Information Treatment Policies and Procedures

In compliance with the provisions contained in article 15 of the political constitution, Law 1581 of 2012, Regulatory Decree 1377 of 2013, and other rules that modify, add, complement or develop, RecruITment committed to respecting and guaranteeing the rights of its users, suppliers, customers, employees and third parties in general, discloses the information processing policies and procedures that are stored and guarded in our database, which are mandatory in all activities involving, storage, use, circulation and/or transfer of such information. Legal Framework This information processing policy has its normative support in article 15 of the political constitution, Law 1581 of 2012, Regulatory Decree 1377 of 2013,which provide: Constitution: Article 15: All persons have the right to their personal and family privacy and good name, and the State must respect and enforce them. Likewise, they have the right to know, update and rectify the information that has been collected about them in data banks and in files of public and private entities. In the collection, processing and circulation of data, freedom and other guarantees enshrined in the Constitution will be respected. Correspondence and other forms of private communication are inviolable. They can only be intercepted or registered by court order, in cases and with the formalities established by law. For tax or judicial purposes and for cases of inspection, surveillance and intervention of the State, the submission of ledgers and other private documents may be required, in the terms indicated by law. Statutory Law 1581 of 2012 "By which general provisions are issued for the protection of personal data" Regulatory Decree 1377 of 2013 "By which Law 1581 of 2012 is partially regulated" Recipients of Information Processing Policies and Procedures - General Framework The Information Processing Policies and Procedures contained herein (hereinafter the Policies) refer to the collection and/or storage and/or use and/or circulation and/or deletion of personal data, and/or any transaction related thereto (hereinafter Personal Data, and Processing, respectively) by RecruITment (here in after RecruITment). The holders of Personal Data that are in the databases of RecruITment (here in after the Holders), to Recruitment, as responsible for the corresponding Processing, to the processors and to third parties acting on behalf of RecruITment, or who are not acting on behalf of RecruITment process Personal Data of the Holders, by their disposal as Processors. It is understood that RecruITment is Responsible for the Processing, since it decides on its databases and / or on the processing of the corresponding Personal Data that are stored in them. Data Processors who process Information and Personal Data on assistance of the Data Controller, such as the operators necessary for the fulfillment of the services provided by RecruITment, including expressly, but not limited to consultants, consultants, researchers, contractors and call-centers, are Data Processors. Purpose of Information Processing RecruITment collects and/or stores and/or uses and/or circulates and/or deletes Personal Data of the Holders, and performs operations related thereto in order to fulfill their social reason and/or services: 1. Search and selection of competent personnel, including expressly, but not limited to the recruitment and placement of Laboure bidders in the territory of the Republic of Colombia and abroad. For these purposes, RecruITment performs the following procedures: a. Obtaining corporate information from the labor claimant and the profile of the required position b. Research. RecruITment conducts a market survey in order to locate potential candidates who meet the profile required by the labor plaintiff who has contracted the RecruITment services to carry out the corresponding search and selection of personnel. c. Interviews and testapplication. RecruITment makes first contact with candidates who can potentially fit the profile required by the labor plaintiff who has contracted the RecruITment services and evaluates those that best fit that profile. d. Inform the customer. RecruITment sends the Laboure claimant who has contracted the RecruITment services a report with the candidates that best fit the profile, so that the profile decides whether to hire any of the candidates included in this report. 2. Evaluation of personnel (assessment). For these purposes, RecruITment evaluates professional skills by designing specific exercises. 3. Competency interviews. RecruITment conducts personal interviews with professionals that include questions about specific situations to measure key competencies. 4. The representation of enterprises, public or private, national and foreign, engaged in activities similar to or complementary to those referred to in the previous numerals. For this purpose, RecruITment will conclude the contracts to which there is a place, with the respective companies. Send promotions and information about courses, seminars and all kinds of training activities, and for statistical purposes; The other purposes that RecruITment informs the respective Owner; and Comply with RecruITment's legal obligations;; If required, RecruITment will transmit and/or deliver and/or transfer Personal Data of the Holders for the purposes mentioned herein to legal entities that have the status of parent companies, subsidiaries, subsidiaries or affiliates of RecruITment, aswell as those that perform with RecruITment a merger or spin-off or purchase of assets, liabilities and contracts, or an equivalent transaction. 