DATA TREATMENT POLICY

1. IDENTIFICATION OF THE RESPONSIBLE FOR THE TREATMENT OF THE INFORMATION:

   LINEXPERTS CONSULTORÍA EMPRESARIAL S.A.S., hereinafter LINEXPERTS identified with NIT 900569187-6, located at Carrera 7B No. 123-46 in Bogotá, telephone 57-1-3841740 / 3005549906, email: This email address is being protected from spambots. You need JavaScript enabled to view it..

2. DEFINITIONS:

   1. Authorization: Prior, express and informed consent of the Holder to carry out the Processing of personal data.

   2. Database: Organized set of personal data that is subject to Treatment.

   3. Personal data: Any information linked to or that can be associated with one or more determined or determinable natural persons.

   4. Person in Charge of Treatment: 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 Person Responsible for Treatment.

   5. 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.

   6. Owner: Natural person whose personal data is subject to Treatment.

   7. Treatment: Any operation or set of operations on personal data, such as collection, storage, use, circulation or deletion.

3. PURPOSES AND TREATMENT TO WHICH THE PERSONAL DATA WILL BE SUBJECTED: The personal data that LINEXPERTS collects, stores, uses, circulates and deletes, and in general, Treats will be used for any of the following purposes:

   1. In relation to the operation of LINEXPERTS

      1. Human resource
         The processing of the data will be carried out for the selection and/or recruitment process, performance of functions or provision of services, administration of human resources, withdrawal or termination of employment contracts. The foregoing depending on the type of legal relationship between the Holder of the information and LINEXPERTS (includes, among others, applicants or applicants for positions, employees, former employees and interns.).

      2. Suppliers and Contractors of LINEXPERTS
         The processing of the data will be carried out for the purposes related to the development of the contractual management process of products or services that LINEXPERTS requires for its operation in accordance with current regulations.

      3. Security in LINEXPERTS facilities
         The Treatment will be carried out for the surveillance and security of the people, goods and facilities of LINEXPERTS.

      4. Purposes for cases in which LINEXPERTS acts as Processor
         In the cases in which LINEXPERTS acts as a manager, the processing of personal data to which it has access is limited exclusively to the purposes related to the execution of the commercial and/or contractual relationship and in any case on behalf of the Responsible, safeguarding in at all times the security of the databases on which the order exists and taking into account the current regulations on the matter.

4. RIGHTS OF THE HOLDERS:

   1. Know, update and rectify the personal data in front of LINEXPERTS as Responsible and in Charge of the Treatment. This right may be exercised, among others, against partial, inaccurate, incomplete, fragmented, misleading data, or those whose Treatment is expressly prohibited or has not been authorized.

   2. Request proof of the authorization granted to LINEXPERTS as Responsible, except when expressly excepted as a requirement for Treatment, in accordance with the provisions of article 10 of Law 1581 of 2012.

   3. Be informed by LINEXPERTS upon request, regarding the use that has been given to the Holder's personal data.

   4. Submit complaints to the Superintendence of Industry and Commerce for violations of the provisions of Law 1581 of 2012 and other regulations that modify, add or complement it.

   5. Revoke the authorization and/or request the deletion of the personal data. The revocation and/or deletion will not proceed when the Holder has a legal or contractual duty to remain in the database.

   6. Free access to the personal data that has been subject to Treatment.

   7. Voluntarily answer questions that are related to sensitive data or minors.

5. DATA OF MINORS:
   Authorization of the parents or legal representatives of the minor.

6. SENSITIVE DATA:
   Sensitive personal data correspond to those that affect the privacy of the Holder or whose improper use may cause discrimination, such as those that reveal race or ethnicity, political orientation, religious or philosophical convictions, membership in unions, social organizations, rights or that promotes the interests of any political party or that guarantees the rights and guarantees of opposition political parties, as well as data related to health, sexual life and biometric data, among others.

   When there are exceptions under which the Processing of sensitive personal data is allowed, this must be done by informing the Holder that he is not obliged to authorize the Processing of sensitive personal data, informing what the sensitive data is and the purpose of the treatment, as well as obtaining the express consent of the person to whom the respective sensitive data belongs.

