Privacy Policy

ORGANIZACIÓN PARKWAY VIAJES Y TURISMO S.A.S
POLICIES FOR THE PROCESSING AND PROTECTION OF PERSONAL DATA 2019

1. DEFINITIONS:
   To fully understand this Policy, please take into account the following definitions in accordance with current legislation:

• Authorization: Prior, express, and informed consent from the Data Subject for the processing of personal data.
• Privacy Notice: A verbal or written communication generated by the Data Controller, directed at the Data Subject, informing them about the existence of personal data processing policies that apply to them, how to access them, and the purposes of data processing.
• Database: An organized set of personal data that is subject to processing.
• Personal Data: Any information linked to or that can be associated with one or several specific or specifiable natural persons.
• Public Data: Data that is neither semi-private, private, nor sensitive. Public data includes information such as a person’s marital status, profession, occupation, or their role as a public servant. By nature, public data can be found in public records, public documents, official gazettes, and duly executed judicial decisions not subject to confidentiality.
• Sensitive Data: Data that affects the privacy of the Data Subject or whose misuse could lead to discrimination, such as data revealing racial or ethnic origin, political orientation, religious or philosophical beliefs, union membership, or information related to health, sexual life, and biometric data.
• Data Processor: A natural or legal person, public or private, who, alone or in association with others, processes personal data on behalf of the Data Controller.
• Data Controller: A natural or legal person, public or private, who alone or in association with others, makes decisions about the database and/or data processing.
• Data Subject: The natural person whose personal data is processed.
• Transfer: When the Data Controller and/or Data Processor, located in Colombia, sends personal data to a recipient who, in turn, is a Data Controller located within or outside the country.
• Transmission: The processing of personal data involving the communication of such data within or outside Colombia when the purpose is processing by the Data Processor on behalf of the Data Controller.
• Processing: Any operation or set of operations on personal data, such as collection, storage, use, circulation, or deletion.

2. PURPOSE AND PROCESSING OF PERSONAL DATA:
   To comply with current data protection legislation, especially Law 1581 of 2012 (and other laws that modify, supplement, or develop it) and Decree 1377 of 2013, we inform all data subjects whose data is stored in ORGANIZACIÓN PARKWAY VIAJES Y TURISMO S.A.S.’s databases about relevant aspects concerning the collection, storage, use, circulation, deletion, management, and/or transfer of personal data carried out by the company based on the authorization you provided for such processing. In line with the provisions of Article 15 of the Political Constitution of Colombia, Law 1266 of 2008, Law 1581 of 2012, Decree 1377 of 2013, and all regulations that govern, supplement, repeal, or amend them, this processing policy outlines the company’s policies for processing your data, the purpose of the processing, your rights as a data subject, and the mechanisms established by law to exercise these rights. In general, the privacy policy and handling of your personal data are intended to inform you that the collection, management, and use of third-party personal information in relation to the commercial dealings with ORGANIZACIÓN PARKWAY VIAJES Y TURISMO S.A.S., and collected in connection with the services provided as part of the company’s business activities, will only be carried out if such data has been provided voluntarily, with your full knowledge and prior, express consent.

Considering that the Data Subject has the right to privacy, ORGANIZACIÓN PARKWAY VIAJES Y TURISMO S.A.S. informs you that personal data collected will be used for the following purposes:

• Establishing and maintaining a business relationship.
• Providing feedback on services to ensure effective customer service.
• Collecting payments for services rendered.
• Sending advertising or commercial notices about the services of ORGANIZACIÓN PARKWAY VIAJES Y TURISMO S.A.S.
• Contacting customers, employees, or suppliers to send information related to contractual, commercial, or other obligations.
• Collecting data to fulfill the company’s duties as the Data Controller of personal information.
• For security or fraud prevention purposes.
• Sending financial, commercial, credit, or service-related information for statistical, control, or supervisory purposes, which may need to be processed, reported, retained, accessed, provided, or updated with authorized data centers or databases, in accordance with legal and regulatory requirements.
• Resolving questions, doubts, or general inquiries.
• Any other purpose that arises from the development of the contract or the commercial relationship between the Data Subject and ORGANIZACIÓN PARKWAY VIAJES Y TURISMO S.A.S.

