POLICY FOR THE PROCESSING OF INFORMATION

A.Identification

EMPRESA JAIME ARTEAGA Y ASOCIADOS S.A.S.
NIT 900.584.064-2
CORREO ELECTRÓNICO [email protected]

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1. INTRODUCTION

JAIME ARTEAGA Y ASOCIADOS S.A.S. guarantees the protection of the rights related to Habeas Data, privacy, intimacy, good name, and image. For this purpose, all actions will always be governed by the principles of good faith, legality, informational self-determination, freedom, and transparency.

In the course of its permanent or occasional functions and activities, JAIME ARTEAGA Y ASOCIADOS S.A.S. may act as the Controller of personal data processing. Therefore, and in compliance with the law, this Personal Information Processing Policy is issued, aiming to inform data subjects about the principles and guidelines that govern the processing of personal data within the organization. This, in turn, seeks to strengthen trust among data subjects when they provide their personal information to JAIME ARTEAGA Y ASOCIADOS S.A.S. for processing.

This Policy applies to all personal data recorded in any database that makes them subject to processing by JAIME ARTEAGA Y ASOCIADOS S.A.S., headquartered in Bogotá, at Calle 26B #4A – 45, Torre KLM, 7th floor, with phone number (+57) 1 747 77 20 and email address [email protected].

2. DEFINITIONS

In accordance with current legislation, the following definitions are established:

Habeas Data: A fundamental right enshrined in Article 15 of the Political Constitution, which guarantees every individual the right to know, update, and correct personal information collected about them in public or private databases or files.

Controller: A natural or legal person, public or private, who by themselves or in association with others, decides on the database and/or the processing of personal data.

Processor: A natural or legal person, public or private, who by themselves or in association with others, processes personal data on behalf of the Controller.

Data Subject: A natural person whose personal data are subject to processing.

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

Authorization: The prior, express, and informed consent of the data subject to carry out the processing of personal data.

Database: An organized set of personal data that is subject to processing.

Personal Data: Any information linked to or that can be associated with one or more individuals.

Private Personal Data: Data that is relevant to the data subject, such as images in photographs and videos, lifestyle, home address, home phone number, personal cell phone, personal email.

Public Personal Data: Data that is not sensitive, such as marital status, profession or occupation, status as a merchant or public servant, and any data that can be obtained without reservation.

Sensitive Personal Data: Personal data that, due to its nature, may affect the data subject’s privacy or whose improper use may lead to discrimination.

Examples: fingerprint, racial or ethnic origin, political orientation, religious or philosophical beliefs, membership in trade unions, social or human rights organizations, or organizations promoting political interests or guaranteeing the rights and protections of opposition political parties, as well as health, sex life, and biometric data.

3. PRINCIPLES APPLICABLE TO PERSONAL DATA PROCESSING

JAIME ARTEAGA Y ASOCIADOS S.A.S. shall apply the following principles, which constitute the rules to be followed in the collection, handling, use, processing, storage, and exchange of personal data:

  • Principle of Legality: The use, capture, collection, and processing of personal data shall be governed by applicable laws and regulations concerning the processing of personal data and other related fundamental rights.
  • Principle of Freedom: The use, capture, collection, and processing of personal data may only be carried out with the prior, express, and informed consent of the data subject. Personal data may not be obtained or disclosed without prior authorization, unless there is a legal, statutory, or judicial mandate that overrides consent.
  • Principle of Purpose: The use, capture, collection, and processing of personal data accessed and collected by JAIME ARTEAGA Y ASOCIADOS S.A.S. shall serve a legitimate purpose, which shall be communicated to the data subject.
  • Principle of Truthfulness or Quality: The information subject to use, capture, collection, and processing must be truthful, complete, accurate, up-to-date, verifiable, and understandable. Processing of partial, incomplete, misleading, or error-inducing data is prohibited.
  • Principle of Transparency: In all data processing, the data subject has the right to obtain information from JAIME ARTEAGA Y ASOCIADOS S.A.S., at any time and without restriction, about the existence of data concerning them.
  • Principle of Restricted Access and Circulation: Personal data, except public information, shall not be available online or through mass communication media unless access is technically controllable to provide limited access to authorized parties only.
  • Principle of Security: Personal data and information used, captured, collected, and processed by JAIME ARTEAGA Y ASOCIADOS S.A.S. shall be protected through the implementation of technological safeguards, protocols, and all necessary administrative, human, and technical measures to secure records and prevent tampering, modification, loss, unauthorized access, or use.

