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Personal Data Processing Policy

Last updated: May 24, 2026

Notice: This is an English translation provided for convenience. The Spanish version is the legally binding text under Colombian Law 1581 of 2012 and Decree 1377 of 2013.

This Personal Data Processing Policy (the "Policy") is issued by PROTEC, identified with NIT 900.123.456-7 ("PROTEC"), in compliance with Article 17 of Law 1581 of 2012, Decree 1377 of 2013 and related regulations.

1. Purpose

To establish the guidelines and procedures applied by PROTEC for the collection, storage, use, circulation and deletion of personal data, as well as the rights of Data Subjects and the mechanisms to enforce them.

2. Scope

This Policy applies to all databases administered by PROTEC in its capacity as Controller or Processor, as well as to internal personnel, contractors, suppliers and partners who have access to personal data by virtue of their relationship with PROTEC.

3. Legal framework

  • Political Constitution of Colombia, Article 15.
  • Law 1581 of 2012 — General Regime for the Protection of Personal Data.
  • Decree 1377 of 2013 — Partial regulation of Law 1581.
  • Decree 1074 of 2015 — Single Regulatory Decree of the Trade, Industry and Tourism Sector.
  • Circulars and guidelines from the Superintendence of Industry and Commerce.

4. Data Controller

  • Company name: PROTEC
  • NIT: 900.123.456-7
  • Domicile: Calle 37 b sur #69-62, Barrio Carvajal, Bogotá D.C.
  • Email: [email protected]
  • Phone: +57 311 250 0123

5. Processing and purposes

PROTEC collects and processes personal data of the following categories of Data Subjects for the following purposes:

5.1 Clients and prospects

  • Handling quotation, advisory and commercial information requests.
  • Managing the commercial, contractual and post-sale relationship.
  • Billing, payment management and compliance with accounting and tax obligations.
  • Sending commercial communications (with prior authorization).
  • Quality and satisfaction surveys.

5.2 Suppliers

  • Management of the contractual relationship.
  • Payments and compliance with legal and tax obligations.
  • Supplier evaluation and verification.

5.3 Employees and candidates

  • Selection, hiring and personnel administration processes.
  • Compliance with labor, social security and tax obligations.
  • Talent management, training and development.

6. Sensitive data and data of minors

PROTEC does not collect sensitive data or data of minors through its website. When exceptionally necessary to process sensitive data (e.g., biometric data for access control at headquarters), express and explicit authorization will be obtained from the Data Subject, in accordance with Article 6 of Law 1581 of 2012.

7. Rights of Data Subjects

Data Subjects whose personal data is processed by PROTEC have the following rights:

  1. Access, update and rectify their personal data.
  2. Request proof of the authorization granted.
  3. Be informed about the use given to their data.
  4. File complaints with the Superintendence of Industry and Commerce.
  5. Revoke the authorization and request deletion of the data.
  6. Free access to their data subject to Processing.

8. Procedure for inquiries and complaints

The Data Subject or their successors may consult the personal information about the Data Subject that exists in any database. PROTEC will provide all information contained in the individual record or linked to the Data Subject's identification.

8.1 Inquiries

Inquiries will be answered within a maximum of ten (10) business days from the date of receipt. When it is not possible to respond within that term, the interested party will be informed, stating the reasons for the delay and the date on which the inquiry will be answered, which in no case may exceed five (5) business days following the expiration of the first term.

8.2 Complaints

The complaint must contain: (i) identification of the Data Subject, (ii) description of the facts, (iii) address and contact details, (iv) documents the party wishes to support.

If the complaint is incomplete, the interested party will be required within five (5) days of receipt to correct the deficiencies. If two (2) months pass without the petitioner providing the required information, the complaint will be deemed withdrawn.

The maximum term to address the complaint will be fifteen (15) business days counted from the day following receipt, extendable by eight (8) additional business days.

9. Service channels

  • Email: [email protected]
  • Mail: Calle 37 b sur #69-62, Barrio Carvajal, Bogotá D.C., attn: Personal Data PROTECtion area.
  • Phone: +57 311 250 0123

10. Validity

This Policy is in force from May 24, 2026 and is of indefinite duration. The databases administered by PROTEC will be valid for the time during which the information is maintained and used for the described purposes, unless otherwise provided by law.

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