MANUAL INFORMATION TO GUARANTEE THE COMPLIANCE OF THE STATUTORY
LAW ON THE PROTECTION OF PERSONAL DATA.
I. GENERAL CONSIDERATIONS
Article 15 of the Political Constitution of the USA establishes the right of
any person to know, update and rectify the information that exists about it in data banks or
files of public or private entities. It also orders those who have personal data of third
parties to respect the rights and guarantees provided in the Constitution when this kind of
information is collected, processed and circulated.
Statutory Law 1581 of October 17, 2012 (hereinafter, "Law 1581") establishes the
minimum conditions for the legitimate treatment of personal data of customers, employees,
and any other natural person. Both subparagraphs k) of article 17 and f) of article 18 from
this law oblige those responsible for the processing of personal data to "adopt an internal
manual of policies and procedures to ensure proper compliance with this law and, in
special, for the attention of inquiries and claims by the holders ".
Article 25 of the same law mandates that the information treatment policies are mandatory
and states that ignorance will result in sanctions.
These policies cannot guarantee a level of treatment lower than that established in Law
1581. Chapter III of December 1377 of June 27, 2013 (hereinafter, "Decree 1377") regulates
some aspects related to the content and requirements of the information processing
policies and privacy notices.
Realty Capital LLC is committed to respecting the rights of its customers, employees
and third parties in general. Consequently, it adopts the following information treatment
policy of obligatory application in all the activities of the Company that involve the
processing of personal data (hereinafter, the "Policy").
This Policy is mandatory and strict compliance by all employees of Realty Capital LLC
as well as contractors and third parties acting on behalf of Realty Capital LLC., all
employees of Realty Capital LLC must observe and respect this Policy in the
performance of their duties. In cases where there is no employment relationship, a
contractual clause must be included so that those who act on behalf of Realty Capital LLCbr> are obliged to comply with the Policy.
Failure to do so will result in penalties of a labor nature or contractual liability, as the case
may be. The foregoing, without prejudice to the duty to respond financially for the
damages that may be caused to the holders of the data or to Realty Capital LLC for
breach of the Policy or the improper treatment of personal data.
For all purposes, this document will act as Internal Manual of Policies and Procedures, as
well as the Information Treatment Policy, referred to in articles 17 (literal k), 18 (literal f)
and 25 of the Law 1581.
The terms used in this document will have the meaning assigned in this section.
Authorization. Prior, express and informed consent of the Holder to carry out the
Processing of Personal Data.
Database. An organized set of Personal Data of the Holders that are subject to Treatment
by the person in charge or the person in charge of the information. It is clarified that the
servers on which the Realty Capital LLC Databases are located in the territory of the
USA or abroad and that said equipment is located in safe places and its
access is only authorized to the personnel responsible for IT by Realty Capital LLC
Candidate. A natural person who sends to Realty Capital LLC, by any means, his
resume and other data related to the exercise of his profession or trade in order to
participate in the selection processes of personnel that the Company advances.
Query. Request of the Data Holder or the persons authorized by it or by law to know the
information of the Owner that rests in databases or files.
Customers. Individuals or legal entities that have a civil or commercial relationship with
Realty Capital LLC by reason of the acquisition of the goods and/or services that it
offers and that can be located anywhere in the world at the moment of making the
Personal Data. Any information linked to or associated with one or more specific or
determinable natural persons such as name, telephone number, address, debit/credit card
number, identification or marital status.
Sensitive Personal Data. Personal Data that affect 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 they promote the interests of any political party
or that guarantee the rights and guarantees of opposition political parties, as well as the
data related to health, sex life and biometric data (fingerprints, among others).
Public personal data. Personal Data classified as such according to the mandates of the
law or the Political Constitution and all those that are not semi-private or private. They are
public, among others, the Personal Data relating to the marital status of the persons, to
their profession or occupation and to their status as merchants or public servants.
By their nature, they can be contained in public documents, public records, gazettes, and
official bulletins, and judicial sentences duly executed that are not subject to reservation.
These Personal Data can be obtained and offered without reservation and regardless of
whether they refer to general, private or personal information.
Personal Private Data. It is the Personal Data that by its intimate or reserved nature is
only relevant for the Data Owner. Examples: books of merchants, private documents,
information extracted from the home inspection.
