General policy for the treatment of personal information
According to the provisions of Law 1581 of 2012 and its Regulatory Decree 1377 of 2013, the company HORBATH TECHNOLOGIES S.A.S. declares and adopts this policy for the processing of personal information, which is made available to all holders of the data collected or that in the future will be obtained in the exercise of commercial, labor and operational management of the company.
1. Identification of the data controller
Organization Name: HORBATH TECHNOLOGIES S.A.S.
Address and domicile: HORBATH TECHNOLOGIES S.A.S. has its main domicile in the city of Barranquilla, at Calle 77b #57-103 Office 505 Torre 2 Centro Empresarial Green Towers.
E-mail: info@horbath.com
Website: horbath.com
Phone number: (57-5) 3517330
2. Purposes and processing of personal data.
It is our commitment to protect the personal data of our stakeholders within the framework of transparency, good relations, business ethics and trust with them.
User information collected and stored by HORBATH TECHNOLOGIES S.A.S., is used for the analysis and implementation of requirements leading to the development, support of applications and software solutions and data analytics for informative, statistical or commercial purposes and other services provided by HORBATH TECHNOLOGIES S.A.S.
Additionally, it is used for recruitment and personnel selection purposes and for the search of a closer knowledge with customers, suppliers, employees and related third parties.
HORBATH TECHNOLOGIES S.A.S. will develop activities aimed at protecting the right to disclosure of personal information that the user voluntarily provides when subscribing or contracting HORBATH TECHNOLOGIES S.A.S. services or registering on the website.
HORBATH TECHNOLOGIES S.A.S. may not use the information collected in each of the computer applications or contained in the databases provided by customers, without their express authorization.
HORBATH TECHNOLOGIES S.A.S. is prohibited from transferring personal information about the user to third parties, as this could result in a deviation from the purpose for which the personal data was provided by the owners. The above, unless prior written authorization documenting the consent of the owner of the personal data.
HORBATH TECHNOLOGIES S.A.S. will take preventive measures, whether administrative, technical or physical, to protect the information from loss, theft or misuse, as well as from unauthorized access, disclosure, modification or destruction of the owner's data.
Confidentiality clauses will be implemented with customers, critical suppliers and employees to protect corporate information.
HORBATH TECHNOLOGIES S.A.S. is obliged to use the information to which it has access by virtue of its functions or contractual relationship, exclusively for the exercise of these functions.
All persons involved in the processing of personal data are obliged to guarantee the confidentiality of the information, even after the end of their relationship with any of the tasks involved in the processing of such data.
There are organizational processes documented in this manual for the treatment of personal data, in which activities and responsible parties are defined. There are specific procedures for the attention of queries and claims of personal data.
HORBATH TECHNOLOGIES S.A.S. will inform, in advance, the persons interested in participating in a selection process, the rules applicable to the processing of personal data provided by the interested party, as well as those obtained during the selection process.
When HORBATH TECHNOLOGIES S.A.S. contracts personnel selection processes with third parties, it will regulate in the contracts the treatment to be given to the personal data provided by the interested parties, as well as the destination of the personal information obtained from the respective process.
The personal data and information obtained from the selection process regarding the personnel selected to work in HORBATH TECHNOLOGIES S.A.S., will be stored in the personal folder, applying to this information the pertinent security measures.
Upon termination of the employment relationship, whatever the cause, HORBATH TECHNOLOGIES S.A.S. will proceed to store the personal data obtained from the selection process and documentation generated in the development of the employment relationship in a central file, subjecting such information to the relevant security measures.
HORBATH TECHNOLOGIES S.A.S. will only receive from its suppliers the data that are necessary and relevant for the purpose of selection and execution of the contract.
HORBATH TECHNOLOGIES S.A.S. will collect from its suppliers the personal data of its employees, which are necessary and relevant, that for security reasons must be analyzed, according to the characteristics of the services contracted with the supplier.
When HORBATH TECHNOLOGIES S.A.S. provides data of its employees or customers to its suppliers, the suppliers must protect the personal data provided, in accordance with the provisions of this guideline. HORBATH TECHNOLOGIES S.A.S. will verify that the data requested is necessary and relevant to the purpose for which the request for access to the data is made.
3. Data Subject Rights
The owner of the data can know in full and free of charge their personal data, as well as update and rectify them in front of HORBATH TECHNOLOGIES S.A.S.
The owner of the data can know the use that has been given to their personal data, upon request to HORBATH TECHNOLOGIES S.A.S.
The owner of the data may request proof of the authorization granted to HORBATH TECHNOLOGIES S.A.S. except when expressly exempted as a requirement for processing, in accordance with the Law.
The owner of the data may revoke the authorization and/or request the deletion of the data when the treatment does not respect the principles, rights and constitutional and legal guarantees. The revocation and/or suppression will proceed when the Superintendence of Industry and Commerce (SIC) has determined that in the treatment, HORBATH TECHNOLOGIES S.A.S. has incurred in conduct contrary to this Law and the Political Constitution.
4. Person or area responsible for attending to requests, inquiries and complaints.
For the purpose of exercising their rights to know, update, rectify and delete information, revoke authorization, among others; the owner of the data can go to HORBATH TECHNOLOGIES S.A.S. as responsible for the treatment by email: info@horbath.com, where each request, query or complaint will be processed in a timely manner by a collaborator provided by the organization for this purpose.
The owner of the data may file complaints with the Superintendence of Industry and Commerce for violations of the provisions of Law 1581 of 2012.
5. Policy Validity
This policy was approved on October 21, 2016, with first revision on June 20, 2017, second revision on March 15, 2022 and third revision on October 4, 2023, it is available to any interested party, the databases of customers, suppliers and collaborators have also been revised on the same date.