Data use and collection

“THE FINANCIAL” requires collecting the following information from its customers, suppliers, contractors, employees and former employees, among others: name; home; birthdate; nationality; occupation, profession, activity or line of business to which it is dedicated; references, landline or cell phone numbers; emails. The owner of the data expressly accepts that “THE FINANCIAL” may use, obtain, compile, exchange, update, collect, process, reproduce and / or dispose of his personal data or information, partially or totally, for the purposes expressed in This Privacy Policy.

«THE FINANCIAL» through the different channels of contact with its customers, suppliers, contractors, employees and former employees, among others, such as administrative office and / or website, may collect personal data such as your full name, telephone number and e-mail that allows you to enter into subsequent contact with them, information regarding which the customer, supplier, contractor, employee and former employee, among others, as the owner of the data you provide, expressly authorizes “THE FINANCIAL” to use it according to the purpose reported here.

«THE FINANCIAL» may collect the information of its customers, suppliers, contractors, employees and former employees, among others, through third parties such as business partners, subcontractors and / or financial entities, for the purposes expressed in this Privacy Policy .

The owner of the data expressly authorizes «THE FINANCIAL» to collect the data in the terms expressed, as well as to consult, complement and update said personal data at any time, with other databases managed by an information operator, with in order to keep updated the information of its customers, suppliers, contractors, employees and former employees, among others.

Likewise, in the case of credit products, «THE FINANCIAL» is obliged to require additional data that will allow it to estimate the feasibility of payment, using an analysis based on quantitative and qualitative information, which allows establishing creditworthiness and capacity of payment, including the consultation or reporting of said information to Credit Information Companies or to third parties with whom you maintain or manifest business or commercial relationships.

Purposes of Customer Data Processing

The personal information of customers, suppliers, contractors, employees and former employees, among others, will be collected, stored, used, circulated, shared, and / or processed to:

The personal data that «THE FINANCIAL» collects will be used for the operation and registration of the products or services that you had hired or intended to hire.
Identify its customers, suppliers, contractors, employees and former employees, among others, «THE FINANCIAL» may collect their information for the execution of the labor and / or civil and / or commercial contract signed with each of them.

Maintain physical or electronic communication with its customers, suppliers, contractors, employees and former employees, among others, including the sending of information related to the labor and / or civil and / or commercial contract signed with each of them. As well as the sending of information about other services, products or goods acquired by “THE FINANCIAL”.

Achieve the purpose of contracts concluded with its customers, suppliers, contractors, employees and former employees, among others, so that they can use the services and / or goods acquired from “THE FINANCIAL”
Outsource third parties to process the information of their customers, suppliers, contractors, employees and former employees, among others, and / or to perform any other activity required by “THE FINANCIAL” in relation to the labor and / or civil contract and / or commercial subscribed with each of them.

Other purposes established in the Terms and Conditions of this Privacy Policy.

For other purposes, such as statistical and market analysis; development and improvement of services and products of «THE FINANCIAL», commercial and promotional initiatives; data update; identification and prevention of fraud, money laundering and other criminal activities; carry out regulatory controls and for market research purposes.

Likewise, «THE FINANCIAL» may use your personal data to offer, where appropriate, other financial products of «THE FINANCIAL» or any of its associated affiliates, commission agents or related companies and send you promotions of other goods or services related to cited financial products, purposes that are not essential for the fulfillment of the legal relationship that gave rise to the contracted product or service.

Customers, suppliers, contractors, employees and former employees, among others, authorize «THE FINANCIAL» to use, obtain, compile, exchange, update, collect, process, reproduce and / or dispose of their personal data or information, in a way partial or total, as well as to transfer such data or partial or total information to third parties.

“THE FINANCIAL” may contract with third parties the processing of information from customers, suppliers, contractors, employees and former employees, among others, and / or to carry out any other activity in relation to using, obtaining, compiling, exchanging, updating , collect, process, reproduce and / or dispose of the data or information of customers, suppliers, contractors, employees and former employees, among others, of «THE FINANCIAL»

Likewise, customers, suppliers, contractors, employees and former employees, among others, authorize «THE FINANCIAL» to share their data with companies with which they have commercial agreements, such as banking entities, among others, for the purposes stated above. and these third parties will be obliged to comply with all regulations and privacy policies of «THE FINANCIAL»

Likewise, with the acceptance of this Privacy Policy, customers, suppliers, contractors, employees and former employees, among others, declare that “THE FINANCIAL” can provide this information to judicial or administrative entities and government entities that exercise functions. control of your operation when there is a legal requirement for it. It also accepts that it may be subject to internal audit or external audit processes by companies in charge of this type of control.

Security and Confidentiality

To guarantee the protection of privacy, confidentiality and integrity of the information, “THE FINANCIAL” has adopted all the means, good practices and technical measures at its disposal to ensure the transmission of information to the databases and to avoid alteration, loss, misuse, unauthorized access and theft of personal data provided by Users for the purposes stated above. However, the User must be aware that the security measures are not infallible.

The information that a client enters on the website of «THE FINANCIAL» (www.kobra.red) is kept strictly confidential and is not shared with third parties other than those indicated in this Privacy Policy.

“THE FINANCIAL” will keep, under the security and confidentiality conditions described herein and for the purposes indicated in this document, the personal data of the suppliers, contractors, employees and former employees, among others, during the entire execution time of each contract labor and / or civil and / or commercial subscribed between “THE FINANCIAL” and its customers, suppliers, contractors, employees and former employees, among others, and for ten (10) more years.