Personal data are semi-private. Personal Data is semi-private that does not have an
intimate, reserved, or public nature and whose knowledge or disclosure may interest not
only its Owner but also a certain sector or group of people or society in general, such as,
among others: the Personal Data Reference the fulfillment and breach of financial
obligations or Personal Data related to relations with social security entities.
In charge of the Treatment. A natural or legal person, public or private, that performs, by
itself or in association with others, the Processing of Personal Data on behalf of
Realty Capital LLC as responsible for the Treatment.
Provider. A natural or legal person that provides a service to Realty Capital LLC or sell
you a product under a contractual relationship.
Claim. Request from the Data Owner or the persons authorized by him or by law to
correct, update or delete his Personal Data.
Responsible for the Treatment. A natural or legal person that decides on the database
and/or the Treatment of Personal Data, determining, among others, the collection and
purposes of the Treatment. For purposes of this Policy, it is understood that the person in
charge is Realty Capital LLC, a commercial company legally constituted with NIT.
Headline. A natural person who has, among others, the quality of client, supplier, worker
or visitor and whose personal data are subject to Treatment by Realty Capital LLC
Employee. Natural person who provides services to Realty Capital LLC under an
Treatment. Any operation or set of operations on Personal Data such as, among others,
the collection, storage, use, circulation or suppression of this kind of information.
Transmission. Processing of Personal Data that implies the communication of the same
within (National Transmission) or outside USA (International Transmission) and that
has the purpose of carrying out a Treatment by the Person in charge on behalf of the
person in charge.
Transfer. It takes place when the person in charge and/or in charge of the Processing of
Personal Data, located in USA, send the Personal Data to a receiver, who in turn is
responsible for the Treatment and is located inside or outside the country.
System. Technology platform of Realty Capital LLC for the processing of transactions
and collection of payments from its Clients, as well as for the validation of processed
transactions, in order to mitigate the risk of fraud by identity theft. For this, Realty Capital LLC
guarantees that the data and information possess the necessary security elements
to safeguard the information, such as Firewalls, authentication and encryption systems.
Visitor. Any natural person who enters the facilities of Realty Capital LLC
For the definition of terms not included in the foregoing list, reference must be made to the
legislation in force, especially Law 1581 of 2012 and Decree 1377 of 2013, giving the
meaning used in them.
IV. PRINCIPLES FOR THE PROCESSING OF PERSONAL DATA
The Processing of Personal Data must be done respecting the general and special rules
on the matter, as well as executing activities permitted by law. In the development,
interpretation, and application of this Policy, the following principles will be applied in a
harmonic and integral manner:
Principles related to the collection of Personal Data.
A principle of freedom. The Treatment of our Databases can only be exercised with the
free, prior, express and informed consent of the Holder. Personal Data may not be
obtained or disclosed without prior authorization or in the absence of legal or judicial
mandate that relieves the consent.
A principle of limitation of the collection. Only Personal Data that are strictly necessary
for the fulfillment of the purposes of the Treatment must be collected, in such a way that
the registration and disclosure of Personal Data that are not closely related to the purpose
of the Treatment are prohibited. Consequently, everything reasonably possible must be
done to limit the processing of Personal Data to the minimum necessary. That is, the
Personal Data must be: (i) adequate, (ii) relevant and (iii) consistent with the purposes for
which they were provided.
Principles related to the use of Personal Data.
A principle of purpose. The Treatment must obey a legitimate purpose in accordance with
the Constitution and the law, which must be informed to the Holder. The Data Holder must
be clearly, sufficiently and previously informed of the purpose of the information provided
and, therefore, Personal Data may not be collected without a specific purpose.
The Personal Data must be treated in accordance with authorized uses. If over time, the
use of Personal Data changes to forms that the person does not expect, it is necessary to
obtain again the prior consent of the Holder.
A principle of non-discrimination. It is prohibited to perform any act of discrimination
due to the information collected in the databases or files.
Repair principle. It is mandatory to indemnify the damages caused by possible faults in
the Processing of Personal Data.
Principles related to the quality of information.
The principle of truth or quality. The information subject to Treatment must be truthful,
complete, accurate, updated, verifiable and understandable. The processing of partial,
incomplete, fractional or misleading personal data is prohibited.
