Privacy Policy

Personal Data Protection Policy

This Policy was last updated on May 7, 2018.

Your privacy is very important to MASSY MOTORS RENTALS S.A.S.

For this reason, we have prepared an Information Treatment Policy (the "Policy") that informs you how we treat your personal information.

Thank you for reviewing our personal data protection practices.

Presentation.

MASSY MOTORS RENTALS SAS (“MMR”), a company domiciled at Av.3 Norte No. 34-46, telephone (2) 485 3999, is respectful of the personal data and information provided by its current, past and potential clients, their employees and suppliers interested and/or related to the services offered (the Owners). This Information Treatment Policy (the "Policy") establishes the purposes, measures and procedures of our databases, as well as the mechanisms that the Holders have to know, update, rectify, delete the data provided or revoke the authorization that is granted together with the knowledge of this Policy. This text has been created by MASSY MOTORS RENTALS SAS as part of the processes adopted to comply with current legislation on data protection, especially Law 1581 of 2012 (and other regulations that modify, add, complement or develop), to Decree 1377 of 2013, Sole Regulatory Decree 1074 of 2015, among others applicable and related.

In this Policy you will find the corporate and legal guidelines under which MASSY MOTORS RENTALS S.A.S processes your data, the purpose, your rights as Holder, as well as the internal and external procedures for the exercise of such rights.

Definitions.

The expressions used in initial capital letters in this Policy will have the meaning given to them here, or the meaning that the applicable law or jurisprudence gives them, as said law or jurisprudence is modified from time to time.

“Authorization”: It is the prior, express and informed consent of the Owner to carry out the Processing of their Personal Data.

“Database”: It is the organized set of Personal Data that are subject to Treatment, electronic or not, whatever the modality of its formation, storage, organization and access.

“Personal Data”: It is any information of any kind, linked or that can be associated with one or several determined or determinable natural or legal persons.

“Public Data”: It is the Personal Data qualified as such according to the mandates of the law or the Political Constitution and that which is not semi-private, private or sensitive. Data relating to the Civil Registry of persons, their profession or trade, their status as a merchant or public servant and those that can be obtained without reservation are public, among others. Due to its nature, public data may be contained, among others, in public records, public documents, official gazettes and bulletins, duly enforced judicial decisions that are not subject to reservation.

“Sensitive Data”: It is the Personal Data that affects the intimacy of the Holder or whose improper use may generate discrimination, such as those that reveal union affiliations, racial or ethnic origin, political orientation, religious, moral or philosophical convictions, membership in trade unions, social or human rights organizations or that promote the interests of any political party or that guarantee the rights and guarantees of opposition political parties, as well as data related to health, sexual life, and biometric data.

“Data Processor”: It is the natural or legal person, public or private, that by itself or in association with others, performs the Processing of Personal Data on behalf of the Data Controller.

"Authorized": It is the Company and all the people under the responsibility of the Company, who by virtue of the Authorization and these Policies have legitimacy to Process the Personal Data of the Holder. The Authorized includes the gender of the Authorized.

"Authorization": It is the legitimacy that expressly and in writing through a contract or document that takes its place, grants MMR to third parties, in compliance with the applicable Law, for the Processing of Personal Data, turning such third parties into Persons in Charge of the Treatment of the Personal Data. Personal Data delivered or made available.

“Responsible for Treatment”: It is the natural or legal person, public or private, that by itself or in association with others, decides on the Database and/or the Treatment of Personal Data.

“Holder” of the Personal Data: It is the natural or legal person to whom the information that rests in a Database refers, and who is the subject of the right of habeas data.

“Transmission”: It is the Processing of Personal Data that implies the communication of the same inside or outside the territory of the Republic of Colombia when its purpose is to carry out a Treatment by the Manager on behalf of the person in charge.

“Transfer”: The transfer of data takes place when the Responsible and/or Responsible for the Processing of personal data, located in Colombia, sends the information or personal data to a receiver, who in turn is Responsible for the Treatment and is within or out of the country.

