DATA POLICY

In Compliance with the Provisions of the Law 1581 of 2012 and the Regulatory Decree 1377 of 2013, through which the General Regime for the Protection of Personal Data in Colombia is established, these general policies are implemented for the treatment of data from officers, clients, suppliers or any Third Party that is part of the database for which CARGO RISK CORPORATION, its parent company, branches, subsidiaries, and other companies of the business group is responsible, hereinafter CARGOCORP UW.

ARTICLE 1: DEFINITIONS

For the purposes of the development of these policies, the following definitions apply:

  1. AUTHORIZATION: It is the specific and free consent THE HOLDER gives to CARGOCORP UW by written documentary means for the handling or processing of their data, prior to their treatment.
  2. SENSITIVE DATA. Sensitive data will be understood as the data that affect the privacy of the Holder or whose improper use may generate discrimination. CARGOCORP UW will not collect or use sensitive data in the development of its commercial activity.
  3. MANAGER: It may be CARGOCORP UW, or a third party authorized to do so, who will process the data provided by THE HOLDER, , in accordance with Law 1581 of 2012 and its regulatory decrees.
  4. RESPONSIBLE: CARGOCORP UW as responsible for the database will decide on it and / or on the treatment of the data provided by THE OWNER , in accordance with Law 1581 of 2012 and its regulatory decrees.
  5. OWNER: Natural or legal person whose data is subject to Treatment.
  6. TREATMENT: It consists of the collection, storage, use, circulation, or deletion of non-sensitive data that CARGOCORP UW uses for its commercial activity.

ARTICLE 2: TREATMENT AND PURPOSE OF THE COLLECTION OF DATA

CARGOCORP UW will obtain personal data through direct collection or through third parties duly authorized to provide such information for exclusively commercial purposes.

CARGOCORP UW will guarantee the secure storage of the information contained in the database, will not sell the information, or supply to third parties other than its parent company, subsidiaries, and other companies of the business group. The data collected will be used exclusively for commercial purposes, marketing, statistics, data updating, satisfaction surveys, trend analysis and in general other useful technical studies for the promotion of CARGOCORP UW products and services.

ARTICLE 3: MECHANISMS FOR OBTAINING THE AUTHORIZATION

CARGOCORP UW will require prior, express, and informed consent of the HOLDER for the collection, storage, use, circulation, or deletion of personal data, which is understood to be included within the service offers developed by CARGOCORP UW.

For this, CARGOCORP UW, in its capacity as responsible for the processing of personal data, will keep proof of the authorization granted in a document by THE HOLDER, which will be available for verification by the latter at any time.

To obtain access to the authorization, THE HOLDER must comply with the provisions of Article 5 of this document.

ARTICLE 4: RIGHTS OF THE HOLDER

For the purposes of the development of these policies, the following definitions apply:

  1. AUTHORIZATION: It is the specific and free consent THE HOLDER gives to CARGOCORP UW by written documentary means for the handling or processing of their data, prior to their treatment.
  2. SENSITIVE DATA. Sensitive data will be understood as the data that affect the privacy of the Holder or whose improper use may generate discrimination. CARGOCORP UW will not collect or use sensitive data in the development of its commercial activity.
  3. MANAGER: It may be CARGOCORP UW, or a third party authorized to do so, who will process the data provided by THE HOLDER, , in accordance with Law 1581 of 2012 and its regulatory decrees.
  4. RESPONSIBLE: CARGOCORP UW as responsible for the database will decide on it and / or on the treatment of the data provided by THE OWNER , in accordance with Law 1581 of 2012 and its regulatory decrees.
  5. OWNER: Natural or legal person whose data is subject to Treatment.
  6. TREATMENT: It consists of the collection, storage, use, circulation, or deletion of non-sensitive data that CARGOCORP UW uses for its commercial activity.

ARTICLE 5: OWNER ATTENTION AREA AND PROCEDURE TO KNOW OR ACCESS YOUR INFORMATION

For the purposes of the development of these policies, the following definitions apply:

  1. AUTHORIZATION: It is the specific and free consent THE HOLDER gives to CARGOCORP UW by written documentary means for the handling or processing of their data, prior to their treatment.
  2. SENSITIVE DATA. Sensitive data will be understood as the data that affect the privacy of the Holder or whose improper use may generate discrimination. CARGOCORP UW will not collect or use sensitive data in the development of its commercial activity.
  3. MANAGER: It may be CARGOCORP UW, or a third party authorized to do so, who will process the data provided by THE HOLDER, , in accordance with Law 1581 of 2012 and its regulatory decrees.
  4. RESPONSIBLE: CARGOCORP UW as responsible for the database will decide on it and / or on the treatment of the data provided by THE OWNER , in accordance with Law 1581 of 2012 and its regulatory decrees.
  5. OWNER: Natural or legal person whose data is subject to Treatment.
  6. TREATMENT: It consists of the collection, storage, use, circulation, or deletion of non-sensitive data that CARGOCORP UW uses for its commercial activity.

