Global privacy policy of patHUBlatam
This Privacy Policy establishes the privacy standards and practices of PATHUBLATAM from the effective date.
PATHUBLATAM (“patHUBlatam”) cares about your privacy and is interested in show you how we collect, use and disclose Personal Data. This Privacy Policy establishes our practices related to the Personal Data that we collect during the execution of our activities, including those carried out through our website (***). By providing Personal Data or using the Services, you recognize that you have read and understood this Privacy Policy. This Privacy Policy applies to all countries in which patHUBlatam provides its Services.
1. Who is the controller of the processing?
PATHUBLATAM with Tax Identification Number XXXX, an international patent solution website, which head office is based in Bogotá D.C. (Colombia), in (***), with telephone +57(***), which acts as the controller of your Personal Data. patHUBlatam provides online consulting and patent prosecution Services, hereinafter referred to as “Services”.
2. What data do we collect?
The information we process (collect, store, use, circulate and delete) about you depends on the interest group to which you belong to and how we interact with you. Personal Data is information that identifies you, information linked to you or that can be associated with you. This includes information that could be used to contact you. We collect the following information:
- 2.1. Individually Identifiable Information. It is information that identifies a natural person, information linked or that can be linked to a determined or determinable natural person (“Personal Data”). Such information may include, but is not limited to, Commercial Information.
- In relation to Commercial Information. Using our Services, we may ask you to provide Business Information that relates you to the company you work for, such as contact information, information about your title and functions at the company; as well as information on the practices, policies, processes and supporting documentation of the company where you work. This Commercial Information is stored in our systems, and we use it to provide the Services that you have contracted in the terms of the agreements that we subscribe with your company.
- 2.2. Personal information of third parties. If you send us Personal Data relating to another person, you declare that you have the authorization to do it and that allow us to use this Personal Data in the terms of this Privacy Policy
3. How do we collect personal data?
We collect Personal Data from the following sources:
- 3.1. Information you provide to us. By fulfilling the registration form in which we ask you to provide your Personal Data to use our Services; contact us; or establish a legal relationship with us.
- 3.2. Information we gather when you use our Services. We collect information related to the solutions we offer, which allows us to identify your browser, your IP address, your account on the website or your consumer behavior data. It includes information about security measures and any other information generated by your interaction with our website.
- 3.3. Information we collect from third parties. We consult and collect information from third parties when we can legally rely on these sources. This information includes information available in public databases.
4. How do we process your personal data?
- 4.1. If you are an employee, job applicant or former employee
- We process your Personal Data to execute our legal and contractual obligations with you to fulfill the following purposes:
- a) Develop recruitment, evaluation and employment processes, make security studies, including polygraph tests; send communications useful for the aforementiones processes; and, know and evaluate the information related to their academic, professional and work activities.
- b) Carry out all the necessary activities to execute the existing contracts with the workers and their obligations, including making the payment of salaries, social benefits and others that arise from the employment relationship.
- c) Verify the compliance of the internal policies of patHUBlatam and the business purposes, including but not limited to compliance with legal or contractual obligations to third parties.
- d) Manage the information and communication systems of patHUBlatam, including, generating backup copies and files of the information contained in the equipment provided by patHUBlatam.
- e) Carry out corporate welfare programs for employees, of vigilance of the Social Security and Health Management System and for health promotion and prevention activities.
- f) Submit information for the procedure before entities related to the Social Security and Health Management System, including the request for reimbursement for payments of licenses or disabilities to the competent organizations, including Health Maintenance
- Organizations, among others. Likewise, in front of financial entities for the analysis of benefits, such as drafts.
- g) Send communications by courier, e-mail, mobile devices, or through any other mean of communication with commercial, advertising or promotional information about Services, events, promotions, campaigns and/or contests of a commercial or advertising nature by patHUBlatam.
- h) Send information related to the liquidation, culmination of activities and participation in future selection processes, after the termination of the employment contract.
