Privacy Policy

Circular Factoring S.A.S., in compliance with Law 1581 of 2012 and other related regulations, is responsible for the processing of your personal data.

The personal data that Circular Factoring S.A.S. requests will be used for the following purposes

Provision of the services offered by Circular Factoring S.A.S. Performance of the contracts executed with Circular Factoring S.A.S. Customer service and marketing. Sending information related to news, promotions, and topics of interest for Circular Factoring S.A.S. clients. Sending information related to the contractual relationship. Keeping statistical records of Circular Factoring S.A.S. clients. Keeping records of suppliers and contractors. Keeping records of the employees of contractors who provide services in the companies of Circular Factoring S.A.S. clients and/or suppliers. Contractual and service statistics (services offered or provided). Communication, consolidation, organization, updating, control, accreditation, assurance, statistics, reporting, maintenance, interaction, and management of the actions, information, and activities in which suppliers, contractors, and their employees are related to or linked with Circular Factoring S.A.S. Execution of the corresponding employment contract. Complying with the obligations arising from the commercial relationship, such as carrying out all necessary procedures before the authorities, such as filing procedures with the National Tax and Customs Directorate—DIAN, or any other activity derived from applicable legislation. To notify family members, the 123 service line, and any priority care service in case of emergencies during their stay at Circular Factoring S.A.S. facilities. General communication, record-keeping, training, authorizations, and management of activities or actions in which employees and their families are related to Circular Factoring S.A.S. Communication, record-keeping, archiving, organization, processing, and management of the actions, strategies, and activities in which Circular Factoring S.A.S. shareholders are linked. Accessing, consulting, comparing, and evaluating all information about Data Subjects that is stored in the databases of any credit risk bureau, financial bureau, databases of judicial background or security background legally constituted, whether public or private, national or foreign. Investigating, verifying, and validating the information provided by Data Subjects, with any information that Circular Factoring S.A.S. lawfully has available. Human Talent management linked to Circular Factoring S.A.S. Data processing will be carried out for hiring/onboarding, performance of functions or provision of services, withdrawal or termination, depending on the type of legal relationship established with Circular Factoring S.A.S. (includes, among others, officials, former officials, interns, and applicants for positions). Maintaining physical or electronic communication with its clients, suppliers, shareholders, contractors, employees, and former employees, among others, including sending information related to the contract executed between the parties. As well as sending information about other services, products, or goods acquired from Circular Factoring S.A.S. As an element of analysis in pre-contractual, contractual, and post-contractual stages to establish and/or maintain any contractual relationship, including, as part of it, the following purposes: i. Update databases and process the opening and/or onboarding of products and/or services ii. Assess risks arising from the potential, current, or concluded contractual relationship, iii. Perform, validate, authorize, or verify transactions, including, when required for such purpose, the consultation and reproduction by Circular Factoring S.A.S. of sensitive data such as fingerprint, image, or voice, all in accordance with what is established in this document and in the respective authorization. iv. Obtain knowledge of the Data Subject’s commercial or transactional profile, allowing the definition of products that fit their needs, tastes, and preferences, for the creation, modification (refinancing, novation), execution and/or termination of direct, contingent, or indirect obligations, the breach of obligations acquired with Circular Factoring S.A.S. or with any third party, as well as updates related to such obligations, payment habits, and credit behavior with Circular Factoring S.A.S. and/or third parties. v. Know the status of current active or passive operations, or of any nature, that in the future may be carried out with Circular Factoring S.A.S., with other financial or commercial entities, with information operators or database administrators, or any similar entity that may be established in the future and whose purpose is any of the above activities. vi. Know information about the Data Subject regarding the management of checking accounts, savings, deposits, credit cards, commercial behavior, employment information, and other products or services and, in general, compliance with and management of credits and obligations, whatever their nature. This authorization includes information regarding the management, status, compliance of relationships, contracts and services, payment habits, obligations, and outstanding debts, overdue debts not paid, processes, or the improper use of financial services vii. Exercise the rights of Circular Factoring S.A.S., including those related to judicial and extrajudicial collection activities and related actions to obtain payment of obligations owed by the Data Subject or their employer, if applicable, and the reinstatement of payroll deduction (libranza) when applicable due to a change of employer viii. Implementation of software and technological services, ix. Process and ensure compliance with and delivery of the products and/or services acquired by the Data Subject, x. Comply with commercial obligations within the framework of contractual relationships. Carry out assignment and/or endorsement and/or sale operations of products and/or services offered by Circular Factoring S.A.S., among which their receivables portfolio is included. Verify the personal and/or commercial