Privacy Policy

IDENTIFICATION OF THE CONTROLLER

In accordance with Law 1581 of 2012, Decree 1074 of 2015, and any regulations that amend, supplement, or replace them, MARKET SUPPORT S.A.S., a Colombian company identified with Tax ID (NIT) 901.153.487-8, domiciled in Bogotá at Carrera 7 # 156 – 10, Office 1707 – North Point Torre Krystal, with email contact soporte@market-support.com and phone number +57 1 3023770130, will collect, use, store, transmit, and in general process personal data in its capacity as Data Controller.

The data provided may be used by MARKET SUPPORT S.A.S. to ensure efficient communication regarding our services, offers, partnerships, research, and content; to provide our services; to fulfill obligations undertaken with our clients, suppliers, and employees; and to evaluate service quality. This includes the collection, storage, copying, delivery, updating, use, organization, classification, transfer, correction, verification, and statistical use of the data provided.

In addition to these general purposes, there are specific purposes depending on the relationship individuals have with MARKET SUPPORT S.A.S., as described below:

  • To obtain essential customer data for subsequent communication regarding their products.
  • To ensure efficient communication regarding our services and partnerships through various channels.
  • To provide information about campaigns and special offers.
  • To inform and invite individuals to marketing campaigns, service promotions, and user education initiatives.
  • To conduct satisfaction surveys regarding services provided.
  • To respond to, manage, and follow up on improvement requests, petitions, and suggestions.
  • To improve service quality.
  • To send information about services and scheduled events via physical mail, email, mobile phone, text messages (SMS and/or MMS), or any other current or future analog and/or digital communication method, for the purpose of promoting, inviting, directing, executing, and informing.

SPECIAL PURPOSES FOR PROCESSING EMPLOYEES’ PERSONAL DATA

Internal and external publications.

Granting access to the organization’s technological platforms.

Providing information to companies requesting verification of employees’ work data for the approval of financial or commercial credit (after verifying the source and purpose of the data, focusing on verification rather than disclosure of information).

Direct contact when required due to their job functions.

Identifying training needs and implementing actions to ensure excellent service delivery.

Informing and managing internal election and promotion processes.

Supporting internal or external audit processes.

Special purposes for processing applicants’ personal data.

Carrying out internal selection and promotion processes.

SPECIAL PURPOSES FOR PROCESSING SUPPLIERS’ AND CONTRACTORS’ PERSONAL DATA

Evaluation of goods and services provided by suppliers and contractors.

Monitoring and managing the contractual relationship.

Special purposes for processing personal data of visitors and other community users.

Ensuring the safety of clients, visitors, employees, and the general community within MARKET SUPPORT S.A.S. facilities.

DATA PROCESSING

With respect to data:

  1. Collected directly through the website https://www.MARKET-SUPPORT.COM, as well as through other electronic and/or physical communication channels that MARKET SUPPORT S.A.S. maintains with its clients.
  2. Obtained from documents provided to the commercial and/or support staff of MARKET SUPPORT S.A.S. These will be used to create the client file for the purpose of ensuring the security of individuals, property, and facilities of MARKET SUPPORT S.A.S., and may be used as evidence in any type of proceeding. If personal data is provided, it will be used solely for the purposes stated herein, and therefore MARKET SUPPORT S.A.S. will not sell, license, transmit, or disclose such data, except when:
  3. There is express authorization to do so;
  4. It is required or permitted by law.

MARKET SUPPORT S.A.S. may subcontract third parties to process certain functions or information. When personal data processing is subcontracted or personal data is provided to third-party service providers, MARKET SUPPORT S.A.S. will inform such third parties of the need to protect the information with appropriate security measures, prohibit its use for their own purposes, and request that it not be disclosed to others.

Personal data of employees may also be processed by MARKET SUPPORT S.A.S. for the proper management of the employment relationship.

PERSONAL DATA PROCESSING POLICY

MARKET SUPPORT S.A.S., a Colombian company identified with Tax ID (NIT) 901.153.487-8, domiciled in Bogotá at Carrera 7 # 156 – 10, Office 1707 – North Point Torre Krystal, with email soporte@market-support.com and phone number +57 1 3023770130, in accordance with Law 1581 of 2012 and Regulatory Decree 1377 of 2013, as the party responsible for the processing and safeguarding of personal data, informs that over several years it has collected, stored, and used individuals’ information for the following purposes:

  1. Providing hosting services, domain registration, email services, and other internet-related services.
  2. Commercial purposes.
  3. Promotional purposes.
  4. Marketing activities and/or promotion of its own services or those provided through partnerships with MARKET SUPPORT S.A.S.
  5. Complying with requirements established by regulatory and supervisory authorities and other competent authorities. In compliance with applicable regulations, it is necessary to implement the data protection policy established in Law 1581 of 2012 and its regulatory decrees.