- i) Verify and update Personal Data.
- 4.2. If you are a contractor or supplier
- We process your Personal Data to execute our legal and contractual obligations with you, in particular, to fulfill the following purposes:
- a) Contact and contract with providers of services or products that patHUBlatam required for the development of its activities and the provision of its facilities; as well as making the necessary requests to report the accounting, legal and tax information related to them.
- b) Perform all the activities required to execute the existing contracts with Suppliers.
- c) Verify the information in credit bureaus or restrictive lists, with the purpose of using it as an element of analysis in the commercial relationship.
- d) Carry out accounting, fiscal, administrative, due diligence, billing, and other procedures related to the commercial relationship.
- e) Send communications by courier, e-mail, mobile devices, or through any other mean of communication with commercial, advertising, or promotional information about the Services, events, campaigns and/or contests created by patHUBlatam.
- f) Verify and update Personal Data.
- g) Support internal or external audit processes and make perform statistical studies or accounting processes.
- 4.3. If you are our client or potential client
- We process your Personal Data for the following purposes:
- a) Provide the contracted Services as well as carrying out satisfaction campaigns and monitoring the provision of the Services.
- b) Send information related to the status of the Services, it progresses, reminders of dates for uploading documents to the platform and warnings about the deadlines for the submission of documents.
- c) Send information to payment gateways to purchase Services offered by patHUBlatam.
- d) Send communications by courier, e-mail, mobile devices, or through any other mean of communication with commercial, advertising, or promotional information about Services, events, promotions, and/or contests of a commercial or advertising nature, related to patHUBlatam.
- e) Process orders, requests or any type of petition that is made by the client through any of the contact forms that are made available to them.
- f) To carry out statistical studies or data analysis based on the information provided by the customer and even that collected through cookies.
- g) Inform about changes in our data privacy policies.
- h) Support internal or external audit processes and accounting processes.
- i) Carry out accounting, fiscal, administrative, due diligence, billing and other procedures related to the commercial relationship.
- j) Verify and update Personal Data.
- k) Process inventor’s Personal Data to fill in the corresponding patent application before the competent authority.
- l) Submit inventor’s Personal Data to monitoring and control agencies.
- m) Process inventor’s Personal Data to support internal or external audit processes and accounting processes.
- 4.4. If you are a partner agent
- We process your Personal Data for the following purposes:
- a) Request the execution of the Services acquired by the client under the terms of the commercial alliance in force.
- b) Send communications by courier, e-mail, mobile devices, or through any other mean of communication with commercial, advertising, or promotional information about Services, events, promotions, and/or contests of a commercial or advertising nature, related to patHUBlatam.
- c) Process orders, requests or any type of petition that is made by the partner agent through any of the contact forms that are made available to them.
- d) Inform about changes in privacy policies.
- e) Support internal or external audit processes and accounting processes.
- f) Carry out accounting, fiscal, administrative, due diligence, billing, and other procedures related to the commercial relationship.
- g) Verify and update Personal Data.
5. With whom do we share your personal data?
Your Personal Data may be stored and processed in any country where we have facilities or service providers. By using our Services or providing us your consent (where required by law), your Personal Data may be transferred to countries outside of your country of residence and even to the United States, in these cases, we will implement measures to protect Personal Data. We will ensure an adequate level of protection to the Personal Data by using one or more of the following approaches:
- 5.1. We may transmit Personal Data to countries with data protection regulations that have been recognized by the country from which the Personal Data is transmitted, with adequate levels of protection for Personal information.
- 5.2. We may celebrate written agreements, such as standard contractual clauses and other Personal Data transmission agreements, with recipients who are required to have an adequate level of protection.
- 5.3. We may request your consent to transmit your Personal Data for specific purposes.
- 5.4. We may confirm on other transmission mechanisms approved by the authorities of the country from which the Personal Data is transmitted.
