Terms and conditions
- Capacity of celebrating contracts
- Registration of Accounts and Users
- Description of the Service
- Scope and level of service
- Payment methods
- Account Information
- Communication Policy
- Security of the Account
- Site Operation
- Interruption and Termination of Service
- Applicable Law and Jurisdiction
- Comments and Questions
Soluciones ALEGRA S.A.S . Personal Data Handling Policy
- Legal Framework
- Authorization of the Account Holder for the Processing of Personal Data
- General Data Protection Regulation (GDPR)
- Authorization of the Account Holder for the handing of Sensitive Data
- Use and Purpose of Personal Data Handling
- Notice of Privacy
- Revocation of Authorization and/or Suspension of Data
- Rights of the Account Holder of the Information
- Procedure for the Exercise of the Rights of the Account Holder of Data
- Duties of Alegra as Processor and Responsible for the Processing of Personal Data
- Information Security Measures Applied to Database Processing
- Responsible for the attention of requests, consultations and claims
- International Transference and Transmission of Personal Data
- Effective Date
Of both parties
The terms expressed in this contract constitute the conditions of use and privacy for all services currently provided and those which may be added in the future, by Alegra on its website www.alegra.com and its app app.alegra.com, the Alegra mobile version and Api.
The user agrees, when beginning to use the service, to respect all the conditions imposed by this contract.
The definitions below will have the following meaning in this contract:
- The term "contract" or "agreement" refers to this contract and its Terms and Conditions.
- The term "applicable laws" refers to the laws that apply to this type of contract.
- The term "site" or "website" refers to the site where all the services that Alegra offers are provided, without considering possible third parties related to Alegra.
- The term "service" or "services" refers to the application that Alegra offers on its website and that operates from the domain app.alegra.com. It also refers to the use of the Alegra website and its support center alegra.com/ayuda/
- The term "Alegra", "Sistema Alegra", "we", "our" refers to Soluciones ALEGRA S.A.S and all its associates.
- The term "System" refers to the web platform used by Alegra to provide its service, including the software used by the platform and all its content.
- The term "Application" refers to the software that Alegra offers as a service on its website app.alegra.com
- The term "account holder" refers to the credit card Bearer in whose name the account was registered.
- The term "user" refers to the person who visits and uses the Alegra website and its application, regardless that he/she be the "account holder".
- The term "Plan" refers to the conditions of use that a user has according to the payment they have made.
Terms and conditions
The user of this site accepts for simple reasons of use of the Alegra system, the provisions of this contract and its Terms and Conditions, subject to change without prior notice from Alegra. If the user represents an organization, he/she is assuming that the organization agrees to be bound by this contract and that he/she has the powers to act on behalf of that organization and therefore compel it with Alegra and accept the obligations established in this contract. The user who does not agree with this, will not be able to use the services provided by Alegra.
Capacity of celebrating contracts
The user who accepts this agreement and its terms and conditions, must be legally able to enter a contract as allowed by their autonomy of will and the applicable laws. This refers therefore to the fact that whoever wishfully enters this contract, is legally bound by the general theory of conclusion of contracts that applies in their country.
Alegra assumes that the user who accepts this agreement of Terms and Conditions knows in advance whether they can enter a contract on behalf of the person who is determined as a User. Those who are not considered to be totally, relatively or partially in said capacity, must have authorization from the general proxy of the user, to celebrate this contract, and the latter will be considered responsible for any conduct of whom they represent.
Registration of Accounts and Users
Alegra provides a software service that is accessed through its website www.alegra.com Users who access this service must register an account and provide the information requested on the forms that are enabled when registering an account. Alegra assumes that any information entered in these forms is made under oath and therefore exonerates Alegra from possessing false information about any User.
Alegra allows the entry of a limited number of Users according to the plan that each account holder or user has chosen when registering their account. Alegra does not allow, under any circumstances, that these users be different from those that the account holder has decided to enable as such for the use of the platform and these may not be replaced by other individuals who have knowledge of the credentials to enter the platform. If said situation were to occur, Alegra will not be liable for the harmful use of the account information against the account holder, the user or any third party.
Description of the Service
Alegra provides the service of its web application in two forms, free and paid. Alegra may stop offering the Free plan for new users, but the user who purchased it before hand, will be able to continue using it indefinitely as long as they do not make subsequent changes to their plan. The User acquires a non-exclusive, worldwide, temporary and non-transferable license to use the Alegra system according to the conditions of the plan that he/she has chosen when paying for the service, or if such is the case, accepts the conditions he/she has as a free user, but at no time or circumstance does he/she acquire ownership of the platform.
The copyright of the software parts of which the platform is composed, and the services shall be the property of Alegra, and under no interpretation of these terms of service shall be understood as transferred to the user.
The Alegra service begins when an account is registered on the Alegra website, after having accepted the conditions expressed in this contract. The service consists of the use of the Alegra software available at app.alegra.com and all the services available on associated websites (alegra.com/ayuda/ and www.alegra.com) , mobile applications and Api.
The user shall be aware of the services for which he/she is paying when using any of the plans offered by Alegra. Alegra will not be liable in any case for the errors made by the user when choosing his/her plan, as well as when digitizing or entering their personal information or that of the operation and progress of their business activity, nor its classification, which will irreparably affect the results produced by the Software.
Alegra assumes that the account holder and the users are aware of any changes that are made in the configuration of the account, as well as that they will be able to make changes that they consider pertinent. Alegra will not be liable for the loss of information that occurs due to force majeure, a fortuitous event or by a third party as explained further on under "Operation of the Site".
