CONTENT OF DATA PROTECTION POLICY
- GENERAL COMPANY INFORMATION
- DATA PROTECTION POLICY
- DEFINITIONS
- SCOPE OF THE POLICY
- PROCESSING OF PERSONAL DATA
- SECTIONS OF THE PRIVACY POLICY FOR USERS OF THE WEBSITE HTTP://MATRIXCPMSOLUTIONS.COM AND CLIENTS OF MATRIX CPM SOLUTIONS
- PERSONAL DATA WE COLLECT AND USE ABOUT YOU
- PURPOSE OF THE PROCESSING OF PERSONAL DATA.
- TEMPORARY LIMITATIONS ON THE PROCESSING OF PERSONAL DATA
- RIGHTS OF PERSONAL DATA HOLDERS
- PROCEDURE FOR THE EXERCISE OF THE RIGHTS OF THE OWNERS
- VALIDITY OF THE PERSONAL DATA PROCESSING POLICY
- MODIFICATIONS TO THE PERSONAL DATA PROCESSING POLICY
- EXCLUSIVE SECTION FOR COLOMBIA OF THE PRIVACY POLICY FOR EMPLOYEES , SUPPLIERS, CONTRACTORS AND THEIR EMPLOYEES OF MATRIX CPM SOLUTIONS
- PERSONAL DATA WE COLLECT AND USE ABOUT YOU
- PROCESSING OF PERSONAL DATA
- PURPOSE OF THE PROCESSING OF PERSONAL DATA
GENERAL COMPANY INFORMATION
COLOMBIA
Name or Business Name MATRIX CPM SOLUTIONS SAS
NIT 900366746-1
City Bogotá DC
Address Carrera 15 No. 93 A 84 Office 309
Area responsible for Data Protection at Matrix CPM Solutions Human Resources
Data Protection Officer at Matrix CPM
Solutions Yeniffer Maria Guzman
Email of the DPO yguzman@matrixcpmsolutions.com
Phone +57 1 9279442
Address for Policy Consultation Carrera 15, #93a-84, office 202
Authority to which complaints or disagreements can be filed Superintendence of Industry and Commerce
MEXICO
Name or Business Name MATRIX CPM SOLUTIONS SA DE CV
RFC MCS160426S81
City Mexico City
Address Heriberto Frías #531, Col. Narvarte Oriente, Benito Juárez Delegation, CP 03023 in Mexico City
Area responsible for Data Protection at
Matrix CPM Solutions Administration
Data Protection Officer at Matrix CPM Solutions Carlos Osorio
Email of the DPO contactos@matrixcpmsolutions.com
Phone +52 55 4430-3031
Address for Policy Consultation It can be consulted on the website http://matrixcpmsolutions.com
Authority to which complaints or disagreements can be filed National Institute of Transparency, Access to Information and Protection of Personal Data (INAI)
VENEZUELA
Name or Business Name MATRIX CPM SOLUTIONS CA
RIF J-314763873
City Caracas
Address Av. San Francisco with Calle Santa Margarita. Urb. Colinas de La California. California Tower Building. Floor 8. Office 8B
Area responsible for Data Protection at Matrix CPM Solutions General Management
Data Protection Officer at Matrix CPM Solutions Ricardo Barreto
Email of the DPO contactos@matrixcpmsolutions.com
Phone +58 212 2562422
Address for Policy Consultation It can be consulted on the website http://matrixcpmsolutions.com
Authority to which complaints or disagreements can be filed Public Prosecutor’s Offices
UNITED STATES
Name or Business Name MATRIX BUSINESS USA CORP
EIN 85-2686924
City Florida
Address 8400 NW 36th St. Suite 450, Doral, Florida 33166, United States
Area responsible for Data Protection at Matrix Business USA Corp General Management
Data Protection Officer at Matrix Business
USA Corp Ronald Rojas
Email of the DPO contact@matrixcorp.business
Phone +1 (954) 361-8716
Address for Policy Consultation It can be consulted on the website http://matrixcpmsolutions.com
Authority to which complaints or disagreements can be filed Federal Trade Commission (FTC)
DATA PROTECTION POLICY
I. DEFINITIONS
Client: Refers to the physical/natural or moral/legal person who has a commercial relationship with MATRIX CPM SOLUTIONS.
