PERSONAL DATA PROCESSING POLICY
TRAVELERS APARTAMENTOS Y SUITES, with its main address in Bogotá D.C., Colombia, as Manager of the Treatment of Personal Data, informs all its stakeholders that it has an Information Treatment Policy.
This Privacy Notice establishes the terms and conditions under which TRAVELERS APARTAMENTOS AND SUITES, will perform the Treatment of Personal Data contained in its Databases.
The information and Personal Data provided to TRAVELERS APARTAMENTOS AND SUITES may be processed, collected, used, circulated, suppressed, shared, updated, transmitted or transferred in whole or in part to the different areas of TRAVELERS APARTAMENTOS AND SUITES, as well as to contractors and shareholders, when required for commercial, financial, administrative and operational purposes, including Sensitive Data, in accordance with the terms and conditions of the Internal Manual of Policies and Procedures for the Processing of Personal Data of TRAVELERS APARTAMENTOS Y SUITES, as applicable, mainly to make possible the development of the operation, including but not limited to accounting records that are required, reports to control and surveillance authorities and other uses for the purposes mentioned.
As holder of your personal data you have the right to:
To know, to update and to rectify your Personal Data in front of TRAVELERS APARTMENTS AND SUITES in its condition of Responsible of the Treatment. This right may be exercised, inter alia, against partial data, inaccurate, incomplete, fractioned, misleading, or those whose Treatment is expressly prohibited or has not been authorized.
Request proof of the Authorization granted to TRAVELERS APARTAMENTOS Y SUITES unless expressly excepted as a requirement for the Treatment, in accordance with the provisions of article 10 of Law 1581 of 2012.
Be informed by TRAVELERS APARTAMENTOS AND SUITES, upon request, regarding the use you have given to your Personal Data.
Submit to the Superintendency of Industry and Commerce complaints for violations of the provisions of Law 1581 of 2012 and other rules that modify, add or complement.
Revoke the Authorization or request the suppression of the data when in the Treatment the principles, rights and constitutional and legal guarantees are not respected.
Access free of charge the Personal Data that have been processed.
AUTHORIZATION FOR THE PROCESSING OF PERSONAL DATA
The information collected by TRAVELERS APARTAMENTOS Y SUITES, may include, in whole or in part according to the needs of each product and / or service, among others the following data:
Names and surnames. • Type and identification number. • Nationality and country of residence. • Date of birth and gender. • Marital status and / or relationship in relation to minors or disabled persons requesting our services. • Fixed and mobile phones (personal and / or work). • Postal and electronic addresses (personal and / or labor). • Profession or trade • Company in which you work and charge. • Origin and destination • Credit card information (number, bank, expiration date). • Personal data of the cardholder (names and surnames, type and identification number).
By accepting this Privacy and Treatment Policy, our guests, visitors, customers, users and suppliers, as owners of the collected data, authorize TRAVELERS APARTAMENTOS AND SUITES to treat them, partially or totally. According to the interest group registered in the current Databases, each catchment area must collect the authorization of the data owners, which is done through the following means:
INTEREST GROUP TYPE MEDIUM OR DOCUMENT
INTEREST GROUP TYPE MEDIUM OR DOCUMENT
CORPORATE CLIENT LINKAGE FORM AND / OR CONTRACT
SPECIAL CUSTOMER CHECK IN REGISTRATION
CLIENT REAL ESTATE CONTRACT
NOMINATES EMPLOYED CONTRACT WORK
SUPPLIERS AND CONTRACTORS SUPPLIERS AND CONTRACTORS LIFE SHEET / LABOR CONTRACT
The Authorization must be express and informed in order to include the specific purposes of the Treatment for which consent is obtained, and be obtained by any means that may be subject to subsequent consultation.
In the event that the Authorization is on the Processing of Sensitive Data, it will be done in accordance with the terms of Law 1581 of 2012 and its Regulatory Decree.
Cases where authorization of the data subject is not required
The authorization of the holder is not necessary when it is:
Public nature data
Cases of medical or health emergency
Treatment of information authorized by law for historical, statistical or scientific purposes.
Data Related to the Civil Registry of persons. (excludes biometric data as sensitive data).
VERACITY OF INFORMATION. Our guests, visitors, customers, users and suppliers must provide truthful information about their personal data in order to make possible the provision of services or commercial relationship as appropriate and under whose condition they agree to deliver the required information.
TRAVELERS APARTAMENTOS AND SUITES assumes the accuracy of the information provided and does not verify, or assume the obligation to verify, the identity of the guests, visitors, customers, users and suppliers, nor the veracity, validity, sufficiency and authenticity of the data that each of them. Therefore, it assumes no liability for damages and / or damages of any nature that may originate in the lack of truthfulness, validity, sufficiency or authenticity of the information, including damages that may be due to the homonymy or the impersonation of the identity .
TRAVELERS APARTMENTS AND SUITES will ensure the proper use of the personal data of children and adolescents, ensuring that the treatment of their data respects their best interests and their fundamental rights.
TRAVELERS APARTAMENTOS AND SUITES informs the guests, visitors, customers, users and suppliers of personal data previously collected as of the date of publication of this Policy for the Processing of Personal Data, that their data are stored in our Database and will continue with the in accordance with the legal provisions and in accordance with the provisions of article 14 of Law 1581 of 2012, the Holder or his successors in title who consider that the information contained in our database must be subject to correction, updating or suppression, or when they notice the alleged breach of any of the duties contained in Law 1581 of 2012, may submit a complaint to the Data Processing Manager under the conditions established in the Procedure for Attention to requests, queries and complaints indicated in This document.