references provided, regarding the management of the accounts and/or products registered in the Data Subject’s name, as well as any other type of information on the transparency and lawfulness of the activities carried out. Record and listen, only when Circular Factoring S.A.S. requires it, to the conversations of the Data Subject with Circular Factoring S.A.S. related to business matters, so that Circular Factoring S.A.S. has support and valid evidentiary means in any judicial proceeding, as well as support for the operations performed. Subcontract third parties to process the information of its clients, suppliers, contractors, employees, and former employees, among others, and/or to perform any other activity required by Circular Factoring S.A.S. in connection with the contract executed between the parties. Conduct, with information operators (Experian, Transunion, credit bureaus and/or any other entity that may manage databases with the same objectives), the consultation of credit information, as well as the reporting of the creation, modification, termination, fulfillment or breach of obligations incurred in favor of Circular Factoring S.A.S., and the improper use of the products and/or services provided or offered by the entity. Carry out, before Social Security information operators (Technological Providers of Electronic Invoicing and Payroll and/or any other entity that may manage databases with the same objectives), the consultation, request, supply, reporting, processing, use, and in general the processing of all information contained in my employment history, within which there are current and non-current employment relationships, contribution base income (IBC), contact data, employer information, pension status, date of birth, affiliation date, transfer date, and other information related to my employment situation and employer, related to my income and mandatory and/or voluntary contributions to health, pensions, and severance funds with social security entities, pension funds or severance funds and/or any similar entity with which I am affiliated, that is stored or administered in RAIS (Individual Savings with Solidarity Regime), the one administered by the Colombian Association of Pension Fund Administrators (Asofondos de Colombia), PILA Information Operators, technology partners, Aportes en línea S.A., and other social security information operators authorized by the Ministry of Health and Social Protection and that are part of the Social Security system, and these in turn so that they provide Circular Factoring S.A.S., through the means considered relevant and secure, my personal data related to affiliation and payment of contributions to the Integrated Social Security System, such as contribution base income and other information related to my employment situation and employer, who may access such information as many times as they require, keep it updated and in general process it, directly or through a representative, for the purpose of carrying out credit application and approval processes, credit risk assessment, collection processes carried out directly or through authorized third parties, and to offer and process products and services. Validate information with the different databases of authorities and/or state entities and third parties such as the National Civil Registry and its certified technology partners, information operators and other entities that form part of the Integrated Social Security System, public utility service providers and mobile phone service providers, among others, to carry out the activities pertaining to the principal and related corporate purpose of Circular Factoring S.A.S. and/or to comply with legal obligations. Initiate contacts for commercial and promotional purposes, either about its own services and products, or those of third parties with whom Circular Factoring S.A.S. has commercial relationships or alliances, through mail, phone, mobile phone, email, or any other known or future means, or to complement, optimize, or deepen the portfolio of products and/or services currently offered. Carry out collection management activities; delivery of statements of obligations; prior notice of negative reporting to credit bureaus or financial information systems, which will be carried out no later than 20 days after the notice or notification, in the event of non-payment of the obligation and the consequent termination of the loan agreement, subject to the provisions of Habeas Data legislation, through physical or electronic mail, phone, mobile phone, SMS or WhatsApp message, or any other known or future means, for obligations less than or equal to (15%) of one (1) current legal monthly minimum wage, the negative record will only be reported after at least two communications on different days have been made. And there must be 20 calendar days between the last communication and the report; and to update the information through different activities such as consultation in public databases, internet pages, social networks, and references from third parties, in particular the persons who have served as references for the use of Circular Factoring S.A.S. services. For security at Circular Factoring S.A.S. facilities, processing will be carried out for surveillance and security of people, assets, and the facilities themselves. For security in logical access at Circular Factoring S.A.S., for user management in applications, developments, web platforms, or in general any technological solution used by Circular Factoring S.A.S., personal information will be collected for the creation and administration of profiles, which will be processed in accordance with this policy. Carry out validation and verification of the identity of clients and users, as well as profiling, among others, through artificial intelligence (AI) systems, to determine the degree of risk for granting credits and other products or services that Circular Factoring S.A.S. offers or may offer. Risk profile analysis will be carried out at the time of the request and also, on other occasions and over time, in cases where a client or Circular Factoring S.A.S. has not been able to accept their request previously.