Personal Data: Refers to the data about you we collect and use. This information is described in section III.
Employees: Refers to individuals who possess such status in accordance with the applicable legislation in each relevant country.
Matrix CPM Solutions or The Company: Refers to Matrix CPM SOLUTIONS, SAS, Matrix CPM Solutions, SA de CV, Matrix CPM Solutions CA and Matrix Business USA Corp.
Platform: Refers to the website http://matrixcpmsolutions.com operated by the Company.
Owner: Natural person whose personal data is processed.
Treatment: Any action or series of actions performed on personal data, including its collection, storage, use, distribution, or deletion.
II. SCOPE OF THE POLICY
This policy is mandatory and must be strictly adhered to by MATRIX CPM SOLUTIONS as the data controller, as well as by all third parties acting on behalf of MATRIX CPM SOLUTIONS or who, without acting on its behalf, process personal data held by the company in their capacity as processors or third parties.
Both MATRIX CPM SOLUTIONS, in its role as the data controller, and its employees, contractors, and suppliers are required to observe and comply with this policy in the performance of their duties and activities, even after the termination of any legal, commercial, labor, or other type of relationship.
MATRIX CPM SOLUTIONS is committed to maintaining the confidentiality and security of the personal data it handles, and ensures that its employees, contractors, suppliers, and all those with whom it has commercial and legal ties are equally committed to maintaining strict confidentiality regarding the processed data.
This Privacy Policy serves as a supplement to the Service Provision Contracts, Agreements, and/or Confidentiality Agreements that MATRIX CPM SOLUTIONS enters into with its clients in the course of their business relationship.
III. PROCESSING OF PERSONAL DATA
Personal data is collected, stored, organized, used, circulated, transmitted, updated, rectified, suppressed, deleted, and generally managed in accordance with the purpose or purposes outlined in this personal data processing policy.
THIS MARKS THE BEGINNING OF THE SECTIONS OF THE PRIVACY POLICY FOR USERS OF THE WEBSITE http://matrixcpmsolutions.com AND CUSTOMERS OF MATRIX CPM SOLUTIONS
IV. Personal Data we collect and use about you.
To carry out the purposes described in this privacy notice, we will collect, either in person, by telephone, by email or through the website, the personal identification data, contact data and employment data listed below:
Personal identification data: name and surname, country of residence.
Contact information: institutional and/or personal email, cell phone.
Employment data: commercial name and company name of the company in which you work, area of work or business, position held, institutional email
MATRIX CPM SOLUTIONS automatically collects and stores User IP information to analyze trends, administer the Website, and gather demographic information. The IP will not be used to identify Users, except in cases in which possible fraudulent activities are investigated.
MATRIX CPM SOLUTIONS will ensure that the Platform complies at all times with the quality and security standards existing in the market regarding the confidentiality, authenticity and integrity of the information provided by the User. However, it will not be liable for damage that may arise from the violation of these measures by third parties who use public networks or the Internet, subverting security systems to access User information. Nor will it be responsible for any theft of information that occurs between the User’s computer and the Company’s content server. Finally, Matrix CPM Solutions cannot be held responsible for security failures originating in the User’s computer such as viruses, spyware, malware, or third-party attacks.
V. PURPOSE OF THE PROCESSING OF PERSONAL DATA
MATRIX CPM SOLUTIONS necessarily will use the personal data of its Clients and/or Users to:
- Respond and address comments made on the Platform.
- Execute all types of contractual, pre-contractual and commercial relationships.
- Carry out customer service activities including issuing reports, completing procedures, and presenting reports.
- Carry out training, accreditations, updates.
- Provide products and services.
