1. INTRODUCTION
HUMAN TEAMS S.A.S., as a company legally incorporated in Colombia, and in order to safeguard the constitutional and regulatory guarantees enshrined in Article 15 of the Political Constitution of Colombia, concerning the right of all persons to their family and personal privacy, and likewise the possibility to know, update and rectify the information that has been collected about them in data banks and files of public and private entities, has established this policy for the protection of personal data in accordance with Law 1581 of 2012 and Regulatory Decree 1377 of 2013.

2. OBJECTIVE
Provide necessary information, guidelines and protect the right of all individuals to know, update and rectify the information that has been collected about them in databases or files that are susceptible of being processed by HUMAN TEAMS S.A.S. in order to comply with the law, policies and procedures of attention to the rights of holders, criteria for collection, storage, use, circulation and deletion of personal data.

3. TARGET AUDIENCE
This policy must be disclosed, known and shall be applied to all databases and/or digital files containing personal data and which are subject to processing by HUMAN TEAMS S.A.S.considered as responsible and/or in charge of the processing of personal data.

4. SCOPE
To comply with the requirements of the regulations in force regarding Personal Data Protection, as well as with any requirement originated in the principle of proven responsibility.

To comply with the requirements of the regulations in force regarding Personal Data Protection, as well as with any requirement originated in the principle of proven responsibility.

5. GLOSSARY
In the development, interpretation and application of the law, regulations and standards in force, the following definitions shall be applied harmoniously and integrally:

Authorization: Prior, express and informed consent of the holder to carry out the processing of personal data.
Privacy Notice: Verbal or written communication generated by the responsible party, addressed to the holder for the processing of his personal data, by means of which he is informed about the existence of the Information Processing Policies that will be applicable to him, the way to access them and the purposes of the processing that is intended to be given to the personal data. 
Database: Organized set of personal data that is the object of processing.
Confidentiality: Information security element that makes it possible to establish who can access the information and under what circumstances.
Personal Data: Any information linked or that can be associated to one or several determined or determinable natural persons.
Sensitive Data: Information that affects the privacy of individuals or whose misuse may lead to discrimination (Racial or ethnic origin, political orientation, philosophical or religious convictions, relevance to trade unions or social organizations or human rights, health, sex life and biometric data).
Public Personal Data: According to the law or political constitution and all those that are semi-private or private, are public, among others, the data contained in public documents, duly executed judicial sentences that are not subject to reserve and those related to the civil status of persons. Among others, the personal data contained in the commercial registry of the Chambers of Commerce are public. (Article 26 of the CO Code)In addition, data may be obtained and made available without reservation and regardless of whether it relates to general, private or personal information. 
Personal Data:Personal data: Any information linked or capable of being linked to one or more specific or identifiable natural persons. Personal data" must therefore be understood as information relating to a natural person.
Semiprivate Personal Data: It is information that is not of an intimate, reserved or public nature and whose knowledge or disclosure may be of interest not only to its owner but also to a certain sector or group of persons or to society in general, as is the case of financial, credit or commercial activities data.
Data Processor: Natural or legal person, public or private, that by itself or in association with others, carries out the processing of personal data on behalf of the Controller.
Información DigitalAll information that is stored or transmitted by electronic and digital means such as e-mail or other information systems.
Claim: Request from the owner of the data or the persons authorized by the owner or by law to correct, update or delete their personal data.
Responsible for the treatment: Natural or legal person, public or private, who alone or in association with others, decides on the database and/or the processing of data.
Headline: Natural person whose personal data is processed.
Transfer: The transfer of data takes place when the Controller and/or Processor of personal data, located in Colombia, sends the information or personal data to a recipient, which in turn is the Data Controller and is located inside or outside the country. 
Transmission: Processing of personal data that involves the communication of such data within or outside the territory of the Republic of Colombia when the purpose of the processing is to be carried out by the processor on behalf of the controller.
Treatment: Any operation or set of operations on personal data, such as collection, storage, use, circulation or deletion.

6. PRINCIPLES
The processing of personal data will be carried out in compliance with the general and special rules in force on the matter and for activities permitted by law.
In the development, interpretation and application of Law 1581 of 2012, which establishes general provisions for the protection of personal data and the rules that complement, modify or add to it, the following guiding principles shall be applied in a harmonious and comprehensive manner: 

6.1. PRINCIPLE OF LEGALITY IN DATA PROCESSING: Treatment is a regulated activity that must be subject to the provisions of the law and other provisions that develop it. 