ARTICLE 6: PROCEDURE TO UPDATE, RECTIFY AND DELETE INFORMATION

For the purposes of the development of these policies, the following definitions apply:

  1. AUTHORIZATION: It is the specific and free consent THE HOLDER gives to CARGOCORP UW by written documentary means for the handling or processing of their data, prior to their treatment.
  2. SENSITIVE DATA. Sensitive data will be understood as the data that affect the privacy of the Holder or whose improper use may generate discrimination. CARGOCORP UW will not collect or use sensitive data in the development of its commercial activity.
  3. MANAGER: It may be CARGOCORP UW, or a third party authorized to do so, who will process the data provided by THE HOLDER, , in accordance with Law 1581 of 2012 and its regulatory decrees.
  4. RESPONSIBLE: CARGOCORP UW as responsible for the database will decide on it and / or on the treatment of the data provided by THE OWNER , in accordance with Law 1581 of 2012 and its regulatory decrees.
  5. OWNER: Natural or legal person whose data is subject to Treatment.
  6. TREATMENT: It consists of the collection, storage, use, circulation, or deletion of non-sensitive data that CARGOCORP UW uses for its commercial activity.

ARTICLE 7: DUTIES OF CRM AS RESPONSIBLE AND / OR IN CHARGE OF THE INFORMATION

  1. Guarantee the Holder, always, the full and effective exercise of the right to the habeas data.
  2. Request and keep, under the conditions set forth in this law, a copy of the respective authorization granted by the Holder, which is understood to be included in the offers submitted by the company.
  3. Properly inform the Holder about the purpose of the collection and the rights that assist him by virtue of the authorization granted.
  4. Keep the information under the necessary security conditions to prevent its adulteration, loss, consultation, use or unauthorized / fraudulent access.
  5. Rectify the information when it is incorrect.
  6. Inform at the request of the Owner about the use given to their data.

ARTICLE 8: WHO CAN EXERCISE THE RIGHTS OF THE HOLDER

The following persons may exercise the rights of the HOLDER:

  1. The Holder, who must prove the identity by the different means made available to him by the person in charge.
  2. By their successors, who must prove such quality.
  3. By the representative and / or attorney-in-fact of the Holder, prior accreditation of the representation or power of attorney.
  4. By stipulation in favor of another or for another prior accreditation of such stipulation.
  5. The rights of children or adolescents shall be exercised by the persons who are empowered to represent them.

ARTICLE 9: PROCEDURE TO KNOW OR ACCESS YOUR INFORMATION

The HOLDER may request to CARGOCORP UW, by written communication or email, to know the information related to their data that is in the CARGOCORP UW databases.

The query will be answered 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, stating the reasons for the delay, and indicating the date on which the query will be attended, which in no case will exceed the term of five (5) business days following the expiration of the first term.

ARTICLE 10: PROCEDURE FOR UPDATE, RECTIFY AND DELETE INFORMATION

If THE HOLDER or the person duly authorized to exercise their rights, consider that the information contained in the database should be subject to correction, updating or deletion, they may file a request to CARGOCORP UW, which will be processed under the following rules:

  1. The request may be formulated by written communication or by email. In it THE HOLDER must fully identify himself, make a description of the facts that give rise to the request, the address, and the documents required.
  2. In the event that the related information is incomplete, the interested party will be contact within five (5) days following receipt of the request to complete the information. After two (2) months from the date of the request, without the applicant presenting the required information, it will be understood that he has withdrawn the request.
  3. In the event that the person who receives the request is not competent to resolve it, he or she will send it to the corresponding person within a maximum term of two (2) business days and will inform the interested party of the situation.
  4. Once the complete request has been received, it will say “request in process” and the reason for it will be included in the database within a term of no more than two (2) business days.
  5. The maximum term to attend the request will be fifteen (15) business days from the day following the date of receipt. When it is not possible to attend the request within said term, the interested party will be informed of the reasons for the delay and the date on which their claim will be attended, which in no case may exceed eight (8) business days from the first term date.

ARTICLE 11: PERSONAL DATA PROCESSING AUTHORIZATION

All employees of CARGOCORP UW must authorize the processing of their data once they enter the company through the following format.

ARTICLE 12: VALIDITY

The policies contained herein are effective as of July 2013 and were readjusted in August 2016, June 2021, and November 2022.

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