- Carry out the necessary procedures for the payment of contractual obligations .
- Strengthen links with Clients and Users through delivery of relevant information, taking orders, attention to complaints and claims and evaluation of management performance.
Additionally, we will use your personal information for the following secondary purposes that are not necessary for the requested service, but that facilitate and allow us to provide you with better service.
- Carry out marketing and communication activities, including sending, via email or text message, commercial, advertising or promotional information about products and/or services, events and/or promotions.
- To carry out surveys about how to improve our service to you, such as visitor feedback
VI. MECHANISMS SO THAT THE OWNER CAN EXPRESS HIS/HER REFUSAL FOR SECONDARY OR ACCESSORY PURPOSES
The Owner has the right not to grant consent for the processing of his/her Personal Data for the secondary purposes referred to in the previous section. If you do not want your Personal Data to be processed for these additional purposes, you can send an email to protecciondedatos@matrixcpmsolutions.com . Refusal to use your Personal Data for these purposes will not be a reason for us to deny you the Company’s services.
VII. TRANSMISSION OF PERSONAL DATA
The information provided to MATRIX CPM SOLUTIONS will be used only for the purposes indicated in this personal data processing policy, and therefore the information will not be sold, licensed, transmitted or disclosed, except in the cases indicated here.
We inform you that the Company will transmit your Personal Data to the following natural/natural and moral/legal persons, for the purposes established:
- Subsidiary, linked, or subordinate companies of MATRIX CPM SOLUTIONS: The Company will provide, share, send or deliver your personal data to comply with the obligations established through contractual relationships or to carry out any of the activities indicated here, in order to provide services and/or products
- Third Party Service Providers: We hire other companies and people to perform functions that are necessary because they improve and facilitate the operations carried out through the Company, such as data centers of the provider of the platform service based on cloud technology used by MATRIX. CPM SOLUTIONS, companies that offer marketing assistance; call centers that offer customer service; intermediary companies in payment management, credit or debit card payment processing; public and/or private entities that provide credit information, auditors, lawyers and collection offices. These parties will have access only to the personal information necessary and essential to perform their functions.
- To Banks or other commercial companies: the information is related to obtaining credit, a merger, consolidation, acquisition, divestiture, or other restructuring process of the company; that is required or permitted by law.
- Competent authorities: The Company will provide the Personal Data of the User or client to police, judicial, administrative authorities or third parties for the purposes of security of the people, property and facilities of MATRIX CPM SOLUTIONS, as well as to demand and guarantee compliance with the law, and protect industrial and intellectual property rights, prevention of crimes such as fraud or illegal acts, whether or not said information has been required by police, judicial or administrative authority, as well as when the Platform is used to carry out illegal activities, cause damage or harm to the Company, its assets, third parties or other Client Users.
We inform you that we need your consent to transfer Personal Data to companies that offer marketing assistance, so you may express your disagreement with said transfer to the email protecciondedatos@matrixcpmsolutions.com, within a period of 5 (five) natural/continuous days, counted from having accepted this privacy notice. If you do not express your disagreement, we will understand that you have given us your consent for the transfer of your data to the aforementioned people.
The User or Client may send an email to protecciondedatos@matrixcpmsolutions.com, so that their Personal Data is not processed for marketing, advertising or commercial prospecting purposes by us. Likewise, if you wish to stop receiving this type of email, you can select the “Instant deletion with SafeUnsubscribe ™” option in the emails you receive for marketing, advertising or commercial prospecting purposes from us.
Subcontracting.
MATRIX CPM SOLUTIONS may subcontract to third parties for the processing of certain functions or information. When the processing of personal information is actually outsourced to third parties or personal information is provided to third-party service providers, MATRIX CPM SOLUTIONS warns said third parties about the need to protect said personal information with appropriate security measures, prohibits the use of the information to own purposes and requests that personal information not be disclosed to others, protecting it with appropriate mechanisms such as confidentiality and information management policies and agreements.
