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Privacy Policy


1. Introduction
We present the current legislation on data protection, presently Act 1581 of 2012 (and regulations that amend, complement, add or enhance the Act) and Decree 1377 of 2013, in order to enforce such legislation as per the relevant aspects related to data capturing, usage and transferring that the School SAN MATEO APOSTOL (hereinafter “SAN MATEO SCHOOL” or the “School”) runs regarding the handling of the personal data you have authorised the school to process.

This personal data processing policy (the “Policy”) outlines the corporate legal norms that support the School’s personal data processing, as well as the rights you have as proprietor of your personal details, and the internal and external procedures in the exercise of such rights.

In accordance with the provisions of article 15 of the Colombian Political Constitution and applicable legislation (Act 1266 of 2008, Act 1581 of 2012, Decree 1377 of 2013 and all regulations that rule, add, repeal or modify the laws) we enforce a clear privacy and protection of personal details policy: we do not obtain third-party personal information of entities who may have a commercial or juridical relationship with the School, including the parents, students, employees or suppliers, unless they voluntarily give such information supported by express and qualified consent.


2. Definitions


In order to interpret this Policy, please consider the following definitions:

  • Personal Data: Any details related to or that may be linked to one or more individuals, identifiable or definable;
  • Sensitive Data: Such details that may affect the individual’s privacy or that improper use of such personal data may produce instances of discrimination;
  • Data processing personnel: a natural or legal person, public or private, that individually or in association with others conducts the data processing for the School in his/her capacity of data processing clerk;
  • Data Processing Policy: is this document, the data processing policy of the School regarding the use of personal details’ information in compliance with current legislation;
  • Supplier: any natural or legal person that is a service provider of the School as per a contract agreement obligation;
  • Responsible of Data Processing: a natural or legal person, public or private, that individually or in association with others, decide all aspects of the School’s Database and/or Data Processing, and that as a result of this Policy, will be acknowledged as Responsible of Data Processing, effectively, The School;
  • Record holder: natural person whose personal details have been entered into the database and are processed; he/she may be a client, a supplier, an employee, or any third party that has a commercial or juridical relationship with the School and that in such capacity has provided the School with his/her personal details;
  • Transference: in reference to the transfer of data sent by the School’s Data Processing responsible officer to a third party agent, natural or juridical person (a recipient), in the country or beyond the national territory borders for adequate data processing;
  • Transmission: in reference to the communication of personal details data by the School’s Data Processing responsible officer to the Data Processing clerk, be it within the country or beyond the national borders, so that the clerk may run the data processing system on behalf of the School’s Responsible officer;
  • Processing: Any operation or set of operations related to data capturing, storage, usage, distribution or deletion.

To fully understand the meaning of any term not included in the above list, please refer to the current legislation, mainly Act 1581 of 2012 and Decree 1377 of 2013, and you may apply such meaning to those terms that were not clear.

3. Use and purpose of data processing


The School acknowledges that the Record holder whose personal details are captured in the data base, has a reasonable expectation of confidentiality regarding his/her personal information, notwithstanding his/her responsibilities, rights and obligations in connection to the School.

In virtue of the relationship established between the Record holder and the School, it is known that the School will capture, store, use and transfer personal details in the form of data to companies located in Colombia and outside the national territory. These personal data will be used for the following purposes:

  • Enforcement of the signed contract with the School.
  • Payment of contractual obligations.
  • Sending adequate information at the request of government or judicial departments.
  • As supporting information during internal and external audits.
  • Sending/Receiving messages and notifications to students, parents and guardians via the database of the School.
  • Registration of information of students, parents and guardians in the database of the School.
  • Registration of information of Employees in the database of the School.
  • Registration of information of school Suppliers in the database of the School
  • Contact with students, parents and guardians, employees or suppliers regarding notifications on contracts and its commercial or contractual obligations therein.
  • Data collection to fulfil the obligations that the School has as Responsible of Information and personal details.
  • For security and fraud prevention purposes.
  • Data collection to send to relevant institutions, entities or responsible natural or juridical persons during Teaching outings, Cultural activities, School trips within and outside Colombia, and School social activities.
  • Any other purpose which may appear during the development of the contract or the relationship between you, the Record holder, and the School.

When you provide us with your personal details, the School shall use such data solely for the purposes outlined in this Policy document; we shall not sell, licence, transmit or divulge your personal information beyond the School, except when (i) you provide explicit authorisation, (ii) it should be necessary in order for agents or contractors to fulfil their contractual obligations, (iii) in the delivery of the School’s products and services, (iv) shared information with marketing service providers and other entities that handle our marketing strategy as per our service agreement, (v) may be related to a merge, consolidation, acquisition, divestment, or other restructuring process, or (vi) as per legal requirement or to the extent permitted by the law.