6. How do we share personal data about you?
In patHUBlatam, we only share Personal Data in the ways we tell you. We do not sell, rent, or share Personal Data to third parties, except as described in this Policy.
- 6.1. Service Providers. We share Personal Data with service providers that help us with our business activities. Services providers support us in processing the types of Personal Data described above in the section “What data do we collect?” and for the purposes described in the section “How do we process your Personal Data?”. They are only authorized to process Personal Data as necessary and as directed by us.
- 6.2. Required by law. If we are required to deliver Personal Data in compliance with a legal obligation or as part of legal process, we will take commercially reasonable steps to notify you of this deliver. We may also be required to release Personal Data in response to lawful requests from government authorities, including requests from national security agencies or law enforcement agencies.
- 6.3. Intellectual Property Offices. We share Personal Data with Intellectual Property offices before which the patent application is processed. This information is shared only for the purposes described in the section “How do we process your Personal Data?” and the information processed corresponds to that described above in the section “What data do we collect?”.
7. How do we process special categories of data?
- 7.1. Sensitive information. We do not collect Personal Data that is considered sensitive (for example, genetic data, biometric data, data that reveals racial or ethnic origin, political opinions, sex life, sexual orientation, religion or other beliefs, health-related data, criminal history, or union affiliation).
- 7.2. Personal data of minors. Our Services are not directed to individuals under the age of 17 and we request that these individuals do not provide Personal Data throughout our Services. If your child has submitted Personal Data and you want to delete it, please contact us as explained in Section 9.
- What are your rights?
- 8.1. You can request to access, update, or correct and, in certain circumstances, delete your Personal Data. Therefore, you can:
- a) Request access to the Personal Data we process about you.
- b) Request that we correct inaccurate or incomplete Personal Data about you.
- c) Request the deletion of your Personal Data.
- d) Request restrictions, temporarily or permanently, on our processing of some or all Personal Data about you.
- 8.2. It is possible that you have additional rights under local law applicable to the processing of your Personal Data.
9. How to exercise your rights?
- 9.1. You can exercise your rights by contacting us through the following email:(xxxxxx@xxx.com). In the case that you consider that the processing of your Personal Data does not comply with the regulation, you can file a complaint at the following email:( xxxxxx@xxx.com).
- 9.2. You do not have to pay extra fees, and we will respond to your request within 15 days of receipt, or in the term stablish by applicable law. We will respect the requests you make
- in relation to your rights according to the law, which means that in some cases there may be reasons that will be impossible to grant your reques
10. How to submit requests and complaints?
- It will be at the head of the ______ area to receive and to resolve requests and complaints submitted by data subjects.
- The requests and complaints should contain as minimum the following information:
- a. Complete identification of the data subject or its representative.
- b. Description of the situation
- c. Data subject contact information
- Requests and complaints can be sent to the following e-mail address: (***)
11. How do we automatically collect data?
- 11.1. Cookies. When you visit our website, we may collect your information automatically through cookies or similar technologies. Cookies are text files that are placed on your computer to collect standard Internet log information and behavioral information about visitors to the website. By using our website, you consent to the use of cookies. The functionalities for which we use these technologies may include the following:
- a) Facilitate navigation.
- b) Facilitate registration in our electronic forms and log in to your user account.
- c) Analyze the use of our Services.
- d) Analyze the geolocation of data subjects
- d) Help with our marketing and promotional efforts (including behavioral advertising).
- 11.2. Other means of automatic collection of Personal Data. We may also gather and process information automatically in the following ways:
- a) Through your browser. Most browsers collect certain information, such as your Media Access Control (MAC) address, type of computer (Windows or Mac), screen resolution, operating system name and version, and Internet browser type and version. We use this information to make sure our website work properly.
- b) IP address. Your IP address is a number that your internet service provider automatically assigns to your devices. An IP address is automatically identified and recorded in our server log files each time a user visits our website, along with the time of visit and the pages viewed. IP address gathering is a standard practice and is done automatically by many online Services. We use IP addresses for purposes such as administering our website.