Data of Children and Adolescents Under 18 Years

«THE FINANCIAL» will ensure the proper use of personal data of children and adolescents under 18 years of age, seeking to respect the best interests of those in their treatment, for the sake of respect for their fundamental rights and as much as possible , taking into account your opinion, as holders of your personal data.

Therefore, if a customer, supplier, contractor, employee and former employee, among others, provides data in such a way that it can be identified that these data correspond to a child under 18, “THE FINANCIAL” will act in accordance with what is stated here to process such data, in accordance with this Privacy Policy.

Rights of the owners:

As the holder of your personal data You have the right to:

(i) Access free of charge to the data provided that have been processed.

(ii) Know, update and rectify your information against partial, inaccurate, incomplete, fractional, error-inducing data, or those whose treatment is prohibited or has not been

authorized.

(iii) Request proof of authorization granted.

(iv) Submit complaints to the Superintendence of Industry and Commerce (SIC) for violations of the provisions of current regulations.

(v) Revoke the authorization and / or request the deletion of the data, provided there is no legal or contractual duty that prevents them from being eliminated.

(vi) Refrain from answering questions about sensitive data. The answers that deal with sensitive data or data on girls and boys and adolescents will be optional.

Data of the person in charge of the treatment.

The Responsible for the Processing of personal data will be “THE FINANCIAL”, which by itself or in association with others will decide on the database and / or the processing thereof.

Name or Social reason: _

Address or address: _

Email: _

Telephone: _

Web page: _

Person or area responsible for the protection of personal data.

The Personal Data Protection Officer will assume the function of personal data protection and will process the requests of the holders, for the exercise of the rights referred to in Law 1581 of 2012, Decree 1377 of 2013 and this policy . It can be contacted through the following means: email [email protected] or by written communication that must be filed at the following address ________________________ Switch ___, Cell _ addressed to “THE FINANCIAL”.

Personal Data Update

Any query or claim against inherent rights of the owners (A client, contractor, employee and former employee, among others), on personal data must be made through the following channels: email [email protected] or through Written statement that must be filed at the following address _____________________________ Switch ___, Cell _ addressed to “THE FINANCIAL”, attaching a photocopy of the identity document of the interested Holder or any other equivalent document that proves his identity and ownership under Law.

Likewise, the owner of the information, through the same channels, may request that they not send correspondence, or not be contacted to offer a good or service offered by «THE FINANCIAL».

Procedure for the exercise of the Rights of the Information Holders

To exercise the rights conferred by the law applicable to each person, the Client, contractor, employee and former employee, among others, may make their request to the following email address: [email protected] and the corresponding legal procedures will be followed.

It is necessary to leave proof of the following:

to. Name and identification of the data holder or the legitimate person

b. Accurate and complete description of the facts that give rise to the claim / consultation

C. Physical or electronic address to send the answer and inform about the status of the procedure

d. Documents and other relevant evidence that you want to assert.

and. Date of receipt of the query / complaint.

Once the identity of the owner is verified, the required personal data will be provided.

To consult, know, correct, update, rectify or delete the data.

• If the query and / or request made by the Data Holder is incomplete, «THE FINANCIAL» will require the interested party within five (5) days after receipt of the consultation and / or request to remedy the failures. After two (2) months from the date of the request, without the applicant submitting the required information, it will be understood that he has given up his query.

• Requests and / or consultations will be attended by «THE FINANCIAL», within a maximum term of ten (10) business days counted from the date of receipt thereof. When it is not possible to respond to the request or consultation within said term, this fact will be informed to the applicant, stating the reasons for the delay and indicating the date on which their request will be answered, which in no case may exceed five (5 ) business days following the expiration of the first term.

The deletion of personal data may not be granted by request made by the owner or his representative, when there is a legal or contractual duty for the personal data to remain in the respective database.

To rectify and delete information and / or revoke the authorization given to “THE FINANCIAL”, to process personal data

• If the application is incomplete, «THE FINANCIAL», you must request the interested party within five (5) days after receipt to correct the failures. After two (2) months from the date of the request, without the applicant submitting the required information, it will be understood that he has given up his request.

• In the event that the person receiving the request is not competent to resolve it, they will transfer to the Legal area of “THE FINANCIAL”, within a maximum period of two (2) business days and inform the interested party of the situation.

• Once the request is received, a legend that says “claim in process” and the reason for the request will be included in the Database, in a term not exceeding two (2) business days. This legend must be maintained until it is decided.

• The maximum term to meet this request will be fifteen (15) business days from the day following the date of receipt. When it is not possible to attend it within said term, the interested party will be informed about the reasons for the delay and the date on which his claim will be addressed, which in no case may exceed eight (8) business days following the expiration of the first term .

Entry into force and term

“THE FINANCIAL” reserves the right to modify this Privacy Policy at any time.

Any modification to this notice may be notified by any of the following means: a written statement sent to your home or delivered to the address of «THE FINANCIAL»; a message contained in your statement; a message sent to your email or mobile phone a message released through the email of «THE FINANCIAL»: [email protected] or any electronic means you use to carry out operations with «The Financial»; or, through messages published in newspapers of wide circulation or by any means stipulated by «THE FINANCIAL».

The last revision made to this Privacy Policy was March 11, 2019, the date from which it is applicable.

The databases in which the personal data will be registered will be valid for the time in which the information is maintained and used for the purposes described in this policy. Once that purpose (s) is fulfilled and provided that there is no legal or contractual duty to retain your information, your data will be deleted from our databases.