Information Processing Policy


This Personal Data Protection Policy will apply to all Databases and / or Files containing Personal Data that are subject to Treatment by 57 Team S.A.S ..


57 Team S.A.S. With address at Carrera 20 No. 168 34 of Bogota D.C., Colombia, with email address and landline (+571) 6744433.


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

Notice of Privacy: Verbal or written communication generated by the Responsible, addressed to the Owner for the Treatment of his Personal Data, by which he is informed about the existence of the Treatment Policies of information that will be applicable to him, the form of access To the same and the purposes of the Treatment that is intended to give the personal data.

Data Base: Organized set of Personal Data that is object of Treatment.

Personal Data: Any information linked to or may be associated with one or more specific or determinable natural persons.

Responsible for the Treatment: Natural or legal person, public or private, that by itself or in association with others, perform the Processing of Personal Data on behalf of the Responsible for Treatment. In events in which the Responsible does not exercise as the Data Base Manager, it will be expressly identified who will be the Manager.

Responsible for the Treatment: Natural or juridical person, public or private, that by itself or in association with others, decides on the Database and / or the Treatment of the data.

Holder: Natural person whose Personal Data is subject to Treatment.

Treatment: Any operation or set of operations on Personal Data, such as collection, storage, use, circulation or suppression.


THE COMPANY, acting as Responsible for the Processing of Personal Data, for the proper development of its commercial activities, as well as for the strengthening of its relations with third parties, collects, stores, uses, circulates and deletes Personal Data corresponding to natural persons with Who have or have had a relationship, such as, but not limited to, workers and their families, shareholders, consumers, customers, distributors, suppliers, creditors and debtors.


The Personal Data are object of Treatment by the COMPANY with the following purposes:

5.1. To send information to their workers and family;

5.2. For the provision of health services to the families of the workers of the COMPANY beneficiaries of the health service;

5.3. For the recognition, protection and exercise of the rights of the shareholders of THE COMPANY;

5.4. In order to strengthen relations with its consumers and customers, by sending relevant information, taking orders and the attention of Petitions, Complaints and Complaints (PQR's) by the customer service area, the evaluation of the quality of Its customer service, among others;

5.5. For the interaction with its Distributors, for the verification of compliance with the distribution standards, its legal obligations with its workers and for the invitation to events organized or sponsored by THE COMPANY, among others.

5.6. To consolidate a timely and quality supply with its Suppliers, through the invitation to participate in selection processes, the evaluation of the fulfillment of their obligations and the invitation to events organized or sponsored by THE COMPANY, among others;

5.7. For verification of balances of your creditors;

5.8. For the determination of outstanding obligations, the consultation of financial information and credit history and the reporting to information centers of unfulfilled obligations, with respect to their debtors;

5.9. For marketing activities, statistics, research and other commercial purposes that do not contravene the legislation in force in Colombia;

5.10. For the attention of judicial or administrative requirements and the fulfillment of judicial or legal mandates;

5.11. In order to be able to contact, by e-mail, or by any other means, natural persons with whom you have or have had a relationship, such as, without limitation, workers and their relatives, shareholders, consumers, customers, distributors, suppliers , Creditors and debtors, for the aforementioned purposes.


Natural persons whose personal data are processed by THE COMPANY have the following rights, which may be exercised at any time:

6.1. Know the Personal Data on which THE COMPANY is performing the Treatment. Similarly, the Holder may at any time request that his data be updated or rectified, for example, if he finds that his data are partial, inaccurate, incomplete, fractioned, misleading, or those whose Treatment is expressly prohibited or not Has been authorized.

6.2. Request proof of the authorization granted to THE COMPANY for the Treatment of your Personal Data.

6.3. Be informed by THE COMPANY, upon request, regarding the use that it has given to your Personal Data.

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

6.5. Request the COMPANY to delete their Personal Data and / or revoke the authorization granted for the Treatment of the same, by submitting a complaint, in accordance with the procedures established in number 11 of this Policy. 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 Database and / or Archives, or while the relationship between The Holder and THE COMPANY, by virtue of which their data were collected.

6.6. Free access to your Personal Data object of Treatment.


The administrative department of 57 Team S.A.S. Is in charge of the development, implementation, training and enforcement of this Policy. For this purpose, all the personnel who perform the processing of personal data in the different areas of THE COMPANY, are obliged to report these Databases to the Department and to immediately transfer to it, all requests, complaints or complaints that Received by the holders of personal data.

