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PRINCIPLE OF CONFIDENTIALITY

BONSOL HOTELS GESTIÓN COLOMBIA SAS is obliged to guarantee the reservation of information, even after the end of its relationship with any of the tasks that comprise the treatment, being able to only supply or communicate personal data when this corresponds to the development of authorized activities in the law.

RIGHTS OF THE DATA HOLDER

The owner of the personal data will have the following rights:

Know, update and rectify your personal data in front of BONSOL HOTELS GESTIÓN COLOMBIA SAS in its capacity as data controller. This right may be exercised, among others, against partial, inaccurate, incomplete, fractioned, misleading data, or those whose treatment is expressly prohibited or has not been authorized.
Request proof of the authorization granted to BONSOL HOTELS GESTIÓN COLOMBIA SAS except when expressly excepted as a requirement for treatment (cases in which authorization is not necessary).
Be informed by BONSOL HOTELS GESTIÓN COLOMBIA SAS, upon request, regarding the use that has been given to your personal data.
Present before the Superintendency of Industry and Commerce complaints for infractions to the provisions of Law 1581 of 2012 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.
Free access to your personal data that has been processed.


DUTIES BONSOL HOTELS GESTIÓN COLOMBIA SAS

By virtue of this personal data treatment and protection policy, the following are the duties of BONSOL HOTELS GESTIÓN COLOMBIA SAS:

Guarantee the holder, at all times, the full and effective exercise of the right to habeas data.
Request and keep a copy of the respective authorization granted by the owner.
Properly inform the owner about the purpose of the collection and the rights that assist him by virtue of the authorization granted.
Keep the information under the necessary security conditions to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access.
Rectify the information when it is incorrect and communicate the pertinent.
Process inquiries and claims made by the owners.
Inform the data protection authority when there are violations of the security codes and there are risks in the management of the information of the holders.
Comply with the requirements and instructions issued by the Superintendence of Industry and Commerce on the particular subject.
Inform at the request of the owner about the use given to their data.
Guarantee that the information is truthful, complete, accurate, updated, verifiable and understandable.
To update the information, thus attending all the novelties regarding the holder's data. Additionally, all necessary measures must be implemented to keep the information updated.
Respect the security and privacy conditions of the holder's information.
Identify when certain information is under discussion by the owner.
Use only data whose processing is previously authorized in accordance with the provisions of Law 1581 of 2012.

THIS MANUAL WILL NOT APPLY TO

To data for exclusively personal or domestic use.
To data whose purpose is national security and defense, as well as the prevention, detection, monitoring and control of money laundering and the financing of terrorism.
To data containing intelligence and counterintelligence information from the State.
To the databases and files regulated by Statutory Law 1266 of 2008.
To the databases and files regulated by Law 79 of 1993.
Data related to the Civil Registry of people.

LEGITIMATION FOR THE EXERCISE OF THE HOLDER'S RIGHT

The rights of the holders may be exercised by the following persons:

By the owner, who must sufficiently prove his identity by the different means made available to him by BONSOL HOTELS GESTIÓN COLOMBIA SAS.
By the titleholder's successors (in cases where he is absent due to death or disability), who must prove such quality.
By the representative and / or attorney-in-fact of the owner, prior accreditation of the corresponding representation or power of attorney.
By stipulation in favor of another or for another.
The rights of children and adolescents shall be exercised by the persons empowered to represent them.

PROCESSING AND PURPOSE OF THE DATA.

The information collected is used to process, confirm, fulfill and provide the services and/or products purchased, directly and/or with the participation of third party product or service providers, as well as to promote and advertise our activities, products and services, carry out transactions, make reports to the various national or international administrative control and surveillance authorities, police authorities or judicial authorities, banking entities and/or insurance companies, for internal administrative and/or commercial purposes such as, market research, audits, accounting reports, statistical analysis, billing, and offering and/or recognition of benefits of our loyalty programs.

By accepting this PERSONAL DATA PROTECTION TREATMENT POLICY, our guests, visitors, clients, customers, users and suppliers
guests, visitors, customers, clients, users and suppliers in their capacity as owners of the data collected, authorize BONSOL HOTELS GESTIÓN COLOMBIA SAS to process them, partially or totally, including the collection, storage, recording, use, circulation, processing, suppression, for the execution of activities related to the services and products purchased, such as, making reservations, modifications, cancellations and changes, reimbursements, consultations, complaints and claims, payment of compensation and compensations, registrations, compensation and compensations, registrations, cancellations and changes, reimbursements, attention to queries, complaints and claims, payment of compensations and compensations, registrations, compensations, registrations and reimbursements, cancellations and changes thereof, refunds, attention to inquiries, complaints and claims, payment of compensation and indemnities, accounting records, correspondence, processing and verification of credit cards, debit cards and other payment instruments, identification of fraud and prevention of money laundering and other criminal activities and/or for the operation of loyalty programs and other purposes indicated in this document.

