Personal Data Processing Policy
Disneyland Designs S.A.S.
This personal data processing policy is prepared in accordance with the provisions of article 15 of the Political Constitution of Colombia, law 1581 of 2012, and Regulatory Decree 1377 of 2013 and will be applied by DISNEYLANDIA DISEÑOS S.A.S., regarding the collection , storage, use, circulation, deletion, transfer and all those activities that constitute the processing of personal data provided to this company.
1. IDENTIFICATION OF THE RESPONSIBLE FOR THE PROCESSING OF THE INFORMATION: DISNEYLANDIA DISEÑOS S.A.S. Located at Calle 16 45 05 Medellín – Antioquia, email juridica.disney@adrissa.com.co and telephone (604) 444 44 02.
2. PURPOSES OF THE COLLECTION OF PERSONAL DATA: The personal data provided by its owner to DISNEYLANDIA DISEÑOS S.A.S. They will be stored in our data banks and will be used for any of the following purposes:
With Clients and franchisees:
- Execute the existing contractual relationship.
- Provide the required products or services.
- Inform about new products or services, or changes in them.
- Exercise control in the delivery of products.
- Evaluate the quality of the service.
- Carrying out statistical, commercial, strategic, financial analyzes that concern the corporate purpose of DISNEYLANDIA DISEÑOS S.A.S.
- Send to the address, email, cell phone or mobile device, via text messages (SMS and/or MMS) or through any other analog and/or digital means of communication, commercial, advertising or promotional information about the products, events and/or promotions of a commercial nature, in order to promote, invite, direct, execute, inform and in general, carry out campaigns, promotions or contests of a commercial or advertising nature, advanced by DISNEYLANDIA DISEÑOS S.A.S. and/or by third parties.
- Transmission, transfer, marketing and/or sale of databases to third parties for statistical, commercial, strategic and financial purposes.
- Share databases with companies related to DISNEYLANDIA DISEÑOS S.A.S.
- To promote the safety of commercial establishments where the public is served and also that of third parties where services are provided. This purpose is applicable to company locations where security cameras are installed.
With Employees:
- Advance selection processes, execution of employment contracts and termination of the employment relationship.
- Develop processes of induction, evaluation, employment relationship and termination of employment relationship.
- Carry out the social security affiliation and payment processes.
- Attend internal or external audit processes.
- Provide, share, send or deliver your personal data to affiliated companies, linked as users, or subordinates of DISNEYLANDIA DISEÑOS S.A.S. and/or and third parties, in the event that said companies require the information for contractual purposes such as social security administrators, parafiscals, courts, among others that arise from the contractual relationship.
- Increase data banks of possible job candidates.
- To promote the safety of commercial establishments where the public is served and also that of third parties where services are provided. This purpose is applicable to company locations where security cameras are installed.
- The personal data of clients obtained through any of the franchises enters directly into any of the databases of DISNEYLANDIA DISEÑOS S.A.S. by express authorization of the franchise contract between the parties and will be used for the execution of advertising campaigns and customer loyalty.
With service providers:
- Advance linking processes, execution of service provision contracts and contract settlement.
- Affiliation with social security and payment of it.
- Attend internal or external audit processes.
- Provide, share, send or deliver your personal data to affiliated companies, linked as users, or subordinates of DISNEYLANDIA DISEÑOS S.A.S. and/or and third parties, in the event that said companies require the information for contractual purposes.
- Increase data banks of possible service providers.
- To promote the safety of commercial establishments where the public is served and also that of third parties where services are provided. This purpose is applicable to company locations where security cameras are installed.
With Suppliers:
- Execute the existing contractual relationship.
- Contact and hire new products and/or services that DISNEYLANDIA DISEÑOS S.A.S. required for the normal functioning of its operation.
- Provide, share, send, assign and deliver your personal data to affiliated companies, linked as users, or subordinates of DISNEYLANDIA DISEÑOS S.A.S. and/or third parties in the event that said companies require the information for their purposes.
3. GUIDING PRINCIPLES
The Company will apply the following specific principles established below, which constitute the rules to follow in the collection, handling, use, treatment, storage and exchange of personal data:
- Principle of legality: In the use, capture, collection and processing of personal data, the current and applicable provisions that govern the processing of personal data and other related fundamental rights will be applied.
- Principle of freedom: The use, capture, collection and processing of personal data can only be carried out with the prior, express and informed consent of the Owner. Personal data may not be obtained or disclosed without prior authorization, or in the absence of a legal, statutory, or judicial mandate that requires consent.
- Principle of purpose: The use, capture, collection and processing of personal data to which you have access and which are accumulated and collected by The Company, will be subordinated and will serve a legitimate purpose, which must be informed to the respective owner of the personal data.
- Principle of truthfulness or quality: The information subject to use, capture, collection and processing of personal data must be truthful, complete, exact, updated, verifiable and understandable. The Processing of partial, incomplete, fragmented or misleading data is prohibited.
- Principle of transparency: In the use, capture, collection and processing of personal data, the Owner's right to obtain from the Company, at any time and without restrictions, information about the existence of any type of information or personal data that is of your interest or ownership.
- Principle of restricted access and circulation: 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 knowledge restricted only to the Owners or authorized third parties. . For these purposes, the Company's obligation will be medium.
- Security principle: The personal data and information used, captured, collected and subject to processing by the Company will be protected to the extent that the technical resources and minimum standards allow it, through the adoption of technological measures of protection, protocols, and all types of administrative measures that are necessary to provide security to electronic records and repositories, avoiding their adulteration, modification, loss, consultation, and in general against any unauthorized use or access.
