Privacy Policy
INNPACTIA S.A.S. PERSONAL DATA TREATMENT POLICY
In compliance with the Political Constitution of Colombia, Law 1581 of 2012, Regulatory Decree 1377 of 2013, and other complementary provisions, this Personal Data Treatment Policy (hereinafter "the Policy") establishes how INNPACTIA S.A.S. (hereinafter "INNPACTIA"), a duly constituted company in Colombia, identified with Tax ID No. 900.979.106, domiciled in the city of Bogotá, D.C., and with offices at Carrera 22 No. 80-73, email address usuarios@innpactia.com, and telephone number (57 1) 6453135, collects and processes your personal data (hereinafter "Personal Data").
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Personal Data subject to treatment by INNPACTIA
In order to fulfill the obligations and activities described in section 2 of this Policy, INNPACTIA directly collects the following Personal Data:
Common to all Data Subjects:
- Name and surname
- Identification document number
- Nationality
- Address
- Physical mailing address
- Email address
- Cell phone number
- Profile picture
- LinkedIn URL
- Website
Specific to each category of Data Subjects
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Users of the INNPACTIA Platform and other clients
- Username/profile
- Contact details of natural persons who serve as contacts for the client, in the case of legal persons
- History of services contracted with INNPACTIA and/or through the INNPACTIA Platform
- History of ratings given to services acquired through the INNPACTIA Platform and/or to the advisors who provided them
- Information related to projects classified by the user as public and private (name, theme, budget)
Development Projects:
- Project name
- Country, province, municipality, nature of the territory
- Project theme
- Sustainable Development Goals of the project
- Number and type of beneficiaries
- Description of beneficiaries
- Population, community, and/or territory issues
- Origin of the situation
- Involvement with the problem
- Consequences of not addressing it
- General and specific objectives of the project
- Project duration and schedules
- Economic amount awarded to the project so far
- Approximate cost of the total project
- Main contact: Name and surname, role, email address
- Team details: Name and surname, position, gender, LinkedIn, CV
Triple Impact Business Project:
- Project name
- Country, province, municipality, nature of the territory
- Project theme
- Financing search objective
- Needs or problems of clients
- Details of the company's products and/or services
- Value proposition
- Description of potential customers for your products and/or services
- Strategies for finding new customers
- Communication channels with customers
- How much money they are seeking
- How they will generate income
- Information about strategic alliances they have
- Definition of directly or indirectly impacted population
- Population, community, and/or territory issues
- How the company is supporting or solving the problems of the beneficiaries, community, and/or territory
- Organization's experience regarding the themes mentioned in this project
- Main contact: Name and surname, role, email address
- Team details: Name and surname, position, gender, LinkedIn, CV
Historical Data of Private or Public Conversations with Other Users and Advisors through Innpactia Platform Tools
Historical Data of User Preferences and/or Interactions on the Innpactia Platform
**Billing Details:**
- Plan
- Plan Description
- Subscription Date
- Payment Frequency
- Payment Gateway
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Advisors
- Banking information for payments (account number and type, bank)
- Historical ratings received from Innpactia Platform users
- Tax Identification Number
- Payoneer payment email
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Financiers
- Entity Name
- Contact Email
- Website
- Address
- Type of support provided
- Type of financier
- Legal form or nature
- Country of origin
- Brief description of the institution
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Contractors, Workers, and Suppliers of INNPACTIA
- Banking information for payments (account number and type, bank)
- Bank references
- Personal and professional references
- Affiliations to the social security system and payment history
- Affiliation to occupational risk administrators and payment history
- Username and passwords assigned in the provided work tools such as Slack, Gmail, Asana, etc.
- Historical activities carried out in the provided work tools such as Slack, etc.
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Applicants to provide services to INNPACTIA under a labor contract or service provision contract
- Curriculum vitae
- Personal and professional references
**Sensitive Data**
Your personal image may be captured through the cameras installed in the INNPACTIA offices when you visit our premises.
Additionally, your personal image, voice, and opinions during mentoring sessions, webinars, and masterclasses may be recorded during the sessions by INNPACTIA, and subsequently used for promotion and publication on all its communication channels.
