Personal information processing policy

This document represents the Information Processing Policy of Colegio Gimnasio Vermont S.A., hereinafter “Gimnasio Vermont”, which is required by article of the Sole Regulatory Decree of the Commerce, Industry and Tourism Sector.

Hence, the content of this document, which Gimnasio Vermont makes available to the community in general, corresponds to the obligations required by the Colombian State in terms of personal data protection, especially those contained in Law 1581 of 2012 and its regulatory decrees.

Why does Gimnasio Vermont have a Personal Information Processing Policy?

The Political Constitution of Colombia, in its article 15, protects the fundamental rights that all people have to privacy, good name and habeas data

The other rules that regulate data protection in Colombia are derived from this constitutional provision, whose main regulatory instrument is Statutory Law 1581 of 2012.

Law 1581 of 2012 establishes the minimum conditions to carry out the legitimate processing of the personal data of any natural person who shares their information, whether with natural persons or legal entities, so that they carry out a proper treatment of personal data in the exercise of their economic activities, as is the case of educational activity.

The aforementioned standard is accompanied by regulatory decrees (1377 of 2013 and 886 of 2014, compiled in the Single Regulatory Decree of the Commerce, Industry and Tourism Sector -1074 of 2015-), which make up the legal system and impose various obligations on legal entities that, like us, process personal data and that by virtue of this acquire the role of data controllers.

Both the Gimnasio Vermont, in its capacity as Controller, and those in charge of data processing -understood as suppliers and third parties that provide services to the educational institution- will comply with the aforementioned standards so that the privacy of individuals is respected, always ensuring the greater interest of the boy, girl and/or adolescent.

Who are we?

Gimnasio Vermont is an institution of educational services, whose corporate purpose is to provide preschool, basic and secondary education, within a concept of comprehensive education, aimed at achieving high academic level objectives, within the guidelines determined by the Colombian educational authorities.

Our contact information is made available to the holder of personal data:

▪ Name or business name: Colegio Gimnasio Vermont S.A. ▪ Nit: 860.058.553-1 ▪ Telephone: (1) 518 57 57 ▪ Address: Calle 195 #54-75 (Bogotá D.C.) ▪ Website:

Important definitions

For the purposes of interpreting and applying this policy, the following concepts must be taken into account:

a) Authorization: Prior, unequivocal and informed consent of the owner of the data to carry out the processing of their personal information. b) Authorized: Person authorized by the owner of personal data in order for them to carry out on behalf of the owner any type of procedure or request before Gimnasio Vermont. c) Database: Any organized set of personal data, which allows access to the data in accordance with certain criteria, whatever the form or modality of its creation, storage, organization and access. d) Student: Natural person enrolled at Gimnasio Vermont after fulfilling the required academic-administrative requirements and processes. e) Consultation: The Owners or their successors in title may consult the personal information of the Owner that rests in any database, whether it is from the public or private sector. The Treatment Manager must provide them with all the information contained in the individual record or that is linked to the identification of the Owner. f) Personal data: Any information linked to or that may be associated with one or more determined or determinable natural persons. g) Private data: Their main characteristic is that they belong to and are of interest solely and exclusively to the person on whom the information falls. h) Public data: These are data that are not semi-private, private or sensitive. Public data is considered, among others, data related to the marital status of people, their profession or trade and their quality as a merchant or public servant. Due to its nature, public data may be contained, among others, in public records, public documents, gazettes, official bulletins and duly enforced judicial decisions that are not subject to reservation. i) Semi-private data: These data, even when they are private, are only of interest to the owner and a certain group of people, who can consult the information through authorization. The typical example of this kind of data is the credit histories managed by credit bureaus. j) Sensitive data: Sensitive data is understood to be those 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, belonging to trade unions, social or human rights organizations or that promote the interests of any political party or that guarantee the rights and guarantees of opposition political parties, as well as data related to health, sexual life and biometric data. k) Person in charge of the processing: Natural or legal person, public or private, that by itself or in association with others, carries out the Processing of personal data on behalf of the Person in charge of the Processing. l) Supplier: A supplier is that natural or legal person that provides its services or supplies a product to Gimnasio Vermont. m) Claim: The Owner or his successors in title who consider that the information contained in a database should be subject to correction, updating or deletion, or when they notice the alleged breach of any of the duties contained in Law 1581 of 2012, may file a claim with the Processing Manager. n) Person Responsible for queries and claims: Person(s) who have been designated internally by Gimnasio Vermont to formally exercise the function of coordinating and managing the queries and claims for personal data that the owners formulate. o) Person Responsible for the processing of information: Natural or legal person, public or private, that by itself or in association with others, decides on the database and/or the Processing of the data. For the purposes of this Policy, the Data Controller is Gimnasio Vermont. p) Owner of the data: Natural person whose personal data is subject to Processing. q) Worker: Any person who, by virtue of an employment contract, is linked to Gimnasio Vermont, whether administrative or teaching and academic staff. r) Transfer: The transfer of data takes place when the Person Responsible and/or Person in Charge of the Processing of personal data, located in Colombia, sends the information or personal data to a receiver, who in turn is Responsible for the processing and is within or out of the country. s) ) Transmission: Treatment of personal data that implies the communication of the same inside or outside the territory of the Republic of Colombia when its purpose is to carry out a Processing by the Manager on behalf of the Responsible person. t) Data processing: Any operation or set of operations on personal data, such as collection, storage, use, circulation or deletion. u) Visitors: Those natural persons who enter the physical facilities of Gimnasio Vermont.