Who we are
We are RESULTS Realty Group and our website address is: https://resultsrealtygroupcr.com.
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Personal Data Processing Policy
OUR COMPANY in compliance with the international General Data Protection Regulation (GDPR), informs the Owners of Personal Data that are processed in any way by the company of this information processing policy, thereby complying with the Law. The main purpose of this Policy is to inform the Owners of the Personal Data, the rights that assist them, the procedures and mechanisms established by the company to make these rights of the Owners effective, and inform them of the scope and purpose of the Treatment to which the Personal Data will be subjected in the event that the Owner grants express, prior and informed authorization. The company thus also ratifies its commitment to the various interest groups with which it interacts; and with the manifest interest of respecting all their rights, especially with this instrument their right to Habeas Data, privacy and other related rights.
CHAPTER I
General disposition
FIRST ARTICLE: DEFINITIONS. These definitions relate to the meaning that should be given to terms within this document.
a) Authorization: It is the prior, express and informed consent of the Owner to carry out the Processing of their personal data.
b) Database: It is the set of personal data that is subject to Treatment regardless of its modality.
c) Financial Data: It is all Personal Data referring to the birth, execution and extinction of monetary obligations, regardless of the nature of the contract that gives rise to them, the Treatment of which is governed by the corresponding regulations.
d) Personal Data: It is any information related or relatable to a natural person.
e) Public Data: It is that which the law calls such, or that which rests in records, certificates, documents or databases of a public nature.
f) Sensitive Data: It is personal data related to the privacy of the Owner or that may give rise to discrimination or differential treatment. Bio-metric data is also part of this category.
g) Data Processor: It is the natural or legal person, public or private in nature, who, by themselves or in association with others, carries out the Processing of Personal Data on behalf of the person responsible for the Treatment.
h) Authorized: This is the person and their dependents who, by virtue of the Authorization and these Policies, have the legitimacy to Process the Owner’s Personal Data. The Authorized includes the genus of the Authorized.
i) Authorization: It is the legitimization that expressly and in writing through a contract or document that replaces it, grants the Company to third parties, in compliance with the applicable Law, for the Processing of Personal Data, converting such third parties into Data Processors. the Personal Data delivered or made available.
j) Data Controller: This is the person, authorized by the Owner, who manages and makes decisions regarding the Database.
k) Owner: It is the natural person to whom the data stored in the Database refers, and the object of protection of the Law and related regulations.
l) Transfer: It is the communication of personal data between the Processor and the person responsible for the treatment.
m) Transmission: It is the Personal Data Processing activity through which the same is communicated, internally or with third parties, inside or outside the country, when said communication has as its objective the performance of any personal data Processing activity.
n) Processing of Personal Data: It is all aimed at the processing of Databases, as well as their transfer to third parties.
SECOND ARTICLE: OBJECT. The Database and Information Treatment Policy aims to develop the procedure to collect, store, use and carry out any activity on personal data, and other rights, freedoms and constitutional guarantees; as well as the right to information thereof, as stipulated by law and other corresponding regulations.
ARTICLE THREE: SUBJECT TO LEGAL PROVISIONS. The Company states that the guidelines for the Processing of personal data will be those provided by the current regulations on the matter.
ARTICLE FOUR: PURPOSES OF THE DATA COLLECTED. All the data that the company collects are aimed at: i) Generating and managing the collection of all the information necessary for compliance with tax, commercial, civil, labor, legal obligations and in general any obligation that concerns the company; ii) Manage the company, with respect to its clients, suppliers, shareholders and other interest groups; Regarding clients, the information collected can be used, without being restricted to: delivery of information to financial entities for the management of financial services; customer loyalty; customer service management; advertising; marketing; management and commercial contact; contacts for informational emails; sending physical and email correspondence; portfolio management; offer of sale, rental and exchange of real estate; receipt and sending of real estate offers; transfer of information for contractual purposes; update or correct property data; information from our commercial partners; making calls (call center) for administrative, commercial and advertising purposes; and in general, information related to the activity involved in the contracts signed between the parties; develop technologies, services or plans that represent a better service for customers iii) Comply with the legal and contractual obligations of the company; iv) Act within the framework of legal requirements in order to verify the legal nature and situation of some clients, contractors or suppliers; v) Keep the physical or digital file for the legally required time so that it can be consulted later by the Owner or an authority; vi) The transfer and transmission of the Databases when necessary to comply with collection actions, credit processing, judicial actions and in general the other purposes provided for in this section; vii) Management of employee information related to payroll, social management, social security, selection processes, contractual relationship and employee well-being ix) Other activities necessary for the effective provision of any of the habitual or accidental services provided by the company.