2. Treatment of Personal Data and its Purposes
INNPACTIA will collect, store in its databases, use, circulate, and delete Personal Data in order to fulfill the normal development of its corporate purpose and the relationship it maintains with its data subjects, in any capacity. In this context, INNPACTIA will process your Personal Data for the following purposes:
**General:**
INNPACTIA collects your Personal Data through various sources of information such as personal or work-related electronic messages, through the website www.innpactia.com, or physical correspondence, by information already existing in INNPACTIA's databases, through voice messages, information stored on INNPACTIA's computers and electronic devices, fax systems, internet access, correspondence, or through any other electronic device for communications and any other technological resource.
INNPACTIA also has security cameras in its offices, through which your personal image will be recorded each time you visit them. Only INNPACTIA staff will have access to these images in case of violation or suspicion of violation of the security measures implemented and required for a business like ours.
INNPACTIA communicates with data subjects through phone calls, emails, messages via the WhatsApp instant messaging application, messages through INNPACTIA Platform tools, SMS, or MMS. INNPACTIA may deliver messages to the following mobile operators: Major operators: AT&T, Verizon Wireless, Sprint, T-Mobile, MetroPCS, U.S. Cellular, Alltel, Boost Mobile, Nextel, and Virgin Mobile. Minor operators: Alaska Communications Systems (ACS), Appalachian Wireless (EKN), Bluegrass Cellular, Cellular One of East Central IL (ECIT), Cellular One of Northeast Pennsylvania, Cincinnati Bell Wireless, Cricket, Coral Wireless (Mobi PCS), COX, Cross, Element Mobile (Flat Wireless), Epic Touch (Elkhart Telephone), GCI, Golden State, Hawkeye (Chat Mobility), Hawkeye (NW Missouri), Illinois Valley Cellular, Inland Cellular, iWireless (Iowa Wireless), Keystone Wireless (Immix Wireless/PC Man), Mosaic (Consolidated or CTC Telecom), Nex-Tech Wireless, NTelos, Panhandle Communications, Pioneer, Plateau (Texas RSA 3 Ltd), Revol, RINA, Simmetry (TMP Corporation), Thumb Cellular, Union Wireless, United Wireless, Viaero Wireless, and West Central (WCC or 5 Star Wireless). Charges may be incurred for the transmission of such messages based on the data subject's telecommunications service provider rates.
INNPACTIA will store Personal Data in its physical and digital files. In compliance with its legal duties and as a mechanism for protecting the Personal Data subject to its treatment, INNPACTIA will limit itself to processing them for authorized purposes, only transmitting them to clients or third parties when necessary as a result of INNPACTIA's ordinary course of operations, and to judicial and administrative authorities when required by court or administrative order.
**By Categories of Data Subjects**
**2.1. Users of the Innpactia Platform and other INNPACTIA clients**
The purposes of processing personal data provided by users of the Innpactia Platform and other clients are:
- Provision of contracted services
- Compliance with contractual and legal obligations
- Billing of contracted services
- Collection and debt recovery
- Reporting to credit bureaus
- Sending commercial information for promotional and marketing purposes
- Sending information about updates to Terms and Conditions and Personal Data Treatment Policy
- Conducting evaluations and/or surveys related to user satisfaction levels of the Innpactia Platform
- Transmission or transfer of personal data to third parties in compliance with contractual obligations and legal duties
- Statistical and applied research purposes for improvement and future developments of the Innpactia Platform
- Promotion of interactions between different categories of users within the Innpactia Platform
- Inclusion of information about public projects in the Innpactia Platform Project Bank
- Promotion of projects included in the Project Bank to registered financing users in the Innpactia Platform communication lists
- Continuation or cancellation of subscription to the INNPACTIA Platform.
**2.2. INNPACTIA Advisors**
The purposes of processing personal data provided by advisors are:
- Monitoring the provision of contracted services
- Compliance with contractual and legal obligations
- Sending commercial information for promotional and marketing purposes
- Sending information about updates to Terms and Conditions and Personal Data Treatment Policy
- Processing evaluations and/or surveys related to user satisfaction with the INNPACTIA Platform
- Continuation or cancellation of the account on the INNPACTIA Platform
- Transmission or transfer of personal data to third parties in compliance with contractual obligations and legal duties.
