Our Privacy Policy has been elaborated with the purpose of accepting under the parameters of self-regulation a treatment of personal data that respects all the rights and guarantees in terms of privacy of the holders on whom we treat personal data. It was the Constitution of Colombia which in its Article 15 has erected as a constitutional right to the protection of your personal data; likewise through Law 1581 of 2012 and regulatory decrees 1377 of 2013 and 886 of 2014 – today contained in Chapters 25 and 26 of the single Decree 1074 of 2015, of the Commerce, Industry and Tourism sector, the general framework of data protection in Colombia was developed.

This policy applies to all personal information registered in the databases of Cantina La 15 SAS who acts as the party responsible for the processing of personal data.

Data processing:

Below, we present some definitions in order to be clear about these concepts:
Privacy Notice: It is the physical, electronic or any other format document, generated by CANTINA LA 15 SAS that has been made available to the Data Subject for the Processing of his Personal Data, which communicates to the Data Subject the information regarding the existence of the Personal Data Processing Policies that will be applicable, the way to access them and the characteristics of the Processing that will be applied.
information regarding the existence of the Personal Data Processing Policies that will be applicable, the way to access them and the characteristics of the Processing that is intended to be given to the Personal Data.
Data Base: Consists of an organized set of Personal Data that are subject to Processing, and includes physical and electronic files.
Personal Data: Any information linked or that may be associated to one or several determined or determinable natural persons. 1 “Personal data” should be understood as information related to a natural person (individual person).
Sensitive Data: Data that affects the privacy of the Data Subject or whose improper use may generate discrimination, such as those that reveal racial or ethnic origin, political orientation, religious or philosophical convictions, membership in trade unions, social organizations, 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, sex life and biometric data.
Data Processor: CANTINA LA 15 SAS acts as data processor of personal data in cases, which by itself or in association with others, performs the processing of personal data on behalf of another data controller.
Data Controller: CANTINA LA 15 SAS acts as responsible for the processing of personal data for all personal data on which it decides directly, in compliance with its own legally recognized functions.
Data Subject: Natural person whose personal data are subject to processing.

The rights of the Data Controllers established in the Law may be exercised by the following persons:
1. by the Data Subject, who must sufficiently prove his identity by the various means made available to him by the Controller.
2. By their successors in title, who must prove such capacity.
3. By the representative and/or attorney-in-fact of the Data Controller, prior accreditation of the representation or power of attorney.
4. By stipulation in favor of or for another.

Processing: It is any operation or set of operations on Personal Data carried out by CANTINA LA 15 SAS or the Data Processors on behalf of the company such as collection, storage, use, circulation or deletion.
Transfer: Consists of sending Personal Data to a recipient who, in turn, is responsible for the Treatment in the terms of Law 1581 of 2012.
Transmission: It is the communication of Personal Data to the Data Processor, within or outside the territory of the Republic of Colombia, for the purpose of the performance of a Processing by the Data Processor on behalf of CANTINA LA 15 SAS.
Data Protection Officer: It is the person within CANTINA LA 15 SAS, whose function is to monitor and control the implementation of the Personal Data Protection Policy, under the guidance and guidelines of the Financial Management and Administration who will appoint the Data Protection Officer.

Suppliers:
– Maintain updated, consistent and sufficient information about the people who have the quality of suppliers or aspire to be suppliers, in their contractual relationship and specifically about their behavior as a Supplier, administrative, tax, financial and logistical aspects in General. 
– To purchase products or request services from its suppliers and to report tax information regarding them.
– Maintain an efficient communication of the information that is useful in the contractual links. Accompany internal or external auditing processes.
– Carry out statistical studies or accounting processes.
– Share personal and/or sensitive information, whose treatment has been authorized, to third parties; especially, to STF Group S.A., Amore Group SAS.

