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POLICIES

OF PRIVACY

PRIVACY POLICIES, TREATMENT AND PROTECTION OF DATA

 

NOTICE OF PRIVACY

We ask you to carefully read this Privacy Policy to understand how your Personal Information is and will be treated when you enter our website www.ricsas.com, as well as when you use any of our services.

ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA reserve the right to modify this Privacy Policy to adapt it to the legislative, regulatory, jurisprudential, practices of the tourism or commercial sector, in which case, it will be informed through the site Web and said changes in the Privacy Policy will be accepted by continuing to use this website and the services provided by said companies.

In case of having any questions regarding the Privacy Policies of the companies listed here, we inform our service points, in the city of Bogotá DC at Calle 24A Bis No. 44A-52, as well as the contact channels with its clients and users, on the telephone lines (57) 17561114 and 3028318178 in the city of Bogotá Colombia and the emails administracion@ricsas.com and administracion@royalvacations.com.co respectively.

 

​DATA TREATMENT

​ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA  in compliance with the provisions of Law 1581 of 2012 and additional regulations of Decree 2017 of 2017 are generated; make this Privacy Notice available, which is intended to provide users with the appropriate resources so that they may previously access this Privacy Policy and grant their consent  _cc781905-5cde-3194- bb3b-136bad5cf58d_for the processing of your personal data.


It is stated that ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA acting as controllers and managers of personal data processing have collected and kept information from suppliers, employees, customers and third parties since before the existence of the law and its entry into force, for the development of its corporate purpose and its collection activity for delinquent customers, consequently and in compliance with the regulatory framework, it is allowed to present the privacy policy for the treatment of personal data that we handle as responsible or as in charge, in which the procedures are established so that the owners can exercise the rights indicated in the regulations applicable to the matter.

ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA undertake to treat and protect your personal data using the means available to them and thus safeguard the authenticity, confidentiality and integrity of the information provided, these policies will be complied with by directors, officers, contractors and third parties who work for ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA

Personal information will not be used or treated for purposes other than those stated here. ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA may carry out data processing on their own servers or on those provided by a third party specialized in the matter and these may be located in Colombia or in other countries. All company personnel who, in the performance of their duties, have access to the personal information of holders, comply with the provisions of the information security and protection policy and sign a confidentiality agreement with the company.

 

DEFINITIONS

Mention is made of the terms used throughout this document, and whose definitions are provided for in Law 1581 of 2012 and its Regulatory Decree 1377 of 2013:

1. Authorization: Prior, express and informed consent of the Holder to carry out the Processing of personal data.

2. Database: Organized set of personal data that is subject to Treatment.

3. Personal data: Any information linked or that can be associated with one or more specific or determinable natural persons.

4. Treatment Manager: Natural or legal person, public or private, that by itself or in association with others, performs the Processing of personal data on behalf of the Data Controller.

5. Responsible for Treatment: Natural or legal person, public or private, that by itself or in association with others, decides on the database and/or the Data Processing.

6. Holder: Natural person whose personal data is subject to Treatment.

7. Treatment:Any operation or set of operations on personal data, such as the collection, storage, use, circulation or deletion.

8. Privacy Notice: Verbal or written communication generated by the Responsible, addressed to the Owner for the Treatment of their personal data, through which they are informed about the existence of the information Treatment policies that will be applicable to them, the way to access them and the purposes of the Treatment that is intended to be given to the personal data.

The privacy notice, at a minimum, must contain the following information:

  • Name or company name and contact information of the data controller.

  • The Treatment to which the data will be subjected and the purpose of the same.

  • The rights that assist the owner.

  • The mechanisms provided by the person in charge so that the owner knows the information treatment policy and the substantial changes that occur in it or in the corresponding Privacy Notice. In all cases, you must inform the Holder how to access or consult the Information Treatment policy.