ARTICLE FIFTH: PRINCIPLES. The principles indicated in this article are the guidelines that will be respected by the company in the processes of collection, storage, use and administration of personal data:
- Principle of legality regarding the Processing of personal data: The Processing referred to in this Policy is an activity regulated by law, which must be subject to what is established therein and the other provisions that develop it.
- Principle of purpose: The Treatment obeys the purposes established in the fourth article of this document.
- Principle of freedom: Treatment can only be carried out with the prior, express and informed consent of the Owner. Personal data may not be obtained or disclosed without prior authorization, or in the absence of a legal or judicial mandate that requires consent.
- Principle of truthfulness: The information subject to Treatment must be truthful, complete, exact, updated, verifiable and understandable.
- Principle of transparency: In the Treatment, the right of the Owner to obtain from the person responsible for the Treatment or the Processor, at any time and without restrictions, information about the existence of data that concerns him or her must be guaranteed.
- Principle of restricted access and circulation: The Processing of personal data and Databases can only be done by the company or whoever it delegates according to the authorization provided by the Owner. Personal data may not be available in public access and mass dissemination media. If stored in the cloud, software or similar mechanisms, these will have restricted access and will not be public.
- Security principle: The company will provide minimum security conditions to protect the information contained in its Databases, for this purpose basic archiving measures will be implemented with respect to physical documents and digital security systems such as anti-virus and/or storage in the cloud for digital files.
- Principle of confidentiality: As a general rule and except as provided in the Law, in the respective contract, or in this Policy (with the authorization of the Owner in the last two cases) the information and personal data will be treated confidentially.
CHAPTER II
Rights and duties
ARTICLE SIX: RIGHTS OF THE OWNER OF PERSONAL DATA. In accordance with the Law, the Holders of Personal Data have the following rights: i) Know, update and rectify their Personal Data before the company or those in charge of processing them. This right may be exercised, among others, against partial, inaccurate, incomplete, fragmented, misleading data, or those whose Processing is expressly prohibited or has not been authorized; ii) Request proof of the Authorization granted to the company, unless the Law indicates that said Authorization is not necessary; iii) Submit requests to the company or the Data Processor regarding the use that has been given to your personal data, and that they provide you with such information; iv) Submit complaints for violations of the Law to a competent control body; v) Revoke your Authorization and/or request the deletion of your Personal Data from the company’s databases, when the Superintendency of Industry and Commerce has determined by means of a definitive administrative act that the company or the Data Processor has incurred in the Treatment in conduct contrary to the Law or when there is no legal or contractual obligation to maintain personal data in the Controller’s database; vi) Request access and access free of charge to your personal data that has been processed in accordance with the Law; vii) Know the modifications to the terms of this Policy prior to and efficiently implementing the new modifications or, failing that, the new information processing policy; viii) Have easy access to the text of this Policy and its modifications; ix) Access in an easy and simple way the personal data that is under the control of the company to effectively exercise the rights that the Law grants to the Owners; x) Know the agency or person authorized by the company to whom you can submit complaints, queries, claims and any other request regarding your personal data.
The Holders may exercise their legal rights and carry out the procedures established in this Policy, by presenting their original identification document. Minors may exercise their rights personally, or through their parents or adults who have parental authority, who must prove it through the relevant documentation. Likewise, the rights of the Owner may be exercised by the successors in title who prove said quality, the representative and/or attorney of the owner with the corresponding accreditation and those who have made a stipulation in favor of another or for another. Requests may be filed physically or via email depending on the data in the header.