Principles related to data protection, access, and circulation
The principle of security. The persons indicated in section II of this Policy must comply
with the necessary technical, human and administrative measures established by
Realty Capital LLC to grant security to the Personal Data, avoiding its adulteration, loss,
Consultation, use or unauthorized or fraudulent access.
The principle of transparency. In the Treatment, the right of the Data Holder to obtain at
any time and without restrictions, information about the existence of Personal Data that
concerns him or her must be guaranteed.
The principle of restricted access. Only the following persons will be allowed access to
(i) To the Data Owner.
(ii) To the persons authorized by the Data Owner.
(iii) To persons who by legal mandate or court order are authorized to know the
information of the Data Holder.
(iv) To the other persons legitimated as indicated in article 20 of Decree 1377.
In all cases, before giving access to Personal Data, the identity of the person requesting to
know the Personal Data must be established with certainty and sufficiency.
Personal Data, except public information, may not be available on the Internet or other
means of dissemination or mass communication unless the access is technically
controllable to provide a restricted knowledge only to the Holders or authorized third
parties according to the law and this Politics.
Principle of confidentiality: All persons involved in the Processing of Personal Data, which
are not public in nature, are obliged to guarantee the preservation of information, even
after the end of their relationship with any of the tasks included in the Treatment, being
able to only supply or communicate Personal Data when it corresponds to the
development of the authorized activities in the law and in the terms of this.
V. PURPOSE OF THE TREATMENT
Realty Capital LLC, as the person in charge of the Processing of Personal Data and
considering the special nature of said data and the purpose of its Treatment, has classified
its databases as follows:
Shareholders. It contains Personal Data of natural persons who own shares of
Realty Capital LLC, whose Treatment is intended to comply with the legal, statutory,
regulatory and internal provisions, to (i) distribute dividends; (ii) make calls for meetings of
the General Assembly of Shareholders; (iii) issue certifications; (iv) administrative and
contact purposes; (v) among other activities related to the shareholders, their participation
in the meetings of the General Assembly of Shareholders, access to the confidential
information of the company, and the management of their participation in the capital of the
Candidates. It contains personal data of natural persons who have initiated a process of
selection of personnel to be linked to Realty Capital LLC, whose treatment has as its
purpose: (i) the adoption of measures tending to the prevention of illicit activities, including
activities related to the laundering of assets and financing of terrorism; (ii) contact
purposes; (iii) evaluate the characteristics and circumstances of the candidates for a
specific position within the structure of Realty Capital LLC; (iv) corroborate that the
information provided by the applicant is correct; (v) among other activities related to the
recruitment and selection of personnel.
Customers. It contains Personal Data of natural persons who have acquired products
and/or services from Realty Capital LLC and other persons who voluntarily and in the
exercise of their rights have directly supplied their Personal Data to the company because
they wish or require contact with it. The purpose of this Database is to: (i) develop the
corporate purpose of the company; (ii) the execution of the contractual or commercial
relationship with Realty Capital LLC; (iii) the sending of commercial, promotional, news
and / or news related to the products and / or services offered by the company; (iv) the
collection of statistical records; (v) the management of permanent analysis of the
preferences, tastes and profiling of the clients in demographic aspects and consumption
habits, consultation of balances, etc .; (vi) among other administrative, commercial and
contact purposes to comply with the company's corporate purpose.
The sending of commercial information to customers, in accordance with the above, may
be done through (i) email, (ii) text messages (SMS), and/or (iii) phone calls (landline or
With its Authorization, the Customer Data Owner allows Realty Capital LLC to share
your Personal Data with the commercial partners of the company and/or its Affiliates.
Likewise, it authorizes Realty Capital LLC, its commercial allies and/or Affiliates to use
its Personal Data in the own management of Realty Capital LLC and/or its Affiliates, in
order to generate added values.
Contractors, Suppliers, and Promoters of Public Shows. It contains Personal Data of
natural persons who have a contractual and/or commercial link with Realty Capital LLC,
as suppliers, contractors and/or promoters of public shows. The purpose of this Database
is to: (i) develop the corporate purpose of the company; (ii) the execution of the contractual
or commercial relationship with Realty Capital LLC; (iii) the collection of accounting
records; (iv) billing management; (v) the adoption of measures aimed at the prevention of
illicit activities, including activities related to money laundering and financing of terrorism;
(vi) among other administrative, commercial and contact purposes to comply with the
company's corporate purpose.
