Policy of "Nemaho  shop"

NEMAHO "New Market Home"., Commercial company, identified with NIT. 1001808434-7, domiciled at Cra. 63a #77-20 Torre 6 BELLO ANTIOQUIA, is responsible for the processing of personal data directly or indirectly related to the COMESTIBLES, LICORES, ASEO brand  and PETS
Through this PRIVACY NOTICE and in compliance with Colombian regulations on the protection of personal data, Law 1581 of 2012 and decree 1074 of 2015 and other regulations that modify or complement them, we inform the holders of personal data about the existence of our PERSONAL DATA PROCESSING POLICY, which is a public document that can be consulted at any time through our page  www.nemaho.co

PURPOSES OF TREATMENT. The personal data of clients, suppliers, contractors, employees, former employees and applicants for job vacancies, which are collected from now on or found in our databases, will be processed for the following purposes:

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Clients: NEMAHO "New Market Home"  will use the information you provide to:

1. Carry out

Carry out the pertinent steps for the development of the pre-contractual, contractual and post-contractual stage with NEMAHO, especially insofar as it corresponds to internal procedures for the creation of the supplier, billing registration, validation of financial data and money transfer, with respect to any of the the products offered by it that it has or has not acquired or, with respect to any underlying contractual relationship that it has with it, as well as to comply with Colombian or foreign law and the orders of judicial or administrative authorities.

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2. Manage

manage procedures (requests, complaints, claims), carry out risk analysis, carry out satisfaction surveys regarding the company's goods and services, as well as its commercial allies.

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3. Supply

Provide contact information and relevant documents to the commercial force and/or distribution network, telemarketing, market research and any third party with which the company has a contractual relationship of any kind.

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4. Make known

Disclose, transfer and/or transmit my personal data inside and outside the country, to third parties as a result of a contract, law or lawful link that requires it, for the presentation of the respective services or by virtue of agreements or commercial alliances .

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5. Perform

Perform through any means directly or through third parties, programming and provision of technical service, sale, purchase, billing, portfolio management, monitoring of product performance, collection, business intelligence, marketing activities, promotion or advertising , improvement of the service, monitoring of collection, verification, consultation and control, enabling means of payment as well as any other related to our current and future products and services, for the fulfillment of contractual obligations and the corporate purpose of the company.

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6.  Shipment

For the sending and receiving of merchandise or advertising material according to the requirements of the functions demanded and substantivity  of the company's business.

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7.Control

Control and prevent fraud in any of its forms.

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Suppliers, contractors

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Carry out analysis, evaluations and selection of potential suppliers and/or contractors. Communication of our policies and procedures for linking suppliers. Analysis of information on quality and service levels received from suppliers. Legal compliance in fiscal, customs and commercial matters with administrative and judicial entities. Initiate business agreements to acquire goods or services Control and payment for goods and services received. Monitor work, control and accounting record of the obligations contracted with suppliers. Consultations, audits and reviews derived from agreements with suppliers and/or contractors. Control and prevent fraud in any of its forms.

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Employees, former employees and applicants for job vacancies

The information collected is used to carry out a process of analysis, evaluation and selection of personnel to work in the company. The data collected necessarily includes data from third parties who are related by blood.  up to second degree and first civil, to attend affiliation processes to compensation funds and the general social security system.

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The data collected from employees is intended to develop the labor relations that exist with them; among them, make them participate in the activities offered within NEMAHO. In particular, the purposes will be:

1. Evaluate the conditions of employability, sufficiency and relevance for a certain position.

2. Carry out security studies (home visits, entrance and exit medical exams, referrals and others).

3. Comply with the obligations contracted by the company with the employees holding the information, in relation to the payment of salaries, social benefits and others enshrined in the employment contract.

4. Inform the modifications that occur in the development of the employment contract.

5. Evaluate the quality of the services offered by the employee.

6. Carry out internal studies on the habits of the employee who owns the information for corporate wellness programs.

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By virtue of the foregoing, the employee authorizes NEMAHO. to process the personal data that is provided in the development of the employment relationship, during the entire time of permanence in the entity and after the relationship has ended, as long as there is a legal or contractual conservation duty on the part of NEMAHO. The authorization for the processing of personal data is granted by the employee within the provisions of this Personal Data Protection Policy, which is known and complies with the provisions of Law 1581 of 2012.

