In Before Communication S.A.S. henceforth Before Communication or the agency is managed responsibly and respectfully all information provided by customers and individuals who contact the agency, either personally, by email, phone call, WhatsApp, social networks or by the use of the website and its diverse functionalities for the acquisition of the service.
This document emphasizes the compliance with the predetermined provisions in the Colombian Law, particularly in decree 1377 of 2013 in order to ensure the fundamental right of habeas data and everything established by Law 1581 of 2012. Likewise, its purpose is to comply with the provisions of paragraph k) of article 17 of Law 1581 of 2012, which refers to the adoption of an internal manual of policies and procedures to ensure the proper attention to complaints and the appropriate treatment of information.
Before Communication is responsible for the processing of personal data acquired either in processes of advice, consultation, negotiation, contracting and/or customer loyalty.
2. Treatment and Purpose
The personal data and information collected by Before Communication will be used to:
- Keep communication with the owners.
- Carry out market studies and research that lead to continuous improvement of the service.
- Promote the service with the owners through digital channels.
- Comply with laws and regulations that prevent risks such as fraud, money laundering and terrorism financing.
3. Data Acquisition
Before Communication will expressly request the necessary data and among others:
- Names and Surnames
- Company Name (if applicable)
- Identification Number or Company Tax Identification Number (if applicable)
- Address (if applicable)
- Phone Number
- Cell Phone Number (Applies WhatsApp)
- Needs and Interests for the Service
All kind of information that is collected in Before Communication, is carried out by administrative, operational and/or commercial staff through face-to-face meetings, telephone calls, emails or other digital communication channels such as WhatsApp, chat and/or social networks.
Likewise, Before Communication collects data and information through events, surveys, business proposals, business applications, business cards, magazines, business and/or academic programs, and research of digital channels with open information open the public*, and by third parties that manage legal databases.
Before Communication will not carry out the collection of data considered sensitive as political, religious, sexual, philosophical inclinations or data related to personal health, racial or ethnic origin and according to the provisions of Law 1581 of 2012.
According to the provisions of Law 1581 of 2012 and regulatory decree 1377 of 2013, the collection, storage and use of personal data must have a process that evidences the authorization and prior consent of the owner to carry out the processing of personal data.
Each owner and legal person that contacts Before Communication, authorizes the agency to store personal data and information related to processes of negotiation, contracting and customer loyalty, in the way that the agency considers it and complying with reasonable security standards for the protection of data and information.
Before Communication takes the necessary security measures to protect personal data and information in order to prevent adulteration, loss, inappropriate uses and unauthorized access. To carry out security management, the agency implements administrative, operational and computer security protection measures that are reasonable and within the scope of the internal policies of the agency.
Similarly, all third parties that are contracted by Before Communication, are bound to adhere to and comply with information security policies and manuals, as well as to have defined information security protocols and processes. Likewise, any agreement of the agency with third parties that compromises the processing of personal data and information implies the attachment of a confidentiality agreement, which specifies the commitments of third parties with everything related to protection, care, security and the preservation of confidentiality, integrity and privacy of all personal data and information.
All information stored in Before Communication’s database will be kept indefinitely with the aim of carrying out contact for processes of updating, advice, consultation, negotiation, contracting and/or customer loyalty with owners. Likewise, the owners have the right to demand the correction or elimination of data and information as stipulated in point 11 of this policy.
8. Professional Ethics
Before Communication manages the storage and processing of data in a professional way, and they are regulated as follows:
Legal and Risk: Before Communication is in the duty to cooperate with the authorities specialized in data protection and national security.
9. Rights and Duties of Owners
Before Communication informs that according to the current legislation, the owners have among others, the right to know, update, rectify the information, and/or eliminate the authorization for the treatment. In particular, the rights of the owners as established in article 8 of Law 1581 of 2012 are:
- To Know, update and rectify personal data.
- To request evidence of the authorization granted.
- To be informed, by request, regarding the use given to the personal data.
- To submit complaints to the Superintendencia de Industria y Comercio for infractions of the provisions of the Law.
- To revoke the authorization and request the elimination of the data.
10. Duties of Before Communication
Being responsible for the information, Before Communication is aware of the responsibility and the importance of managing policies and control processes that protect the data of the owners and the authorized use. Before Communication will make use of personal data for the purposes expressed to the owner at the time of advice, consultation, negotiation and/or contracting of the service or for those that were authorized, committing to:
- Keep the information under security measures to avoid adulteration, loss, inappropriate uses and unauthorized access.
- Manage and process the requests of owners in the response time established by law.
- Allow access to information only to personnel authorized by Before Communication under a confidentiality agreement.
- Report to the Superintendencia de Industria y Comercio violations of information security processes.
11. Information Query Process and Request for Correction, Update or Elimination
The owners may carry out a query process about the management of the information by written means through the following email firstname.lastname@example.org
Requirements: When presenting a query request, the owners must present their personal data. This is verified by Before Communication with the aim of avoiding risks that violate the protection of the information stored by the agency.
Response: Before Communication will respond to all requests in a period of 7 working days from the reception of the request in the email mentioned above.
Request for Correction, Update or Elimination
The requests for correction, update or elimination will be addressed immediately once the agency have contact with them, either by email, phone call or personally.
Database: Organized set of personal data that is subject to treatment.
Personal Data: Any information linked to or associated with one or several legal persons determined or determinable.
Sensitive Data: Information that affect the owner’s privacy or whose inappropriate use may generate discrimination.
Responsible: Legal person, public or private, that by itself or in association with others, perform the processing of personal data on behalf of the controller.
Owner: Legal person whose personal data are subject to treatment.
Treatment: Any operation or set of operations such as collection, storage, use, circulation or deletion.