2 Rights of Holders Holders who provide Personal Data to RecruITment will have the rights contained in these Policies and in particular those set out below. These rights shall be exercised in accordance with these Policies. 1. Ask RecruITment for information about the existence of The Owner's Personal Data in the RecruITment databases. 2. Access the Personal Data of the Owner that they rest in the databases of RecruITment. 3. Know, update and rectify the Personal Data of the Owner against RecruITment or the Processors, if applicable. 4. Request RecruITment to correct or remove Personal Data from the Owner to repossess in the RecruITment database. 5. Request proof of the authorization granted to RecruITment for the Processing of Personal Data 6. Holder, Titularwhere required for the corresponding Processing. 7. Be informed by RecruITment or the Processors, upon request by the Owner, regarding the use given to your Personal Data. 1 8. Be informed by RecruITment, prior to its collection, which of the Personal Data that will be sensibles processed are sensitive2 and the purpose of the Processing. 9. Do not answer questions related to Sensitive Data2, if deemed necessary or convenient by the Owner.. 10. File complaints with the competent authority for violations of Law 1581 of 2012, once the consultation or complaint proceedings have been exhausted before RecruITment.. 1 Where, in the processes of search and selection of personnel provided by RecruITment, individually or jointly or in collaboration with other undertakings which also provide such services, Laboure claimants expressly request the respective service provider to provide their identity and other information which they provide to recruiting the latter confidentially during the relevant process, and only Laboure bidders participating in such a process are disclosed from a certain stage within the process, RecruITment shall inform the respective Owner of Laboure in such circumstances, so that the latter indicates whether it authorizes RecruITment to use his personal information and share it with the respective Laboure claimant for the purposes of the corresponding search process. 2 Sensitive data are data that affect the privacy of the Holder or whose misuse may lead to discrimination, such as racial or ethnic origin, political orientation, religious or philosophical beliefs, membership of trade unions, social organizations, human rights or political parties, health, sex life, and biometric data of titlet Legitimation for the Exercise of the Rights of the Holder The rights of The Holders may be exercised by: 1. The Holder, who must prove his/her identity; 2. The successors of the Owner, who must prove their quality as such; 3. The representative and/or proxy of the Holder, who must prove his/her quality as representatives or representatives; and 4. By stipulation in favor of another or for another. Holder's Duties Those who provide information to RecruITment undertake to do so in a truthful, complete, accurate, up-to-date, verifiable and understandable manner. RecruITment Duties as Data Controller RecruITment, as Data Controller, shall have the following duties and the others applicable to you in accordance with the Law, which shall be exercised in accordance with these Policies. 1. Inform the Holders of the existence of the Policies and Procedures of Processing of Information that will be applicable to them, the way to access them, and the purposes of the Processing that is intended to give to their personal data. 2. Guarantee to the Owner, at all times, the full and effective exercise of the right of Habeas Data (to know and/or update and/or rectify their personal data that they rest in the databases of RecruITment); 3. Request and retain a copy of the authorization granted by the Owner for the Processing of his/her personal data; 4. Inform the Owner about the purpose of the collection and the rights that assist it by virtue of the authorization granted; 5. Keep the information collected under the necessary security conditions to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access; 6. Ensure that the information provided to the Data Processor is truthful, complete, accurate, up-to-date, verifiable and understandable; 7. Update the information by informing the Rating Officering a timely manner, all the news regarding the data previously provided to him and take the other necessary measures to keep the information provided to him up to date; 8. Rectify information where incorrect and communicate the relevant to the Data Processor; 9. Provide the Data Processor with only Personal Data whose Processing is previously authorized by the Data Controller;; 10. Require the Data Processor at all times to respect the security and privacy conditions of the Owner's information;; 11. To process the inquiries and complaints made by the Owner;; 12. Inform the Data Processor when certain information is under discussion by the Data Controller, once the complaint has been filed and the respective procedure has not been completed; 13. Inform at the Request of the Owner about the use given to his/her data; 3 14. Inform the data protection authority when security code violations occur and there are risks in the administration of The Owners' information; and 15. Comply with the instructions and requirements of the Superintendency of Industry and Commerce. 