In compliance with the provisions of the statutory law 1581 of 2012 and its Regulatory Decree 1377 of 2013, the Louis Barton group of companies adopts the present policies for the treatment of personal data, which will be informed to all the owners of the data collected or that will be obtained in the future in the exercise of the commercial, labor or productive activities.

In this way, the Louis Barton group of companies declares that it guarantees the rights of privacy, intimacy and good name, in the treatment of personal data, and consequently all its actions will be governed by the principles of legality, purpose, freedom, veracity, transparency, security and confidentiality.

The Louis Barton group of companies is aware that personal data is the property of the people to whom it refers and only they can decide about it.

Likewise, the Louis Barton group of companies does not commercialize, transfer or share its databases, and uses such data only for the purposes for which it is duly authorized, and in any case, respecting the current regulations on the protection of personal data.

Data of the person in charge of processing the databases:

LOUIS BARTON ZONA FRANCA S.A.S.

CORREGIMIENTO CAIMALITO, ZONA FRACA INTERNACIONAL DE PEREIRA. B-36

TELEFONOS (6) 3153742- 3153731

E-MAIL: [email protected]

Data of the database manager:

NIDIA SOFIA ARANGO HURTADO

CARGO: CONTADORA

CORREGIMIENTO CAIMALITO, ZONA FRACA INTERNACIONAL DE PEREIRA. B-36

TELEFONOS (6) 3153742- 3153731

E-MAIL: [email protected] 

INDUSGTRIAS SUR E.U.

AV.30 DE AGOSTO # 87-763, PEREIRA

TELEFONOS (6) 3200070

E-MAIL: [email protected]

Data of the database manager:

NIDIA SOFIA ARANGO HURTADO

CARGO: CONTADORA

AV.30 DE AGOSTO # 87-763, PEREIRA

TELEFONOS (6) 3200070

E-MAIL: [email protected]

INDUSTRIAS BUENOS AIRES LTDA.

CRA 14 #103-45, BODEGA 13. PEREIRA.

TELEFONOS (6) 3205453

E-MAIL: [email protected]

Data of the database manager:

ANALID LOZANO PULIDO

CARGO: CONTADORA

CRA 14 #103-45, BODEGA 13. PEREIRA.

TELEFONOS (6) 3205453

E-MAIL: [email protected]

CAMISAS EL DUQUE LTDA.

CRA 58 # 127- 59. LOCAL 104. BOGOTA.

TELEFONOS (1) 2261628

E-MAIL: [email protected]

Data of the database manager:

ANALID LOZANO PULIDO

CARGO: CONTADORA

CRA 14 #103-45, BODEGA 13. PEREIRA.

TELEFONOS (6) 3205453

E-MAIL: [email protected]

1. SCOPE

These personal data protection policies shall apply to all databases and/or files containing personal data that are processed by the Louis Barton Group of companies.

2. DEFINITIONS

Authorization: Prior, express and informed consent of the Owner to carry out the Processing of Personal Data.

Privacy Notice: verbal or written communication generated by the responsible, addressed to the holder for the treatment of their personal data, by which they are informed about the existence of the Treatment Policies of information that will be applicable, the way to access them and the purposes of the treatment that is intended to give the personal data.

Database: organized set of personal data that is subject to treatment.

Personal Data: any information linked or that can be associated to one or more determined or determinable natural persons.

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 data controller

Person responsible for the treatment: natural or legal person, public or private, who by itself or in association with others, decides on the data base and/or the treatment of the data.

Holder: natural person whose personal data are processed.

Processing: any operation or set of operations on personal data, such as collection, storage, use, circulation or deletion.

Public data: data that is not semi-private, private or sensitive. Public data are considered, among others, data relating to the marital status of individuals, their profession or trade and their status as merchants or public servants. By its nature, public data may be contained, among others, in public records, public documents, official gazettes and bulletins, and duly executed court decisions that are not subject to reservation.

Private data: this is data 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 group of persons or to society in general. For its treatment, the express authorization of the owner of the information is required. (E.g. Financial and credit data).

