Personal data processing policy
GENERAL
This policy is defined in accordance with the entry into force of Statutory Law 1581
of 2012, the purpose of which is to dictate the general provisions for data protection
personal data and develop the constitutional right that all persons have to know,
update and rectify the information that has been collected about them in databases or
archivos así como el derecho a la información; por tanto PACIFIC DMC, teniendo en
Considering his status as responsible for the processing of personal data that assists him, it is
allows the formulation of this text in order to effectively comply with said regulations and in
especially for the attention of queries and claims about the treatment of personal data
personnel who collect and handle PACIFIC DMC.
The right to HABEAS DATA is the one that every person has to know, update and rectify the
information that has been collected about it in files and data banks of a public nature or
private and guarantees all citizens decision-making power and control over their information
staff. Therefore, PACIFIC DMC accepts such provisions, taking into account that for the
development of its corporate purpose, it is continuously compiling and carrying out various treatments
to databases of customers, shareholders, suppliers, business partners and employees.
By virtue of the foregoing, within the legal and corporate duty of PACIFIC DMC to protect
the right to privacy of people, as well as the power to know, update or request the
information that is filed on them in databases, PACIFIC DMC, has designed the
This policy for the management of personal information and databases in which it is
describes and explains the treatment of Personal Information to which you have access through
our website, email, physical information (strips), text messages, text messages
voice, App, telephone calls, face to face, physical or electronic means, current or in the future
are developed as other communications sent as well as through third parties that
participate in our business or legal relationship with all of our customers, employees,
suppliers, shareholders, strategic and related allies.
This will be adjusted to the extent that the regulations are regulated
applicable to the matter and new provisions enter into force.
GENERAL OBJECTIVE
With the implementation of this policy, it is intended to guarantee the reservation of the
information and security about the treatment that will be given to it to all
customers, suppliers, employees and third parties of whom PACIFIC DMC has
legally obtained information and personal data in accordance with the guidelines
established by the regulatory law of the right to Habeas Data. Also, through the
issuance of this policy complies with the provisions of literal K of article
17 of the aforementioned law.
DEFINITIONS
1. Authorization: Refers to the prior, express and informed consent of the Owner to
what
PACIFIC DMC, or its Managers carry out the Data Processing
Owner’s personal
2. Owner: natural person whose data is processed by the company.
3. Database: They consist of an organized set of Personal Data that are
object of Treatment, and includes physical and electronic files. The databases of
property of PACIFIC DMC, are detailed in section VI of these
policies.
4. Personal data: information that is linked to a person. is any piece of
information linked to one or more determined or determinable persons or that
may be associated with a natural or legal person. Personal data can be
public, semi-private or private.
5. Treatment: It is any operation or set of operations on Personal Data
carried out by PACIFIC DMC or the Treatment Managers on behalf of the
sales such as collection, storage, use, circulation or disposal.
6. Person in charge of the treatment: natural or legal person, public or private, who by itself
itself or in association with others, carries out any processing of personal data on behalf of
of the data controller.
7. Responsible for the treatment: natural or legal person, public or private, who by itself
itself or in association with others, decide on the database and/or the treatment of the
data.
8. Public Data: Personal Data classified as public by law or the Political Constitution.
Are public, among others, the data related to the marital status of people, their profession
or trade, in his capacity as a merchant or public servant.
9. Semi-private data: Semi-private data that does not have an intimate, reserved nature, or
public and whose knowledge or disclosure may be of interest not only to its owner but also to a certain
sector or group of people or society in general, such as financial and credit data
of commercial activity.
10.Private data: It is the data that due to its intimate or reserved nature is only relevant for
the owner.
11. Sensitive Data: Personal Data whose use affects the privacy of the Holder or whose use
may generate their discrimination, such as those that reveal the racial origin
ethnicity, political orientation, religious or philosophical convictions, membership of
unions, social organizations, human rights or that promote interests of
any political party or that guarantee the rights and guarantees of political parties
of opposition as well as data related to health, sexual life and biometric data
12. Privacy Notice: It is the physical, electronic or any other document
format, generated by PACIFIC DMC that has been made available to the Holder
for the Treatment of your Personal Data, which communicates to the Holder the information
regarding the existence of the Personal Data Processing Policies that will be
applicable, the way to access them and the characteristics of the Treatment that is
intends to give Personal Data.
13. Transfer: Consists of sending Personal Data to a recipient who, in turn,
is responsible for the Treatment under the terms of Law 1581 of 2012.
14. Transmission: It is the communication of Personal Data to the Treatment Manager,
inside or outside the territory of the Republic of Colombia, with the purpose of carrying out
of a treatment by the person in charge of quality systems.