Clients and end users
CANTINA LA 15 SAS, will use the information you provide or will be provided to:

Execute the existing contractual relationship with workers, suppliers, customers and other business contacts.
– To develop processes of selection, evaluation, and labor linkage.
– To comply with the obligations contracted with the workers of CANTINA LA 15 SAS in relation to the payment of salaries, social benefits and others enshrined in the labor contract.
– Send communications by physical mail, email, mobile device, or through any other analog and/or digital means of communication with commercial, advertising or promotional information about products and/or services, events, promotions, campaigns and/or contests of commercial or advertising nature, advanced by CANTINA LA 15 SAS.
– Manage home delivery orders of any of the restaurants of CANTINA LA 15 SAS.
– Manage reservation requests for any of the CANTINA LA 15 SAS restaurants.
– Carry out satisfaction campaigns and follow up on the provision of their services and the quality of these and the products offered in their restaurants.
– Send commercial information about the activities carried out by CANTINA LA 15 SAS restaurants and about the launching of new products or services.
– Contact customers in case of complaints, claims or suggestions about the service of CANTINA LA 15 SAS restaurants.
Evaluate the quality of services provided by employees.
– Purchase products or request services from its suppliers and report tax information regarding them.
– Maintain an efficient communication of the information that is useful in the contractual links.
– To carry out statistical studies or accounting processes.
– Share personal and/or sensitive information, whose treatment has been expressly authorized through this document, to related and/or allied companies, especially STF Group SAS, Cantina La 15 SAS.

Some of these tasks are performed in compliance with a legal and contractual duty and therefore the processing of personal data is understood to be included in the same.

Employees:
The information collected is used to perform a process of analysis, evaluation and selection of personnel to work in the company.

– The employee authorizes CANTINA LA 15 SAS to treat the personal data provided in the development of the employment relationship, during the entire time of permanence in the entity and after the termination of the relationship as long as there is a legal or contractual duty of conservation by CANTINA LA 15 SAS.
– The authorization for the processing of personal data is granted by the employee within the terms described in this Personal Data Protection Policy, which is known and complies with the provisions of Law 1581 of 2012.
– Similarly, the employee who, without being authorized to do so, destroys, damages, deletes, erases, deteriorates, alters or deletes computer data, or an information processing system or its parts or logical components, may be criminally denounced for the crime of computer damage. Likewise, any employee who, without being authorized to do so, obtains, compiles, subtracts, offers, sells, exchanges, sends, buys, intercepts, discloses, modifies or uses personal codes, personal data contained in files, archives, databases or similar means, for his/her own benefit or for the benefit of a third party, may be criminally prosecuted for the crime of computer damage.
may be denounced for the conduct of violation of personal data. It will be considered a serious offense the breach of these Personal Data Protection Policies adopted and published by CANTINA LA 15 SAS becoming a cause for suspension or termination of the employment contract. (In all cases the employee (a) may make use of their rights of Habeas Data (Know, update and rectify your information) except as provided by law.

Former employees:
The information is stored for documentary conservation purposes and file information related to aspects of social security, pension and labor history, during the term established in the labor law.

Candidates in selection process:
Collects information from the resumes, certifications and personal references of those who apply for selection processes in CANTINA LA 15 SAS With it we seek to identify the most suitable candidates to be linked, in order to
place the person in the most appropriate business context to their profile.
In the case of sensitive personal data, it may be used and treated when:
– The same indicated for the case of employees.

• The Owners of the Personal Data registered in the Data Bases of CANTINA LA 15 SAS, as mentioned in the Law and its decrees have the following rights:
• To know, update and rectify their personal data. These rights may be exercised, among others, against partial, inaccurate, incomplete, fractioned, or misleading Personal Data, or those whose processing is expressly prohibited or has not been authorized.
  has not been authorized;
• Request proof of the Authorization granted to CANTINA LA 15 SAS except when expressly exempted as a requirement for the Treatment, in accordance with the provisions of Article 10 of Law 1581 of 2012;
• Be informed about the use that has been given to their Personal Data by CANTINA LA 15 SAS, or the Data Processor, upon request;
• By means of a claim filed pursuant to Art. 15 of Law 1581 of 2012, may request the revocation of the authorization and/or request the deletion of the Personal Data when the Processing does not respect the principles, rights and constitutional and legal guarantees or at any time provided that the holder has no legal or contractual duty to remain in the databases of CANTINA LA 15 SAS and in accordance with the procedure outlined in paragraph IV, of this Policy. 
• Access free of charge, at least once a month to their personal data that have been processed. 

