DEFINITIONS
This Personal Data Protection Policy will apply to all Databases and/or Files that contain Personal Data that are subject to Treatment by MENTOR LAB S.A.S. considered responsible and/or in charge of the processing of Personal Data.
IDENTIFICATION OF THE RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA
MENTOR LAB S.A.S. company domiciled at Carrera 69B No. 24 B – 55 in the city of Bogotá D.C., Colombia identified with the Tax Identification Number NIT 901.393.218-2 and Email: hello@mentor.page, telephone +57 (1) 301 7859220
DEFINITIONS
Authorization: Prior, express and informed consent of the Owner to carry out the Processing of Personal Data.
Privacy Notice: Verbal or written communication generated by the Responsible, addressed to the Holder for the Treatment of his Personal Data, by which he is informed about the existence of the Information Treatment Policies that will be applicable to him, the way to access to them and the purposes of the Treatment that is intended to be given to personal data.
Database: Organized set of Personal Data that is subject to Treatment.
Personal Data: Any information linked or that can be associated with one or several determined or determinable natural persons.
Sensitive Data: Information that affects the privacy of people or whose improper use can generate discrimination (racial or ethnic origin, police orientation, philosophical or religious convictions, belonging to unions or social organizations or human rights, health data, sexual life and biometrics. )
Treatment Manager: Natural or legal person, public or private, that by itself or in association with others, performs the Processing of Personal Data on behalf of the Treatment Manager. In the events in which the Responsible does not act as Manager of the Database, it will be expressly identified who will be the Manager.
Responsible for the Treatment: Natural or legal person, public or private, that by itself or in association with others, decides on the Database and/or the Treatment of the data.
Terms and Conditions: General framework in which the conditions for participants in commercial or related activities are established.
Owner: Natural person whose Personal Data is subject to Treatment.
Treatment: Any operation or set of operations on Personal Data, such as collection, storage, use, circulation or deletion.
Transfer: The transfer of data takes place when the person in charge and/or in charge of the treatment of personal data, located in Colombia, sends the information or personal data to a recipient, who in turn is the person in charge of the treatment and is inside or outside from the country.
Transmission: Treatment of Personal Data that implies the communication of the same inside or outside the territory of the Republic of Colombia when its purpose is to carry out a Treatment by the Manager on behalf of the Responsible.
TREATMENT
MENTOR LAB S.A.S., acting as Responsible for the Processing of Personal Data, for the adequate development of its commercial activities, as well as for the strengthening of its relations with third parties, collects, stores, uses, circulates and deletes Personal Data corresponding to natural persons. with whom it has or has had a relationship, such as, without the enumeration implying limitation, workers and their relatives, shareholders, consumers, clients, distributors, suppliers, creditors and debtors.
PURPOSE
Personal Data is processed by MENTOR LAB S.A.S., with the following purposes:
Participation in different types of surveys through records or online forms.
Filling out subscription requests, software orders and online services, or to facilitate the request for specific information that is required of us.
Make it easier for you to use our website.
Adapt the most relevant content to your interests.
Inform you of important news concerning MENTOR LAB.
Inform you about our new products or services, product updates, technical support issues, events and special offers.
Promote products and services on our website and the websites of our business partners or partners.
Prevent and detect fraud or other illegal or prohibited activities.
Ensure the security and integrity of our Website.
As part of an ongoing sales process.
While providing technical support or consulting regarding a product.
To be part of the process of maintenance and modernization of our products.
To be part of automated means such as communication protocols.
RIGHTS OF THE HOLDERS OF PERSONAL DATA
Natural persons whose Personal Data is processed by MENTOR LAB have the following rights, which they can exercise at any time:
Know the Personal Data on which MENTOR LAB is carrying out the Treatment. In the same way, the Holder can request at any time that his data be updated or rectified, for example, if he finds that his data is partial, inaccurate, incomplete, divided, misleading, or those whose Treatment is expressly prohibited or not. has been authorized.
