Legal Warning

POLICY FOR PERSONAL DATA PROCESSING AND DATA Habeas

POLIKEM SAS - NIT 890.928.929-1

Polikem SAS committed to the values ​​of respect, subject to law, reserve, confidentiality, availability, integrity and proper handling of information and especially the belief in the guarantee of fundamental rights through this development and proposal aims comply with the law 1266 of 2008 and law 1581 of 2012, regulated by decree 1377 of 2013, within which the need to adopt a Manual of Policies and Procedures to ensure compliance with that law stands, meeting the inquiries and complaints arising from the holder of personal data.

In subparagraphs d) and e) of Section 3 of Act 1581 of 2012, mention of the manager and the controller is done. SAS Polikem compliance with these two qualities simultaneously, and many of the databases that are managed, responsible for all information about personal data and agrees to guard them in the manner prescribed in this Act.

Current technologies should allow companies and / or entities management, operation and efficient storage of personal information that is used to fulfill their corporate objectives and business, solely for the purposes for which it is linked. For this reason, Polikem simplified joint stock company, is authorized to execute and deliver any civil or commercial lawful act. Notwithstanding the foregoing, its purpose will be geared primarily to the exercise of the following economic activities: The company Polikem SA was incorporated by public deed No. 01619 of notaria 8 Medellin on July 15, 1981, transformed SAS document private enrolled in the chamber of commerce of Medellin on October 3, 2011, for an indefinite term; whose main purpose is the import of machinery and raw material for the manufacture of chemical products for the automotive, plastics, metal, rubber, mainly also imports and produces detergents and other chemicals allowed by law for sale throughout the domestic or foreign markets. Polikem specializes in the design, manufacture, storage and marketing of products for automotive, industrial and home business industry; also it specializes in Anodized Aluminum, Metal surface treatment in general and Services "Outsourcing", and Maquila.

In developing the corporate purpose, shall be construed as included in the corporate purpose described above, acts, contracts and transactions directly related thereto and whose purpose is to exercise the rights or comply with legal obligations or conventionally derived from the existence or activity of the society. In general, the company may carry out on its own behalf or on behalf of third parties, all kinds of transactions, acts or contracts commercial, necessary or appropriate to achieve the goals that they pursue or which may promote or develop their activities nature or the companies in which it has interests that directly relate to the company. For the full realization of the object the company may acquire, usufructuar, encumber or limit, give or take on lease or other title, all kinds of movable or immovable property, sell it; give or take money in mutual as an ancillary activity aimed at fulfilling its corporate purpose and without financial activity is prohibited by law; encumber their movable and immovable property and to celebrate all kinds of credit operations that allow them to obtain funds and other assets necessary for enterprise development; establish subsidiary companies for the establishment and operation of companies intended to carry out any activities within the corporate purpose, and take interest as a participant, partner or shareholder, founder or not, in other companies in similar or complementary to its object, make contributions in cash or kind to those companies, sell their shares, rights or shares in them, merge with such companies or absorb them, and generally hold or execute all kinds of contracts, acts or operations movable or immovable property, commercial, which relate to medium with the objects expressed; complies with the provisions of the law that deals with habeas data and PERSONAL DATA

The fundamental right to habeas data, should guarantee citizens the power of decision and control over information assists them, use and destination of your personal data.

The right to protection of personal data of each holder extends from knowing who retains such data and use is being given to them, to define who has the ability to consult them.

The law gives the power to each holder of view, edit, delete and resume that information, and develops the guarantees and instruments to ensure the enforcement of the fundamental right.

The purpose of this manual is to enshrine internal policies to be fixed in accordance with the law 1581 of 2012 and that our condition of charge and responsible for the processing of personal data, we must implement and organize to meet a whole fully with the provisions set out in the law.

The manual covers the basics of nature and separate annexes rules and procedures schemes that allow the authorization.