CANTINA LA 15 SAS guarantees the right of consultation, providing to the persons acting in exercise of this right, all the information contained in their individual record or that is linked to the identification of the Holder.
The person responsible for attending to the requests in the exercise of the rights by the holders will be the Compliance Analyst as the person who will receive, process and channel the different requests received, and will send them to the respective unit, dependencies, offices, etc.
Once these communications are received, these agencies will begin to comply with the function of protection of personal data, and must process the requests of the owners, in the terms, terms and conditions established by the regulations in force, for the exercise of the rights of access, consultation, rectification, updating, suppression and revocation referred to in the regulations in force on protection of personal data.

The interested party may send his request to the e-mail address cumplimientonormativo@cantinala15.com.co or by submitting a written request at our offices located at the Administrative Headquarters Calle 16 Norte #9n-52, Cali-Colombia.

In any case, regardless of the mechanism implemented for the attention of consultation requests, they will be attended within a maximum term of ten (10) working days from the date of receipt. In case of impossibility to attend the consultation within such term, we will inform the interested party before the expiration of the 10 days, expressing the reasons for the delay and indicating the date on which the consultation will be attended, which in no case may exceed five (5) working days following the expiration of the first term.

Likewise, we guarantee the right of claim, to the databases for correction, updating or deletion, or when they notice the alleged breach of any of the duties contained in Law 1581 of 2012 and other applicable rules. The claim will be processed under the following rules:

• If the claim received does not have complete information that allows it to be processed, such as the identification of the Holder, the description of the facts that give rise to the claim, the address, and accompanying documents to be asserted, the claimant will be required within five (5) days of receipt to correct the faults. After two (2) months from the date of the requirement without the applicant submitting the required information, it shall be understood that the claim has been withdrawn.
• If for any reason CANTINA LA 15 SAS receives a claim addressed to another organization, it will transfer it to the appropriate party within a maximum period of two (2) business days and inform the claimant of the situation.
• Once the claim is received in full, it will include in the database maintained by CANTINA LA 15 SAS a legend that says “claim in process” and the reason for this, within a period not exceeding two (2) business days. This legend must be maintained until the claim is decided. 
• The maximum term to address the claim will be fifteen (15) working days from the day following the date of receipt. If it is not possible to deal with it within such term, the interested party will be informed before the expiration of such term, the reasons for the delay 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.
• The request for deletion of the information and the revocation of the authorization will not proceed when the Data Subject has a legal or contractual duty to remain in the database.

Special rules for the exercise of the rights of the holders.

The request for rectification, updating or deletion must be submitted through the means enabled by CANTINA LA 15 SAS indicated in the privacy notice and in this document, and contain, at least, the following information:

• The name, address of the holder and means of contact to receive the answer such as telephone, e-mail, residence address.
• Documents proving the identity or representation of its representative.
• The clear and precise description of the personal data with respect to which the holder seeks to exercise any of the rights.
• CANTINA LA 15 SAS, has the obligation to rectify and update at the request of the holder, the information that is incomplete or inaccurate, in accordance with the procedure and terms outlined above. In this regard, the following shall be taken into account: CANTINA LA 15 SAS has full freedom to enable mechanisms that facilitate the exercise of this right.

• Consider that they are not being treated in accordance with the principles, duties and obligations set forth in Law 1581 of 2012.
• Are no longer necessary or relevant for the purpose for which they were collected.
• The period necessary for the fulfillment of the purposes for which they were collected has been exceeded.

This suppression implies the total or partial elimination of personal information as requested by the holder in the records, files, databases or processing carried out by CANTINA LA 15 SAS The holder should note that the right of cancellation is not absolute and the responsible may deny the exercise of this right when:

• The request for deletion of information will not proceed when the holder has a legal or contractual duty to remain in the database.
• The deletion of data hinders judicial or administrative proceedings related to tax obligations, the investigation and prosecution of crimes or the updating of administrative sanctions.
• The data is necessary to protect the legally protected interests of the holder; to carry out an action in the public interest, or to comply with an obligation legally acquired by the holder.