Employees and Ex-employee. It contains Personal Data of the natural persons that are
currently linked to Realty Capital LLC, those that were labor-related in the past. The
purpose of this Database is to comply with the legal and regulatory provisions in labor and
tax matters, as well as: (i) payroll management and payments of contributions to the social
security and pension system; (ii) personnel registration and control; (iii) the execution of
the contractual relationship; (iv) reports to control and surveillance authorities; (v)
compliance with instructions from the competent judicial and / or administrative authorities;
(vi) implementation of labor and organizational policies and strategies of the parent
company; (vi) implementation of programs and activities aimed at the welfare and
development of human talent; (vii) among other administrative and contact purposes.
PQRS. It contains Personal Data of natural persons who have raised queries, requests,
complaints, claims and / or suggestions to Realty Capital LLC, in relation to the products
and / or services offered by the company, whose Treatment has the following purposes: (i)
attention and processing of the application; (ii) contact; (iii) the collection of statistical
records; (iv) reports to control and surveillance authorities; and (v) other activities related
to customer service.
Visitors. It contains Personal Data of the natural persons that visit the installations of the
headquarters of Realty Capital LLC, whose Treatment has the purpose of complying with
the internal dispositions of security and control of access to the facilities located in the
6801 Hollywood Blvd, Hollywood, CA 90028, including control and monitoring of all
people and goods in the facilities.
When visiting the web portal https://anvio.com/, certain information is automatically stored
in the servers for the administration of the system, it is processing, statistical purposes or
to maintain backup copies. This information includes: (i) the name of the Internet service
provider used; (ii) in some cases, the Internet Protocol (IP) address; (iii) the search
software version (browser software); (iv) the operating system of the electronic device
used to access the portals that are being visited; and even (v) any search history that has
been used to find such portals.
In case Realty Capital LLC carries out a merger, acquisition, spin-off, global disposal of
assets, restructuring, or any other similar process, Personal Data may be subject to
Transfer to the buyer, screener, merged or any other person involved in the said
In the portals of Realty Capital LLC "Cookies" and other proprietary and third-party
technologies are used in order to improve the user's experience, facilitate navigation,
optimize our services and provide information related to your preferences by analyzing
your browsing habits. Likewise, they can be used to facilitate the use of the web portals
By entering and remaining in our web portals, the user authorizes that their browsing data
mobile device provided by them.
Cookies are small units of information stored temporarily in the electronic device of the
user and serve, for the control of sessions, in particular improved navigation, to obtain a
high performance as user friendly of a website, to store personal information related to
identification, as well as to allow the server to provide users of the websites with
advertisements and services.
Realty Capital LLC You can use these technologies to authenticate a user, to
remember your preferences for the use of the Website, to present offers that may be of
interest and to facilitate any type of transactions.
The web portal of Realty Capital LLC may share the information obtained with authorized
and controlled third parties in order to improve the services provided, create user profiles,
offer personalized campaigns and, in any case, perform a statistical analysis of the
browsing behavior of each user to be anonymous.
These third parties will only give the use established in this Policy and in case of requiring
any other action, this will be informed to all the users by the means that the web portal of
Realty Capital LLC disposes of.
Most web browsers accept these technologies automatically, however, the user can avoid
this by changing the configuration of their browser. You can delete those stored in your
electronic device at any time by deleting temporary Internet files.
Realty Capital LLC You can also process the Personal Data for the following purposes:
(i) Carry out the relevant procedures for the development of the pre-contractual,
contractual and / or post-contractual stages of the Data Holders, against any of the
contracts in which it is part Realty Capital LLC, as well as comply with Colombian or
foreign law and the orders of judicial or administrative authorities.
(ii) To disclose, transfer and/or transmit Personal Data within and outside the country to
third parties, as a result of a lawful contract or law or link that so requires or to comply with
the contracts to which Realty Capital LLC is a party, as well as Implement cloud and big
data computing services.