Sensitive data: Sensitive data is understood to be that which affects the privacy of the Data Subject or whose improper use may generate discrimination, such as that which reveals racial or ethnic origin, political orientation, religious or philosophical convictions, membership in unions, social organizations, human rights or that promotes the interests of any political party or that guarantees the rights and guarantees of political opposition parties, as well as data relating to health, sex life, and biometric data.

3. RIGHTS OF THE HOLDERS OF PERSONAL DATA

Natural and legal persons whose personal data are processed by the Louis Barton Group have the following rights, which they may exercise at any time:

To know the personal data on which the Louis Barton Group of companies is processing. Similarly, the owner may request at any time, that their data be updated or rectified, for example, if they find that their data are partial, inaccurate, incomplete, fractionated, misleading, or those whose treatment is expressly prohibited or has not been authorized.

Request proof of authorization given to the Louis Barton Group of Companies for the processing of your personal data.

To be informed by the Louis Barton Group of companies upon request, regarding the use of your personal data.

Submit complaints to the Superintendence of Industry and Commerce for violations of the provisions of the Law on Protection of Personal Data.

Request the Louis Barton Group of Companies to delete your personal data and/or revoke the authorization granted for the treatment of such data, by submitting a complaint. However, the request for deletion of the information and the revocation of the authorization will not proceed when the holder of the information has a legal or contractual duty to remain in the Data Base and/or Files, nor while the relationship between the Holder and the Louis Barton corporate group by virtue of which his data were collected is in force.

Access free of charge to your personal data being processed.

4. CLASSIFICATION OF DATABASES

Employee databases: these are manual, physical or digital databases that contain data on individuals who have been linked to the Louis Barton group of companies for work purposes, the processing of which is intended to comply with legal and regulatory provisions. This database includes private and public information, sensitive data and data on minors.

Customer databases: these are manual or digital databases containing data on natural or legal persons who have a business relationship, whose processing is intended to comply with the contractual provisions for the sale of goods that are part of the company’s corporate purpose. This database contains public and private data, which are only intended for the development of contractual relations. The treatment of these data for different purposes other than the maintenance of the contractual relationship or the fulfillment of legal duties, requires prior authorization from the owner.

Suppliers’ databases: these are manual or digital databases containing data on individuals or legal entities that maintain a contractual and commercial relationship, whose treatment is intended to comply with the contractual provisions for the acquisition of goods and services demanded by them for their normal operation. This database contains public and private data, which are only intended for the development of contractual relations. The treatment of these data for different purposes other than the maintenance of the contractual relationship or the fulfillment of legal duties, requires prior authorization from the holder.

5. TREATMENT

The Louis Barton group of companies, acting as the party responsible for the processing of personal data, for the adequate development of its commercial activities, as well as for the strengthening of its relations with third parties, collects, stores, uses and deletes Personal Data corresponding to natural persons with whom it has or has had a relationship, such as, without the enumeration meaning limitation, workers and their families, shareholders, customers and suppliers.

6. PURPOSE

The Personal Data is processed by the Louis Barton group of companies for the following purposes:
For the provision of health services to the family members of the workers of the Louis Barton corporate group who are beneficiaries of the health service.
For the strengthening of relations with its consumers and clients, through the taking of orders and the attention to requests, complaints and claims, in addition to the evaluation of the quality of the product and service offered.
To ensure timely and quality supply with Providers, manage orders and send performance re-evaluation information.

To communicate brand activities related to marketing and promotions, through emails and/or other media.

7. AUTHORIZATION

7. 1 Public data: The Louis Barton group of companies warns that it handles personal data of a public nature and those contained in public records without prior authorization from the owner. This situation does not imply that the necessary measures are not taken to ensure compliance with the other principles and obligations set forth in Law 1581 of 2012 and other rules governing this matter.

7. 2 Private data: The Louis Barton group of companies restricts the treatment of private data to what is strictly indispensable and requests prior and express consent from the owners, representatives or attorneys-in-fact, informing them of the exclusive purpose of the treatment.

