Privacy Policies

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Colombia (2)
Perú (3)

Colombia

PRIVACY NOTICE

Philippi, Prietocarrizosa, Ferrero DU & Uría S.A.S (the “Data Controller” or “PPU COLOMBIA”), as the entity responsible for the processing of personal data and in compliance with the provisions contained in Statutory Law 1581 of 2012, its regulatory decrees, and other related regulations, informs the data subjects that their personal data will be processed according to the nature of the data and the purposes established in the Personal Data Processing Policy of PPU COLOMBIA (the “Policy”), which include:

To comply with commercial obligations within the framework of contractual relationships.
To send newsletters related to legal topics to PPU COLOMBIA clients.
To send invitations to participate in events organized by PPU COLOMBIA.
To provide information about training sessions or conferences scheduled by PPU COLOMBIA.
To assess the quality of services provided by PPU COLOMBIA.
To conduct market research and consumer behavior studies, statistical analyses, and customer behavior reports.

In cases where PPU COLOMBIA has access to sensitive data, the Data Subject will be informed about the voluntary nature of answering questions related to such sensitive data or to the personal data of children and adolescents.

Company’s Information

Company Name: Philippi, Prietocarrizosa, Ferrero DU & Uría S.A.S.
Address: Bogotá D.C., Colombia.
Address: Carrera 9 N. 74 – 08 Oficina 105.
Email: [email protected]
Telephone: 3268600 ext. 1437

In accordance with the Personal Data Protection Law, the Data Subject has the right to access, update, rectify, and delete their personal data, as well as to revoke the consent given for its processing.

To learn about the personal data processing policy of PPU COLOMBIA as well as any substantial changes made to it, we invite you to click here.

To submit an inquiry, complaint, or request related to the processing of personal data, you may send your request to the email [email protected], contact the telephone line (1) 3268600 ext. 1640, or you may submit these requests in writing in the city of Bogotá at the address where the person responsible for handling personal data is located.

PERSONAL DATA PROCESSING POLICY

The following Personal Data Processing Policy (the “Policy”) governs the collection, storage, use, circulation, and deletion of personal data carried out by Philippi, Prietocarrizosa, Ferrero DU & Uría S.A.S (the “Company” or “PPU COLOMBIA”), in accordance with the provisions contained in Statutory Law 1581 of 2012 and Decree 1074 of 2015, through which general provisions for the protection of personal data are established.

1. Company’s Information

Company Name: Philippi, Prietocarrizosa, Ferrero DU & Uría S.A.S
Address: Bogotá D.C., Colombia.
Address: Cra. 9 N. 74 – 08 Office 105
Email: [email protected]
Telephone: 3268600 ext 1437

2. Use and Processing of Personal Information

Personal data is collected, stored, organized, used, shared, transmitted, transferred, updated, rectified, suppressed, deleted, and managed in accordance with the nature of the data and the purposes established in this Policy.

2.1. Public and private Personal Data Processing.

PPU COLOMBIA accesses data from its clients and collaborators, such as their names, ID numbers, email addresses, landline and mobile phone numbers, among others. These data are collected for the following purposes:

2.1.1. Purposes for Processing Alumni Personal Data:

To send commercial information from PPU COLOMBIA.
To share information related to the ALUMNI event organized by PPU COLOMBIA.

2.1.2. Purposes for Processing Applicant Personal Data:

To analyze an Applicant’s information for the purpose of initiating a recruitment process.
To contact the Applicant to express the interest in initiating a recruitment process.
To verify the truthfulness and authenticity of the information provided in your resume with the institutions where you have pursued your studies and held positions.
To begin the assessment of housing and safety conditions to determine eligibility for employment at PPU Colombia.
To share your data with PPU COLOMBIA’s partners and clients who are interested in contacting individuals with your profile to explore potential employment opportunities.

2.1.3. Purposes for Processing Client Personal Data:

To comply with commercial obligations within the framework of contractual relationships.
To process and ensure the compliance and delivery of products and/or services acquired by PPU COLOMBIA’s clients, as well as prepare the corresponding billing.
To send advertising and promotional materials about PPU COLOMBIA’s products and services.
To offer products from PPU COLOMBIA’s various business lines.
To announce discounts, promotions, and new product launches.
To perform client analysis and profiling to identify products to best suit clients purchasing preferences and tastes.
To notify information of activities and events organized by PPU COLOMBIA.
To conduct market research and consumer behavior studies, statistical analyses, and client behavior reports.
To design and provide loyalty and benefit programs for clients.
To send satisfaction surveys or any other mechanisms to assess the quality of products and services provided by PPU COLOMBIA.