(iii) Implement CRM (customer relationship management) strategies, which include,
among others: (i) a management model of the entire organization, based on customer
orientation and relationship marketing; (ii) create databases or computer systems to
support the management of customer relations, sales, and marketing.
(iv) Conduct invitations to events, improve products and/or services or offer new products,
and all those activities associated with the commercial relationship or existing link with
Realty Capital LLC, or the one that may become available.
(v) Manage procedures (requests, complaints, claims), conduct satisfaction surveys
regarding the goods and/or services of Realty Capital LLC or commercial allies.
(vi) Provide contact information and relevant documents to the commercial force and/or
distribution network, telemarketing, and any third party with the Realty Capital LLC,
have a contractual link of any kind.
VI. RIGHTS OF THE PERSONAL DATA HOLDERS
The rights of the Holders established in the Law and in this Policy may be exercised by the
By the Holder, who must prove his identity sufficiently.
For their successors, prior accreditation of such quality.
By the representative and/or agent of the Holder, prior accreditation of such quality
By stipulation in favor of another or for another.
By the persons that are legally authorized to represent, in the case of minors.
6.1. Know, update and rectify Personal Data. For this purpose, it is necessary to previously
establish the identification of the person, in order to prevent unauthorized third parties from
accessing the Personal Data of the Holder.
6.2. Obtain a copy of the Treatment Authorization.
6.3. Inform about the use that Realty Capital LLC has given or is giving the Personal
Data of the Owner.
6.4. Process the Queries and/or Claims, following the guidelines established in the law and
in this Policy.6.5. Access the request for revocation of the Authorization and/or deletion of
Personal Data when the Superintendence of Industry and Commerce has determined that
in the Treatment by Realty Capital LLC there have been conducted contrary to Law
1581 or the Constitution.
The Holder may also revoke the Authorization or request the deletion of Personal Data
when there is no legal or contractual mandate that imposes the duty to remain in the
database or file of the person in charge or in charge.
The request for suppression of the information and the revocation of the Authorization
shall not proceed when the Holder has a legal or contractual duty to remain in the
database of the person in charge or in charge.
6.6. Access your Personal Data free of charge. The information requested by the Data
Holder may be provided by any means, including electronic means, as required by the
Data Owner. The information should be easy to read, without technical barriers that
impede access and should correspond to the one that rests in the corresponding
VII. DUTIES OF TECH4SENSE S.A.S. AS RESPONSIBLE FOR THE PROCESSING OF
All those obliged to observe this Policy must keep in mind that Realty Capital LLC. must
comply with the duties imposed by USA law. Therefore, they must act in such a way
that they fulfill the following obligations:
Regarding the Data Holder.
Request and keep, under the conditions provided in this Policy and in the law, a copy of
the respective Authorization granted by the Data Owner.
Inform in a clear and sufficient way to the Data Holder about the purpose of the collection
and the rights that assist him by virtue of the Authorization granted.
Guarantee the Data Holder, at all times, the full and effective exercise of the right of
habeas data, that is, knowing, updating or rectifying your Personal Data.
Inform, at the request of the Data Owner, about the use given to their Personal Data.
Process the Queries and Claims formulated in the terms indicated in this Policy and in the
Regarding the quality, security, and confidentiality of Personal Data.
Observe the principles of truthfulness, quality, security, and confidentiality in the terms
established in this Policy.
Keep the information under the security conditions necessary to prevent its adulteration,
loss, consultation, use or unauthorized or fraudulent access.
Update the information when necessary.
Rectify the Personal Data when it is appropriate.
When performing the Treatment through a Manager.
Provide the Data Processor with only the Personal Data whose Treatment is previously
authorized. In the case of national and international Transmissions, a Contract of
Transmission of Personal Data must be signed or contractual clauses that contain the
provisions of article 25 of Decree 1377 must be signed.
Ensure that the information provided to the Treatment Manager is true, complete,
accurate, updated, verifiable and understandable.
Communicate in a timely manner to the person in charge of the processing, all the news
regarding the Personal Data previously provided to him, and adopt the other necessary
measures so that the information provided to him remains updated.
A report in a timely manner to the Person in Charge of Processing the rectifications made
on the Personal Data, so that the latter may proceed to make the appropriate adjustments.
To demand to the Person in Charge of the Treatment, at all times, the respect to the
conditions of security and privacy of the information of the Data Holder.