In the event that the cancellation of personal data is appropriate, CANTINA LA 15 SAS, must operationally perform the deletion in such a way that the deletion does not allow the recovery of the information. It should also be noted that in some cases certain information must remain in historical records in compliance with legal duties of the organization so that its deletion will deal with the active treatment of the same and in accordance with the request of the holder.

REVOCATION AND/OR CANCELLATION OF AUTHORIZATION

The holders of personal data may revoke the authorization granted in favor of the Data Controller on their personal data, at any time, by filing a claim in accordance with the procedure established in Law 1581 of 2012 and / or any other rule that adds, amends or repeals it. The request for deletion of information and the revocation of the authorization will not proceed in cases where the associate or supplier of CANTINA LA 15 SAS, has a legal or contractual duty to remain in the database.
It is important to note that the revocation may be requested on all or part of the data that comprise the authorization granted in this document of Information Processing Policies – Privacy Notice, but not with respect to the data regulated under Law 1266 of 2008 and/or any other rule that adds, amends or repeals it, nor, it is reiterated, with respect to those cases in which the associate or supplier has a legal or contractual duty to remain in the database.

INTERNATIONAL TRANSFER OF PERSONAL DATA.

In the event that data is sent or transferred to another country, the authorization of the owner of the information being transferred must always be obtained. Unless the law states otherwise, the existence of such authorization is a prerequisite for the international circulation of data. In this sense, before sending personal data to another country, those obliged to comply with this policy must verify that they have the prior, express and unequivocal authorization of the owner that allows the transfer of their personal data.
Such transfer of personal data is made only to third parties with whom CANTINA LA 15 SAS, has contractual, commercial and / or legal relationship.

DATA PROTECTION OFFICER

According to article 2.2.2.2.25.4.4.4 decree 1074 of 2015, all responsible and in charge must designate a person or area that “assumes the function of personal data protection” and that “will process the requests of the holders, for the exercise of the rights referred to in the law 1581 of 2012 and the decree.
The function of the data protection officer or the area in charge of data protection in the organization is to ensure the effective implementation of the policies and procedures adopted by the organization to comply with the rules, as well as the implementation of good practices of personal data management within the company.
The data protection officer will have the task of structuring, designing and managing the program that allows the organization to comply with the rules on personal data protection, as well as establishing the controls of that program, its evaluation and ongoing review.

NATIONAL REGISTRY OF DATABASES

In accordance with Art. 25 of Law 1581 and its regulatory decrees, CANTINA LA 15 SAS has registered its databases along with this policy of treatment of Personal Data in the National Registry of databases administered by the Superintendence of Industry and Commerce in accordance with the procedure stipulated by Circular 002 of 2015.

The update of this policy is effective as of September 01, 2022, for a term of ten (10) years and will be made available to the owners through the website: www.cantinala15.com

As a general rule, the termination of authorizations for the use of personal data is understood as the termination of the business relationship or relationship with the company and during the exercise of the company’s corporate purpose.

The holder’s authorizations may be terminated at any time by the holder’s will. If the person is an active customer of CANTINA LA 15 SAS their data may not be used for purposes other than the provision of the product or service and for the offer of subsequent renewals when the service has this modality.
When the terms of the data processing policies of any of the services or products contracted by a holder, change in essence, as a general rule, in the services that have the option of renewal, the new authorization will be obtained in this new authorization. For other cases, the authorization will be obtained in the form established for each policy or privacy notice or through the usual means of contact between the company and the owners.
Any substantial change in the policies of Treatment, will be communicated in a timely manner to the owners of the data through the usual means of contact, in the communications area of the Restaurants and / or through:

Website: www.cantinala15.com

        E-mail sent to the holders

For holders who do not have access to electronic media or those who cannot be contacted, it will be communicated through open notices on the website or at the headquarters of the company and its commercial establishments.
Communications will be sent at least ten (10) days before implementing the new policies and/or substantial update of the same.