**2.3. INNPACTIA Contractors, Workers, and Suppliers**
The purposes of processing personal data provided by contractors and workers of INNPACTIA are:
- Classification, storage, and archiving of personal data
- Compliance with obligations derived from the contract concluded with the Data Subject
- Compliance with legal obligations regarding social security and parafiscal contributions
- Providing information to judicial and administrative authorities when there are judicial and/or administrative orders to that effect
- Providing information to internal or external auditors, attorneys, and potential investors or buyers in the event of the sale of the company or the incorporation of new shareholders, if required.
**2.3. Applicants to Provide Services to INNPACTIA**
The purposes of processing personal data provided by applicants to provide services to INNPACTIA through the signing of an employment contract or service provision contract are:
- Conducting a selection process
- Obtaining personal and/or professional references
- Obtaining judicial and administrative background checks.
3. Your Rights as Data Subject
In accordance with Article 8 of Law 1581 of 2012, INNPACTIA informs you that you have the following legal rights:
- Know, update, and correct your Personal Data with INNPACTIA. This right can be exercised, among others, in relation to information that is partial, inaccurate, incomplete, misleading, or whose processing is prohibited or unauthorized.
- Request proof of consent granted to INNPACTIA for the collection and processing of your Personal Data, have access to your Personal Data processed by INNPACTIA, and in general, be informed by INNPACTIA about the processing being carried out on your Personal Data. For this, it is important to follow the procedures established in section 6 of this Privacy Policy.
- Revoke the authorization granted to INNPACTIA and/or request the deletion of your Personal Data when you consider that INNPACTIA is not respecting constitutional and legal principles, rights, and guarantees. In these cases, INNPACTIA will inform you about the implications of revoking the authorization or deleting your Personal Data from the database.
- Access the Personal Data that INNPACTIA has collected and processed.
If you are not satisfied with how INNPACTIA handles your Personal Data or have any complaints or grievances, you may submit a complaint to INNPACTIA's data protection officer at the email address usuarios@innpactia.com.
If INNPACTIA's data protection officer does not resolve your concerns or address your complaint, you may contact the Superintendence of Industry and Commerce to raise your concerns, complaints, or grievances if you believe that INNPACTIA has violated your data protection rights or the provisions of Law 1581 of 2012, Decree 1377 of 2013, and other regulations that modify, add, or complement them.
4. Individuals or Department Responsible for Responding to Queries, Requests, or Complaints Related to the Processing of Your Personal Data
If you have questions, inquiries, or complaints related to your Personal Data, you can contact INNPACTIA's Data Protection Officer at the email address usuarios@innpactia.com (hereinafter the "Data Protection Officer"). You can exercise your right to know, update, rectify, or delete your Personal Data and revoke the consent granted to INNPACTIA for the processing of your Personal Data with this individual or department at INNPACTIA.
5. INNPACTIA Security Policy
INNPACTIA takes effective, appropriate, and reasonable measures to protect your Personal Data from loss, misuse, unauthorized access, disclosure, alteration, and destruction.
6. Procedure for Exercising Your Rights
Any questions or inquiries regarding your Personal Data collected and processed by INNPACTIA will be received by the Data Protection Officer of INNPACTIA. You should send a written description of your inquiry to the email address usuarios@innpactia.com.
The Data Protection Officer of INNPACTIA will address your question or inquiry within ten (10) business days from the date the question or inquiry is received. If it is not possible for the Data Protection Officer of INNPACTIA to respond to your claim within the mentioned term, the Data Protection Officer of INNPACTIA will inform you of the situation and explain the reason for the delay. In any circumstance, the Data Protection Officer of INNPACTIA will respond to you within five (5) business days following the expiration of the initial ten (10) business days term.
The consent given by you may be revoked at any time, with prior notice, written and signed, addressed to the Data Protection Officer of INNPACTIA, at the aforementioned email address, under the terms established by law.
If you believe that the information contained in INNPACTIA's database is subject to correction, updating, or deletion, or if you believe that INNPACTIA is not complying with its obligations established in Law 1581 of 2012, you must file a complaint with INNPACTIA, addressed to the Data Protection Officer, which will be processed according to the procedure established in Article 15 of Law 1581 of 2012.
7. Effective Date of the Policy and Database Expiry Date
This privacy policy will come into effect on January 1, 2023, and your Personal Data will remain in INNPACTIA's database until they fulfill the purpose for which they were collected, or at the end of the established time period when a legal provision intervenes.