Policies of protection, confidentiality, privacy and processing of personal data
COPLIQUIDO, S.A.S with NIT 901.571.730-6 with main address in the city of Bogotá, D.C., Colombia, as stated in the certificate of existence and legal representation issued by the Bogotá Chamber of Commerce, and hereinafter referred to as "Liquido".
The purpose of this document is to inform you about the type of personal data we collect from you, the purposes of the processing, the transfers we may make and the options you have to exercise the rights of access, rectification, cancellation and opposition provided for in the Personal Data Legislation.
Liquido is a legally constituted commercial company, which in the development of its corporate purpose collects and manages personal information. Therefore, it recognizes the importance of the security, privacy and confidentiality of the personal information of its customers, employees, candidates, suppliers, shareholders, allies and all those Holders of whom the processing of personal data is exercised by Liquido.
The purpose of this Personal Data Protection and Processing Policy (hereinafter "the Policy") is to ensure compliance with the laws 1581 of 2012, law 1266 of 2008 and the regulatory decrees that add, modify, supplement or replace, in accordance with the criteria of general scope developed by judgments C-1011 of October 16, 2008 and C-748 of 2011 of the Constitutional Court that carried out the prior control of statutory laws, against the data we collect. In addition to defining the guidelines for the attention of consultations and Complaints of the Holders of Personal Data on which Liquido carries out some type of Processing.
The protection of the information collected by Liquido is very important. That's what this is about. which is why precautions and measures are taken to protect your information. Liquido will guarantee access to the Policy at all times and will make a special effort in the complete and timely attention of the consultations and claims that may be formulated by the different Holders.
The Policy is mandatory for Liquido, its directors, directors, employees, employees, Related Entities and other third parties who represent or act for this purpose, or with whom Liquido has some kind of relationship, whether legal, commercial or conventional.
The policy is aimed at all individuals or legal entities that make use of the services offered by Liquido.
Liquido may need to update or modify the Policy, which will be informed to users through the https://www.liquido.com/. If it is necessary that you renew your consent through an email that will be sent informing you how these changes were and to be able to update your registration.
It should be noted that acceptance of the Policy is not mandatory, but if you do not have the authorization to process the data, Liquido will not be able to access the information or consult it for the purposes indicated below, so there will be services that will not be available to users, However, these are accepted, we will have understood that they have been read, understood and accepted in full.
Liquido, you must obtain from Helder your prior, express and informed authorization to collect and process your Personal Data. This obligation is not necessary in the case of public data,such as existing public data in the Chambers of Commerce (Article 26 of the Commercial Code). By this virtue, Liquido informs the Owner of the Personal Data clearly and expressly the Policy.
In the development and implementation of the Policy, the following principles will be applied in a harmonious and integral manner:
- a) Principle of Legality: The privacy and confidentiality policy was constructed in accordance with the content of Law 1581 of 2012 and the other rules or provisions issued and applicable by the respective control bodies within the Colombian jurisdiction.
- b) Principle of Purpose: The treatment we give personal information has a legitimate purpose in accordance with Colombian law, these purposes are indicated below.
- c) Principle of Freedom: The processing we give to the data can only be exercised with prior consent, express and informed, with the acceptance of the Policy that we confirm such consent. Personal Data may not be obtained or disclosed without the prior consent of the Owner, or in the absence of a legal or judicial mandate that relieves consent.
- d) Principle of Truth or Quality: The information subject to treatment must be true, complete, accurate, up-to-date, verifiable and understandable. The processing of partial, incomplete, fractional, or misleading data is prohibited, so if the processing of the information is accepted, but this information has inconsistencies that the submitted request may be refused. Reasonable steps should be taken to ensure that the data is and, when requested by Helder or when Liquido so determines, are updated, corrected or deleted, if applicable.
- e) Security Principle: The information subject to the Processing must be treated with the technical, human and administrative measures necessary to grant security to records that prevent their tampering, loss, consultation, use or unauthorized or fraudulent access.
- f) Principle of Confidentiality : All information sent, disclosed or consulted will be confidential.
- g) Principle of Limitation of Collection: Only personal data strictly necessary for the fulfillment of the purposes of the Processing must be collected, so that the registration and disclosure of data that are not closely related to the purpose of the Processing is prohibited.
- h) Principle of Temporality: Personal Data will be kept only for the reasonable time and necessary to fulfill the purpose of the Processing and the legal, contractual or instruction requirements of the surveillance and control authorities or other competent authorities. In order to determine the end of the Treatment, the rules applicable to each purpose and the administrative, accounting, tax, legal and historical aspects of the Information.