12. How to manage your cookies?
You can choose to reject cookies at any time; however, if you do it, please be aware that some features are only available using cookies, and therefore if you choose not to accept them, these features will not be available.
13. Privacy policies of other websites
Our website may include links to other websites, however, the Privacy Policy of patHUBlatam apply only to our website. If you click on a link to another website, provide or submit Personal Data to those websites or online Services, the privacy policies of those websites or online Services will apply to your Personal Data. We suggest you carefully read the privacy policies of any website you visit.
14. How long do we keep your personal data?
We will retain your Personal Data while we are providing our Services to you, while you are working with us, as long as we have a business partnership in place, or while we are addressing a concern, question, complaint or request that you have made of us, as applicable to our interactions with you. If we have a contract or other agreement with you, we will meet the with the data retention obligations of that agreement.
We may retain Personal Data for longer if we have a legal obligation to register it for legal, financial, compliance or other reporting obligations, and to enforce our rights and agreements.
16. Supplemental privacy notices according to local regulations
We can make changes to this Policy based on changes in the applicable laws and regulations or other requirements that apply to us, changes in technology, or changes in our business.
Any changes we make to the Policy in the future will be posted on this page, and when we change this Policy in a way that also affects how we process your personal information, we will notify you directly by email or other direct contact with you, and we will also post a notice on our home page that this Policy has changed.
Supplemental privacy notice for Colombia
This Supplemental Privacy Notice is an addition to the information contained in the Global Privacy Policy of patHUBlatam (above) and applies only to Colombian residents (“You”).
As a result, with the acceptance of the authorization for processing your Personal Data, you express that you are aware about the Global Privacy Policy of patHUBlatam and the Supplemental Privacy Notice of patHUBlatam for Colombia, and in those terms, you give your authorization for the treatment of your Personal Data in the terms established in these documents.
1. Rights of the data subjects under Colombian regulations
If your personal data must be processed under the rules of the General Colombian Data Protection Regime (“RGPD” for its acronym in Spanish), in addition to the rights established in the Global Privacy Policy of patHUBlatam, you will have the following rights:
- a) Request a copy of the authorization granted to the data controller for processing your Personal Data, unless it is expressly excluded as a requirement for processing, in accordance with the RGPD.
- b) Be informed about the processing of Personal Data.
- c) Submit to the local authority their request and complaints for infractions of the provisions of the RGPD and the additional regulations that modify, add, or complement it.
- d) Revoke the informed consent and/or request the deletion of the data at any time at your will.
2. Consent
We will request your authorization for the processing of your Personal Data through the registration form designed for this purpose available on the website (***). We will not require consent to process public personal information, neither in the cases where the data processing is one of the exceptions established in article 10 of Law 1581/12.
3. Area in charge of handling requests, queries, and claims
It will be at the head of the area (***) to receive requests, queries and claims connected to the processing of Personal Data, in the exercise of the rights referred to in this Privacy Policy and in Law 1581/12.
4. Procedure for the exercise of the rights of the interested parties
We will receive and resolve inquiries from interested parties about:
• What are the Personal Data of the interested party that are kept in our databases?
• What is the scope of the processing of Personal Data?
• What are the purposes of processing Personal Data?
Such inquiries should be sent to the following email address:(***). We will keep proof of the query and your response. The query will be answered within a maximum period of ten (10) business days from the date of receipt. When it is not possible to attend the queries within said period, th
it will be attended, which in no case may exceed the following ten (10) business days. the expiration of the first term.
b) Complaints. We will receive and resolve complaints made by data subjects or data subjects in relation to:
• Personal Data that must be corrected, updated, or deleted.
• Failure to comply with any of the obligations derived from local regulations.
Said claims must be sent to the following email:(***). We will retain proof of the claim and your response.