This document contains the policy under which the private law body called “GLOBAL EXCHANGE INTERNATIONAL SAS”, for profit organization founded according to Colombian law, hereinafter referred to as “GLOBAL EXCHANGE INTERNATIONAL SAS”, will protect the rights of the users of this website in terms of privacy and use of data provided by users. This policy is part of the document of conditions of use of the website, which are on www.tumejorexperiencia.com

We ask the visitor and user of this website to read thoroughly and carefully this privacy policy and the conditions of use of this website before exploring or using it. If the visitor or user does not agree with any provision of this policy or with the conditions of use of our website, please refrain from using it.

I. General aspects.

The general aspects of the privacy policy of “GLOBAL EXCHANGE INTERNATIONAL SAS” website are listed below.

Based on paragraph k) article 17 and paragraph f) article 18 of the Statutory Law 1581 of 2012 and article 13 of Decree 1377 of 2013, it is mandatory for people responsible for personal data processing to adopt an in-house handbook including policies and procedures to ensure that user’s inquiries and claims regarding data processing are responded.

“GLOBAL EXCHANGE INTERNATIONAL SAS” is committed to complying with the law and protection of people’s rights. Therefore, we inform users the implementation of the following policies on recollection, processing and use of personal data, which will be mandatory for the company, as responsible for employees’ treatment, as well as third parties who might process data by company’s disposition.

These policies will apply for the collection and processing of data available on “GLOBAL EXCHANGE INTERNATIONAL SAS” database.

The main objective of personal data processing policies is to protect people who perform support, labor and commercial activities, either permanent, transitory or occasionally can provide personal information or data to “GLOBAL EXCHANGE INTERNATIONAL SAS”. The company is responsible for data processing and must allow the data holder to review, update and rectify it.

Guiding principles for personal data processing.

According to Act 1581 of 2012, the following guiding principles will be applied in the collection, management, use, processing, storage and exchange of personal data:
Principle of lawfulness in terms of data processing. Principle of purpose limitation.
Principle of freedom.
Principle of accuracy or quality.
Principle of transparency.
Principle of access and storage limitation. Principle of safety.
Principle of confidentiality.

Definitions:

Consent: Prior and explicit consent from data holder to process the data.

Personal data: any information relating or associating to a determined or determinable natural person, which can be identified. For example, a name, address, telephone, email address, marital status, fingerprint, etc.
Semi-private personal data: Data that do not have intimate, reserved nor public nature and whose knowledge or divulgation may not only be of the holder’s interest but of a certain field or group or even the society in general. In this case, it is required the holder’s explicit consent for data processing. For example: financial data, data related to social security entities.

Sensitive personal data: This is understood to be information that affects the privacy of the holder of such, which in the case of being misused, could lead to him or her being discriminated against, this including information revealing racial or ethnic origins, political orientations, religious or philosophical beliefs, trade unions, social or human rights organization, promoting the interests of any political party or ensuring the rights and guarantees of the opposition parties as well as data concerning the health and sexuality of the holder as well as his or her biometric data. Data cannot be processed unless for protecting holder’s vital interest or if the holder is incapacitated and has given explicit consent.

Private personal data: The datum that by its intimate or reserved nature is only relevant for the holder. An explicit consent is required to process this information. For example: Education level, commercial books, among others.

Public personal data: That which is stipulated as such by law or the Constitution. In this case, holder’s consent is not required to collect or process data. For example: marital status, data contained on the RUNT, court rulings that have been duly executed, among others.

Processing Supervisor: Natural or legal persona, public or private, who by himself or in partnership with others, performs the personal data processing on behalf of the controller.

Processing Responsible: Natural or legal person, public or private, who by himself or in partnership with others, decides about the data basis and/or the data processing.

Holder: Natural persona whose personal data are subject to be processed. In case of underage, their legal representative will give the consent whether or not process the data.

Processing: Any operation or set of operations related to the personal data, such as recollection, storage, use, circulation or suppression. The personal data and its purpose will be subjected to this.