RIGHTS THAT ALL DATA HOLDERS HAVE AGAINST THE COMPANY
PERSONAL
Any process that involves treatment by any area of the company of
personal data of both customers, suppliers, employees and in general any
third party with which PACIFIC DMC maintains commercial and labor relations
must take into account and inform you expressly and in advance, by any means of the
which a record of compliance can be kept, the rights that assist you to
that owner of the data, which are listed below:
1. Right to know, update, rectify, consult your personal data at any
moment in front of PACIFIC DMC, regarding the data that it considers partial,
inaccurate, incomplete, fractional and those that lead to error.
2. Right to request at any time a proof of the authorization granted to
PACIFIC DMC.
3. Right to be informed by PACIFIC DMC, upon request of the owner of the
data, regarding the use that has been given to them.
4.Derecho a presentar ante la Superintendencia de Industria y Comercio las quejas que4. Right to submit to the Superintendence of Industry and Commerce the complaints that
consider relevant to assert your right to Habeas Data against the company.
5. Right to revoke the authorization and/or request the deletion of any data when
consider that PACIFIC DMC has not respected your rights and guarantees
constitutional.
6. Right to free access to personal data that you voluntarily decide
share with PACIFIC DMC, for which the company in aid of Management
of Informatics and Technology, is in charge of conserving and archiving safely and
the authorization forms of each of the holders of personal data are reliable
duly granted.
CASES IN WHICH THE COMPANY DOES NOT REQUIRE AUTHORIZATION FOR THE
PROCESSING OF THE DATA YOU HAVE IN YOUR POSSESSION
1. When the information is requested from the company by a public entity or……………………………. ………………………………………………………. ………………………………………………………. ………………………………………………………. ………………………………………………………. ………………………………………………………. ………………………………………………………. ………………………………………………………. ………………………………………………………. ………………………………..
administrative authority that is acting in the exercise of its legal functions or by order
judicial.
2. When it comes to data of a public nature because they are not protected by
the scope of application of the rule.
3. Duly proven medical or health emergency events.
4. In those events where the information is authorized by law to fulfill purposes
historical, statistical and scientific.
5. In the case of data related to the civil registry of people due to the fact that
This information is not considered as data of a private nature.
TO WHOM INFORMATION MAY BE DELIVERED BY THE COMPANY WITHOUT
NEED TO HAVE THE AUTHORIZATION OF THE DATA HOLDERS
To the owners of the data, their heirs or representatives at any time and at
through any means when requested to PACIFIC DMC.
To judicial or administrative entities in the exercise of functions that raise some
request to the company for the information to be delivered.
To third parties that are authorized by any law of the Republic of Colombia.
To third parties to whom the Data Owner expressly authorizes to deliver the information
and whose authorization is delivered to PACIFIC DMC.
DUTIES THAT THE COMPANY HAS WITH RESPECT TO THE HOLDERS OF THE DATA
PACIFIC DMC acknowledges that personal data is the property of the owners
of the same and that only such persons may decide on them. In this
sense, will make exclusive use for those purposes for which it is empowered in the
terms of the law and for the sake of the foregoing, it is allowed to inform the duties that it assumes in
your capacity as data controller:
1. The company must find the means through which to obtain the express authorization
by the owner of the data to carry out any type of treatment.
2. The company must clearly and expressly inform its customers, employees,
providers and third parties in general from whom the treatment to which the data is obtained
to which they will be subjected and the purpose of said treatment. to which they will be subjected and the purpose of said treatment.
must design the strategy through which for each event, mechanics or request for
data that is carried out, will inform them of the respective treatment in question.
Some of these means may be sending text messages, filling out
physical formats, through the PACIFIC DMC websites, among others.
3. The company must inform the owners of the data for each case, the nature
optional to respond and provide the respective information requested.
4.In all cases in which data is collected, the rights that you have
assist all owners regarding their data.
5. The company must inform the identification, physical or electronic address and telephone number of
the person or area that will have the quality of data controller, within the
which may have the web page of http://www.PACIFICTRAVEL.CO and the Customer Service offices of the
company PACIFIC DMC, or email info@pacifictravel.co
6. The company must guarantee at all times to the holder of the information, the full and
effective exercise of the right to habeas data and petition, that is, the possibility of
know the information that exists about him or rests in the data bank, request the
update or correction of data and process queries, all of which will be done by
through the mechanisms for consultations or claims provided for in this policy.
7. The company must keep the data records with due security
personal stored to prevent deterioration, loss, alteration, unauthorized use
or fraudulent and periodically and timely update and rectify the
data, each time the holders of the same report news or requests.