For people who are not selected, their information will be kept in order to be analyzed in the future in vacancies different from those initially applied.

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RIGHT OF THE HOLDERS . The owners may at any time exercise their rights to Know, Update, Rectify and Delete the personal data that has been collected from them by directing communication to any of the available contact channels. Cra. 63a #77-20 Torre 6. Phones: (4) 2069342. Website:  www.nemaho.co _  e-mail: customerservice@nemaho.co  

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MECHANISMS FOR CONSULTATIONS AND CHANGES IN THE TREATMENT POLICY . Our personal data processing policy may be updated, in accordance with the information processing needs, a circumstance that may occur at any time. In this case, the new conditions on data processing will be announced before its implementation, through our traditional communication channels. At any time, the owner can consult our treatment policy on the company's website.

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NEMAHO

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1. Objective:

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Nemaho., in the development of its commercial activities, has designed its policy for the treatment of personal data, which reflects the principles and rules established in the General Regime for the Protection of Personal Data in order to guarantee the right to habeas data. of personal information holders.

This policy has been prepared in order to welcome us under self-regulatory parameters to a comprehensive process for all interactions we have with our collaborators, regarding the processing of personal data that respects all the rights and guarantees regarding privacy of the owners on those of us who process personal data. It was the Constitution of Colombia that in its Article 15 has established the protection of your personal data as a constitutional right. Likewise, through Law 1581 of 2012 and its regulatory decrees 1377 of 2013 and 886 of 2014 - Today contained in chapters 25 and 26 of the sole Decree 1074 of 2015 of the Commerce, Industry and Tourism sector, the general protection framework was developed of data in Colombia.

2. Applied:

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Nemaho, is the Colombian company that applies the latest trends in food and household goods, especially designed for the family.  sophisticated and stylish Latina. Its mission is to highlight the Latino lifestyle, providing the best grocery alternative among others.   and generate  a unique shopping experience, with innovative products that make you feel good.

This policy is mandatory and strict compliance by all employees of  Nemaho., contractors and third parties acting on behalf of  Nemaho.  all Nemaho employees  must observe and respect these policies in the performance of their duties. In cases where there is no employment relationship, a contractual clause must be included so that all those who act on behalf of  Nemaho.  or represent it, are obliged to comply with these policies. Failure to comply with them will cause labor-type sanctions or contractual liability, as the case may be. The foregoing, without prejudice to the duty to respond patrimonially for the damages caused to the owners of the data or to  Nemaho.  for the breach of these policies or the improper treatment of personal data.

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3. Identification data

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Nemaho., NIT 1001808434-7, contact details. Address: Cra. 63a #77-20 Torre 6 Bello., Antioquai. Tels: (4)2069342  website: www.nemaho.co; e-mail: customerservice@nemaho.co.

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4. Glossary

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Authorization:  It refers to the expression of the prior, express and informed consent of the owner so that  Nemaho, or its Managers carry out the treatment of the Personal data of the owner.

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Notice of Privacy:  It is the physical document, electronic or in any other format, generated by  Nemaho., which has been made available to the owner for the processing of their personal data, which communicates to the owner the information regarding the existence of the personal data processing policies that will be applicable, the way to access them and the characteristics of the treatment that is intended to be given to Personal data.

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Database:  They consist of an organized set of personal data that is subject to treatment, and includes physical and electronic files. Databases owned by  Nemaho., are detailed in section VI of this policy.

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Personal Data:  According to Law 1581 of 2012, it is any information linked to or that can be associated with one or more determined or determinable natural persons.

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Public Data:  Personal data classified as public by law or the Political Constitution. Data relating to the marital status of individuals, their profession or trade, their status as a merchant or public servant are public, among others.

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Sensitive data:  Personal data whose use affects the privacy of the owner 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.

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Data Protection Officer:  is the person inside  Nemaho, whose function is to monitor and control the application of the personal data protection policy, under the guidance and guidelines of the Board of Directors, which is the management body that must appoint the Data Protection Officer.

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Headline:  Natural person whose personal data is subject to treatment.

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Treatment:  It is any operation or set of operations on personal data that  Nemaho., or those in charge of treatment on behalf of  Nemaho., such as the collection, storage, use, circulation or suppression.

