COLOMBIA TECH WEEK S.A.S., identified with NIT. 901.800.432-1 (hereinafter, “CTW”), is a company that respects the personal data provided by its current and potential clients, employees, candidates, business partners, suppliers, sponsors, and potential attendees and those interested in CTW’s services. Therefore, CTW has implemented this Privacy Policy and Personal Data Processing (hereinafter, the “Policy”) to inform you about which Personal Data we process, why we process it, your rights as a Personal Data Holder, and the mechanisms you can use to exercise them.
The use of CTW’s platform and/or website, the execution of employment contracts, business partnerships, or service agreements, and/or your express and unequivocal acceptance of the terms and conditions and this Policy imply that you agree to the processing of your Personal Data in accordance with the provisions of this Policy.
How can you better understand this policy?
1. Definitions
To help you better understand this Policy, here’s what each term means throughout this document.
- Authorization:
- The prior, express, and informed consent you give us to process your Personal Data.
- Database:
- An organized set of Personal Data that is subject to Processing.
- Inquiry:
- A request you make as a Data Subject to know the information we have about you in our Databases.
- Anonymized Data:
- Data that does not personally identify you and may be used by CTW for statistical or aggregated analysis.
- Personal Data:
- Any information that can be used to identify you.
- Private Personal Data:
- Data that, due to its intimate or reserved nature, is only relevant to you as the Data Subject.
- Semi-private Personal Data:
- Data that is not intimate, reserved, or public, and whose knowledge or disclosure may be of interest not only to you (the Data Subject) but also to a certain sector or group of people or society in general. For example, financial, credit, commercial or service activity, and social security data.
- Public Data:
- Data classified as public by law and all data that is not semi-private, private, or sensitive.
- Sensitive Data:
- Data that affects your privacy or whose improper use may lead to discrimination, such as data revealing racial or ethnic origin, political orientation, religious or philosophical beliefs, union membership, as well as health, sexual life, and biometric data (e.g., fingerprints).
- Data Processor:
- A natural or legal person, public or private, who processes Personal Data based on the instructions provided by the Data Controller. CTW may contract certain people or companies to act as Data Processors for your Personal Data.
- Purpose:
- The objective for which CTW will process your Personal Data.
- Source:
- The person, entity, or organization that receives or knows Personal Data of Data Subjects by virtue of a commercial or any other type of relationship and supplies this data to an Information Operator, who then provides it to the Data Subject.
- Operator:
- The person, entity, or organization that receives Personal Data about various Data Subjects from the Source, manages it, and makes it available to the Data Subjects under the parameters of Law 1266 of 2008 and complementary regulations.
- Website:
- Refers to CTW's website through which the Services are promoted and sold.
- Platform:
- Refers to the CTW website or application through which the Services are provided.
- Claim:
- A request you make to exercise your rights related to your Personal Data.
- Data Controller:
- A natural or legal person, public or private, who decides on the Processing of Personal Data, determining the purpose. In this case, CTW is the Data Controller of your Personal Data.
- Procedural Requirement:
- The preliminary step you must take before filing a complaint with the Superintendence of Industry and Commerce. This involves a direct claim to the Data Processor or Controller of your Personal Data.
- Services:
- Refers to the services provided by CTW, which involve organizing various events and activities to promote innovation and entrepreneurship, positioning Colombia as a leader in the international entrepreneurial ecosystem, with the goal of generating connections, business opportunities, promoting collaboration, and knowledge exchange.
- Data Subject:
- You, the natural person whose Personal Data is being processed.
- Processing:
- Any operation performed on your Personal Data, such as collection, storage, processing, analysis, use, circulation, transfer, transmission, updating, correction, or deletion, among others. Processing may be national (within Colombia) or international (outside Colombia).
- Transmission:
- The delivery of Personal Data to a Data Processor to carry out Processing in accordance with the instructions provided by the Data Controller, within or outside the territory of the Republic of Colombia.
- Transfer:
- The delivery of Personal Data for another Data Controller to autonomously process the Personal Data, within or outside the territory of the Republic of Colombia.
2. Scope
This Policy applies to all Personal Data held by CTW, which acts as the Data Controller for Personal Data Processing.
3. Principles of Personal Data Processing
The Processing of Personal Data will be carried out in accordance with the principles set forth in Article 4 of Law 1581 of 2012 and Article 4 of Law 1266 of 2008, as well as any regulations that update or modify them. These principles are summarized below:
- Purpose:
- The Processing must have a legal purpose in accordance with the Constitution and the law, which we must inform you about.
- Necessity and Reasonableness:
- The Personal Data held by CTW must be necessary to fulfill the purposes of the Processing.