ARTICLE SEVEN: MANAGER AND RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA. The company will be the one directly responsible and in charge of the processing of personal data; Within it you may delegate any area or dependency for such purposes. In general, the company undertakes to: i) Receive requests from the Holders of personal data, process and respond to those that are based on the Law or this document, such as: requests to update personal data; requests to know personal data; requests for deletion of personal data when the Owner presents a copy of the decision of a competent control body in accordance with the provisions of the Law, requests for information on the use given to their Personal Data, requests to update Personal Data, requests of proof of the Authorization granted, when it has proceeded according to the Law; ii) Respond to the Holders of Personal Data regarding those requests that do not proceed in accordance with the Law. The company’s contact information is indicated in the corresponding section.
CHAPTER III
Procedures
ARTICLE EIGHTH: OWNER PROTECTION MECHANISMS. The owner may claim his rights, using the following procedures for this purpose:
8.1. Queries: The company will have mechanisms for the Owner, his successors, his representatives and/or attorneys, those to whom it has been stipulated in favor of another or for another, and/or the representatives of minor Owners, to formulate queries regarding of the personal data of the Owner that resides in the company’s Databases.
Whatever the medium, the company will keep proof of the query and its response. a) If the applicant has the capacity to formulate the query, in accordance with the accreditation criteria established in the Law, the company will collect all the information about the Owner that is contained in the individual record of that person or that is linked to the identification of the Owner within the company’s databases and will be made known to the applicant. b) The person responsible for answering the query will respond to the applicant as long as he or she has the right to do so because he or she is the Owner of the Personal Data, his successor in title, attorney-in-fact, representative, whether it has been stipulated by another or for another, or is the legal person responsible in the case. case of minors. This response will be sent within ten (10) business days from the date on which the request was received by the company. c) In the event that the request cannot be attended to within ten (10) business hours, the applicant will be contacted to inform them of the reasons why the status of their request is in process. To do this, the same means or one similar to that used by the Owner to communicate their request will be used. d) The final response to all requests will not take more than fifteen (15) business days from the date on which the initial request was received by the company.
8.2. Claims: The company has mechanisms for the Owner, his successors, representative and/or attorneys, those who stipulated for another or for another, and/or the representatives of minor Owners, to formulate complaints regarding (i) Personal data Treated by the company that must be corrected, updated or deleted, or (ii) the alleged breach of the company’s legal duties. The claim must be presented by the Owner, his successors or representatives or accredited in accordance with the Law, as follows:
· You must contact the company electronically at the email address given in the relevant section; or physically the address given by the company.
· It must contain the name and identification document of the Owner.
· It must contain a description of the facts that give rise to the claim and the objective pursued (updating, correction or deletion, or compliance with duties).
· It must indicate the address and contact and identification information of the claimant.
· It must be accompanied by all the documentation that the claimant wants to assert.
8.2.1 Before addressing the claim, the company will verify the identity of the Personal Data Owner, its representative and/or attorney, or the accreditation that there was a stipulation by or for another. To do so, you may require the Holder’s original citizenship card or identification document, and any special or general powers or documents that may be required as the case may be.
8.2.2 If the claim or additional documentation is incomplete, the company will require the claimant once within five (5) days of receipt of the claim to correct the deficiencies. If the claimant does not present the required documentation and information within two (2) months following the date of the initial claim, it will be understood that he or she has abandoned the claim.
8.2.3 Once the claim is received with the complete documentation, a legend that says “claim in process” and the reason for it will be included in the company’s Database where the Owner Data subject to the claim is stored, in a term no more than two (2) business days. This legend must be maintained until the claim is decided.
8.2.4 The maximum term to address the claim will be fifteen (15) business days counted from the day following the date of receipt. When it is not possible to address the claim within said term, the interested party will be informed 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.
VALIDITY. This Policy applies as of January 1, 2024. The personal data that is stored, used or transmitted will remain in our Database, based on the criteria of temporarily and necessity, for the time necessary for the purposes mentioned in this Policy, for which they were collected.