Polikem SAS is established in the city of Medellin - Colombia on 16-41 CRA 43B OFFICE 1601, Email: polikem@une.net.co . - Telephone (4) 520 31 November - website: http://www.polikem.com.co

  1. PURPOSE

Polikem SAS, through this policy formalizes the processing of personal data applicable to the activities with users, customers, members, suppliers, lenders, employees, distributors, and in general, any individual holder of personal data are recorded in our databases and those of our operated, to fulfill the corporate purpose of the Bank and specifically for: (i) to comply with its obligations under the contracts and trade relations held; (Ii) Provide information about our products and services; (Iii) Conduct promotional events or commercial, social and informative our members and / or suppliers, customers, employees, distributors and other third parties; (Iv) carry out campaigns, surveys, promotions or contests commercial, social, marketing, advertising or execution of our corporate purpose; (V) loyalty programs and update customer data, members, suppliers, employees, distributors and other third parties; (Vi) report on changes in our products, prices or services; (Vii) send statements portfolio; (Viii) evaluate the quality of our products and / or services through satisfaction surveys; (Ix) collection activities, collection, inquiries, verifications, monitoring and enabling means of payment. (X) Polikem SAS may take fingerprint or use other authorized biometric mechanisms of their customers, members and / or suppliers, employees, distributors and other third parties and manage them in order to validate their identity management products and / or services purchased with society. (Xi) Polikem SAS can deliver the personal data of its customers, members, suppliers, employees, distributors and other third parties entities located in Colombia or abroad, whether public or private, as long as Sean companies or entities with which Polikem SAS is related by ties of shareholding or whether its parent, subsidiary or operated; or delivery of personal data has as its purpose the structuring, design and implementation of product offerings and / or services, or general proposals for additional value to which Polikem SAS is able to provide autonomously, or is intended to facilitate the development of the corporate purpose of Polikem SAS by outsourcing their processes, such as physical or digital file, collections, risk management, software development, contact members, market research, preparation of statistical analysis, developing business strategies and / or social marketing, social impact studies, participation in social programs including the state, establishment of new service channels, and other related and related purposes. Similarly, the personal data of customers, employees and / or members, providers or any other person whose personal data are available, will be used by Polikem SAS in order to properly forward all processes in the development of activities above mentioned and comply with regulations related to Habeas Data. The data supplied by the employees and / or service providers Polikem SAS, will aim to advance the selection process for internal recruitment. Furthermore, these data may be used by Polikem SAS during labor or delivery services or strategic linkage relationship through contracts and / or agreements; with the aim of enhancing the skills of employees, members, or linked through courses, training, workshops, etc., and to incorporate them into the different processes of welfare and benefit plans. Similarly, the personal data of employees, providers, members, customers, users, providers, managers or linked in general, will be used by Polikem SAS in order to properly forward all analysis processes credit risk and comply the regulations related to Habeas data Financial, also Polikem SAS may obtain the personal data of their employees and service providers for purposes of providing employment references or provision, membership or strategic links. Polikem SAS can deliver the personal data of its employees and service providers linked through their work, for delivery or alliance, used in the various contracts and agreements, to entities located in Colombia or abroad provided that: these are companies or entities which Polikem SAS is related by ties of shareholding or whether its parent, subsidiary or operated, or delivery of personal data has as its purpose the structuring, design and implementation of benefits and welfare schemes or selection, outsourcing the physical file or digital or general proposals for additional value to which Polikem SAS is able to provide autonomously, or is intended to facilitate employee development and management of information Polikem SAS by outsourcing their processes. IN GENERAL, Polikem SAS obtain and manage personal data supplied by its customers, affiliates, suppliers, employees, members, managers, users and generally any individual from which personal data have, for following the development of its object purposes social, as simplified joint stock company, which is authorized to execute and deliver any civil or commercial lawful act. Notwithstanding the foregoing its purpose will be mainly oriented to the exercise of the following economic activities: 1) The import of machinery and chemicals for the automotive industry, the metalworking industry in general, textile and plastics industry. 2) The import of detergents and chemicals for agriculture. 3) The distribution in the country of the products listed above. 4) The export and production of agricultural chemicals for textile, metal, paper, detergent, and rubber. 5) The provision of specialized technical services for the automotive industry in the application of the products imported and / or manufactured. 6) The importation, marketing and distribution in the country parts

domestic and foreign machine tool engineering for industrial automotive, auto parts and related assembly origin.