6.2. PRINCIPLE OF FINALITY: The processing must obey a legitimate purpose in accordance with the Constitution and the Law, which must be informed to the owner. 

6.3. PRINCIPLE OF TEMPORALITY: Personal data will be kept for the reasonable time necessary to fulfill the purpose of the processing and the legal requirements or instructions of the supervisory and control authorities or other competent authorities. The data will be kept when this is necessary to comply with a legal or contractual obligation. To determine the term of the processing, the rules applicable to each purpose and the administrative, accounting, fiscal, legal and historical aspects of the information will be considered.

6.4. PRINCIPLE OF FREEDOM: The treatment can only be exercised with the prior, express, and informed consent of the holder. Personal data may not be obtained or disclosed without prior authorization, or in the absence of legal or judicial mandate that relieves the consent. 

6.5. PRINCIPLE OF COLLECTION LIMITATION: Personal data will be collected that are strictly necessary for the fulfillment of the purposes of the processing, so that the recording and disclosure of data that are not closely related to the purpose of the processing is prohibited. Accordingly, reasonable efforts will be made to limit the processing of personal data to the minimum necessary. In other words, the data must be: 
Adequate.
Relevant.
In accordance with the purposes for which they were intended.
 
6.6. PRINCIPLE OF TRANSPARENCY: The right of the data subject to obtain from the controller or processor, at any time and without restriction, information about the existence of data concerning him/her, must be guaranteed in the processing. 

6.7. PRINCIPLE OF RESTRICTED ACCESS AND CIRCULATION: The processing is subject to the limits deriving from the nature of the personal data, the provisions of the law and the Constitution. In this sense, the processing may only be carried out by persons authorized by the owner and/or by the persons provided for by law. Personal data, except for public information, may not be available on the Internet or other means of dissemination or mass communication, unless access is technically controllable to provide restricted knowledge only to the owners or third parties authorized by law. 

6.8. SAFETY PRINCIPLE: The information subject to processing by HUMAN TEAMS S.A.S.The records shall be managed with the technical, human and administrative measures necessary to ensure the security of the records, avoiding their adulteration, loss, consultation, use or unauthorized or fraudulent access. 

6.9. CONFIDENTIALITY PRINCIPLE: HUMAN TEAMS S.A.S., is obliged to guarantee the confidentiality of the information, even after the end of its relationship with any of the tasks included in the processing, and may only provide or communicate personal data when it corresponds to the development of the activities authorized by law. 

7.  DERECHOS QUE LE ASISTEN AL TITULAR DE LA INFORMACIÓN 
The holder of the personal data shall have the following rights: 
7.1. To know, update and rectify your personal data in front of HUMAN TEAMS S.A.S.in its capacity as data controller. This right may be exercised, among others, against partial, inaccurate, incomplete, fractioned, misleading data.
7.2. Request proof of the authorization granted to HUMAN TEAMS S.A.S., except when expressly exempted as a requirement for treatment (cases in which authorization is not required). 
7.3. To be informed by HUMAN TEAMS S.A.S.Upon request, regarding the use you have made of your personal data. 
7.4. File complaints before the Superintendency of Industry and Commerce for violations of the provisions of Law 1581 of 2012 and other regulations that modify, add or complement it. 
7.5. To revoke the authorization and/or request the deletion of the data when the processing does not respect the constitutional and legal principles, rights and guarantees. 
7.6. Access free of charge to your personal data that has been processed.