The administrative department of 57 Team S.A.S. Has also been designated by THE COMPANY as an area responsible for handling requests, queries, complaints and claims before which the Information Holder may exercise his rights to know, update, rectify and delete the data and revoke the authorization.


THE COMPANY must request previous, express and informed consent to the Owners of the Personal Data on which it is necessary to carry out the Treatment.

8.1. Prior authorization means that the consent must be granted by the Holder, at the latest at the time of collection of Personal Data.

8.2. Express authorization means that the consent of the Holder must be explicit and specific, are not valid open and non-specific authorizations. The Holder is required to express his / her willingness to authorize THE COMPANY to process the Personal Data.

This manifestation of will of the Holder can take place through different mechanisms made available by THE COMPANY, such as:

In writing, for example, filling out an authorization form.

Orally, for example, in a telephone conversation or videoconference.

Through unequivocal conduct that allows to conclude that it granted its authorization, for example, through its express acceptance of the Terms and Conditions of an activity within which the participants' authorization is required for the Processing of their Personal Data.

IMPORTANT: In no case THE COMPANY will assimilate the silence of the Owner to an unequivocal conduct.

Whatever the mechanism used by THE COMPANY, it is necessary that the authorization be retained so that it can be consulted at a later date.

8.3. Informed Authorization means that at the moment of requesting consent to the Holder, it must be clearly informed:

The Personal Data that will be collected.

The identification and contact details of the Responsible and the Manager of the Treatment.

The specific purposes of the intended Treatment, ie how and for what purpose the collection, use and circulation of Personal Data will be done.

What are the rights you have as the holder of the Personal Data; For the effect see number 6 of this Policy.

The optional nature of the answer to the questions that are asked, when they are about sensitive data or about the data of children and adolescents.


According to the Law on the Protection of Personal Data, sensitive data are those that affect privacy or whose abuse may lead to discrimination, such as those related to:

Racial or ethnic origin.

Political orientation.

Religious / philosophical beliefs.

Membership of trade unions, social organizations, human rights organizations or political parties.


Sex life.

Biometric data (such as fingerprint, signature and photo).

Treatment of Personal Data of a sensitive nature is prohibited by law, unless there is prior express authorization from the Card Holder, among other exceptions set forth in Article 6 of Law 1581 of 2012.

In this case, in addition to complying with the requirements established for the authorization, THE COMPANY shall:

Inform the Cardholder that because it is sensitive data, it is not obliged to authorize its Treatment.

Inform the Holder which of the data that will be subject to Treatment are sensitive and the purpose of the Treatment.

IMPORTANT: No activity may be conditional on the Holder providing Sensitive Personal Data.


According to the provisions of Article 7 of Law 1581 of 2012 and article 12 of Decree 1377 of 2013, THE COMPANY will only carry out the Treatment, that is, the collection, storage, use, circulation and / or suppression of Personal Data corresponding to Children and adolescents, provided that this Treatment responds and respects the best interests of children and adolescents and ensures respect for their fundamental rights.

Once the above requirements have been fulfilled, THE COMPANY must obtain the authorization of the legal representative of the child, prior to the child's exercise of their right to be heard, an opinion that will be valued taking into account the maturity, autonomy and capacity to understand the matter.










Define the policy and procedure for the handling of personal data by 57 TEAM S.A.S. Identified with NIT. 900,566,396-5.

In compliance with what is established in Article 17 Numeral k of Law 1581 of 2012, this internal manual of policies and procedures is adopted to guarantee the adequate attention of consultations and claims regarding the handling of personal data by our company.

Our company will be responsible for what is stipulated in Law 1581 of 2012, without prejudice to the other provisions set forth in this law and others that govern its activity.

57 TEAM SAS is responsible for the processing of personal data, which has been collected by our company in order to disseminate and promote the activities it carries out as part of its corporate purpose and obtained through different means through which it has or has had Contact with third parties (by telephone, by registration in web page, by email and others). In compliance with the provisions and provisions of the regulations governing the right of Habeas Data in our country, the following procedure is established to deal with queries and complaints.

