POLICY AND INSTRUCTION FOR THE MANAGEMENT, ADMINISTRATION AND PROCESSING OF PERSONAL DATA

OBJECTIVE

In accordance with current regulations regarding data management (Colombian Law 1581 of 2012). Allow the owner of the information the free exercise of the right to Habeas Data, the constitutional right to know, update and rectify information that has been collected in databases of public or private entities.

INFORMATION PROCESSING AUTHORIZATION

In all processing of personal data, QUIRURGICOS LTDA. meets the following requirements:

a) The Holder must give his explicit authorization to the data treatment, except in cases where it is not required by law.

b) In the event that the owner is physically or legally incapacitated, the legal representatives must grant their data authorization.

VALIDITY OF THE DATABASES

This policy applies from the date of issue. The databases will have a validity equal to the period in which the purpose or purposes of the data treatment are maintained or the period of validity that indicates a legal, contractual cause or specific activity.

TREATMENT TO WHICH THE DATA WILL BE SUBMITTED

In exercise of its corporate purpose, QUIRURGICOS LTDA. carries out the Processing of personal data of its employees, contractors, suppliers, and clients.

In development of the principles of purpose and freedom, the collection of personal data by QUIRURGICOS LTDA. is limited to thosepersonal data that are pertinent and adequate for the purpose for which they are collected or required in accordance with current regulations. Except in the cases expressly provided for in the Law, no personal data is collected without authorization from the Holder.

QUIRURGICOS LTDA. has the obligation to maintain the confidentiality of the personal data subject to Treatment and may only disclose them at the express request of the surveillance and control entities, as well as authorities that have the legal power to request the information and in those cases QUIRURGICOS LTDA. will allow them at all times and for Free to know, update and correct the personal information of the Holder in accordance with article 8 of the Colombian Law 1581 of 2012.

Data processing includes the collection, storage, administration, use, transfer, transmission, and destruction, in the manner permitted by law and is carried out with the following specific purpose for each case:

  1. Processing of personal data of employees and former employees: It is carried out to comply with the labour obligations incharge of QUIRURGICOS LTDA., Such as payroll payments, opening of bank accounts, control of access to the company,payments and reports to the general system of social security, affiliations and news to Family Compensation Funds and / or Pension and Severance Fund Administrator. Attention to inquiries, requests, requests, actions, and claims, made by the Holder of the information or by her heirs, or by entities of the general social security system to which the Holder is or has been linked.
  2. Treatment of personal data, of contractors, who provide services in QUIRURGICOS LTDA. facilities, comply with the contractual obligations under their responsibility, such as assignment and control of technological elements, materials, equipment, identification of income, monitoring of compliance with obligations in charge of Contractors, attention to eventual emergencies, response to queries, requests, requests, actions and claims, made by the Owner of the information or by his heirs.
  3. Treatment of personal data of Suppliers: allows the fulfilment of contractual obligations in charge of QUIRURGICOS LTDA. , such as payment of fees, invoice payments, payment reports, quotes, reports or interactions that by law or by internal policies it has the obligation to carry out , attention to queries, requests, requests, actions and claims made by the owner of the information orby his heirs.
  4. Treatment of personal data of Clients: it has the purpose that QUIRURGICOS LTDA. can comply with the contractual obligations under its charge, such as billing, collections, quotes or interactions that by law or by internal policies it has the obligation to carry out, attention to queries, requests, requests, actions and claims, made by the owner of the information or by his heirs.
  5. Treatment of personal data of Members: it is for the purpose of QUIRURGICOS LTDA. to control their participation in the company.

RIGHTS OF THE HOLDERS

Holders of personal data have the following rights:

  1. Know, update, and rectify your personal data in front of the Treatment Managers. This right may be exercised, among others, against partial, inaccurate, incomplete, fractioned, misleading data, or those whose Treatment is expressly prohibited or has not been authorized.
  2. Request proof of the authorization granted to the Data Controller except when expressly excepted as a requirement for the Treatment, in accordance with the provisions of Article 10 of Colombian Law 1581 of 2012.
  3. Be informed by the Treatment Manager or the Treatment Manager, upon request, regarding the use that has been given to your personal data.
  4. Present before the Superintendence of Industry and Commerce complaints for infractions to the provisions of this law and the other regulations that modify, add, or complement it.
  5. Revoke the authorization and/or request the deletion of the data when the treatment does not respect the principles, rights, and constitutional and legal guarantees. The revocation and/or deletion will proceed when the Superintendence of Industry and Commerce has determined that in the Treatment the Responsible or Person in Charge have incurred in conduct contrary to the Constitution and the law.
  6. Free access to your personal data that have been subject to Treatment.

PROCEDURE FOR THE EXERCISE OF RIGHTS BY THE HOLDERS.

Holders of personal data should direct their inquiries, requests or claims to the email treatmentdatos@quirurgicosltda.com

TEMPORARY LIMITATIONS TO THE PROCESSING OF PERSONAL DATA

QUIRURGICOS LTDA. may only carry out the Processing of personal data for as long as necessary, in accordance with the purposes that justified the Processing, taking into account the applicable provisions and the administrative, labor, accounting, tax, legal and historical aspects of the information.