8. DUTIES OF HUMAN TEAMS S.A.S.
Under this policy for the protection of personal data are duties of HUMAN TEAMS S.A.S.The following, without prejudice to the provisions of the law. 
8.1. Guarantee the holder, at all times, the full and effective exercise of the right of habeas data. 
8.2. Request and keep a copy of the respective authorization granted by the owner. 
8.3. Duly inform the owner about the purpose of the collection and the rights he/she has by virtue of the authorization granted. 
8.4. Keep the information under the necessary security conditions to prevent its adulteration, loss, consultation, unauthorized or fraudulent use or access. 
8.5. Ensure that the information is truthful, complete, accurate, up-to-date, verifiable and understandable. 
8.6. Update the information, thus taking care of all the novelties with respect to the holder's data. Additionally, all necessary measures must be implemented to keep the information updated. 
8.7. Rectify the information when it is incorrect and communicate the pertinent. 
8.8. Respect the security and privacy conditions of the holder's information. 
8.9. Process inquiries and claims formulated in the terms established by law. 
8.10. Identify when certain information is under discussion by the owner.  
8.11. Inform the holder's request about the use given to his data. 
8.12. Informs the data protection authority when there are violations to the security codes and there are risks in the administration of the information of the holders. 
8.13. Comply with the requirements and instructions issued by the Superintendence of Industry and Commerce on the particular subject. 
8.14. Use only data whose processing is previously authorized in accordance with the provisions of Law 1581 of 2012. 
8.15. HUMAN TEAMS S.A.S.will use the personal data of the holder only for those purposes for which it is duly authorized and respecting in any case the current regulations on personal data protection. 

9. TREATMENT OF PERSONAL DATA
Under this policy for the protection of personal data are duties of HUMAN TEAMS S.A.S.The following, without prejudice to the provisions of the law. 

9.1. SENSITIVE DATA:
HUMAN TEAMS S.A.S.shall restrict the processing of sensitive personal data to what is strictly indispensable and shall request prior and express consent from the owners, informing them of the exclusive purpose of the processing. HUMAN TEAMS S.A.S.uses and treats data classified as sensitive:
The processing has been expressly authorized by the owner of the sensitive data, except in cases where, by law, the granting of such authorization is not required.
The treatment is necessary to safeguard the vital interest of the holder and he/she is physically or legally incapacitated. In these events, the legal representatives must grant authorization.
The processing refers to data that are necessary for the recognition, exercise or defense of a right in a judicial proceeding.
The processing has a historical, statistical or scientific purpose or, within the framework of improvement processes; the latter, provided that measures are taken to suppress the identity of the owners or the data is dissociated, i.e., the sensitive data is separated from the identity of the owner and is not identifiable or it is not possible to identify the owner of the data or sensitive data.
 
9.2. PERSONAL DATA:
The processing of personal data of customers, employees, former employees, suppliers, contractors, or any person with whom the company has a business relationship. HUMAN TEAMS S.A.S.The Company, whether it has established or establishes a permanent or occasional relationship, shall do so within the legal framework that regulates the matter.
In any case, personal data may be collected and processed for:
To send information related to programs, activities, news, contents by area of interest, products and other goods or services offered by the Company. HUMAN TEAMS S.A.S.
Comply with regulations applicable to suppliers and contractors, including, but not limited to, tax and commercial regulations. 
Comply with the provisions of the Colombian labor and social security laws, among others, applicable to former employees, current employees and candidates for future employment. 
Conduct satisfaction surveys related to services or goods. of HUMAN TEAMS S.A.S.
Access and consult the information of the owner of the data held or contained in databases or files of any Private or Public Entity. (such as, among others, the Ministries, Administrative Departments, the DIAN, the Public Prosecutor's Office, the National Civil Registry, the Courts, tribunals and High Courts). whether domestic or foreign.
 
9.3. DATABASES:
HUMAN TEAMS S.A.S., has classified the databases as listed below:
CUSTOMER DATABASES
These are databases that contain data of legal or natural persons as clients who voluntarily and in the exercise of their commercial relationship, through the provision of services of HUMAN TEAMS S.A.S.,
SUPPLIER AND CONTRACTOR DATABASES.
These are databases containing data of natural persons who maintain a contractual relationship whose processing has the purpose of complying with the contractual provisions stipulated in the contracts for the acquisition of services and goods demanded by the company. HUMAN TEAMS S.A.S., for its operation and/or fulfillment of some of its functions. This database contains public, private and sensitive personal data, which are intended for the development of contractual relationships. The processing of this data for purposes other than the maintenance of the contractual relationship or the fulfillment of legal duties, requires prior authorization from the owner.
The purposes for which the personal data of suppliers will be used will be: 
Sending invitations to contract and making arrangements for the pre-contractual, contractual and post-contractual stages. 
The others specifically established in the authorizations that are granted by the suppliers themselves, when these are required in accordance with the regulations in force or in accordance with Law 1581 of 2012.
 
