Privacy Notice
In accordance with the applicable data protection regulations, below you will find all the relevant information about how we process the personal data you share with us. This Privacy Notice is prepared in accordance with the Constitution of the Republic of Ecuador, the Organic Law on Personal Data Protection ("LOPDP") and its Regulation (hereinafter jointly referred to as "PDP Regulations"), as well as the Constitution of the Republic of Colombia, Statutory Law 1581 of 2012 and its implementing rules.
1. Data controller
AXESNET S.A.S. (hereinafter ALDEAMO) with NIT 830.015.727-2 has its domicile in Bogotá, carrera 17 A No. 106-30, tel. +57 1 6291066, email pqrs@aldeamo.com.
ESTRATEGIAS MOVILES ECUADOR ESTRAMOVEC S.A., with RUC 1792318440001, is responsible for the Processing of Personal Data. Its contact details are:
- Domicile: Guayaquil
- Telephone number: 046012295
- Email: pqrs@aldeamo.com
Both entities act as controllers of personal data processing and guarantee its protection, confidentiality, security and appropriate use. Through the contact channels previously indicated, you may make inquiries, requests or claims related to the processing of your personal information.
2. Purposes for which your personal data will be processed
We will process your personal data for the following contractual purposes:
A. Purposes — client database
- Communicate offers of products and/or services that have been requested by the client.
- Safekeeping of offers, contracts and documents of the commercial relationship.
- Send relevant, update, advertising and other market-related information about our services and/or products.
- Manage information or contact requests, to handle requirements regarding personal information related to the client, among others.
- Determine and assess the effectiveness of our communications for advertising purposes.
- Conduct satisfaction and perception surveys.
- Access or download guides, reports, exclusive material and access to or recordings of webinars.
- Comply with tax regulation requirements regarding the prevention of money laundering and the financing of terrorism, or for other legal reasons, which involve searching databases and requesting information.
- Process requests, petitions, complaints, claims and other means of action proposed by clients.
B. Purposes — prospective client database
- Communicate offers of products and/or services requested by prospective clients.
- Safekeeping of offers and confidentiality agreements.
- Send relevant, update, advertising and other market-related information about our services and/or products.
- Manage information or contact requests, to handle requirements regarding personal information related to prospective clients, among others.
- Access or download guides, reports, exclusive material and access to or recordings of webinars.
- Process requests, petitions, complaints, claims and other means of action proposed by prospective clients.
C. Purposes — employee and human-resources database
- Carry out activities related to staff recruitment.
- Manage the human talent area and develop personnel selection processes.
- Carry out actions related to the training and profiling of our employees or prospective employees.
- Evaluate performance and other performance indicators.
- Manage social benefits for our employees.
- Make available to our team the IT, work-organization and other tools determined by ALDEAMO.
- Make publications in magazines, videos, albums, brochures and/or on websites, as informational media, directly related to and/or managed by ALDEAMO.
- Make publications, in the form of data messages, on the various social networks and other digital media where ALDEAMO has a presence.
- Send communications, in the form of congratulations or announcements, through corporate email and other ALDEAMO social networks, for reasons related to academic, personal, sporting and/or professional achievements, among others.
- Communicate the participation of ALDEAMO and its team in social, cultural and/or sporting initiatives promoted or supported by the organization.
- Process requests within the organization.
- Publish images and professional data in the human-talent tools accessed by the group's staff, from Peru, Ecuador, Bolivia, Panama, Costa Rica, El Salvador, Mexico, Guatemala, Nicaragua, Honduras, the Dominican Republic and Colombia.
D. Purposes — supplier database
- Manage the commercial, supply, cooperation and, in general, business relationship.
- Verify and control the processes and the quality of the service provided by the supplier.
- Comply with tax regulation requirements regarding the prevention of money laundering and the financing of terrorism, or for other legal reasons, which involve searching databases and requesting information.
- Safekeeping of contracts, confidentiality agreements and other documents of the commercial relationship.
- Carry out audits, verifications and/or compliance surveys.