Principle of Confidentiality: All individuals who manage, handle, update, or access personal information in databases maintained by JAIME ARTEAGA Y ASOCIADOS S.A.S. are committed to strictly maintaining confidentiality and not disclosing such information to third parties. This includes personal, commercial, accounting, technical, or any other type of information provided during the performance of their duties. All database administrators must sign an additional agreement to ensure compliance. This obligation remains in effect even after the termination of their role or relationship with the company.

4. DUTIES OF JAIME ARTEAGA Y ASOCIADOS S.A.S. AS CONTROLLER OF PERSONAL DATA

When acting as the Controller, JAIME ARTEAGA Y ASOCIADOS S.A.S. shall comply with the following duties:

Comply with instructions and requirements issued by the Superintendence of Industry and Commerce.

Guarantee the data subject the full and effective exercise of the right to Habeas Data at all times.

Request and retain, under the conditions established by law, a copy of the authorization granted by the data subject.

Duly inform the data subject of the purpose of data collection and their rights under the granted authorization.

Store information with the necessary security measures to prevent tampering, loss, consultation, unauthorized or fraudulent use or access.

Ensure that the information provided to the Processor is truthful, complete, accurate, up-to-date, verifiable, and understandable.

Update information and communicate in a timely manner to the Processor any changes regarding the data previously provided and take necessary measures to keep the information updated.

Correct the information when it is inaccurate and inform the Processor accordingly.

Provide the Processor, as appropriate, only personal data authorized for processing under the law.

Require the Processor at all times to respect the security and privacy conditions of the data subject’s information.

Handle inquiries and complaints within the legal timeframes.

Adopt an internal manual of policies and procedures to ensure compliance with the law, especially regarding the handling of inquiries and complaints.

Inform the Processor when certain information is under dispute by the data subject, once a complaint has been filed and until the process is resolved.

Inform the data subject upon request about how their personal data is being used.

Notify the data protection authority when security breaches occur and pose risks to the administration of personal data.

5. DUTIES OF JAIME ARTEAGA Y ASOCIADOS S.A.S. AS PROCESSOR OF PERSONAL DATA

When acting as Processor, JAIME ARTEAGA Y ASOCIADOS S.A.S. shall comply with the following duties:

  • Ensure the data subject’s full and effective exercise of the right to Habeas Data at all times.
  • Store the information with necessary security measures to prevent tampering, loss, consultation, unauthorized or fraudulent access or use.
  • Timely update, rectify, or delete the data in accordance with this law.
  • Update the information provided by the Controllers within five (5) business days from receipt.
  • Address data subjects’ inquiries and complaints in accordance with the legal provisions.
  • Adopt an internal manual of policies and procedures to ensure proper compliance with this law, especially to handle data subjects’ inquiries and complaints.
  • Mark the database with the phrase “claim in process” as regulated by law.
  • Mark the database with the phrase “information under judicial review” once notified by the competent authority of legal proceedings involving the data’s validity.
  • Refrain from disseminating any information under dispute and blocked by order of the Superintendence of Industry and Commerce.
  • Allow access to information only to those authorized to view it.
  • Notify the Superintendence of Industry and Commerce of any security violations and risks in managing data subjects’ information.
  • Comply with the instructions and requirements issued by the Superintendence of Industry and Commerce.

6. POLICIES APPLICABLE TO PERSONAL DATA PROCESSING

6.1 Request for Authorizations

Subject to the exceptions provided by law, personal data processing requires prior, express, and informed consent from the data subject, which must be obtained through any means that allows for future consultation and verification.

JAIME ARTEAGA Y ASOCIADOS S.A.S. will collect the required authorizations, which may be in physical or electronic form, as a data message, or any other format that allows for subsequent verification, and through an appropriate technical or technological mechanism such as a click to-accept option or any other mechanism that ensures clear and understandable consent.

The data subject’s authorization will be sought for the processing of data only for those purposes related to the provision of services, and they will be informed of their rights, the purposes of data collection, the entity responsible for processing, and the use of their data.

