Privacy Policy
Personal information processing policy
In compliance with the provisions contained in article 15 of the Political Constitution, Law 1581 of 2012, Regulatory Decree 1377 of 2013, and other regulations that modify, add, complement or develop it, the company LUM 360 SAS, hereinafter LUM 360, committed to respecting and guaranteeing the rights of its clients, suppliers, employees and third parties in general, discloses the policies and procedures for the processing of personal data that are stored and safeguarded in our database, which are mandatory in all activities that involve, totally or partially, the collection, storage, use, circulation and / or transfer of said information.
This Personal Information Processing Policy is mandatory for LUM 360 SAS, as the data controller, as well as for all allied companies, subsidiaries, or those that are part of the business group of this company.
Legal framework
This Personal Information Processing Policy is based on Article 15 of the Political Constitution, Law 1581 of 2012, and Regulatory Decree 1377 of 2013, which provide:
Political Constitution, Article 15. "All persons have the right to their personal and family privacy and to their good name, and the State must respect them and ensure that they are respected. Likewise, they have the right to know, update, and rectify information collected about them in databases and in the files of public and private entities.
In the collection, processing, and circulation of data, freedom and other guarantees enshrined in the Constitution will be respected.
Correspondence and other forms of private communication are inviolable. They may only be intercepted or recorded by court order, in the cases and with the formalities established by law.
For tax or judicial purposes and in cases of inspection, surveillance and intervention by the State, the presentation of accounting books and other private documents may be required, in the terms established by law."
Statutory Law 1581 of 2012 "Whereby general provisions are issued for the protection of personal data."
Regulatory Decree 1377 of 2013 "By which Law 1581 of 2012 is partially regulated" -
General information about LUM 360 SAS as the controller of personal data
Company name: LUM 360 SAS
NIT. 901489963-5
Address: Medellin
Telephone: 3145113989
Email: infownacare@gmail.com
Website: www.ownacare.com
Purpose of the personal data processing policy
The purpose of the Personal Data Processing Policy is to develop and inform the general public of the corporate and legal guidelines under which LUM 360 SAS processes personal data, the purpose of the processing, the rights that data subjects have, as well as the internal and external procedures that exist for the exercise of such rights before LUM 360 SAS, among others.
Legal definitions
For the purposes of implementing this policy and in accordance with legal regulations, the following definitions shall apply:
Authorization : Prior, express and informed consent of the Owner to carry out the Processing of personal data;
Database : Organized set of personal data that is the object of processing;
Owner : Natural person whose personal data is subject to processing, whether client, supplier, employee, or any third party who, by reason of a commercial or legal relationship, provides personal data to LUM 360 SAS
Processing : Any operation or set of operations on personal data, such as collection, storage, use, circulation or deletion.
Personal data : Any information linked to or that can be associated with one or more specific or determinable natural persons;
Public data : Data that is not semi-private, private, or sensitive. Public data includes, among others, data relating to a person's marital status, their profession or occupation, and their status as a merchant or public servant. By its nature, public data may be contained in, among other things, public registries, public documents, official gazettes and bulletins, and duly enforceable court rulings that are not subject to confidentiality.
Sensitive data : Sensitive data is understood to be that which affects the privacy of the Owner or whose improper use may lead to discrimination, such as those that reveal racial or ethnic origin, political orientation, religious or philosophical beliefs, membership in unions, social organizations, human rights organizations or that promote the interests of any political party or that guarantee the rights and guarantees of opposition political parties, as well as data related to health, sexual life, and biometric data.
Transfer : Data transfer occurs when the Controller and/or Processor of personal data, located in Colombia, sends the information or personal data to a recipient, who in turn is the Controller and is located within or outside the country.
Transmission : Processing of personal data that involves communicating the same within or outside the territory of the Republic of Colombia when the purpose is to carry out processing by the Data Processor on behalf of the Controller.
When a term used is defined in this Information Processing Policy, that definition shall apply. Likewise, when a term used is not expressly defined in this document or in applicable law, the literal meaning of the provisions shall apply, provided that such interpretation is consistent with the purpose of this Information Processing Policy.
Principles governing LUM 360 SAS's actions in the processing of personal data
The principles governing the processing of personal data by LUM 360 SAS are as follows:
Principle of legality : The processing of personal data is a regulated activity that must be subject to the provisions of Law 1581 of 2012, Decree 1377 of 2013, and other implementing provisions.
Principle of purpose : the purpose of the processing must be legitimate and informed to the owner.