- Temporality:
- The period during which we process Personal Data must be only as long as necessary to achieve the purpose for which it was collected.
- Freedom:
- We may only process Personal Data with your prior, express, and informed consent. Personal Data cannot be obtained or disclosed without your prior authorization or a legal or judicial mandate.
- Truthfulness:
- The information subject to Processing must be true, complete, accurate, up-to-date, verifiable, and understandable. We will not process partial, incomplete, fragmented, or misleading data.
- Transparency:
- We must guarantee your right to obtain, at any time and without restrictions, information from CTW about the existence of your Personal Data in our Databases.
- Restricted Access and Circulation:
- Non-public Personal Data will only be processed by individuals who need to do so to fulfill the intended purpose.
- Security:
- The Data Controller and Processor must comply with all necessary technical, human, and administrative measures to ensure the security of Personal Data, preventing unauthorized or fraudulent modification, loss, consultation, use, or access.
- Confidentiality:
- All individuals involved in the Processing of Personal Data that is not public must maintain the confidentiality of the information.
- Non-Discrimination:
- We will not engage in any discriminatory acts based on the Personal Data collected.
- Reparation:
- We are obligated to compensate for any damages caused by potential failures in the Processing of Personal Data.
- Limitation in Collection:
- We will only collect the Personal Data necessary to fulfill the purposes of the Processing.
4. When Do We Collect Your Personal Data and What Personal Data Do We Collect?
Data Collection. CTW collects Personal Data from Data Subjects in the following cases:
- When Data Subjects purchase the Service through the Website or Platform.
- When Data Subjects register and share their data on the Website or Platform for the use, purchase of Services, or any other purpose.
- When a partner transfers the Personal Data of the Data Subjects to us.
- When Data Subjects voluntarily provide Personal Data, for example, by filling out CTW forms, whether physical or digital.
- When Data Subjects use CTW’s Services.
- When Data Subjects register to attend events organized by CTW as part of the Services.
- When Data Subjects are interested in joining the CTW team and send their resume or participate in a selection process.
- When you enter into any type of contract with CTW, such as employment, service provision, commercial alliance, partnership, sponsorship, service provider, supply, mandate, or any other type.
Information Collected. CTW may request or collect, except for exceptions related to sensitive data or data of children and adolescents, the data necessary to fulfill the intended purpose, including but not limited to the following:
Data We Collect from All Data Subjects
Name and surname, nationality, age, identification number, and a copy of the ID. Mailing address and city of residence, contact phone number, email address. Personal Data that CTW receives from third parties, including financial, commercial, and credit information from authorized data sources and social security information operators approved by the Ministry of Health and Social Protection (PILA information operators). Any other Personal Data necessary to achieve the purposes described in this Policy.
Data We Collect from Employees, Former Employees, and Job Applicants
Marital status, professional license, employment, clinical, health, academic, and financial history. Work and personal references, occupational medical history, workplace, position or profession. Resume, certification of affiliations to EPS (healthcare provider), pension fund, and severance funds. Bank account details including the financial entity, emergency contact information (including name and relationship). Family data such as name, age, and number of children and adolescents under first-degree consanguinity. Employment information of your spouse or permanent partner and relatives, photographic records.
Data We Collect from Our Partners, Sponsors, and Suppliers
Company name or business name, position within the company, economic sector in which the company operates. Tax identification number, copies of unique tax registration (RUT). Legal representative's information, including full name, ID number, email, and phone contact. References, commercial background, bank account details, banking references, websites. Information of their employees or collaborators who interact with CTW.
Data We Collect from Our Clients and Service Users
Tax identification number (NIT), company name, logos, position within the company. The economic sector of the company where you work or perform professionally, address of company offices. Commercial contact information, legal representative data, commercial activity. Investment status of the company (e.g., pre-seed, seed, Series A, B, C rounds, etc.). Financial data of the company where you work or perform your professional duties, such as financial statements, cash flow status, profit, EBITDA, and any other financial data necessary to assess the financial and equity status of the company you represent or work for. Browsing history on the Platform.
Sensitive Data and Its Processing
Considering the characteristics of our Service, CTW does not require the Processing of Sensitive Data. However, CTW will only collect and process Sensitive Data in legally permitted cases. In such cases, you will be informed that you are not obligated to provide Sensitive Data or authorize its Processing. If you choose not to authorize the Processing of your Sensitive Data, CTW may not be able to continue with the identity validation process, making it impossible to continue providing the Services.
Image Data
By participating in any video conference or event sponsored or organized by CTW, you agree and authorize that your name and images may appear in programs, events, publications, and other advertising media, and generally in all promotional or commercial dissemination materials that CTW wishes to produce for a period of 50 years, without any obligation to compensate you for your participation. By accepting this Policy, you waive any claim against CTW for image rights.