2.1.4. Purposes for Processing Employee Personal Data:

To comply with the Employer’s labor obligations as established in labor legislation, the employment contract, and the Internal Work Regulations, such as: affiliation to the Comprehensive Social Security System and payment of contributions, affiliation to the Compensation Fund and payment of contributions, payment to the DIAN (National Tax and Customs Directorate) of withheld amounts, issuance of income and withholding certificates and employment certificates, as well as, to provide information to any national entity or authority requiring personal data, in accordance with current regulations.
To make the necessary payments to the bank account designated by the Employee or entities expressly indicated by the Employee.
To hire life and/or medical insurance coverage, or to grant any other benefits derived from the employment relationship with the Employer, if applicable.
To notify family members in case of emergencies during working hours or in the course of work-related activities.
To ensure the safety and health of workers in the workplace, in accordance with the applicable standards of the Occupational Health and Safety Management System (hereinafter “OH&S”) and preserve the documents specified in Article 2.2.4.6.13 of Decree 1072 of 2015.
To provide instructions pertaining to the employment contract.
To assess the Employee’s job performance.
To collect information and evidence for the purpose of conducting employee disciplinary processes, if necessary.
To store personal data in the Employer’s internal computer system.
To share and consult the data among the individuals specified in this Section, exclusively for the purposes set forth herein.
To use the information for procedures and documents related to the employment relationship between the Employee and the Employer.

2.1.5. Purposes for Processing Journalist Personal Data:

To send information related to closings or significant transactions for the preparation of reports.
To send information related to the Company’s events, awards, and/or activities.
To send invitations for events, cocktails, conferences, and social and/or academic activities of the Company.
To share information about activities that may serve as material for interviews or opinion pieces.

2.1.6. Purposes for Processing Providers Personal Data

To organize and register the providers’ information for the purpose of sending purchase orders.
To research, verify, and validate the information supplied by providers using data lawfully held by PPU COLOMBIA, as well as international lists related to criminal offenses and money laundering.
To communicate, consolidate, organize, update, control, verify, ensure, analyze, report, maintain, manage, and oversee the actions, information, and activities involving or linking providers and contractors with PPU COLOMBIA.
To draft reports on performance and compliance by the providers.

2.2. Sensitive data processing.

PPU COLOMBIA may access and use sensitive employee data such as videos, photographs, and fingerprints. Similarly, PPU COLOMBIA collects information about the health status of its employees in compliance with legal obligations related to occupational health and safety. For these purposes, PPU COLOMBIA shall apply the legal provisions regarding the processing of sensitive data, including the following:

a) To obtain the Data Subject’s explicit authorization for the processing, informing them of the voluntary nature of such consent and identifying the data classified as sensitive. This authorization shall be implemented in all sensitive data collection, except in the following cases where authorization is not required by legal provision:

a. The processing of the information is necessary to safeguard the vital interest of the Data Subject, and the Data Subject is physically or legally incapacitated. In these events, legal representatives must grant their authorization.

b. The processing of the information is carried out in the course of legitimate activities and with appropriate safeguards by a foundation, NGO, association, or any other non-profit organization with a political, philosophical, religious, or trade union purpose, provided that the data refers exclusively to its members or to individuals who maintain regular contact with it in connection with its purpose. In these events, data cannot be provided to third parties without the consent of the Data Subject.

c. The processing of information refers to data that is necessary for the recognition, exercise, or defense of a right in a legal proceeding.

d. The processing is conducted with a historical, statistical, or scientific purpose. In this event, measures must be adopted to ensure the anonymization of the Data Subjects’ identities.

In cases where PPU COLOMBIA has access to sensitive data, the use of such data will be carried out for the following purposes:

2.2.1. Data related to the health status and occupational medical history of applicants and employees for the following purposes:

To verify if the applicant meets the necessary physical requirements to perform the position for which they are applying or are hired.
To possess the necessary information to address any medical emergency that may arise during the provision of services at the facilities of PPU COLOMBIA.
To comply with occupational health and safety regulations and implement the Occupational Health and Safety Management System (OH&S), as well as any other program, system, and/or plan aimed at protecting the health of workers and individuals in the workplace.

