Privacy Notice
Data Controller:
Mentum Group
In accordance with Article 15 of the Political Constitution of Colombia, all individuals have the right to know, update, and rectify the information held about them in data repositories. This document explains how Mentum Group has established procedures and policies aimed at ensuring trust, security, and quality in the use of information belonging to our clients, candidates, employees, and prospects.
The processing of personal data includes its receipt, collection, recording, storage, preservation, modification, transfer, consultation, and deletion. Therefore, personal data may be used for the following purposes:
a. To execute existing contractual relationships with clients, suppliers, and employees, including the payment of contractual obligations.
b. To provide the services and/or products requested by users.
c. To inform users about new products or services and/or changes to existing ones.
d. To evaluate service quality.
e. To conduct internal studies regarding consumer habits.
f. To send commercial, advertising, or promotional information regarding products and/or services, events, and/or promotions—whether commercial or otherwise—through physical mail, email, mobile phone, text messages (SMS and/or MMS), or any other current or future analog and/or digital communication channel, with the purpose of promoting, inviting, directing, executing, informing, and generally carrying out commercial or advertising campaigns, promotions, or contests conducted by Mentum Group and/or third parties.
g. To carry out recruitment, evaluation, hiring, and termination processes.
h. To support internal or external audit processes.
i. To record information regarding employees and/or retirees (active and inactive) in Mentum Group’s databases.
j. To carry out the purposes indicated in the authorization granted by the data subject or described in the applicable privacy notice, as the case may be.
k. To provide, share, send, or deliver personal data to subsidiaries, affiliates, or related companies of Mentum Group located in Colombia or any other country when such companies require the information for the purposes described herein.
l. To obtain authorization for the processing of personal data by Mentum Group’s subsidiaries, affiliates, or related companies when business operations require such processing.
With respect to data (i) collected directly through physical or logical security control points, (ii) obtained from documents provided by individuals to security personnel, and (iii) gathered through video recordings conducted inside or outside Mentum Group facilities, such information will be used for the security of individuals, assets, and facilities of Mentum Group and may be used as evidence in any corporate, disciplinary, and/or judicial investigation process (when required by Colombian authorities).
If personal data is provided, such information will only be used, sold, licensed, transmitted, or disclosed when:
(i) express authorization has been granted;
(ii) it is necessary to enable contractors to provide the entrusted services;
(iii) it is necessary to provide our services and/or products;
(iv) it is necessary to disclose it to entities providing marketing services on behalf of Mentum Group or to entities with which joint marketing agreements exist;
(v) the information is related to a merger, consolidation, acquisition, divestiture, or other corporate restructuring process; or
(vi) disclosure is required or permitted by law.
Mentum Group may subcontract third parties to process certain functions or information. Whenever personal information processing is outsourced or personal information is provided to third-party service providers, Mentum Group will inform such third parties of the need to protect personal information through appropriate security measures, prohibit the use of such information for their own purposes, and require that personal information not be disclosed to others.
Rights of Personal Data Subjects
Personal data subjects, either directly or through a representative, attorney-in-fact, or successor, may exercise the following rights regarding personal data processed by Mentum Group:
Right of Access: To access personal data under the control of Mentum Group free of charge at least once per calendar month and whenever substantial changes to information processing policies justify a new consultation.
Right to Update, Rectify, and Delete: To request the updating, correction, and/or deletion of personal data being processed, provided that the purposes of the processing can still be fulfilled.
Right to Request Proof of Authorization: Except in cases where authorization is not required under applicable legal regulations.
Right to Be Informed: Regarding the use of personal data.
Right to File Complaints Before the Superintendence of Industry and Commerce: For violations of current regulations governing personal data processing.
Right to Demand Compliance: With orders issued by the Superintendence of Industry and Commerce.
Exercising Your Rights
To exercise the rights to know, update, rectify, and/or delete personal data (provided there is no contractual relationship in the case of deletion), you may use the following channels:
Email: datospersonales@mentum.group
Request the Personal Data Processing Policy through the email address provided above.
Any changes to this notice will be communicated through the email address provided above.
If sensitive personal data is collected, the data subject may refuse authorization for its processing, provided that no contractual relationship exists or is expected to exist.
Mentum Group will be responsible for handling requests, complaints, and claims submitted by data subjects in the exercise of the rights established under the section “Obligations When Processing Through a Data Processor” of the Personal Data Processing Policy, except for the obligation described in subsection (e).
For these purposes, the data subject or their representative may submit requests, complaints, or claims Monday through Friday from 8:00 a.m. to 4:30 p.m. via email at datospersonales@mentum.group, by calling the Bogotá landline number +57 (1) 601-508-8877, or by submitting them in writing to the following address:
Cl. 98 Bis #71D-20, Bogotá, Colombia.