Privacy

Policy

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PERSONAL DATA PROCESSING POLICY

LEGAL REGULATION AND SCOPE OF APPLICATION:

This personal data processing policy is prepared in accordance with the provisions of the Political Constitution, Law 1581 of 2012, Regulatory Decree 1377 of 2013 and other complementary provisions and will be applied by the company.

1. Regarding the collection, storage, use, circulation, deletion and all those activities that constitute personal data processing.

2. DEFINITIONS: For the purposes of executing this policy and in accordance with legal regulations, the following definitions will apply: a.) Authorization: Prior, express and informed consent of the owner to carry out the processing of personal data; b.) Privacy Notice: Physical, electronic document or in any other format generated by the Responsible Party that is made available to the Owner for the processing of their personal data. In the Privacy Notice, the Holder is informed of the information regarding the existence of the information processing policies that will be applicable, the way to access them and the purpose of the treatment that is intended to be given to personal data; c.) Database: Organized set of personal data that is subject to Treatment; d.) Personal data: Any information linked to or that may be associated with one or more determined or determinable natural persons; e.) Public data: It is the data qualified as such according to the mandates of the law or the Political Constitution and that which is not semi-private, private or sensitive. Data relating to the marital status of individuals, their profession or trade, their status as a merchant or public servant and those that may be obtained without reservation are public, among others. By its nature, public data may be contained, among others, in public records, public documents, official gazettes and bulletins; f.) Private data: It is the data that due to its intimate or reserved nature is only relevant for the owner; g.) Sensitive data: Sensitive data is understood to be those that affect the privacy of the Holder or whose improper use may generate discrimination, such as those that reveal racial or ethnic origin, political orientation, religious or philosophical convictions, 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; h.) Treatment Manager: Natural or legal person, public or private, that by itself or in association with others, performs the Treatment of personal data on behalf of the Treatment Manager; i.) Responsible for the Treatment: Natural or legal person, public or private, that by itself or in association with others, decides on the database and/or the Treatment of the data; j.) Owner: Natural person whose personal data is subject to Treatment; k.) Treatment: Any operation or set of operations on personal data, such as the collection, storage, use, circulation or deletion of the same.

PURPOSE WITH WHICH THE COLLECTION OF PERSONAL DATA AND TREATMENT OF THE SAME IS CARRIED OUT:

THE COMPANY. may make use of personal data to: a.) Execute the existing contractual relationship with its customers, suppliers and workers, including the payment of contractual obligations; b.) Provide the services and/or products required by its users; c.) Inform about new products, promotions or services and/or about changes in them; d.) Evaluate the quality of the service; e.) Carry out internal studies on consumption habits; f.) Send to physical mail, email, cell phone or mobile device, via text messages (SMS and/or MMS) or through any other analog and/or digital means of communication created or to be created, commercial, advertising or promotional information about the products and/or services, events and/or promotions of a commercial or non-commercial nature, in order to promote, invite, direct, execute, inform and in general, carry out campaigns, promotions or contests of a commercial nature or advertising, advanced by THE COMPANY. and/or by third parties; g.) Develop the selection, evaluation, and employment process; h.) Support internal or external audit processes; i.) Register the information of employees and/or pensioners (active and inactive) in the databases of THE COMPANY; j.) Provide, share, send or deliver your personal data to affiliated, linked, or subordinate companies of THE COMPANY located in the country, in the event that said companies require the information for the purposes indicated herein.

Regarding the data: ▪ Collected directly at the security points, ▪ Taken from the documents that people provide to the security personnel and ▪ Obtained from the video recordings that are made inside or outside the facilities of THE COMPANY, these will be used for purposes security of people, assets and facilities of THE COMPANY and may be used as evidence in any type of process. If a personal data is provided, said information will be used only for the purposes indicated here, and therefore, THE COMPANY will not proceed to sell, license, transmit, or disclose it, unless: ▪ There is express authorization to do so; ▪ Is necessary to allow contractors or agents to perform the services entrusted; ▪ It is necessary in order to provide our services and/or products; ▪ It is necessary to disclose it to the entities that provide marketing services on behalf of THE COMPANY or to other entities with which they have joint market agreements; ▪ The information is related to a merger, consolidation, acquisition, divestment, or other restructuring process of the company; ▪ That is required or permitted by law. THE COMPANY may subcontract to third parties for the processing of certain functions or information. When the processing of personal information is effectively subcontracted to third parties or personal information is provided to third party service providers, THE COMPANY warns said third parties about the need to protect said personal information with appropriate security measures, the use of the information for own purposes and it is requested that personal information is not disclosed to others.

