In compliance with the provisions of Law 1581 of 2012 and its Regulatory Decree 1377 of 2013, Blockcannan SAS, adopts this Policy for the Treatment of Personal Data (hereinafter "The Policy"), which will be informed to all holders of the data collected or that will be obtained in the future.
In this way, Blockcannan S.A.S. declares that it guarantees the rights of privacy, intimacy and a good name in the treatment of personal data, making use of blockchain and bigdata technology and, consequently, all its actions will be governed by the principles of legality, purpose, freedom, truthfulness o quality, transparency, access and restricted circulation, security and confidentiality.
This document describes in detail the information that Blockcannan S.A.S. It brings together its collaborators through the registration process with us, through our website and DApp Becannan Pay. In addition, this document is public knowledge for our collaborators and outsiders to know how Blockcannan S.A.S. you are manipulating the information in your possession.
All persons who supply personal data to Blockcannan S.A.S., may know it, update it, rectify it, delete it or revoke the authorization previously granted.
As the Owner of the Personal Data you give your consent to the treatment of these when being in the applications or the websites of Blockcannan S.A.S. I ask you to verify and approve the acceptance box of the Policy for the Treatment of Data of Blockcannan S.A.S. In the same way, you declare with the acceptance of this Policy, that the data provided is true and that you have not omitted or altered any information.
You are not obliged to provide us with your personal information; however, if you choose not to, you will not be able to use some of our services or we will not be able to respond to your queries and needs. Finally, you will always have access to this Data Processing Policy by entering the main page of our website.
The company is governed by international regulations for the use and processing of data of all our collaborators, as well as by the law of the Colombian State, which is the territory where we are legally established as a company.
Principles and definitions
For the correct understanding of the Data Processing Policy of Blockcannan S.A.S., the following terms will have the following meaning:
Database: Organized set of personal data that is subject to Treatment.
Personal data: Any information linked or that may be associated with one or more determined or determinable natural persons.
Treatment Manager: Natural or legal person, public or private, who by himself or in association with others, performs the processing of personal data on behalf of the person responsible for the Treatment.
Responsible for the Treatment: Natural or legal person, public or private, who by himself or in association with others, decides on the database and / or the Treatment of the data, in this case Blockcannan S.A.S.
Authorization: Prior, express and informed consent of the Owner to carry out the Processing of personal data.
Privacy Notice: Verbal or written communication generated by the Responsible, addressed to the Owner for the Treatment of your Personal Data, through which you are informed about the existence of the Information Processing policies that will be applicable, the way of accessing to them and the purposes of the Treatment that is intended to be given to Personal Data.
Owner: Natural person whose personal data is subject to Treatment.
Treatment: Any operation or set of operations on personal data, such as collection, storage, use, circulation or deletion.
Transfer: The data transfer takes place when the person in charge and / or in charge of the treatment of personal data, located in Colombia, sends the information or personal data to a recipient, who in turn is responsible for the treatment and is inside or outside. from the country.
Transmission: Treatment of Personal Data that implies the communication of the same inside or outside the territory of the Republic of Colombia when it has as its object the realization of a Treatment by the Manager on behalf of the Responsible.
Natural Person: Human person who exercises rights and fulfills duties in a personal capacity.
External: Any legal or natural person other than the people who directly belong to Blockcannan S.A.S.
Collaborator: Natural or legal person who accepts electronic exchanges through the Becannan Pay Wallet to access the goods and / or services offered by the company Blockcannan S.A.S. Also, they are collaborators, employees, suppliers.
Sensitive data: Those that affect the privacy of the Owner or whose improper use can generate their discrimination.
Public data: It is the data that is not semi-private, private or sensitive and may be contained, among others, in public records and documents, gazettes and official gazettes and judicial decisions.
Private data: it is the data that due to its intimate or reserved nature is only relevant to the owner.
Semi-private data: these are data that are not intimate, reserved or public in nature and whose knowledge or disclosure may interest not only the owner but a certain sector or society in general.
Cookie: is a file of information sent by a website and stored in the user's browser, so that the website can check the user's previous activity.
