Privacy and Personal Data Protection Policy

Last updated: December 2, 2024

Scope of Application

At JL OUTSOURCER SAS, we are committed to protecting and respecting your privacy. This Privacy Policy outlines how we collect, use, and safeguard your personal information when you visit our website at https://matchlatin.com and engage with our services.

This Privacy Policy constitutes a binding document for JL OUTSOURCER SAS, hereinafter referred to as the “Data Controller,” in accordance with Colombian Law 1581 of 2012, which establishes general provisions for the protection of personal data.

The terms outlined in this policy apply to all personal data that JL OUTSOURCER SAS handles or is responsible for. The responsibilities and obligations described in this policy are based on Article 17 (k) and Article 18 (f) of Law 1581 of 2012, as well as Article 2.2.2.25.3.1 of Decree 1074 of 2015, a Colombian regulatory framework that governs how personal data should be managed. These legal norms describe the duties of data controllers and processors, and how data subjects’ requests and complaints should be handled. The policy also complies with Section Three of Decree 1074 of 2015 on “Data Processing Policies,” which requires organizations to define clear procedures for handling personal data and ensuring third-party compliance with those procedures.

Definitions

Information we collect and store from our clients, collaborators, and suppliers:
Depending on the nature of their relationship with the Data Controller, the following types of information may be collected or stored:

  • Personal Data: Any information that is linked or can be associated with one or more specific individuals.

  • Public Data: Information that is not classified as private or sensitive, such as information found in public documents.

  • Semi-private Data: Information that is neither intimate nor public and that may be of interest to specific groups or sectors, such as financial and credit data.

  • Private Data: Sensitive information relevant only to the data subject, such as income level, financial data, personal or family details, consumption habits, social media preferences, and personal contact information (home address, phone number, personal email).

  • Sensitive Data: Highly confidential personal information, the mishandling of which may result in discrimination or significant harm. Examples include biometric data, health information, religious beliefs, sexual orientation, or union membership.

  • Data Processing: The handling of personal data for purposes authorized by the data subject or by applicable law.

  • Authorization: The informed, prior, and express consent granted by the data subject for the processing of their personal data. In the case of sensitive data, this authorization is optional and will be explicitly explained to the data subject.

  • Privacy Notice: A document provided by the Data Controller to the data subject outlining the existence of data processing policies, access procedures, and the nature of the intended processing.

  • Database: An organized collection of personal data subject to processing.

  • Communication Channel: A medium established by the organization to manage questions, complaints, requests, and suggestions (PQRS).

  • Data Processor: A natural or legal person, public or private, who processes personal data on behalf of the Data Controller.

  • Data Protection Officer (DPO): The appointed official within JL OUTSOURCER responsible for ensuring compliance with this policy.

Purposes of Data Processing

Purposes related to contractual obligations or legal requirements:

  • Carrying out all activities necessary to fulfill contracts entered into with clients, collaborators, or suppliers, including sending relevant information.

  • Assessing customer satisfaction with products or services.

  • Conducting commercial campaigns and marketing activities.

  • Sharing product launches, events, promotions, and advertisements through email, phone, WhatsApp, SMS, social media, or similar channels.

  • Sending commercial offers and promotional material related to the Data Controller or its business partners.

  • Reactivation authorization: If a contract ends, we may use your information to inform you of future offers or services that may be of interest, and to reestablish a commercial relationship. You may revoke this consent at any time using the contact methods provided.

  • Sharing information with strategic partners for contracting products and services, managing risk, responding to claims, or commercial management.

  • Transmitting or transferring personal data as needed to support company operations or implement corporate strategy.

Purposes related to internal operations:

  • Managing employee, contractor, or applicant data for onboarding, performance, service provision, termination, and benefits, including payroll and HR functions.

  • Handling payments and enrollment in Colombia’s Social Security System.

  • Managing health-related data to prevent occupational illnesses or accidents and monitor occupational safety.

  • Monitoring company premises for safety through video surveillance; collected data may be used in investigations or administrative procedures.

  • Analyzing digital behavior to tailor product recommendations and understand user preferences.

  • Other necessary purposes related to the company’s operations and HR functions.

Specific Purposes by Category:

Job Applicants:

  • Participating in current and future recruitment processes.

  • Capturing sensitive data (images, fingerprints, etc.) for access control.

