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Privacy Policy

DOUBLE DOME S.A.S., in compliance with Law 1581 of 2012, Decree 1377 of 2013, in Colombia, and in order to safeguard the fundamental rights to the exercise of habeas data, personal and family privacy, freedom of information, and good name, implements this Personal and/or Sensitive Data Protection Policy for the mandatory and comprehensive compliance by all employees of the organization.

PRINCIPLES

INTEGRITY. DOUBLE DOME S.A.S. will always act within the ethical frameworks of the Organization, promoting the protection of human rights, especially those related to privacy, the exercise of habeas data, and freedom of information.
 

CONFIDENTIALITY. DOUBLE DOME S.A.S. and all natural or legal persons, public or private, involved in commercial, administrative, and labor activities that entail the processing of personal and/or sensitive data are required to guarantee the confidentiality of the information, except in cases where the information is public in nature or is necessary for the development of activities of the same nature, and only when authorized by the data controller. (See Confidentiality Agreement and Authorization for the Processing of Clients, Suppliers, and Employees’ Personal Data).
 

PRINCIPLE OF FREEDOM. Personal and/or sensitive information will always be subject to review, modification, cancellation, and removal from DOUBLE DOME S.A.S.’s databases by the users themselves, or when the organization determines that a fundamental right of the data subject is being violated or is at risk, except in cases where the information is subject to a public nature process.
 

LEGITIMACY. The processing of information, when the organization acts as data controller or data processor, will be subject to the provisions of the Political Constitution, Statutory Law 1581 of 2012, Decree 1377 of 2013, the Colombian Technical Standard (N.T.C.), ISO 27000, and other national and international regulations governing the protection of personal and/or sensitive data.
 

INFORMED CONSENT. Data processing can only be carried out with the prior, express, and informed consent of the data subject. The data controller must certify such consent through the Confidentiality Agreement and Authorization for the Processing of Clients, Suppliers, and Employees’ Personal Data. This does not apply to personal and/or sensitive information related to minors in connection with activities of a public nature, for which consent from the data subject will not be required at any stage of the processing.
 

DATA PURPOSE. The processing of personal and/or sensitive data must pursue a legitimate purpose in accordance with the Constitution and the law. This purpose must be informed to the data subject by DOUBLE DOME S.A.S. in cases where it is the data controller, and by the data controller in cases where the organization is the data processor. The purpose must be recorded in supporting documents such as the Confidentiality Agreement and Authorization for the Processing of Clients, Suppliers, and Employees’ Personal Data.
 

DATA QUALITY OR VERACITY. Personal and/or sensitive data for which DOUBLE DOME S.A.S. is responsible must be truthful, complete, accurate, up-to-date, verifiable, and understandable. In cases where DOUBLE DOME S.A.S. is the data processor, it is the obligation of the data controller to certify that the data meets these conditions. Processing partial, incomplete, fragmented, or misleading data is prohibited. The Senior Management designates the Administrative Management as the party responsible for sensitive information belonging to Business Partners, Employees, and other stakeholders.
 

AVAILABILITY. The data subject may, at any time and without restrictions, obtain information about their data for which DOUBLE DOME S.A.S. is responsible or which it holds for the development of its corporate purpose, in accordance with Law 1581 of October 17, 2012.
 

RESTRICTED ACCESS AND CIRCULATION. Personal and/or sensitive data stored in the databases of DOUBLE DOME S.A.S. will be used by the organization solely for the purposes and with the authorization granted by the data subject or certified by the data controller. Therefore, such data cannot be accessed, transferred, assigned, or disclosed to third parties without prior authorization.
ersonal data under the custody of DOUBLE DOME S.A.S. may not be made available on the Internet or any other mass communication medium, unless access is technically controlled and secure, and restricted to the data subject or authorized third parties, in accordance with the law.
 

DATA RETENTION PERIOD. Once the purpose of the activity for which the personal and/or sensitive data was collected and/or processed has been fulfilled, DOUBLE DOME S.A.S. must cease its use and adopt the necessary security measures for such purpose, except in cases where the data controller authorizes retention for the purpose of reporting to competent authorities within the organization’s corporate purpose.
 

DATA SECURITY. DOUBLE DOME S.A.S., whether acting as data controller or processor, will adopt the necessary physical, technological, and/or administrative security measures to ensure the integrity, confidentiality, and availability of personal and/or sensitive data, as outlined in the Confidentiality Agreement and Authorization for the Processing of Clients, Suppliers, and Employees’ Personal Data.
 

SPECIAL PROTECTION OF SENSITIVE DATA. In accordance with the classification of personal and/or sensitive data, DOUBLE DOME S.A.S. has high-level security measures to mitigate the risk of alteration, loss, leakage, consultation, unauthorized use, or fraudulent access to sensitive data.
 

RIGHTS OF DATA SUBJECTS

  1. Right of Access – The data subject may, at any time, access free of charge their personal data that has been processed.

  2. Right to Update – The data subject may request the update of their data at any time when it has undergone any modification.

  3. Right to Rectification – The data subject may request modification of inaccurate, incomplete, or non-existent data.

  4. Right to Erasure (Cancellation) – The data subject may request the erasure of personal and/or sensitive data when it is excessive, irrelevant, or when the processing is contrary to the law.

  5. Right to Revoke Consent – The data subject may revoke their consent for data processing at any time, except in cases where the information is used for public activities or as provided by law.

  6. Right to Object – The data subject may object to the processing of their personal and/or sensitive data, except when used for public purposes or as mandated by law.

  7. Right to File Complaints and Claims – The data subject may submit complaints and claims to DOUBLE DOME S.A.S., the Superintendence of Industry and Commerce, or any competent entity.

  8. Right to Authorize Data Processing – Authorization is not required in specific legal exceptions such as when requested by public entities, for public data, public activities, emergencies, or for historical, statistical, or scientific purposes, among others established by law.
     

DUTIES OF DOUBLE DOME S.A.S.

  • Guarantee the full and effective exercise of the right to habeas data.

  • Maintain security conditions to prevent alteration, loss, or unauthorized access to data.

  • Update, rectify, or delete data in a timely manner as required by law.

  • Handle consultations and claims in accordance with legal terms.

  • Report security breaches to the Superintendence of Industry and Commerce.

  • Ensure disaster recovery procedures for databases containing personal and/or sensitive data.

  • Keep accurate and updated records of all databases containing personal data.
     

PROCEDURE FOR THE EXERCISE OF RIGHTS

DOUBLE DOME S.A.S. has procedures in place to ensure the exercise of the rights to information, access, update, rectification, cancellation, and opposition by data subjects.

If you believe that DOUBLE DOME S.A.S. has used your data contrary to the authorization granted or applicable laws, you may contact us in writing at daniela.carrascal@double-dome.com.

Data subjects may also exercise their rights by sending their request to: daniela.carrascal@double-dome.com.

The maximum response time for any complaint or claim will be fifteen (15) business days from the date the request is submitted, in accordance with Article 18, paragraph d) of Law 1581 of 2012.

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