Inform the Person in Charge of the Treatment when certain information is in a discussion
by the Data Owner, once the claim has been filed and the respective procedure has not
Regarding the Superintendence of Industry and Commerce.
Inform them of possible violations of the security codes and when there are risks in the
administration of the information of the Data Holders.
Comply with the instructions and requirements issued by the Superintendence of Industry
VIII. AUTHORIZATION FOR THE PROCESSING OF PERSONAL DATA
Law 1581 requires that the Authorization to collect Personal Data (email address,
telephone, etc.) be informed in advance and expressly, as illustrated below:
Thus, those obliged to comply with this Policy must obtain from the Data Holder their prior,
express and informed Authorization to collect and process their Personal Data. The
Authorization is not necessary when dealing with: (i) Personal Data of a public nature, (ii)
Processing of information for historical, statistical or scientific purposes, in which the
information is not linked to a specific person; and (iii) Personal Data related to the Civil
Registry of persons.
The request for authorization must include
(i) The Treatment to which your Personal Data and the purpose of it will be submitted.
(ii) The optional nature of their answers to the questions that are asked, when they are
about Sensitive Data or about Data of children and adolescents.
(iii) The rights that assist him as Data Owner, provided in article 8 of Law 1581.
(iv) The mechanisms provided by Realty Capital LLC to access or consult the
information processing policy, as well as its substantial changes.
Secondly, the Holder's consent will be obtained through any means that may be the
subject of a subsequent Consultation.
Proof of compliance with the obligation to inform and consent granted by the Data Owner
must be left. If the Owner requests a copy of these, Realty Capital LLC must supply
The Authorization may also be obtained from unambiguous behavior of the Data Subject,
which allows to reasonably conclude that the latter granted his consent for the Treatment
of his information. Said behavior (s) must be very clear so that it does not admit any doubt
or mistake about the willingness to authorize the Treatment. In no case may the silence of
the Data Holder be considered unequivocal conduct.
Authorization for Data Processing of children and adolescents.
When dealing with the collection and processing of personal data of children and
adolescents, the following requirements must be met:
The Authorization must be granted by persons who are authorized to represent children
and adolescents. The representative of the children and adolescents must guarantee the
right to be heard and to value their opinion of the Treatment, taking into account the
maturity, autonomy, and capacity of the children and adolescents to understand the
It must be informed that it is optional to answer questions about the Personal Data of
children and adolescents.
Treatment must ensure respect for the best interests and fundamental rights of children
It must be explicitly and previously informed to the Data Holder which of the Personal Data
that will be subject to Treatment are sensitive and the purpose of said Treatment.
X. INTERNATIONAL TRANSFER OF PERSONAL DATA
When Personal Data is sent or transferred to another country, it will be necessary to have
the Authorization of the Personal Data Owner that is subject to Transfer. Unless the law
says otherwise, such Authorization is a prerequisite for the international circulation of
Personal Data. In this sense, before sending Personal Data to those responsible for the
Treatment located in another country, those obliged to comply with this Policy must verify
that they have prior, express and unequivocal authorization from the Data Holder that
allows such Transfer.
When this is required in accordance with the provisions of article 26 of Law 1581,
Realty Capital LLC will request the corresponding declaration of conformity from the
Superintendence of Industry and Commerce.
XI. INTERNATIONAL AND NATIONAL PERSONAL DATA TRANSMISSIONS
When Realty Capital LLC wishes to send or transmit Personal Data to one or several
Managers located inside or outside the national territory, it must, through contractual
clauses or through a Contract of Transmission of Personal Data, agree on the following:
The scope of the Treatment.
The activities that the Manager will carry out on behalf of Realty Capital LLC
The obligations that the Manager must meet with the Data Owner and
Realty Capital LLC
The obligation of the person in charge of complying with the duties of the person
responsible, observing this Policy and the law.
The duty of the person in charge of processing Personal Data in accordance with
the authorized purpose and observing the principles established in USA law
and in this Policy.
The obligation of the Person in Charge to adequately protect Personal Data and
databases, as well as to keep confidentiality regarding the Treatment of Personal
XII. PROCEDURES TO PROCESS THE CONSULTATIONS
Consultation of personal data: The Holders may consult the Personal Data that is
stored in the Databases of Realty Capital LLC, for which Realty Capital LLC
as the person in charge of the Treatment or in Charge of the Treatment is obliged
to provide all the information contained in the individual record linked with the
identification of the Holder, after verification of the identity of the applicant.
