PRIVACY NOTICE

ADSMOVIL S.A.S., business corporation identified with NIT No. 900351784-6, domiciled the city of Bogotá D.C., through its web page, requests, collects, stores, uses, circulates and suppresses data of a personal nature (name and e-mail), for the proper development of its commercial activities.

Bearing in mind the foregoing, ADSMOVIL S.A.S. acts as responsible for the processing of personal data corresponding to natural persons with whom it has or has had some kind of connection.

In compliance with the provisions in the personal data protection regulations, it informs you that the personal data you provide by virtue of the activities or operations held with the company, shall be processed pursuant to the Personal data protection policy and through the use and maintenance of technical, physical and administrative security measures in order to prevent unauthorized third parties from accessing them.

1. PURPOSE AND PROCESSING TO WHICH DATA SHALL BE SUBJECTED

Information and data are collected, stored, organized, used, circulated, transmitted, transferred, updated, rectified, suppressed, eliminated and managed pursuant to the nature of the data and the purposes established in this Policy. ADSMOVIL accesses data of its customers and collaborators, or of any person with whom the company has established or would establish a relationship, whether permanent or occasional.

These data are collected and processed with the following purposes:

1. To execute the existing contractual relationship with its clients, suppliers and employees, including the payment of contractual obligations.
2. To provide the required services and/or products for its users.
3. To fulfill contractual obligations within the framework of contractual relationships.
4. To inform about new products or services and/or changes in same.
5. To assess service quality. To deliver satisfaction surveys and any other mechanisms to assess the quality of the services provided by ADSMOVIL.
6. To conduct market research and studies on consumer habits, statistical analysis and reports on the behavior of the customers, the users and the audiences which access the different advertisement solutions.
7. To carry-out analysis and profiling of the customers, the users and the audiences who access the different advertising solutions, and which shall allow defining the products that suit their purchase inclinations and preferences.
8. To send to the physical address, electronic address, cellphone or mobile device, via text message (SMS and/or MMS) or through any other analogous and/or digital communication media created or to be created, commercial, advertising or promotional information regarding products and/or services, commercial-type events and/or promotions of these, in order to promote, invite, direct, execute, inform and in general, carry-out campaigns, promotions or contests of a commercial or advertising nature, provided by ADSMOVIL and/or third parties.
9. To develop the labor selection, assessment and relationship process.
10. To support internal and external auditing process.
11. To register in ADSMOVIL’S databases the information of employees and/or pensioners (active or inactive).
12. Those indicated in the authorization granted by data holder or described in the corresponding privacy notice, as appropriate.
13. To provide, share, send or deliver its personal data to affiliate, linked, or subordinated companies of the Company located in Colombia or in any other country in the event that said companies require the information for purposes indicated herein.
14. To allow third parties to consult same so as to contact the Holder, in order to corroborate its information and/or carry-out any of the activities described in the present document or on the one regarding the Terms and Conditions.
15. To obtain, gather, exchange, store, use, circulate, correct or suppress same.
16. To use the information granted by the Holder in order to contact prospective new customers to offer ADSMOVIL’S services.
17. Any other activity of a similar nature to the ones described above which are necessary to develop ADSMOVIL’S corporate purpose.
18. To design and offer loyalty and benefit programs for customers.

The processing of personal data of children and adolescents shall be handled as provided in the present policy in the paragraph related to the rights of them.

Where a personal data be provided, said information shall be used only for the purposes indicated herein, and thus, ADSMOVIL shall not proceed to sell, license, transmit, or disclose same, unless: (i) express authorization exists to do so; (ii) it be necessary to allow its contractors or agents to provide the entrusted services; (iii) it be necessary in order to provide our services and/or products; (iv) it be necessary to disclose same to the entities which provide marketing services on behalf of ADSMOVIL or to other entities with whom it has joint market agreements; (v) the information is related to a merger, consolidation, acquisition, disinvestment, or other restructuring process of the company; (iv) it be required or permitted by the law.

ADSMOVIL may subcontract third parties for the processing of certain functions or data. When the processing of personal data is effectively subcontracted or personal data is provided to third party service providers, ADSMOVIL warns said third parties about the need to protect said personal data with appropriate security measures, prohibits the use of the data for purposes of its own and requests that the personal data not be disclosed to others.

2. RIGHTS OF THE PERSONAL DATA HOLDER

According to the referred current applicable regulation in regards to data protection, the following are the rights of personal data holders:

1. To Access, know, update and rectify his Personal Data before ADSMOVIL or those in Charge of Processing same. This right may be exercised, among others, before partial, inaccurate, incomplete, fractionated, or misleading data, or those whose processing is expressly prohibited or has not been authorized.
2. To request proof of the Authorization granted to ADSMOVIL, for the processing of the data, by any valid means, except in the cases in which, pursuant to the law, authorization of same it is not necessary.
3. Submit applications before ADSMOVIL or that in Charge of the Processing in regards to the use given to your Personal Data, and that these provide to you such information.
4. Submit before the Superintendence of Industry and Commerce complaints due to violations to the Law, prior consultation or requirement proceeding before ADSMOVIL.
5. To revoke your Authorization and/or request the suppression of your Personal Data from the databases of ADSMOVIL, when in the Processing of same the constitutional and legal principles, rights and guarantees are not respected.
6. To learn about the modifications to the terms of this Policy prior the efficient implementation of the new modifications or, failing this, of the new data processing policy.
7. To have easy Access to the text of this Policy and the modifications of same.
8. To easily, simply and freely access your Personal Data which are under the control of ADSMOVIL, and which have been subject to processing, at least one time on each calendar month, and whenever substantial modifications to the present policy are made which motivate new consultations.
9. To know the unit or person empowered by ADSMOVIL before whom it may file complaints, queries, complaints or any other request regarding your Personal Data.

These rights may be exercised by:

• The holder, who must give proof of his identity in sufficient form through his citizenship identity card in original form.
• The persons entitled under the holder, who must give proof of such capacity in the manner legally provided.
• The holder’s representative and/or attorney-in-fact, prior accreditation of the representation or empowerment, in the manner legally provided.
• Another person in favor or for which the holder would have stipulated the above-mentioned right, by means of a written document.

2.1. RIGHTS OF CHILDREN AND ADOLESCENTS

ADSMOVIL declares that it does not collect personal data of minors and it is the responsibility of the father/mother or legal guardian to ensure the privacy of minors, doing everything possible to ensure that they have authorized the collection and use of the minor’s personal data.

In likewise manner, in the processing of personal data, respect for the prevailing rights of minors shall be ensured.

3. AUTHORIZATION FOR THE PROCESSING OF SENSIBLE DATA

In the event that sensible personal data are collected, the Holder may refuse to authorize the Processing of same.

For queries and concerns related with these issues you can contact us by email at [email protected].