Alegra guarantees the user free access to the website www.alegra.com y alegra.com/ayuda/ and mobile application to view the information available there under normal conditions, however the user accepts that there are technical circumstances under which said information may become temporarily inaccessible and therefore exonerates Alegra from any type of responsibility for this fact, on the understanding that this may be due to limitations inherent to the current state of technology.
Scope and level of service
Under normal conditions, the Alegra platform has a “down time” of approximately 1%, so that the platform is available 99% of the time. Alegra will carry out the procedures that it deems appropriate, so that the application is available to the user, but does not guarantee the above, since there may be events such as damage to communications, acts of third parties, maintenance or restructuring of the application, among others that are beyond the control and responsibility of Alegra. Notwithstanding the foregoing, Alegra guarantees users that the application will be available under normal circumstances, as announced, from anywhere in the world that allows an Internet connection, as long as the user remembers their account credentials and the Internet service provided by each provider, allow it.
In case access to the platform is not possible due to the type of connection or deficient Internet service by the provider, this does not imply at any time non-compliance or breach in contract with the service provided by Alegra.
Regarding the maintenance and restructuring of the application, Alegra reserves the right to carry out the necessary procedures, without prior notice to users, but will procure to carry them out with an advanced notice that in its criteria, deems convenient or prudent to avoid inconveniences or eventual damages in data or information processing.
The user will be able to choose the payment plan and period when making the first payment. Depending on the chosen period, be it monthly, semi-annual or annual, the following payments shall be made on the same day of the month as that of the registration date.
Payment to Alegra is anticipated and the user agrees to make recurring charges according to the chosen periods. In addition, he/she agrees to notify Alegra, 2 business days prior the following payment is due, if they do not wish the next payment to be generated.
In case the user does not notify Alegra in advance of his/her desire to suspend payments, he will have 5 business days to request the money be refunded according to the right of withdrawal provided in the Consumer Statute.
Alegra offers the means of payment outlined on its website. However, in order to access Alegra through some of these payment systems, it may be necessary for the account holder to register some information, such as an account number or a valid credit card issued by a financial institution, in order to collect payment for the services provided in our online software available at app.alegra.com or on the mobile application. If there are any type of withholdings,must be assumed by the user.
Alegra is aware that possessing information from users' credit cards or bank accounts is delicate, and therefore, is committed to keeping the user information safe and isolated from inappropriate uses.
Alegra assumes that the credit card information entered to create an account is known to the account holder and therefore is not responsible for the improper use of credit cards at the time it is used to register an account., and is understood as irresponsible use, falsification and impersonation of the owner of the account.
Alegra, therefore, refrains from carrying out all kinds of acts tending to carry out the verification of the user's personal data to confront them with those registered on their credit card, since it assumes that the information is provided by the owner, and therefore is privy to information and no other person has access to it, in addition to not having databases with which to confront such information.
Notwithstanding this, the user authorizes Alegra to carry out any verification or consultation of their data in any database, information and risk centers and any other source of information that provides history on the way in which they attend to their financial and credit commitments, both nationally and internationally.
The user affirms under the gravity of oath, that he/she is not included in the Clinton List and that his/her income is not related to any type of acts of those that national and international legislation determine for money laundering, drug trafficking, terrorism or any other crime, and that they are acquired in a lawful way.
Alegra is a Web application, which provides a site where data is stored that the user manages at his own risk and expense. Alegra ensures that the user´s information is stored safely and takes the precautions in its judgment necessary for it, but it is not liable for the malicious acts of third parties and the consequences thereof towards the user or against third parties.
Alegra informs its users that the information it provides will be hosted on third-party servers, specifically Amazon, which comply with the highest standards of security and suitability.
Alegra is also not responsible for the type of information entered by each user into their account or for the inadequate results if it was entered inappropriately in accordance with the accounting and tax parameters applicable to the matter in each case. It is implied that the user, when using Alegra services, will make an appropriate and legal use of all the tools that are made available to them, exempting Alegra of any improper use of information by any user, this being understood therefore, as use of information in order to avoid tax obligations, among others.
Alegra will not be obliged to ensure the legality of the content and information that users have in their account through the Services provided, however, it may take corrections against illegal information, when it deems it appropriate.
The user agrees when using any of the Alegra services to (i) not cause physical, moral or mental harm to other users of the service (ii) not to use the service for malicious or ill-intentioned purposes, nor to benefit to the detriment of third parties and much less of the State, understanding by it, anyone individual who, according to applicable regulations, must collect currency for taxes of any denomination as a result of the user's commercial operation. (iii) not to use the service for criminal or illegal purposes nor to take advantage or illicit benefit for himself or for third parties, whether remunerated or not, (iv) not to publish information that violates the rights of third parties, such as intellectual property rights, industrial secrets or any other that is owned by third parties and for which it is not authorized (v) to publish sensitive information that is no longer in force or that may mislead third parties or the State.
The Alegra user declares to be the owner of the information entered into the system and under no circumstances will this information become the property of Soluciones ALEGRA SAS, and conversely, the latter company is the sole owner of the platform on which the user enters the information, without any transfer being considered as result of this contract. If the user terminates the contract, he/she will have the information at their disposal, but at no time is Alegra obliged to deliver it in any format or to carry out any type of migration process, much less to carry out a development so that the information can be analyzed, entered or digitized in any other software, given that data is solely entered, for consultation and processing with the purpose of its operation and use.
In addition to the above, Alegra is not liable for the wrong completion of a form or for the information that the USER erroneously provides when carrying out a procedure or entering the information into the software.
Google Analytics advertising functions implemented in Alegra
Alegra uses Google Analytics remarketing audiences for use in Google AdWords and DoubleClick Bid Manager, this in order to publish remarketing campaigns directed at its users. The user accepts that their information is processed for Big Data purposes and therefore allows Alegra to use these tools for statistical purposes.
