Information Processing Policies

As of July 2023, Colnodo, domiciled in Colombia, was selected to serve as the Secretariat of the Latin American and Caribbean Internet Governance Forum (LACIGF).

The following are COLNODO’s Information Processing Policies in accordance with the provisions of Law 1581 of 2012 “whereby general provisions are issued for the protection of personal data” and Decree 1377 of 2013 “whereby Law 1581 of 2012 is partially regulated”.

1-. Colnodo data:

COLNODO Association, domiciled in the city of Bogotá at Diagonal 40ª 14-75, info@colnodo.apc.org., Telephone 57 1 2324246.

2-. Treatment to which the data will be submitted and its purpose.

The treatment that COLNODO will give to the data applies to the users (or Owner) of the Internet systems owned by COLNODO; people participating in courses, conferences, campaigns, sweepstakes, contests or promotional activities; users of social networks such as Facebook and Google +, but not limited to these; followers of the account (s) on twitter that COLNODO has; followers or contacts of any account on any social network that COLNODO has.

Personal information is understood as that provided by the User, which includes data such as name, identification, age, gender, address, email and telephone number, among others.

It is in COLNODO’s interest to safeguard the privacy of the User’s personal information obtained through the Website, for which it undertakes to adopt a confidentiality policy in accordance with the following:

The User acknowledges that the entry of personal information is done voluntarily.

The User accepts that through the registration in the Web Site, Colnodo collects personal data, which will not be transferred to third parties without his/her knowledge.

The collection and automated processing of personal data as a result of browsing and/or registration on the Website has the following purposes: (i) the proper management and administration of the services offered on the Website, in which the User decides to register, use or hire; (ii) the quantitative and qualitative study of the visits and the use of services by users and (iii) the sending by traditional and electronic means of information related to Colnodo, its programs and initiatives. (iv) follow up on online training processes, carry out evaluations and generate certificates of participation.

3-. Rights that you have as a Holder.

The purpose of the collection and automated processing of personal data is to maintain the contractual relationship established with COLNODO; the management, administration, provision, expansion and improvement of services in which the User (Holder) decides to subscribe, register or use the adequacy of such services to the preferences and tastes of Users; the study of the use of the services by the Users; the design of new services related to such services; the sending of updates of the services; the sending, by traditional and electronic means, of technical, operational and commercial information about products and services offered by COLNODO Web products, currently and in the future. In this regard, it should be noted that COLNODO does not use the system of automatic insertion of cookies. The purpose of the collection and automated processing of personal data also includes the sending of survey forms, which the User is not obliged to answer.

In compliance with the provisions of Law 1581 of 2012 “by which general provisions are issued for the protection of personal data”, it is reported the existence of an automated file of personal data. The User is recognized the rights of access, rectification, cancellation and opposition to the processing of personal data and may exercise them by e-mail to the address info@colnodo.apc.org.

COLNODO will not transfer to third parties the User’s personal data collected through the Website without his/her express consent. Notwithstanding the foregoing, the User consents to the transfer of his/her personal data when so required by the competent administrative authorities or by court order.

The User also understands that the data provided by him/her will be part of a file and/or database that may be used by COLNODO for the purpose of carrying out a certain process.

COLNODO is not responsible for any consequences arising from the improper entry of third parties to the database and / or any technical failure in the operation and / or maintenance of data in the system in any of the menus of its website.

COLNODO has adopted the security levels of protection of personal data legally required, installing the necessary technical and organizational measures to prevent the loss, misuse, alteration, unauthorized access and theft of the data provided.

COLNODO reserves the right to modify this policy to adapt it to new legislation or jurisprudence as well as industry practices. In such cases, COLNODO will announce on this page the changes introduced with reasonable notice prior to their implementation.

COLNODO is concerned about the protection of personal data of its Users, therefore, ensures the confidentiality of the same, and will not transfer or assign or otherwise provide them, except in those cases where current legislation so indicates. The use that the User makes of COLNODO’s web products may be stored in order to generate statistical information regarding the use of sections, parts and in general, the Content of these, in order to determine the total and specific numbers, by section, of visitors to COLNODO’s web products, with the main objective of knowing the needs and interests of the User and to provide a better service.

Users freely and voluntarily determine whether they wish to provide the personal data that may be required or that may be obtained from the Users, on the occasion of the subscription or registration in some of the services offered in COLNODO’s Web products.

COLNODO has adopted the security levels of protection of Personal Data legally required, and has installed all the technical means and measures at its disposal to prevent the loss, misuse, alteration, unauthorized access and theft of Personal Data provided by the / as / as User / as. Nevertheless, the User must be aware that Internet security measures are not impregnable.

These policies and treatment manual will also apply to the personal data of customers, suppliers and employees, when the contact is made or the treatment of their data is outside the scope of the commercial and labor relationship that is maintained with them, respectively.

4. Attention to petitions, queries and claims before which the holder of the information may exercise his/her rights to know, update, rectify and delete the data and revoke the authorization.

The attention of petitions, queries and claims before which the Holder of the information may exercise his rights to know, update, rectify and delete the data and revoke the authorization must be made by e-mail to the address info@colnodo.apc.org

5. Procedure for the holders of the information to exercise their rights to know, update, rectify and delete information and revoke the authorization.

Access, consultation and complaint procedures

Law 1581 of 2012 confers on all natural persons certain rights and guarantees that seek to provide them with tools to protect their personal data and the use given to them. Any right that intends to be effective must have a known and efficient mechanism through which it can be enforced.