3 Where, in the processes of search and selection of personnel provided by RecruITment, individually or jointly or in collaboration with other undertakings which also provide such services, the Laboure claimants expressly request the respective service provider that their identity, geographical location, and the other information they provide to the latter be the demands kept confidential during the relevant process, and only Laboure bidders participating in such a process are disclosed from a certain stage within the process, RecruITment shall inform the respective Owner of the workforce in such circumstances, so that the latter indicates whether it authorizes RecruITment to use his personal information and share it with the respective Laboure claimant for the purposes of the corresponding search process. Duties of Data Processors Data Processors shall perform the following duties, without prejudice to the other provisions provided for in the law and in others governing their activity: 1. To process, in the name of the RecruITment as Data Controller, the Personal Data to which you have access under these Policies. 2. Guarantee to the Holder, at all times, the full and effective exercise of the right of Habeas Data; 3. Keep personal data under the necessary security conditions to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access, and to safeguard the security of the databases in which the corresponding Personal Data is located; 4. Keep confidential with respect to the Personal Data to which you have access, as well as the Processing thereof, exercising for this purpose the same degree of diligence that you use to protect confidential information of your property; 5. Perform in a timely manner the updating, rectification or deletion of Personal Data in the terms of these Policies; 6. Update the information reported by the Data Controllers within five (5) business days of receipt; 7. Process inquiries and claims made by Holders in the terms indicated by law; 8. Adopt an internal Information Processing Policies and Procedures manual. 9. Record in the database the legend "claim pending" in the way indicated in these Policies; 10. Insert into the database the legend "information in judicial discussion" once notified by the competent authority about judicial processes related to the quality of personal data; 11. Refrain from circulating information that is being disputed by the Owner and whose blocking has been ordered by the Superintendency of Industry and Commerce; 12. Allow access to information only to people who can access it; 13. Inform the Superintendency of Industry and Commerce when security code violations occur and there are risks in the administration of holders' information; 14. Comply with the instructions and requirements of the Superintendency of Industry and Commerce. RecruITment will fulfill the duties set forth herein for the Processors when processing Personal Data on part of another entity (Data Controller). Authorization for the Processing of Personal Data6 RecruITment will inform the Owner what Personal Data of the Latter that RecruITment will collect and the specific purposes of the respective Processing and, no later than the time of collection, will request authorization for the Processing of these. The Holder may make the authorization in writing, or orally, by automated manifestation through electronic means, or by any other unequivocal conduct that allows to reasonably conclude that the Owner granted the authorization (for example, it is understood as unequivocal conduct of authorization to RecruITment to collect and / or store and / or use the corresponding Personal Data, the delivery by the Personal Data Holder to RecruITment either verbally, physically or electronically, without having been requested by the latter). Silence is not assimilated to unequivocal conduct. The Owner acknowledges that RecruITment does not require authorization for the processing of your Personal Data in the following cases: 1. When the information is required by a public or administrative entity in the exercise of its legal functions or by court order. 2. Where the Owner's data are of a public nature(public data4). 3. In cases of medical or health emergency. 4. Where the Processing of the corresponding information is authorized by law for historical, statistical or scientific purposes. 5. When the information is related to the Civil Registry of Persons. 4 Public data are all data which are not semi-private, private, or sensitive, such as those relating to the marital status of persons, their profession or profession, their status as a trader or a public servant. By their nature, public acts may be contained among others, in public registers, public documents, gazettes and official bulletins, as well as in executed court judgments that are not subject to reservation. Holders may revoke the authorization given to RecruITment for the processing of their Personal Data at any time, provided that it is not prevented by a legal provision. In the revocation the Owner must indicate whether it applies to all personal data of the Owner, or to some only, specifying which, or if it refers to any type of Processing, or only to any or some, specifying which or which. International Transfer of Personal Data In cases where RecruITment has contractual or legal links with natural or