Personal data processing and
protection policy
Soluciones Estratégicas en Información S.A.S., hereinafter SEI, identified with NIT 800.160.251-1, with its main address in Bogotá, acting in its capacity as the controller and/or processor of personal data, informs data subjects that the processing of personal information contained in its databases is carried out in strict compliance with the principles and provisions of Law 1581 of 2012, Decree 1377 of 2013, and other regulations that modify or complement them.
SEI recognizes the importance of privacy and the protection of the data of its customers, employees, suppliers, contractors, and participants in the quantitative and qualitative studies it conducts.
- Data controller: SEI acts as the data controller for the personal data of its employees, customers, and suppliers, as it is the entity that decides on the purpose and processing of such information. In this capacity, SEI is the entity before which data subjects must exercise their rights.
- Processor: SEI acts as the processor of the personal data of participants in its studies. In this role, SEI processes the information under a consulting contract, following the instructions and purposes defined by the contracting client, who assumes the role of controller. However, SEI undertakes to comply with all the duties of the processor established by law.
For the purposes of applying this policy, the definitions established in current Colombian legislation are adopted. Additionally, the following concepts are specified in the context of SEI’s operations:
- Collection operation: Planned process of gathering information for a specific study.
- Participants: Individuals who voluntarily take part in an SEI research project, contributing information, experiences, or opinions in the context of surveys, interviews, workshops, focus groups, or other exercises.
- Data collection instrument: Any tool or resource used to obtain data from people participating in studies; through these instruments, researchers approach the phenomena under study to extract relevant information.
- Statistical purposes: Refers to the purpose of collecting, organizing, and analyzing data from a population or sample to draw conclusions and make predictions, without identifying individuals.
- Anonymization: An irreversible process of dissociating data that makes it impossible to identify the data subject, allowing the information to be used for statistical purposes without violating privacy rights.
- Sensitive data: Data that affects the privacy of the data subject or whose misuse may lead to discrimination. This includes, among other things, data on racial or ethnic origin, political opinions, religious beliefs, trade union membership, biometric data, and data on health or sex life.
SEI requests or collects the personal data necessary for the development of its corporate purpose. This data may include, among others:
- Identification and contact data: Full name, type and number of identification, residential address, city, telephone number, cell phone number, email address.
- Sociodemographic data: Date of birth, age, gender, profession, place of work, and job title.
- Technical data: Information collected from the computer and browser, such as IP address, software and hardware attributes.
- Study data: For information collection operations, in addition to basic data, information may be collected that allows for a more complete and relevant characterization for the specific study. This may include perceptions, opinions, and, if necessary, sensitive data, provided that the explicit and separate authorization of the owner is obtained.
SEI assumes the accuracy of the information provided and does not assume the obligation to verify the authenticity of the data provided. Accordingly, SEI shall not be liable for any damages or losses resulting from the inaccuracy, invalidity, or lack of authenticity of the information provided.
The information provided by the owners will be collected, stored, used, processed, and circulated for the following purposes:
For customers, suppliers, and employees:
- To maintain fluid communication for contracting, service management, and projects.
- To process quotes, service orders, or purchase orders.
- Process the payment of invoices and equivalent documents.
- Distribute SEI information, announcements, and documents.
- Comply with legal and labor obligations (social security affiliations, payments, etc.).
- Consult and update personal data at any time.
For participants in quantitative and qualitative studies:
- Process information for statistical, research, and analysis purposes, in accordance with the purpose of the contracted consultancy.
- Deliver the information to the client who commissioned the study, in accordance with the contract, ensuring compliance with security and confidentiality standards. In this case, SEI shall act as the data processor.
- Re-contact participants to verify the information provided, arrange new visits, or invite them to participate in new studies, always with their prior authorization.
For the use of the SíSEI platform (electronic signature):
- To give legal validity and formalize legal acts and contracts entered through the platform.
- Process the user’s personal data (name, ID, email, etc.) and the metadata generated (IP address, date, time) to create and store the electronic signature record, which constitutes proof of the user’s intent and the integrity of the signed document.
- To retain the data for the time legally required for the validity of the contracts and for the purposes of future legal claims.