Alegra, through the installation of its own and third-party cookies and identifiers, and through tools for the analysis of account use, will be able to carry out follow-up activities of its users of its application. With these tools, Alegra will be able to collect information from 02,each user for statistical analysis and implementation of communication and advertising strategies. These tools will be able to track user settings making his/her experience more practical, recognizing and remembering their preferences and settings.
To this extent, Alegra may collect usage data, such as duration of use, or demographic data such as origin, sex, and age. Alegra uses this information for analytical purposes. The Alegra user will be able to inactivate these tools.
Monitoring activities carried out by Alegra may also be carried out within the application, for internal analysis, for example, but not exclusively, to determine trends and participation in the application, time of use, preference, among others. These tools may be inactivated by the user ‘to preserve their privacy. Learn more here.
The user, when creating his account and making use of the Alegra application, accepts that THE COMPANY may supply, transfer, share and analyze the ordinary data of its business course, with allied, subsidiary, linked or subordinate companies of THE COMPANY in Colombia or in any other country, and that this information may be used for commercial purposes by third parties.
The user can at any time may request THE COMPANY to indefinitely stop the process of sharing their data with third parties, for which they must submit their request to email firstname.lastname@example.org or communicate it through the customer service chat.
When registering an account with Alegra, the account holder must enter an email and a contact telephone number, as well as register all the data that the software requests in order to determine not only their identification, but also what allows the software to process the information that the same user registers or enters. By doing so, he/she agrees to receive all emails and calls with information on the use of Alegra, promotional information or any other information processed or sent by Alegra. Notwithstanding the foregoing, Alegra may not use the information entered by the user for its benefit or that of third parties, however, it may use the database of companies or users for advertising or commercial purposes for itself or for third parties, without having to share or pay any type or amount of income to the user. The user may request that their data be no longer shared at any time and through the established channels and/or by submitting a request to: email@example.com
In addition , users will have the possibility to communicate with the Alegra team in case they have questions or concerns to resolve, general questions about their account or about the software as such. For the above cases, they should write to support@Alegra.com. or use the support tab available in the application.
Security of the Account
Alegra safeguards the security of the password provided by the account holder and users when registering an account with Alegra and guarantees that it will take the measures within its reach so that this password is not seen by third parties, but cannot take responsibility for ensuring their confidentiality. On the other hand, Alegra is not responsible for the misuse of the password by the user or for the use of passwords that are easy to decipher, assuming that whenever the system is accessed, the user does it directly.
Alegra will carry out the procedures that it deems appropriate, tending to make the associated websites always available to the user, but does not guarantee the above, both for damage to communications, for acts of third parties, maintenance or restructuring of the sites or other types of acts that are beyond the reach and direct responsibility of Alegra. Notwithstanding the foregoing, Alegra guarantees its users who pay for the service, that the software will be available on app.alegra.com from anywhere in the world that allows an Internet connection, if the user remembers their account credentials. and the conditions of the Internet service provider connection service, allow it, which is beyond the scope of Alegra’s obligations, and therefore in the event the platform could not be accessed due to the type of connection and its specific characteristics, due to communication failures or deficient service of the aforementioned provider, does not imply at any time non-compliance or breach of contract with the service contracted with Alegra. Regarding the maintenance and restructuring of the site, Alegra reserves the right to do so without prior notice to users, but will procure to carry them out, with advanced notice as early as it deems appropriate or prudent in order to avoid any inconvenience or eventual damages in the data or information processing.
THE CLIENT may not apply reverse engineering techniques, decompile or disassemble the software, or perform any other operation that tends to discover the source code. Furthermore, the separation of the components is prohibited. Alegra authorizes the use of the software as a single product. The parts that compose it cannot be separated for use in more than those units or workstations in which THE COMPANY installs them, nor can they be used separately. The user understands that not complying with the provisions of this clause constitutes a crime in accordance with the applicable regulations..
Interruption and Termination of Service
Alegra reserves the right to terminate the service at any time, both permanently and temporarily, for those cases in which successive payments must be made.
Alegra may unilaterally terminate a user's account in the following scenarios: (i) In the event that the USER uses the services provided by Alegra for purposes contrary to the law, especially those that contradict the intellectual property rights of third parties and of everyone from Alegra and other users; (ii) In the event that Alegra finds that the USER is using his account to transmit malicious programs such as viruses, malwares, spywares, Trojans or the like, that may compromise the proper functioning of the Alegra platform or that harm third parties; (iii) When there are elements that allow Alegra to infer that the USER does not have the minimum age to contract the Services, under the terms of the second article of these Conditions. Alegra reserves the right to decide if the content published by users, as well as the textual or photographic material that is uploaded to the Alegra website is appropriate and complies with the Conditions. In this sense, Alegra may prevent the publication and commercialization of content that infringes image, habeas data and privacy rights of third parties, as well as those that are offensive, defamatory or that constitute infractions of the law.
Paragraph: Suspension of Service.
THE COMPANY reserves the right to suspend the provision of services to the USER and to disable their access to the Software, as well as to any of the modules created for THE USER if after two attempts to collect payments, the collection is unsuccessful, or in case of not receiving payment for the service in the agreed form.
The suspension of the service will be given to the USER with advanced notice.
In case of suspension, the USER's account will not be reactivated until all debts owed at said moment have been fully payed. If after three attempts to collect payment for the service the collection is unsuccessful, the USER shall make the payment of the money owed through a payment link. To obtain the link where said payment must be made, the USER must contact the Alegra support team by writing to www.alegra.com/123
The suspension of the USER's account does not eliminate his obligation to pay the outstanding debts, as well as the percentage collected does not prevent the generation of collection costs and compensation for damages that could be generated in favor of Alegra for such non-compliance.