2.2.2. Biometric data (fingerprints and photographs) of employees:

To identify personnel accessing the facilities of PPU COLOMBIA.
To grant access to PPU COLOMBIA facilities.
To verify the employee’s presence within the premises of PPU COLOMBIA.
To comply with the legal obligations arising from the employment relationship, such as undertaking all necessary procedures for the registration of beneficiaries before the Social Security System, or any other activity derived from the applicable legislation.
To ensure the safety in the training sessions and activities conducted by PPU COLOMBIA for its employees.
To advertise and disseminate the participation of PPU COLOMBIA employees in various activities, conferences, and social events.

2.3. Video surveillance

PPU COLOMBIA employs various video surveillance means installed in different areas of its facilities or offices.

The information collected will be used for the security purposes of individuals, property, and facilities. This information may be used as evidence in any type of proceeding before any type of authority and organization. PPU COLOMBIA shall implement authorizations for obtaining this information in compliance with regulations governing access to sensitive data.

2.4. Children and adolescents Data processing:

PPU COLOMBIA may process data of applicants’ or employees’ children who are under 18 years of age. This information is collected with the authorization of parents or legally authorized individuals, in accordance with the requirements outlined in data protection regulations. Therefore, the purposes of collecting this data are:

To identify an applicant’s children during visits and interviews conducted at the applicant’s residence.
To comply with the legal obligations arising from the employment relationship, such as carrying out all necessary procedures for the registration of beneficiaries with the authorities, such as the Social Security System, or any other activity derived from applicable legislation.
To inform employees about the wellness activities that PPU COLOMBIA has organized for their children.
To notify employees about the birth of children of PPU COLOMBIA officials.

3. Transfers and Transmissions of Personal Data.

PPU COLOMBIA transfers data of its clients and collaborators to international partners and members of its business group located in the United States, England, Spain, Peru, Chile, or any country where PPU operates, as part of business development, legal advisory, and the fulfillment of the purposes outlined in section

2.1. Of this Policy.

Similarly, PPU COLOMBIA carries out the transmission of personal data of its clients and collaborators due to the fact that several service providers hired by PPU COLOMBIA are located outside the country. Additionally, PPU COLOMBIA offers Cloud services for the storage of this information, with servers located outside the country. PPU COLOMBIA has implemented the necessary transmission authorizations and contracts for this purpose.

4. Rights of the Data Subject

In accordance with the provisions of Article 8 of Law 1581 of 2012 and Decree 1074 of 2015 (Chapter 25), the Data Subject has the following rights:

a) To be informed, update, and rectify their personal data with PPU COLOMBIA, in their capacity as the Data Controller. This right may be exercised against partial, inaccurate, incomplete, or fragmented data that could lead to error, or those whose processing is expressly prohibited or has not been authorized.

b) To request proof of the authorization granted to PPU COLOMBIA, in its capacity as Data Controller, unless expressly exempted as a requirement for Processing, in accordance with the provisions of Article 10 of Law 1581 of 2012 (or the regulations that govern, supplement, amend, or repeal it), or when the continuity of the use of information has been presented as provided for in numeral 4 of Article 2.2.2.25.2.7 of Decree 1074 of 2015.

c) To be informed by PPU COLOMBIA, upon request, about the use of your personal data.

d) To submit complaints before the Superintendency of Industry and Commerce for violations of the provisions of Law 1581 of 2012, once the query or claim process with PPU COLOMBIA has been fully pursued.

e) To revoke authorization and/or request the deletion of data when the Use of information does not adhere to constitutional and legal principles, rights, and guarantees. Revocation and/or deletion shall proceed when the Superintendence of Industry and Commerce has determined that the Controller or Processor has engaged in data processing practices that are contrary to the law and the Constitution.

f) To access their personal data that has been subject to Processing free of charge.

5. Department responsible for requests, inquiries, and complaints

The Ethics, Conflicts of Interest, and Regulatory Compliance Department of PPU COLOMBIA shall be responsible for handling requests, inquiries, claims, and complaints, as well as for facilitating the exercise of the Data Subject’s rights regarding personal information.

6. Procedure for Exercising the Rights of the Data Subject

6.1. Procedure for Access and Inquiry

The Data Subject, or their successors, may request the information stored in the databases held by PPU COLOMBIA. For this purpose, they must send the corresponding request to the email address [email protected], contact (1) 3268600 ext. 1640, or submit these requests in writing and file them at Cra 9 N. 74 – 08 Office 105, Monday to Friday from 8:00 AM to 1:00 PM or from 2:00 PM to 6:00 PM in the city of Bogotá.