PRINCIPLES APPLICABLE TO THE PROCESSING OF PERSONAL DATA:

The processing of personal data in THE COMPANY will be governed by the following principles: a.) Principle of purpose: The processing of personal data collected must obey a legitimate purpose, which must be informed to the Owner; b.) Principle of freedom: Treatment can only be carried out with the prior, express and informed consent of the Holder. Personal data may not be obtained or disclosed without prior authorization, or in the absence of a legal or judicial mandate that relieves consent; c.) Principle of veracity or quality: The information subject to treatment must be truthful, complete, exact, updated, verifiable and understandable. The Treatment of partial, incomplete, divided or misleading data will not be carried out; d.) Principle of transparency: In the treatment, the right of the Holder to obtain from THE COMPANY at any time and without restrictions, information about the existence of data that concerns him must be guaranteed; e.) Principle of restricted access and circulation: Treatment is subject to the limits derived from the nature of personal data, the provisions of this law and the Constitution. Personal data, except public information, and the provisions of the authorization granted by the owner of the data, may not be available on the Internet or other means of disclosure or mass communication, unless access is technically controllable to provide restricted knowledge only to the Holders or authorized third parties; f.) Principle of security: The information subject to treatment by THE COMPANY must be protected through the use of technical, human and administrative measures that are necessary to grant security to the records avoiding their adulteration, loss, consultation, use or unauthorized or fraudulent access; g.) Principle of confidentiality: All persons involved in the processing of personal data are obliged to guarantee the confidentiality of the information, even after the end of their relationship with any of the tasks included in the Treatment. FIRST PARAGRAPH: In the event that sensitive personal data is collected, the Holder may refuse to authorize its Treatment.

3. RIGHTS OF HOLDERS OF PERSONAL DATA PROCESSED BY THE COMPANY: The holders of personal data by themselves or through their representative and/or proxy or successor in title may exercise the following rights, with respect to the personal data that is subject to treatment by THE COMPANY: a.) Right of access: By virtue of which you can access the personal data that is under the control of THE COMPANY for the purpose of consulting them free of charge at least once every calendar month, and whenever there are substantial modifications of the Information Treatment Policies that motivate new queries; b.) Right to update, rectify and delete: By virtue of which you can request the updating, rectification and/or deletion of the personal data subject to treatment, in such a way that the purposes of the treatment are satisfied; c.) Right to request proof of authorization: Except in those events in which, according to current legal regulations, authorization is not required to carry out the treatment; d.) Right to be informed: Regarding the use of personal data; e.) Right to file complaints with the Superintendency of Industry and Commerce: For violations of the provisions of current regulations on the processing of personal data; f.) Right to require compliance: Of each and every one of the orders issued by the Superintendence of Industry and Commerce. FIRST PARAGRAPH: For the purposes of exercising the rights described above, both the holder and the person representing him must prove his identity and, if applicable, the quality by virtue of which he represents the holder. SECOND PARAGRAPH: The rights of minors will be exercised through the persons who are empowered to represent them.

4. DUTIES OF THE COMPANY: All those required to comply with this policy must bear in mind that THE COMPANY is obliged to comply with the duties imposed by law in this regard. Consequently, the following obligations must be met: a.) Duties when acting as responsible party: ▪ Request and keep, under the conditions set forth in this policy, a copy of the respective authorization granted by the owner. ▪ Clearly and sufficiently inform the owner about the purpose of the collection and the rights that assist him by virtue of the authorization granted. ▪ Inform at the request of the holder about the use given to their personal data. ▪ Process queries and claims formulated in the terms indicated in this policy. ▪ Ensure that the principles of accuracy, quality, security and confidentiality in the terms established in the following policy. ▪ Keep the information under the security conditions necessary to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access. ▪ Update the information when necessary. ▪ Rectify personal data when appropriate. b.) Duties when acting as Person in Charge of the processing of personal data. If you process data on behalf of another entity or organization (Data Controller), you must comply with the following duties: ▪ Establish that the Data Controller is authorized to supply the personal data that it will process as Processor ▪ Guarantee the owner, at all times , the full and effective exercise of the right of habeas data. ▪ Keep the information under the security conditions necessary to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access. ▪ Carry out timely updating, rectification or deletion of data. ▪ Update the information reported by the Treatment Managers within five (5) business days from its receipt. ▪ Process queries and claims made by the owners in the terms indicated in this policy. ▪ Record in the database the legend "claim in process" in the manner established in this policy. ▪ Insert in the database the legend “information under judicial discussion” once notified by the competent authority about judicial processes related to the quality of the personal data. ▪ Refrain from circulating information that is being controversial by the owner and whose blocking has been ordered by the Superintendence of Industry and Commerce. ▪ Allow access to information only to persons authorized by the owner or empowered by law for that purpose. ▪ Inform the Superintendence of Industry and Commerce when there are violations of the security codes and there are risks in the administration of the holders' information. ▪ Comply with the instructions and requirements issued by the Superintendency of Industry and Commerce. c.) Duties when processing through a Processor: ▪ Provide the Processor only with personal data whose processing is previously authorized. For the purposes of the national transmission of data, a personal data transmission contract must be signed or contractual clauses agreed upon as established in article 25 of decree 1377 of 2013. ▪ Guarantee that the information provided to the person in charge of the treatment is truthful. , complete, accurate, updated, verifiable and understandable. ▪ Communicate in a timely manner to the Person in Charge of the treatment all the news regarding the data that you have previously provided and adopt the other necessary measures so that the information provided to it is kept up to date. ▪ Inform the Person in Charge of the treatment in a timely manner of the rectifications made to the personal data so that he/she proceeds to make the pertinent adjustments. ▪ Require the Data Processor, at all times, to respect the security and privacy conditions of the owner's information. ▪ Inform the Person in Charge of the treatment when certain information is under discussion by the owner, once the claim has been submitted and the respective procedure has not been completed. d.) Duties with respect to the Superintendence of Industry and Commerce: ▪ Inform it of possible violations of security codes and the existence of risks in the administration of the information of the holders. ▪ Comply with the instructions and requirements issued by the Superintendency of Industry and Commerce.