In developing the corporate purpose, shall be construed as included in the corporate purpose described above, acts, contracts and transactions directly related thereto and whose purpose is to exercise the rights or comply with legal obligations or conventionally derived from the existence or activity of the society. In general the Company may carry out on its own behalf or on behalf of third parties, all kinds of transactions, acts or contracts commercial, necessary or appropriate to achieve the goals that they pursue or which may promote or develop their activities nature or companies in which it has an interest and directly relate to the company. For the full realization of the object the company may acquire, usufructuar, encumber or limit, give or take on lease or other title, all kinds of movable or immovable property, sell it; give or take money in mutual as an ancillary activity aimed at fulfilling its corporate purpose and does not constitute financial activity prohibited by law; encumber their movable and immovable property and to celebrate all kinds of credit operations that allow them to obtain funds and other assets necessary for enterprise development; establish subsidiary companies for the establishment and operation of companies intended to carry out any activity within the social object, and take interest as a participant, partner or shareholder, founder or not, in other companies in similar or complementary to its object, make contributions in cash or kind to those companies, sell their shares, rights or shares in them, merge with such companies or absorb them, and generally hold or execute all kinds of contracts, acts or operations movable or immovable property, commercial, that half relate to the corporate purpose expressed

The above activities may be carried out through physical mail, email, phone, website, cell phone or mobile device, via text message, fax, social networking, surveys or through any other means widely known communication, giving compliance with the provisions of current regulations.

Polikem SAS may process personal data that you provide your customers, suppliers and other third parties with the purpose of: (i) verify compliance with Bank policies on recruitment and selection of suppliers; (Ii) verify the proper fulfillment of obligations; (Iii) satisfy legitimate interest derived from the relationship established or is planned to set; (Iv) provide or obtain commercial references and / or financial; (V) manage and operate the product or service purchased, which comprises, among other things, the handling and accounting of the operations carried out during the term of any legal relationship and all those performed for completion, closing or settlement thereof; (Vi) document the relationship and verify the implementation and enforcement of the respective contract; (Vii) verify and confirm the identity and contact; (Viii) send commercial information about the products and / or services provided Polikem SAS developing its corporate purpose; (Ix) adopt measures aimed at preventing illegal activities; and (x) delivering personal customer data employees, suppliers, partners, suppliers and third parties to entities located in Colombia or abroad, whether public or private, as long as Sean companies or entities with which Polikem SAS relates by ties of shareholding or whether its parent, subsidiary or operated; or delivery of personal data has as its purpose the structuring, design and implementation of product offerings or services, or general proposals for additional value to which Polikem SAS is able to provide autonomously, or is intended to facilitate the development the corporate purpose of Polikem SAS by outsourcing their processes, such as physical or digital file, collections, risk management, software development, contact customers, suppliers, employees, partners, suppliers, operated, people you have links members agreements and contracts, market research, preparation of statistical analysis, development of business strategies, social marketing, social impact studies, establishment of new service channels, and other related and related purposes.

Similarly, the personal data of customers, employees, service providers, members, suppliers, employees, individuals with whom alliances established in contracts and / or agreements, operated, distributors, third parties and in general, any individual holder has of personal data which are recorded in databases will be used by Polikem SAS in order to properly forward all running processes of providing health services for the community and comply this way with this manual and law 1266, 2008, 1581, 2012 statutory law and its implementing regulations.