In order to prevent unauthorized third parties from accessing the Data Subject’s personal information, it will first be necessary to establish the identification of the Data Subject. If the request is submitted by a person other than the Data Subject and such person does not provide evidence of acting on the Data Subject’s behalf, the request shall be deemed not submitted.

The inquiry will be addressed within a maximum period of ten (10) business days from the date of receipt. If it is not possible to respond to the inquiry within the established period, the interested party shall be informed of the reasons for the delay and given the date on which the inquiry will be addressed, which in no case may exceed five (5) business days following the expiration of the initial period.

6.2. Procedure for requesting updates, corrections, deletions, revocation of authorization, or for filing claims

The Data Subject, or their successors in title, who consider that the information contained in PPU COLOMBIA’s databases should be corrected, updated, or deleted, or who notice an alleged breach of any of the obligations set forth in this law, may submit a claim to PPU COLOMBIA, which shall be processed in accordance with the following rules, pursuant to Article 15 of Law 1581 of 2012:

a) The claim shall be made through an application that can be sent to the email [email protected] or by submitting a written communication from Monday to Friday between 8:00 AM to 1:00 PM or 2:00 PM to 6:00 PM, at Cra 9 N. 74 – 08 Office 105, in the city of Bogotá.

b) In order to prevent unauthorized third parties from accessing the Data Subject’s personal information, it will first be necessary to establish the identification of the Data Subject. If the request is submitted by a person other than the Data Subject and such person does not provide evidence of acting on the Data Subject’s behalf, the request shall be deemed not submitted.

c) The request must contain the following information:

(i) The identification of the Data Subject.

(ii) The contact information (physical and/or electronic address and contact phone numbers).

(iii) The documents that verify the identity of the Data Subject, or the representation of their representative.

(iv) Clear and precise description of the personal data regarding which the Data Subject seeks to exercise any of their rights.

(v) Description of the circumstances giving rise to the claim.

(vi) The documents intended to support the claim.

(vii) Signature, identification number, and fingerprint.

(viii) Filing of the original document.

d) If the claim is incomplete, PPU COLOMBIA shall request the interested party to correct the deficiencies within five (5) business days following receipt of the claim. If two (2) months have elapsed since the date of the request without the applicant submitting the required information, it shall be understood that the claim has been withdrawn.

e) If the department that receives the claim is not competent to address it, it shall forward the claim to the appropriate area within a maximum of two (2) business days and inform the interested party of the situation.

f) Once the complete claim is received, a note stating “claim in process” along with the reason for the claim will be included in the database within no more than two (2) business days. This notice must remain until the claim is resolved.

The maximum period to address the claim will be fifteen (15) business days counted from the day following the date of its receipt. If it is not possible to respond to the claim within the established period, the interested party shall be informed of the reasons for the delay and given the date on which the claim will be addressed, which in no case may exceed eight (8) business days following the expiration the initial period.

6.3. Data Suppression

The Data Subject has the right to request PPU COLOMBIA to delete their personal data, especially when:

a) The Data subject considers that the data is not being processed in accordance with the principles, duties, and obligations established under Law 1581 of 2012.

b) The data is no longer necessary or relevant for the purpose for which it was collected.

c) The period necessary to fulfill the purposes for which the data was collected has elapsed.

Such deletion implies the total or partial removal of personal information, as requested by the Data Subject, from the records, files, databases, or processing activities carried out by PPU COLOMBIA.

It is important to consider that the right of cancellation is not absolute, and the data controller may refuse its exercise when:

(i) The request for the deletion of information will not proceed when the Data Subject has a legal or contractual obligation to remain in the database.

(ii) The deletion of data hinders judicial or administrative proceedings related to tax obligations, the investigation and prosecution of crimes, or the updating of administrative sanctions.

(iii) The data is necessary to protect the Data Subject’s legally protected interests, to carry out an action in the public interest, or to fulfill a legally binding obligation undertaken by the Data Subject.

6.4. Revocation of Consent

The Data Subject may revoke consent to the Processing of their personal data at any time, provided that no legal provision prevents it.