  • 6.2 Processing and Purposes for Which Personal Data Will Be Used

JAIME ARTEAGA Y ASOCIADOS S.A.S. acknowledges that personal data always belongs to the individuals to whom it refers and that only they can decide on its use. In this regard, JAIME ARTEAGA Y ASOCIADOS S.A.S. uses this data only for the purposes for which it is duly authorized and always in compliance with current regulations on personal data protection. In any case, and for data that is not of a public nature, it will only be disclosed with the express authorization of the data subject or when a competent authority requests it.

Specifically, the purposes for which data is used within JAIME ARTEAGA Y ASOCIADOS S.A.S. are:

  • 6.2.1 Employees

Employee information, including that of individuals participating in selection processes, will be processed for the purpose of managing the contractual relationship between JAIME ARTEAGA Y ASOCIADOS S.A.S. and the employee or collaborator, and particularly for:

  • Fulfilling the employer’s obligations, as determined by Colombian labor law or mandated by competent authorities.
  • Administration, management, and payment of payroll and social security.
  • Pension requests and procedures.
  • Providing appropriate work attire.
  • Conducting and maintaining records of training and development plans.
  • Carrying out the accounting records required by law.
  • Implementing the Occupational Safety and Health Management System (SG-SST).
  • Conducting processes for determining the origin and percentage of loss of work capacity in which the employee participates.
  • Supporting and executing benefits derived from an employment contract, such as, but not limited to: registration and/or updating of beneficiaries with the comprehensive social security system, provision of welfare activities, and development of various work activities.
  • Creating and managing user accounts for access to the organization’s platforms (software).
  • Conducting performance evaluations and disciplinary procedures.
  • Issuing employment certificates and providing job references upon request.
  • Contacting family members in case of emergencies.
  • Personal data such as images, captured in photographs, will be processed for the purpose of employee documentation with identification cards and for internal corporate publications, on the company’s website, and/or on social media.
  • Sensitive data such as fingerprints will be processed for the purpose of verifying consent in contractual matters.
  • Sensitive data such as monitoring health symptoms will be collected for the sole purpose of complying with biosafety protocols required by the health emergency generated by the pandemic.
  • Other purposes contained in the respective authorization or privacy notice.

This data will be retained for a period of twenty (20) years from the termination of the employment relationship, in accordance with Resolution 312 of 2019. Labor history information related to parafiscal contributions and social security in general will be stored for a period of eighty (80) years from the termination of the employment relationship, in accordance with legal or contractual circumstances that necessitate the preservation of the information.

  • 6.2.2 Participants in Selection Processes or Applicants

Applicant information will be processed for the purpose of selecting personnel for the organization and ultimately formalizing an employment relationship between the applicant and JAIME ARTEAGA Y ASOCIADOS S.A.S., and particularly for:

  • Facilitating the development of the organization’s selection processes.
  • Participating in psychotechnical and/or psychophysical tests.
  • Verifying references and conducting security screenings, if deemed relevant.
  • Verifying the accuracy of information, personal and/or work references, disciplinary and/or judicial records, or those related to restrictive risk lists, prevention of money laundering, corruption, and terrorism financing.

In the case of applicants, personal information will be kept for a period of six (6) months from the moment the applicant concluded their participation in the selection process for which they applied, also considering any legal or contractual circumstances that may necessitate processing for an additional period.

  • 6.2.3 Shareholders

The information of individual shareholders will be processed for the purpose of managing the commercial relationship between JAIME ARTEAGA Y ASOCIADOS S.A.S. and the shareholder, and particularly for:

  • Inviting to company meetings and generally exercising the duties and rights of every shareholder.
  • Issuing certifications of shareholder status.
  • Maintaining the company’s corporate books.
  • Carrying out the accounting records required by law.
  • Carrying out registrations with the commercial registry and/or relevant authorities as required by law.
  • Contacting for communications and notifications related to the company’s development.
  • Other purposes contained in the respective authorization or privacy notice. In the case of shareholders, personal information will be kept for the duration of their shareholder status and for any additional time required by legal or contractual circumstances.
  • 6.2.4 Suppliers or Contractors

The information of suppliers (legal entities) or individual contractors will be processed for the purpose of managing the contractual relationship between JAIME ARTEAGA Y ASOCIADOS S.A.S. and the supplier, and particularly for:

