Privacy Policy

Deeploy S.A.S., identified with NIT 900.953.171-5 (hereinafter “Deeploy” or the “Company”), respects the privacy of the Company’s users (hereinafter the “Users”) and is committed to protecting personal data, as defined in the applicable regulations, to which it may have duly authorized access granted by the data owner (the “Personal Data”) through this website (hereinafter the “Website”) and/or other available digital channels where authorized collection of Personal Data is carried out.

In accordance with the provisions of Law 1581 of 2012, Decree 1081 of 2015, and other regulations that add, complement, and/or modify them, Deeploy presents this privacy policy and personal data processing (hereinafter the “Privacy Policy and Personal Data Processing”).

Data Controller Identification:

Principles:

To guarantee the protection of personal data, the Company will apply the following principles harmoniously and integrally, under which the processing of Personal Data will be carried out:

  1. Legality: The processing of Personal Data is a regulated activity, subject to current and applicable legal provisions.
  2. Purpose: The processing of Personal Data by the Company or to which it has access will serve a legitimate purpose in accordance with the Colombian Political Constitution, which must be informed to the respective data owner.
  3. Freedom: The processing of Personal Data can only be done with the prior, explicit, and informed consent of the data owner. Personal Data cannot be obtained or disclosed without prior authorization or in the absence of legal, statutory, or judicial mandate that overrides the consent.
  4. Transparency: In the processing of Personal Data, the Company will guarantee the data owner the right to obtain information at any time and without restrictions about the existence of any information or personal data of their interest.
  5. Restricted Access and Circulation: The processing of Personal Data is subject to the limits arising from their nature, Colombian law, and the Colombian Political Constitution. Therefore, processing can only be done by authorized persons and/or as provided by Colombian law. Personal Data, except for public information, cannot be available on the internet or other mass communication means unless access is technically controllable to provide restricted knowledge only to the data owners or authorized third parties according to Colombian law. The Company’s obligation in these purposes will be means-based.
  6. Security: The information subject to processing by the Company must be handled with necessary technical, human, and administrative measures to ensure the security of records and prevent their adulteration, loss, unauthorized or fraudulent consultation, use, or access.
  7. Confidentiality: All persons in the Company who administer, manage, update, or access information in databases are obligated to guarantee the confidentiality of the information. They commit to keep and maintain it strictly confidential and not to disclose it to third parties, except for activities expressly authorized by the applicable data protection law. This obligation persists even after the end of their relationship with any tasks comprising the processing.

Personal Data Processing:

Personal Data will be subject to the following processing:

  • Collection, reception, transmission, and/or transfer in applicable and duly authorized cases.
  • Digital and/or physical storage as applicable.
  • Use, circulation, and/or suppression.
  • Backup creation.

The processing described herein will be carried out in accordance with applicable legal provisions and solely for the purposes outlined in this Privacy Policy and Personal Data Processing.

Purposes of Personal Data Processing:

Deeploy will process Personal Data for the following purposes: a. Provide information about services offered, requested, and/or duly contracted by the data owner, such as quotations, guides, and support. b. Deliver the Company’s services and follow up according to the User’s specific needs to provide appropriate services and products to cover their specific and contracted needs. c. Improve the Website and the services offered by Deeploy. d. Send marketing communications through authorized and deemed pertinent channels, including newsletters, promotional offers, satisfaction surveys, among others. e. Analyze Website usage. f. Disclose, transfer, and/or transmit Personal Data to service providers operating the Website who will comply with applicable personal data protection regulations. g. Disclose, transfer, and/or transmit Personal Data in the event of a merger or acquisition involving the Company. h. Disclose, transfer, and/or transmit Personal Data to parent companies, affiliates, or subsidiaries and/or third parties that comply with all legal and operational personal data protection requirements. i. Perform internal processes within the Company for operational development and/or system administration purposes.

Rights of Personal Data Owners:

The data owner will have the following rights: a. Know, update, and rectify their Personal Data with the Data Controllers or Processors as defined in applicable regulations. This right can be exercised, among others, against partial, inaccurate, incomplete, fragmented data that leads to error, or data whose processing is explicitly prohibited or has not been authorized. b. Request proof of the authorization granted to the Data Controller, except when expressly exempted as a requirement for processing, in accordance with applicable regulations. c. Be informed by the Data Controller or Processor, upon request, about the use of their Personal Data. d. File complaints with the Superintendence of Industry and Commerce for violations of the relevant regulations. e. Revoke authorization and/or request the deletion of Personal Data when the processing does not respect constitutional and legal principles, rights, and guarantees. Revocation and/or deletion will proceed when the Superintendence of Industry and Commerce has determined that the processing by the Data Controller or Processor involves conduct contrary to this Colombian law and the Colombian Political Constitution. f. Access their Personal Data free of charge that has been processed.

Channels, Procedures, and Responsible Area:

Any questions or exercise of any of the rights of Personal Data owners provided in the relevant regulations and described in this Privacy Policy and Personal Data Processing can be addressed to the following channels:

The Personal Data owner must follow the procedure described below:

  1. Prove their status as the Personal Data owner in the following ways:
    • By the owner, who must sufficiently prove their identity by various means made available.
    • By their successors, who must prove such status.
    • By stipulation in favor of another or for another.
  2. Provide a complete and accurate description of their question or exercise of any rights they hold as the Personal Data owner.
  3. Provide a sufficient notification address for the Company to send the response.

The area responsible for everything related to this Privacy Policy and Personal Data Processing will be the Company’s Legal Department. The response will be provided by the responsible area no later than fifteen (15) business days following receipt of the communication.

Security:

Deeploy takes all reasonable precautions and legally pertinent measures to protect Users’ Personal Data against unauthorized access, disclosure, hacks, information leaks, alteration, and/or destruction. The Personal Data owner acknowledges, accepts, and expressly declares that Deeploy will not be responsible for any hacks and/or information leaks that may occur in databases storing Personal Data, resulting in unauthorized access, disclosure, alteration, and/or destruction of their Personal Data, among others.

The Personal Data owner is solely responsible for all information and data they authorize for processing. Therefore, the Personal Data owner declares and guarantees to hold harmless Deeploy, its employees, directors, representatives, and licensees from any damage (direct, indirect, incidental, consequential, or punitive), claim, loss, obligations, and/or expenses that may arise from any situation related to their Personal Data.

Adjustments and Changes to the Privacy Policy and Personal Data Processing:

Deeploy may update this Privacy Policy and Personal Data Processing when deemed appropriate. Any changes will be published on this Website. The Company recommends periodically reviewing this Privacy Policy and Personal Data Processing to stay informed about any updates. Adjustments, changes, and/or updates will follow all applicable legal provisions.

Effective Date of the Privacy Policy and Personal Data Processing and Database Validity Period:

The effective date of this Privacy Policy and Personal Data Processing is December 2016.

Deeploy has implemented Privacy Policies and Personal Data Processing since the issuance of Law 1581 of 2012 and subsequently with the issuance of Decree 1377 of 2013 and Decree 1081 of 2015.

The databases in which Personal Data will be stored will be valid as long as Personal Data is maintained and used for the purposes described in this Privacy Policy and Personal Data Processing.