Habeas Data

Data Processing Policy

Personal data processing policy under Law 1581 of 2012.

Ensure proper processing of personal data administered by ICARO under Law 1581 of 2012.

ICARO processes data under legality, purpose, freedom, accuracy, transparency, restricted access, security, confidentiality, and demonstrated accountability.

Processing may include personal, employment, commercial, and corporate data; biometric data with authorization; images; videos; access logs; geolocation; and contractual information.

Processing requires the data subject’s prior, express, and informed authorization, except as provided by law.

Data may be processed by national and international technology providers acting as processors under confidentiality and security agreements.

Data subjects may submit inquiries to privacidad@icaroriskmanagement.com. Requests are handled under Colombian legal timelines.

ICARO implements physical and logical security, encryption, access control, incident management, traceability, backups, and business continuity controls.

This policy applies from publication and remains in force while ICARO processes personal data.