5. Why Do We Collect Your Personal Data?
CTW will process Personal Data in accordance with the conditions established by the Data Subject for the development of its economic activity. Generally, CTW will collect, store, organize, circulate, use, transmit, and transfer Personal Data in accordance with the purposes outlined below:
Purposes Common to All Data Subjects
Fulfill CTW's corporate purpose; manage the labor, civil, or commercial relationship with the Data Subjects; comply with legal, accounting, commercial, and regulatory obligations; access, collect, and process Personal Data received from third parties, including financial, commercial, and credit information from authorized data centers and PILA Information Operators; control and safeguard the security of people, assets, and information of CTW; execute the purpose of the labor, commercial, or civil relationship; manage the CTW Website and Platform; store Personal Data on CTW's servers; disclose information when necessary to comply with laws, regulations, or legal processes, prevent fraud, security attacks, technical issues, or to protect the rights of others; verify references in databases; check national and international restrictive lists (National Police, Comptroller's Office, Interpol, FBI, OFAC); comply with anti-money laundering and counter-terrorism financing regulations; maintain direct communication with Data Subjects; perform statistical, commercial, financial, social, administrative, or technical analyses; share information with governmental authorities or regulatory entities; verify identity, criminal, disciplinary, financial, and credit backgrounds; transmit, transfer, and provide Personal Data to the parent company and other companies within CTW's corporate group; contact the Data Subject through the internet, phone calls, physical correspondence, SMS, WhatsApp, Instagram, Facebook, Twitter, LinkedIn, Telegram, Messenger, or any other social network and/or videoconferencing platform; transmit, transfer, and provide Personal Data to business partners or other national and/or international companies; conduct marketing activities such as market research, service promotions, satisfaction surveys; address inquiries, requests, actions, and claims; and use the data as evidence in any type of legal process and send invitations to events.
Employees, Former Employees, and Applicants
Protect the health of CTW workers and contractors; verify conflicts of interest, disqualifications or incompatibilities; select personnel, manage hiring processes, handle labor and social relations, and provide benefits to employees directly or through third parties; grant employees access to CTW's IT resources; maintain a record of disciplinary sanctions; contribute to the general social security system; transmit, transfer, and provide the Data Subjects' information for the purpose of providing labor and/or professional references; evaluate and develop selection processes.
Suppliers, Sponsors, and Partners
Generate reports to credit and commercial information operators' databases; provide commercial references; manage the payment of remunerations, commissions, discounts, and tax or parafiscal withholdings; send invoices; issue contractual or commercial certificates; manage the organization and development of events within the framework of the Services.
Clients and Users
Fulfill the value proposition and the Service offered to each client and user; transmit, transfer, and provide, free of charge or for a fee, the Data Subjects' information to national and/or international business partners; improve services and carry out all activities associated with the existing or future commercial relationship; assess the need for new services and products; contact the Data Subject through WhatsApp, email, and/or any other contact method to send payment requests, invoices or event information; execute commercial profiling actions, prospecting, analytics, identifying marketing trends, defining patterns, with or without the use of artificial intelligence tools; define customer consumption profiles; conduct marketing and advertising studies and strategies; carry out marketing tasks and send advertisements; send news or articles; conduct satisfaction surveys; provide information about the scope and features of CTW Services and new events.
Transmission and Transfer of Personal Data
CTW may transfer or transmit Personal Data to one or more Processors or Controllers located within or outside the territory of the Republic of Colombia when you authorize us to do so, or when required by law or an administrative or judicial mandate. By accepting this Policy, you authorize us to transfer or transmit your Personal Data to our partners, suppliers, parent company (if applicable), or cloud service providers solely for the purposes established in this Policy. If CTW transmits your data to third parties, they will process your Personal Data in accordance with this Policy. However, if we transfer your Personal Data, your data will be processed in accordance with the data protection policy of the new Controller.
6. Authorization for Sensitive Data and New Purposes
When CTW collects Sensitive Data or data of minors, your Authorization must be explicit; we will inform you that you are not obligated to authorize the Processing of such information. For new uses, we will publish changes to the Policy on our Platform and notify you of the change. If you do not agree with the new Purposes, you may revoke the Authorization, and we will delete your Personal Data if we do not have any legal obligation to retain it. CTW will only process your Personal Data related to criminal records solely and exclusively to ensure the legality of its operations, the security of CTW and its stakeholders, and to prevent fraud, money laundering, and terrorism financing activities.