3. Legal bases for processing personal data
ESTRATEGIAS MOVILES ECUADOR ESTRAMOVEC S.A. processes personal data to fulfill the detailed purposes on the basis of the following legal grounds: execution of pre-contractual measures or performance of contractual obligations, consent of the data subject, legitimate interest, and compliance with legal obligations.
4. Data we collect
We process only the data necessary for each of the purposes identified above. For the purposes mentioned above, we will process the following categories of personal data:
A. Data included in the client database
- Identification: username (created by the user), initial service access password, document type (citizenship ID, passport, foreigner ID in the case of foreigners), photo of the identity document (if applicable), identification number, date and place of issue of the identity document, expiry date of the foreigner ID, first name(s), last name(s), domicile and residential address (including department, municipality, postal code), telephone, email, or voice recordings.
- Professional and employment: category or job position of the contact person.
- Economic and financial: bank details, signatures appearing on contracts or offers.
- Commercial: activities or businesses, subscriptions to publications or media.
- IP address: a set of numbers that logically and hierarchically identifies a network interface of a device, which may therefore be identifying data at the geolocation level.
B. Data included in the prospective client database
- Identification: first name(s), last name(s), telephone, email.
- Professional and employment: category or job position of the contact person.
- Commercial: activities or businesses, subscriptions to publications or media.
C. Data included in the employee and human-resources database
- Identification: first name(s), last name(s), citizenship ID, social security number, domicile, residential address, telephone, email, photographs or voice recordings.
- Personal: date and place of birth, age, marital status, family data, blood type and RH, clothing and shoe size.
- Academic and training: academic record, education and qualifications.
- Professional and employment: professional experience, category or position to be or already performed by the worker, the worker's professional record, EPS, AFP, ARP, severance fund administrator.
- Economic and financial: bank details, income, earnings, credits, loans, guarantees, pension plan, retirement.
- Health: processing containing health-related data, referring exclusively to the degree of disability or the simple declaration of the disability or incapacity status of the affected person, for the purpose of complying with public duties.
- Judicial: judicial record or history, sanctions, judicial proceedings.
- IP address.
D. Data included in the supplier database
- Identification: first and last names, citizenship ID, passports/foreigner ID, domicile and address, telephone, email, RUT.
- Professional and employment: company where they work, category or position, telephone, experience certificates, training and qualification certificates, payroll-contribution certificate.
- Economic and financial: bank details, income.
- Commercial: activities or businesses, subscriptions to publications or media, artistic, literary, scientific or technical creations.
5. Rights of data subjects
Data subjects, by themselves or through their representative and/or attorney-in-fact, may exercise the following rights:
- Right to information: the data subject must be informed about the processing of their personal data.
- Right of access: they may access the personal data under the control of ESTRATEGIAS MOVILES ECUADOR ESTRAMOVEC S.A., free of charge and whenever there are substantial modifications to this Privacy Notice.
- Right to update and rectify: request that their inaccurate or incomplete personal data be rectified or updated, presenting the corresponding supporting documents.
- Right to erasure: request the deletion of their personal data when the processing does not comply with the principles of the LOPDP, is not necessary or relevant, the purpose has been fulfilled, the retention period has expired, it affects fundamental rights, consent has been revoked, or there is a legal obligation to delete it.
- Right to object: request that their personal data not be processed when third-party rights are not affected, the processing is for direct marketing, or their consent is not necessary due to a legitimate interest.
- Right to portability: obtain their personal data in a compatible, structured, common, interoperable and machine-readable format, or have it transferred to another controller when technically possible.
- Right to suspension: request that processing be suspended when the accuracy of the data is contested, the processing is unlawful, the data is no longer necessary for ALDEAMO but is for you, or you have objected to the processing while the legitimacy of the grounds is verified.
- Right not to be subject to decisions based solely or partially on automated assessments: request reasoned explanations, submit observations, request the assessment criteria of the automated program, information about the types of data used and their source, and challenge the decision.