  • DEFINITIONS

For purposes of this policy, then the definitions established by current regulations relate:

  • Authorization : prior, express and informed consent of the Contractor to carry out the processing of personal data.
  • Database: organized personal data is processed set.
  • Personal data: Any linked information or may be associated with one or more specific or identifiable individuals.
  • Processor: natural or juridical, public or private, which by itself or in association with others, perform the processing of personal data on behalf of the controller.
  • Controller: natural or juridical, public or private, which by itself or in association with others, decide on the database and / or data processing.
  • Title: Natural person whose personal data are processed.
  • Treatment: Any operation or set of operations on personal, such as collection, storage, use, movement or deletion data.
  • Privacy Notice: verbal or written communication generated by Polikem SAS to the holder of personal data, which is informed of the existence of political information processing that will be applied, how to access them and purposes of treatment that aims to give personal information.
  • Public information: It is relative to civil status of persons, to their profession or trade and as a merchant or a public servant; those who by nature are not subject to protection.
  • Sensitive data: is defined as sensitive data those affecting the privacy of the owner or whose misuse can lead to their discrimination, such as those revealing racial or ethnic origin, political orientation, religious or philosophical beliefs, trade union membership, social organizations, human rights or promote interests of any political party or to guarantee the rights ,, as well as data concerning health, sexual life, and biometric data.
  • Transfer: Data transfer occurs when Polikem SAS, located in Colombia, sends the information or personal data to a receiver, which in turn is responsible forthe treatment and is inside or outside the country.
  • Transmission: Processing of personal data that involves communicating them within or outside the territory of the Republic Polikem SAS when intended tocarry out a treatment by the Manager on behalf of SAS Polikem
  1. RIGHTS OF CHILDREN AND TEENS.

In the treatment will ensure respect for the prevailing rights of children and adolescents.

the processing of personal data of children and adolescents, except data that is public in nature is outlawed.

It is the task of the state and educational institutions of all types to provide information and train legal representatives and guardians about the potential risks to which children and adolescents are facing regarding the improper processing of personal data, and provide knowledge about responsible and safe use by children and adolescents of their personal data, their right to privacy and protection of personal information and that of others.

  1. BEGINNING

In accordance with the law, Polikem SAS will act in any collection, management and deletion of personal data in accordance with the principles to be followed in the processing of personal data and the protection of the law of habeas data, they are:

  • Legality: For treatment of personal data, SAS Polikem be subject to the provisions of the law and other provisions.
  • Purpose: Polikem SAS inform the holder the purpose of the treatment of personal data, which must be legitimate according to the constitution and the law.
  • Freedom: The processing of personal data will be exercised only with the consent SAS Polikem prior, express and informed consent of the owner; or legal or judicial mandate.
  • Accuracy or quality: The information subject to processing of personal data must be truthful, complete, accurate, current, verifiable and understandable. The treatment of partial, incomplete, split or misleading data is prohibited.
  • Transparency: Polikem SAS guarantees the holder the right to obtain at any time without restrictions, information about the existence of your data.
  • Restricted Access and Circulation: The SAS Polikem treatment given to personal data shall be subject to the provisions of the law and the Constitution.Personal data may not be available on the Internet or other mass media or mass communication, except those that are public in nature or those in which access is controlled to provide technically restricted to the owner or authorized third parties knowledge.
  • Security: The information subject to treatment by Polikem SAS, will be protected by using technical, human and administrative measures to give security to the records, avoiding adulteration, loss, see, use or unauthorized or fraudulent access.
  • Confidentiality: Persons involved in the processing of personal data that do not have public nature, are obliged to ensure confidentiality of information provided, even after their relationship ended with some of the works comprising treatment.
  1. HEADLINE

For purposes of this policy, holders of personal data is understood, distributors, employees, service providers, customers, users, suppliers and generally any natural person to whom the personal data are recorded in databases of Polikem SAS

In the case of minors (children and adolescents), their legal representatives shall have the power to authorize or not the processing of personal data. In the processing of these data, respect for the rights of minors prevalent as privacy and protection of personal information will be ensured.

  • AUTHORIZATION

For the processing of personal data by Polikem SAS, prior, and informed consent of the owner, which must be obtained by any written, physical or electronic medium that may be subject to further consultation is required; subject to the exceptions provided by law.