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Transfer:  It consists of sending personal data to a recipient who, in turn, is responsible for the treatment under the terms of Law 1581 of 2012. Transmission: It is the communication of personal data inside or outside the territory of the Republic of Colombia , with the purpose of carrying out a treatment by the person in charge on behalf of  Nemaho.

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5. POLITICS  PERSONAL DATA PROCESSING:

5.1. TREATMENT TO WHICH THE PERSONAL DATA WILL BE SUBJECTED

The personal data of customers, suppliers, contractors, employees, former employees, which are collected from now on or found in our databases will be processed for the following purposes:

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Customers:  Nemaho., will use the information you provide to:

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1. Carry out the pertinent steps for the development of the pre-contractual, contractual and post-contractual stage with  Nemaho., especially administrative procedures for creation, financial registration and transfer, with respect to any of the products offered by it that it has or has not acquired or, with respect to any underlying contractual relationship that it has with it, as well as to comply with Colombian law. or foreign and the orders of judicial or administrative authorities.  

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2. manage procedures (requests, complaints, claims), perform risk analysis, conduct satisfaction surveys regarding the company's goods and services, as well as its business partners.

3. Provide contact information and pertinent documents to the commercial force and/or distribution network, telemarketing, market research and any third party with which the company has a contractual relationship of any kind.

4. Disclose, transfer and/or transmit the personal data of the holders inside and outside the country, to third parties as a result of a contract, law or lawful link that requires it, for the presentation of the respective services or by virtue commercial agreements or alliances.

5. Perform through any means directly or through third parties, programming and provision of technical service, sale, purchase, billing, portfolio management, monitoring of product performance, collection, business intelligence, marketing activities, promotion or advertising, service improvement, collection monitoring, verification, consultation and control, enabling means of payment as well as any other related to our current and future products and services, for the fulfillment of contractual obligations and the corporate purpose of the company .

6. For the shipment and reception of merchandise or advertising material according to the requirements of the functions demanded and sustainable of the company's business.

7. Control and prevent fraud in any of its forms.

8. Registration of visitors in stores to comply with the biosafety protocols issued by the Ministry of Health to mitigate, control, and adequately manage the COVID-19 pandemic in the country.

Suppliers, contractors :  Nemaho will use the information you provide to:

1. Carry out analysis, evaluation and selection of potential suppliers and/or contractors. Communication of our policies and procedures for linking suppliers.

2. Analysis of information on quality and service levels received from providers.

3. Legal compliance in fiscal, customs and commercial matters with administrative and judicial entities.

4. Initiate business agreements to acquire goods or services.

5. Control and payments for goods and services received. Monitoring, control and accounting tasks of the obligations contracted with the suppliers.

6. Consultations, audits and revisions derived from agreements with suppliers and/or contractors.

7. Control and prevent fraud in any of its forms.

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Employees, former employees and applicants for job vacancies:  The information collected is used to carry out a process of analysis, evaluation and selection of personnel to work in the company. In specific cases, family data will be required, for procedures before compensation funds and affiliations to the general health system. The data collected from employees is intended to develop the labor relations that exist with them; among them, make them participate in the activities offered within the  Nemaho.

In particular, the purposes will be:

1. Evaluate the conditions of employability, sufficiency and relevance for a certain position.

2. Carry out security studies (home visits, entrance and exit medical exams, referrals and others).

3. Comply with the obligations contracted by the company with the employees holding the information, in relation to the payment of salaries, social benefits and others enshrined in the employment contract.

4. Inform the modifications that occur in the development of the employment contract.

5. Evaluate the quality of the services offered by the employee.

6. Carry out internal studies on the habits of the employee who owns the information for corporate wellness programs. By virtue of the foregoing, the employee authorizes  Nemaho.  to treat the personal data that is provided in the development of the employment relationship, during the entire time of permanence in the entity and after the relationship has ended, as long as there is a legal or contractual conservation duty on the part of  Nemaho.

The authorization for the processing of personal data is granted by the employee within what is described in this Personal Data Protection Policy, which is known and complies with the provisions of Law 1581 of 2012. Some of these tasks are carried out in compliance with a legal and contractual duty and therefore the processing of personal data is understood to be included in them. For people who are not selected, their information will be kept in order to be analyzed in the future in vacancies different from those initially applied.