In case of non-payment, or improper use of the account, the user will receive a notification via email, upon which they will have a grace period of 15 days during which they will be able to consult their account as well as the information that has been stored in it so far, but without the possibility of adding new information. The user will be responsible for copying or subtracting said information, since once the 15-day period expires, Alegra will no longer be responsible for the information stored in the account and which may then be freely deleted.
Applicable Law and Jurisdiction
This contract is governed by the laws of the Republic of Colombia. If any part of this contract is declared null or contrary to the law, then the invalid or non-enforceable provision will be considered replaced by a valid and applicable provision that is closest to the intention of the original contract and the remaining part of the agreement between Alegra and the user will continue in effect. Unless otherwise specified in this document, these Conditions constitute the entire agreement between the account holder and Alegra regarding the Alegra Services, and supersedes all previous and proposed communications, both electronically, orally and in writing, between the user and Alegra with respect to Alegra Services.
Notwithstanding the foregoing, the parties agree that these Terms and Conditions will also be subject to the mandatory rules of each country in which they are operating, especially in relation to, but not limited to: consumer rights and duties, ability to sign contracts , computer crimes, and information handling, among others.
Comments and Questions
If there are queries, complaints or claims regarding the information contained in these Terms and Conditions document, please write to the email firstname.lastname@example.org, using as subject: Comments Terms and Conditions.
Last update: December 13, 2017
Soluciones ALEGRA S.A.S . Personal Data Handling Policy
SOLUCIONES ALEGRA S.A.S. has implemented this POLICY ON THE PROCESSING OF PERSONAL DATA, in order to give due handling to the information provided within any personal data record, carried out directly, through the its site www.alegra.com or the mobile application called Alegra . Said policy includes handling requests, inquiries and claims related to the treatment of this type of information.
This Personal Data Handling Policy is directed for all-natural persons who have or have had any relationship with SOLUCIONES ALEGRA S.A.S., and who have their personal data stored in its databases.
Company: Soluciones Alegra S.A.S.
Tax Identification Number -NIT-: 900.559.088-2
Address: Carrera 43 c # 5-115, Medellín - Colombia
Telephone: +574 4480132
Web Page: www.alegra.com
II. Legal Framework
This personal data processing policy is prepared in accordance with the provisions of the mandatory rules of each Country or State, and other complementary provisions that modify, add or complement them, which will be applied by SOLUCIONES ALEGRA S.A.S. regarding the collection, storage, use, circulation, deletion and all activities that constitute handling of personal data.
The following are the guiding principles of the Handling of the Account Holder´s Personal Data and THE COMPANY as a respectful law abiding entity: Principle of Legality, Principle of Purpose, Principle of Freedom, Principle of Veracity or Quality, Principle of Transparency, Principle of Restricted Access and Circulation, Principle of Temporality of Data, Principle of Security and Principle of Confidentiality.
For the purposes of interpreting and applying this policy, we request that the following definitions be considered:Click here
In this document, the Internal Manual of Policies and Procedures for the Handling of Personal Data of SOLUCIONES ALEGRA SAS is established, which will apply to all databases where personal information is stored and is processed by the Company, hereinafter ALEGRA or THE COMPANY.
Alegra, understands by data protection, all those measures taken at the physical, technical and legal level to ensure that the information of the Account Holders - natural persons - (customers, employees, former employees, suppliers, creditors, etc.), is safe from any attack or attempt to access it by unauthorized persons as well as that its use and conservation be adequate.
Alegra will be able to use personal data for:
a) Executing the existing contractual relationship with its clients, workers, providers and applicants, including payment of contractual obligations
b) Provide the services and/or products required by its users
c) Report on new products or services and / or changes in them
d) Evaluate the quality of the service
e) Carry out internal studies on consumer habits
f) Send to physical, electronic, cell phone or mobile device, via text messages (SMS and / or MMS) or through any other analog and / or digital means of communication created or to be created, commercial, advertising or promotional information regarding products and/or services, events and/or promotions of a commercial or non-commercial nature, in order to promote, invite, direct, execute, inform and in general, carry out campaigns, promotions or contests of a commercial or advertising nature , advanced by Alegra and/or by third parties
g) Develop the of selection, evaluation, and hiring process of employees
h) Support internal or external audit processes
i) Register the information of employees and/or pensioners (active and inactive) in the Alegra databases: Those indicated in the authorization granted by the data owner or those described in the corresponding privacy notice.
j) Provide, share, send or deliver your personal data to Alegra´s affiliated, related or subordinate companies located in Colombia or any other country, in the event that said companies require the information for the purposes indicated herein.
A. The databases in which the company SOLUCIONES ALEGRA S.A.S. acts as responsible and oversees its handling:
In the treatment of data contained in the following databases Alegra acts both as Responsible, given it collects the information and makes the decisions regarding treatment of data, in its processor condition , to the extent that it executes data processing.
Below are the 4 databases on which SOLUCIONES ALEGRA S.A.S. executes the processing of personal information:
Client Data bases:
Description: This database corresponds to the information of THE COMPANY's clients, that is, it corresponds to those natural persons who access the different Alegra services.
Content: This database contains the following personal information: name, identification number, city and country of residence, address of correspondence, email, telephone, economic activity, bank information such as account number, type, bank, credit card number.
Data collection method: The information is obtained directly by registering the form through the website or the mobile application and finally the account is configured, in all cases it is recorded in specialized Amazon servers that have all the infrastructure to guarantee the security of the information. In the collection of information, the client expresses the authorization for the collection of his personal data by Alegra according to the purposes established in this policy and published on the website www.alegra.com and in the corresponding application.