Polikem SAS upon request the holder authorization must inform clearly and expresses the purpose for which the personal data is collected, the treatment which will undergo their personal data, the rights of the holder and means by which you can exercise them.

For the purposes of protection of the law Habeas Data, Polikem SAS, will have prior authorization and notification to the holder, in order to be reported to the CIFIN, Datacredito and PROCREDITO Entities.

Information personal data may be provided by Polikem SAS holder, its successors, legal representative and / or agent, or third parties authorized by this or by law and public and administrative bodies exercising statutory functions or court order .

Polikem SAS will continue the processing of data contained in their databases for the purpose indicated in this policy, without prejudice to the power conferred on the holder at any time exercise their right and request deletion of the data.

  • RIGHTS

The holder of personal data and / or, what applies to the holder of the credit obligation to purchase with Polikem SAS shall be entitled to:

  • Know, update and rectify your personal data against Polikem SAS

This right may be exercised, including against partial data, inaccurate,

incomplete, split, misleading, or those whose treatment is

It prohibited or has not been authorized.

  • SAS Polikem request proof of authorization granted for the processing of personal data, unless otherwise provided by law.
  • SAS Polikem be informed upon request, concerning the use that is given to personal data.
  • SAS Polikem to submit questions and file complaints with the agency responsible for the protection of personal data.
  • Request the revocation and / or delete your personal data when Polikem SAS incurs conduct contrary to the law and the Constitution. Free and unlimited access to personal data are processed way.
  1. HOMEWORK

The holder of personal data, will keep your information and ensure, at all times Polikem SAS, the veracity of it. Polikem SAS shall not be liable in any circumstances for any kind of liability for the inaccuracy of the information provided by the owner.

  1. MANAGER RESPONSIBLE AND PERSONAL DATA PROCESSING

Polikem SAS is responsible for the processing of personal data.

Administrative and financial management, will be the area responsible for processing personal data on behalf of Polikem SAS, who will be provided with information on each employee, provider, operated, partner, customer, supplier and in general any natural person who has collected personal information and to rest in a database.

The official in charge of that area take a report from the database and will be responsible for the following functions:

  • Knowing this policy and give application that apply to them.
  • Send an email communication to each officer, employee or person within the company operate or have handled some personal data of members of the Company, in the sense that they inform the department responsible, the name and email users who have personal data.
  • Develop, address, order and / or delegate to others the establishment of measures to be taken in commercial contracts or forms and formats that deal with credit or personal data
  • Develop, address, order and / or delegate to others the establishment of measures to be taken in labor contracts
  • Inform the holder of the purpose of data collection and guarantee the exercise of his rights under the authorization granted.
  • Keep a copy of the relevant authorization granted by the holder of personal data.
  • Ensure that the information object of treatment is truthful, complete, accurate, current, verifiable and understandable.
  • Rectify cardholder information when incorrect.
  • Use only personal data that have been obtained by permission unless they do not require it.
  • Respect the security and privacy of cardholder information.
  • Upgrade, correction or deletion of personal data within five (5) working days of your receipt.
  • Allow access to information only to authorized persons.
  • Comply with the instructions and requirements given by the competent administrative authority.
  • Sign confidentiality agreements with those who manage information related to the processing of personal data.
  • timely handle inquiries and complaints made by the holders of personal data.
  • Others enshrined in law.
  • Administrative and financial management Polikem SAS shall ensure that each incorporating a new worker knowledge of this Policy as documents that complement is required. Polikem SAS, perform all contractual and legal settings for such contracts, confidentiality agreements, contractual clauses and other compliance documents is incorporated by employees, members, managers, suppliers, contractors and other third parties involved; in addition to seeking to obtain express authorization of each holder for handling personal data.
  • It is the responsibility of workers Polikem SAS report any incidents of information leakage, computer damage, violation of personal data, marketing data, use of personal data of children or adolescents without proper authorization, impersonation, or behaviors they may violate the privacy of a person, or has evidence that they are being used for criminal purposes and / or unauthorized.
  1. COLLECTION AND MANAGEMENT OF PERSONAL DATA BY Polikem SAS

This policy shall apply in cases where Polikem SAS requested the processing of link requests, surveys or forms of telephone, digital or face shape as well as the forms of assistance to events without prejudice to any special conditions which apply in each case.

