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ALBERTO ÁLVAREZ S. S.A.
In compliance with Law 1581 of 2012, Decree 1377 of 2013, Law 1266 of 2008, and External Circulars 002 and 003 of 2024 issued by the Superintendence of Industry and Commerce (SIC), ALBERTO ÁLVAREZ S. S.A. establishes this Manual of Personal Data Processing Policies and Procedures with the purpose of guaranteeing the protection, management, and security of the information of data subjects who interact with the company.
Digital transformation and the expansion of the real estate sector have made the protection of personal data a fundamental aspect of our operations. ALBERTO ÁLVAREZ S. S.A. has implemented leading-edge measures in information security, regulatory compliance, and access policies, ensuring responsible, reliable, and transparent data processing.
This document aims to establish the guidelines and procedures applicable to the processing of personal data, ensuring that such processing is carried out in strict compliance with current legislation, the fundamental principles of legality, transparency, security, and confidentiality, and respecting the rights of the data subjects.
The terms used in this document have the meaning assigned by Law 1581 of 2012 and the guidelines of the SIC, including:
Personal data: Information linked or that may be associated with an identified or identifiable natural person.
Sensitive data: Information that affects the privacy of the data subject or whose improper use may generate discrimination.
Database: Organized set of personal data subject to processing.
Processing: Any operation performed on personal data, such as collection, storage, use, circulation, or deletion.
Data processor: Individual or legal entity that performs the processing of personal data on behalf of the data controller.
Data controller: Individual or legal entity that decides on the database and its processing.
International data transfer: Sending personal data to a country other than Colombia.
Authorization: Prior, express, and informed consent of the data subject for the processing of their personal data.
Data Protection Officer (DPO): Person responsible for supervising and ensuring compliance with personal data processing policies within the organization.
The personal data processed by ALBERTO ÁLVAREZ S. S.A. will have the following purposes:
In the processing of personal data, ALBERTO ÁLVAREZ S. S.A. will ensure compliance with the following principles:
Legality: Data processing will be governed by the provisions of the law.
Purpose: Processing must correspond to a legitimate purpose that is informed to the data subject.
Transparency: The right of the data subject to obtain information about their data at any time will be guaranteed.
Security: Technical, human, and administrative measures necessary to prevent unauthorized access, use, or consultation will be adopted.
Restricted access: Only authorized personnel may access the information.
Confidentiality: Data will be used solely for the purposes informed.
Minimum retention: Personal data will only be stored for the time necessary to fulfill the purposes of processing.
Accountability: The data controller must demonstrate effectively compliance with the principles, duties, and obligations regarding personal data protection. This involves implementing policies, controls, records, and measures ensuring traceability and accountability in data management.
Proportionality: Only the strictly necessary data must be collected to fulfill the informed purpose. This principle prohibits excessive or irrelevant data processing and imposes the obligation to minimize data collection and avoid gathering more information than reasonably required.
Data subjects may exercise the following rights:
In accordance with current regulations, ALBERTO ÁLVAREZ S. S.A. obtains prior, express, and informed authorization from data subjects for the processing of their personal data. Such authorization is granted through physical, digital, or electronic forms through which the data subject expresses their consent for the collection, storage, use, circulation, transfer, and deletion of their personal data in accordance with the purposes outlined in this manual.
The data subject has the right to know how their information will be used and to revoke their authorization at any time when there is no legal or contractual obligation preventing its deletion. The company ensures that data processing is conducted under principles of legality, security, and confidentiality, always protecting the privacy of data subjects.
If the data subject does not grant the required authorization, ALBERTO ÁLVAREZ S. S.A. will refrain from performing any processing of their information, unless expressly authorized by law.
The Privacy Notice is the communication through which ALBERTO ÁLVAREZ S. S.A. informs data subjects of the existence of personal data processing policies, how the data is collected, used, and protected, and the rights they have over their information. This notice is made available to data subjects at all data collection points, including physical and digital forms, contracts, and the company’s website.