User: Subscriber to the developments made by Blockcannan S.A.S. and that on the occasion of the same you can acquire, send, and subscribe to Goods and / or Services offered and sold by Blockcannan S.A.S and Collaborators.
Blockcannan S.A.S. It will apply the specific principles established below, which constitute the rules to be followed in the collection, handling, use, treatment, storage and exchange of Personal Data, which apply without prejudice to the other principles established in the rules and regulations. of applicable Personal Data protection:
Principle of legality: The Treatment of your Personal Data will be made based on the provisions of the law and other applicable provisions and in this Policy.
Principle of freedom: The Processing of Personal Data can only be exercised with the prior, express and informed consent. Your Personal Data may not be obtained or disclosed by Blockcannan S.A.S. without prior authorization, or in the absence thereof, without a legal or judicial mandate that relieves consent.
Principle of transparency: As the Owner of Personal Data, you have the right to obtain information regarding your Personal Data, the purposes of the Treatment, the databases in which they are contained, among other aspects related to your privacy and the protection of the right access to Personal Data.
Security principle: Your personal information will be managed by Blockcannan S.A.S. through the provision of the technical, human and administrative measures that are necessary to grant security to your data, avoiding adulteration, loss, consultation, use or unauthorized or fraudulent access.
Principle of confidentiality: Your Personal Data will be subject to confidentiality in accordance with the nature of the same and the applicable regulations.
By Blockcannan S.A.S. the information that our collaborators share with us is a precious asset. Therefore, we guarantee the good treatment in the use and manipulation of the data that is in our power, respecting the guiding principles of data treatment that we describe in our SARLAFT manual. Blockcannan S.A.S. does not accept behaviors within its services that are considered SPAM and whoever engages in these practices may be suspended, disabled or blocked from our services.
The purpose of this Policy is to define the general guidelines for compliance with Law 1581 of 2012 and Decree 1377 of 2013 in Colombia, which regulates the management of personal databases.
By virtue of this, the criteria for the collection, storage, use, circulation and suppression of personal data processed by Blockcannan S.A.S.
To comply with Law 1581 of 2012 on the protection of personal data, the following considerations must be kept in mind:
Blockcannan S.A.S. is responsible for the treatment of personal databases.
In principle, Blockcannan S.A.S. will be directly responsible for the Processing of Personal Data; however, it reserves the right to delegate to an external, national or foreign, for such Treatment, demanding compliance with the policies implemented here, as well as those derived from the Colombian legal system.
Outsiders who have access to the databases will be in charge of the Treatment and therefore must comply with the provisions of Law 1581 of 2012, Decree 1377 of 2013, the regulations that complement them, modify them and this Policy.
The Law is mandatory throughout the Colombian territory and to transmit personal data to other countries, their legislation must contemplate security measures, equal to or greater than those contained in the aforementioned Law.
Personal databases in Blockcannan S.A.S. are considered. all of natural persons, whether they are suppliers, affiliates, clients, consumers, volunteers, apprentices or linked by any means, employees, or any other natural person whose information is subject to treatment by us.
Specific Conditions and Privacy
The following specific conditions must be taken into consideration:
As of the date, every employee who initiates an employment relationship with Blockcannan S.A.S must have a clause in their employment contract that expresses the commitment to comply with Law 1581 of 2012 and Decree 1377 of 2013.
A text regarding the obligation to comply with Law 1581 of 2012 and Decree 1377 of 2013 will be included in the internal work regulations, to cover the entire current universe.
Any external party that requires personal databases in relation to areas of Blockcannan SAS should be asked for a contractual clause stating the knowledge of the regulations and the responsibility for complying with them, and likewise, will require prior authorization from the Owner to process your personal data.
All suppliers, affiliates, customers, consumers, volunteers or linked by any means, employees, or any other person whose information is subject to treatment by us, must be asked in writing for authorization so that their data can be processed without restrictions. This must extend to all the effects that in our exercise appear.