Personal data from users, employees, corporate governance, suppliers, and other third parties of “GLOBAL EXCHANGE INTERNATIONAL SAS” will be processed for the following purposes:

1. Register process to “GLOBAL EXCHANGE INTERNATIONAL SAS”.
2. Filling out the application, agreements, attachment to the agreement, and other contractual instruments required on the application, execution, development, and compliance of the cultural exchange program.
3. Reponses to enhancement requests, requests, complains and claims.
4. Issuing certifications.
5. Campaigns to comply with current regulations.
6. Information about new products and services.
7. Definition of demand and analysis of services provided by “GLOBAL EXCHANGE INTERNATIONAL SAS”.
8. Satisfaction surveys of the services and assistance provided.
9. Update data and identification documents.
10. In general, all the information that allow accomplishing the corporate purpose of “GLOBAL EXCHANGE INTERNATIONAL SAS”, as well as the Mission and Vision.

 

Holders’ rights

1. This website, its information, content, services included are of public knowledge. Therefore, the full acceptance of this privacy policy is mandatory and essential to allow the user to use it.
2. The acceptance of this privacy policy by the user of this website will be gained on the following cases: i) Data provided on the website’s registration forms. ii) Implementation of acceptance, safety and access methods to the website set by “GLOBAL EXCHANGE INTERNATIONAL SAS”. iii) Looking up information included on the website. iv) Using any of the services available on the website.
3. The website’s user accepts that knows, respects and complies with the regulations, rules, and national and international uses related to his or her responsibilities and duties under this privacy policy.
4. “GLOBAL EXCHANGE INTERNATIONAL SAS” has the right to review, change or add, at any time, any provision of this privacy policy to comply with any legal requirement.

 

II. Registration details

1. Collection, access and use of information

The following guidelines of our privacy and data protection policy are related to the collection, access and use of Registration details provided by the user through “GLOBAL EXCHANGE INTERNATIONAL SAS” website.
a) Users’ personal and general data collected on the website by “GLOBAL EXCHANGE INTERNATIONAL SAS”, will be only used to comply with the purposes of its website. Its use is set in this privacy and personal data protection policy.
b) By accepting this privacy and personal protection policy, the website’s user explicitly gives in his or her personal and general data provided to “GLOBAL EXCHANGE INTERNATIONAL SAS”, through this website. The website’s user consents to conduct an automatic processing and using them according to this privacy and personal data protection policy.
c) User’s Registration details is the essential to comply with the current legal requirements in Colombia and with the international application about privacy and data protection on the Internet, such as OCDE Privacy Guidelines (www.oecd.org).
d) During the registration process, users will be notified by an asterisk (*) the information that must be provided mandatorily or alternatively.
e) The website’s user explicitly authorizes “GLOBAL EXCHANGE INTERNATIONAL SAS” to automatically process the requested information to provide him or her with an efficient and customized service. The user explicitly authorizes “GLOBAL EXCHANGE INTERNATIONAL SAS” to disclose, give in or transfer his or her personal data and information provided on this website to other entities, companies, agencies promoters of this cultural exchange program, classes, and public entities f of the country and national and international government to comply with the corporate purpose of “GLOBAL EXCHANGE INTERNATIONAL SAS”.
f) Registration details by no means or circumstances will be shared with third parties, except with other entities, companies, agencies promoters of this cultural exchange program, classes, and public entities of the country and national and international government linked or associated with “GLOBAL EXCHANGE INTERNATIONAL SAS”.
g) User’s Registration details will be shared with other websites of “GLOBAL EXCHANGE INTERNATIONAL SAS”, provided that its use will enhance the services provided to the user.
h) “GLOBAL EXCHANGE INTERNATIONAL SAS” has the right at any time of conducting surveys to users in order to internally assess the website’s use and quality of the online services provided by “GLOBAL EXCHANGE INTERNATIONAL SAS”.
i) “GLOBAL EXCHANGE INTERNATIONAL SAS” will not send information that has not been requested to the user’s email address, except information, news or changes regarding to “GLOBAL EXCHANGE INTERNATIONAL SAS” services.
B) Disclosure of registration details

The registration details from each user are private and they cannot be shared with other people or companies, except when “GLOBAL EXCHANGE INTERNATIONAL SAS” acting reasonably, considers there is one of the following circumstances:

1. A legal duty or mandate that obliges to provide them.
2. Protect and defend the rights and interests of “GLOBAL EXCHANGE INTERNATIONAL SAS”.
3. Require compliance of the conditions of use of any information, content or service available on “GLOBAL EXCHANGE INTERNATIONAL SAS” website.
4. Protect and defend the rights and interests of the website’s users and third parties.
5. Any other exception defined in the law applicable to this privacy and personal data protection policy.