From the moment the owner of the personal data authorize Polikem SAS for collection and processing of personal data, they may be used in the development of commercial and industrial activities.

Polikem SAS may use the personal data of the holder as email address, physical mailing address and / or landline number or cell phone to send advertising related to its products and services offer and contact for events and other activities.

In any case, depending on the activity undertaken, Polikem SAS will notify the holder of personal data clearly the mechanisms made available to know, update, modify and delete their data and to revoke the authorization granted.

XII. PRIVACY, CONFIDENTIALITY AND SECURITY OF PERSONAL DATA

SAS Polikem ensure holders of information, privacy, confidentiality and security of data delivered, avoiding adulteration, loss, consultation, use or unauthorized or fraudulent access by third parties.

SAS Polikem giving effect to the principle of autonomy, it reserves the right to keep and catalog information as confidential resting in their databases.

SAS Polikem adopt the technical, human and administrative measures to provide security to personal data and avoid its adulteration, loss, see, use or unauthorized or fraudulent access.

Polikem SAS states that some of their websites may contain links to third party websites on which no management or control, for this reason, is not responsible for the content privacy policies, security and / or data handling is done, personal established therein, being an obligation of the owner of the personal data found on the respective websites, policies related to the protection and treatment of your information.

On the website of SAS Polikem instructions under absolute security for each user or holder of personal data to interact with them and submit their applications to Polikem SAS, on any correction, modification and / or deletion be established.

  • AREA OF APPLICATION

Policies are applicable to databases that are under the management of Polikem SAS, or are likely to be known by it under the trade relations or development of its objects that must be applied to other entities that part of society to which it belongs, commercial alliances, agreements or publicity events, both Polikem SAS, and its operated. In the first case, Polikem SAS will act as responsible in other cases may have quality manager or responsible, depending on whether a third party or receives the collected herself.

Likewise, it shall apply where processing of the data takes place in Colombian territory. And when the controller or the processor is not resident in Colombia but under international norms and treaties will be applicable Colombian law.

  • Habeas DATA.

The Art.15 of the COP establishes the right of all people to know, update and rectify information gathered about them in databases or files both public and private entities.

Likewise, and in accordance with the Judgment C-748 of 2011 of the Constitutional Court, this right includes other powers as authorizing treatment, new data include, exclude or delete a database or file.

This right was developed jurisprudential way from 1991 until 2008, in which the Special Law of Habeas Data, which regulates what has been termed as the "habeas data finance", meaning it right that has been issued everyone to know, update and rectify your personal business, credit, and financial information contained in central public or private information, whose function is to collect, process and circulate such data in order to determine the level of financial risk of the Holder . This Special Law considers as head of information both natural and legal persons.

Subsequently, Law 1581 "General Protection of Personal Data", which develops the right of Habeas Data from a broader perspective than the above-mentioned financial and credit was issued on 17 October 2012. So that any holder of personal data has the power to control the information itself has been collected in any database or file, run by private or public entities. Under this Act, holds the natural person.

  1. NATIONAL REGISTER OF POLICIES AND / OR DATABASES

It is the public directory databases subject to treatment operating in the country, and will free consultation to citizens.

SAS Polikem perform registration policies and / or databases before the competent administrative authority, in time and place as it may establish.

  • RIGHTS HOLDERS
  1. Polikem SAS target through established channels, which are indicated in the Notice of Data Privacy, in order to know, update and rectify your personal data.This right may be exercised, among others against partial, inaccurate, incomplete, split data, misleading, or those whose treatment is prohibited or not authorized.
  2. Request proof of the authorization granted to Polikem SAS except in accordance with the law, the treatment being performed does not require it. c) Be informed by Polikem SAS on the use given to the collected personal information, request after presented through channels arranged for this purpose. d) To submit to the Superintendency of Industry and Commerce complaints for violations of the Law 1581 of 2012 and its implementing regulations. e) Revoke in cases that do not fall under the Law 1266 of 2008, authorization and / or request the deletion of data when treatment is not the principles, rights and respect constitutional and legal guarantees. f) Access free, through the channels provided by Polikem SAS, their personal data that have been processed.