Purpose: The information contained in this database is intended to enable Alegra to fulfill its objective of providing accounting services from a cloud platform. Therefore, this database has the following purposes: Contacting the customer at: Technical support and customer service, for billing: Billing support, collection management, and for marketing and advertising: Sending newsletters, promotions, surveys and information on new features
Handling: The personal information contained in this database is the object of collection, storage, use, and circulation.
Handling: The personal information contained in this database is the object of collection, storage, use, and circulation.
External circulation: The information contained in this database is stored on an Amazon server and can only be accessed by certain authorized Alegra personnel such as from the engineering and administrative areas. Similarly, the Panel can only be accessed by each user, since it is personal and has a password and a security token for it. There is an accounting provider for billing and accounts receivable issues, collection payment platforms are used or they can be done directly at banking institutions. Currently the authorization for the processing of personal data is obtained through the website app.alegra.com, as well as through the mobile application. From the time of registration, said data is expanded to the financial information at the time of the registration and corresponding payment.
Validity: The personal information contained in this database is stored during the duration of the commercial relationship with the client plus an additional period of 10 years. If, in an individual case, there are indications of a need for protection or of historical interest, the data storage period will be extended until the legal need for protection has been clarified.
2. Databases of employees, former employees and applicants:
Description: This database contains the information that is collected of applicants for any vacant position within THE COMPANY through the resumes, company employees through employment contracts, internship students and former Alegra employees. This database is handled by the Alegra Administrative and Management area.
*Content: The personal information specified in this Database contains the following personal data: Name, identification number, copy of the identification document, place of issue, date and place of birth, marital status, city of residence, residence address, telephone number, mail, salary, income, medical exams, blood type, pension fund, Health Service Provider (EPS), severance fund, family data including children and adolescents in the first degree of consanguinity, photographic records, occupation, position, academic information, work experience, work and personal references, bank account number, bank, withdrawal date, contact details in case of emergency, name and relationship. The company collects certain sensitive data which include data from minors, blood type and photographic records.
Data collection method: The Administrative area collects the information through the resumes provided by the applicant, in job interviews in the presence of the applicant and in the work contracts signed between the employee and THE COMPANY.
Purpose: The aforementioned data is only collected in order to comply with the obligations derived from the work contract, which include, attention of requests, generation of certificates and certifications, affiliation to Social Security entities, Occupational Health, human services activities, collection of accounting records, reports to control and surveillance authorities, contact with the employee, taxation, communication in case of absence, among other administrative and contact purposes. Sensitive data is used for information related to the health of the worker, and is used in cases of emergency, or for reporting to Social Security System entities.
Handling: The handling that this database receives from THE COMPANY in its condition as responsible and processor includes the collection, storage, use and circulation. Circulation can be internal or external and is carried out as follows:
Internal Circulation: For payment of payroll and other services, for accounting records and for monitoring employees, regarding their work and occupational health issues.
External Circulation: As requested by the following entities: For the UGPP for Pension and Parafiscal Management, for DIAN (Colombian Department of Taxes and Customs), for SENA (National Learning Service) and for ICBF (Colombian Childcare Institute). The data is also used to send reports to administrative entities that request it, based Social Security System and related norms and regulations. The information contained in this database is stored in drive files and email, and to access them, passwords are required, which are only known to the respective areas that have access to the information. Likewise, confidentiality policies are established.
Validity: This Database will be in force if there is an employment relationship between the employee and THE COMPANY, and for 90 more years from the date of termination of the contract. Likewise, THE COMPANY stores the information in a historical file of the individuals who have been employees , as well as of applicants to the positions that have been vacant.
3. Provider Database
Description: This database corresponds to the personal information that is collected of natural persons who provide services and sell products to THE COMPANY.
Content: This database contains the following information: Name, identification number, address, telephone, mail, bank account number, account holder, rut and in case of having it, a website.
Data collection method: The information is obtained through the documentation provided by the provider in order to make payments after invoicing. It is important to highlight that the providers have authorized the collection of their data by completing and accepting the form.
Purpose: The information contained in this database is intended to register the provider on the Alegra Drive file, fulfill the obligations derived from the commercial relationship, make payments, carry out bank transfers associated with the products sold or services provided, send reports to the competent entities and tax entities, in accordance with the provisions of Colombian regulations and to contact them for further services in the future
Handling: The personal information contained in this database is the object of collection, storage, use and circulation. The information contained in this database is stored in a Drive file of the Company, by the Administrative area. The authorization consists of an electronic form, which is completed and accepted by the provider. Regarding security measures, the Drive file can only be accessed by authorized personnel.
Validity: This database is valid if the commercial relationship with the provider exists and an additional period of 10 years.
4. Acrecer Database
Description: Contains information related with natural persons who have decided to refer our application and for which they will receive economic retribution.
Content: This database contains the following information: Name of the referring individual, e-mail of the referring individual, e-mail of the referred individual, telephone, Tax Number (Rut) and bank reference.
Data collection method: The referred client directly registers their data on the Alegra platform and enters their referrer information with a code, thus allowing this database to store information of the referring and the referred.
Purpose: To comply with the obligations derived from the commercial relation, carry out payments, carry out bank transfers associated with the products sold or services provided, send reports to the competent entities, in accordance with the provisions of the applicable regulations and contact them for further services in the future.
Handling: The personal information contained in this database is the object of collection, storage, use and circulation. The information contained in this database is stored in a Drive file of the company, by the Administrative area. The authorization consists of an electronic form, which is completed and accepted by the providers. Regarding security measures, the Drive file can only be accessed by authorized personnel.