LEGAL FRAMEWORK AND SCOPE OF APPLICATION:

This Personal Data Processing Policy has been prepared in accordance with the Political Constitution of Colombia, Law 1581 of 2012, Regulatory Decree 1377 of 2013, and other complementary provisions, and will be applied by MARKET SUPPORT S.A.S. with respect to the collection, storage, use, circulation, deletion, and all other activities that constitute personal data processing.

Special purposes for processing clients’ data:

  1. To obtain essential customer data for subsequent communication regarding their products.
  2. To ensure efficient communication regarding our services and partnerships through various channels.
  3. To provide information about campaigns and special offers.
  4. To inform and invite individuals to marketing campaigns, service promotions, and user education initiatives.
  5. To conduct satisfaction surveys regarding services provided.
  6. To respond to, manage, and follow up on improvement requests, petitions, and suggestions.
  7. To improve service quality.
  8. To send information about services and scheduled events via physical mail, email, mobile phone, text messages (SMS and/or MMS), or any other current or future analog and/or digital communication method, for the purpose of promoting, inviting, directing, executing, and informing.

Special purposes for processing suppliers’ and contractors’ personal data

  • Evaluation of goods and services provided by suppliers and contractors.

PROCESSING TO WHICH PERSONAL DATA MAY BE SUBJECT

  1. Consultation
  2. Administrative procedures
  3. Sending information
  4. Research
  5. Requesting completion of surveys
  6. Making phone calls

Note: Regarding the processing of sensitive data, the law allows such data to be processed only when:

  1. The data subject has given explicit authorization for such processing, except in cases where authorization is not required by law.
  2. The processing is necessary to safeguard the vital interest of the data subject and the subject is physically or legally unable to grant authorization. In such cases, legal representatives must grant authorization.
  3. The processing is carried out in the course of legitimate activities and with appropriate safeguards by a foundation, NGO, association, or any other non-profit organization with political, philosophical, religious, or trade union purposes, provided that the data relates exclusively to its members or to individuals who maintain regular contact in connection with its purposes. In such cases, the data may not be disclosed to third parties without the data subject’s authorization.
  4. The processing relates to data necessary for the recognition, exercise, or defense of a right in a judicial proceeding.
  5. The processing has a historical, statistical, or scientific purpose. In such cases, measures must be adopted to remove the identity of the data subjects.
  6. Likewise, the processing of personal data of children and adolescents will be carried out under the parameters set forth in this policy.

INQUIRIES

Data subjects or their successors may consult the personal information of the data subject contained in any database of MARKET SUPPORT S.A.S., which will provide all information contained in the individual record or linked to the identification of the data subject.

Inquiries may be submitted through the various physical or electronic channels enabled for this purpose, provided that proof of submission can be maintained.

The inquiry will be addressed within the term established by law, counted from the date it is received at the facilities of MARKET SUPPORT S.A.S. when submitted physically, or at the email address [soporte@market-support.com](mailto:soporte@market-support.com) when submitted electronically. If it is not possible to respond within such term, the interested party will be informed of the reasons for the delay and the date on which the inquiry will be addressed, which in no case may exceed five (5) business days following the expiration of the initial term.

PROOF OF AUTHORIZATION

MARKET SUPPORT S.A.S. will implement the necessary physical and electronic means to preserve proof of authorization granted by data subjects for the processing of their personal data, regardless of the method through which such authorization was obtained.

PRIVACY NOTICE

If MARKET SUPPORT S.A.S. is unable to make this information processing policy available to the data subject, it will publish the privacy notice attached to this document, the text of which will be retained for subsequent consultation by the data subject and/or the Superintendence of Industry and Commerce.

SECURITY MEASURES

To comply with the security principle established in Article 4, subsection (g) of Law 1581, MARKET SUPPORT S.A.S. has implemented internal information security mechanisms and database management procedures to prevent alteration, loss, unauthorized consultation, use, or fraudulent access.

PETITIONS, COMPLAINTS, AND CLAIMS

The data subject has the right to file any type of claim regarding their personal data by submitting a written request addressed to MARKET SUPPORT S.A.S. via email to soporte@market-support.com, indicating in the subject line “PQR – Market Support.” The request must include:

  • Full name of the data subject.
  • Copy of ID document.
  • Description of the petition, complaint, or claim.

If the data subject fails to provide these requirements or submits them incompletely, they will have fifteen (15) business days to resubmit the request; otherwise, it will be understood that they have withdrawn the claim. MARKET SUPPORT S.A.S. has fifteen (15) business days to respond to the request, counted from the date the email is received.

EFFECTIVE DATE OF THE INFORMATION PROCESSING POLICY AND DATA RETENTION PERIOD

This Personal Data Processing Policy of MARKET SUPPORT S.A.S. has been in effect since January 2022. MARKET SUPPORT S.A.S. will retain personal data for as long as necessary or relevant for the purposes for which it was collected and as long as the data subject authorizes its processing.