legal persons located abroad, with which it requires sharing data that rests in its databases, the respective international transmissions of Personal Data that take place between RecruITment as Responsible and / or Data Processor to allow the Processor to carry out the Processing on without the Responsibility, will require prior, express and unequivocal authorization from the Owner. However, they will not require to be informed to the Owner or 7have their consent when there is a contract for the transmission of personal data, inthe terms established in Article 25 of Decree 1377 of 2013. In the event that there is no contract transmitting personal data, authorization from the Owner will be required for this purpose. Petitions and Inquiries suprimir The Owner may submit requests to RecruITment in order to know, update and rectify his/her Personal Data that they may hold in the RecruITment database, or to request RecruITment to delete Personal Data from the Owner of its databases, or to revoke the authorization given by it to RecruITment for the Processing of its Personal Data. For this purpose, you must file the respective petition or inquiry with the Department of RecruITment Petitions, Inquiries and Complaints in the email: team@recruitment.com.co.. RecruITment will respond to the request or consultation submitted within a maximum period of ten (10) working days from the date of receipt of the same. Where it is not possible to attend the consultation within the term indicated herein, RecruITment will inform the interested party, expressing the reasons for the delay and indicating the date on which his consultation will be attended, which in no case may exceed five (5) working days following the expiration of the first term. Claims The Owner may request from RecruITment the correction, updating or deletion of his/her Personal Data that rests in the RecruITment database, as well as revoke the authorization granted for the Processing there of, by filing a complaint with RecruITment. You may also file complaints with RecruITment when you notice the alleged breach of any of the duties contained in Law 1581 of 2012 and other applicable rules. The claim will be filed with the RecruITment Requests, Inquiries and Complaints Department in the team@recruitment.com.co.. Claim processing 1. The claim must be submitted expressly indicating: 1.1. The Identification of the Holder 1.2. The Address of the Holder 1.3. If the claim is filed by a successor, representative or proxy of the Owner, or under a stipulation in favor of the Owner or for the Owner, the identification of the claimant and the documents attesting to the quality in which he acts 1.4. The means of contact to receive a response to the complaint, if different from the address of the Holder 1.5. The description of the facts that give rise to the claim, expressly indicating the Personal Data for which the complainant requests the correspondingcorrection, updating or deletion 1.6. The documents that the complainant wants to enforce 2. In the event that the person receiving the claim is not competent to resolve it, he/she shall transfer the person responsible for a maximum term of two (2) working days and inform the interested party of the situation. 3. If the claim is incomplete, RecruITment will require the applicant within five (5) days of receipt of the claim for the claim to complete the failures. 4. If within two (2) months the applicant does not submit the required information, it shall be understood that he has given up the claim. 5. Upon receipt of the complete claim, RecruITment will include in its database the legend "claim pending" and the reason for it, in a term not more than two (2) business days from the date on which the claim is received, which will be maintained, until the claim is decided. 6. RecruITment will address the claim within a maximum term of fifteen (15) business days, counted from the day following the date of receipt of the full receipt of the information required to address the claim. 7. Where it is not possible to address the claim within the term referred to in point 4 above, RecruITment shall inform the interested party of the reasons for the delay and the date on which it will meet its claim, which in no case exceeds eight (8) working days following the expiration of the term referred to in point 6 above. The request for the deletion of the information and the revocation of the authorization shall not proceed where the Holder has a legal or contractual duty to remain in the database, and in the in cases where RecruITment does not require authorization for the Processing of Personal Data of the Owner, mentioned in the separate Authorization for the Processing of Personal Data (above). Effect These Information Processing Policies are in force since July 1, 2020. RecruITment will inform the Holders in a timely manner of any substantial changes thereto, prior to the implementation of the respective change. The personal data collected by RecruITment in the terms set out in these Policies will be stored in them for an indefinite period, unless the respective Owner has requested RecruITment to deleting your Personal Data, in accordance with the Claims procedure set out in these Policies. Information from the Company Responsible for Treatment Any breach of the obligations and, in general, of the Policies contained herein must be reported to our mail of requests, complaints and complaints: team@recruitment.com.co