Validity: This database is valid if there is a commercial relationship with the provider and an additional 10-year period.
B. Data bases that collect Special Data
For the purposes of handling Sensitive Data, THE COMPANY has obtained the corresponding authorization from the Holders whose information rests in its Databases and will obtain their authorization in advance, provided it is new data.
For the treatment of Sensitive Data, THE COMPANY must comply with the following obligations:
Inform the Account Holder that given it is Sensitive Data, he is not obliged to authorize its treatment.
Inform the Account Holder which of the Data is Sensitive and the purpose of its Treatment.
THE COMPANY does not condition any activity contingent on the Account Holder providing Sensitive Data.
2. Personal Data bases
This database is described in section A. of this manual.
C. Registration of Databases
In accordance with the applicable regulations, the databases will be registered in the National Registry of Databases.
VI. Authorization of the Account Holder for the Processing of Personal Data
THE COMPANY through the "Authorization for the Handling of Personal Data" has adopted procedures to request the user, at the latest before their personal data is collected, their authorization to process said data and inform them of the specific purposes of the Handling for which their consent is obtained.
By creating an account, the user authorizes THE COMPANY to collect, provide, transfer, transmit, analyze, verify and use their personal and/or business data, financial, accounting data, and in general data related to the ordinary course of their business dealings. Likewise, it authorizes to share them whenever necessary for payment processes, commercial strategies or other business-related issues that seek the benefit of the user, with suppliers, affiliated, linked, subordinated or allied companies of THE COMPANY located in Colombia or in third countries, so they can store, analyze, use, consult and verify them with information and risk operators, and contact the user in order to send information, make commercial offers of products and services, or to maintain them.
As the bearer of the information, the user accepts and understands the right that assists him/her to know, update and rectify their personal data, request proof of the authorization granted for its handling, to be informed about the use that has been made of it, file complaints before the SIC (Superintendent´s Office of Industry and Commerce), revoke the authorization and / or request the deletion of their data where appropriate and access them free of charge.
The authorization granted by the account holder to THE COMPANY, complies with the requirements of the current applicable legislation, when he/she manifests: • In writing • Orally • By unequivocal conduct of the bearer that allows a reasonable conclusion that the latter granted THE COMPANY the corresponding authorization. In no case will his/her silence be assimilated by THE COMPANY as unequivocal conduct.
THE COMPANY has established the email address email@example.com and the customer service chat, as the channels for the Data Holder, at any time to request as Responsible or Processor of Handling, the deletion of their personal data and/or revoke the authorization he/she has given us to manage it.
VII. General Data Protection Regulation (GDPR)
Alegra collects and stores all user information, which is hosted on specialized Amazon servers. Account data can only be accessed with a username and password. The stored information complies with current security standards.
Alegra has an established security protocol that is followed by the entire work team, so that when the user requests their data, it will be delivered or deleted, as required.
The data that is collected within Alegra is all related to the business, which is collected in order to make use of the platform, provide support and collect when a payment plan is taken.Alegra uses tools and integrations with third parties for the handling of information that comply with the GDPR regulations for specific purposes without the right to be shared or used for any purpose other than that initially authorized by the user. See more.
The new members of the Alegra work team are trained at the time of their entry, with all the security regulations regarding the data stored in Alegra, in order to ensure proper use of the information.
When said rule came into effect, Alegra appointed a DPO (data protection officer) to ensure compliance with the regulations, maintain a training record for the work team and establish security procedures. The DPO can be contacted at the email address firstname.lastname@example.org.
VIII. Authorization of the Account Holder for the handing of Sensitive Data
THE COMPANY will comply with the following obligations:
Inform the account holder that because it is sensitive data, he is not obliged to authorize its treatment.
Inform the account holder explicitly and previously, in addition to the general authorization requirements for the collection of any type of personal data, which of the data that will be processed are sensitive and the purpose of their treatment and also obtain their consent express.
None of the activities carried out by THE COMPANY is nor will it be conditioned to the owner providing their sensitive personal data.
IX. Use and Purpose of Personal Data Handling
THE COMPANY acknowledges that the account holder of the personal data has the right to have adequate elements to guarantee it, considering, in any case, their responsibilities, rights and obligations.
THE COMPANY collects, registers, stores, uses the personal data of the account holders, for its own use with the purposes that were requested or by requirements of public entities.
The Personal Data of the bearers is used by THE COMPANY to: • Execute the activities of THE COMPANY to fulfill its corporate purpose, all of which will be done based on the purpose of the Database in which the personal data of the account holder is stored . • Offer products, services and / or benefits that seek to satisfy the needs of the account holders, or the products and services of THE COMPANY, which can be done by physical means or through emails and / or mobile terminals. • Send the information to government entities by legal requirement. • Consult information in the control lists (National and International Lists), consult the CIFIN, the information centers, the Clinton List, the Attorney General's Office, the Comptroller's Office, the National Police, and DIJIN in order to preserve trust and transparency between the account holder of the data and THE COMPANY • Support external and internal audit processes. • For the execution of judicial and extrajudicial processes in the cases allowed by THE COMPANY's Statutes and Regulations. • Register the information of Employees, former employees, providers, customers (active and inactive) in THE COMPANY's databases, for the sending of contractual, commercial and obligatory information, if any. • For verification of references of employees, ex-employees, providers, customers (active and inactive) in the databases. • Regarding the collection and processing of data carried out through automated mechanisms in order to generate activity records of visitors and audience records, THE COMPANY may only use said information for the preparation of reports that meet the stated objectives. In no case may it carry out operations that involve associating said information with any identified or identifiable user.