6. Exercising rights in Colombia
ALDEAMO has established a procedure so that data subjects can: access, free of charge, the data that has been processed; request proof of the authorization granted; file complaints with the Superintendence of Industry and Commerce (SIC) for possible infringements of the applicable regulations; revoke the authorization and/or request the deletion of their personal data, provided there is no legal or contractual duty preventing its deletion; know, update and rectify their information with respect to partial, inaccurate, incomplete or fragmented data; and refrain from answering questions about sensitive data (optional, including that of children and adolescents).
The way to exercise these rights will be to send a request to our email address pqrs@aldeamo.com or on our website, in the petitions, complaints, claims and suggestions link, indicating: full name and last names, identification number, contact details, means to receive a reply, the reason(s)/event(s) giving rise to the claim with a brief description of the right you wish to exercise, and signature (if applicable).
The maximum term provided by law to resolve your claim is fifteen (15) business days, counted from the day following the date of its receipt. When it is not possible to address the claim within that term, the interested party will be informed of the reason for the delay and the date on which the claim will be addressed, which in no case may exceed eight (8) business days following the expiry of the first term.
Once the terms indicated by Law 1581 of 2012 and the other rules that regulate or complement it have been met, a data subject who is denied, totally or partially, the exercise of their rights may bring their case to the attention of the Superintendence of Industry and Commerce, in the Deputy Office for the Protection of Personal Data.
7. Exercising rights in Ecuador
The way to exercise these rights will be to send a request to our email address pqrs@aldeamo.com, or physically to the address: Guayaquil / Tarqui / Av. Joaquín Orrantia and Av. Leopoldo Benítez.
We will address your request within the term provided by the applicable regulations. Within five (5) days of receiving your request, we may ask you to clarify or expand the information provided, and you will have a term of ten (10) days from the day following receipt of our notice to clarify or expand your request. Should you fail to do so within the established time, we will archive it, without this preventing you from submitting a new request.
In the event that we do not address your request within the established term, or you have reason to believe that your rights have been violated by the response provided, you may file a claim with the Personal Data Protection Authority. You may also revoke the consent granted by submitting a request at the addresses indicated.
8. Refusal by the data subject to provide personal data
Should you choose to refuse to provide your personal data, or object to the processing, we will not be able to assist you with your requirements, since we will not be able to process your personal data.
9. Erroneous or inaccurate data
Providing us with erroneous or inaccurate personal data has an impact on the fulfillment of the purposes detailed in this Notice, and therefore we will not be able to assist you with your requirements. You will be solely and exclusively responsible for ensuring that the personal data you provide is true, complete and up to date.
10. Retention period
We will retain personal data for as long as necessary to fulfill the purposes indicated in this Notice, and for as long as necessary to comply with legal or contractual obligations, unless we must store it for a longer period by virtue of a legal, contractual or judicial obligation (tax, accounting, legal or audit matters, or until the statute of limitations for legal actions). Once the indicated period has been met, we will delete your personal data from our systems, or anonymize it.
11. Transfers of personal data
We share your personal data with those third parties with whom we have a legal, contractual or judicial obligation to do so in order to fulfill the processing purposes. Likewise, personal data may be communicated to related companies or commercial partners. In the event that such communications imply an international transfer, third parties will be required to comply with appropriate standards of confidentiality, availability, integrity and resilience, especially when the transfer is made to countries or organizations that do not have an adequate level of protection.
12. Cookies
The website of ESTRATEGIAS MOVILES ECUADOR ESTRAMOVEC S.A. uses cookies for its operation and to provide you with a personalized experience. In addition, cookie information will be used to analyze pages visited and searches performed, and to improve commercial and promotional initiatives, including the display of advertising or promotions. You may configure the use of cookies in your browser.
13. Related policies
This Privacy Notice relates to the following documents: Personal Data Processing Policy, Terms and Conditions and Cookie Policy.
14. Updates to this Notice
We will review this Notice periodically, so it is subject to modifications or updates in line with reforms to the applicable regulations, or resolutions issued by the Personal Data Protection Authority. Before using the Website, we recommend reviewing this Notice to read its content, as well as its modifications.
15. Mechanisms to access the Data Processing Policy
The data subject can access our Information Processing Policy, published at www.aldeamo.com, or request the current document at the email address pqrs@aldeamo.com.