VIII. TEMPORARY LIMITATIONS ON THE PROCESSING OF PERSONAL DATA
MATRIX CPM SOLUTIONS may only collect, store, use or circulate personal data for as long as is reasonable and necessary, in accordance with the purposes that justified the treatment, taking into account the provisions applicable to the matter in question and the administrative aspects. , accounting, fiscal, legal and historical information. Once the purpose(s) of the processing have been fulfilled and without prejudice to legal regulations that provide otherwise, the personal data in its possession will be deleted. However, personal data must be preserved when required to comply with a legal or contractual obligation.
IX. RIGHTS OF PERSONAL DATA HOLDERS
Rights of Personal Data Holders
- Right of Access
The Owner of the data will be able to access the personal data that is under the control of MATRIX CPM SOLUTIONS, and know what we use them for and the conditions of use that we give them, for the purposes of consulting them for free at least once every calendar month. , and whenever there are substantial modifications to the Data Processing Policies that motivate new queries.
- Right to Update and Rectify
The Data Owner may at any time request the updating and rectification of the personal data being processed that is in the possession of the person responsible or in charge of the treatment if it is outdated, inaccurate or incomplete.
- Right to Revocation of Authorization and Deletion
The Data Owner may revoke the authorization and/or request the deletion of the data when the Processing does not respect constitutional and legal principles, obligations, rights and guarantees.
The revocation and/or deletion will be carried out when the owner of personal data has complied with the legal and/or constitutional procedures applicable in each country and the competent administrative and/or judicial authority has determined by firm decision that the person responsible or in charge have engaged in conduct contrary to the rights of the owners.
The request for deletion of information and revocation of authorization will not proceed when the Owner has a legal or contractual duty to remain in the database or the person responsible has a legal or contractual duty to continue the treatment.
- Right to Oppose
The Data Owner may object to the use of his or her personal data for specific or secondary purposes.
- Right to Request Proof of Authorization
The Data Owner may request evidence of the authorization provided to the Data Controller, except in cases where such proof is explicitly exempted as a requirement for processing.
- Right to Be Informed Regarding the Use of Personal Data
The data owner has the right to be informed by the Data Controller or the Data Processor, upon request, regarding the use that has been given to their personal data.
X. PROCEDURE FOR THE EXERCISE OF THE RIGHTS OF THE OWNERS
To respond to requests, complaints, claims, access , know, update, rectify, cancel, oppose or delete information and revoke the authorization formulated by every owner of personal data in the exercise of constitutional rights and in this Data Processing Policy. Personal, MATRIX CPM SOLUTIONS establishes the following:
PROCEDURE
The owner of the personal data or whoever acts as his representative may:
- a) Send a request to the email protecciondedatos@matrixcpmsolutions.com; Applications will be reviewed Monday through Friday from 8:00 a.m. to 5:00 p.m.
- b) Call the telephone line published at the top of this Policy for the country of your residence; or file a document at the address published at the top of this Policy for the country of your residence, addressed to MATRIX CPM SOLUTIONS
CONTENT OF THE APPLICATION
The request must include the full identification of the Data Owner, documents verifying their identity or, if applicable, the authority of the representative. It should also provide a detailed account of the facts, a clear and precise description of the Personal Data in question, any additional information or documents that aid in locating the Personal Data, the physical and electronic addresses where the response should be sent, a contact telephone number, and any supporting documents you wish to submit.
ATTENTION TO THE REQUEST
The Request will be responded to within a maximum period of ten (10) business days from the date of receipt. When it is not possible to attend to the query within said term, the interested party will be informed, expressing the reasons for the delay and indicating the date on which their query will be attended to, which in no case may exceed five (5) business days following the expiration of the first term.
REQUIREMENT FOR ADDITIONAL INFORMATION OR DOCUMENTATION
If the information or documents received are incomplete, the interested party will be required within five (5) days following receipt of the request to correct the deficiencies. After two (2) months from the date of the request, without the applicant presenting the required information, it will be understood that he or she has withdrawn from the application. In the event that the person receiving the request is not competent to resolve it , he or she will forward it to the appropriate person within a maximum period of two (2) business days and will inform the interested party of the situation.
