PRIVACY, TREATMENT AND PROTECTION OF PERSONAL DATA POLICY

Policies for the processing of personal data Entry into force:

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Quadi SAS, with address in Bogotá D.C. Colombia, commercial company, identified with tax identification number No. 901013376-9 (hereinafter the "Agency") is respectful of the personal data and information provided by the different persons. In the present privacy policy, the established purposes, measures and procedures for the use of our databases are established, as well as the mechanisms by which people, whose data is in our database, count to know, update, rectify , suppress and generally enforce their rights. The express or unequivocal acceptance of these policies implies acceptance of this Privacy Policy and its authorization for the uses and treatments described herein. In any case, these Privacy Policies, at no time, may be interpreted in any way contrary to the applicable laws and the rights that correspond to them.

Your personal information will be used and managed under strict security and responsibility, using the appropriate physical and magnetic means that allow the confidentiality of the information.

1. PURPOSE OF THE DATABASE. (i) Maintain by any means known or known, an efficient communication related to the products, services, communications events of the agency, its clients and / or third parties hired by the agency (ii) conduct studies on consumption habits, brand investigations , and determine the quality of the products, services, events, communications of the agency and / or its clients; (iii) contracting, execution and commercialization of the products, services, events, communications and contents of the agency; (v) the transmission of data to third parties with whom contracts for this purpose have been concluded for commercial, administrative, marketing and / or operational purposes; (vi) comply with service contracts entered into with the agency's clients; (vii) maintain and process any type of information related to the business of current and future clients of the agency in order to provide strategic communications, advertising and marketing services; (vii) the other purposes determined by those responsible in processes for obtaining personal data for processing and that are communicated to you at the time of the collection of personal data.

2. METHOD OF OBTAINING AND DATA SUPPLIED. The agency may expressly request the data that is necessary to fulfill the purpose of the database, which are -among others- your name and surnames, identification number, date of birth, address of correspondence, contact telephone, email , experience, place of work, references and work history, needs and interests, purchases made, tastes. The data may be provided to the agency, collected personally, obtained through consultation with third parties that manage databases or collected in events, claims, requests, surveys, proposals, or requests to participate in projects, programs, events, through the web page, etc.

The agency will not collect data considered as sensitive data according to the provisions of law 1581 of 2012, such as data revealing racial or ethnic origin, political orientation, religious or philosophical convictions, membership of unions, social organizations, data related to health, sex life or biometric data.

3. AUTHORIZATION FOR COLLECTION FOR COLLECTION AND PROCESSING OF PERSONAL DATA AND INFORMATION. By voluntarily supplying some of the personal data in the manner indicated in the preceding paragraph, and / or express verbal or written authorization, the owner expressly or unequivocally authorizes the agency to collect personal data and any other information it provides, as well as to carry out the treatment of your personal data, in accordance with this Privacy Policy and the law.

4. TREATMENT OF PERSONAL DATA STORED IN THE DATABASES OF THE AGENCY. The agency will only use, process and circulate the personal data and other information of its members for the purposes described and for the treatments authorized in this Privacy Policy or in the laws in force. The Agency will comply with the National Database Registry in accordance with the provisions of Decree 886 of 2014. In addition to what is mentioned in other clauses, the third party expressly authorizes the Agency to collect, use and circulate their personal data and other information for the following purposes and in the following circumstances: (i) establish communication between the agency and you for any purpose related to the purposes set forth in this privacy policy of the agency either through calls, text messages, emails and / or physical; (ii) audit study, analyze and use information from the database to design, implement and develop programs, projects and events; (iii) audit study, analyze and use information from the database for the socialization of policies, projects, programs, results and organizational changes; (iv) comply with laws, regulations or legal processes, to ensure compliance with the terms and conditions, to stop or prevent fraud, attacks on the safety of the Agency or others, prevent technical problems or protect the rights of others as require the terms and conditions or the law; (v) The rest established in the law.

5. APPLICATION FOR AUTHORIZATION FOR NEW USES. The Agency may request authorization for the use or circulation of your data or information for purposes other than those expressed in this Privacy Policy, for which it will publish the changes in this Privacy Policy on its website www.quadi.com.co co or in any public medium that it deems appropriate according to the case.

6. INFORMATION AND DATA OF MINORS. The agency does not use, store or perform any treatment on personal data of minors. if for any fraud or error, you get to have stored information of a minor this will be deleted from our databases immediately, once it is known that the data belongs to a minor.

7. STORAGE OF PERSONAL DATA. The owner expressly authorizes the agency to store your data in the manner it considers most appropriate and complies with the security required for the protection of data in accordance with normal and reasonable standards applicable to companies such as the Agency.