- Principle of confidentiality: All people involved in the use, capture, collection and processing of personal data that are not public in nature are obliged to guarantee the confidentiality of the information, even after their relationship with any of the tasks they carry out has ended. It includes the Treatment, and may only supply or communicate personal data when this corresponds to the development of the activities authorized in this law and in the terms thereof.
4. PROCESSING OF SPECIAL DATA.
Regarding the processing of sensitive data or data whose owner is a minor DISNEYLANDIA DISEÑOS S.A.S. adapts all the necessary measures for its protection and points out the following:
- Sensitive data: DISNEYLANDIA DISEÑOS S.A.S. warns the Owner of sensitive data that he has the right to choose not to provide any sensitive information requested, related, among others, to data on his racial or ethnic origin, membership in unions, social or human rights organizations, political or religious convictions, of sexual life, biometrics or health data.
- Data of minors: The provision of personal data whose owner is a minor is optional, and must be carried out with the authorization of the parents or legal representatives of the minor. DISNEYLANDIA DESIGNS S.A.S. will only use, store and process personal data of minors who are children, descendants or who depend on or are in charge of employees or contractors and which are of a public nature or for which prior authorization has been obtained. The purpose of said treatment will be solely to plan and carry out activities related to the personal and family well-being of employees and minors. And that of affiliations as dependent on the social security system. For these purposes, DISNEYLANDIA DISEÑOS S.A.S. will take into account the respect and prevalence of the rights of minors, their best interests and their fundamental rights.
5. RIGHTS OF THE OWNERS.
The owners of personal data handled by DISNEYLANDIA DISEÑOS S.A.S. By themselves or through their representative and/or attorney-in-fact or their successor in title, they may exercise the following rights in such a way that the purposes of the law are satisfied:
- Right to know: By virtue of which you can access personal data that is under the power of DISNEYLANDIA DISEÑOS S.A.S. for the purposes of consulting them, whenever they consider it pertinent, or whenever there are substantial modifications to the Information Processing Policies that motivate new queries.
- Right to update: The owner of the information has the right to update his or her personal data when it is partial, fragmented or incomplete.
- Right to rectification: The owner of the information has the right to rectify his or her personal data when it is inaccurate or misleading.
- Right to deletion or revocation: The owner of the information may revoke the authorization and/or request the deletion of the data when the processing does not respect constitutional and legal principles, rights and guarantees. Revocation will not proceed when the owner has a legal or contractual duty to remain in the database.
- Right to request proof of authorization: except in events in which, according to current legal regulations, authorization is not required to carry out the treatment.
- Right to be informed regarding the use of personal data.
6. PROCEDURE TO EXERCISE RIGHTS.
To exercise your rights as owner, you can visit the company facilities located at Calle 16 45 05 Medellín – Antioquia or write to the email juridica.disney@adrissa.com.co, for the purposes of prompt and correct attention, please note which in all cases must indicate the following information.
- Name and identification of the Owner.
- The precise and complete description of the facts that give rise to the procedure.
- The physical or electronic address to send the response and report on the status of the procedure.
- The documents and other evidence that is intended to be asserted, if any.
Paragraph: queries will be resolved in accordance with current regulations that regulate responses to requests.
If the attention is in person with the completion of the Information Update form.
7. SECURITY OF THE INFORMATION.
DISNEYLANDIA DESIGNS S.A.S. has human, administrative and technical security measures to protect the information of the Owners, and prevent unauthorized access to their data or any unauthorized modification, disclosure or destruction thereof.
Access to personal data is restricted to employees, contractors, representatives and agents of DISNEYLANDIA DISEÑOS S.A.S. those in charge of processing personal data and/or who need to know them to perform their functions and develop the corporate purpose of the company.
8. VALIDITY OF THE DATABASE.
The personal data incorporated into the DISNEYLANDIA DISEÑOS S.A.S. Database. They will be in force for the period necessary to fulfill their purposes and to allow compliance with their legal and contractual obligations as a general rule, specifically the periods will be:
- Candidate information in selection processes: if it is not claimed by the candidate for three (3) months after participation in the process for which they applied, the information will be destroyed.
- Information of employees who never show up for work: if it is not claimed by the employee one (1) month after signing the contract, the information will be destroyed.
- Terminated employees: information that is regulated by special regulations such as contracts, affiliations, social security or payroll payments and others will be kept for the time indicated in each regulation; The other information will be kept for up to 6 months after the employment relationship ends.
- Clients: if the information has been obtained through security cameras, the information will be stored on one of our servers and will be kept for a maximum of 1 month. To share the information obtained by said means, there must be a violation of other rights and it must be requested by a competent authority since such filming also collects personal information from other people. The information obtained directly by the client for any commercial or contractual relationship will be stored by the standard that regulates said relationship. If the information has been received and no legal act or business is carried out, the information will be kept for a maximum of one month, after that time it will be destroyed.
- Suppliers: if the information has been obtained through security cameras, the information will be stored on one of our servers and will be kept for a maximum of xx months. To share the information obtained by said means, there must be a violation of other rights and it must be requested by a competent authority since such filming also collects personal information from other people. The information obtained directly by the supplier for any commercial or contractual relationship will be stored by the standard that regulates said relationship. If the information has been received and no legal act or business is carried out, the information will be kept for a maximum of one month, after that time it will be destroyed.
Paragraph: Once the deadlines stipulated here or the deadlines provided by law for the conservation of documents have been met, DISNEYLANDIA DISEÑOS S.A.S. will proceed with the physical and/or magnetic destruction of the information contained in its databases. PERSONAL DATA PROCESSING POLICY DISNEYLANDIA DISEÑOS S.A.S.