SEI undertakes not to use personal data for marketing or promoting products or services unrelated to its corporate purpose and not to sell the databases.
The provision of personal data by data subjects, whether through forms, surveys, self-administered instruments, or any other data collection tool, constitutes the data subject’s explicit, informed, and unequivocal authorization for SEI to process their personal information in accordance with the purposes described in this policy. In fact, SEI’s data collection protocols establish that, prior to administering any survey or other collection instrument, the interviewer must present the study, clarify any questions about it, and give the person the option to decide whether or not to participate in the study and provide their opinions and information.
Authorization for sensitive data: Authorization for the processing of sensitive data is optional and must be granted explicitly and separately from general consent. The data subject is not obliged to answer questions about sensitive data.
SEI will not transfer or disclose the information outside its databases, unless:
- The information is required by competent authorities.
- The data subject expressly authorizes it.
- It is necessary to enable its contractors or suppliers to provide the services entrusted by SEI.
- The transfer is necessary for the performance of a contract between the data subject and SEI.
- In the event of a corporate reorganization, the data is transferred to other companies, informing the owners.
The processing of personal data of minors will be carried out with a rigorous approach, ensuring the protection of their fundamental rights and responding to their best interests. Such processing will be possible provided that the following criteria are met:
- Prior, express, and written authorization is obtained from the minor’s legal representative.
- The minor is informed, in accordance with their level of maturity, about the purpose of the processing and their rights.
- The purpose of the processing is in the best interests of the minor, and their fundamental rights are respected.
SEI implements human, administrative, and technological protection measures to ensure the security of personal data and prevent unauthorized access, tampering, loss, or consultation. These measures include:
- Contractual privacy and confidentiality obligations for employees, contractors, and suppliers.
Ongoing training of staff on security policies and protocols. - Procedures for anonymizing the information of study participants when data is provided to the client for statistical purposes. In this same vein, SEI promotes the alignment of its clients with personal data protection and, to this end, requests that they include in consulting contracts, clauses in this regard, containing their commitment to anonymize the personal data included in the databases provided by SEI, when these are processed for statistical purposes.
However, the owner acknowledges that there is no absolute security method and accepts that the measures implemented by SEI are reasonable and sufficient for the purposes of this policy.
Data subjects have the following rights under Colombian law:
- To know, update, and rectify their personal data.
- To request proof of the authorization granted to SEI for processing.
- To be informed by SEI, upon request, regarding the use that has been made of their data.
- To file complaints with the Superintendency of Industry and Commerce (SIC) for violations of the law.
- Revoke authorization and/or request the deletion of data, unless there is a legal or contractual obligation to retain it.
- Access your personal data that has been processed free of charge.
SEI has established the following channels for receiving and handling inquiries, complaints, or for the exercise of the rights of data subjects:
- Email: proteccion-datos@sei-consultores.com.co
- PQRS: https://sisei.app/ords/r/sisei/sisei_verf/generar-pqrsf
The procedure and deadlines for handling inquiries and complaints shall be governed by the provisions of Law 1581 of 2012. Inquiries shall be resolved within a maximum of ten (10) business days, and complaints within a maximum of fifteen (15) business days.
If the request is incomplete, the owner will be required to correct the deficiencies within five (5) days of receipt. If two (2) months have elapsed since the date of the request without the required information being provided, the claim will be deemed to have been withdrawn.
This policy is governed by Colombian legislation on the protection of personal data, including Law 1581 of 2012 and Decree 1377 of 2013.
SEI, in its capacity as the entity responsible for the processing of personal data, shall proceed to register with the National Database Registry (RNBD) before the Superintendency of Industry and Commerce (SIC) in the manner and within the time frame established by law.
This policy is effective as of the date of its publication. SEI reserves the right to modify it at any time and unilaterally. Any substantial change will be duly published and notified to the owners. Continued use of the services or failure to disassociate by the owner, once the new policy has been notified, will constitute acceptance of the same.
Date of publication: August 21, 2025.
Version history:
- August 21, 2025 version: Current publication.
- May 1, 2017 version: Previous modification.
- Version dated July 26, 2013: Original version.
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