7. AUTHORIZATION OF THE HOLDER:
   Without prejudice to the exceptions provided by law, the Treatment requires the prior, express and informed authorization of the Holder, which must be obtained by any means that may be subject to consultation and subsequent verification.

   The Authorization may also be obtained from unequivocal conduct of the Holder that allows a reasonable conclusion that he/she gave his/her consent to the Treatment.

8. CASES IN WHICH AUTHORIZATION IS NOT REQUIRED::
   The authorization of the Holder will not be necessary in the case of:

   1. Information required by a public or administrative entity in the exercise of its legal functions or by court order.

   2. Data of a public nature.

   3. Cases of medical or health emergency.

   4. Treatment of information authorized by law for historical, statistical or scientific purposes.

   5. Data related to the Civil Registry of Persons.

9. ATTENTION OF PETITIONS, INQUIRIES AND CLAIMS:
   To make requests, queries or claims related to the Processing of Personal Data, the Holder or his successors in title may use any of the following communication channels:

   • At the LINEXPERTS headquarters: Avenue 7B No. 123 - 46 From Monday to Friday during public service hours (8:00 AM to 5:30 PM)

   • Landline: (571) 3841740 / 3005549906

   • Email: This email address is being protected from spambots. You need JavaScript enabled to view it.

   • Person or area responsible for handling requests, queries and claims: Requests, queries or claims received through the different channels will be directed to the marketing area that LINEXPERTS has designated for handling requests, queries or claims.

10. PROCEDURE TO EXERCISE RIGHTS:

    1. Queries
       They will be resolved within a maximum term of ten (10) business days from the date of receipt.

       When it is not possible to answer the query within said term, the Holder will be informed before the expiration of 10 days, stating the reasons for the delay and indicating the date on which his request will be addressed, which in no case may exceed five days. (5) business days following the expiration of the first installment.

    2. Claims
       People who consider that the information contained in a LINEXPERTS database should be corrected, updated or deleted, or who notice the alleged breach of any of the duties contained in Law 1581 of 2012, may file a claim with LINEXPERTS, through any of the communication channels described in number 8; and it must contain the following information:

       1. Name and identification of the Holder.

       2. The precise and complete description of the facts giving rise to the claim.

       3. The physical or electronic address to send the response and report on the status of the procedure.

       4. The documents and other evidence that is intended to be asserted.

    If the claim is incomplete, LINEXPERTS will require the interested party within five (5) days of receipt to correct the faults. After two (2) months from the date of the request, without the petitioner submitting the requested information, it will be understood that he has withdrawn from it.

    Once the complete claim is received, LINEXPERTS will include in the respective database a legend that says "claim in process" and the reason for it, within a term not exceeding two (2) business days. Said legend will remain until the claim is decided.

    The maximum term to address the claim will be fifteen (15) business days counted from the day following the date of its receipt, and if it is not possible to respond within said term, LINEXPERTS will inform the interested party of the reasons for the delay and the date on which it will be attended, without exceeding, in any case, eight (8) business days following the expiration of the first term.

11. EFFECTIVE DATE OF THE INFORMATION PROCESSING POLICY AND VALIDITY PERIOD OF THE LINEXPERTS DATABASES:
    This policy governs from its issuance and the databases subject to Treatment will remain in force as long as it is necessary to comply with the purposes informed in number 2 of the same.

12. DATA PROTECTION AUTHORITY
    The state data protection authority to which to refer in cases of doubts or complaints about the use of personal data, is the Superintendence of Industry and Commerce.

DOCUMENT CHANGE CONTROL

• Version 01: Creation
  Distribution: Operations Manager.

• Version 02: Logo adaptation and wording in the document
  Date: 23/11/2020
  Distribution: Operations Manager.

• Version 03: Adjustments in the wording, inclusion of definitions, an independent chapter of sensitive data is created, detailing when Linexperts acts as a manager.
  Date: 10/02/2022
  Distribution: Manager of Innovation and Expansion of New Businesses. Contractor - Data Protection Expert.

• Version 04: Policy review
  Date: 20/02/2023
  Distribution: Manager of Innovation and Expansion of New Businesses. Contractor - Data Protection Expert.

• Version 05: Document Update.
  Date: 20/02/2024
  Distribution: Manager of Innovation and Expansion of New Businesses. Contractor - Data Protection Expert.