“Personal Data Treatment”: It is any operation and systematic procedure, electronic or not, that allows the collection, conservation, ordering, storage, modification, relationship, use, circulation, evaluation, blocking, destruction and in general, the processing of Data. Personal, as well as their transfer to third parties through communications, consultations, interconnections, assignments or data messages.

For the understanding of the terms that are not included in the previous list, you must refer to the current legislation, especially Law 1581 of 2012, Decree 1377 of 2013, and Single Regulatory Decree 1074 of 2015, giving the meaning used in said norm to the terms of whose definition there is any doubt.

Responsible for the Treatment of the Information

The data controller is MASSY MOTORS RENTALS SAS, a commercial company, identified with NIT 901252875-7, located in Santiago de Cali – Valle at Av.3 Norte No. 34-46 and telephone (2) 485 3999. The The processing of personal data is carried out legitimately within the applicable legal parameters and without carrying out any activity that may affect the rights of the Owners or the quality of the personal data.

Porpuse and Treatment of Personal Data

Personal Information includes any information relating to the personal or material circumstances of an identified or identifiable individual directly or indirectly. The Personal Information collected by MMR includes, without limitation: names, surnames, gender, age, email account, landline and/or cell phone number, address, city and department.

MASSY MOTORS RENTALS S.A.S also collects information that by itself does not allow to identify or directly associate a specific individual. Some examples of this information are: occupation, stratum of place of residence, hobbies, among other data that allow the company to better understand the behavior of its customers so that it can improve its products, services and marketing and advertising campaigns.

MASSY MOTORS RENTALS S.A.S proceeds with the collection and processing of certain Personal Data to fulfill purposes related to the corporate purpose and business of the Company. The Personal Data collected are those strictly necessary to fulfill said purposes, which are.

Employees.

MASSY MOTORS RENTALS SAS proceeds with the processing of personal data of its employees for purposes related to the development of its corporate purpose, the execution of the contract, payment of contractual obligations, inclusion of information in the databases of the person in charge, reporting to authorities, monitoring employee performance, compliance with labor obligations, in greater detail the purposes of the treatment correspond to:

• Personnel management, payment of contractual obligations and execution of the employment contract.

• Report to judicial and/or administrative authorities in accordance with given requirements.

• Support in external/internal audit processes.

• Registration of employee information in the company database for circulation purposes in the facilities and use of technological tools.

• For security purposes or fraud prevention and/or anti-corruption practices.
Delivery and authorization of the processing of your personal data to third parties in charge, in accordance with the provisions of the applicable law, when necessary for the continuity of the business or use of technological tools that are in favor of the efficiency, processes, costs, interconnectivity of areas of the company, among others. The Manager will offer adequate protection measures and may or may not be domiciled in Colombia according to the nature of the service.

• Transfer of Personal Data inside and outside Colombia to maintain the continuity of the business and corporate purpose of MASSY MOTORS RENTALS S.A.S, as well as in the event of a merger, consolidation, sale of shares, acquisition, divestment or other restructuring process.

• Any other purpose that results in the development of the contract or the relationship between the employee and MASSY MOTORS RENTALS S.A.S.

• Any other purpose in accordance with the authorization that the employee has granted in favor of the Company.

• Conduct audits, data analysis, and research to improve products, services, and communications with customers, employees, suppliers, shareholders, and other stakeholders.

• All of the above is related to the fulfillment of obligations in charge of MASSY MOTORS RENTALS S.A.S as an employer in favor of the well-being, continuity of the employee and correct execution of the employment relationship. It is also related to the development of the corporate purpose of the company.

Suppliers and Customer.

MASSY MOTORS RENTALS SAS proceeds with the processing of personal data of its suppliers and customers for purposes related to the development of its corporate purpose, the execution of the contract, payment of contractual obligations, inclusion of information in the Responsible's databases, reporting to authorities , obtaining a record of those who provide services and sell products for tax payments and processes. In greater detail, the purposes of the treatment correspond to:

• Management of collections and payments, billing and compliance with the contract signed with MASSY MOTORS RENTALS S.A.S.