In the authorization cited in the previous paragraph, the responsibility of the Holders must be made clear to keep the information updated and truthful, communicating in a timely manner to Blockcannan S.A.S, to which they conferred their authorization, any modification in this regard.
All the personal databases that the areas of Blockcannan S.A.S treat must have the guarantee of recovery (Back up).
You must have limited access to personal databases. When these are sent by mass means, they must contain keys so that access to them is restricted.
Databases must not be published on the Blockchain or on the internet without them being restricted for access.
Periodically, Blockcannan S.A.S must promote campaigns to update its personal databases.
For the treatment of personal databases, all areas that require it must have a written procedure that guarantees compliance with the policy and with Law 1581 of 2012 and Decree 1377 of 2013.
Blockcannan S.A.S must have a procedure for dealing with queries and claims, guaranteeing compliance with the law regarding this matter.
The application of the policy is not necessary, by legal exception, when:
The databases and files are intended for national security and defense, as well as the prevention, detection, monitoring and control of money laundering and terrorist financing.
The databases that have as their purpose and contain intelligence and counterintelligence information.
The databases and files are for journalistic information and other editorial content.
We understand that there may be a particular case that may give rise to an exception, for these cases you can contact us through email@example.com, firstname.lastname@example.org, and each case will be analyzed by the area of support of Blockcannan SAS or will be directed to a Committee that is pertinent for the evaluation and subsequent response to each case, if this is by any of our collaborators.
Responsible for the Treatment
The following is the information of Blockcannan S.A.S, which is responsible for the processing of personal data:
Blockcannan S.A.S. Identified with NIT 901346913-3, with main address at CRR 42 # 56 SOUTH 36, SABANETA, ANTIOQUIA, Republic of Colombia.
Treatment and Purpose
The Treatment that the Data Controller will carry out will be carried out in accordance with the provisions of Law 1581 of 2012, Decree 1377 of 2013 and the regulations that add or modify it, as well as with the provisions of this Policy.
Blockcannan S.A.S. You may collect, transfer, store, use, circulate, delete, share, update and transmit said data for purposes, among others, of:
Share your personal information with Trade Collaborators and / or service providers, to use their trading platforms. Blockcannan S.A.S. and / or Commercial Collaborators will be obliged to use the User's personal information only for the purposes established in this Policy. Blockcannan S.A.S. ensures that all external parties involved in the Processing of Personal Data use standards of protection in accordance with applicable legislation and in accordance with the provisions of this Policy.
Transmit, transfer or communicate to any public authority of any of the countries where Blockcannan S.A.S. operates. (For example, the Attorney General's Office, the National Police, and in general any administrative or judicial authority in the exercise of their functions).
Share your Personal Data with Commercial Collaborating entities that provide the means of payment provided on our platform, franchises, verification entities, networks or other entities, that intervene in the processing and validation of payments. By granting your Authorization supported by this Policy, you authorize Blockcannan S.A.S. to share your Personal Data with those entities.
Share your Personal Data with operators, agents or service providers that are partners or contractors of Blockcannan S.A.S., for the proper functioning of the company's services. In all cases, Blockcannan S.A.S. will ask those who share the Personal Data to take the appropriate organizational and technical measures in order to protect the Personal Data and respect the corresponding legislation.
Share your Personal Data with regulatory compliance service providers, in the terms allowed by law.
Disclose your personal information when we are obliged to do so in compliance with the credit card management policies or rules of the financial institutions that participate in the processing and validation of payments.
Disclose your personal information, on the occasion of a legal process, litigation and / or at the request of public and governmental authorities inside or outside the country of residence of the User or in compliance with compulsory procedures, such as reports to government entities in withholdings and taxes.
Disclose your personal information when it considers that there are sufficient indications to believe that the disclosure of personal information is necessary to avoid damages to Blockcannan S.A.S. or to any user who uses the services offered by Blockcannan S.A.S. and Collaborators.
Disclose your personal information when it requires reporting any indication of illegal activity.