Reasonable Limit Principle : The storage and processing of personal data will be limited to what is essentially necessary to fulfill the previously specified purposes of the business relationship, as well as the fulfillment of the purposes authorized by the Data Subject.
Principle of freedom : personal data may only be processed with the prior, express and informed consent of the Data Subject or by legal or judicial order.
Principle of truthfulness : information must be truthful, complete, accurate, up-to-date, verifiable and understandable.
Principle of transparency : the right of the Owner to obtain information about his personal data whose processing is carried out by LUM 360 SAS must be guaranteed.
Principle of Restricted Access and Circulation : Processing may only be carried out by persons authorized by the Data Controller or by the persons provided for by law.
Security Principle : Information must be handled with the necessary measures to ensure security of records and prevent their adulteration, loss, unauthorized or fraudulent consultation, use or access.
Confidentiality Principle : Personal data that is not public in nature is confidential and may only be provided in accordance with the law.
Principle of Systematic Incorporation : The principles of Personal Data Protection will be implemented in all processes and procedures of LUM 360 SAS's business activity.
Rights of personal data holders
To know, update, and rectify your personal data with the Data Controllers or Data Processors. This right may be exercised, among other things, in the case of partial, inaccurate, incomplete, fragmented, misleading data, or data whose processing is expressly prohibited or unauthorized;
Request proof of the authorization granted to the Data Controller except when expressly exempted as a requirement for the Treatment, in accordance with the provisions of Article 10 of this law;
To be informed by the Data Controller or the Data Processor, upon request, regarding the use that has been given to your personal data;
Submit complaints to the Superintendency of Industry and Commerce for violations of the provisions of this law and other regulations that modify, add to or complement it;
Revoke authorization and/or request data deletion when the processing does not respect constitutional and legal principles, rights, and guarantees. Revocation and/or deletion will proceed when the Superintendency of Industry and Commerce has determined that the Controller or Processor has engaged in conduct contrary to this law and the Constitution in the processing;
Access your personal data that has been processed free of charge.
Authorization for the processing of personal data
LUM 360 SAS, acting as Data Controller, has adopted procedures to request your authorization for the processing of your personal data at the latest at the time of collection and to inform you of the personal data that will be collected, as well as all the specific purposes for which your consent is obtained.
The Data Subject will be deemed to have granted LUM 360 SAS authorization to process their personal data when this is expressed: (i) in writing; (ii) orally; or (iii) through unequivocal conduct by the Data Subject that reasonably allows us to conclude that they have granted LUM 360 SAS the respective authorization. Under no circumstances will silence be construed as unequivocal conduct.
Notwithstanding the foregoing, the Data Subject's authorization will not be required for the following: (i) Information required by a public or administrative entity in the exercise of its legal functions or by court order; (ii) Data of a public nature; (iii) Cases of medical or health emergencies; (iv) Processing of information authorized by law for historical, statistical, or scientific purposes; and (v) Data related to the Civil Registry of Persons.
Revocation of authorization and/or deletion of data
The owner of the personal data may at any time request LUM 360 SAS, as the Data Controller, to delete their personal data and/or revoke the authorization they have granted for the processing of said data by submitting a complaint, in accordance with the provisions of Article 15 of Law 1581 of 2012.
Notwithstanding the foregoing, we advise that the request for deletion of information and/or revocation of authorization will not proceed when, as the Owner of the personal data, you have a legal or contractual obligation by virtue of which it must remain in the LUM 360 SAS database.
You can unsubscribe through the following means : customer service. Use the unsubscribe button at the bottom of emails. To unsubscribe from text messages, you must contact our Customer Service team, via chat, or WhatsApp.
Purpose of the processing of personal data
LUM 360 SAS will process personal data for the following purposes:
Carry out, through any means, directly or through third parties, marketing, promotion and/or advertising activities, whether our own or those of third parties, sales, billing, collection management, collection, programming, technical support, market intelligence, service improvement, verifications and queries, control, behavior, habits and enabling of payment methods, fraud prevention, as well as any other activities related to our current and future products and services, in order to fulfill contractual obligations and our corporate purpose.
Generate optimal communication regarding our services, products, promotions, billing, and other activities.
Evaluate the quality of our products and services and conduct studies on consumer habits, preferences, purchasing interest, product testing, concepts, service evaluation, satisfaction, and other research related to our services and products.
Provide assistance, service, and technical support for our products and services.