C) User’s obligations and duties.
The following are the obligations, duties, minimum practices and warnings that should guide the user's behavior in accordance with this privacy and personal data protection policy:
a) The user agrees to provide "GLOBAL EXCHANGE INTERNATIONAL SAS" true, accurate, updated and complete information about him or her, as indicated in the registration form. Moreover, the user agrees to cooperate with "GLOBAL EXCHANGE INTERNATIONAL SAS", to keep this information updated and complete.
b) "GLOBAL EXCHANGE INTERNATIONAL SAS" reserves the right to withdraw without prior notice to the user, any information that is disclosed on the website and that it considers harmful or detrimental to their interests or the interests of third parties. However, "GLOBAL EXCHANGE INTERNATIONAL SAS" is not obliged to remove information that any user considers offensive or harmful or to supervise the conversations or dialogues of the users or visitors of the website in forums or chats.
c) When the user provides any information to "GLOBAL EXCHANGE INTERNATIONAL SAS", the same user must take precautionary measures to avoid the loss or inappropriate use of such information. In case of not taking such measures, "GLOBAL EXCHANGE INTERNATIONAL SAS" will not be responsible for the use that third parties may make of information improperly secured and protected by the user.
d) "GLOBAL EXCHANGE INTERNATIONAL SAS" is not responsible for the privacy of the personal information that the user discloses or uses on forums, chat sessions of "GLOBAL EXCHANGE INTERNATIONAL SAS" website, in emails or in any other website. The user is exclusively responsible for the privacy and custody of any personal data that provides a person or company other than "GLOBAL EXCHANGE INTERNATIONAL SAS".
e) The user will not collect and disclose the personal data or information of the website’s users of "GLOBAL EXCHANGE INTERNATIONAL SAS" and that it is disclosed through it or that it is available on the information systems of "GLOBAL EXCHANGE INTERNATIONAL SAS".
f) The user will not publish on other websites or through any means, the personal data or information of other users of "GLOBAL EXCHANGE INTERNATIONAL SAS" website and that it is disclosed through it or that it is available on the systems of information of "GLOBAL EXCHANGE INTERNATIONAL SAS".
g) The provision of false information or the omission of any obligation or duty of the user established in this privacy policy, grants the right to "GLOBAL EXCHANGE INTERNATIONAL SAS" to finish automatically, without prior notice and definitively, the provision of user’s services.

 

III. Incorporation by reference.

The visitor and user of "GLOBAL EXCHANGE INTERNATIONAL SAS" website is warned that according to Article 44 of Act 527 of 1999, this privacy and protection of personal data policy is an integral part of the conditions of use of "GLOBAL EXCHANGE INTERNATIONAL SAS" website and is incorporated by reference to them. This privacy and protection of personal data policy and its terms will be legally valid as if they had been incorporated in its entirety, in the text of the conditions of use of the website.

 

IV. Guarantee policies for information security

In accordance with this Policy adopted by "GLOBAL EXCHANGE INTERNATIONAL SAS", to process personal data of our users, we inform that the mechanisms through which they are used are safe and confidential since "GLOBAL EXCHANGE INTERNATIONAL" SAS" has the technological means to ensure that such data are stored in a secure manner, guaranteeing confidentiality.

V. Treatment of minors’ data.

For the treatment of personal data of adolescents and / or minors in the range between 15 to 17 years, 11 months and 31 days, who are users of "GLOBAL EXCHANGE INTERNATIONAL SAS", it is prohibited, except in the case of data that are of a public nature and when the treatment meets the following parameters and requirements:
a) That responds and respects the best interests of adolescents and / or minors between 15 to 17 years, 11 months and 31 days.
b) The respect of their fundamental rights must be ensured.
c) Once the above requirements have been met, the legal representative of the child, adolescent and / or minors between 15 to 17 years, 11 months and 31 days, will grant the authorization of the minor's right to be heard, opinion that will be assessed based on the maturity, autonomy and ability to understand the matter.