Once the complete application is received, a legend that says “application in process” and the reason for it will be included in the database, within a period of no more than two (2) business days. This legend must be maintained until the request is resolved.
The maximum period to address the claim is fifteen (15) business days, starting from the day after the claim is received. If it is not possible to resolve the claim within this period, the interested party will be informed of the reasons for the delay and the expected resolution date, which shall not exceed eight
(8) business days beyond the initial deadline.
XI. USE OF COOKIES, WEB BEACONS, HTTP PROTOCOL OR ANY OTHER SIMILAR OR ANALOGUE TECHNOLOGY
The User or Client knows and accepts that the platform uses Cookies.
Cookies are small pieces of information that are sent by the Platform to your browser and are stored on the hard drive of the computer on which the website was accessed and are used to determine your preferences when you connect to the Company’s services. as well as to track certain behaviors or activities carried out by you within the website.
In certain sections of our site, we require that cookies be enabled as some functionalities depend on them to operate. Cookies allow us to: a) recognize you when you visit our site, offering a personalized experience; b) remember your specified site preferences; and c) calculate our audience size and measure traffic parameters. Each browser that accesses our site receives a cookie, which helps us determine usage frequency and the sections visited. This information reflects your habits and preferences, which we use to improve the content of our platform.
Cookies also help us track online surveys by detecting if a survey has already been completed, ensuring it is not displayed again.
Cookies will not be used to identify Users or Clients, except in cases in which possible fraudulent activities are investigated.
In the case of the use of cookies, the “help” button found in the toolbar of most browsers will tell you how to avoid accepting new cookies, how to have the browser notify you when you receive a new cookie or how to disable all cookies.
Cookies can be blocked by entering the content management section of your internet browser. This action could influence the ability to use the Platform however, since it offers certain functionalities that are only available through the use of Cookies. .
Regardless of whether cookies are disabled, web servers using HTTPS technology (Hypertext Transfer Protocol Secure) can log information such as the device’s IP address, date and time of the HTTPS request, the requested page, the HTTPS response code, the number of bytes served, the user agent, and the originating site. However, this information cannot be linked to a specific individual and is therefore not considered Personal Data.
XII. THIRD PARTY ELECTRONIC LINKS
To provide greater value to Clients and Users, the Platform may contain electronic links, hyperlinks, or “Hot Links” to other websites sponsored, managed, and/or operated by external providers and organizations closely associated with the Company. However, even when these providers are allied with the Company, the Company has no control over these linked websites, which have their own privacy policies and data collection practices independent of the Company’s.
The Company is not responsible for the independent policies and actions of other companies on their websites regarding privacy practices, content management, data collection, and other matters. These electronic links, hyperlinks, or “Hot Links” are provided for the convenience of Users and Visitors; therefore, accessing other websites linked from the Platform is at their own risk and responsibility.
XIII. VALIDITY OF THE PERSONAL DATA PROCESSING POLICY
The effective date of this Personal Data Processing Policy is September 1, 2018.
Personal data that is stored, used or transmitted will remain in the MATRIX CPM SOLUTIONS
Databases for as long as necessary to fulfill the purposes mentioned in this document.
XIV. MODIFICATIONS TO THE PERSONAL DATA PROCESSING POLICY
This Personal Data Processing Policy may be modified at any time by MATRIX CPM SOLUTIONS. It will be available to employees, contractors, suppliers, clients and the general public in its updated version at the address indicated at the top of the Policy for your country of residence.
If changes are made to the formal part of the procedures, such as changes in address, telephone number, contact emails, URL, area in charge, they will be reflected in the document and made known through the company’s website or by suitable mechanisms that allow the consultation of documents.