Carry out the necessary steps to comply with the obligations inherent to the services provided by LUM 360 SAS
Comply with the obligations contracted with our clients, allies, users, suppliers, their subsidiaries, distributors, subcontractors and other persons directly or indirectly related to the corporate purpose of LUM 360 SAS
Control and prevent fraud in all its forms.
Procedure for handling requests and queries related to personal information
The owner of the personal data or whoever is duly authorized may:
Make requests and inquiries to know the personal information of the Owner held by LUM 360 SAS
Request the update, modification, rectification, or deletion of the Data Subject's data, when appropriate in accordance with this Policy and applicable law.
Request a copy of the authorization granted by the Owner to LUM 360 SAS to process your Personal Data.
These inquiries may be made free of charge at least once every calendar month and whenever substantial changes to the Information Processing Policies require new inquiries.
The Data Subject or whoever is authorized to do so may make inquiries to LUM 360 SAS regarding the Data Subject's personal information through the following mechanisms:
In writing, addressed to the following address: Cra 43a #1a Sur-29, Colmena Building, Office 414, Medellin, Colombia
Email to infownacare@gmail.com
The query will be answered within a maximum period of ten (10) business days from the date of receipt.
When it is not possible to answer the query within the term indicated above, LUM 360 SAS will inform the interested party, stating the reasons and indicating the date on which the query will be answered, no later than five (5) business days following the expiration of the first term.
Procedure for handling complaints and revoking authorization for the processing of personal data
Through this procedure, the Holder or whoever is duly authorized may:
Revoke Authorization for Data Processing.
File complaints when you believe there has been an alleged breach of LUM 360 SAS's obligations related to the Processing of Personal Data, in accordance with the provisions of these Policies or the Personal Data Protection Law.
Revocation of the Data Subject's Authorization for the Processing of Personal Data.
The Data Subject may revoke the authorization and request the deletion of his or her data in the following cases:
By unilateral, free, and voluntary decision of the Data Subject, when there is no legal or contractual obligation imposing on the Data Subject the duty to remain in the database; and
When constitutional and legal principles, rights, and guarantees are not respected, provided that the Superintendency of Industry and Commerce has determined that the Controller or Processor has engaged in conduct contrary to the law in the Processing.
The foregoing is without prejudice to the regulations that LUM 360 SAS must observe regarding document retention for the fulfillment of formal obligations. Consequently, LUM 360 SAS will delete the data or suspend its use when appropriate, respecting the applicable document retention regulations.
The procedure for handling complaints regarding the personal data of the Owner is as follows :
The Data Subject or whoever is duly authorized to do so may file complaints with LUM 360 SAS regarding the processing of their personal data in the following cases:
When you consider that the Data Subject's information contained in a database should be corrected, updated, or deleted; or when you become aware of a suspected breach of any of the obligations contained in the Data Protection Law.
Complaints must be submitted through any of the following channels:
In writing, addressed to the following address: Cra 43a #1a Sur-29, Colmena Building, Office 414, Medellin, Colombia
Email to infownacare@gmail.com
The claim submitted by the Data Subject or a person authorized to do so must contain, at a minimum, the following: (i) Identification of the Data Subject; (ii) Description of the facts giving rise to the claim; (iii) Contact information and location of the Data Subject (address, telephone number, cell phone number, email address, etc.); and (iv) Documents or evidence supporting the claim. If the above information is not provided, the claim will be deemed incomplete.
If the claim is incomplete, LUM 360 SAS will request the interested party to correct the deficiencies or send the information or documentation required within five (5) business days following receipt of the claim by LUM 360 SAS. After two (2) months from the date of the request, if the applicant does not present the required information, it will be understood that the claim has been withdrawn and it will be filed.
LUM 360 SAS has a term of fifteen (15) business days to address the claim, counted from the business day following the date of receipt at LUM 360 SAS.
When it is not possible to address the claim within the aforementioned term, LUM 360 SAS will inform the interested party of the reasons for the delay and the date on which the claim will be addressed, which may not exceed eight (8) business days following the expiration of the first term.
Area Responsible for Handling Requests, Queries and Complaints
The Customer Service area of LUM 360 SAS is responsible for receiving requests, queries and complaints from the Owner of Personal Data related to their rights to
to know, update, rectify, and delete Personal Data, and revoke Authorization. Likewise, the Customer Service department will ensure that each of LUM 360 SAS's departments responds promptly and appropriately to requests, inquiries, and complaints from Data Subjects.
Validity of the personal information processing policy
This personal information processing policy is effective from January 1, 2016, until it is expressly revoked or modified.
This manual is adopted by management on behalf of LUM 360 SAS