To inform all our employees, customers, suppliers, shareholders and in general all the agents that interfere in the development of the business about the data processing policies, guaranteeing the right they have to know, update and rectify the information that has been collected about them and that is stored in the databases or files of ESCUDEO LLC.registered with Tax ID # L19000206558, domiciled at 325 Ocean Dr., Fl 33139-6960, ESCUDEO LLC., hereinafter ""ESCUDEO LLC", in compliance with the rights, freedoms and constitutional guarantees referred to in Articles 15 and 20 of the Political Constitution of 1991

5.1 ESCUDEO LLC *

In all processing of personal data will be respectful of the rights of the owners. For the purposes of this policy, the holder of the personal data shall have the following rights:

5.1.1 To know, update and rectify your personal data with respect to data controllers or data processors. This right may be exercised, among others, with respect to partial, inaccurate, incomplete, fractioned, misleading data, or data whose processing is expressly prohibited or has not been authorized by the rules that regulate, add, execute, complement, modify, suppress or repeal.

5.1.2 Request proof of the authorization granted to ESCUDEO LLC * except when expressly exempted as a requirement for processing.

5.1.3 To be informed by the data controller or processor, upon request of the data subject, regarding the use made of his or her personal data.

5.1.4 File before the Superintendence of Industry and Commerce complaints for infringements, as provided in law 1581 of 2012 and the other rules that modify, add, complement, modify, suppress or repeal it.

5.1.5 To revoke at any time the authorization and/or request the deletion of the data, when the treatment does not respect the principles, rights and constitutional and legal guarantees. The revocation and / or deletion will proceed when the Superintendence of Industry and Commerce determines that, in the process of processing the information, ESCUDEO LLC * has incurred in conduct contrary to law and the Constitution.

5.1.6 Access free of charge to your personal data that you voluntarily chose to share with ESCUDEO LLC *, which have been subject to processing.

In accordance with the object of this declaration, the holder, in relation to his non-public personal data, has the right to knowledge, access, rectification, updating, revocation and/or deletion of his personal data.

5.2 Licensee's authorization

Any processing that ESCUDEO LLC * does of personal information requires the prior and informed consent of the owner, which must be obtained by any means that may be subject tode consulta posterior. La autorización no será necesaria en las excepciones previstas en la ley, a manera enunciativa y sin perjuicio de las normas modifiquen, adicionen o complementen, la autorización no será necesaria en los siguientes casos: 

1. Information required by a public or administrative entity in the exercise of its legal functions or by court order.

2. Data of a public nature.

3. Cases of medical or sanitary emergency.

4. Processing of information authorized by law for historical, statistical or scientific purposes.

5. Data related to the Civil Registry of persons.

5.3 Duty to inform the holder

The data controller, at the time of requesting the authorization to the data subject, shall clearly and expressly inform him/her of the following:

1. The processing to which your personal data will be subjected and the purpose of such processing;

2. The optional nature of the answer to the questions asked, when they deal with sensitive data or with the data of children and adolescents;

3. The rights you have as a holder;

4. The identification, physical or electronic address of the data controller.

5.4 Persons to whom information may be provided

The company may provide the information to the following persons:

1. To the Holders, their successors in title or their legal representatives;

2. To public or administrative entities in the exercise of their legal or court-ordered functions;

3. To third parties authorized by the Holder or by law.

6.1. Obligations of ESCUDEO LLC *.

6.1.1 Guarantee the holder, at all times, the full and effective exercise of the right of habeas data.

6.1.2 Request and keep, under the conditions set forth in Law 1581 of 2012 and the regulatory decrees and other rules that modify or reform them, a copy of the respective authorization granted by the holder.

6.1.3 Duly inform the owner about the purpose of the collection and the rights he/she has by virtue of the authorization granted.

6.1.4 Keep the information under the necessary security conditions to prevent its adulteration, loss, consultation, unauthorized or fraudulent use or access.

6.1.5 Ensure that the information provided to the data processor is truthful, complete, accurate, up-to-date, verifiable and understandable.

6.1.6 To update the information, communicating in a timely manner to the data processor, all the news regarding the data previously provided and to adopt the other necessary measures so that the information provided to the data processor is kept up to date.

6.1.7 Rectify the information when it is incorrect and communicate, by means of the most expeditious means of communication available, the relevant information to the data processor.

6.1.8 To provide to the data processor, as the case may be, only data whose processing is previously authorized in accordance with the provisions of the law.

6.1.9 To require the data processor at all times to respect the security and privacy conditions of the data subject's information.

6.1.10 Process queries and claims formulated under the terms set forth in the law.

6.1.11 Adopt an internal manual of policies and procedures to ensure adequate compliance with the law and, in particular, to deal with queries and complaints.

6.1.12 Inform, through the available and most expeditious means of communication, the data processor when certain information is under discussion by the owner, once the claim has been filed and the respective process has not been completed.

6.1.13 Inform at the request of the owner about the use given to his/her data.

6.1.14 Inform the data protection authority when there are violations to the security codes and there are risks in the administration of the data subjects' information.

6.1.15 Comply with the instructions and requirements issued by the Superintendence of Industry and Commerce.

6.2. Duties of data controllers and data processors.

6.2.1 Guarantee the holder, at all times, the full and effective exercise of the right of habeas data.

6.2.2 Keep the information under the necessary security conditions to prevent its adulteration, loss, consultation, unauthorized or fraudulent use or access.

6.2.3 Timely update, rectification or deletion of the data in accordance with the law.

6.2.4 Update the information reported by data controllers within fifteen (15) working days of receipt.

6.2.5 To process queries and claims formulated by the owners under the terms set forth in the law.

6.2.6 Adopt an internal manual of policies and procedures to ensure proper compliance with the law and, in particular, to deal with queries and complaints from owners.

6.2.7 Record in the database the legend "claim in process" in the manner regulated by law.

6.2.8 Insert in the database the legend "information under judicial discussion" once notified by the competent authority about judicial proceedings related to the quality of the personal data.

6.2.9 Refrain from circulating information that is being disputed by the owner and whose blocking has been ordered by the Superintendence of Industry and Commerce.

6.2.10 Allow access to information only to persons who may have access to it.

6.2.11 To inform the Superintendence of Industry and Commerce when there are violations to the security codes and there are risks in the administration of the owners' information.

6.2.12 Comply with the instructions and requirements issued by the Superintendence of Industry and Commerce.

7.1. Area of Competence.

ESCUDEO LLC * through the area responsible for the information in the company, will attend all requests, queries and / or claims of the owner of the information, related to the rights established by law to know, update, rectify and delete or revoke the authorization that had given to ESCUDEO LLC * against their personal data.

7.2. Procedure for the exercise of the rights of the holder of the information

The holders or their assignees may consult the personal information of the holder that is in the Company's database, request correction, updating or deletion or claim. Their rights may be exercised through:

• Through the mobile application in the P.Q.R. customers section.

• Send e-mail to  info@escudeo.com  or telephone communication, in the city of Bogota (Colombia) to telephone +1 786 8259660.

Term to obtain response: After receiving the request by the established means, ESCUDEO LLC* will have fifteen (15) working days (from receipt of the request) to respond to the owner of the information that alleges any request to the company.