PERSONAL DATA PROCESSING POLICY (HABEAS DATA)

• Legal Name: Iglesia Camino
• Main Address: Calle 18 # 20-91, Barrio Jardín, Santa Marta, Magdalena, Colombia
• Contact Phone: +57 305 317 3460
• Official Email: contabilidad.iglesiacamino@gmail.com
• Website: https://www.iglesiacamino.co/

The purpose of this policy is to guarantee the constitutional right that all persons have to know, update, rectify and delete the information collected about them in the databases of Iglesia Camino, in strict compliance with Law 1581 of 2012, Decree 1377 of 2013 and the jurisprudence of the Constitutional Court of Colombia.

In the processing of the personal data of the community, Iglesia Camino will rigorously apply the following principles:

• Principle of Legality: Data processing is a regulated activity subject to what is established in Colombian law.
• Principle of Purpose: The data collected will obey a legitimate purpose in accordance with the constitution and the law, which is expressly informed to the owner.
• Principle of Freedom: Processing will only be carried out with the prior, express and informed consent of the owner.
• Principle of Truthfulness or Quality: The information subject to processing must be truthful, complete, exact, updated, verifiable and understandable.
• Principle of Transparency: The owner’s right to obtain information about the existence of their data at any time and without restrictions is guaranteed.
• Principle of Restricted Access and Circulation: Personal data will not be available on the internet or other mass dissemination media, unless access is technically controllable to offer restricted knowledge to owners or authorized third parties.
• Principle of Security: The information will be handled with the technical measures necessary to provide security to the records, avoiding their adulteration, loss or unauthorized consultation.
• Principle of Confidentiality: All persons who intervene in the processing of personal data are obliged to guarantee the confidentiality of the information.

In accordance with Article 6 of Law 1581 of 2012, sensitive data are those that affect the owner’s privacy or whose improper use may generate discrimination, such as data that reveal religious or philosophical affiliation or conviction.

Rules for the processing of sensitive data at Iglesia Camino:

• Optional Nature: The provision of sensitive data by the owner is entirely voluntary. No person is obliged to provide sensitive information to attend our services or be part of the community.
• Express Authorization: For the processing of sensitive data, the Church will request the prior, explicit and informed authorization of the owner.
• Exclusive Use: The sensitive data collected (such as counseling requests, testimonies, prayer motives or membership) will be used exclusively for the purposes of the exercise of freedom of worship, spiritual care and pastoral administration of Iglesia Camino.
• Prohibition of Commercialization: The sale, transfer or commercialization under any title of the databases containing sensitive information of our attendees, members or donors is expressly prohibited.

The personal data collected by Iglesia Camino will be processed for the following purposes:

• Pastoral Care and Attention: Follow-up and accompaniment of members, attendees and families in their processes of faith, counseling and formation.
• Membership Administration: Registration of official members, participation in assemblies, formation courses and service in volunteering.
• Institutional Communications: Sending newsletters, calls, schedule changes, information on special events and ministerial activities via WhatsApp, email or calls.
• Management of Donations and Financial Aspects: Compliance with legal, fiscal and accounting obligations related to tithes, offerings and donations, as well as the issuance of donation certifications required by donors.
• Security and Video Surveillance: Guarantee the physical security of people, goods and facilities of the venue located at Calle 18 # 20-91, Barrio Jardín, Santa Marta, through closed-circuit television (CCTV) cameras if applicable.

As the owner of personal data, you have the right to:

• Know, update and rectify your personal data before Iglesia Camino. This right may be exercised, among others, over partial, inexact, incomplete, fractioned or misleading data.
• Request proof of the authorization granted to the Church for the processing of your data.
• Be informed by the Church, upon request, regarding the use it has made of your personal data.
• File complaints with the Superintendence of Industry and Commerce (SIC) for infractions of the provisions of Law 1581 of 2012 and the other regulations that modify or complement it.
• Revoke the authorization and/or request the deletion of the data when the processing does not respect the constitutional and legal principles, rights and guarantees.
• Access your personal data that has been subject to processing free of charge.

Owners or their successors may exercise their rights to know, update, rectify, delete data and revoke authorization by sending a formal request through the following channels:

• Email: contabilidad.iglesiacamino@gmail.com
• In-person Attention or Physical Mail: Calle 18 # 20-91, Barrio Jardín, Santa Marta, Magdalena, Colombia.
• Phone: +57 305 317 3460

Requirements of the Request:

• Full name and surnames of the owner.
• Identity document number.
• Contact details (physical or electronic address and contact phone).
• Clear and precise description of the data over which they seek to exercise any of the rights or the facts giving rise to the claim.
• Documents they wish to assert (if applicable).

Response Times:

• Inquiries: Inquiries will be answered within a maximum term of ten (10) business days from the date of receipt. When it is not possible to answer the inquiry within said term, the interested party will be informed of the reasons for the delay and the date on which their inquiry will be addressed, which in no case may exceed five (5) business days following the expiration of the first term.
• Claims: When the owner considers that the information contained in a database must be corrected, updated or deleted, or when they notice the alleged breach of any of the duties, they may file a claim which will be addressed within a maximum term of fifteen (15) business days from the day following the date of its receipt.

The databases under the control of Iglesia Camino will be kept for the reasonable and necessary time to fulfill the processing purposes informed in this policy, or while the pastoral, community, civil or legal relationship between the owner and the Church persists.

This Personal Data Processing Policy is in force from its publication on the church’s website.