Contents of the Privacy Notice
Identity of the data controller: ALBERTO ÁLVAREZ S. S.A.
Purposes of Processing: The company will use the collected data for contract administration, document management, billing, security, market analysis, regulatory compliance, and other purposes described in this manual.
Rights of the Data Subject: Access, update, correct, and delete personal data, revoke authorization, and file complaints with the Superintendence of Industry and Commerce if their information is being used improperly.
Mechanisms to Exercise Rights: Data subjects may exercise their rights through the email info@albertoalvarez.com or by written request at the company’s offices.
-** Security Measures: ALBERTO ÁLVAREZ S. S.A. *implements technical, administrative, and organizational security measures to protect personal data.
The Privacy Notice is available on the company’s official website, in signed contracts with clients, collaborators, and third parties, and in this document.
ALBERTO ÁLVAREZ S. S.A. adopts technical, human, and administrative security measures necessary to protect personal data and prevent alteration, loss, consultation, use, or unauthorized access.
Personal data will be treated with strict confidentiality and may only be accessed by authorized company personnel, following internal protocols for access, control, and information custody.
Additionally, in compliance with guidelines issued by the Superintendence of Industry and Commerce (SIC), in the event of security incidents, improper access, data leaks, breaches, or any event compromising integrity, availability, or confidentiality of data:
an immediate internal emergency route will be activated, following the company’s established procedures, to:
These actions ensure proper data management and uphold the fundamental rights of data subjects.
As part of its institutional commitment to ethical, responsible, and transparent data use, ALBERTO ÁLVAREZ S.S.A., as the data controller, adopts this policy to regulate the processing of operational usage data generated in digital environments, in a strictly anonymized manner and for statistical purposes.
10.1 Purpose of the Processing
The company may collect operational data derived from the interaction with technological platforms, digital solutions, and internal systems exclusively to:
Evaluate process performance.
Generate aggregated management indicators.
Conduct statistical, historical, and institutional behavior analyses.
Identify opportunities for improving real estate operations.
This processing does not involve identifying natural or legal persons and is limited to non-personalized operational metrics analyzed in aggregated or dissociated form.
10.2 Data Subject to Processing
The following usage data may be collected, among others:
Frequency of system use and navigation.
Duration and response times of digital procedures.
General variables related to managed properties (e.g., general location ranges, transaction types, or standard non-individualized features).
Functional activities within platforms, such as queries, registrations, views, or interactions.
Names, identifications, sensitive data, or information that allows linking to a specific data subject will not be collected.
10.3 Anonymization and Dissociation
Data collected under this policy will be subject to anonymization or dissociation techniques, using technological tools that prevent any possibility of linking the information to specific persons, entities, or properties.
This process ensures that the data cannot be reversed or re-identified, protecting privacy and following principles of minimization and ethical data use.
10.4 Authorization of the Data Subject
The processing of this data will be preceded by prior, express, and informed authorization, granted when signing lease or administration agreements or when using platforms managed by ALBERTO ÁLVAREZ S.A.S.
The clause will clearly state:
That data collection is for statistical and institutional purposes.
That data is non-identifiable and irreversible.
That its use is limited to efficiency analysis and service improvement.
In compliance with organizational principles and ethical guidelines, the following restrictions apply:
These data may not be used for individual profiling or automated decisions that affect rights or interests of data subjects.
They may not be transferred to third parties for commercial, advertising, or marketing purposes, except under legal obligation.
They may not be used for segmentation or discrimination of natural or legal persons.
Improper use of these data constitutes a violation of the internal data protection framework and may result in disciplinary, contractual, or legal actions.
This manual will be periodically reviewed and updated according to regulatory or internal changes, ensuring ongoing compliance with best practices in personal data protection.
This manual becomes effective as of its publication and will be updated when necessary.