The above, without prejudice to other purposes that have been informed in this document and in the terms and conditions of each of the products and services of each of our business units.

We warn that third party suppliers may be involved in these activities, such as suppliers of booking systems, travel agencies, call centers, banking entities, insurance companies, etc.

Additionally, our travelers, customers and users, as owners of the data collected, by accepting this privacy policy, authorize us to:

Use the information received from them, for marketing purposes of their products and services, and products and services of third parties with which BONSOL HOTELS GESTIÓN COLOMBIA SAS maintain a business relationship.
Provide personal data to the police or judicial control and surveillance authorities, under a legal or regulatory requirement and / or use or disclose this information and personal data in defense of their rights and / or their assets insofar as such defense is related to the products and / or services contracted by its travelers, customers and users.
Allow access to information and personal data to auditors or third parties contracted to carry out internal or external auditing processes inherent to the commercial activity that we develop.
Consult and update personal data, at any time, in order to keep such information up to date.
To contract with third parties for the storage and/or processing of information and personal data for the proper execution of contracts entered into with us, under the security and confidentiality standards to which we are bound.

DATA OF GIRLS, BOYS AND ADOLESCENTS

Duties regarding the Treatment of data of Infants and Adolescents.

BONSOL HOTELS GESTIÓN COLOMBIA SAS, in its capacity as Responsible and in Charge of Processing the personal data of the aforementioned groups, must take special care to ensure compliance with the Law regarding these groups and respect for their rights in the event that they arrive. to have personnel in charge corresponding to the aforementioned groups, especially regarding personal data that do not fit into the category of public data (name, sex, date of birth, etc.).

The processing of personal data of children and adolescents is prohibited except in the case of data of a public nature, and when such processing meets the following parameters and / or requirements:
that respond to and respect the best interests of children and adolescents.
that respect for their fundamental rights is ensured.
that there is authorization from the father or guardian of the child or adolescent.

TO WHOM THE INFORMATION MAY BE PROVIDED

The information that meets the conditions established by law may be provided to the following people:

To the owners, their successors in title (when those are missing) or their legal representatives.
To public or administrative entities in the exercise of their legal functions or by court order.
To third parties authorized by the owner or by law.

made up of the list of all the information that is linked to the identification of the owner in the database. The query will be answered within a maximum term of fifteen (15) business days, counted from the day following the date of receipt. When it is not possible to attend the query within said term, the interested party will be informed, stating the reasons for the delay and indicating the date on which the query will be attended, which in no case may exceed eight (8) business days following the expiration of the first term. The consultation will be attended in writing and will not generate cost for the owner.

PROCEDURE FOR DELETING, CORRECTING AND UPDATING DATA

The owners may at any time request BONSOL HOTELS GESTIÓN COLOMBIA SAS to delete, correct or update their personal data and / or revoke the authorization granted for the treatment thereof, by submitting a claim as follows:
The claim will be formulated by means of communication addressed to the email: ma.vich@themorganagroup.com with the identification of the owner, the description of the facts that give rise to the request, the address and accompanied by the documents that support the request to be applicable .

If the claim is incomplete, BONSOL HOTELS GESTIÓN COLOMBIA SAS will require the holder within five (5) business days following receipt of the request to correct the faults. After two (2) months from the date of the requirement, without the holder submitting the required information, it will be understood that the claim has been withdrawn.

Once the complete claim has been received, a legend will be included in the database stating "claim in process" and the reason for the claim, an activity that must be carried out within a term not exceeding two (2) business days. Such legend shall be maintained until the claim is decided.

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

DATA PROCESSING TIME

The information provided by customers and users will remain stored for up to fifteen (15) years from the date of the last treatment, to allow us to comply with the legal and / or contractual obligations under your charge, especially in accounting matters, fiscal and tributary.


MODIFICATIONS TO THE TRUTH POLICIES

BONSOL HOTELS GESTIÓN COLOMBIA SAS reserves the right to make changes or updates to this Privacy Policy at any time, to attend to new legislation, internal policies or new requirements for the provision or offering of its services or products.

Registration of the Bases.

BONSOL HOTELS GESTIÓN COLOMBIA SAS in its capacity as Responsible and in Charge of Treatment must proceed to the registration of the bases in the terms indicated by the Colombian regulations.

Acceptance.

The holders of the information accept the processing of their personal data in accordance with the terms of this Manual, at the time of providing their data.

Validity:

This General Privacy Policy is effective from the date of its publication.