- i) Principle of Transparency: In the Processing must be guaranteed the right of the Holder to obtain at any time and without restrictions, information about the existence of data concerning him.
- j) Principle of Access and Restricted Circulation: Access to Personal Data will only be allowed to the Holder, to persons who, by court order or court order, are authorized to know the information of the Holder and the persons authorized by the owner.
To make the content of the policy more understandable, we want to inform you of the definition that should be given to each of the words that are part of the document:
- a) Acceptance/Authorization: Prior, express and informed consent of the owner of the personal data for the processing of personal data.
- b) Database: Organized set of personal data subject to electronic processing or not, whatever the modality of its formation, storage, organization and access.
- c) Client: Natural or legal person with whom Liquido has established relationships with legal or contractual origin, for the provision of products or services, in Development of its corporate purpose.
- d) Consultation: Request of the Holder of personal data, of the persons authorized by him,or those authorized by law, to know the information that rests on it in the NET Databases.
- e) Personal data: Any information that may be associated with or linked to one or more natural persons.
- f) Private personal data(s): These are the data that, by its nature, is only relevant to the user who owns it.
- g) Public personal data: These are the data classified as such in accordance with the mandates of the law or the Political Constitution and all those that are not semi-private, private or sensitive. Public data includes, but is not, data relating to people's civilian status, profession or trade, and their status as a merchant or public servant. This data may be obtained and offered without reservation and regardless of whether it refers to general, private or personal information.
- h) Semi-private data: One that is not of an intimate, reserved or public nature and whose knowledge or disclosure may be of interest not only to its owner, but to a particular sector or group of persons or society in general; such as financial and credit data of the commercial activity.
- i) Sensitive data: Those that affect the privacy of the Holder or whose misuse may generate discrimination, such as those that reveal racial or ethnic origin, political orientation, religious or philosophical convictions, membership of trade unions, social organizations, human rights or that promote the interests of any political party, among others.
- j) Person responsible for Processing: Natural or legal person, public or private, who alone or in association with other people, performs the processing of personal data on behalf of the controller.
- k) Related Entities: These are the legal entities with which Liquido has a strategic or commercial contractual agreement and b) those in which Liquido has a direct stake or control, affiliates or subsidiaries.
- l) Source: It is this channel that allows access to information.
- m) Complaint: Request of the Owner of the data or persons authorized by him or by law to correct, update or delete his Personal Data or when it is noticed that there is an alleged violation of the data protection regime.
- n) Procedure Requirement: Prior step that must be taken by the Holder before submitting a complaint to the Superintendence of Industry and Commerce. This consists of a claim directly to the Data Processor or Responsible for the processing of your Personal Data.
- o) Controller: Natural or legal person, public or private, who by himself or in association with other people, decides in the database and/or in the processing of data.
- p) Third parties: They are individuals whose personal or sensitive data are recorded, processed and/or managed by the owner.
- q) Holder: Natural person whose personal data are subject to processing.
- r) Transmission: Processing of personal data that allow the communication of the same inside or outside the territory of the Republic of Colombia when it is intended to carry out a Processing by the Controller on behalf of the Controller.
- s) Transfer: Processing of Personal Data that occurs when the Data Controller and/or Personal Data Processor sends the Personal Data to a recipient, who in turn is responsible for the processing and is located inside or outside the country.
- t) Processing: Any operation or set of operations on personal data, such as collection, storage, use, circulation, deletion, among others.
- u) User: It is the natural or legal person who, without being a customer, uses the services of Liquido.
3. Type of information collected
Liquido, you can obtain information directly from the Holders or from different sources of individuals, customers or users, as well as their employees and suppliers, through the use of our website, or when there is a business relationship, oral laboratory or provision of services with us.
We may obtain information, during the processing, redemption and clearing of transactions carried out with payment instruments and through any of the channels we enable for this purpose. Similarly, we obtain information from companies using Liquido products or services, publicly available information systems, database operators, and commercial information services.
The types of personal data we collect are:
- Contact information: Such as first and last name, type number and id, address and email address and phone number.
- Information collected through the services provided by Liquido related to the services that the user receives from Liquido.
- The credit or debit card number and expiration date of the card, bank account number and expiration date, and, in the case of sellers or companies, business category and certain information about sales and transaction volume.
- Information about your transactions with credit cards and debit cards or electronic wallets: such as the value of the transaction, date and time, place or company where the transaction was made, the description provided by the seller about the goods and services purchased, the type of payment method used, the description of the reason for the transaction, and the offer associated with the transaction (if any), and your purchase or payment history.