VI. Processing sensitive data.

Processing sensitive data of "GLOBAL EXCHANGE INTERNATIONAL" SAS" users is prohibited, except in the following cases:
a) When the user has given his explicit authorization to such processing, except in cases in which by law is not required the granting of such authorization.
b) When data processing is necessary to protect the user's personal interest and the user is physically or legally incapacitated. In these cases, legal representatives must grant their authorization.
c) When the processing is carried out during legitimate activities and with due guarantees by a foundation, NGO, association or any other non-profit organization, whose purpose is political, philosophical, religious or trade union, provided that they refer exclusively to their members or to those who keep in touch due to their purpose. In these cases, data cannot be provided to third parties without the Holder’s authorization.
d) When the treatment refers to data that are necessary for the recognition, exercise or defense of a right in a judicial process.
e) When the processing has a historical, statistical or scientific purpose. In this case, measures leading to the suppression of holders’ identity must be adopted.
The user must be warned of the following conditions:
For the processing of his or her sensitive data, the user is not obliged to authorize its processing. In addition to the general requirements of the authorization for the collection of any type of personal data, it must be established explicitly and previously which of the data that will be subject of treatment are sensitive and the purpose that will be given to them, as well as to obtain their express consent.

In the case of data of user’s health, they will be considered part of the Process and/or Application for the processes of "GLOBAL EXCHANGE INTERNATIONAL SAS" and they will have the discretion established in the law for this.

VII. People to whom authorization for data processing can be provided.

The information that meets the conditions established in this policy may be provided to the following people:
a) To the Holders, their successors or their legal representatives.
b) To public or administrative entities in exercise of their legal duties or by judicial order.
c) To third parties authorized by the Holder or by law. Contact Us.
Dear user, if you receive an unsolicited email message, or any threatening or offensive message, or if you consider that another user or any person is violating a right under this privacy and personal data protection policy, send us a complete copy and without modifying the email message with the complete headings to the following electronic address: gerencia.irinaromero@aupaircol.com
Questions that users or any person wishes to ask about what is stated in this privacy and data protection policy, can be formulated at the following electronic address: gerencia.irinaromero@aupaircol.com

PROCESSING HANDBOOK FOR INQUIRIES AND CLAIMS

Users of "GLOBAL EXCHANGE INTERNATIONAL SAS" will be able to access and consult their personal information through the following means that the company has arranged:
Website www.tumejorexperiencia.com
Bogota Customer Service Line
Customer Service Offices in the city Bogotá located at Avenida Carrera 45 (Auto Norte) No. 108 A - 50 OF 802 ED BOSCH.
Telephone: 57 1 3907089

In order to access such information, "GLOBAL EXCHANGE INTERNATIONAL SAS" will perform, prior to the request, verification of the user's identity by requesting confirmation of certain personal data that are stored in the database. Once the identity of the holder has been verified, all the information about your personal data will be provided and any procedure related to them may be carried out.

In the event that the user needs to make an additional inquiry or requires that the information contained on the database of "GLOBAL EXCHANGE INTERNATIONAL SAS" be updated, rectified, modified or deleted, or consider that there is an alleged breach in the protection of your data.

This Privacy and Protection of Personal Data Policy of the users of "GLOBAL EXCHANGE INTERNATIONAL SAS" is effective as of January 1, 2016.
User may submit an inquiry/complaint through the email address gerencia.irinaromero@aupaircol.com, customer service line +57 1 3907089 and the Customer Service Office. The response process to the inquiry/claim from the user will be in charge of Customer Service.

The inquiry/complaint raised by a user must, in all cases, be submitted in writing and must contain, at least, the following points: a) Complete user’s identification (name, notification address, identification document). b) Description of the facts that give rise to the inquiry/claim. c) Supporting documents from the facts.
d) Mean by which you want to receive the answer to your inquiry/claim.
e) In case of an inquiry, the user will be replied within ten (15) business days following the filing of the request. When it is not possible to attend the inquiry within the previous term, the user will be informed, stating the reasons for the delay and indicating the date on which his inquiry will be answered, which in no case may exceed fifteen (15) business days following the expiration of the first term.
f) In the event of a complaint, a response will be given within fifteen (15) business days counted from the day following the date of filing. When it is not possible to attend the claim within said term, the user will be informed of the reasons for the delay and the date on which his claim will be handled, which in no case may exceed fifteen (15) business days following the expiration of the first finished.
g) If "GLOBAL EXCHANGE INTERNATIONAL SAS" is not able to resolve it, it will notify the corresponding party within a maximum term of five (5) business days and inform the situation to the user.