• Sending information to government or judicial entities at the express request of the same.

• Support in external/internal audit processes.

• Sending/Receiving messages for commercial, advertising and/or customer service purposes as long as it is intrinsically related to the existing business relationship.

• Registration of customer and supplier information in the MASSY MOTORS RENTALS S.A.S database, as appropriate.

• Contact for sending information related to the contractual, commercial and mandatory relationship that takes place.

• For security purposes or fraud prevention and/or anti-corruption practices.

• Delivery and authorization of the processing of your personal data to third parties in charge, in accordance with the provisions of the applicable law, when necessary for the continuity of the business or use of technological tools that are in favor of the efficiency, processes, costs, interconnectivity of areas of the company, among others. The Manager will offer adequate protection measures and may or may not be domiciled in Colombia according to the nature of the service.

• Transfer of Personal Data inside and outside Colombia to maintain the continuity of the business and corporate purpose of MASSY MOTORS RENTALS S.A.S, as well as in the event of a merger, consolidation, sale of shares, acquisition, divestment or other restructuring process.

• Any other purpose that results in the development of the contract or the relationship between the supplier/client and MASSY MOTORS RENTALS S.A.S.

• Any other purpose in accordance with the authorization that the supplier/client has granted in favor of the Company.

• Send important notifications such as the lists of vehicles that present novelties or faults, or communications about changes in our terms, conditions and information treatment policies

• Create, develop, operate, deliver, and improve our products, services, content, and advertising

• Carry out the control and prevention of fraud and money laundering, including, but not limited to, consultation on restrictive lists, and all the necessary information required for the SARLAFT.

• In the event of a merger, acquisition or sale of MMR, we may transfer some or all of the personal information that we have in our databases to the relevant third party in any of the aforementioned transactions.

• Maintain and process by computer or other means known or to be known, any type of information received from the client in order to provide the relevant services and products.

• Monitor through video surveillance systems, for purposes related to security, the activities carried out at the points of sale that are owned or managed by the company.

• Monitor and use the images that are captured through video surveillance systems in order to control and supervise the development and performance of work activities in the space or workplace of the company's employees.

We also inform you that, in your capacity as supplier and/or client, your personal data is only collected for the identification of your position, trade, profession or merchant quality, for which they respond to being of a public nature, not being required. your prior, express and informed consent. In any case, even if it is of a public nature, you have the right to be informed of the purpose of the treatment and are empowered to exercise the rights that protect you as the owner of personal data.

If you provide us with Personal Data, whether as an employee, supplier and/or client, this information will be used only for the purposes indicated here, and we will not proceed to sell, license, transmit or disclose it outside of MASSY MOTORS RENTALS S.A.S. unless (i) you expressly authorize us to do so, (ii) it is necessary to allow our contractors or agents to perform the services we have entrusted to them, (iii) in order to provide you with our products or services, (iv) is disclosed to entities that provide marketing services on our behalf or to other entities with whom we have joint marketing agreements, or (v) as required or permitted by law.

In cases where subcontracting with third parties is necessary for the processing of your personal information or we provide your personal information to third party service providers, we warn said third parties about the need to protect said personal information with appropriate security measures, we prohibit the use of your personal information for their own purposes and we prevent them from disclosing your personal information to others.

When there is authorization for this purpose, MASSY MOTORS RENTALS S.A.S. will send the financial and credit information to Information Operators and/or Commercial Information Agencies, in accordance with Law 1266 of 2008.

MASSY MOTORS RENTALS S.A.S. will send the information to the governmental or judicial authorities that rests in its databases, when there is an administrative act or a judicial order that so provides.

Principles for the Processing of Personal Data.