The Personal Data will be used by THE COMPANY only for the purposes indicated here, therefore, THE COMPANY will not sell, license, transmit or disclose the Personal Data, unless: • The account holder expressly authorizes to do so • The account holder´s information is related to a merger, consolidation, acquisition, divestment or other restructuring process of THE COMPANY • Is permitted by law.
For the internal handling of the Data, these may be known by the authorized personnel of THE COMPANY, which includes the General Assembly of Shareholders, the Statutory Auditor, and Management.
THE COMPANY may subcontract third parties for the processing of certain functions or information. When this happens, said third parties will be obliged to protect Personal Data in the terms required by law and in their capacity as processor of handling THE COMPANY's Databases.
In the case of transmission of personal data, THE COMPANY subscribed the transmission contract under the terms of Decree 1074 of 2015.
Likewise, THE COMPANY may transfer or transmit (as appropriate), preserving the appropriate security measures, personal data to other entities in Colombia or abroad for the provision of a better service, in accordance with the authorizations that have been granted by the account holders of personal data.
Once the need for Processing of Personal Data ceases, they will be removed from THE COMPANY's databases in secure terms.
X. Notice of Privacy
This legend is found on all forms or documents through which information is collected from providers, workers, customers and other account holders of personal data handled by THE COMPANY. When they are collected verbally, this legend is communicated to the account holder in the same way, and the authorization is recorded through technical means arranged for this purpose.
- Privacy Notice
- Authorization: For the website
- Authorization: For Employees
XI. Revocation of Authorization and/or Suspension of Data
THE COMPANY has arranged a free and agile mechanism through which the account holder can at all times, and provided that there is no legal or contractual duty that prevents it, request the COMPANY to delete personal data and / or revoke the authorization that has been granted for the handling of the same, by submitting an application.
If the corresponding legal term has expired, THE COMPANY will not delete the personal data of the account holder that requested it from the databases, he/she will have the right however, to request the Superintendence of Industry and Commerce to order the revocation of the authorization and / or the deletion of personal data.
XII. Rights of the Account Holder of the Information
The account holder of the personal data will have the following rights:
a) Know, update and rectify their personal data before Alegra in its capacity as data processor. This right may be exercised, among others, against partial, inaccurate, incomplete, fractional data that is misleading, or those whose treatment is expressly prohibited or has not been authorized.
b) Request proof of authorization granted to Alegra except when expressly excepted as a requirement for management (cases in which authorization is not necessary).
c) Be informed by Alegra, upon request, regarding the use it has made of its personal data.
d) Submit complaints to the Superintendence of Industry and Commerce for infractions of the provisions of Law 1581 of 2012 and the other regulations that may modify, add to or complement it.
e) Revoke the authorization and/or request the deletion of data when the handling does not respect the principles, rights and constitutional and legal guarantees.
f) Free access to his/her personal data that has been processed.
XIII. Procedure for the Exercise of the Rights of the Account Holder of Data
The rights of the account holders may be exercised before THE COMPANY by the following individuals: a. By the data user, who must satisfactorily demonstrate their identity to THE COMPANY by the different means or mechanisms that we have at their disposal. b. For the successors in title of the account holder of the data, who must accredit such quality before THE COMPANY. c. By the representative and/or attorney of the Data Account Holder, after accreditation to THE COMPANY of the representation or empowerment. d. By stipulation in favor of another or for another person. In accordance with the provisions of the law, any of the rights that assist the Data Account Holder, allows him/her to make use before THE COMPANY any of the mechanisms established below:
1. Procedure for Queries: - The account holders, their successors in title, their representatives or attorneys-in-fact, may consult the personal information of the account holder that may be found in the COMPANY's databases. - THE COMPANY as Responsible and /or Processor for the handling will provide the requested information that is contained in the database or that is linked to the identification of the account holder. - The account holder will prove his/her condition by means of a copy of the pertinent document and his identity document that he will be able to provide physically or digitally, in case he/she is represented by a third party, the respective power of attorney must be provided, which must contain the corresponding content before a notary, the attorney must also demonstrate his/her identity in the terms indicated. - The consultation will be made through the channels that have been enabled by THE COMPANY for this purpose and especially through written or electronic communication, addressed to the dependency and person indicated in this Manual. - The consultation will be attended by THE COMPANY within a maximum term of ten (10) business days from the date of receipt of the same. - When it is not possible for THE COMPANY to attend the query within said term, it will inform the interested party, expressing the reasons for the delay and indicating the date on which the query will be answered, which in no case will exceed five (5) business days following the expiration of the first term.
Personal data may be consulted free of charge at least once every calendar month, and whenever there are substantial modifications to the Policies established in this Manual that motivate new consultations.
For queries whose frequency is greater than one for each calendar month, THE COMPANY may charge the account holder the costs of shipping, reproduction and, where appropriate, certification of documents.
2. Procedure for Claims: The account holders, their successors in title, their representatives or attorneys, who consider that the information that is contained in THE COMPANY's databases must be subject to correction, updating or deletion, or when they notice the alleged breach of any of the duties contained in the law, may file a claim with THE COMPANY as Processor and/or Responsible for Handling, which will be processed under the following rules: - The claim will be formulated by written request addressed to THE COMPANY, with the identification of the account holder, the description of the facts that gives rise to the claim, the address, and accompanying the documents that wish to be asserted. - A photocopy of the identification document of the Data Account Holder must be attached to the claim. - The claim will be made through the channels that have been authorized by THE COMPANY for this purpose and will be addressed to the agency and the person indicated in this Manual.