7. Information Security

In accordance with the principle of security, PPU COLOMBIA has adopted reasonable technical, administrative, and human measures to protect the information of Data Subjects and to prevent its alteration, loss, consultation, use, or unauthorized or fraudulent access. Access to personal data is restricted to the Data Subjects themselves, and PPU COLOMBIA shall not allow third-party access to this information, except upon the express request of the Data Subject or by individuals legally authorized in accordance with national regulations.

8. Duration of the Policy

PPU COLOMBIA has had a Data Processing Policy in place since 2013. The amendments introduced in this version were disclosed on May 2, 2018. Any substantial changes to this policy will be announced through a notice on the website www.ppulegal.com.

The validity of the authorizations for the use of personal data shall be understood to last for the duration of the commercial relationship or service engagement, and for as long as the company’s corporate purpose is exercised, except in cases where the law establishes a different period.

Perú

PRIVACY POLICY

OBJECTIVE

The following Privacy Policy governs the processing of personal data carried out by Philippi, Prietocarrizosa, Ferrero DU & Uría S. Civil de R.L. located at Avenida Santa Cruz No. 888, Int. 401, district of Miraflores, province and department of Lima (the “Responsible Party” or “PPU Perú”), in accordance with the provisions contained in Law No. 29733 – Personal Data Protection Law, its Regulations approved by Supreme Decree. 003-2013-JUS, and complementary provisions.

SCOPE

It applies to PPU Peru clients in their various contracting processes and concerning the processing of their personal data.

DESCRIPTION OF DATA PROCESSING

3.1. PURPOSE

PPU Perú hereby informs you that your personal data will be processed for the following purposes.

a. To process and ensure compliance with and delivery of the services acquired by the clients.

b. To research, verify, and validate information provided by clients using data lawfully held by PPU Perú, as well as international lists related to criminal offenses and money laundering.

c. To store and organize client information records.

d. To issue the corresponding invoices.

e. To provide the data to natural or legal persons, domiciled in Peru or abroad, who are responsible for legal advisory or auditing services.

f. To comply with the mandates or requirements of administrative, police, tax, and judicial authorities.

g. In general, to use the information to comply with legal obligations and to carry out any procedure or sign any document related to the contractual relationship.

h. To send regulatory updates and/or alerts with legal or regulatory content.

i. To send satisfaction surveys or any other mechanisms to assess the quality of services provided by PPU Perú.

In order to carry out the aforementioned purposes, we require you to provide us with the following data: (i) name; (ii) surname; (iii) ID number; (iv) address; (v) phone number; (vi) email; (vii) photo; (viii) signature; (ix) marital status; (x) date of birth; (xi) nationality; (xii) gender; (xiii) profession; (xiv) age; (xv) credits, loans, guarantees; (xvi) banking details; (xvii) credit history; (xviii).

Tax-related information; (xix) patrimonial assets; (xx) debts; (xxi) economic income; and (xxii) passport.

Failure to provide the required personal data will prevent us from continuing with the contractual relationship.

Optionally, and provided we have obtained your prior and express consent, PPU Perú may inform you about activities, events, and webinars organized by PPU Perú. Additionally, you may provide information about the services and/or products offered by PPU Perú.

Your data will be stored in the database named “Clients,” registered in the National Registry of Personal Data Protection with code RNPDP No. 19433.

3.2. CONSIDERATIONS

Your data will be retained for the duration of the relationship between the parties, unless you request its cancellation, or it is necessary for the fulfillment of legal obligations.
Your personal data is shared within the limits and circumstances specified in this Privacy Policy.
PPU Perú transfers personal data to group companies (detailed in the following table) for business development and legal advice, as indicated in section 3 regarding the purposes of this Privacy Policy:

Recipient	Country
Philippi, Prietocarrizosa, Ferrero Du & Uría S.A.S.	Colombia
Philippi, Prietocarrizosa, Ferrero Du & Uría S.P.A.	Chile
Uría Menéndez Abogados S.L.P.	Spain

The collected personal data will be stored on the servers provided and managed, as detailed below.

Recipient	Country	Purpose
Microsoft	United States of America	Provision of cloud services

Unless otherwise stated above, should there be a legal obligation or requirement from any competent authority, your personal data shall not be disclosed to third-party individuals or legal entities that do not serve as data processors for PPU Perú.

