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PRIVACY POLICY AND PERSONAL DATA PROTECTION

CUATRO PERLAS S.A.S., with offices in Carrera 60D # 90-32 Bogotá D.C. Colombia, contact number +57 1 8053161, hereby informs that personal data gathered through their website, as well as through campaigns, template, events, webpages and all other formats used in marketing activities will be treated in a reliable and safe manner for the following purposes: to comply with the obligations derived from contractual relations established with the owner of such data; to grant warranty on the products that have been purchased when necessary; inform about commercial conditions and post-sale information among other actions related to the business that the company enters into with the owner of such data. Likewise, we hereby inform that data may be delivered in a safe manner under the direction of CUATRO PERLAS S.A.S., to the service provider and or a contractor and will be managed in a safe IT infrastructure, in a confidential manner and will not be given to third parties.
They may also be delivered to the authorities when required, pursuant to their legal faculty, and they may also be consulted in databases that are of public use to detect risks. In addition to the aforementioned, all personal data information obtained from the owner of this data may be treated for the following purposes, if authorized by the owner:

To carry out business intelligence actions, prospection of clients, market research and trends regarding the personal information that the holder of such information has granted. To create offers tailor-made for the client and his or her needs and invite them to participate in special events that are of interest to them, among others. To communicate promotions to the clients on products and services that may be of interest to him or her, as well as sending gifts for advertising campaigns.

To send advertising to the client on products, goods and services of CUATRO PERLAS S.A.S. For the execution of orders, online payment and the delivery of information on shipping information.

To deliver data and personal information to third parties as stated in the previously mentioned processing of such data.

The holder of such data may exercise his/her rights to access, correct, delete, revoke or claim due to a breach on his/her data and all other rights stated in article 8 of law 1581 of year 2012 and all other provisions that supplement or supersede the former, by means of the following: email, info@mercedessalazar.com., or to submit a written request in the main offices of the administrative area.
Holders of the information are hereby informed that they may consult the personal data protection policy herein below:

PERSONAL DATA PROTECTION POLICY

CUATRO PERLAS S.A.S. is a company identified with Colombian Tax Id Number - NIT 830087454-5 and established pursuant to Colombian trade laws, with main offices in the city of Bogotá Carrera 60D # 90-32 and switchboard PBX 7437100, hereby commits to comply, by means of this document, to that provided for by Law 1581 of 2012 in order to ensure that obtaining, registering, managing, transmitting, transferring and storing and in general any other type of processing to personal data that the company may carry out during the execution of its subject matter, is guaranteed with the compliance of principles governing the above mentioned law and all other standards that regulate processing of personal data.

This policy applies to all officials, contractors and third parties that provide services to CUATRO PERLAS S.A.S. who have any access to information through printed documents, IT equipment, IT infrastructure and other company’s communication channels.

This Policy is based on provisions contained in articles 15 and 20 of the Colombian Political Constitution, Law 1266 of 2008, Law 1581 of 2012, Decree 1377 of 2013 and Decree 886 of 2014. CUATRO PERLAS S.A.S. may change its policy regarding the protection of personal date when deemed convenient, however, it is compelled to save the previous versions of the current policy, if any, and ensure the rights of holders determined by legislation in force.

The information provided by holders of CUATRO PERLAS S.A.S. is required to be gathered, used, disseminated, stored, shared, transmitted and/or as provided in the following processing of data for the following purposes:

The performance of administrative processes of creation, contracting and management of vendors.

Procedures related to the payment of vendors and as it relates to proceedings, consultations, claims and complains.

To contact through different means individuals that act as vendors or employees of the former in order to provide information related to the existing commercial bond.

The performance of processes related to the management of clients that include activities related to the compliance of a contractual relation entered into, granting warranties when deemed necessary, for the communication of information on commercial conditions and post-sale services, to carry out business intelligence actions, client prospecting, market research and terns related to the personal information granted by the holder of such data, for the creation of offers according to clients’ needs, sending invitations to events, sending advertising information about the products, goods and services of the company, sending promotional information and gifts for advertising campaigns.

To execute the placement of orders, online payments and delivery of information regarding shipping information.

To issue sale invoices of products, goods and services.

To carry out all that related and by virtue of the contractual relationship, inscription processes, payroll, contributions to social Security, payment of fringe benefits, internal communications and all other information and activities in which employees or their family members are related thereto or engaged in.

To carry out all internal management and or proceedings of the company to fulfill its selection processes.

To respond to legal related claims.

To fulfill administrative, judicial or legal mandates.

To issue certificates related to the relationship of the holder of the data with the company.

In order to ensure the security of people, assets and facilities.

To eventually contact, via telephone, email or by any other means individuals with whom the company has had a relationship, such us, but without limitation to, workers and their families, vendors, clients, online contacts, selection process candidates and all other stakeholders for the purposes already mentioned.