PURPOSES IN THE CAPTURE, USE AND PROCESSING OF PERSONAL DATA
PACIFIC DMC, in the development of its corporate purpose and its relations with third parties,
understood by these clients, employees, suppliers, creditors, strategic allies,
subsidiaries, subordinates among others; constantly collects data to carry out various
purposes and uses within which can be framed:
. Administrative, commercial, promotional, informative, marketing and sales purposes.
. Offer all kinds of commercial services; as well as carry out promotional campaigns,
marketing, advertising.
. Search for closer knowledge with all its customers, suppliers,
employees and related third parties.
In relation to the above, PACIFIC DMC may execute the following actions:
1.Get, store, compile, exchange, update, collect, process, reproduce
and/or have the data or partial or total information of those owners who
grant the due authorization in the terms required by law and in the formats that
for each case deemed appropriate.
2.Classify, order, separate the information provided by the owner of the data.
3. Carry out investigations, compare, verify and validate the data obtained in due
form with credit risk centers with which they have commercial relations.
4. Extend the information obtained under the terms of the habeas data law, to the
companies with which it contracts the services of capture, storage and management of its
databases prior to the due authorizations obtained in this regard.
5. Transfer the data or partial or total information to its affiliates, businesses, companies and/or
affiliated entities and strategic allies.
THE AUTHORIZATION
In order to carry out the aforementioned purposes, PACIFIC DMC,
requires free, prior, express and duly informed authorization by
part of the owners of the data and for this purpose it has provided suitable mechanisms
part of the owners of the data and for this purpose it has provided suitable mechanisms
authorization. It may be recorded in any medium, be it a physical document,
electronically or in any format that guarantees its subsequent consultation through
technical and technological tools and information security developments.
The authorization is a declaration that informs the owner of the data the following
information:
. Who is responsible or in charge of collecting the information
. Data collected
. Purposes of the treatment
. Procedure for the exercise of the rights of access, correction, updating or
data suppression
. Information on the collection of sensitive data.
DATA COLLECTED BEFORE THE ISSUANCE OF DECREE 1377 OF 2013
For the purposes of complying with the provisions of article 9 of Law 1581 of 2012,
Those responsible for the processing of personal data will establish mechanisms to
obtain the Authorization of the owners or of whoever is legitimated in the
terms of the Law. These mechanisms may be predetermined through means
technicians that facilitate the holder its automated manifestation. The Authorization may
The Authorization may (i) In writing, (ii) Verbally
or (iii) Through unequivocal conduct of the owner that allows to conclude in a
reasonable person who gave the authorization. In no case can silence be assimilated to a
unequivocal conduct.
Likewise, in accordance with the provisions of article 10 of Decree 1377 of 2013,
PACIFIC DMC, will publish in newspapers with wide national circulation, the notice of
privacy through which I communicate the existence of this policy, informing the
with respect to the Superintendence of Industry and Commerce. As indicated in this
Decree, if within thirty (30) business days from the implementation of the
previous mechanism, the holders did not contact the RESPONSIBLE or IN MANAGER to
request the deletion of your personal data, the RESPONSIBLE and MANAGER may
continue carrying out the Processing of personal data contained in their databases
data for the intended purpose or purposes indicated in the data processing policy
la información.
PROTECTION OF PERSONAL DATA OF MINORS AND ADOLESCENTS
Pursuant to the provisions of Statutory Law 1581 of 2012 and the Regulatory Decree
1377 of 2013, PACIFIC DMC, ensures that the Processing of personal data
of children and adolescents will be carried out respecting their rights, which is why,
in the commercial and marketing activities carried out by PACIFIC DMC, you must
have the prior, express and informed authorization of the father or mother or the
legal representative of the child or adolescent.
FORM OF PROCEEDING WITH RESPECT TO THE INQUIRIES AND REQUESTS MADE BY THE
DATA OWNERS
Every owner of personal data has the right to make inquiries and submit requests to the
company regarding the management and treatment given to your information.
A). PROCEDURE FOR THE PROCESSING OF CLAIMS OR REQUESTS:
Any request, request, complaint or claim (PQR) that is presented to
PACIFIC DMC, by any owner or their successors in title with respect to the
handling and treatment given to your information will be resolved in accordance with the law
regulation to the right to habeas data and will be processed under the following rules:
1. The request or claim will be made in writing or any other means
defined in this policy for this purpose, addressed to PACIFIC DMC, with the
identification of the holder, the description of the facts that give rise to the claim, the
address or means through which you wish to obtain your response, and if applicable,
accompanying the supporting documents that you want to enforce. In case the
writing is incomplete, the company will request the interested party to correct the faults
within five (5) days of receipt of the claim. after two months
from the date of the request, without the applicant submitting the required information,
it will be understood that the claim or request has been withdrawn.