9. public data: It is the data that is not semi-private, private or sensitive. Data relating to the marital status of individuals, their profession or trade and their quality as a merchant or public servant are considered public data. Due to its nature, public data may be contained, among others, in public records, public documents, official gazettes and bulletins, and duly executed judicial decisions that are not subject to reservation.

10. Sensitive data: Sensitive data is understood as those that affect the privacy of the Holder or whose improper use may generate discrimination, such as those that reveal racial or ethnic origin, political orientation, religious or philosophical convictions, membership in trade unions, social organizations , human rights or that promotes the interests of any political party or that guarantees the rights and guarantees of opposition political parties, as well as data related to health, sexual life, and biometric data.

The processing of sensitive data is prohibited, except when:

  • The Holder has given his explicit authorization to said Treatment, except in cases where the granting of said authorization is not required by law.

  • The Treatment is necessary to safeguard the vital interest of the Holder and he is physically or legally incapacitated. In these events, the legal representatives must grant their authorization.

  • The Treatment is carried out in the course of legitimate activities and with due guarantees by a foundation, NGO, association or any other non-profit organization, whose purpose is political, philosophical, religious or trade union, provided that they refer exclusively to its members or to people who maintain regular contact by reason of its purpose. In these events, the data may not be provided to third parties without the authorization of the Owner.

  • The Treatment refers to data that is necessary for the recognition, exercise or defense of a right in a judicial process.

  • The Treatment has a historical, statistical or scientific purpose. In this event, the measures leading to the suppression of the identity of the Holders must be adopted.

11. Transfer: The transfer of data takes place when the Responsible and/or Responsible for the Processing of personal data, located in Colombia, sends the information or personal data to a receiver, who in turn is Responsible for the Treatment and is inside or outside the country.

12. Transmission: Treatment of personal data that implies the communication of the same inside or outside the territory of the Republic of Colombia when its purpose is to carry out a Treatment by the Manager on behalf of the Responsible.

 

BEGINNING

The principles that will govern the way in which ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA will process personal data are as follows: Principle of legality in data processing, principle of purpose, principle of freedom, principle of truthfulness o quality, principle of transparency, principle of access and restricted movement, principle of security and principle of confidentiality.

 

USE OF PERSONAL INFORMATION

As part of the activities of the development of its corporate purpose, collection activity, data updating, reporting to information operators, contacting customers and users, as well as those intended to maintain adequate security and service conditions for our customers. and in general for the development of the different activities carried out by ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA, the delivery of different data will be required in accordance with the purposes presented in this policy, but not limited to: name, address, age , as well as other contact information such as telephone number and email address and specific information regarding references and economic conditions of the debtors of the own portfolios of ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA, as well as other relevant information to provide the exercise of the activities of the corporate purpose of the same companies.

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PURPOSE OF INFORMATION PROCESSING

As part of the activities of ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA of the provision of services, pre-legal and legal collection for the recovery of its own portfolio, reporting to Information operators, visits to holders and contact reports to clients and users and in general, for the development of the different activities carried out by ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA, the delivery of different personal data will be required in accordance with the purposes set forth in this policy, but not limited to: name , physical and electronic addresses, age, contact information such as landline phone number - cell phone and email address, work activity and specific information regarding the economic conditions of the User in his capacity as debtor of his own portfolios, or delegated by mandate, as well as other relevant information aimed at facilitating the exercise of the activities of the object company of ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA.
The USER's information is required to be collected, used, processed, shared, and incorporated into the database of ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA and in general it will be treated in order to:

  1. Keep record of attendance of visitors, customers and contract holders to the facilities of ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA

  2. Send information of a commercial, promotional nature or invitations from ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA or their potential clients, or strategic allies.

  3. Send information or invitations to brigades in a physical, electronic, text or voice message to the holders of their own portfolios, so that they can normalize their obligations.

  4. Carry out collection activities, portfolio recovery, georeferencing, statistical studies of credit risk behavior, location of debtors through interpretation and interaction of data from various sources, for the own portfolio, or delivered under mandate.