5. REQUEST FOR AUTHORIZATION TO THE OWNER OF THE PERSONAL DATA: In advance and/or at the time of collecting personal data, THE COMPANY will request the data owner's authorization to collect and process it, indicating the purpose for which the data is requested, using automated technical means for these purposes. , written or oral, that allow proof of the authorization and/or the unequivocal conduct described in article 7 of Decree 1377 of 2013 to be preserved. Said authorization will be requested for as long as is reasonable and necessary to satisfy the needs that gave rise to the the data request and, in any case, with observance of the legal provisions that govern the matter.

6. PRIVACY NOTICE: In the event that THE COMPANY cannot make this information processing policy available to the owner of the personal data, it will publish the privacy notice attached to this document, the text of which will be kept for subsequent consultation by the owner of the data and /or from the Superintendence of Industry and Commerce

7. TEMPORARY LIMITATIONS ON THE PROCESSING OF PERSONAL DATA: THE COMPANY. You may only collect, store, use or circulate personal data for as long as is reasonable and necessary, in accordance with the purposes that justified the treatment, in accordance with the provisions applicable to the matter in question and the administrative, accounting, fiscal, legal and historical information. Once the purpose or purposes of the treatment have been fulfilled and without prejudice to legal regulations that provide otherwise, it will proceed to the deletion of the personal data in its possession. Notwithstanding the foregoing, personal data must be kept when required to comply with a legal or contractual obligation.

RESPONSIBLE AREA AND PROCEDURE FOR THE EXERCISE OF THE RIGHTS OF HOLDERS OF PERSONAL DATA: THE COMPANY. It will be responsible for addressing the requests, complaints and claims made by the owner of the data in exercise of the rights contemplated in numeral 5 of this policy, except for the one described in its literal e). For such purposes, the owner of the personal data or whoever exercises their representation may send their request, complaint or claim from Monday to Friday from 8:00 a.m. to 5:00 p.m. to 5:00 p.m. to the email of THE COMPANY The request, complaint or claim must contain the identification of the Holder, the description of the facts that give rise to the claim, the address, and accompanying the documents that you wish to attach. If the claim is incomplete, the interested party will be required within five (5) days after receipt of the claim to correct the faults. After two (2) months from the date of the request, without the applicant submitting the required information, it will be understood that the claim has been withdrawn. In the event that the person receiving the claim is not competent to resolve it, it will be transferred to the appropriate person within a maximum term of two (2) business days and the interested party will be informed of the situation. Once the complete claim is received, a legend will be included in the database that says "claim in process" and the reason for it, in a term not exceeding two (2) business days. Said legend must be kept until the claim is decided. The maximum term to address the claim will be fifteen (15) business days from the day following the date of receipt. When it is not possible to address the claim within said term, the interested party will be informed of the reasons for the delay and the date on which his claim will be addressed, which in no case may exceed eight (8) business days following the expiration of the first finished.

8. DATA COLLECTED BEFORE THE ISSUANCE OF DECREE 1377 OF 2013: In accordance with the provisions of number 3 of Article 10 of Regulatory Decree 1377 of 2013 THE COMPANY. will proceed to publish a notice at the headquarters of its facilities addressed to the holders of personal data for the purpose of publicizing this information processing policy and the way to exercise their rights as holders of personal data housed in the databases of THE COMPANY.

9. SECURITY MEASURES: n development of the security principle established in Law 1581 of 2012, THE COMPANY will adopt the technical, human and administrative measures that are necessary to provide security to the records, avoiding their adulteration, loss, consultation, use or unauthorized or fraudulent access. The personnel who carry out the processing of personal data will execute the established protocols in order to guarantee the security of the information.

10. EFFECTIVE DATE: This Personal Data Policy was created on AUGUST 20, 2021 and is effective as of AUGUST 23, 2021. Any change that occurs regarding this policy will be reported by prior publication in the facilities of the business.

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