The Holders or their successors may request the consultation of the personal information of the Holder who is in any database, whether public or private. The person in charge of the treatment or in charge of the treatment must supply all the information contained in the individual registry or that is linked to the identification of the holder.

The consultation will be attended in a maximum term of ten (10) working days counted from the date of receipt of the same. When it is not possible to attend the consultation within this term, the interested party will be informed, stating the reasons for the delay and indicating the date of the consultation, which in no case may exceed the five (5) business days following the Expiration of the first term.

The consultation will be considered as received whenever it is physically presented at the main premises of the company or by e-mail addressed to, signed by the Holder and accompanied by a copy of the Holder's identity document.

When the request is made by a successor in title, proxy and / or representative of the holder, it must prove such quality, in accordance with the applicable rules on the subject.

The consultation will be taken care of by the Commercial Department and its response will be given within the term established by Colombian law.

The consultation will be taken care of by the Commercial Department and its response will be given within the term established by Colombian law.

The Holder or his assignees who consider that the information contained in a database must be corrected, updated or deleted, or when they notice the alleged breach of any of the duties contained in the law, may submit a complaint to the Head of the Treatment or the Treatment Manager which will be processed under the following rules:

1. The claim shall be made through an application addressed to the Manager of Treatment or to the Manager of the Treatment, with the identification of the Holder, the description of the facts that give rise to the claim, the address, and accompanying the documents that he wishes to assert. If the claim is incomplete, the interested party will be required within five (5) days of receipt of the claim to remedy the faults. After two (2) months from the date of the request, without the applicant submitting the requested information, it will be understood that he has withdrawn from the claim.

In the event that the person receiving the complaint is not competent to resolve it, it will transfer to whom it corresponds in a maximum term of two (2) business days and inform the interested party.

2. Once received the complete claim, a legend that says "claim in process" and the reason for it, in a term not greater than two (2) business days will be included in the database. This legend must be maintained until the claim is decided.

3. The maximum term to attend the claim shall be fifteen (15) working days from the day following the date of receipt. When it is not possible to deal with the claim within that term, the interested party will be informed of the reasons for the delay and the date on which the claim will be dealt with, which in no case may exceed eight (8) business days following the expiration of the first finished.

The claim shall be considered as received whenever it is physically presented in the main premises of the company or by e-mail addressed to gestió, signed by the Holder and accompanied by a copy of the Holder's identity document.

When the request is made by a successor in title, proxy and / or representative of the holder, it must prove such quality, in accordance with the applicable rules on the subject.

The Holder or assignee may only file a complaint with the Superintendency of Industry and Commerce once the process of consultation or complaint has been exhausted before the person responsible for the treatment or in charge of the treatment.

The present procedure shall apply from the date of issue. The period of validity of the databases shall be governed by the provisions governing the matter.


When the services contained within the COMPANY websites are accessed or used, the COMPANY may collect information in a passive way through information management technologies, such as "cookies", through which information is collected about Computer hardware and software, IP address, browser type, operating system, domain name, access time and the addresses of the websites of origin; Through the use of these tools are not collected directly Personal Data of users. It will also collect information about the pages that the person visits most frequently on these websites in order to know their browsing habits. However, the user of the COMPANY websites has the possibility to configure the operation of "cookies", according to the options of your internet browser.


THE COMPANY, in strict application of the Security Principle in the Processing of Personal Data, shall provide the technical, human and administrative measures necessary to provide security for the records, preventing their adulteration, loss, consultation, use or unauthorized or fraudulent access. The obligation and responsibility of THE COMPANY is limited to having the appropriate means for this purpose. THE COMPANY does not guarantee the total security of its information nor is it responsible for any consequences derived from technical failures or from improper entry by third parties to the Database or File on which the Personal Data object of Treatment by the COMPANY And their Managers. THE COMPANY shall require service providers to contract, adopt and comply with appropriate technical, human and administrative measures for the protection of Personal Data in relation to which such suppliers act as Managers.


This Personal Data Protection Policy, the Privacy Notice and the Authorization Format that forms part of this Policy as Annex 1, are governed by the provisions in the current legislation on the protection of Personal Data referred to in Article 15 Of the Political Constitution of Colombia, Law 1266 of 2008, Law 1581 of 2012, Decree 1377 of 2013, Decree 1727 of 2009 and other norms that modify, repeal or replace them.


This Privacy Policy is effective as of September 1, 2013.