7.3 Sensitive data: The Louis Barton group of companies restricts the processing of sensitive personal data to what is strictly indispensable and requests prior and express consent from the owners, representatives or attorneys-in-fact, informing them of the exclusive purpose of the processing. The Louis Barton group of companies uses and processes data classified as sensitive, when

When the processing has been expressly authorized by the owner of the sensitive data.

The treatment is necessary to safeguard the vital interest, and this is physically or legally incapacitated.

The treatment refers to data that are necessary for the recognition, exercise or defense of a right in a legal proceeding.

7.4 Treatment of data of minors: the treatment of personal data of children and adolescents is regulated except when it is data of a public nature, in accordance with the provisions of article 7 of Law 1581 of 2012, and when such treatment complies with the following parameters and requirements

That it responds to and respects the best interests of children and adolescents.
That the respect of their fundamental rights is ensured.

Once the above requirements are met, the representative or guardian of the child or adolescent will grant the authorization, prior to the exercise of the minor’s right to be heard, an opinion that will be assessed taking into account the maturity, autonomy and capacity to understand the matter.

Prior authorization for the processing of private, sensitive and minor data means that consent must be given by the holder, at the latest at the time of collection of personal data. Express Authorization means that the Holder’s consent must be explicit and concrete, open and non-specific authorizations are not valid. The Holder is required to express his/her willingness to authorize the Louis Barton group of companies to process his/her personal data.

This manifestation of the Holder’s will can be given through different mechanisms made available by the company, such as

In writing, for example, by filling out an authorization form or by accepting it via e-mail.
Whatever the mechanism used by the Louis Barton Group of Companies, the authorization must be kept in order to be consulted later.

8. AREA RESPONSIBLE FOR THE IMPLEMENTATION AND MONITORING OF POLICIES

The Accounting area is in charge of the development, implementation, training and follow-up of these policies, since it has the control and administration of the accounting software where all the digital databases are stored. It also has the authority to control the physical databases that are under the responsibility of other processes. For this purpose, all employees who process personal data in the different areas of the company are obliged to report these databases to the Accounting Department and to inform it immediately of all requests, complaints or claims received from the Personal Data Holders.

In the same way all the holders can exercise the rights to know, to update, to rectify and to suppress information and to revoke the authorization, communicating in this department, with the person in charge of the treatment of data bases.

9. SECURITY MEASURES.

The Louis Barton group of companies adopts the necessary technical, human and administrative measures to guarantee the security of the personal data being processed, thus avoiding its adulteration, loss, consultation, use or unauthorized access.

Privileges for the administration of technological resources, network services and information systems are assigned only to the person in charge of database processing.

The users of the accounting software, network services and information systems of the Louis Barton Group of Companies must be responsible for the actions carried out in them, as well as for the user and password assigned for access to them.

Employees must not share their user accounts and passwords with other colleagues or with personnel provided by third parties.

The process managers must ensure that the passwords of the alarm systems, keys and other security mechanisms of access to their areas are only used by the authorized personnel and, except for emergency situations or other type of events that by their nature require it, these are not transferred to other employees of the company.

The Louis Barton group of companies provides the necessary mechanisms to guarantee the protection of the information and resources of the technological platform where it is processed and stored, adopting the necessary controls to avoid the disclosure, modification or permanent damage caused by the spread of malicious software.

The Louis Barton Group certifies the generation of backup copies and storage of its critical information and personal databases, providing the necessary resources and establishing the procedures and mechanisms to carry out these activities. The areas that own the information and databases define the strategy to be followed and the retention periods for the backup and storage of information.

10. POLICY UPDATES.

The Louis Barton group of companies may change the terms and conditions of this document, as part of our effort to meet the obligations established by Law 1581 of 2012, regulatory decrees and other regulations that complement it.

Where this occurs, the new document will be posted on the website: www.louisbarton.com.

The present policies come into effect on the seventeenth (17) day of June of the year 2015.