3.3. RIGHTS AS DATA SUBJECTS

As the Data subjects of your personal data, you may exercise your rights to access, rectify, cancel, object, as well as revoke your consent for the use of your data, when applicable, with the Human Management area of PPU Perú, located at Santa Cruz No. 888, Int. 401, Miraflores district, province and department of Lima or to the email: [email protected]

If you believe that your rights have not been addressed, you may file a complaint with the National Authority for the Protection of Personal Data by contacting the Front Desk of the Ministry of Justice and Human Rights (Calle Scipión Llona 350, Miraflores, Lima, Peru).

3.4. SECURITY OF YOUR PERSONAL DATA

PPU Perú is committed to protecting the security and confidentiality of your personal data. We hereby declare that, in order to prevent the loss, misuse, alteration, unauthorized access, and theft of the personal data or confidential information you provide to us, we have adopted the legally required personal data protection security measures and levels, and we have implemented all the means and technical measures at our disposal.

PRIVACY POLICY (PROVIDER)

PURPOSE

SCOPE

It applies to Providers of PPU Perú in their various engagement processes and with respect to the processing of their personal data.

DESCRIPTION OF DATA PROCESSING

3.1. PURPOSE

PPU Perú hereby informs you that your personal data will be processed for the following purposes:

To send purchase orders and/or service contracts with the provider.
To research, verify, and validate information provided by the providers using data lawfully held by PPU Perú, as well as international lists related to criminal offenses and money laundering.
To store and organize providers with information records.
To make the necessary payments to the bank account designated by the provider.
To draft reports on performance and compliance with suppliers.
To comply with the mandates or requirements of administrative, police, tax, and judicial authorities.
In general, to use the information to comply with legal obligations and to carry out any procedure or sign any document related to the contractual relationship.

In order to carry out the aforementioned purposes, we require you to provide us with the following data: (i) name; (ii) surname; (iii) ID number; (iv) address; (v) phone number; (vi) email; (vii) photo; (viii) signature; (ix) marital status; (x) date of birth; (xi) nationality; (xii) sex; (xiii) profession; (xiv) age; (xv) bank details; (xvi) tax information; (xvii) insurance; (xviii) debts; and, (xix) passport.

Failure to provide the required personal data will prevent us from continuing with the contractual relationship.

Your data will be stored in the database named “Providers”, registered with the National Registry of Personal Data Protection under code RNPDP No. 19434.

3.2. CONSIDERATIONS

Your data will be retained for the duration of the relationship between the parties, unless you request its cancellation, or it is necessary for the fulfillment of legal obligations.
Your personal data is shared within the limits and circumstances specified in this Privacy Policy.
PPU Perú transfers personal data to group companies (detailed in the following table) for business development and legal advice, as indicated in section 3 regarding the purposes of this Privacy Policy:

Recipient	Country
Philippi, Prietocarrizosa, Ferrero Du & Uría S.A.S.	Colombia
Philippi, Prietocarrizosa, Ferrero Du & Uría S.P.A.	Chile
Uría Menéndez Abogados S.L.P.	Spain

The collected personal data will be stored on the servers provided and managed, as detailed below:

Recipient	Country	Purpose
Microsoft	United States of America	Provision of cloud services

Except as stated above, unless there is a legal obligation or requirement by a competent authority, your personal data will not be shared with third-party individuals or legal entities that do not act as data processors for PPU.

3.3. RIGHTS AS DATA SUBJECTS

3.4. SECURITY OF YOUR PERSONAL DATA

PRIVACY POLICY (APPLICANTS AND WEB USERS)

PURPOSE

SCOPE

It applies to Applicants and Web users of PPU Perú in their various engagement processes and with respect to the processing of their personal data.

DESCRIPTION OF DATA PROCESSING

3.1. DESCRIPTION OF PROCESSING

A. To access any of our job or partnership opportunities, you may voluntarily provide us with your personal data, which will be handled as follows:

Purpose: To carry out calls for applications to our job or partnership opportunities, participation in talks, evaluations, and the hiring of collaborators.

Personal Data: In order to carry out the aforementioned purposes, we require you to provide us with the following data: (i) name; (ii) surname; (iii) ID number; (iv) address; (v) phone number; (vi) email; (vii) signature; (viii) date of birth; (ix) nationality; (x) gender; (xi) profession; (xii) academic information; (xiii) membership in clubs or associations (professional organizations).

Failure to provide the required personal data will prevent us from proceeding with the selection process.

Database: Your data will be stored in the database named “Applicants” registered in the National Registry of Personal Data Protection with code RNPDP No. 13227.

B. Personal data through “contact us” will be processed in accordance with the following:

Purpose: To manage and address your request submitted through the contact us section of our website.

