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Information processing policy

Value Partners Solutions SAS

The policies contained in this document were prepared taking into account the provisions contained in articles 15 and 20 of the Political Constitution, Law 1581 of 2012 “By which general provisions are issued for the protection of personal data” and Decree 1377 of 2013 “by which Law 1581 of 2012 and Circular 02 of November 2015 of the Superintendency of Industry and Commerce are partially regulated.
The policies described below apply to the processing of personal data collected and controlled by VALUE PARTNERS SOLUTIONS SAS with address at Carrera 12 No. 89-33 Piso 6 Bogotá D.C, email comunicacion@vpslatam.com telephone 57 (1) 7561220.

The policies and procedures contained in this document apply to the databases and historical records managed by VALUE PARTNERS SOLUTIONS SAS, whose validity period extends to the entire duration of the company.

TREATMENT TO WHICH THE PERSONAL DATA COLLECTED BY VALUE PARTNERS SOLUTIONS SAS WILL BE SUBJECTED

The personal data for which VALUE PARTNERS SOLUTIONS SAS is responsible are included in databases and will be used for the following purposes:

1. Provision of services inherent to the accounting discipline;
2. Provision of delegated administration services;
3. Administrative management outsourcing services;
4. Provision of business management services.
The information being processed by VALUE PARTNERS SOLUTIONS SAS may be transmitted for use by third parties only when a contract signed with VALUE PARTNERS SOLUTIONS SAS mediates with those third parties and for purposes similar or analogous to those indicated above.
RIGHTS THAT ASSIST YOU AS THE OWNER OF THE INFORMATION CONTAINED IN OUR DATABASES
In accordance with the provisions of article 8 of Law 1581 of 2012, the owner of personal data has the following rights:

1. Know, update and rectify your personal data against VALUE PARTNERS SOLUTIONS SAS, in its capacity as data controller.
2. Request proof of the authorization granted to VALUE PARTNERS SOLUTIONS SAS in its capacity as data controller.
3. Be informed by VALUE PARTNERS SOLUTIONS SAS, upon request, regarding the use that has been given to your personal data.
4. Submit complaints to the Superintendency of Industry and Commerce for violations of the provisions of Law 1581 of 2012, once the consultation or claim process has been exhausted before the person responsible for the Treatment.
5. Revoke the authorization and/or request the deletion of the data when the processing does not respect constitutional and legal principles, rights and guarantees.
6. Access free of charge to your personal data that has been processed.

PROCEDURES FOR ACCESS, CONSULTATION, RECTIFICATION AND UPDATE OF INFORMATION
The owners of the information have the right to access their personal data and the details of their processing, as well as to rectify and update them if they are inaccurate or to request their deletion when they consider that they turn out to be excessive or unnecessary for the purposes they justified. obtaining or opposing the processing of the same for specific purposes of access, consultation, rectification and updating of the information, the ways that have been implemented to guarantee the exercise of said rights, through the presentation of the respective request are:
– Our physical offices, in the area in charge of data protection Customer Service, located at Carrera 12 No. 89-33 Floor 6 of Bogotá D.C., telephone 57 (1) 7561220
– Email comunicacion@vpslatam.com

The above mechanisms have been enabled so that information holders or third parties authorized by law to act on their behalf can exercise the following rights:
RIGHT OF ACCESS: The owner of the information may consult his or her personal data for free at least once every calendar month. To know the personal data that is subject to processing by VALUE PARTNERS SOLUTIONS SAS, the owner of the information may submit a request indicating the information they wish to know through any of the mechanisms indicated above.

The request will be responded to within a maximum period of ten (10) business days from the date of receipt. When it is not possible to attend to the request within said term, this fact will be informed to the applicant, expressing the reasons for the delay and indicating the date on which their query will be attended to, which in no case may exceed five (5) business days. following the expiration of the first term.

CLAIMS: In accordance with the provisions of article 14 of Law 1581 of 2012, when the Owner or his successors consider that the information contained in a database must be corrected, updated or deleted, or when it must be revoked by If the alleged breach of any of the duties contained in Law 1581 of 2012 is noticed, they may file a claim with the administrative management, which will be processed under the following rules:
The rights of rectification, updating or deletion or revocation of consent may only be exercised by:
• The owner or his successors, after proving his identity;
• His representative, after accreditation of the representation;
• By stipulation in favor of another or for another.

When the request is made by a person other than the owner and it is not proven that the request is acting on behalf of the owner, it will be considered not submitted. The request for rectification, update, deletion or revocation must be submitted through the means enabled by VALUE PARTNERS SOLUTIONS SAS and contain, at least, the following information:
1. The name and address of the owner or any other means to receive the response.
2. The documents that prove the identity of the applicant and, if applicable, that of his representative with the respective authorization.
3. The clear and precise description of the personal data with respect to which the owner seeks to exercise any of the rights and the specific request.
4. If necessary, other elements or documents that facilitate the location of personal data.

The maximum term to address the claim will be fifteen (15) business days counted 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 their claim will be addressed, which in no case may exceed eight (8) business days following the expiration of the first term.
SENSITIVE DATA: In accordance with the provisions of article 6 of Law 1581 of 2012, sensitive data is considered to be data that affects the privacy of the Owner or whose improper use may generate discrimination, such as data that reveals racial or ethnic origin. political orientation, religious or philosophical convictions, membership in unions, social organizations, human rights organizations or organizations 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, to sexual life and biometric data.
In the event that the treatment involves data classified by law as sensitive, VALUE PARTNERS SOLUTIONS SAS must have express and prior authorization for treatment and is obliged to use them in accordance with the rules established in article 6 of Decree 1377 of 2013.

AREA RESPONSIBLE FOR ATTENTION TO PETITIONS, CONSULTATIONS, CLAIMS
The area responsible for addressing requests for access, rectification, updating, deletion of data or revocation of consent or authorization granted for the processing of your personal data is Customer Service, located at Carrera 12 # 89-33 Piso 6 Bogotá D.C. , email comunicacion@vpslatam.com and telephone 57 (1) 7561220

The information processing policy contained in this document comes into force as of March 2016.