7. What Are Cookies and What Do We Use Them For?
A cookie is a harmless file that is downloaded to your device when you access certain web pages. CTW uses both its own and third-party cookies to store and retrieve information about a user's browsing habits and trends, personalize content, and analyze navigation. We will not collect debit or credit card numbers or any other financial or credit information. You can refuse the use of cookies through the appropriate settings in your browser; however, please note that if you do, the Platform may not function properly.
8. Declarations of Personal Data Holders
By voluntarily providing your Personal Data and/or granting written authorization and/or clicking “I authorize the processing of my Personal Data,” you declare that: you do so voluntarily; you have been informed and understand that Sensitive Data includes information that affects the Holder's privacy and your right not to provide it; you have been informed of the purposes; you accept the security measures implemented by CTW; you have been informed about your rights and the mechanisms to exercise them; and, if you are a client, you acknowledge your contractual relationship with CTW.
9. How long will we process your data?
We will process your Personal Data from the moment you grant us Authorization until the day CTW is dissolved and liquidated or until the purpose for which the Personal Data was collected is fulfilled. Once the purpose is fulfilled, the Personal Data will be stored in the Databases as historical information of the Data Subjects.
10. How do we protect your Personal Data?
CTW diligently implements human, administrative, and technical protection measures that are reasonably within its reach, such as having an access management system and sharing information in an encrypted manner, to prevent alteration, loss, unauthorized use, and access. The data of CTW's Clients and Data Subjects will be stored by CTW's providers in any country where they have branches or service providers.
Deletion or suppression. Once the purpose of processing is fulfilled, or when the Data Subject directly requests CTW to do so, and as long as there is no contractual or legal obligation that prevents it, CTW will proceed to delete the Personal Data. To submit a request, send an email to hello@colombiatechweek.co. CTW will annually evaluate the information it holds and may decide to delete data, notifying Data Subjects in advance, who will have fifteen (15) business days to submit queries or claims.
Confidentiality and anonymization. CTW respects the fundamental rights to privacy, freedom of expression, good name, and honor. It will refrain from disclosing confidential information without authorization; instruct those who may access it on its proper handling; and anonymize Personal Data when there is a risk to privacy.
Accuracy and quality. CTW will request the necessary and integral information, refrain from processing partial or incomplete data, and verify the identity of Data Subjects through documents such as ID card, RUT (Unique Tax Registry), criminal and police records, credit history, and certifications from private and/or public entities.
11. Rights of Data Subjects and how to exercise them
You have the right to:
- Know, update and rectify your Personal Data.
- Request proof of the Authorization granted, unless it is a case where authorization is not required under Article 10 of Law 1581 of 2012.
- Be informed, upon request, about how your Personal Data has been used.
- Submit complaints to the Superintendence of Industry and Commerce regarding violations of the law.
- Revoke the authorization and/or request the deletion of your Personal Data.
- Access your Personal Data that has been processed, free of charge.
- Refrain from answering questions about Sensitive Data or data of children and adolescents.
The request for the deletion of information and the revocation of the Authorization will not proceed if you have a legal or contractual obligation to remain in CTW's Database. Direct marketing communications will include simple means to stop receiving them.
Procedure. Send an email to hello@colombiatechweek.co addressed to COLOMBIA TECH WEEK S.A.S. specifying: (i) the name and identification of the Data Subject or authorized person; (ii) a precise and complete description of the facts; (iii) requests or claims; (iv) a physical or electronic address to send the response; and (v) relevant documents.
Inquiries will be resolved within a maximum of ten (10) days, extendable by five (5) business days. Claims will be resolved within a maximum of fifteen (15) business days, extendable by eight (8) business days. If the claim is incomplete, CTW may request the Data Subject to complete it within five (5) days; if two (2) months pass without a response, the claim will be considered withdrawn. Before filing a complaint with the Superintendence of Industry and Commerce, you must first complete the direct procedure with CTW.
12. CTW's Duties
- Ensure the full and effective exercise of your rights.
- Process your Personal Data in accordance with the principles of this Policy.
- Maintain the information under appropriate security conditions.
- Update and rectify the information when appropriate.
- Provide the Data Processor only with data for which processing is authorized.
- Ensure the truthfulness, completeness and understandability of the information.
- Communicate updates and corrections to the Data Processor.
- Require the Data Processor to respect security and privacy conditions.
- Inform the Data Processor when certain information is in dispute.
- Notify the Superintendence of Industry and Commerce of security code violations.
- Comply with the instructions and requirements of the Superintendence.
13. Other information you need to know
Contact information: Any questions or additional requests will be received and processed through hello@colombiatechweek.co.
Changes: Any substantial changes to this Policy will be communicated to you promptly by publishing the new version on our Platform, and we will request your authorization through the same channel.
Last Update: This Policy was last updated on May 29, 2024.