- If the claim is incomplete, THE COMPANY will require the interested party within five (5) business days after receipt of the claim to correct the failures. - After two (2) months from the date the request is made by THE COMPANY, without the applicant submitting the required information, THE COMPANY will understand that the claim has been withdrawn. - In the event that the person receiving the claim is not competent to resolve it, they will transfer it to the appropriate person within a maximum term of two (2) business days and will inform the interested party of the situation. - Once THE COMPANY receives the complete claim, it will include in the database a legend that indicates: "claim pending" and the reason for it, within a term not exceeding two (2) business days. Said legend must be kept until the claim is decided. - The maximum term to attend to the claim by THE COMPANY will be fifteen (15) business days from the day following the date of receipt. - When it is not possible for THE COMPANY to attend the claim within said term, the interested party will be informed of the reasons for the delay and the date on which their claim will be addressed, which in no case may exceed the following eight (8) business days after the expiration of the first term.
3. Enabled Channels: The rights of the account holders may be exercised by the aforementioned persons through the channels that have been enabled by THE COMPANY for this purpose, which are available to them free of charge, as follows: - Through the e- mail address: email@example.com
Through THE COMPANY's telephone number: 574-4480132 in the municipality of Medellín, or at the following address: Carrera 43 C N ° 5 - 115, Medellín - Antioquia.
XIV. Duties of Alegra as Processor and Responsible for the Processing of Personal Data
The following are the duties of Alegra, without damage to the provisions provided by law:
a) Guarantee the account holder, always, the full and effective exercise of the right of habeas data.
b) Request and keep a copy of the respective authorization granted by the account holder.
c) Properly inform the account holder regarding the purpose of the collection and the rights that assist him under the authorization granted.
d) Preserve the information under the necessary security conditions to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access.
e) Guarantee that the information is truthful, complete, exact, updated, verifiable and understandable.
f) Update the information, thus attending all information regarding data of the account holder.
g) Rectify the information when it is incorrect and communicate everything that is pertinent.
h) Respect the security and privacy conditions of the account holder´s information.
i) To process the queries and claims formulated in the terms indicated by law.
j) Identify when certain information is under discussion by the account holder.
k) Inform at the request of the account holder regarding the use given to their data.
l) Inform the data protection authority when there are violations of the security codes and there are risks in the administration of the information of the account holders.
m) Comply with the requirements and instructions issued by the Superintendence of Industry and Commerce on the specific matter.
n) Use only data whose treatment is previously authorized in accordance with the provisions of law 1581 of 2012.
o) Make use of the personal data of the owner only for those purposes for which it is duly empowered and, in any case, respecting the current regulations on the protection of personal data.
XV. Information Security Measures Applied to Database Processing
ALEGRA will adopt the technical, human and administrative measures that are necessary to grant security to the records, avoiding their adulteration, loss, consultation, use or unauthorized or fraudulent access. The personnel who carry out the processing of personal data will execute the established protocols in order to guarantee the security of the information.
For this purpose, it has security protocols and access to information, storage and processing systems, including physical security risk control measures. Vulnerability analysis are permanently made in order to monitor the system.
Access to the different databases is restricted even for employees and collaborators.
All employees have signed confidentiality clauses in their contracts and are committed to the proper manipulation of databases in accordance with the guidelines on the handling of information established in the Law.
The personal information provided by Alegra users is secured by an access key that only the User can access and that only he/she knows; the User is solely responsible for the handling of said password. Alegra does not have access to or knows the key, all user keys are encrypted. For greater security, Alegra recommends that the Users of our sites periodically change their login password.
It is the responsibility of the User to have all the security controls on their computers or private networks for their navigation to our sites.
Alegra has implemented all the security mechanisms in force in the market according to its products. In addition, it has deployed a series of documents and activities internally to guarantee the correct operation of technical security schemes, however, despite the due diligence adopted, Alegra is not liable for any consequence derived from the improper or fraudulent entry by third parties to the database and/ or due to any technical failure in the operation. These guidelines are applicable to mandatory compliance for web sites owned by Alegra, and those that are acquired or developed in the future.
The following prohibitions and sanctions are established because of non-compliance with regulations: Prohibitions
XVII. Responsible for the attention of requests, consultations and claims
The responsibility in the treatment of personal data in Alegra lies with all employees, within each area they must adopt the rules and procedures for the application and compliance with the standard, given their condition as custodians of the personal information that is contained in THE COMPANY's information systems.
Alegra has designated the Administrative area as responsible for compliance with this policy and will be attentive to solve requests, queries, and complaints and to carry out any update, rectification, deletion and revocation of authorization to handle personal data, through the channels provided for this purpose.
The Administrative Area will be responsible:
Name: Magda Patricia Rios Giraldo
Telephone: +574 4480132
Address: Carrera 43 C N° 5 - 115
Web Page: www.alegra.com
XVIII. International Transference and Transmission of Personal Data
SOLUCIONES ALEGRA S.A.S. may carry out transfer and transmission of personal data of the account holders. For the international transfer of personal data of account holders, Alegra will take the necessary measures so that third parties know and commit to observing this Policy, with the understanding that the personal information they receive can only be used for matters directly related to THE COMPANY and only while it lasts and cannot be used or destined for a different purpose. For the international transfer of personal data, the provisions of article 26 of Law 1581 of 201 will be observed.
With the acceptance of this policy, the Account Holder expressly authorizes the transfer and transmission of Personal Information. The information will be transferred and transmitted, for all the relationships that may be established with ALEGRA.
XIX. Effective Date
This Personal Data Policy was created on October 11, 2016 and is effective as of May 15, 2017. Any change that occurs with respect to this policy, will be reported through the electronic address: www.alegra.com
Date of last modification: May 25, 2018
JORGE ANDRES SOTO RAMIREZ
SOLUCIONES ALEGRA S.A.S.