MASSY MOTORS RENTALS S.A.S., in compliance with the provisions of Law 1581 of 2012, applies the principles of legality, purpose, freedom, truthfulness, transparency, access and restricted circulation, security and confidentiality.

Authorization for the Processing of Personal Data.

Prior to the collection of any non-sensitive personal data, MASSY MOTORS RENTALS S.A.S. will have the personal data processing authorization referred to in article 9 of Law 1581 of 2012, and article 7 of Decree 1377 of 2013. The aforementioned authorization can be obtained in writing or by electronic means, where the Holder of the information authorizes MASSY MOTORS RENTALS SAS to treat your personal data in accordance with the provisions of this document.

Notwithstanding the foregoing, MASSY MOTORS RENTALS S.A.S. It will also collect and process the personal data that is required for the fulfillment of its legal and judicial obligations, in accordance with article 10 of Law 1581 of 2012.

Conservation of the Information.

The information contained in electronic and physical files will be located only on corporate computers for personal and exclusive use by persons authorized to process personal data within the organization.

Rights of the Information Holder.

In accordance with article 8 of Law 1581 of 2012, the rights of the Holder of the information subject to treatment of MASSY MOTORS RENTALS S.A.S. are the following:

• Know, update and rectify your personal data against MASSY MOTORS RENTALS S.A.S. This right may be exercised, among others, against partial, inaccurate, incomplete, fragmented, misleading data, or those whose Treatment is expressly prohibited or has not been authorized;

• Request proof of authorization granted MASSY MOTORS RENTALS S.A.S. except when expressly excepted as a requirement for Treatment, in accordance with the provisions of article 10 of Law 1581 of 2012.

• Be informed by MASSY MOTORS RENTALS S.A.S., upon request, regarding the use that has been given to your personal data.

• Submit complaints to the Superintendence of Industry and Commerce for violations of the provisions of Law 1581 of 2012, Decree 1377 of 2013 and the other regulations that modify, add or complement it.

• Revoke the authorization and/or request the deletion of the data when the principles, rights and constitutional and legal guarantees are not respected in the Treatment. The revocation and/or deletion will proceed when the Superintendency of Industry and Commerce has determined that in the Treatment the Responsible or Person in Charge has incurred in conduct contrary to Decree 1377 of 2013, Law 1581 of 2012 and the Political Constitution.

• Free access to your personal data that has been processed, in accordance with the provisions of paragraph c of numeral 2 of article 12 of this document.

Procedure for the Exercise of your Rights as the Holder.

If you have questions about this Policy, or any concerns or complaints regarding the administration of the Policy, please contact us through any of the following means:

MASSY MOTORS RENTALS S.A.S
Av.3 North No. 34-46
Telephone (2) 485 3999 – 485 2727

In the case of exercise of complaint, rectification, update, query, or request for access or theft of data, you must send it to the Personal Data Protection Officer to the following email account: customer.service@alamo.co

Your request or request in relation to your personal data must be attended to within a maximum term of five (5) business days from the receipt of the request or request. For the correct and complete consideration of your request, request or claim, we ask you to provide the identity of the applicant, your identification number, the address of notifications/responses and the documents you want to assert.

If your request or request does not have sufficient data and facts that allow MASSY MOTORS RENTALS SAS to attend it correctly and completely, you will be required within five (5) days following receipt of the request, request or claim so that fix its flaws. After five (5) days have elapsed from the date of the request, if you as the applicant have not rectified as required, the company as the recipient of your request understands that you have withdrawn your request.

Modification of the Policy.

This policy may be modified at any time, which is why we recommend that you review it regularly or periodically through the contact details of MASSY MOTORS RENTALS SAS, and the latest version of this Policy or the mechanisms to obtain a copy of it will be made available to you same.

This Policy will come into force as of March 1, 2019, for which it will be made known to the holders of the information through the institutional email and website of MASSY MOTORS RENTALS SAS: https://www. alamo.co/

Contact Us

If you have any questions about these Terms of Use, please contact us at customer.service@alamo.co