i) The Owner may consult his/her personal data free of charge (i) at least once a calendar month, and(ii) whenever there are substantial changes to the Policies that motivate further consultations. If more than one query is presented for each calendar month, RecruITment may charge the Holder for shipping, reproduction and certification of documents (if applicable)) PRIVACY NOTICE The Information Processing Policies and Procedures (hereinafter the Policies) that will apply to the information and personal data that you and/or third parties provide to RecruITment, as well as substantial modifications thereto, can be accessed on our website (www.recruitment.com.co/politicastratamientodeinformacion.pdf. ) Unless in a separate document RecruITment has agreed with you (as the Holder of Information and Personal Data, or as a representative and/or representative of a legal entity – hereinafter the Legal Person), that the personal data (yours and/or the Legal Person and/or the persons linked to them, as the case may be - hereinafter the Personal Data) will be used for a different purpose, they will be the subject of collection and / or storage and / or use and / or circulation and / or deletion, and / or any operation related to them (hereinafter the Processing) by RecruITment to: 1. The purposes contained in the Information Processing Policies and Procedures (www.recruitment.com.co/politicastratamientodeinformacion.pdf. ) 2. In case you are a Laboure offered, to: a. Establish quality profiles and staff competency required by labor claimants – RecruITment customers to fill their job openings; and b. Transmit and/or deliver and/or transfer your Personal Data to labor claimants – RecruITment customers to fill their job openings. Please note that in some processes of search and selection of personnel provided by Recruitment, individually or jointly or in collaboration with other companies that also provide such services, Laboure seekers (our customers) expressly ask the respective service provider that their identity and other information they provide to the service provider be kept confidential during the relevant process, and that only Laboure bidders who participate in that process are disclosed from a certain stage within the process. 3. In the event that you are our customer as a labor claimant, to: a. Provide you with the services for which you have contracted us; b. Transmit and/or deliver and/or transfer your Personal Data to labor bidders involved in the search and selection processes of personnel to fill their work vacancies, in accordance with written instructions given to RecruITment for this purpose, and in the absence of these at the time and form in which RecruITment deems it appropriate or necessary; c. Transmit and/or deliver and/or transfer your Personal Data to the Public Employment Service for the purpose of registering and publishing the relevant vacant(s). d. In case you work for one of our clients, to make the evaluations that they require and that you agree to submit. 4. Candidates who participate in search and selection processes provided by RecruITment, individually or jointly or in collaboration with other companies that also provide this type of services, to publish it on the RecruITment website, and to share or deliver it to recruITment customers and/or potential customers. 5. In the event that you are a RecruITment consultant, advisor or supplier, for RecruITment to comply with its legal obligations as a contractor, including expressly but not limited to the transmission of information required by tax authorities and other competent authorities, to share and/or deliver it to recruITment customers and/or potential customers, to candidates involved in search and selection of staff provided by RecruITment, individually or jointly or in collaboration with other companies that also provide such services, and to publish it on the RecruITment website. We inform you that on our website we use cookies and other technologies through which it is possible to monitor your behavior as an Internet user, provide you with a better service and user experience when browsing our website, as well as to offer you new products and services based on your preferences. The Personal Data we obtain from these tracking technologies are as follows: browsing time, browsing time on our website and sections consulted. These technologies may be disabled from your internet browser, in accordance with your particular instructions. Rights of Holders Holders who provide Information and Personal Data to RecruITment shall have the rights contained in the RecruITment Information Processing Policies and Procedures(www.recruitment.com.co/politicastratamientodeinformacion.pdf. ). The Owner is not obliged to answer questions related to sensitive data2 if deemed necessary or convenient. Information from the Company Responsible for Treatment ubstantial change control record to this document Version Date Modifications 1.0 1/7/2020 Preparation and publication 1 Modifications to this Privacy Notice will be posted in (www.recruitment.com.co/politicastratamientodeinformacion.pdf. ( ) 2 Sensitive data are data that affect the Privacy of the Owner or whose misuse may lead to discrimination, such as racial or ethnic origin, political orientation, religious or philosophical beliefs, membership of trade unions, social organizations, human rights or political parties, health, sex life, and biometric data of the Holder.