  5. Updating the personal data of holders, through different activities such as consulting public databases and referencing third parties or directly with the holders. For our own portfolio, or delivered by mandate from our clients.

  6. Carry out through any means, directly or indirectly, own marketing activities or those of third parties.

  7. Update the databases of ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA to achieve an effective collection process of the own or managed portfolio.

  8. Carry out consultation and reports of the current obligations of own portfolio to the legally established credit risk centers.

  9. To evaluate the quality of the services of ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA.

  10. Comply with the legal obligations of information to administrative entities, as well as competent judicial authorities that require it.

  11. Send information about activities carried out by ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA or send information that is considered of interest to clients and strategic allies.

  12. Share the information securely with third parties or strategic allies that provide their services to ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA and that in order to fulfill their functions they must access the information to some extent, such as service providers messaging, service providers, among others of messages, collections, legal professionals who collaborate with ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA in the development of its corporate purpose, justice auxiliaries, etc. In any case, these entities and persons will also be subject to the same confidentiality obligations in the handling of the information to which ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA are subject, with the legal limitations imposed by the applicable laws on the matter. In colombia.

 

OBJECTIVES OF DATA PROCESSING

​The Personal Data that you provide us meets the following purposes:

  1. The support of the contractual relationship, where applicable, established with ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA.

  2. The provision of services offered and in which the client decides to subscribe or use.

  3. Carrying out all the activities related to the service and for which they will be included in a list of emails and text messages for sending information.

  4. Processing your requests and clarifications

  5. Marketing, sale and collection of our services.

  6. Notification of new services that are related to those already contracted or acquired.

  7. For security in business transactions with your financial institution, with our service providers and with yourself.

  8. The sending, by traditional and electronic means, of technical, operational and commercial information about products and services offered by ROYAL INVESTMENT DE COLOMBIA SAS, and ROYAL VACATIONS DE COLOMBIA SA to its associates or suppliers, currently and in the future.

  9. Carry out the transfer of data to other companies or commercial alliances in order to fulfill our corporate purpose.

  10. ROYAL INVESTMENT DE COLOMBIA SAS, and ROYAL VACATIONS DE COLOMBIA SA understand that if you provide personal information about a person other than yourself, you are legitimately authorized to do so and by virtue of this we do not assume responsibility for damages or losses of any nature that could originate from the lack of veracity, homonymy or the impersonation of the information provided.

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OBJECTIVES OF INTERNAL PERSONAL DATA PROCESSING.

The information in the resume of the candidates will serve for ROYAL INVESTMENT DE COLOMBIA SAS, and ROYAL VACATIONS DE COLOMBIA SA, to form an opinion on the qualities of the person. Likewise, this information may be shared with other companies and entities seeking that the candidate's profile be known by them and have greater possibilities of being linked.

The data collected from the people who provide services in the company as suppliers, business alliances or natural persons, are intended to develop the commercial relationships that exist with them, seeking to know and monitor their financial suitability and commercial behavior. Among them, making them participate in the wellness activities provided by ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA.

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RIGHTS OF THE HOLDERS

In accordance with current Colombian legislation, in particular the Political Constitution and Law 1581 of 2012, USERS, their legal representatives or successors in title have the right to:

  1. Know, update and rectify your personal data against ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA. This right may be exercised, among others, against partial, inaccurate, incomplete, fragmented, misleading data, or those whose Treatment is expressly prohibited or has not been authorized.

  2. Request proof of authorization, except when expressly excepted as a requirement for treatment.

  3. Be informed, upon request, regarding the use you have given to your personal data.

  4. Submit complaints to the Superintendency of Industry and Commerce for violations of the provisions of the law and other regulations that modify, add or complement it.