Personal Data: In order to carry out the aforementioned purposes, we require you to provide us with the following data: (i) first name; (ii) last name; and (iii) email address.

Failure to provide the required personal data will prevent us from processing your request submitted through the contact us section of our website.

Optionally and provided we have obtained your prior and explicit consent, PPU Perú may send you communications related to PPU Perú’s services and commercial activities.

Database: Your data will be stored in the database named “Web User,” registered in the National Registry of Personal Data Protection with code RNPDP No. 19431.

3.2. CONSIDERATIONS

Your data will be retained for the duration of the relationship between the parties, unless you request its cancellation, or it is necessary for the fulfillment of legal obligations.
PPU Perú transfers the personal data of Applicants to the companies within the business group, as part of their business operations for the selection of such personnel, according to the following details:

Recipient	Country
Philippi, Prietocarrizosa, Ferrero Du & Uría S.A.S.	Colombia
Philippi, Prietocarrizosa, Ferrero Du & Uría S.P.A.	Chile
Uría Menéndez Abogados S.L.P.	Spain

Furthermore, the Applicants’ personal data collected will be stored on the servers provided and managed, as detailed below:

Recipient

Country

Purpose

Oracle

United States of

America

Provision of cloud services

The personal data of web Users collected through the PPU Perú website will be stored on servers provided and managed, as detailed below:

Recipient

Country

Purpose

Oracle

United States of

America

Provision of cloud services

Unless otherwise stated above, should there be a legal obligation or requirement from any competent authority, your personal data shall not be disclosed to third-party individuals or legal entities that do not serve as data processors for PPU Perú.

3.3. RIGHTS AS DATA SUBJECTS

3.4. SECURITY OF YOUR PERSONAL DATA

Colombia

PRIVACY NOTICE

To comply with commercial obligations within the framework of contractual relationships.
To send newsletters related to legal topics to PPU COLOMBIA clients.
To send invitations to participate in events organized by PPU COLOMBIA.
To provide information about training sessions or conferences scheduled by PPU COLOMBIA.
To assess the quality of services provided by PPU COLOMBIA.
To conduct market research and consumer behavior studies, statistical analyses, and customer behavior reports.

Company’s Information

Company Name: Philippi, Prietocarrizosa, Ferrero DU & Uría S.A.S.
Address: Bogotá D.C., Colombia.
Address: Carrera 9 N. 74 – 08 Oficina 105.
Email: [email protected]
Telephone: 3268600 ext. 1437

To learn about the personal data processing policy of PPU COLOMBIA as well as any substantial changes made to it, we invite you to click here.

PERSONAL DATA PROCESSING POLICY

1. Company’s Information

Company Name: Philippi, Prietocarrizosa, Ferrero DU & Uría S.A.S
Address: Bogotá D.C., Colombia.
Address: Cra. 9 N. 74 – 08 Office 105
Email: [email protected]
Telephone: 3268600 ext 1437

2. Use and Processing of Personal Information

2.1. Public and private Personal Data Processing.

2.1.1. Purposes for Processing Alumni Personal Data:

To send commercial information from PPU COLOMBIA.
To share information related to the ALUMNI event organized by PPU COLOMBIA.

2.1.2. Purposes for Processing Applicant Personal Data:

To analyze an Applicant’s information for the purpose of initiating a recruitment process.
To contact the Applicant to express the interest in initiating a recruitment process.
To verify the truthfulness and authenticity of the information provided in your resume with the institutions where you have pursued your studies and held positions.
To begin the assessment of housing and safety conditions to determine eligibility for employment at PPU Colombia.
To share your data with PPU COLOMBIA’s partners and clients who are interested in contacting individuals with your profile to explore potential employment opportunities.

2.1.3. Purposes for Processing Client Personal Data:

To comply with commercial obligations within the framework of contractual relationships.
To process and ensure the compliance and delivery of products and/or services acquired by PPU COLOMBIA’s clients, as well as prepare the corresponding billing.
To send advertising and promotional materials about PPU COLOMBIA’s products and services.
To offer products from PPU COLOMBIA’s various business lines.
To announce discounts, promotions, and new product launches.
To perform client analysis and profiling to identify products to best suit clients purchasing preferences and tastes.
To notify information of activities and events organized by PPU COLOMBIA.
To conduct market research and consumer behavior studies, statistical analyses, and client behavior reports.
To design and provide loyalty and benefit programs for clients.
To send satisfaction surveys or any other mechanisms to assess the quality of products and services provided by PPU COLOMBIA.