In line with the above purposes, your personal data may be made available to the company’s authorized personnel, or transferred to contractors, consultants, advisors, or external offices as necessary to fulfill the stated purposes.

2.1 REGARDING THE CUSTOMER DATABASE OF ORGANIZACIÓN PARKWAY VIAJES Y TURISMO S.A.S:
This database is generated by the company’s commercial department to manage marketing activities and provide specific services to customers.

2.2 REGARDING THE EMPLOYEE AND/OR CONTRACTOR DATABASE OF ORGANIZACIÓN PARKWAY VIAJES Y TURISMO S.A.S:
The company processes data as a legal entity for the purposes of employment, service provision, termination, or the conclusion of contracts, depending on the type of legal relationship with ORGANIZACIÓN PARKWAY VIAJES Y TURISMO S.A.S. (including, but not limited to, employees, apprentices, and job applicants).

2.3 REGARDING THE SUPPLIER DATABASE OF ORGANIZACIÓN PARKWAY VIAJES Y TURISMO S.A.S:
This database contains information related to the company’s suppliers, including physical infrastructure, technology, and services.

3. RIGHTS OF THE DATA SUBJECT:
   At any time, the Data Subject whose personal data is processed may exercise the rights granted by the Constitution and Laws of Colombia, specifically those established in Article 8 of Law 1581 of 2012:

• Know, update, and rectify personal data held by the Data Controllers or Data Processors, especially in the case of partial, inaccurate, incomplete, or misleading data, or data whose processing is prohibited or unauthorized.
• Request proof of the authorization granted to the Data Controller unless expressly exempted by law.
• Be informed by the Data Controller or Data Processor about the use given to their personal data, upon request.
• File complaints with the Superintendence of Industry and Commerce regarding breaches of the provisions of the current law or other relevant regulations.
• Revoke the authorization and/or request the deletion of data when processing fails to comply with constitutional and legal principles, rights, and guarantees. Revocation and/or deletion will proceed when the Superintendence of Industry and Commerce determines that the Data Controller or Processor has engaged in conduct contrary to this law and the Constitution.
• Access personal data that has been subject to processing, free of charge.

4. SENSITIVE DATA:
   The Data Subject has the right not to provide any sensitive information requested by ORGANIZACIÓN PARKWAY VIAJES Y TURISMO S.A.S., such as data related to racial or ethnic origin, union membership, social or human rights organizations, political, religious, sexual, biometric, or health-related information.
5. MINORS’ DATA:
   The provision of personal data of minors is optional and must be authorized by parents or legal guardians.
6. DATA SUBJECT AUTHORIZATION:
   Except as provided by law, the processing of data requires the prior, express, and informed authorization of the Data Subject, which must be obtained through any means that can be subject to future verification.
7. PROCEDURE FOR EXERCISING DATA SUBJECT RIGHTS:
   ORGANIZACIÓN PARKWAY VIAJES Y TURISMO S.A.S. has an area responsible for handling requests, inquiries, and complaints, through which the Data Subject can exercise their rights as described above. This area can be contacted via email at organizaciondeviajesyturismo@gmail.com or at the physical address Av Carrera 24 # 42-10 in Bogotá.

Requests related to the processing of personal data can be submitted physically or electronically through the above contact channels, clearly specifying contact information for a response.
Once the request is received, ORGANIZACIÓN PARKWAY VIAJES Y TURISMO S.A.S. will have fifteen (15) business days to respond or take the necessary measures.
If the request lacks sufficient contact information or does not clearly state the facts for the company to address it, this will be communicated within five (5) days of receipt, giving the requester fifteen (15) additional business days to provide the necessary information. Failure to do so will result in the request being considered withdrawn.

8. VALIDITY:
   ORGANIZACIÓN PARKWAY VIAJES Y TURISMO S.A.S. reserves the right to modify this policy at any time, with prior electronic communication to the data subjects. For this reason, we encourage regular consultation of our website www.ecoturismocolombia.com, where the latest version of this Policy will always be available.

This Data Processing Policy takes effect as of May 5, 2019.