the data, it shall comply with the following duties:

  • Verify that there is authorisation to process the data.
  • Guarantee the holder, at all times, the full and effective exercise of the right of Habeas Data;
  • Keep the information under the security conditions necessary to prevent its adulteration, loss, consultation, unauthorised or fraudulent use or access;
  • Update the information reported by data controllers within five (5) working days of receipt;
  • To process queries and claims made by data subjects under the terms set out in this policy and in the Law;
  • Adopt an internal manual of policies and procedures to ensure proper compliance with the Law and, in particular, for the attention of queries and complaints by the owners. CONSERVAS DELCASINO S.A.S. complies with this obligation through the adoption of this policy.
  • Record in the database the legend "habeas data claim in process" in relation to personal information that is disputed or questioned by data subjects, in accordance with the manner regulated by law;
  • Insert in the database the legend "information on habeas data under judicial discussion" once notified by the competent authority on judicial proceedings related to the quality of the personal data;
  • Refrain from circulating information that is being disputed by the holder and whose blocking has been ordered by the Superintendence of Industry and Commerce or by another competent authority;
  • Allow access to information only to those who can access it;
  • Inform the Superintendence of Industry and Commerce when violations of the "Security Codes" occur and there are risks in the administration of the information of the holders and comply with the instructions and requirements given by the Superintendence of Industry and Commerce.

In the event that the same person is both Data Controller and Data Processor, he/she shall be required to comply with the duties foreseen for each of them.

10. SPECIAL CATEGORIES OF DATA:

a. SENSITIVE PERSONAL DATA: Sensitive data are those data that affect the privacy of the owner or whose improper use may lead to discrimination, such as those that reveal racial or ethnic origin, political orientation, religious or philosophical beliefs, membership in trade unions, social organizations, human rights or that promote the interests of any political party or that guarantee the rights and guarantees of opposition political parties as well as data relating to health, sex life and biometric data. CONSERVAS DELCASINO S.A.S. will restrict the processing of sensitive personal data to what is strictly necessary and will request prior and express consent on the purpose of its processing.

- PROCESSING OF SENSITIVE PERSONAL DATA:

Data classified as sensitive may be used and processed when:

  • The data subject has given his or her explicit consent to such processing, except in cases where, by law, the granting of such consent is not required;
  • The processing is necessary to safeguard the vital interests of the data subject and the data subject is physically or legally incapacitated. In these events, the legal representatives must grant their authorisation.
  • The processing relates to data which are necessary for the establishment, exercise or defence of a right in legal proceedings;
  • The processing has a historical, statistical or scientific purpose, or within the framework of improvement processes, provided that measures are taken to suppress the identity of the data subjects.

b. PERSONAL DATA OF CHILDREN AND ADOLESCENTS: Minors are holders of their personal data and therefore bear the corresponding rights. In accordance with the provisions of the Political Constitution and in accordance with the Code for Children and Adolescents, the rights of minors must be interpreted and applied in a prevalent manner and, therefore, must be observed with special care. As stated in Judgment C-748 of 2011, the views of children should be taken into account when processing their data. 

CONSERVAS DELCASINO S.A.S. therefore undertakes, in the processing of personal data, to respect the prevailing rights of minors and to request the authorisation of their representatives - parents - for the processing of their data. The processing of personal data of minors is forbidden, except for data of a public nature.

11. CLASSIFICATION OF INFORMATION AND DATABASES:

Databases shall be classified as follows:

a. CONFIDENTIAL DATABASES: These are databases or electronic files with confidential information which is treated by CONSERVAS DELCASINO S.A.S. business model. This is the case of financial data, personnel databases, databases with sensitive information about managers, suppliers, etc.

b. DATA BASE WITH SENSITIVE INFORMATION: Data that affect the privacy of the holder or whose improper use may lead to discrimination, such as those that reveal racial or ethnic origin, political orientation, religious or philosophical beliefs, membership of trade unions, social organizations, human rights or promoting the interests of any political party or to ensure the rights and guarantees of opposition political parties as well as data relating to health, sex life and biometric data. At CONSERVAS DELCASINO S.A.S., access to this type of information is restricted and will only be known by an authorised group of employees.

c. DATABASES WITH PUBLIC INFORMATION: These are databases that contain public data qualified as such according to the mandates of the Law or the Political Constitution and that are not qualified as semi-private, private or sensitive data. Public data includes, among others, data relating to the civil status of individuals, their profession or trade, their status as traders or public servants, and data that can be obtained without any reservation whatsoever. By their nature, public data may be contained, among others, in public registers, public documents, official gazettes and bulletins, duly enforced court rulings that are not subject to confidentiality.

12. PASSIVELY OBTAINED INFORMATION:

It is presumed that when a user accesses the website, he/she does so at his/her own risk and therefore fully and unreservedly accepts the content of the terms and conditions of use of the website. 

When using the services contained within the CONSERVAS DELCASINO S.A.S. websites, this may collect information passively through technologies for information management, such as "cookies", through which information is collected about the hardware and software of the computer, IP address, browser type, operating system, domain name, access time and the addresses of the websites of origin; through the use of these tools are not collected directly personal data of users. Information about the pages that the individual visits most frequently on these websites will also be collected in order to learn about his or her browsing habits. However, the user of CONSERVAS DELCASINO S.A.S. websites has the possibility to configure the functioning of the "cookies", according to the options of his internet browser.

With regard to access to personal data via the internet, except for public information, it cannot be made available or widely consulted, as its knowledge is limited to data subjects or authorised third parties in accordance with the law.