Channels to exercise rights.
The consultation may be submitted electronically or in writing to the offices of
Realty Capital LLC to the mail and address specified in this Policy.
All inquiries made by the persons entitled to know the Personal Data that is stored in
Realty Capital LLC will be received through the channels to exercise rights set forth in
this Policy or those that are enabled by the company. In any case, it is necessary to leave
proof of the following: (i) Date of receipt of the Consultation, and (ii) Identity of the
Once the identity of the Data Holder has been verified, the Personal Data will be provided,
when required by law. The response to the Consultation must be communicated to the
applicant within a maximum term of ten (10) business days from the date of receipt of the
same. When it is not possible to attend the Consultation within said term, this will be
informed to the interested party, stating the reasons for the delay and indicating the date
on which his Consultation will be attended, which in no case may exceed the following five
(5) business days at the expiration of the first term.
The Claims are intended to correct, update or delete Personal Data, or raise a complaint
about the alleged breach of any of the duties contained in Law 1581 and in this Policy.
The Claim must be submitted by means of a request addressed to Realty Capital LLC,
which contains the following information:
Name and identification of the Data Owner or the person legitimated for that purpose.
An accurate and complete description of the facts that give rise to the Claim.
Physical or electronic address to send the response and report on the status of the
Documents and other relevant evidence you want to enforce.
If the Claim is incomplete, the interested party will be required within five (5) business days
following receipt of the Claim 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
he has withdrawn the Claim.
The maximum term to attend the Claim will be fifteen (15) business days counted from the
day following the date of receipt. When it is not possible to attend the Claim within the said
term, the interested party will be informed of the reasons for the delay and the date on
which his Claim will be handled, which in no case may exceed eight (8) business days
following the expiration of the first finished.
XIII. RESPONSIBLE FOR THE PROTECTION OF PERSONAL DATA AREA
The Customer Service Area of Realty Capital LLC is the dependency or area in charge
of the protection function of Personal Data.
The area in charge of protection of Personal Data will ensure the effective implementation
of the policies and procedures adopted by Realty Capital LLC to comply with the
regulations in force. Likewise, it will implement good practices for the management of
Personal Data within the company.
Among its activities are, among others, the following:
Register the databases of Realty Capital LLC in the National Registry of
Databases and update the report according to the instructions issued by the
Superintendency of Industry and Commerce.
Review the contents of International Data Transmission contracts that are
subscribed with Non-resident Managers in USA.
Accompany and assist the company in the attention of the visits and the
requirements made by the Superintendence of Industry and Commerce.
Coordinate the definition and implementation of controls to this Policy.
XIV. VIDEO SURVEILLANCE
Realty Capital LLC guaranteeing the protection of the right to privacy, it uses various
video surveillance devices installed in internal and/or external locations of its facilities. This
video surveillance system contemplates the capture of images.
Regarding images of specific or determinable people, operations such as capture,
recording, transmission, storage, preservation or reproduction in real time or later, among
others, are considered as Processing of Personal Data and, consequently, are subject to
the legal regime of protection of Personal Data and this Policy.
As a mechanism for obtaining the Authorization of the Holders of this type of Personal
Data, Realty Capital LLC uses distinctive notices in the video surveillance areas, which
must comply, at least, with the content of a privacy notice, in the terms of the Decree 1377.
It must be guaranteed that the notices are visible and legible.
The information collected will be used for the security of people, property, and facilities.
This information can be used as evidence in any type of process before any type of
authority or organization.
In consideration of the principles of purpose and limitation of the collection, as well as the
intrusive nature of the video surveillance systems, Realty Capital LLC provides that
only the Personal Data needed to meet the purposes pursued be collected. Consequently,
these Personal Data will be adequate, pertinent and in accordance with the purposes for
which they were collected.
The Participant accepts and allows the Organizer to make public the images and videos of
their participation for advertising purposes.