For the performance of the administrative processes related to the subject matter of the company, when necessary, to contract so that services may be rendered by third parties, and in these cases the information will be transferred with the required security measures that allow safeguarding the intimacy of the holder and the correct rendering of services, and to comply with all other legal and constitutional obligations.

The holder of the information will have the right to:

a) To know, update and rectify personal data vis-á-vis those responsible for its processing or in charge of such processing. This right may be exercised, among others, vis-à-vis partial, inaccurate, incorrect or incomplete data, that may lead to an error, or in those cases in which such processing has been expressly forbidden or has not been authorized.

b) To request evidence of the authorization granted by the person responsible for such processing, with the caveat that it has been expressly exempted as a requirement for the processing of data, in accordance with that foreseen in article 10 of law 1581 of 2012.

c) To be informed by the person responsible of such processing or the person in charge thereof, prior a request, of the use that has been granted to such personal data.

d) To submit before the Industry and Trade Superintendence complaints due to a breach of that provided for by the law and all other norms that may supplement or supersede the former.

e) To revoke the authorization and or to request deleting such data when processing thereof does not respect legal and constitutional principles, rights and guarantees. Such revocation and/or deletion shall proceed, when the Industry and Trade Superintendence has determined that in such processing, the person responsible or in charge has incurred in conducts that are contrary to the Law and the Constitution.

f) To access, free of charge to their personal data, that was subject to such processing.

To exercise the right that owners of information have to know, update, rectify data, and to revoke the authorization they may send a communication to our email: info@mercedessalazar.com.co or submit a written request in the main offices of the administrative area. The company will provide a response to the owner that makes the petition within the terms established by law 1581 of 2012 on account of consultations and claims, respectively; to that end, the request must contain all the necessary data and applicable to the right to petition to ensure a timely and effective response. Furthermore, it shall contain a clear and accurate description of personal data upon which the owner seeks to exercise any of the rights. Every request, to be processed, must be submitted by the owner or holder of such data or his/her legal representative ; therefore, CUATRO PERLAS S.A.S. reserves the right to verify the identity of the requesting party by any means. The request will be answered in a term of maximum ten (10) business day as of the date such request was delivered. If unable to respond within such term, the interested party will be informed, with the reasons of the delay and stating a date in which such request will be answered, and under no circumstances may it exceed the following five (5) business days following the expiration of the first term.

Requests to update, correct, rectify or delete data will be answered within fifteen (15) business days following the date in which the request was received. If unable to respond within such term, it will inform the interested party before the expiration of the referred term the reasons for such delay and the date in which such request will be answered, which under no circumstances may exceed eight (8) business days following the expiration of the first term.

Petitions requesting rectifying or updating personal data, the owner must indicate the correction to be carried out and provide documentation endorsing his/her petition.

The deletion of personal data may imply the total or partial elimination of information according to the request filed by the owner, in all records, files, data bases or processing granted by CUATRO PERLAS S.A.S.

It is important to bear in mind that the right to cancel is not absolute and the entity or person responsible thereof may deny the exercise of such rights when:

The owner has a legal or contractual duty to remain in the database.

The elimination of data hinders judicial or administrative endeavors linked to fiscal, investigative obligations, or obligations to prosecute crime or update on administrative sanctions.

When data are deemed necessary to carry out an action according to public interest, or to comply with an obligation legally entered into by the owner.

Owners of personal data may revoke the consent to the processing of their personal data at any time, provided however it does not hinder a legal or contractual provisions. One shall consider that there are two modalities in which the revoke to the consent may be issued. The first one may be on all consents granted, this means that CUATRO PERLAS S.A.S. must abstain from processing the data of the owner; and second, it may be on specific processing of data, for example for advertising purposes or market studies. The second modality, which refers to the revoking the consent partially, other processing purposes of such data are maintained by the responsible party, according to the authorization granted, the responsible party may carry out and the owner agrees thereto.

Any owner or holder that provides information with the purpose of establishing pre-contractual, contractual, labor or any other relation that allows the company the normal performance of its subject matter, must provide in voluntary manner the data required by the registration process as a stakeholder of the company.

It contains the privacy notice which is the physical and/or electronic document that is made available to the owner of the information by which CUATRO PERLAS S.A.S. informs on the existence of the policy for the protection of personal data, the way to access it and the processing that will be granted to his/her personal data.

The company will have information mechanism in place such an email and a website of the Responsible party, through which it will disseminate the policy and protocols defined to service requests related to the information provided.

This policy is effective as of its issuance and databases subject to Processing will be effective while it is deemed necessary for the purposes established. As a rule of thumb, the term of authorizations on the use of personal data is understood as in force during the performance of the subject matter of CUATRO PERLAS S.A.S.

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