The databases held by the Agency will comply with the National Database Registry under the conditions established by Decree 886 of 2014

SECURITY MEASURES FOR THE PROTECTION OF PERSONAL DATA AND OTHER INFORMATION. The security measures available to the Agency seek to protect the data of people included in them, in order to prevent their adulteration, loss, use and unauthorized access. To do this, the Agency diligently implements human, administrative and technical protection measures that are reasonably available. The owner expressly accepts this form of protection and declares that he considers it convenient and sufficient for all purposes.

Likewise, third parties hired by the Agency are also obliged to adhere to and comply with the security policies and manuals of the information, as well as the security protocols that we apply to all our processes.

Any agreement of the Agency with third parties (contractors, external consultants, temporary collaborators, etc.) that involves the processing of information and personal data, includes a confidentiality agreement, which details its commitments for protection, care, security and preservation of confidentiality. , integrates and privacy of it.

RIGHTS OF THE HOLDERS. The agency informs that according to current legislation, people have among others, the right to know, update, rectify their information and / or revoke the authorization for their treatment. In particular, they are rights of the holders as established in article 8 of Law 1581 of 2012:

A. Know, update and rectify your personal data.
B. Request proof of the authorization granted.
C. Be informed, upon request, regarding the use you have given to your personal data
D. Submit to the Superintendency of Industry and Commerce complaints about infractions or the provisions of the Law.
E. Revoke the Authorization and / or request the deletion of the data.
F. Access free of charge to your personal data that have been subject to treatment

CONTACTS

(I) PERSON IN CHARGE OF PETITIONS, CONSULTATIONS AND CLAIMS. The person in charge of attending the requests, queries and claims of the holders to exercise their rights to know, update, rectify and delete their data and revoke their authorization is digital@qdata.io, or to the correspondence address calle 99 No 7ª-77 oficina 201 Bogotá, Colombia.

(II) PROCEDURE TO EXERCISE YOUR RIGHTS. In case you wish to exercise your rights, you must send an electronic or physical email to the contact addresses established in this Privacy Policy.

(III) PETITIONS AND CONSULTATIONS ON PERSONAL DATA When the owner of the data or his successors wish to consult the information that rests in the database, the Agency will respond to the request within a maximum of ten (10) days or the maximum period established by law. In compliance with the provisions of the Law 1581 of 2012, when it is not possible to attend the consultation within said term, will be informed of the reasons for the delay and will indicate the date on which your query will be attended, which may not exceed the (5) business days following the expiration of the first term, or the maximum term established by Law.

(IV) RENEWAL OF AUTHORIZATION WITHDRAWAL OR SUSPENSION OF THE DATABASE AND CLAIMS ON PERSONAL DATA. When the owner of the data or his successors consider that the information contained in the databases 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 submit a claim before the Agency, which will be processed under the following rules, which in no case will diminish or restrict the rights established by Law:

1. The claim will be formulated by means of a request addressed to the Agency with the identification of the holders, a description of the facts that give rise to the claim, the address, and the documents that they want to assert will be annexed. If the claim is incomplete, the Agency may require the interested party within five (5) days after the 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 shall be understood that the claim has been abandoned. In the event that the Agency is not competent to resolve the claim, it will transfer to the corresponding party within a maximum period of (2) business days and inform the Holder of the situation, which will be relieved of any claim or liability for the use , rectification or deletion of data.

2. Once the complete claim has been received, a legend that says "claim in process" and the reason for it will be included in the database, in a term not exceeding two (2) business days. This legend must be maintained until the claim is decided

3. The maximum term to attend the claim will be fifteen (15) business days counted from the day following the date of its receipt. When it is not possible to meet the claim within said term, the Owner will be informed of the reasons for the delay and the date on which his claim will be handled, which in no case may exceed eight (8) business days following the expiration of the first finished.

11. CONTACT. Any questions or additional information will be received and processed by sending them to the contact addresses established in this Privacy Policy.

12. DATABASE EFFECTIVE PERIOD The personal data included in the database will be valid for the period necessary to fulfill its purposes, which in any case will not be less than 80 years.

The personal data included in the database will comply with the Registry in the database policies created by Law 1581 of 2012 and regulations by Decree 886 of 2014.

13. CHANGES IN THE PRIVACY POLICY. Any substantial change in treatment policies will be communicated in a timely manner to the owners through publication on our web portals.

14. CURRENT LEGISLATION. The current national legislation on the protection of personal data is contained in the Law of 1581 of 2012, Decree 1377 of 2013, Law 1266 of 2008 and Decree of 886 of 2014 the rules that modify or complement it.