Using your Personal Data, when we believe in good faith that doing so is necessary to: (i) comply with applicable law; (ii) protect our users from spam or prevent fraud attempts against our users or our system; (iii) for the operation and maintenance of our websites, products and services, such as, for example, to prevent or end an attack on our networks and our computer systems; (iv) protect our rights and assets; (v) to demand compliance with the terms that govern the use of our websites, products or services.
Combine your personal information with other information that we have or that results from the use you make of our services, to provide and improve Blockcannan S.A.S services, their content and advertising, among others.
The information that is collected by cookies and other technologies is processed by Blockcannan S.A.S. as non-personal information, unless in accordance with the legislation of the countries in which Blockcannan S.A.S provides its services, you must have this Treatment.
Use the data for the efficient, safe and personalized provision of the services of Blockcannan S.A.S.
Process and advance any transaction and / or interaction on the Blockcannan S.A.S. In the event of payment transactions, depending on the type of payment, Blockcannan S.A.S. will share the data with the institutions that validate and process each means of payment, if applicable, their authorization, validation and corresponding compensation. This implies that Personal Data may be collected for these purposes by financial institutions that issue the means of payment, acquiring financial institutions, payment processing networks, franchises such as Visa, MasterCard or American Express, to name a few.
Verify the identity of the User.
Authenticate and validate that any interaction on the platform is not fraudulent and / or any impersonation.
Use Personal Data in transactional or monitoring reports that can be used by Blockcannan S.A.S.
Compare your information.
Use your data in order to enforce our Terms and Conditions.
Use your personal information for internal purposes, such as audits, reports, analysis or data mining, investigations to improve products, services and communications as a user of the services of Blockcannan S.A.S.
Personalize, measure and improve the services provided by Blockcannan S.A.S., as well as our web pages and access to our services.
Information related to the use of the services offered by Blockcannan SAS, through our information channels such as: website, social networks, electronic wallet, transactions, as well as any other information related and generated by the interaction with the platform and derived transactions. , will be used for the analysis of Blockcannan SAS, and the development or improvement of future products and / or services.
Request your opinion or participation in electronic surveys, in addition to sending communications and commercial and advertising information from Blockcannan S.A.S., or from external parties that include promotions.
Organize and carry out contests, games, offers or promotional or marketing operations, and similar events of Blockcannan S.A.S.
Send you discount coupons or grant benefits.
Propose your affiliation to loyalty programs, create user consumption profiles, and send you promotional and advertising materials that may be of interest to you.
Make backup copies of the databases, in order to protect them and guarantee the continuity of the commercial relationship with Blockcannan S.A.S.
Advance user satisfaction surveys.
Provide you with a support and troubleshooting service.
Sending notifications, account status information, and other information related to the services offered by Blockcannan S.A.S. through any electronic means.
Statistical analysis of operations, transactions and activities carried out on the website or any other means or service of Blockcannan S.A.S.
Invoice the use of the services of Blockcannan S.A.S.
Register with the competent authorities the data when the law requires it.
Sensitive Data Processing
Sensitive Data is understood in accordance with Law 1581 of 2012 those that affect the privacy of the Owner or whose improper use may generate their discrimination. In addition, it is guaranteed that authorization for the treatment of said data will be obtained in advance and expressly, complying with the following obligations:
Blockcannan S.A.S. does not voluntarily collect, use or disclose personal information from minors, according to the equivalent minimum age in the relevant jurisdiction.
The services of Blockcannan S.A.S. they are not intended or designed to attract minors. We encourage parents to stay informed about their children's online activities to ensure that information is not collected from a child without parental permission.
The Holder of the data will be informed that because it is Sensitive Data, she is not obliged to authorize its Treatment.
The Owner will be previously and expressly informed of the sensitive data and the purpose of the Treatment that will be given.
No activity will be conditioned on the Owner supplying Sensitive Data.
Likewise, Blockcannan S.A.S. accepts the general rule according to which the Treatment of Sensitive Data is prohibited by law, except in the following cases:
When the Owner has expressly authorized the Treatment. b. When by law the granting of said Authorization is not required. c. When the Treatment is necessary to safeguard the vital interest of the Holder. d. When the Treatment is carried out by a foundation, NGO, association or any non-profit organization, whose purpose is political, philosophical, religious or union. and. The Treatment is necessary for the recognition, exercise or defense of a right in a judicial process. F. The Treatment obeys a historical, statistical or scientific purpose. In this case, the identities of the Holders must be deleted.