Request proof of the authorization granted to MENTOR LAB for the Processing of your Personal Data.
To be informed by MENTOR LAB, upon request, regarding the use that it has given to your Personal Data.
Submit complaints to the Superintendence of Industry and Commerce (SIC) for violations of the provisions of the Personal Data Protection Law.
Request MENTOR LAB to delete their Personal Data and/or revoke the authorization granted for their Treatment, by filing a claim, in accordance with the procedures established in number 11 of this Policy. However, the request to delete the information and the revocation of the authorization will not proceed when the Owner of the information has a legal or contractual duty to remain in the Database and/or Files, nor while the relationship between the Owner and MENTOR LAB, by virtue of which their data was collected.
Free access to your Personal Data subject to Treatment.
AREA RESPONSIBLE FOR THE IMPLEMENTATION AND OBSERVANCE OF THIS POLICY
The Administrative and Financial Management and Legal Affairs of MENTOR LAB S.A.S., is in charge of the development, implementation, training and observance of this Policy. For this purpose, all the officials who carry out the Processing of Personal Data in the different areas of MENTOR LAB S.A.S., are obliged to report these Databases to the Administrative and Financial Management and Legal Affairs and to transfer it immediately, in all requests, complaints or claims received by the Holders of Personal Data. The Administrative and Financial Management and Legal Affairs has also been designated by MENTOR LAB S.A.S., as the area responsible for handling requests, queries, complaints and claims before which the Owner of the information may exercise their rights to know, update, rectify and Delete the data and revoke the authorization.
AUTHORIZATION
MENTOR LAB S.A.S., must request prior, express and informed authorization from the Holders of the Personal Data on which the Treatment is required.
Prior authorization means that the consent must be granted by the Holder, at the latest at the time of collection of Personal Data.
Express authorization means that the Holder’s consent must be explicit and specific, open and non-specific authorizations are not valid. The Holder is required to express his willingness to authorize MENTOR LAB S.A.S., to carry out the Processing of his Personal Data. This manifestation of will of the Holder can occur through different mechanisms made available by MENTOR LAB, such as:
In writing, for example, filling out a personal data processing authorization form.
Orally, for example, in a telephone conversation or videoconference.
Through unequivocal conduct that allows us to conclude that you have granted your authorization, for example, through your express acceptance of the Terms and Conditions of an activity within which the authorization of the participants is required for the Processing of their Personal Data.
IMPORTANT: In no case MENTOR LAB S.A.S. will assimilate the Holder’s silence to an unequivocal conduct. Whatever the mechanism used by MENTOR LAB S.A.S., it is necessary that the authorization be kept in order to be able to consult it later.
Informed Authorization means that, when requesting consent from the Holder, they must be clearly informed:
The Personal Data that will be collected.
The identification and contact details of the Responsible and the Treatment Manager.
The specific purposes of the Treatment that is intended to be carried out, that is to say: how and for what the collection, use, circulation of Personal Data will be done.
What are the rights you have as the Holder of Personal Data; for this effect, see number 6 of this Policy.
The optional nature of the answer to the questions that are asked, when they are about sensitive data or about the data of children and adolescents
SPECIAL PROVISIONS FOR THE PROCESSING OF PERSONAL DATA OF A SENSITIVE NATURE.
In accordance with the Personal Data Protection Law, data of a sensitive nature is considered to be data that affects privacy or whose improper use may generate discrimination, such as those related to:
Racial or ethnic origin.
Political orientation.
Religious / philosophical convictions.
Membership of trade unions, social organizations, human rights organizations or political parties.
Health.
Sex life.
Biometric data (such as fingerprint, signature and photo).
The Treatment of Personal Data of a sensitive nature is prohibited by law, unless there is the express, prior and informed authorization of the Owner, among other exceptions enshrined in Article 6 of Law 1581 of 2012. In this case, in addition to comply with the requirements established for authorization, MENTOR LAB must:
Inform the Holder that because it is sensitive data, he is not obliged to authorize the Treatment of him.