HUMAN TEAMS S.A.S., may collect personal data of employees from its suppliers when, for security reasons, it must analyze and evaluate the suitability of certain persons, according to the characteristics of the services contracted with the supplier. 
The collection of the personal data of employees of suppliers by HUMAN TEAMS S.A.S., The purpose of this requirement is to verify the moral suitability and competence of the employees; therefore, once this requirement has been verified, HUMAN TEAMS S.A.S., return such information to the supplier, except when expressly authorized to retain it. 
When HUMAN TEAMS S.A.S.if the Company provides personal data of any Data Subject to its suppliers, the latter shall protect the personal data provided, in accordance with the provisions of the regulations in force. For such purpose, the respective audit provision shall be included in the contract or document that legitimizes the delivery of personal data. HUMAN TEAMS S.A.S.The company will verify that the data requested are necessary, pertinent and not excessive with respect to the purpose on which the request for access to them is based.

10. EXPRESS AUTHORIZATION TO USE COOKIES
HUMAN TEAMS S.A.S. needs to implement its own and third party cookies, to offer its web services and additionally provide a quality service to all users who use such services, please note that if you choose not to use some cookies, this website may not function properly, present failures or prevent the operation of some of its features, affecting the user experience.

10.1. DEFINICIÓN Y TIPO DE COOKIES
A cookie is a small piece of text that is stored in your browser when you visit almost any web page. Its usefulness is that the web is able to remember your visit when you return to browse that page. Cookies usually store technical information, personal preferences, personalization of content, usage statistics, links to social networks, access to user accounts, etc.. Cookies allow that page, among other things, store and retrieve information about your browsing habits or your computer, and depending on the information they contain and the way you use your computer, can be used to recognize the user and facilitate navigation on the website.
The user's browser stores cookies on the hard disk occupying minimal memory space and without harming the computer. Most cookies are deleted from the hard disk at the end of the browser session (so-called session cookies). The most popular browsers (such as Google Chrome, Mozilla Firefox or Internet Explorer) constantly use cookies to ensure a better and more efficient user experience. Typically, browsers offer the possibility to be configured to allow or prevent the collection of certain types of cookies. The data they store are of a technical nature, statistics, personal preferences, content personalization, etc.

10.2. CURRENT REGULATIONS
In Colombia, there are no regulatory bodies that have defined cookies or their regulation. However, within our good corporate practices and attending to the application of the duties enshrined in the Colombian data protection regulations (which include Law 1581 of 2012, Decree 1377 of 2013, among others) we have developed this policy, with special attention to the principles of purpose, freedom, transparency and truthfulness of the data.

10.3. ACCEPTANCE OF THE USE OF COOKIES
If the User has indicated through the button [Accept and continue], found in the drop-down notification on the website, that he/she agrees with the treatment of cookies and in that sense, remains in the same and/or does not disable the use of cookies in his/her browser, we understand that he/she has consented to their use. However, at any time, you can revoke it and disable cookies, deleting those stored on your computer, through the settings and configurations of your browser.

9.4. DISABLING OR DELETING COOKIES
The user, in his first access to the website can configure and accept or reject cookies on this Website. Subsequently, the user may, at any time, change or withdraw their consent through this Cookies Policy or configure their browser.

11. PERSONS RESPONSIBLE AND IN CHARGE OF THE INFORMATION
HUMAN TEAMS S.A.S., as a legal entity, is the general controller of the personal data of customers, employees, former employees, suppliers, contractors, or any other person with whom it HUMAN TEAMS S.A.S., established or established a relationship, permanent or occasional.

The channels of communication with HUMAN TEAMS S.A.S.are:

Website: https://human-teams.com/contact/
E-mail: hola@human-teams.com
Phone: 57 322 7918338
 
12. LAW, JURISDICTION AND VALIDITY 
Any interpretation, judicial or administrative action derived from the processing of personal data that make up the databases of HUMAN TEAMS S.A.S.This policy shall be subject to the rules of personal protection established in the Republic of Colombia and the competent administrative or jurisdictional authorities for the resolution of any concern, complaint or lawsuit about them will be those of the Republic of Colombia. On the other hand, in general, the information in our Databases will remain being treated as long as a legal or contractual relationship is maintained with the Holder of the information. In any case, in general, the information will not be object of Treatment for a period of more than twenty (20) years counted from its collection according to the legal or contractual circumstances that make necessary the handling of the information, without prejudice that, in any case, it will be kept if necessary to comply with statistical or historical management or any obligation of legal nature.