2.1.4. Purposes for Processing Employee Personal Data:

To comply with the Employer’s labor obligations as established in labor legislation, the employment contract, and the Internal Work Regulations, such as: affiliation to the Comprehensive Social Security System and payment of contributions, affiliation to the Compensation Fund and payment of contributions, payment to the DIAN (National Tax and Customs Directorate) of withheld amounts, issuance of income and withholding certificates and employment certificates, as well as, to provide information to any national entity or authority requiring personal data, in accordance with current regulations.
To make the necessary payments to the bank account designated by the Employee or entities expressly indicated by the Employee.
To hire life and/or medical insurance coverage, or to grant any other benefits derived from the employment relationship with the Employer, if applicable.
To notify family members in case of emergencies during working hours or in the course of work-related activities.
To ensure the safety and health of workers in the workplace, in accordance with the applicable standards of the Occupational Health and Safety Management System (hereinafter “OH&S”) and preserve the documents specified in Article 2.2.4.6.13 of Decree 1072 of 2015.
To provide instructions pertaining to the employment contract.
To assess the Employee’s job performance.
To collect information and evidence for the purpose of conducting employee disciplinary processes, if necessary.
To store personal data in the Employer’s internal computer system.
To share and consult the data among the individuals specified in this Section, exclusively for the purposes set forth herein.
To use the information for procedures and documents related to the employment relationship between the Employee and the Employer.

2.1.5. Purposes for Processing Journalist Personal Data:

To send information related to closings or significant transactions for the preparation of reports.
To send information related to the Company’s events, awards, and/or activities.
To send invitations for events, cocktails, conferences, and social and/or academic activities of the Company.
To share information about activities that may serve as material for interviews or opinion pieces.

2.1.6. Purposes for Processing Providers Personal Data

To organize and register the providers’ information for the purpose of sending purchase orders.
To research, verify, and validate the information supplied by providers using data lawfully held by PPU COLOMBIA, as well as international lists related to criminal offenses and money laundering.
To communicate, consolidate, organize, update, control, verify, ensure, analyze, report, maintain, manage, and oversee the actions, information, and activities involving or linking providers and contractors with PPU COLOMBIA.
To draft reports on performance and compliance by the providers.

2.2. Sensitive data processing.

c. The processing of information refers to data that is necessary for the recognition, exercise, or defense of a right in a legal proceeding.

d. The processing is conducted with a historical, statistical, or scientific purpose. In this event, measures must be adopted to ensure the anonymization of the Data Subjects’ identities.

In cases where PPU COLOMBIA has access to sensitive data, the use of such data will be carried out for the following purposes:

2.2.1. Data related to the health status and occupational medical history of applicants and employees for the following purposes:

To verify if the applicant meets the necessary physical requirements to perform the position for which they are applying or are hired.
To possess the necessary information to address any medical emergency that may arise during the provision of services at the facilities of PPU COLOMBIA.
To comply with occupational health and safety regulations and implement the Occupational Health and Safety Management System (OH&S), as well as any other program, system, and/or plan aimed at protecting the health of workers and individuals in the workplace.

2.2.2. Biometric data (fingerprints and photographs) of employees:

To identify personnel accessing the facilities of PPU COLOMBIA.
To grant access to PPU COLOMBIA facilities.
To verify the employee’s presence within the premises of PPU COLOMBIA.
To comply with the legal obligations arising from the employment relationship, such as undertaking all necessary procedures for the registration of beneficiaries before the Social Security System, or any other activity derived from the applicable legislation.
To ensure the safety in the training sessions and activities conducted by PPU COLOMBIA for its employees.
To advertise and disseminate the participation of PPU COLOMBIA employees in various activities, conferences, and social events.

2.3. Video surveillance

PPU COLOMBIA employs various video surveillance means installed in different areas of its facilities or offices.

2.4. Children and adolescents Data processing:

To identify an applicant’s children during visits and interviews conducted at the applicant’s residence.
To comply with the legal obligations arising from the employment relationship, such as carrying out all necessary procedures for the registration of beneficiaries with the authorities, such as the Social Security System, or any other activity derived from applicable legislation.
To inform employees about the wellness activities that PPU COLOMBIA has organized for their children.
To notify employees about the birth of children of PPU COLOMBIA officials.