  5. Revoke the authorization and/or request the deletion of the data when the principles, rights and constitutional and legal guarantees are not respected in the Treatment. The revocation and/or suppression will proceed when the Superintendency of Industry and Commerce has determined that ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA have engaged in conduct contrary to the law and the Constitution.

  6. Free access to your personal data that has been subject to Treatment, once a month, for queries greater than one per calendar month ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA, may charge the expenses incurred to this end.

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DUTIES OF ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA

  1. Guarantee the Holder, at all times, the full and effective exercise of the right of habeas data.

  2. Keep the information under the necessary security conditions.

  3. Carry out timely updating, rectification or deletion of data under the terms of the law.

  4. Process queries and claims made by the Holders.

  5. Refrain from circulating information that is being controversial by the Holder and whose blocking has been ordered by the Superintendence of Industry and Commerce.

  6. Inform the Superintendence of Industry and Commerce when there are violations of the security codes and there are risks in the administration of the information of the Holders.

  7. Comply with the instructions and requirements issued by the Superintendence of Industry and Commerce.

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PROCESSING FOR THE EXERCISE OF RIGHTS BY THE HOLDERS

In order for the USER to exercise their rights, they may contact ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA through written communication addressed to our customer service area at the following address: Calle 24A Bis # 44A-52 PBX 7561114 - 3028318178 , administracion@ricsas.com / administracion@royalvacations.com.co The aforementioned communication must contain all the necessary data applicable to the right of petition in order to guarantee a timely and effective response, accompanied by a clear and precise description of the personal data with respect to which the USER seeks to exercise their rights; likewise, in the event of not acting directly, the interested party must formally certify the quality in which he acts. ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA will respond to the petitioner within the terms established by Law 1581 of 2012. It should be noted that while the USER of the information appears as a debtor of obligations of ROYAL or of the entities of the which the information is managed, the information will be maintained and the USER will lack the power to request the deletion of the information from the databases. If the withdrawal request is made after the total and effective cancellation of the obligation and/or the legal or contractual relationship has ended, the deletion of the data will mean that they will not be accessible for the development of normal ROYAL operations. INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA, however, may be kept in their files for statistical and historical purposes, knowledge of their clients or attention to the requirements of administrative or judicial authorities.

 

CALL RECORDINGS AND SECURITY VIDEO RECORDING

ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA within their policies of quality, security, monitoring of their activities, entry and exit controls of their offices and updating or complementing the information maintained in their databases, will make recordings of audio to the management carried out with clients, holders of their own or third-party portfolios delivered under mandate for their management, which by order of the financial superintendence must be recorded to be monitored and control of advanced management, and for access control and security Of the offices there are cameras with video recording in the offices and common places, Such audio recordings will have a duration in the files of ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA of a maximum of 5 years to later be subject to deletion or destruction, unless you must keep them for the purpose of complying with current regulations or contractual duties. And the video recordings will last in your files for two months, date on which they are deleted if not required.
Likewise, ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA will make use of information technologies to send various communications such as sending account statements, certifications, communications of interest, calls for normalization brigades, location days of holders, etc., report notices to Information Operators, management reports for clients, call monitoring reports, audios of the different calls requested by our clients in compliance with the financial consumer law and others that in terms of the Financial Superintendence that are required of those supervised.

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INFORMATION FROM THIRD PARTIES

ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA, in development of their corporate purpose, manage or act as a service provider for third-party natural and legal persons belonging to the financial, real, solidarity and public services sectors, among other sectors. In these cases, ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA play the role of data processor, in such a way that their actions will always be based on the conviction that these third parties have the necessary authorizations from the owners. of the information, due to the existence of a contractual and/or credit link, for the activity of collection or promotion and sale for which it is delivered to ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA. In the event that the request made by the owner of the data or his successors in title falls on the existing authorizations for the treatment of the data that are collected by those third parties, ROYAL will transfer the request to the corresponding managers and so that An adequate response is provided to the needs of the petitioner, however, in such cases ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA, will not be responsible for the scope of the authorizations granted or for the content of the responses that are granted. to requests.
It is understood that whoever delivers the information to ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA has all the relevant authorizations referred to in Law 1581 of 2012 and that the purposes for which the delivery has been fully known. and accepted by the owner and in that sense releases ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA from any responsibility for the use given to the data in compliance with the purposes for which the information is delivered. The foregoing, under the understanding that ROYAL in development of its internal policies or by order of a competent authority may require proof of such authorizations.