Inform the Owner which of the data that will be subject to Treatment are sensitive and the purpose of the Treatment.
IMPORTANT: No activity may be conditioned to the Owner providing sensitive Personal Data.
SPECIAL PROVISIONS FOR THE PROCESSING OF PERSONAL DATA OF CHILDREN AND ADOLESCENTS
According to the provisions of Article 7 of Law 1581 of 2012 and Article 12 of Decree 1377 of 2013, MENTOR LAB S.A.S., will only carry out the Treatment, that is, the collection, storage, use, circulation and/or deletion of Personal Data corresponding to children and adolescents, as long as this Treatment responds to and respects the best interests of children and adolescents and ensures respect for their fundamental rights. Once the above requirements have been met, MENTOR LAB S.A.S., must obtain the Authorization of the legal representative of the child or adolescent, prior to the exercise of the minor’s right to be heard, an opinion that will be assessed taking into account maturity, autonomy and ability to understand the affair.
PROCEDURE FOR ATTENTION AND RESPONSE TO REQUESTS, QUERIES, COMPLAINTS AND CLAIMS FROM PERSONAL DATA HOLDERS
The Holders of the Personal Data that are being collected, stored, used, put into circulation by MENTOR LAB, may at any time exercise their rights to know, update, rectify and delete information and revoke the authorization. For this purpose, the following procedure will be followed, in accordance with the Personal Data Protection Law: 11.1 ATTENTION AND RESPONSE TO REQUESTS AND QUERIES: What does the procedure consist of? The Holder or the successor in title thereof, may request MENTOR LAB S.A.S., through the means indicated below:
Information on the Personal Data of the Holder that are subject to Treatment.
Request proof of the authorization granted to MENTOR LAB S.A.S. for the Processing of your Personal Data.
Information regarding the use that has been given to it by MENTOR LAB S.A.S. to your personal data.
Means enabled for the presentation of requests and queries: MENTOR LAB S.A.S., has arranged the following means for the reception and attention of requests and queries, all of which allow proof of them to be preserved:
Communication addressed to MENTOR LAB S.A.S., Administrative and Financial Management and/or Legal Affairs, Carrera 69B No. 24 B – 55 Apt. 501 Tower 5 of the city of Bogotá D.C.,
Request submitted to email: hello@mentor.page
Attention and response by MENTOR LAB S.A.S.: Requests and inquiries will be addressed within a maximum term of ten (10) business days from the date of receipt thereof. When it is not possible to attend to the request or query within said term, the interested party will be informed, stating the reasons for the delay and indicating that the request or query will be addressed, which in no case may exceed five (5) business days. following the expiration of the first term. 11.2 ATTENTION AND RESPONSE TO COMPLAINTS AND CLAIMS: What does the procedure consist of? The Holder or the successor in title thereof, may request MENTOR LAB S.A.S., through a complaint or claim submitted through the channels indicated below:
The correction or update of the information.
The deletion of your Personal Data or the revocation of the authorization granted for the Treatment thereof.
That the alleged breach of any of the duties contained in the Personal Data Protection Law be remedied or corrected.
The request must contain the description of the facts that give rise to the complaint or claim, the address and contact information of the requester, and must be accompanied by the documents that are to be asserted. Means enabled for the presentation of complaints and claims: MENTOR LAB S.A.S., has arranged the following means for the reception and attention of complaints and claims, all of which allow proof of their presentation to be preserved:
Communication addressed to MENTOR LAB S.A.S., Administrative and Financial Management and/or Legal Affairs, Carrera 69B No. 24 B – 55 Apt. 501 Tower 5 of the city of Bogotá D.C.