- Information on buying habits and payment behavior: age, date of birth, gender and family, stratum or socioeconomic situation.
- Mobile Device Data: Such as computer model, operating system version, unique identifiers, and data about mobile network, IP address, geographic location, or physical location, including phone number and telecommunications service provider.
- Information collected from you through third-party verification services related to the use of third-party payment methods to which Liquido is linked.
- Personal information of Liquido employees, personal information of candidates for any position or job at Liquido.
- Liquido is authorized to confirm the veracity of personal information by going to public entities, specialized companies or risk centers, their contacts or the employer, as well as their personal, banking or work references, etc.
Sources of information
- a) The information disclosed: In the process of registering on the Liquido platform or when the required form is completed, personal and slightly financial information is provided; also in some processes documentation is requested that supports the veracity of the information, these documents usually contain information or data are sources of information
- b) Indirect sources of information when using our services: During registration or transactional processes, information relating to market preferences, payment habits, payment history on transactions, merchants from which they buy frequently, etc. are accessed indirectly.
- c) Cookies: When you enter the Liquido website or make use of transactional services, the information known as cookies is temporarily stored on the computer, this allows better traceability to tastes or habits, allowing you to provide a better service. There are features that can only be opened on the computer through cookies, however, these can be excluded from the tools available in different browsers.
- d) Third party information providers: Liquido may obtain information through third parties in order to verify the authenticity of the requested transaction, this information may be sociological, geolocation or financial when the transaction requires, in the same way, when the registration of the companies refers, Liquido may consult restrictive lists or blacklists in order to avoid the risk of Money Laundering and Terrorist Financing by provision of the law.
- e) Through registered companies: It is possible that through payment orders generated directly by merchants we obtained personal information without consent, therefore, it is necessary to always check with suppliers or in the online store in which it is intended to purchase, the privacy and confidentiality protection policy, since, in this case, the person responsible for the handling and confidentiality of the information are commercial establishments because they were the Recipients.
4. Treatment of information and purpose
Liquido, you can perform the Processing of Personal Data, which may include, but is not sure, the collection, storage, updating, use, circulation, transfer, transmission and deletion of Personal Data. This Treatment can be performed by physical, automated or digital means according to the type and form of information collection.
Personal Data will be used by Liquido for the purposes set forth in the Policy, Liquido may transfer, transmit or disclose them outside our Databases when:
- a) is necessary to allow our contractors, suppliers or agents to provide the services we entrust to them, whether or not this third party operates in the jurisdiction or territory
- b) we or third parties will use it to provide our products or Services,
- c) is delivered to entities providing marketing services on our behalf or to other entities with which we have joint marketing agreements,
- d) refers to a process of merger, consolidation, acquisition, disinvestment or other restructuring;
- e) implement a contract for the transmission of personal data pursuant to Decree 1377 of 2013,
- g) Liquido may share the information with different suppliers, allies or c, in order to ensure the provision of the service and the improvement of its quality, also to make users participating and beneficiaries of the different programs aimed at loyalty and complementation of the portfolio.
In all cases, the information provided will remain stored for as long as necessary to enable us to comply with the purposes set forth herein and to comply with legal and/or contractual obligations under our responsibility, especially in labor, accounting, tax and tax matters or in all that provided for by law.
Liquido purposes for character data processing
- a) Exercise your right to know sufficiently the Holder with whom you intend to establish relationships, provide services and assess the present or future risk of the same relationships and services.
- b) Comply with Colombian or foreign laws and the orders or requirements of judicial or administrative authorities.
- c) Perform commercial, commercial and promotional activities, customer service, brand activation activities, awards and promotions, directly or through third parties derived from commercial alliances or any link.
- d) Receive information from Liquido about current and future commercial campaigns, promotion of own and third-party products and services and other communications necessary to keep the Customer informed and informed through: phone call, text message, e-mail, any social integration network or instant messaging.
- e) Make invitations to events, improvements of products and services or offer new products, and all these activities associated with the existing commercial relationship or link with Liquido.
- f) For business monitoring, statistics, econometrics, research, segmentation and development of markets, products and values added to Commercial Establishments, financial institutions, Customers and Users.
- g) Manage procedures (requests, complaints, claims), conduct satisfaction surveys on the goods and services offered by Liquido, Related Entities, subsidiaries, subordinates or other commercial allies of Liquido.
- h) Access, consult, send, compare and evaluate all information about the Holder that is stored in the Databases of any credit center and financial risk, information systems and / or files of the Payment system, the financial institution that acquires judicial or security records, of a state or pr nature. invada, national or foreign, or any commercial or service database, which allows to establish in a complete historical manner, the behavior that as debtor, User, Client, guarantor, endorser, affiliate, beneficiary, subscriber, taxpayer and / or as Holder of financial services, commercial or any other.