  • Responding to requests from social security institutions.

  • Preventing terrorism and money laundering.

  • Sharing information with affiliates or third parties for recruitment and tech services.

  • Conducting audits and supporting the company’s social purpose.

Employees, Former Employees, Pensioners, Interns, and Family Members:

  • Managing employment processes.

  • Handling payroll and legal compliance.

  • Medical and emergency care.

  • Capturing sensitive data for access and security.

  • Performance evaluations and career development.

  • Sharing data with third parties for HR purposes.

  • Managing benefits and perks.

  • Performing audits and fulfilling JL OUTSOURCER’s corporate objectives.

Suppliers:

  • Managing supplier registration and service evaluation.

  • Processing payments and invoices.

  • Capturing sensitive data for security and access.

  • Conducting audits and supporting business operations.

Clients:

  • Registering and managing clients.

  • Delivering products and services.

  • Fulfilling contractual obligations.

  • Capturing sensitive data for security.

  • Auditing and maintaining operational integrity.

Shareholders, Legal Representatives, and Executives:

  • Responding to regulatory requests.

  • Managing dividend and fee payments.

  • Capturing sensitive data for security and access.

  • Conducting internal audits and corporate functions.

Third Parties:

  • Sending information about products and services.

  • Capturing sensitive data for access control.

  • Performing audits in line with JL OUTSOURCER’s business objectives.

Processing of Minors’ Data:

  • Handling children’s and adolescents’ data only with the express consent of parents or legal guardians, in compliance with Colombian Law 1581 of 2012 and Decree 1377 of 2013.

  • Enrolling minors in healthcare and compensation funds, insurance policies, educational or wellness programs, and other authorized processes.

Data Subject Rights

In accordance with Colombian Law 1581 of 2012, individuals have the right to authorize the use of their personal data, request access to it, update or correct it when inaccuracies are found, request its deletion, and revoke authorization at any time, provided there is no legal or contractual obligation to retain the data. These rights are outlined in Article 2.2.2.25.2.8 of Decree 1074 of 2015.

However, for purposes that are essential to the execution of contracts or to the internal operation of JL OUTSOURCER SAS, the processing of certain personal data may be necessary and non-optional.

Exercising Rights Over Personal Data

JL OUTSOURCER SAS has appointed the following department as its Personal Data Protection Officer, responsible for receiving, addressing, and responding to requests, complaints, claims, and any other inquiries related to the personal data of the Data Subjects:

  • Company: JL OUTSOURCER SAS

  • Department Responsible for Handling Inquiries: Legal Department

Data subjects may exercise their rights to access, update, correct, or delete their data by submitting a written request through any of the following service channels provided by JL OUTSOURCER SAS:

International and Domestic Data Transfers to Processors

If JL OUTSOURCER SAS needs to send or transfer data to one or more processors located within or outside of Colombia, it will include appropriate contractual clauses or enter into a Data Transmission Agreement to ensure the proper handling of the personal information.

Disclosure of Personal Information to Service Providers:
In order to fulfill its contractual obligations with data subjects, JL OUTSOURCER may share personal data with service providers for the purposes authorized by the data subject or as permitted by Colombian law. This ensures the proper execution of the company’s business activities and services. When sharing data, JL OUTSOURCER will require providers to comply with its privacy policies and will sign confidentiality and data processing agreements where necessary, especially when the nature of the data transfer so requires.

Website Browsing Data

Our websites use both first-party and third-party cookies to collect statistical information and improve the services we offer by delivering content aligned with users’ preferences, based on the analysis of their browsing habits. This helps us personalize content and enhance the customer experience when interacting with the company.

The data collected through cookies will be processed in accordance with Colombian regulations and this Privacy Policy.

Users may choose to browse JL OUTSOURCER’s websites without cookies. However, this may limit access to personalized offers and reduce the overall user experience. To browse without cookies, users can configure their web browser to reject them or to alert them when a cookie is being created.

Acceptance of This Policy

The data subject accepts the processing of their personal data in accordance with the terms of this Privacy Policy by providing their data through our service channels or contact points, and when purchasing, acquiring, subscribing to, or using any of our products or services.

Duration of Data Processing: The information provided by the data subjects will be stored for as long as necessary to fulfill the purposes for which it was collected, in compliance with applicable Colombian data protection laws.