Request submitted to email: hello@mentor.page
Attention and response by MENTOR LAB S.A.S.: If the complaint or claim is presented incomplete, MENTOR LAB S.A.S., must request the interested party within five (5) days following receipt of the complaint or claim to correct the failures. After two (2) months from the date of the request, without the applicant presenting the required information, it will be understood that he has withdrawn the complaint or claim. In the event that the person receiving the complaint or claim is not competent to resolve it, they will notify the Administrative and Financial Management and Legal Affairs of MENTOR LAB S.A.S., within a maximum term of two (2) business days and inform the interested party of the situation. . Once the complete complaint or claim is received, a legend that says “claim in process” and the reason for it will be included in the Database, within a term of no more than two (2) business days. Said legend must be maintained until the complaint or claim is decided. The maximum term to address the complaint or claim will be fifteen (15) business days from the day following the date of receipt. When it is not possible to address the complaint or claim within said term, the interested party will be informed of the reasons for the delay and the date on which their complaint or claim will be addressed, which in no case may exceed eight (8) business days. following the expiration of the first term. In accordance with Law 1755 of 2015, which regulates what is pertinent to the fundamental right enshrined in article 23 of the Political Constitution of Colombia.
INFORMATION OBTAINED PASSIVELY
When accessing or using the services contained within the websites of MENTOR LAB S.A.S., it may collect information passively through information management technologies, such as “cookies”, through which information is collected. about your computer hardware and software, IP address, browser type, operating system, domain name, access time, and referring website addresses; Through the use of these tools, Personal Data of the users is not directly collected. Information will also be collected about the pages that the person visits most frequently on these websites in order to know their browsing habits. However, the user of the websites of MENTOR LAB S.A.S., has the possibility of configuring the operation of the “cookies”, according to the options of their internet browser.
SECURITY OF PERSONAL DATA
MENTOR LAB S.A.S., in strict application of the Principle of Security in the Treatment of Personal Data, will provide the technical, human and administrative measures that are necessary to grant security to the records avoiding their adulteration, loss, consultation, use or unauthorized or fraudulent access. . The obligation and responsibility of MENTOR LAB S.A.S. is limited to having the appropriate means for this purpose. MENTOR LAB S.A.S., does not guarantee the total security of your information nor is it responsible for any consequence derived from technical failures or improper entry by third parties to the Database or File in which the Personal Data object of Treatment by MENTOR LAB S.A.S. MENTOR LAB S.A.S., and its Managers. MENTOR LAB S.A.S., will require the service providers it hires to adopt and comply with the appropriate technical, human and administrative measures for the protection of Personal Data in relation to which said providers act as Managers.
TRANSFER, TRANSMISSION AND DISCLOSURE OF PERSONAL DATA
MENTOR LAB S.A.S., may disclose to its related companies worldwide, the Personal Data on which it performs the Treatment, for its use and Treatment in accordance with this Personal Data Protection Policy. Likewise, MENTOR LAB S.A.S., may deliver Personal Data to third parties not related to MENTOR LAB when: a. They are contractors in execution of contracts for the development of the activities of MENTOR LAB S.A.S.; b. By transfer to any title of any line of business to which the information relates. In any case, in the contracts for the transmission of Personal Data, which are signed between MENTOR LAB S.A.S., and the Persons in Charge of the Processing of Personal Data, it will be required that the information be processed in accordance with this Personal Data Protection Policy and will include the following obligations at the head of the respective Manager:
Give Treatment, in the name of MENTOR LAB S.A.S., to Personal Data in accordance with the principles that protect them.
Safeguard the security of the databases in which Personal Data is contained.
Keep confidentiality regarding the Treatment of Personal Data.
APPLICABLE LEGISLATION
This Personal Data Protection Policy, the Privacy Notice, the Information Security Policy and the Data Processing Authorization Forms are governed by the provisions of current legislation on the protection of Personal Data to which they refer. Article 15 of the Political Constitution of Colombia, Law 1266 of 2008, Law 1581 of 2012, Decree 1377 of 2013, Decree 1727 of 2009 and other regulations that modify, repeal or replace them.
VALIDITY
This Personal Data Protection Policy has been in force since July 15, 2020.