- i) Know, store and process all information provided by Data Subjects in one or more Databases, in the format you deem most convenient.
- j) Perform all tax, accounting, tax and billing procedures directly or through third parties hired for this function.
- k) In accordance with Law 1480, Article 53, the merchant who wishes to register to make use of the services of the electronic payment platform and charge for their products will have the duty to enter a minimum of contact data that will be visible in the payment portal or checkouts for the complete identification of the trade by customers.
- l) Perform the services for which you have a commercial or contractual relationship with Liquido.
- m) Information previously shared or consulted, help us to protect users and companies from electronic or computer crimes or impersonation fraud, this information may be analyzed by the fraud prevention monitoring system or by authorized and highly qualified personnel to analyze this data and even communicate by telephone with users to confirm the authenticity of the operation and authorization.
- n) The information obtained by Liquido with the user's authorization must remain stored in our database, in order to ensure the attention of possible controversies that may arise about the services provided by Liquido. The stored information remains protected under security policies and standards.
- o) When any controversy or withdrawal is generated, Liquido may share the information provided with the entities involved in this process.
- p) Liquido may share the information with different suppliers or allies in order to ensure the provision of some service and improvement in the quality of it.
- p) The information of Liquido employees and jobseekers at Liquido, to manage compliance with the terms established in the employment relationship, such as: social security information and more. Comply with labor, social security, pension, occupational risks, family compensation funds (Integral Social Security Scheme) and taxes, and the necessary treatment for the performance of tasks within Liquido. As well as the processing of job applications I received from a jobseeker.
Processing of Traders' Information
By linking an entity to the Liquido service network, the latter is authorized to process the data with credit, financial, commercial, transactional and service information in credit hishistory and, in turn, Liquido is authorized so that it can share the information with the Related Entities.
The information collected will be used for the following purposes: Validate the information provided by the Commercial Establishment and, in general, validate, consult, process, save and send information related to it, in risk centers, information systems, linked to the conduct of investigations and validation of information from the entry processes.
Monitoring and monitoring and stylization of its behavior in the system and in the market, linked to the duties of knowledge of the Client and its market.
To make a dynamic assessment of your needs and your transactional profile.
Make known, share your data in and out of the country to Related Entities, national or international brand systems, third parties as a result of a contract, lily or legal link that requires you or implements cloud computing services
For the development of Liquido service operations, through any of the channels we enable.
Protect through monitoring and alerting systems for customers and/or users to prevent fraud and maintain ing reliable history and computer support from incidents and Operations.
For business monitoring and monitoring of commercial campaigns, monitoring of commercial campaigns, operation, evaluation and improvement of our business operations.
For the fulfillment of obligations of a pecuniary nature and other nature, to know your financial, commercial and credit behavior and compliance with your legal obligations, verification of the history of incidents related to money laundering, terrorist financing and/or fraud and/or pattern of compliance with other contractual obligations.
The above purposes are not limited to the moment of entry, but extend to all the list and, in accordance with the provisions on the loss of file retention information, may be maintained, after the end of the relationship, until constitutionally permitted period.
Without prejudice to the actual ownership of the information which, according to the Constitution, the Law, is understood as the head of the person or entity to which it refers;reputed as the owner of the Bases or information systems that they collect in an orderly manner such information, such as that of Liquido's customer network and its services, for authorized and legitimate uses, in accordance with national and international laws and instruments that protect intellectual property and rights related to the construction of information systems and the creation of databases.
Liquido guarantees confidentiality policies on information disclosed directly or indirectly that may disclose confidential information and violate human dignity, in the same way, Liquido will not give a different use to that advertised to the information and will implement all mechanisms of law and good practices that promote this practice.
6. Rights and duties as owner of the information
The information disclosed directly or indirectly will remain the property of users, however, it must be taken into account what are the rights and duties of the same for the correct processing of the data and ensure the purposes for which they were or will be disclosed.
- (a) Rights:
- Refuse or deny disclosure of information and processing: By accepting the Policy you are making a statement that you have read and understood the entirety of this document, so any request requiring authorization for the processing of the information may be refused.
- Rights of access, cancellation and rectification of personal information and procedure for the exercise of the rights of the Holders.
- Know, update and rectify your personal data in front of the entity responsible for processing or responsible for the processing of your personal data. This right may also be exercised, against partial, inaccurate, incomplete, fractional, misleading or those whose Processing is expressly prohibited or not authorized.