Below COLNODO presents the rights that you can assert before us, as the owner of the information, and the mechanisms we have at your disposal to do so.

Right of access: The power of disposal or decision that the Holder has over the information of which it is the owner implies the right to access and know if your personal information is being processed, as well as its scope. COLNODO guarantees the Data Subject’s right of access as follows:

a) The owner of the information may know, upon request, whether or not his or her data is being processed by COLNODO;

b) The Data Subject may have access to his/her personal data held by the Data Controller;

c) COLNODO will inform the Data Subject, at the time of obtaining his/her information, about the type of personal data processed and each and every purpose justifying the Processing.

COLNODO will guarantee the right of access, upon proof of the identity of the Data Subject or personality of his representative, making available to him, free of charge, the details of his personal data through physical or electronic means that allow direct access to them, so that the Data Subject may exercise his right to rectify, correct or request the deletion of all or part of his data.

Consultations. In accordance with the provisions of Article 14 of Law 1581 of 2012, the owners or their assignees may consult the personal information of the Holder that is contained in any database. Consequently, COLNODO will guarantee the right of consultation, providing them with all the information contained in the individual record or that is linked to the identification of the Holder.

For the attention of requests for consultation of personal data COLNODO guarantees:

To have enabled its telephone line (571) 2324246, as well as the email account info@colnodo.apc.org and others that it considers relevant at the time and that will be effectively announced through amendments to its Privacy Notice.

In any case, regardless of the mechanism implemented for the attention of consultation requests, these will be attended within a maximum term of ten (10) working days from the date of receipt. When it is not possible to attend the consultation within such term, the interested party shall be informed before the expiration of the 10 days, stating the reasons for the delay and indicating the date on which the consultation will be attended, which in no case may exceed five (5) business days following the expiration of the first term.

Claims. In accordance with the provisions of Article 14 of Law 1581 of 2012, the Data Subject or his/her assignees who consider that the information contained in a database should be corrected, updated or deleted, or when they notice the alleged breach of any of the duties contained in Law 1581 of 2012, may file a claim with the Data Controller, which will be processed under the following rules:

1) The claim shall be formulated by means of a request addressed to the Data Controller or the Data Processor, with the identification of the Data Subject, the description of the facts that give rise to the claim, the address, and including the documents that support the claim. If the claim is incomplete, the interested party will be required within five (5) days following the receipt of the claim to correct the faults. After two (2) months from the date of the requirement, without the applicant submitting the required information, it will be understood that the claim has been withdrawn. In the event that COLNODO. is not competent to resolve it, it will transfer it to the appropriate person within a maximum period of two (2) working days and inform the interested party of the situation.

2) Once the complete claim is received, it will be included in the database within a term not exceeding two (2) business days, a legend that says “claim in process” and the reason for the same. Said legend shall be maintained until the claim is decided.

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

Deletion of data. The Data Subject has the right, at any time, to request COLNODO to delete his/her personal data when:

• He/she considers that the same are not being treated in accordance with the principles, duties and obligations provided in Law 1581 of 2012.
• They 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 deletion implies the total or partial elimination of the personal information as requested by the Holder in the records, files, databases or treatments carried out by COLNODO. It is important to note that the right of cancellation is not absolute and the data controller may deny the exercise of the same in the following cases:

1. The request for deletion of the information will not proceed when the Holder has a legal or contractual duty to remain in the database.
2. It is not possible to delete the data by order of a judicial or administrative authority with jurisdiction in the National Territory.
3. The data is necessary to protect the legally protected interests of the Data Subject, or to ensure compliance with an obligation legally acquired by the Data Subject.

Implementation of procedures to guarantee the right to submit queries and claims. At any time and free of charge, the Holder or his representative may request COLNODO information on the use of their personal data, rectification, updating or deletion of these, upon proof of identity. The rights mentioned herein may only be exercised by:

1. The Data Subject or his or her successors in title, upon proof of identity.
2. Their representative, upon proof of representation.

When the request is made by a person other than the Data Subject and it is not proven that the person is acting on behalf of the Data Subject, in order to protect the data of individuals, COLNODO will consider the claim as not submitted.

All requests must be submitted through the means provided by COLNODO, as indicated in the Privacy Notice, and contain, at least, the following information:

• The name and address of the Holder, or any other means, such as an email, that allows communicating the response.
• The documents proving the identity or personality of its representative.
• A clear and precise description of the personal data with respect to which the Data Subject intends to exercise his/her rights.

COLNODO ensures that the means made available to the holders of the information allow a response in the terms established by Law 1581 of 2012.

Whenever COLNODO makes available a new tool to facilitate the exercise of their rights by the holders of information or modifies the existing ones, it will inform through its website and in its Privacy Notice.

Revocation of consent. The holders of personal data may revoke their consent to the processing of their personal data at any time, as long as it is not prevented by a legal provision. The owner of the information must clearly request if the revocation of their authorization concerns the totality of the purposes initially consented to, that is, that COLNODO must stop processing the data of the Data Subject completely, or if the revocation of their consent concerns specific types of processing, such as for advertising or market research purposes. With the second modality, that is, partial revocation of consent, other purposes of the processing that the Controller, in accordance with the authorization granted, may carry out and with which the Data Subject agrees, remain unaffected.

In view of the above, it will be necessary that the Data Subject, at the time of submitting the request for revocation of consent to COLNODO, indicates whether the intended revocation is total or partial. In the second case, the data subject must indicate with which treatment the data subject does not agree.

6. Effective date of the information processing policy and period of validity of the database.

This document is effective as of October 1, 2016 and until such time as it is expressly revoked or modified.