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SENSITIVE DATA :  On the occasion of the processing of data of employees, former employees and applicants for job vacancies, sensitive personal data may be processed, which will be managed under the conditions indicated in this Policy and under the express authorization of each of the owners in accordance with Law 1581 of 2012 and its regulations.

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5.2. RIGHTS OF THE HOLDERS

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The Owners of the Personal Data registered in the Databases of  Nemaho., have the following rights:

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1. Know, update and rectify your personal data. These rights may be exercised, among others, against Personal Data that is partial, inaccurate, incomplete, fragmented, misleading, or those whose treatment is expressly prohibited or has not been authorized.

2. Request proof of authorization granted to Nemaho. for its collection, storage or treatment, except when expressly excepted as a requirement for treatment, in accordance with the provisions of article 10 of Law 1581 of 2012.

3. Be informed regarding the use that has been given to your Personal Data by  Nemaho, or the person in charge of the treatment, upon request.

4. Through a claim filed in accordance with Art. 15 of Law 1581 of 2012, you can request the revocation of the authorization and/or request the deletion of Personal Data when the treatment does not respect the principles, rights and constitutional and legal guarantees or in any moment provided that the owner does not have the legal or contractual duty to remain in the databases of  Nemaho, and in accordance with the procedure indicated in numeral-4., of this Policy.

5. Access free of charge once a month to your Personal Data that have been subject to Processing.

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5.3. INQUIRIES AND CLAIMS PROCEDURE

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Nemaho., guarantees the right of consultation, supplying the people who act in exercise of this right, all the information contained in their individual registration or that is linked to the identification of the Holder.

The person responsible for dealing with the requests in exercise of the rights by the holders will be the CUSTOMER SERVICE area or the unit that acts as the person who will receive, process and channel the different requests that are received, and will make them reach the respective dependency in charge of the treatment, dependency that once receives these communications, will enter to fulfill the function of protection of personal data, and must process the requests of the owners, in the terms, deadlines and conditions established by the current regulations, for the exercise of the rights of access, consultation, rectification, updating, deletion and revocation referred to in the current regulations on personal data protection.

For the attention of requests for consultation of personal data  Nemaho guarantees that there are different communication channels for the exercise of the rights of the owners.

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Nemaho, has full freedom to enable new channels that facilitate the exercise of this right.

In any case, regardless of the mechanism implemented to attend consultation requests, they will be attended to within a maximum term of ten (10) business days from the date of receipt. In case of impossibility to attend the query within said term, the interested party will be informed before the expiration of 10 days, stating the reasons for the delay and indicating the date on which his query will be attended, which in no case may exceed the five (5) business days following the expiration of the first installment.

Likewise, we guarantee the right to claim, for the correction, updating or deletion of the information contained in the databases, or when they notice the alleged breach of any of the duties contained in Law 1581 of 2012 and other applicable regulations. The claim will be processed under the following rules:

If the claim received does not have complete information that allows it to be processed, such as the identification of the owner, the description of the facts that give rise to the claim, the address, and accompanying documents that you want to assert, the claimant will be required within five (5) business days of receipt to correct the faults. After two (2) months from the date of the request without the applicant submitting the required information, it will be understood that the claim has been withdrawn.

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1. If for any reason  Nemaho receives a claim addressed to another organization, it will transfer it to the appropriate person in said organization within a maximum term of two (2) business days and will inform the claimant of the situation.

2. Once the claim is received in full, it will be included in the database it maintains.  Nemaho, a legend that says "claim in process" and the reason for it, in a term not exceeding two (2) business days. Said legend must be kept until the claim is decided.

3. The maximum term to address the claim will be fifteen (15) business days from the day following the date of receipt. When it is not possible to attend to it within said term, the interested party will be informed before the expiration of the aforementioned period of the reasons for the delay and the date on which their claim will be addressed, which in no case may exceed eight (8) business days following the expiration of the first term.

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5.3.1. Special rules for the exercise of the rights of the holders:

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The request for rectification, updating or deletion must be submitted through the channels enabled by  Nemaho., indicated in the privacy notice and in this document, and contain, at a minimum, the following information:

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1. The name, address of the holder and means of contact to receive the response such as telephone, email, residence address.

2. Documents proving the identity or representation of your representative.

3. The clear and precise description of the personal data with respect to which the owner seeks to exercise any of the rights.

