TRANSBANK LTDA  Privacy Policy

Basic Information

Data Controller: Compañía Colombiana De Seguridad Transbank Ltda (hereinafter, “TRANSBANK”).

Main purpose of data processing: establish, maintain and manage the pre-contractual or contractual, shareholder and / or commercial relationship between you and TRANSBANK. 

Legitimisation: the data will be processed mainly based on the execution of the service contract between you and TRANSBANK, compliance with a legal obligation, obtaining consent and legitimate interest. 

Recipients of the data:

  • Third parties to which TRANSBANK is obliged to transmit information, such as public authorities, security forces and bodies, judges and courts, in order to comply with the requirements of said authorities and the applicable regulations, if applicable.
  • Companies within the business group to which TRANSBANK belongs (hereinafter, the “Grupo PROSEGUR”) as a result of the centralization of administrative and IT processes existing within the Grupo PROSEGUR.

Data protection rights: you may withdraw your consent for personal data processing activities performed by TRANSBANK at any time and exercise, at your discretion, your rights of access, amendment, erasure, limitation or opposition to data processing, data portability, and not to be subject to automated decisions, as indicated in the section on “Your Data Protection Rights” in our Privacy Policy.

 

Additional Information 1. Data Controller

1.1 Information of the Data Controller

The present document governs the privacy policy of the TRANSBANK website (hereinafter also referred to as the "Website”). 

TRANSBANK provides a wide range of services, ranging from basic logistics services to outsourcing high value-added services. The company's activity is mainly focused on the banking and distribution sector. 

For your information, the identity details of the company are provided below:


Business name:    Compañía Colombiana De Seguridad Transbank Ltda
Tax ID No.:    900.170.865
Address:    Calle 19 #68b-76 Bogotá D.C., Colombia
Contact:    protecciondedatostransbank@prosegur.com o 018000129980.

1.2. Scope

This Privacy Policy regulates the data processing carried out by TRANSBANK in relation to the users of the TRANSBANK corporate website. The foregoing would include the processing of personal data of (i) suppliers and / or potential suppliers; (ii) clients and / or potential clients; and / or (iii) shareholders; that access or transmit information through the website. Therefore, this privacy policy reflects the information related to the treatment with respect to the different categories of interested parties indicated.
 

2. Purposes and Legitimisation

You are hereby informed that all the data that TRANSBANK requests or may request from you are required for the purposes described in this privacy policy and failing to provide them would make it impossible to contact you or handle the request made with TRANSBANK. Furthermore, TRANSBANK reserves the right to refrain from responding or handling requests that do not include the data requested.

You hereby guarantee the accuracy of the personal details provided to TRANSBANK. TRANSBANK may periodically ask that you revise and update your personal data. 

On the Website you can find information that may be useful in order to find out about the services offered by TRANSBANK, as well as information related to the company. In this sense, TRANSBANK will only request and process the necessary data to be able to initiate and maintain a commercial and / or contractual relationship with you, provide the contracted service, and / or, where appropriate, be able to offer you company information that results from your interest, whether due to their status as a client, potential client, supplier or potential supplier or shareholder.

The following describes the legitimacy bases used that support the processing of your personal data, as well as their different purposes:


2.1. In the event that you are a client or potential client of TRANSBANK

Next, the different purposes for which your personal data are processed and the bases that legitimize the treatment are described, in case of being a client or potential client:


i.    Legitimization for the execution of the service contract between you and TRANSBANK or application of pre-contractual measures:

  • Manage the commercial relationship with potential clients, making commercial visits and responding to requests for information on products and services offered by TRANSBANK.
  • Formalize the contractual relationship, which will include the process of contracting and signing contracts.
  • Manage the contractual relationship with the clients of the Grupo PROSEGUR and ensure the provision of the contracted services, which includes both installation assistance and technical service, as well as billing, collection and cancellation of the same.

ii.    Express consent:

  • Sending commercial communications related to different products and services to those contracted, by any means, including electronics, from TRANSBANK and its Grupo of companies dedicated to basic logistics services up to the outsourcing of high added value services.
  • Transfer of data to companies of the Grupo PROSEGUR and to third entities in order to send you commercial communications. 

iii.    Legitimacy on the grounds of the legitimate interests of TRANSBANK: 

  • Sending commercial communications by any means, including electronic communications, related to TRANSBANK products and services similar to those contracted. In this case, the legitimate interest of TRANSBANK is based on keeping you informed of and introducing you to products or services that may be of interest to you.
  • Requesting public economic solvency files to verify that you are up to date with your payments, whether you are in arrears, and if you had been in the past, how long it took you to pay off your debts, which will simplify and streamline the risk analysis at the time the contract is taken out. In such a case, the legitimate interest of TRANSBANK is to safeguard its own operations and prevent fraud.
  • Creating business process automation projects to enhance the products and services provided by TRANSBANK. The legitimate interest in this case would be to improve the efficiency and productivity of TRANSBANK activities.
  • Profiling based on personal data to calculate the degree of readiness to acquire other products or services that may be of interest to you, as well as the likelihood of cancelling the services under contract and the assignment of an assessment for the exclusive purpose to carry out commercial actions.


2.2. In the event that you are a supplier or potential supplier of TRANSBANK 

On the website you can find information that may be useful in order to find out about TRANSBANK’s activity. For this purpose, if you are or represent a supplier or a potential supplier of TRANSBANK and decide to contact the company, the data that will be processed will be those necessary to start and maintain a contractual relationship with you, whether you are an individual entrepreneur, or with the company you represent. 