Polikem SAS, through the Data Privacy Notice, report on the channels and procedures for the holder to exercise their rights effectively.

DATABASES UNAUTHORIZED information personal and sensitive data will be available for consultation and / or modifications to the databases authorized as follows :

Página web: http://www.polikem.com.co

The above databases have the necessary security mechanisms to protect data such as Backup, centralized system contingency schemes and access control profiles.

.CANALES XVII SUPPLY OF INFORMATION

Polikem SAS, establishes communication channels with the headlines:

Página web: http://www.polikem.com.co

Email: polikem@une.net.co

  • INQUIRIES AND COMPLAINTS

Inquiries and complaints to be made to Polikem SAS, should be addressed to email polikem@une.net.co If additional information, the applicant may call telephone (4) 520-11-31 or contact the CRA 43B No 16-41 OFFICE 1601 in Medellin.

  • CONSULTATIONS

Inquiries made by the holder of personal data or its assignees, will be attended by Polikem SAS, within a maximum period of ten (10) working days from receipt of the respective application, which may be extended for a maximum term five (5) working days Polikem SAS must first inform the person concerned.

XXI. COMPLAINTS

The owner or his successors consider that the information contained in the database Polikem SAS should be subject to correction, updating or deletion, or when warn the alleged breach of any of the duties under the law or this policy may file a complaint, which will be processed under the following rules:

  • The claim shall be made by writing to Management

Administrative and financial to the cardholder identification description

the facts giving rise to the claim, management, and the accompanying documents required.

  • The maximum term to address the claim will be fifteen (15) working days from the day following the date of receipt, which may be extended by a maximum of eight (8) working days when it is not possible attend the claim within this term, having the area of ​​human management inform the person concerned the reasons for the delay.
  • If the complaint is incomplete, the interested party will be required within five (5) business days after receipt of the complaint to rectify the faults. If, within two (2) months from the date of application, without the applicant submits the required information, it shall be deemed to have waived the claim.
  • If the recipient of the claim is not competent to solve, will transfer to the area responsible for a maximum term of two (2) working days and report the situation to the person concerned.
  • Before going to the agency responsible for monitoring compliance with the rules on protection of personal data, the holder must initially process your claim with SAS Polikem through the media and channels provided for this purpose.

XXII LEVEL SECURITY MEASURES APPLIED TO TREATMENT.

Polikem SAS has a "Policy Manual Information Security", forecasts contained therein ensure compliance with the requirements regarding information security.

It has been established that contracts with clauses stating managers clearly the duty of these to ensure the security and privacy of cardholder information are included.

  • APPLICABLE LEGISLATION
    • Constitution of Colombia, articles 15 and 20.
    • Law 527 of 1999
  • Law 1266 of 2008.
  • Law 1273 of 2009.
  • Enacting Law 1581 of October 17, 2012.
  • 2009.2952 decrees 1727, 2010, 1377, 2013 and 886 of 13 May 2014
  • Judgment C-748 of 2011 of the Constitutional Court
  • ENTRY INTO FORCE AND MODIFICATION

This policy shall become effective on October 1, 2016 and shall remain valid until Polikem SAS exercises its social object in Colombia, or until the law provides otherwise or different matter.

This policy may be modified at any time unilaterally by Polikem SAS, must give timely notice to the holders of personal data, such amendments.

Policies, according to instructions provided by the SVS of Industry and Trade will be published chord so established by such entity.

Controllers:

Name: Danny Ramirez Osuna,

Phone: 5201131

Email: dany.ramirez@polikem.com.co

Area: Administrative and Financial Management

______________________________

Legal representative

CARLOS D. CASTAÑEDA FIELD

CC # 3332020