In accordance with legal provisions, if there are any changes to the purposes for which personal data is processed, the owners of the personal data registered in the company’s databases will be notified. The latest version of the Personal Data Processing Policy will be made available to them, along with the appropriate form to obtain a copy of their updated authorization.
EXCLUSIVE SECTION FOR COLOMBIA: PRIVACY POLICY OF MATRIX CPM SOLUTIONS FOR EMPLOYEES, SUPPLIERS, CONTRACTORS AND THEIR EMPLOYEES
In accordance with Law 1581 of 2012 and Regulatory Decree 1377 of 2013, this section is created for employees, suppliers, contractors and their employees to detail the purposes of the data collected.
- PERSONAL DATA WE COLLECT AND USE ABOUT YOU.
- PROCESSING OF PERSONAL DATA
Personal data is collected, stored, organized, used, circulated, transmitted, updated, rectified, deleted, eliminated and in general managed in accordance with the purpose or purposes indicated in this personal data processing policy and this section. .
III. PURPOSE OF THE PROCESSING OF PERSONAL DATA EMPLOYEES AND/OR WORKERS
MATRIX CPM SOLUTIONS may use the personal data of its employees and/or workers to:
- Develop the selection, evaluation and job placement process.
- Execute the contractual relationship including the payment of contractual obligations.
- Send information reports to the entities that are part of the comprehensive Social Security System and/or Occupational Prevention, Health and Safety System of each country and other entities through which benefits are provided to the worker or legal obligations are met.
- Support internal or external audit processes
- Carry out communication, registration, accreditation, organization, updating, assurance, processing, investigation, security, planning, improvement, processing of legal defense and management of actions derived from the employment relationship.
- Issue certifications related to the employee’s relationship with MATRIX CPM SOLUTIONS after the employment relationship has ended, as well as to classify, store, and file Personal Data in accordance with legal regulations. Additionally, the company may provide information to administrative or judicial authorities upon request, as well as information that may be of interest to the data owner.
- Carry out training, accreditations, updates.
- Register the information of employees and/or workers and/or pensioners (active and inactive) in the databases.
- Provide, share, send or deliver your personal data to affiliated, linked, or subordinate companies of MATRIX CPM SOLUTIONS located in Colombia or any other country to comply with the obligations established in the contractual relationship or to carry out any of the activities here. pointed out.
- Carry out activities for employees and/or workers and their families that are related or linked to MATRIX CPM SOLUTIONS.
- Transfer the data to the countries where the data centers of the provider of the platform service based on cloud technology used by MATRIX CPM SOLUTIONS are located and deliver the personal data to the service provider, who in that event will act as Data Processor.
- Use the data for the security of individuals, property, and facilities of MATRIX CPM SOLUTIONS, and as evidence in any proceedings before police, judicial, or administrative authorities.
SUPPLIERS, CONTRACTORS AND THEIR EMPLOYEES AND/OR WORKERS
MATRIX CPM SOLUTIONS may use the personal data of suppliers, contractors and employees and/or workers of the contractors to:
- Execute contractual, pre-contractual and commercial relationships
- Carry out the necessary procedures for the payment of contractual obligations
- Carry out training, accreditations, updates.
- Carry out all activities necessary for the effective provision of products and services.
- Carry out communication, registration, organization, updating, processing, control, accreditation, assurance, security, statistics, reporting, legal defense and management activities.
- Provide, share, send or deliver your personal data to affiliated, linked, or subordinate companies of MATRIX CPM SOLUTIONS located in Colombia or any other country to comply with the obligations established in the contractual relationship or to carry out any of the activities here. pointed out.
- Carry out all activities in which suppliers, contractors and their employees are related or linked to MATRIX CPM SOLUTIONS.
- Transfer the data to the countries where the data centers of the provider of the platform service based on cloud technology used by MATRIX CPM SOLUTIONS are located and deliver the personal data to the service provider, who in that event will act as Data Processor.
- Use the data for the security of individuals, property, and facilities of MATRIX CPM SOLUTIONS, and as evidence in any proceedings before police, judicial, or administrative authorities.