General Information

ENCAJES S.A., identified with Tax ID (NIT) 900.060.476-3, in compliance with Law 1581 of 2012 and other applicable regulations, adopts this Personal Data Protection and Processing Policy, which governs the collection, storage, use, circulation, transfer, transmission, and deletion of personal data processed in the course of its business activities.​

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The purpose of this policy is to guarantee the fundamental right of habeas data and the protection of the personal information of all data subjects.

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Data Controller

• Corporate Name: ENCAJES S.A.

• Domicile: Bogotá D.C., Colombia

• Address: Calle 17 A #69B-06

• Email: protecciondedatos@encajes.com

• Phone: (+57) 601 294 2888 Ext. 154

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​Scope

This policy applies to all employees, processes, products, and business lines of Encajes S.A. Colombia, as well as to third parties that directly or indirectly impact the Company’s activities.​

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Regulatory Framework

The processing of personal data is governed, among others, by the following provisions:

• Political Constitution of Colombia, Article 15

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  Law 1581 of 2012

• Decree 1377 of 2013

• Decree 1074 of 2015

• Single Circular of the Superintendence of Industry and Commerce (SIC)

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Principles for the Processing of Personal Data

ENCAJES S.A. applies the principles of legality, purpose, freedom, accuracy or quality, transparency, restricted access and circulation, security, and confidentiality, in accordance with Law 1581 of 2012.​

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Authorization of the Data Subject

The processing of personal data shall be carried out with the prior, free, express, informed, and unequivocal authorization of the data subject, except in cases expressly authorized by law.​ Authorization may be obtained through physical, electronic, or verbal means, or through unequivocal conduct that allows its verification.

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Processing of Sensitive Data

The processing of sensitive data shall be exceptional and carried out only when the data subject has granted explicit authorization, when necessary to protect a vital interest, for the exercise or defense of a right in judicial proceedings, or when expressly authorized by law. Under no circumstances shall any activity be conditioned upon the provision of such data, except where legally required.​

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Processing of Data of Children and Adolescents

ENCAJES S.A. recognizes the special protection of personal data of children and adolescents. Processing shall only occur when it responds to the best interests of the minor, has the authorization of the legal representative, and enhanced security measures are adopted.​

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​The Company may collect and publish images of minors in institutional, cultural, or well-being activities, provided that prior and express authorization from the legal representative is obtained, the use is respectful, and it does not have commercial purposes.

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Purposes of Data Processing

Personal data will be processed, among others, for the following purposes:​

• Management of labor, contractual, and commercial relationships.

• Personnel administration and compliance with labor and social security obligations.

• Accounting, financial, tax, and administrative management.

• Management of suppliers, contractors, and strategic partners.

• Handling of requests, inquiries, and complaints.

• Compliance with legal obligations and responses to authorities.

• Ensuring the security of people, assets, and facilities.

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Rights of Data Subjects

Data subjects have the right to know, access, update, and rectify their personal data; request proof of authorization; be informed about the use of their information; file complaints with the SIC; revoke authorization and request the deletion of their data, when applicable; and access their data free of charge.​

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Procedure for Inquiries and Complaints

Data subjects may submit inquiries or complaints regarding the processing of their personal data. Complaints will be addressed within a maximum period of fifteen (15) business days, extendable by eight (8) additional business days, in accordance with the law.​

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Service Channel

Inquiries and complaints must be sent to the following email address: protecciondedatos@encajes.com

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Transfer and Transmission of Personal Data

ENCAJES S.A. may transfer and transmit personal data to third parties, both nationally and internationally, ensuring compliance with applicable regulations, the execution of confidentiality agreements, and the implementation of appropriate security measures.​

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Security Measures

The Company implements reasonable technical, human, and administrative measures to protect personal data against unauthorized access, loss, alteration, misuse, or unauthorized disclosure. These measures are periodically reviewed.​

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Validity and Updates​

This policy becomes effective upon its approval and replaces any previous version. Any substantial modification will be communicated in a timely manner to data subjects through the channels established by ENCAJES S.A.