This analysis includes, without limitation, the following

Consultation and reporting to watchlists, lists of politically exposed persons, and information bureaus, for the prevention and mitigation of money laundering, terrorism financing, financial risks, and identity fraud. Consultation, whenever necessary, of information about their credit history, contact information, financial data, and information related to their employment situation, to information operators and credit bureaus. Implementing relationship strategies and/or segmentation with clients, suppliers, and other third parties with whom Circular Factoring S.A.S. has contractual or legal relationships. For other purposes, such as statistical and market analysis; development and improvement of Circular Factoring S.A.S. services and products; commercial and promotional initiatives; updating data; to carry out regulatory controls; to comply with its legal duties, including within these, those related to the prevention of tax evasion, money laundering, and terrorism financing, or other similar purposes issued by competent authorities. Other purposes established in the Terms and Conditions and in this Privacy Policy.

Circular Factoring S.A.S. may hire third parties located in Colombia or abroad to process the information of clients, suppliers, shareholders, contractors, employees, and former employees, among others, and/or to perform any other activity related to using, using, obtaining, compiling, exchanging, updating, collecting, processing, reproducing, or otherwise handling the data or information of clients, suppliers, contractors, employees, and former employees, among others, of Circular Factoring S.A.S. This process may involve the collection, archiving, processing, transfer and/or transmission of such information and personal data with third parties, among contractually linked companies to Circular Factoring S.A.S., such as call and contact center service providers, messaging service providers, collection companies, and legal professionals who collaborate with the entity in the recovery of its receivables portfolio, located within or outside Colombia. In any case, those entities will be equally subject to the same confidentiality obligations in the handling of the information to which Circular Factoring S.A.S. is subject, with the legal limitations imposed by applicable laws on the matter, in the jurisdiction where it is collected, archived, processed, or transmitted.

Likewise, by accepting this Privacy Policy, clients, suppliers, shareholders, contractors, employees, and former employees, among others, acknowledge that Circular Factoring S.A.S. may provide this information to judicial or administrative entities and government entities that exercise control functions over its operation when there is a legal requirement to do so. Likewise, they accept that they may be subject to internal audit processes or external audit processes by companies in charge of this type of control.

In the event that CIRCULAR FACTORING S.A.S. is not able to carry out processing by its own means, it may transfer the collected data so that it is processed by a third party, prior notice to the Data Subjects whose data were collected, who will be in charge of the processing and must ensure suitable conditions of confidentiality and security of the information transferred for processing.

As the Data Subject, you have the right to know, update, and rectify your personal data and, only in cases where applicable, to delete it or revoke the authorization granted for its processing, by sending your request to the following email address circular@circularfactor.com.

If you require more information to learn about our personal data processing policy and any substantial changes made to it and/or to our Privacy Notice, please consult the following link: Data Processing Policy