Rights of the Holders
Blockcannan S.A.S., through procedures defined in this policy, guarantees the Holders of the data the exercise of their legal rights established in Law 1581 of 2012 and other applicable and complementary provisions, such as:
As Holders of personal data, they will have the following rights:
Free access to the data provided that have been processed.
Know, update and rectify your information against partial, inaccurate, incomplete, fractional, misleading, or those whose treatment is prohibited or has not been authorized.
Request proof of the authorization granted to the Data Controller except when expressly excepted as a requirement for Treatment, in accordance with the provisions of article 10 of law 1581 of 2012.
Submit complaints to the Superintendency of Industry and Commerce for violations of the provisions of current regulations.
Revoke the authorization or request the deletion of the data, provided that there is no legal or contractual duty that prevents deletion.
Refrain from answering questions about sensitive data. Responses that deal with sensitive data or data on minors will be optional.
Be informed by the Data Controller or the Treatment Manager, upon request, regarding the use that has been given to your Personal Data.
Duties of the Holders of Personal Data
All the Personal Data and information that you provide as a User of the services of Blockcannan S.A.S., must be truthful, complete, accurate, updated, verifiable and understandable.
When you exercise your right to correct, update, delete, revoke your consent to the Treatment of your Personal Data, you must prove that you are in effect the Owner or who requests it is authorized by you, in the terms required by law and the means provided by Blockcannan S.A.S.
Blockcannan S.A.S. will request through the official means, at the latest in the collection of the information, the Authorization of the Holder for the use and Treatment of his Personal Data. Said Authorization will be kept physically or electronically.
The Authorization may appear in a physical, electronic document, data message, the Internet, websites, in any other format that guarantees its subsequent consultation, or through a suitable technical or technological mechanism, which allows to express or obtain consent via click or double click, through which it can be unequivocally concluded if the Holder's conduct has not been provided, the data would never have been captured and stored.
Blockcannan S.A.S. It will use the mechanisms it currently has, and it will implement and adopt the necessary and necessary actions to keep records or technical or technological mechanisms suitable for when and how it obtained Authorization from the Holders of Personal Data for the Treatment of the same. To comply with the foregoing, physical files or electronic repositories made directly or through external contracted for this purpose may be established.
Blockcannan S.A.S. will be responsible for taking the technical and physical measures necessary to preserve, protect and facilitate access to the Data Processing Authorization.
The Holder's Authorization will not be necessary in the case of information required by a public or administrative entity in the exercise of its legal functions or by court order or in any other of the cases provided for in Article 10 of Law 1581 of 2012 and in the other applicable and complementary laws and regulations.
To make any request, claim, and / or request regarding your right of access, withdrawal, use and / or modification of personal data, our collaborators may do so through our website in your User Account, through our DApp Becannan Pay , through the email email@example.com, by post to the address: Crr 42 # 56 south -36 Sabaneta, Colombia. In the cases that the revocation of the Authorization is possible, it will be attended under the following two modalities:
Total: On all the consented purposes, that is, that Blockcannan S.A.S. You must completely stop treating the Personal Data Holder's data.
Partial: On certain consented purposes such as for advertising or market research purposes. In this case, Blockcannan S.A.S. You must partially suspend the Treatment of the Personal Data of the Owner. Then other purposes of the Treatment are maintained that the Responsible, in accordance with the Authorization granted, can carry out and with which the Owner agrees.
The right of revocation is not an absolute right and Blockcannan S.A.S. As Responsible for the Processing of Personal Data, you can deny or limit its exercise when the Data Holder has a legal or contractual duty to remain in the Database. To request the revocation of the Authorization, the Holder must send a claim to Blockcannan S.A.S. following all the rules established in this Policy.