4. Where appropriate, other elements or documents that facilitate the location of personal data.

5. Nemaho., has the obligation to rectify and update at the request of the owner, the information of the latter that turns out to be incomplete or inaccurate, in accordance with the procedure and the terms indicated above. In this regard, the following will be taken into account:

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5.3.2. Data Deletion:

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The owner has the right, at any time, to request  Nemaho, the deletion (deletion) of your personal data when:

• Consider that they are not being treated in accordance with the principles, duties and obligations provided for in Law 1581 of 2012.

• They are no longer necessary or relevant for the purpose for which they were collected.

• The period necessary for the fulfillment of the purposes for which they were collected has been exceeded.

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This deletion implies the total or partial elimination of personal information in accordance with the request of the owner in the records, files, databases or treatments carried out by  Nemaho.  The holder must warn that the cancellation right is not absolute and the person in charge can deny the exercise of the same when:

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1. The owner has a legal or contractual duty to remain in the database.

2. Obstruct judicial or administrative actions related to tax obligations, the investigation and prosecution of crimes or the updating of administrative sanctions.

3. Are necessary to protect the legally protected interests of the holder; to carry out an action based on the public interest, or to comply with an obligation legally acquired by the owner.

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In case of proceeding the cancellation of personal data,  Nemaho., You must operationally perform the suppression in such a way that the elimination does not allow the recovery of the information.

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5.4. INFORMATION SECURITY AND SECURITY MEASURES

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In development of the security principle established in the current regulations,  Nemaho has adopted the necessary technical, human and administrative measures to provide security to the records, preventing their adulteration, loss, consultation, use or unauthorized or fraudulent access. These measures, their protocols and procedures are contained in the respective information security documents, which are reserved for internal use by the organization.

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5.5. USE AND INTERNATIONAL TRANSFER OF PERSONAL DATA AND PERSONAL INFORMATION BY  Nemaho.

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Depending on the nature of the permanent or occasional relationships that any person holding personal data may have with  Nemaho., all of your information may be transferred abroad, subject to applicable legal requirements, with the acceptance of this policy, you expressly authorize the transfer of personal information. The information will be transferred, for all relationships that may be established with Nemaho.

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Without prejudice to the obligation to observe and maintain the confidentiality of the information, Nemaho will take the necessary measures so that these third parties are aware of and agree to observe this Policy, under the understanding that the personal information they receive may only be used for matters directly related to one's own relationship with  Nemaho, and only while it lasts, and may not be used or intended for a different purpose or purpose.

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Nemaho may also exchange Personal Information with other government or public authorities (including, but not limited to, judicial or administrative authorities, tax authorities, and criminal, civil, administrative, disciplinary, and fiscal investigation agencies), and third parties involved in legal and civil proceedings. , and their accountants, auditors, lawyers and other advisers and representatives, considering that it is necessary or appropriate to:

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1. Comply with applicable laws, including laws other than those of your country of residence.

2. Comply with legal processes.

3. Respond to requests from public authorities and the national government and other than those of your country of residence.

4. Enforce our terms and conditions.

5. Protect our operations.

6. Protect our rights, privacy, safety or property, yours or that of others.

7. Get the  recovery or limit the damages that may affect us.

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5.6. PERIOD OF VALIDITY OF THE DATABASES:

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The period of validity of the databases will be the same period of validity of the company  Nemaho, except for those bases whose purpose is for a one-time specific activity and its validity will be until the end of said activity.

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5.7. DATA PROTECTION OFFICER

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According to article 2.2.2.25.4.4 of Decree 1074 of 2015, every person responsible and in charge must designate a person or area that "assumes the function of personal data protection" and that "will process the requests of the owners", for the exercise of the rights referred to in Law 1581 of 2012, therefore  Nemaho.  has appointed the Compliance Officer as Data Protection Officer.

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5.8. VALIDITY AND UPDATING OF THE POLICY

This policy is effective as of March 24, 2017.

When the terms of the privacy policy change in essence, as a general rule, a new authorization will be obtained in the established manner through the usual means of contact between the company and the owners.

Any substantial change in the treatment policies will be communicated in a timely manner to the owners of the data through the usual means of contact and/or through: The website www.Nemaho.co Email sent to the owners: for holders who do not have access to electronic means or those who cannot be contacted, will be communicated through open notices at the company's headquarters.

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