13. STRATEGIES FOR THE PROTECTION OF PERSONAL DATA.

  1. Drafting data protection clauses in contracts.
  2. Inclusion of the clause authorising the processing of personal data in the contents of the website and information collection forms.
  3. Request for authorisation prior to the publication of content, images, videos involving personal data.
  4. Constantly implement measures to safeguard data subjects' information.
  5. Training for CONSERVAS DEL CASINO SAS staff on the protection of personal data.

14. INTELLECTUAL PROPERTY:

The intellectual property of the contents of the website either belong to CONSERVAS DELCASINO SAS or, where appropriate, are owned by third parties who have authorised their use on the website or are public information governed by the Colombian laws on access to public information.

The texts and graphic elements that make up the website, as well as their presentation and assembly, are either the exclusive property of CONSERVAS DELCASINO SAS or it holds the necessary exploitation rights. 

15. PROCEDURE FOR ATTENTION AND RESPONSE TO REQUESTS, QUERIES, COMPLAINTS AND CLAIMS FROM THE OWNERS OF PERSONAL DATA:

The owner of CONSERVAS DELCASINO SAS data may access and consult their personal information through the following means provided by the company:

In order to access such information, THE COMPANY will, prior to the request, verify the identity of the user, requesting confirmation of certain personal data held in the database. Once the identity of the owner has been verified, he/she will be provided with all the information about his/her personal data and will be able to carry out any procedure related to the same.

In the event that the owner needs to make an additional query or request that the information contained in the database of CONSERVAS DELCASINO SAS is updated, rectified, modified or deleted, or considers that there is an alleged breach in the protection of their data, they may submit a query/complaint via email [email protected], user service line in Bogotá 482 3222 extension 202, and in writing at the offices of THE COMPANY located at Av. Esperanza N 96-10. The response to the query/complaint submitted by the user will be handled by the User Service area.

The enquiry/complaint submitted by a holder must, in all cases, be in writing, preferably with the following:

  • Full identification (name, notification address, identification document);
  • Description of the facts giving rise to the enquiry/complaint;
  • Documents supporting the facts;
  • The way you would like to receive the answer to your query/complaint.

In case of consultation, the holder will be given an answer within ten (10) working days following the filing of the request or within the term established by law, depending on the type of request. If it is not possible to deal with the request within the aforementioned period, the holder will be informed stating the reasons for the delay and indicating the date on which the request will be dealt with, which in no case may exceed five (5) working days following the expiry of the first period.

In the case of a claim, a response will be given within fifteen (15) working days from the day following the date on which the claim was filed. When it is not possible to deal with the claim within this period, the reasons for the delay and the date on which the claim will be dealt with, which in no case may exceed eight (8) working days following the expiry of the first period.

If CONSERVAS DELCASINO S.A.S. is not competent to resolve it, it will transfer it to the appropriate person within a maximum of five (5) working days and inform the user of the situation.

16. PENALTIES:

Pursuant to Article 23 of Law 1581 of 2012, the sanctions for improper processing of personal data shall be:

"Article 23. Sanctions. The Superintendency of Industry and Commerce may impose the following sanctions on data controllers and processors:

  1. Fines of a personal and institutional nature up to the equivalent of two thousand (2,000) legal monthly minimum wages in force at the time the sanction is imposed. Fines may be successive as long as the non-compliance that gave rise to them persists.
  2. Suspension of treatment-related activities for up to six (6) months. The act of suspension shall indicate the corrective measures to be taken.
  3. Temporary closure of the operations related to the Processing once the term of suspension has elapsed without the corrective measures ordered by the Superintendence of Industry and Commerce having been adopted.
  4. Immediate and definitive closure of the operation involving the Processing of sensitive data".

"Article 24. Criteria for graduating sanctions. The penalties for infringements referred to in the previous article shall be graduated according to the following criteria, insofar as they are applicable:

  1. The extent of the damage or danger to the legal interests protected by this law;
  2. The economic benefit obtained by the offender or third parties by virtue of the commission of the offence;
  3. Recidivism in the commission of the offence;
  4. Negative resistance or obstruction to the investigative or surveillance action of the Superintendence of Industry and Commerce;
  5. Reluctance or contempt to comply with orders issued by the Superintendence of Industry and Commerce;
  6. The express acknowledgement or acceptance by the person under investigation of the commission of the offence prior to the imposition of the appropriate sanction".

17. NOTICE OF PERSONAL DATA POLICY:

CONSERVAS DELCASINO SAS data holders are informed that the privacy notice is published at the following e-mail address: www.salsasdelcasino.com/politica-de-tratamiento-de-datos.

18. PROHIBITIONS:

In accordance with the provisions of Law 1581 of 2012, CONSERVAS DELCASINO S.A.S. will not transfer personal data of the owners to a country that does not offer an adequate level of data protection. To determine whether a country offers an adequate level of data protection, that country must comply with the standards set by the Superintendence of Industry and Commerce on the subject, which in no case may be lower than those required by this law to its recipients.

This prohibition shall not apply toThis shall apply in the case of the following:

  • Information in respect of which the data subject has given his or her express and unambiguous authorisation for the transfer;
  • Exchange of medical data, where the processing of the data subject so requires for reasons of public health or hygiene;
  • Bank or stock exchange transfers, in accordance with the legislation applicable to them;
  • Transfers agreed within the framework of international treaties to which the Republic of Colombia is a party, based on the principle of reciprocity;
  • Transfers necessary for the performance of a contract between the data subject and the controller, or for the implementation of pre-contractual measures, provided that the data subject has given his or her consent;
  • Transfers legally required for the safeguarding of the public interest, or for the recognition, exercise or defence of a right in legal proceedings.

19. VALIDITY:

This update of the policy for the protection of personal data of CONSERVAS DELCASINO SAS data subjects shall be effective as of 19 August 2021.

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