XVI. PREVALENCE OF THE POLICY
In the case of inconsistencies in the Treatment of Personal Data between this Policy and
any other internal standard of Realty Capital LLC, the provisions of the Policy shall
XVII. RESPONSIBILITY DEMONSTRATED AGAINST THE PROCESSING OF
Realty Capital LLC will adopt the necessary measures to, if necessary, demonstrate
before the Superintendence of Industry and Commerce that it has implemented
appropriate and effective measures to comply with its legal obligations in everything
related to the Processing of Personal Data. Said measures shall be consistent with the
instructions issued by the Superintendency of Industry and Commerce and with the
mandates of articles 26 and 27 of Decree 1377.
XVIII. DATE OF ENTRY IN FORCE OF THE POLICY AND TERM OF VALIDITY OF THE
This Policy will come into force as of its publication.
Realty Capital LLC reserves the right to modify the Policy at any time and without prior
notice. Any modification will become effective and will have effects against third parties
since its publication in the corresponding channel. Consequently, it is recommended that
clients and others interested visit and frequently consult the web portal: https://anvio.com/,
in the corresponding module, to know the changes.
If the change of this Policy consists in modifying: (i) the name of the person responsible or
(ii) the purpose of the Treatment, Realty Capital LLC communicates the changes to the
Data Subject before or at the latest when the new Policy is implemented. In addition, when
the change refers to the purpose of the Treatment, you must obtain a new Authorization
from the Data Holder.
The validity of the databases will be the reasonable and necessary time to fulfill the
purposes of the Treatment, taking into account the provisions of article 11 of Decree 1377,
and that the Personal Data must be preserved when required for the fulfillment of a legal
or contractual obligation.
XIX. TYPE OF INFORMATION SUBJECT TO TREATMENT
Realty Capital LLC recognizes that its candidates, workers, customers, suppliers, and
visitors have the right to have a reasonable expectation about the type of data that may be
subject to processing, according to the relationship they have with Realty Capital LLC
and the responsibilities, rights, and obligations that from it it is derived. By virtue of this
relationship Realty Capital LLC will collect, store, use and process personal data, which
From the candidates
Full name, Email, Contact telephone number. Age, Last work experience, Latest studies,
Studies in progress, Hours available to work, Resume
From the workers
Full name, Number and type of identity document, E-mail, Contact telephone number,
Age, Date of birth, Resume, Selection process (test results, safety studies, etc.), Work
contract and modifications, Salary and other payments (aid, benefits, bonuses, etc.),
information on judicial and authorized discounts (cooperatives, drafts, etc.), affiliations and
contributions to entities of the comprehensive social security system, fingerprint, HR and
blood group, history occupational clinic (results of entrance exams, discharge and
newspapers, medical disabilities, etc.), photographic record, video recording, voluntary
contributions to pensions or severance payments, information of your family group (full
name, age, number and type of document identity, kinship, study information, etc.),
Trainings received, Bank information (name of the account holder, bank account number,
name and credit codeanco), Tax information (benefits and exemptions), Performance
From suppliers and customers
Full name, Number and type of identity document, Address of address or to receive
correspondence, Contact telephone number, E-mail address, Economic activity, Tax
information: data such as: RUT, Bank information: data such as: name of the owner of the
account, bank account number, name and bank code, Health information: Presence of a
physical or cognitive disability that implies special service requirements.
From the legal representative: data such as full name, number, and type of identity
document, contact telephone, and email. From the person assigned for the portfolio
collection: data such as full name, position, contact telephone number, and email. From
the person designated for the supervision of the contract: data such as full name, position,
contact telephone number, and email. Tax information: data such as RUT Bank
information: data such as name of the account holder, bank account number, name and
From the visitors
Full name, Number and type of identity document, Address of address or to receive
correspondence, Contact telephone, E-mail, Contact in case of emergency, EPS and / or
ARL to which you are affiliated, RH and blood group, Photographic record or in video, Tax
information: data such as: RUT, Bank information: data such as: name of the account
holder, bank account number, name and bank code, Health information: Presence of a
physical or cognitive disability that involves special service requirements or allergies.
If sensitive information is found within the information collected, Realty Capital LLC will
inform about the quality of said data, the purpose of its processing and the possibility of
refusing to provide it.
XX. DATE AND VERSION.
This Policy is published in the month of November 2020 and corresponds to Version No. 1 of