In order to apply the above Policy, your personal details will be subjected to the above parameters and divulged to the School’s Human Resources personnel, clerks, consultants, advisors and other persons and offices, as the case may be.

The School may subcontract third party contractors to handle data processing and your personal details will be passed on with the provision of absolute confidentiality. The service provider shall take all appropriate measures to protect the School data, they are forbidden from using your personal information for their own purposes and they may not divulge your personal information to others. Likewise, the School may transfer or transmit (as the case may be) your personal details to overseas companies for security reasons, or administrative efficiency and better service, in accordance with authorisation levels held by such persons. The School has approved all appropriate security and data protection measures applicable within these companies jurisdiction that are similar to the data protection outlined in this Policy document. In the case of personal details transmission, an adequate contract shall be drawn as per the provisions of Decree 1377/13. Furthermore, be informed that, once your personal details are no longer used in the School data processing, they shall be deleted or safely archived, and may only be ever divulged as per the provisions of the law.

You, the Record holder, hereby authorise the School, expressly, informed and specifically, to process any sensitive data of yours that may exist, and that you have freely provided to the School. Be aware that should sensitive data of yours may be subjected to processing other than the data processing outlined in this Policy document, The School shall inform you, in advance and clearly, the nature of such sensitive data and the reason why they will be processed. The School has a Sensitive Data Processing Policy: no service offered by the School may be conditioned to producing sensitive data. We remind you that as far as sensitive data is concerned, you are not obliged to authorise the School to process sensitive personal details. However, should such sensitive data be necessary for the School operation as an education institution, should you decide to withhold authorisation for data processing, the School will be forced not to provide such service.

Conversely, the School has the right to process the personal details of children and minors; in those instances, the School shall protect such data and any data processing will safeguard the highest interests of the minor and ensure the respect of basic rights, obtaining authorisation from the minor’s legal representative, having asked the minor’s opinion, which shall be valued in relation to the child’s maturity, personal autonomy and ability to understand the matter.

4. Rights of the Record Holder


In accordance with the provisions of article 8 of Act 1581 of 2012, the rights of the Record holder concerning his/her personal details are:

  1. To know, update and amend his/her personal details given to the School as Data Processing Responsible officer or data processing clerk. This right may be enforced, among other instances, should the data be incomplete, inaccurate, fragmented, that may force errors, or unauthorised or forbidden data may be processed;
  2. May request proof of authorisation given to the School as Data Processing Responsible officer, except when such instance is exempted as requirement for data processing;
  3. To be informed by the School as Data Processing Responsible officer or by the data processing clerk, prior request, regarding the use given to his/her personal details;
  4. To present at the Superintendence of Industry and Commerce any claim of violation against the current legislation and regulations that modify, add or complement the law;
  5. To revoke authorisation and/or to request the data be deleted should the data processing lack respect for principles, rights and constitutional and legal guaranties;
  6. To have free access to his/her personal details that have been processed.

You will find in this Policy document Information on the procedure where by the School guaranties your rights.

5. Procedure for exercising the rights of a Record Holder


Should you have any queries regarding this Policy, or should you have a concern or complaint, or should you need to act upon a claim, a rectification case, update, consultation, access request or data subtraction, or queries regarding the management of the Policy, please do not hesitate to contact us on:

Email: infogeneral@csma.edu.co
Telephone: +571 6760885

Please consider that once you contact the School and your query is directed to the relevant responsible person, the process of attending to your case, be it a complaint, a request or an enquiry, shall commence.

A record holder may query with the School regarding his/her personal details in record, by producing a valid identity document. The School shall proceed with the consultation of the Data base within a period of ten (10) working days, counted since the receipt of the query. This term may be extender by the School, if necessary, only once, informing the applicant of the reason for the delay. The School shall provide the relevant information not later than five (5) working days after the initial period of ten days expired. A query regarding complaints, updates, amendments or deletion of personal details shall be resolved in a maximum period of fifteen (15) working days from the day of receipt. In order to facilitate a prompt resolution to your query, please provide the name of the record holder in question, identity document, return address and the relevant documents that substantiate the query.

Should your query or request to the School is not accompanied by the appropriate documents, the School shall inform you within five (5) days of receipt, that you need to provide such documents. However, should two (2) months pass after the School request for substantiating documents with no response, the School shall understand that the query is no longer standing.

6. Amendment of this Policy


This Policy may be amended at any time, therefore we advise to review this information on our web page, where the relevant information shall be updated on a regular basis and the latest version of the Policy will be made available or the steps to obtain a copy will be indicated.

Date of effective validity of the Policy: September 2013

Date of latest amendment: September 2013

Date of effective validity of the Data base: The effective validity of the Data base shall be a reasonable and necessary time to conclude operations of data processing.

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