2. Once the complete petition or claim is received, the company will include in the registry
individual in a term not exceeding two (2) business days a legend that says “claim in
procedure” and the nature of it. Such information must be kept until the
claim is decided.
3. The applicant will receive a response from PACIFIC DMC, within
ten (10) business days from the date on which you had
effective knowledge of the request.
4. When it is not possible to meet the request within said term, the
concerned, stating the reasons for the delay and indicating the date on which the
your request, which in no case may exceed five (5) business days following the
expiration of the first term.
B. INQUIRIES:
The PACIFIC DMC Personal Information Management Policy, and
the basic rights that the owners of the data have in relation to it may
be consulted through the following means:
http://www.PACIFICTRAVEL.CO info@PACIFIC DMC, Servicio al cliente.
Any query that a holder has about his information or personal data or when
considers it necessary to initiate a request for information or considers that your rights
have been violated in relation to the use and handling of your information; you can do it to
through the following email: info@pacifictravel.co
If within the ten (10) designated days, it is not possible for the company to meet the
consultation, the corresponding area must inform the interested party, the reasons for the delay
consultation, the corresponding area must inform the interested party, the reasons for the delay
five (5) business days following the expiration of the first term.
C. RESPONSIBLE FOR THE TREATMENT:
PACIFIC DMC, has the quality of data controller, through the
This policy allows you to inform your identification data:
Company name: PACIFIC DMC
RTN: 67212
Person or agency responsible for handling requests, queries and claims: the
The area in charge of receiving and channeling all requests and concerns is the
Quality Department via email info@PACIFIC DMC
D. PROCESSOR OF THE TREATMENT:
Eventually, PACIFIC DMC may have the quality of MANAGER OF THE
TREATMENT, in which case the identification data is as follows:
Company name: PACIFIC DMC
RTN: 67212
Person or agency responsible for handling requests, queries and claims: the
The area in charge of receiving and channeling all requests and concerns is the
Quality Department via email info@PACIFIC DMC
COMPUTER SECURITY POLICIES
For PACIFIC DMC, it is essential and a priority to adopt technical measures,
legal, human and administrative that are necessary to ensure the safety of the
personal data protecting the confidentiality, availability, integrity,
unauthorized and/or fraudulent use, access. Likewise, it is allowed to inform that
Internally, the company has implemented mandatory security protocols
compliance for all personnel with access to personal data and to the
information systems.
The internal security policies under which the owner’s information is kept for
prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access, are
the following:
1. Policies in the perimeter technological infrastructure in the data network (System of
intrusion prevention (IPS), Firewalls, secure mail, content control, control of
network access NAC and antivirus).
2. Policies in the technological infrastructure and access control policies to the
information, applications and databases (security modules).
3. Technological implementation policies that protect computers and servers
of the organization
4. Technological implementation policies that support the information contained in the
different platforms.
5.Written policy on information security and use of security tools
información.
6. Confidentiality agreement with suppliers and third parties.
7. Confidentiality clause in employee employment contracts.
8. Self-control procedures and response to Internal and External Audit.
9.In all the events that are carried out, in which customer information is captured,
includes the Habeas data paragraph, with its respective implications.
10.Habeas Data Notice. By participating in the Event, all participants declare
know and authorize in a free, prior, voluntary, express and duly informed manner
PACIFIC DMC to collect, record, process, disseminate, compile,
exchange, update and dispose of the data or partial information that you provided, and
for the purpose of participating in the Event; as well as to transfer said data or information
partially or totally to its shops and companies in order that PACIFIC DMC can
offer your products and/or services to your customers in a more personalized and
directly, and also to contact the person in case of turning out to be the winner of the
Event, to send advertising information of own brands, mailing, sms,
direct mail and, commercialize all the data and information that voluntarily
provided at the time of participating in the Event. The use of the database will be
from the start of the Event until the day PACIFIC DMC goes into liquidation.
PACIFIC DMC guarantees that it complies with data protection
PACIFIC DMC guarantees that it complies with data protection
regulation of the right to HABEAS DATA, for which it is allowed to inform:
1.That the right of habeas data is the one that every person has to know, update and
1.That the right of habeas data is the one that every person has to know, update and
databases of a public or private nature.
2. That the client, as the owner of the information, may access their data at any
moment, for which you can modify, correct, update, revoke and request
proof of the authorization given if you consider it so through this means or through the
PACIFIC DMC Customer Service office.
3. That the client, as the owner of the information, has the power or not to report those
data freely available and to submit requests regarding the use that has been given
to your data.
4. That for the full and effective exercise of this right by all its clients,
PACIFIC DMC has provided the following means through which you can
Submit your requests and/or complaints and/or claims: info@pacifictravel.co.
Sincerely:
PACIFIC DMC