The following describes the legitimacy bases used that support the processing of your personal data, as well as their different purposes:

i.    Legitimization for the execution of the contract with TRANSBANK or application of pre-contractual measures:

  • Manage the commercial relationship with potential suppliers, attending to requests for information.
  • Formalize the contractual relationship, which will include the process of contracting and signing contracts.
  • Manage the contractual relationship with the suppliers of the Grupo PROSEGUR, which includes monitoring the relationship and paying them.

ii.    Express consent:

  • Sending commercial communications related to different products and services to those contracted, by any means, including electronics, from TRANSBANK and its Grupo of companies dedicated to basic logistics services up to the outsourcing of high added value services. 
  • Transfer of data to companies of the Grupo PROSEGUR and to third entities in order to send you commercial communications. 

iii.    Legitimacy on the grounds of the legitimate interests of TRANSBANK: 

  • Sending commercial communications by any means, including electronic communications, related to TRANSBANK products and services similar to those contracted. In this case, the legitimate interest of TRANSBANK is based on keeping you informed of and introducing you to products or services that may be of interest to you.


2.3. In the event that you are a shareholder of TRANSBANK 

In these cases, PROSEGUR will process your data as a shareholder with the main purpose of carrying out the necessary actions to manage the relationship with you, including providing you with relevant information about the company and complying with legal requirements in this area.

The following describes the legitimacy bases used that support the processing of your personal data, as well as their different purposes:

i.    Legitimization for the execution of the contract with TRANSBANK or application of pre-contractual measures:

  • Manage the relationship with you as a shareholder, responding to requests for information, which includes monitoring the relationship.
  • Formalize the relationship with you as a shareholder, which will include the process of buying and selling shares and signing contracts.

ii.    Legitimization for compliance with legal obligations TRANSBANK: 

  • Comply with legal obligations and requirements in this area, which require the processing of your personal data, taking into account your status as a shareholder.

iii.    Express consent:

  • Sending commercial communications related to different products and services to those contracted, by any means, including electronics, from TRANSBANK and its Grupo of companies dedicated to basic logistics services up to the outsourcing of high added value services. 
  • Transfer of data to companies of the Grupo PROSEGUR and to third entities in order to send you commercial communications. 

iv.    Legitimacy on the grounds of the legitimate interests of TRANSBANK: 

  • Provide you with relevant information about the company, taking into account your status as a shareholder. In this case, the legitimate interest of TRANSBANK is based on keeping you informed and updated on relevant aspects of the company that may be of interest.
  • Sending commercial communications by any means, including electronic communications, related to TRANSBANK products and services similar to those contracted. In this case, the legitimate interest of PROSEGUR is based on keeping you informed of and introducing you to products or services that may be of interest to you. 

3. Recipients

The personal data that you provide to TRANSBANK may be sent to the following recipient categories:

  • Third parties to whom TRANSBANK is obliged to send information, including public authorities, security forces, judges and courts, in order to comply with the requirements of these authorities and the applicable regulations, where appropriate.
  • Companies that form part of the Grupo PROSEGUR, in order to manage the corresponding contractual relationship appropriately as a result of the centralization of administrative and computing processes within the Grupo PROSEGUR.

You are hereby informed that the Grupo PROSEGUR may include companies outside the European Union. In these instances, the parent company requires that these companies fulfil the measures designed to protect personal data established in a binding contract, unless for instances in which the European Commission has determined that the country in which the recipient is located provides an appropriate level of personal data protection. 
 

4. Data Retention

The criteria that TRANSBANK uses to define the periods for storing your data have been established in line with the requirements established in the applicable legislation, regulations and guidelines, in addition to TRANSBANK operating requirements relating to the correct management of its relationship with present and/or potential customers.

Your data will not be kept for a period exceeding 10 years from the end of any possible contractual relationship between you and TRANSBANK, the previous period of conservation of the blocked data having been set in accordance with article 28 of Law 962 of 2005. Notwithstanding the foregoing, in the event that legal proceedings are taken against you, your data may be stored in a blocked format for the additional amount of time required until the final legal ruling is issued. Once this period comes to an end, your data will be deleted.
 

5. Your Data Protection Rights

You may make contact with TRANSBANK whenever you believe and retain the right to exercise your rights of access, rectification, cancellation, limitation and opposition, in addition to the right of portability and to not be subject to automated decisions, by request addressed to Compañía Colombiana De Seguridad Transbank Ltda en Calle 19 #68b-76 in Bogotá D. C., or by writing to: protecciondedatostransbank@prosegur.com, attaching documentation proving your identity.

Furthermore, you are hereby informed that you may withdraw your consent whenever you so desire by contacting TRANSBANK at the address or email address mentioned above.

Finally, if you would like more information about your data protection rights or need to file a complaint, you may contact the appropriate Supervisory Authority. 
 

6. Data Security

TRANSBANK has appropriate policies and technical and organizational measures in place to safeguard and protect your personal data against illegal or unauthorized access, accidental loss or destruction, damage, use or illegal or unauthorized dissemination. You can obtain a copy of the measures required by TRANSBANK by contacting the Data Protection Officer.

We will also take all the reasonable measures to ensure that our staff and employees who have access to your personal data have received appropriate training.
In any case, the user is hereby informed that any disclosure of data online is not completely secure and, therefore, he/she proceeds at his/her own risk. Although we will do our utmost to protect your personal data, TRANSBANK cannot guarantee the security of the personal data sent via our website.

© 2020 Compañía Colombiana De Seguridad Transbank Ltda. All rights reserved.

 

*In the event of any discrepancies between the Spanish and the English version, the Spanish version shall prevail.