On the other hand, ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA are committed to making an adequate use and treatment of the personal data of the holders, in order to avoid as much as possible unauthorized access to third parties that allows to know or violate , modify, disclose and/or destroy the information that resides in the databases of ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA. For which, it has security protocols and access to our information, storage and processing systems, including physical security risk control measures. All established in the information security policy. In the event that the holder provides any type of information through the portal or the internet, he is aware that he knows and accepts that no transmission over the internet is absolutely secure, nor can said end be guaranteed, therefore, he assumes and knows that eventually A risk of vulnerability may be generated. For its part, it is understood that the owner states that it has implemented the necessary security controls in its equipment and private networks for browsing the portal of ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA or for sending emails. to addresses of ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA. Likewise, ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA have the security mechanisms in accordance with the services offered, notwithstanding the foregoing, ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA are not responsible for any consequence derived of fraudulent entry by third parties to the database and for any technical failure in the operation that exceed the activities carried out with due diligence.

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DISCLOSURE OF INFORMATION

Personal information will not be used or treated for purposes other than those stated here. ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA may carry out data processing on their own servers or on those provided by a third party specialized in the matter and these may be located in Colombia or in other countries. All company personnel who, in the performance of their duties, have access to the personal information of holders, comply with the provisions of the information security and protection policy and sign a confidentiality agreement with the company.

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TRUTH AND CHANGES IN THE INFORMATION PROVIDED

The information shared with ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA must be complete, current and truthful, resulting in any discrepancy between the data provided and reality being the sole responsibility of the person who provides it, assuming the legal consequences of the case. Any change in the information provided to the entity must be notified to ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA within five (5) business days following the occurrence of the events that produce the data change, through of the channel arranged for the effect.

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MODIFICATIONS TO THE PRIVACY POLICY

ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA reserve the right to modify the Privacy Policy for Personal Information at any time and unilaterally when deemed necessary or changes are made in the regulations that warrant it. For this purpose, a notice will be published on the website ten (10) business days prior to its entry into force. In the event that any owner states that they do not agree for valid reasons and that they constitute a just cause with the new policies for handling personal information, the owners of the information or their representatives may request ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA the withdrawal of your information through the means indicated above, however, data withdrawal may not be requested while a contractual, legal or any order link is maintained with ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA or with third parties for whom ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA carry out any collection or marketing and sales activity.
If no objections are received by the holders to the modifications after the notification of the new privacy policy, it constitutes the acceptance of the same by the holders.

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LAW AND JURISDICTION

Any interpretation, judicial or administrative action derived from the processing of personal data that make up the databases of ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA and this privacy statement will be subject to the personal protection regulations established in the Republic of Colombia and the competent administrative or jurisdictional authorities for the resolution of any concern, complaint or demand about them will be those of the Republic of Colombia.

 

SPECIAL DATA PROCESSING OF MINORS

In accordance with current personal data protection regulations, ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA undertake to process the data of minors in compliance with the requirements of:

  1. Respect for the best interests of children and adolescents.

  2. Respect for your fundamental rights

In such a way that ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA guarantees that any question that deals with minor children and adolescents will be optional to be supplied by their guardian or legal representative and reserves the possibility of putting authorities are aware of situations that ROYAL INVESTMENT DE COLOMBIA SAS and ROYAL VACATIONS DE COLOMBIA SA may endanger the integrity of a minor.​

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