PERSONAL DATA PROCESSING MANAGER
TRAVELERS APARTMENTS AND SUITES as Responsible for the information presents the following duties to its position:
To guarantee to the holder, at all times, the full and effective right of Habeas Data.
Request and keep, copy of the authorization granted by the Holder.
Properly inform the Card Holder about the purpose of the collection and the rights that assist him by virtue of the authorization granted.
Keep the information under the necessary security conditions to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access.
Correct the information when it is incorrect and communicate the pertinent information to each Data Processing Manager.
To process the consultations and claims formulated in the terms indicated in the Law.
TRAVELERS APARTMENTS AND SUITES as legal entity, is the general Responsible for the Treatment of the information that rests in the databases of each of the areas that comprise it, nevertheless has determined some areas responsible for the collection and maintenance of the information in by virtue of the class of data handled by them, this responsibility is defined in the Matrix of personal data.
PROCEDURE OF ATTENTION OF PETITIONS, CONSULTATIONS AND CLAIMS
The owner’s power of disposition or decision on the information that concerns him necessarily entails the right to access and know if his personal information is being processed, as well as the scope, conditions and generalities of said treatment.
Identification of the Holder: Full name and address of the Holder or indication of any other means to receive the response from the Treatment Manager.
Identification of the Assignee: In the event that he or she is the assignee, he / she must send the documents accrediting this quality with respect to the Owner of the Personal Data.
Description of the Personal Data: Clear and precise description of the Personal Data in respect of which the Holder intends to exercise any of the rights.
Claim: In the event of a claim, the Holder or his successor in title shall describe the facts that give rise to the claim together with the supporting documents.
Other: Any document additional to those mentioned above that allow to identify the link of the Holder with TRAVELERS APARTAMENTOS AND SUITES like: employee, contractor, client, community or other.
The Legal Representative of the Headquarters will process the request with the official responsible for the catchment area according to the interest group defined in the Matrix of Treatment of Personal Data (Annex 1), so that TRAVELERS APARTMENTS AND SUITES, as Head of Treatment, forward the actions necessary for the exercise of the rights of the Holder
Requests for consultation and claim will be answered within “a maximum term of ten (10) working days from the date of receipt of the same. When it is not possible to attend the consultation within this term, the interested party will be informed, stating the reasons for the delay and indicating the date of the consultation, which in no case may exceed the five (5) business days following the expiration of the first term “(Art 14 Title V of Law 1581 of 2012)
TRAVELERS APARTMENTS AND SUITES has adopted the technical, human and administrative measures necessary to provide security for the records, preventing their adulteration, loss, consultation, use or unauthorized access or fraudulent.
Notwithstanding the foregoing, the client assumes the risks that derive from providing this information in a medium such as the internet, which is subject to various variables – attacks by third parties, technical or technological failures, among others. TRAVELERS APARTAMENTOS AND SUITES will make its best technological effort to guarantee the security of the personal information of all its clients and / or users, using reasonable and current methods of security to prevent unauthorized access, to maintain the accuracy of the data and to guarantee the correct use of the information.
TRAVELERS APARTMENTS AND SUITES will maintain mandatory security protocols for staff with access to personal data and information systems. The procedure should consider, as a minimum, the following aspects:
MAGNETIC STORAGE: The access to the platforms or in Software where they are stored and given the treatment to the personal data is restricted. Depending on the level of responsibility of each area and its functions, user profiles are created with the assignment of personal passwords to control access and thus prevent their adulteration, loss, consultation, use or unauthorized or fraudulent access to the information.
The backup copies of the information will be made following the Tics Procedure defined in the Quality System.
PHYSICAL STORAGE: only documents with personal data that are required for the development of the operation and those required to support reports or reports to government entities will be kept in this medium. They must be stored in a way that guarantees their safety and prevents deterioration, loss and / or improper handling. It is the responsibility of the assigned area for its control and custody. The following indications must be met:
Do not print or reproduce or retain unnecessary copies of documents
Do not keep financial documents or a copy after the end of the business relationship (such as credit cards, debit cards, non-face-to-face sales authorizations)
Do not use recycled paper containing personal information.
Completely destroy documents that have exhausted the retention time.
DATE OF ENTRY INTO FORCE OF THE INFORMATION TREATMENT POLICY.
The TRAVELERS APARTMENTS AND SUITES Information Treatment Policy is effective as of November 1, 2016.
The information previously provided by customers and users will remain stored for up to fifteen (15) years from the date of the last treatment, to enable us to comply with legal and / or contractual obligations, especially in accounting matters , tax and tax.
Travelers Apartments & Suites satisfies lodging needs with hotel services in apartments, suites and suites furnished, comfortable, safe and strategically located; also offers advisory services and real estate management. We seek to fulfill our promise of service with kindness and efficiency, seeking the well-being of our clients and the profitability to the partners.
At Travelers Apartments & Suites we are committed to continuously improving processes, involving and encouraging the participation of employees, suppliers, customers and guests in the management of environmental, socio-cultural and socio-economic aspects. We will ensure the strengthening of the knowledge and skills of the employees for their personal development and remuneration in the provision of the Service.
Finally, Travelers Apartments & Suites rejects all acts involving the sexual exploitation of minors, as well as any type of discrimination towards groups due to their race, gender, sexual orientation, disability or origin