Procedure for the Exercise of the Right to Habeas Data and Consultations
The Holder of Personal Data, his successors or representatives may consult the information of the Holder that rests in the data base (s) of Blockcannan S.A.S. and exercise your right to modify, correct, update, delete it and other rights in accordance with applicable law and in accordance with the form and times established by the legislation of your country or the country in which the Processing of Personal Data is being carried out.
For the attention of the petition, complaint or claim, the following information must be requested:
Full name and surname of the Owner of the personal data.
Contact details of the Owner of the personal data:
Physical address and / or email.
Reasons or facts that give rise to the claim, request or consultation with a brief description of the right that you wish to exercise (know, update, rectify, request proof of authorization granted, revoke it, delete it, access the information, among others).
Signature (if possible).
Once this information is received, the Responsible will have a maximum term of fifteen (15) business days, counted from the day following the date of your request, query or claim, to attend to it. When it is not possible to attend the request, query or claim within the aforementioned term, the Responsible will inform the Holder or interested party the reasons for the delay and the date on which their claim will be addressed, which in no case may exceed eight ( 8) business days following the expiration of the first term.
Once the terms indicated by Law 1581 of 2012 and the other regulations that regulate or complement it have been complied with, the Holder who is totally or partially denied the exercise of the rights of access, updating, rectification, deletion and revocation, may put their case in the knowledge of the Superintendence of Industry and Commerce - Office for the Protection of Personal Data.
In relation to the deletion, the Personal Data Holder has the right at all times, taking into account the following assumptions:
That they are not being treated in accordance with the principles, duties and obligations provided in the current regulations on the protection of Personal Data.
That they are no longer necessary or relevant for the purpose for which they were collected.
That the period necessary for the fulfillment of the purposes for which they were collected has been exceeded.
This deletion implies the safe or total or partial elimination or deletion of personal information in accordance with what is requested by the Owner in the records, files, databases or Treatments carried out by Blockcannan S.A.S. The right of erasure is not an absolute right, and Blockcannan S.A.S. As Responsible for the Processing of Personal Data, you can deny or limit its exercise when the Data Holder has a legal or contractual duty to remain in the Database.
Modifications to the data processing policy
Blockcannan S.A.S may periodically change these Privacy Policies. The latest version will be available on our website www.blockcannan.com. Likewise, we will have a repository with the inventory of documentation that is essential for the proper use of our services, such as the SARLAFT manual and the General Terms and Conditions.
If the modifications require the express consent of the User, the User will be informed to expressly accept the renewal of the Authorization you have given us for the Treatment of the data. The continuous use of the services or non-separation of the same by the Owner of the Personal Data after the notification of the modification of the Policy or the new guidelines constitutes the acceptance of the same.
Linked websites and external applications
There may be links on the Blockcannan website that redirect to another website. The linked websites are not under the control of Blockcannan S.A.S. and they have different privacy policies. If you use extras, add-ons or external applications to access Blockcannan S.A.S.'s services and goods, the provider of such applications may have access to certain User Personal Data. Blockcannan S.A.S. cannot control how the application provider uses the Personal Data available in relation to them. Don't forget to read the provider's privacy policies before installing or using the applications.
International Transmission of Personal Data
Blockcannan S.A.S. they may carry out the transfer and transmission, even internationally, of the personal data that they have in their databases, as long as the applicable legal requirements are met; and consequently the holders of personal data expressly authorize the transfer and transmission, including internationally.
For the transfer of personal data of the holders, Blockcannan S.A.S. will take the necessary measures so that the outsiders know and commit to observe this policy, with the understanding that the personal information they receive can only be used for matters directly related to Blockcannan S.A.S. or the purposes expressly authorized by the owner, and only while this authorization is in force. It may not be used or destined for a different purpose or purpose.
Blockcannan S.A.S. complying with the provisions of article 26 of Law 1581 of 2012, which regulates the international transfer of personal data, will make available to the public authority (ies) responsible for supervising the processing of personal data, of compliance with applicable legislation and protection of the rights of the holders, the information that in each case is necessary for the proper functioning of the services offered to Users.
Notice of Privacy