Personal Data Processing Policy
VIRTUS GLOBAL SAS
To comply with the current legislation on data protection, especially Law 1581 of 2012 and Decree 1377 of 2013, below we inform you of the relevant elements concerning the collection, storage, use, and transmission of personal data that VIRTUS GLOBAL SAS (hereinafter “VIRTUS GLOBAL”) makes of your personal data.
In this personal data processing policy, you will find the corporate and legal guidelines under which VIRTUS GLOBAL processes your data, its purpose, your rights as owner, as well as the internal and external procedures for the exercise of such rights.
1. Identification of the individual responsible for data control
VIRTUS GLOBAL SAS, located at Calle 98 No.22-64 of. 410 Bogotá DC, Colombia, website https://virtus.global/en/home/, email email@example.com and telephone (571) 8052741, ( 571) 3112024771, (571) 3102888265.
2. Purposes and Treatment to which the Personal Data will be subjected
The personal data provided to VIRTUS GLOBAL will be stored in the VIRTUS GLOBAL databases and will be used for any of the following purposes:
- Clients: The processing of the data will be carried out to provide the advisory or consultancy services contracted with VIRTUS GLOBAL, and to send information of interest to VIRTUS GLOBAL clients and documentation related to the execution of the contract.
- Employees: The processing of data will be carried out for purposes related to their entailment, execution, and termination of the employment relationship that arises between the employee and VIRTUS GLOBAL.
- Suppliers and Contractors: The processing of data will be carried out to contact and hire suppliers or contractors’ products or services that VIRTUS GLOBAL requires for the normal functioning of its operation and the adequate provision of its facilities or offices.
- Job candidates: The processing of personal data will be carried out for personnel selection processes and hiring employees.
- Shareholders: The processing of personal data will be carried out for the communication, registration, filing, organization, processing, and management of the actions, strategies, and activities in which the shareholders of VIRTUS GLOBAL are involved.
Consequently, for the purposes described, VIRTUS GLOBAL may:
- Know, store and process all the information provided by the holders in one or several databases in the format it deems most convenient.
- Sort, catalog, classify, divide or separate the information provided by the owners.
- Verify, corroborate, validate, investigate or compare the information provided by the holders with any legitimately available information.
- Access, consult, compare and evaluate all the information about the holders stored in the databases of any legitimately constituted credit, financial, judicial background, or security risk center, of state or private, national or foreign nature.
- Analyze, process, evaluate, treat or compare the information provided by the holders.
In the event that VIRTUS GLOBAL is not able to carry out the treatment by its own means, it may transfer the data collected to be processed by a third party, with prior notification to the owners of the data collected, who will be in charge of the treatment. and must guarantee suitable conditions of confidentiality and security of the information transferred for treatment.
3. Rights of the holder
In accordance with article 8 of Law 1581 of 2012, the rights of the owner in relation to their personal data are:
- Know, update, and rectify your personal data facing VIRTUS GLOBAL as those responsible for the treatment or those in charge of the treatment. This right may be exercised, among others, against partial, inaccurate, incomplete, fragmented, misleading data, or that of which treatment is expressly prohibited or has not been authorized;
- Request proof of the authorization granted to VIRTUS GLOBAL as data controllers, except when expressly excepted as a requirement for processing;
- Be informed by VIRTUS GLOBAL, as data controllers or by the data processor, upon request, regarding the use that has been given to your personal data;
- Submit complaints to the Superintendence of Industry and Commerce for violations of the provisions of this law and the other regulations that modify, add or complement it;
- Revoke the authorization and/or request the deletion of the data when the principles, rights, and constitutional and legal guarantees are not respected in the treatment;
- Free access to your personal data that has been processed.
4. Sensitive Data
The owner has the right to choose not to respond to any sensitive information requested by VIRTUS GLOBAL, related, among others, to data on their racial or ethnic origin, membership in trade unions, social or human rights organizations, political, religious, life convictions, sexual, biometric, or health data.
5. Data of Minors
The provision of the personal data of minors is optional and must be done with the authorization of the minor’s parents or legal representatives.
6. Procedure for exercising your rights as owner
The owner has the right to request proof of the authorization granted to VIRTUS GLOBAL and to know, update and rectify their personal data. The owner may also request the deletion of the information from our databases or the revocation of the authorization granted for the processing of your personal data.
When making a request, the owner must present the following documents:
- The holder: Attach a copy of their identity document.
- The successor in title: Identity document, civil death record of the holder, document that proves the capacity in which he acts and the holder’s identity document number.
- Legal representative and/or proxy: Valid identity document, document that proves the capacity in which it acts (Power of Attorney) and the holder’s identity document number.
The query will be answered within a maximum term of ten (10) business days from the filing date.
When the consultation cannot be attended within said term, you will be informed of the reasons for the delay, and the date in which your consultation will be attended, which in no case may exceed five (5) business days following the expiration of the first established term.
The owner may access his personal data free of charge and the requested information may be provided by any means, including electronic means, as required.
7. Information Security
VIRTUS GLOBAL has adopted reasonable security measures to protect the information of the holders and prevent unauthorized access to their data or any unauthorized modification, disclosure or destruction thereof. Access to personal data is restricted to those employees, contractors, representatives and agents of VIRTUS GLOBAL in charge of data processing and who need it to perform their duties and develop the established corporate purpose. VIRTUS GLOBAL does not allow access to this information by third parties under conditions other than those announced, except at the express request of the data’s owner or legitimate persons following national regulations.
Notwithstanding the foregoing, VIRTUS GLOBAL will not be responsible for computer attacks and in general any action that has the objective of violating the security measures established for the protection of personal data and information other than those contained in its computer equipment or those contracted with third parties