- Request proof of the Authorization granted to the Data Controller, except when expressly exceeded as a requirement for the Processing.
- Be informed by the Data Controller or the Data Processor upon request as to what you have given the personal data.
- Submit to the Superintendence of Industry and Commerce complaints for violations of the regime of protection of personal data.
- Revoke the Authorization and/or request the deletion of Personal Data pursuant there 1581 of 2012. Access your personal data that have been subject to the Processing free of charge.
- Request that data processing for advertising purposes stop: At any time users may request that their information not be used for advertising or informational purposes through a request sent to the email firstname.lastname@example.org
- For the protection of information: Users have the right to have their information protected and for this Liquido best practices and system for the protection and safeguarding of information.
- The information will be confidential and will be processed only for the purposes set out in the policies.
- (b) Duties:
- Provide true information: Liquido actually takes all the information provided by users, in fact, this can be verified for control and validation purposes, Liquido can deny requests when it finds that the information delivered has inconsistencies, changes or when it is not true.
- Keep contact information up to date: It's very important that users keep all information up to date, thus ensuring that all notifications that need to be made are made in a timely manner.
- Prohibition of the use of third parties: Access to the services provided by Liquido must be carried out in person, either through the legal representative or designated for work in the case of legal entities; therefore, it is possible to make requests or requests on behalf of third parties even with the authorization, the operations in which it is detected that are being carried out by third parties and not by the owner of the information will be denied or reversed.
Treatment by a manager's intermediary
Provide the Data Processor with only Personal Data whose Processing is previously authorized.
Make sure that the information provided to the Data Processor is true, complete, accurate, up-to-date, verifiable, and understandable.
Communicate in a timely manner with the Data Processor, all news about the data provided earlier and take the other necessary measures to keep the information provided up to date.
Inform the Data Processor in a timely manner of the corrections made to the Personal Data so that it can make the relevant adjustments.
Require the Data Processor at all times, respect the security and privacy conditions of the Owner's information. Inform the Treatment Manager when certain information is under discussion by the Holder, once the complaint has been filed and the respective procedure has not been completed.
Liquido does not collect, disclose or process the information of minors, since all services are restricted to minors. Liquido is not responsible for the unauthorized use of the payment platform or any of the services by minors who use third-party information, parents are advised to supervise minors when they manipulate or have access to the Internet.
Liquido does everything in its power and that good industrial and international practices dictate that information is protected with the best quality standards in security, but it is possible that, on the occasion of some kind of unforeseen external attack identified even by the control agencies and by industry as a vulnerability in operating systems, Network standards, data encryption protocols, processors, etc., there may be security gaps that allow the loss or leakage of information, so that users declare to understand the risk contained in the disclosure or sharing or allow access to information by electronic means and, therefore, exempt Liquido from any liability when unforeseen situations violate the rights of the owners of the information.
This information, privacy and confidentiality process policy is designed to inform users how Liquido treats the information, any general provision that is not regulated by doing so will be governed by the content of Law 1581 of 2012 and other applicable provisions.
10. Headline service channel
The owner, directly or through duly authorized persons, may consult your personal data at any time, especially whenever there are changes to the Information Processing Policies. To do so, you must send a written request to the email@example.com email informing you of such intent.
11. Complaints and inquiries
The owner or his successors in title who consider that the information contained in a database should be corrected, updated, deleted or when they notice the alleged breach of any of the duties by Liquido, may file a complaint as follows:
The claim will be formulated through a request addressed to Liquido, with the identification of the Holder, the description of the facts that give rise to the complaint, the address and follow-up of the documents you wish to state. If the claim is incomplete, the interested party will be required within 5 (five) business days of receiving the statement to correct the failures. After two (2) months from the date of the application, without the applicant presenting the necessary information, it will be understood that he withdrew the application.
Once the full claim is received, a caption will be included in the database that says "claim in process" and the reason for this will be included within a period of not more than two (2) business days. It has to be maintained until the claim is decided. The maximum period to attend the request will be fifteen (15) working days from the day following the date of receipt or the full submission of the information after a Liquido requirement.
When it is not possible to appear to the complaint within this period, the interested party will be informed of the reasons for the delay and the date on which his claim will be met, which in no case may exceed eight (8) business days after the end of the first term.
It can only be raised for complaint before the Superintendence of Industry and Commerce once the consultation or complaint process before the Controller or Controller has been exhausted.
12. Physical notifications
If you want to submit your complaint by physical means, it should be addressed to this address. The procedure to be handled will follow the procedure described above. Cr 19 A Nº 84 29 De 704 Municipality: Bogotá D.C.