  • Verifying the suitability and competence of the Supplier or Contractor, and/or their employees.
  • Developing the supplier evaluation and selection process.
  • Conducting financial analysis.
  • Facilitating the perfection of the contractual relationship linking them to JAIME ARTEAGA Y ASOCIADOS S.A.S.
  • Formalizing and complying with the documentation required within the registration processes for Suppliers or Contractors.
  • Fulfilling the organization’s obligations, as determined by law or mandated by competent authorities.
  • Enabling the execution of the contracted commercial purpose.
  • Managing the pre-contractual, contractual, and post-contractual stages.
  • Carrying out the accounting records required by law.
  • Verifying against risk lists or restrictive lists, public lists, disciplinary, fiscal, and criminal records.
  • Issuing certificates and providing references upon request.
  • Requesting clarifications, guarantees, or audits when necessary.
  • Evaluating the quality of services, both qualitatively and quantitatively, considering the service levels received from suppliers.
  • Sensitive data such as fingerprints will be processed for the purpose of verifying consent in contractual matters.
  • Maintaining efficient communication of information that is useful in the contractual relationships between the organization and its Suppliers and Contractors.
  • Other purposes contained in the respective authorization or privacy notice.

In the case of suppliers or contractors, personal information will be kept for the duration of the commercial relationship between JAIME ARTEAGA Y ASOCIADOS S.A.S. and the supplier or contractor plus five (5) years, and for any additional time required by legal or contractual circumstances.

  • 6.2.5 Clients

The information of individual clients will be processed for the purpose of managing the contractual relationship between JAIME ARTEAGA Y ASOCIADOS S.A.S. and the client, and particularly for:

  • Presenting quotations and budgets.
  • Facilitating the perfection of the contractual relationship linking them to JAIME ARTEAGA Y ASOCIADOS S.A.S.
  • Fulfilling the organization’s obligations, as determined by law or mandated by competent authorities.
  • Enabling the execution of the contracted commercial purpose.
  • Providing advice for the identification, formulation, support, and closing of businesses in any sector of the economy; consulting; advisory services; research; diagnostics; and studies related to projects in the fields of management, public administration, and regional and urban, national, and international development.
  • Conducting studies and research aimed at guiding and quantifying social, economic, or social communication processes.
  • Conducting socioeconomic and feasibility studies, actuarial studies, development of mathematical, econometric, and statistical models, and economic evaluation of projects.
  • Studies of culture and communication within companies and institutions.
  • Developing educational programs for individuals and institutions in the areas previously described.
  • Managing the pre-contractual, contractual, and post-contractual stages, which may include collection activities.
  • Carrying out the accounting records required by law.
  • Processing transactions through our platform and validating them to mitigate the risk of identity theft fraud in electronic commerce.
  • Providing after-sales service.
  • Conducting qualitative and quantitative evaluations of the levels of satisfaction with the service received.
  • Sensitive data such as fingerprints will be processed for the purpose of verifying consent in contractual matters.
  • Sending useful information via email, text messages (SMS and/or MMS), or any other means of communication to maintain efficient communication.
  • Promoting the services of JAIME ARTEAGA Y ASOCIADOS S.A.S. and its allied third parties.
  • Other purposes contained in the respective authorization or privacy notice.

In the case of clients, personal information will be kept for the duration of the contracts between JAIME ARTEAGA Y ASOCIADOS S.A.S. and the client, plus five (5) years, in addition to any additional time required by legal or contractual circumstances.

  • 6.2.6 Potential Clients

The information of potential individual clients will be processed for the purpose of promoting the consolidation of a commercial relationship between the potential client and JAIME ARTEAGA Y ASOCIADOS S.A.S., and particularly for:

  • Presenting the organization’s portfolio.
  • Presenting the service offerings.
  • Addressing concerns or questions raised by the potential client.
  • Developing the pre-contractual negotiation stage to solidify the commercial relationship between the potential client and the organization.
  • Sending invitations to events organized by the organization.
  • Conducting marketing and/or advertising activities.
  • Maintaining efficient communication of information that is useful for potential clients.
  • Other purposes contained in the respective authorization or privacy notice. In the case of potential clients, personal information will be kept for a period of one (1) additional year from the moment the potential client last expressed interest in the products or services offered by JAIME ARTEAGA Y ASOCIADOS S.A.S., also considering any legal or contractual circumstances that may necessitate processing for an additional period.
  • 6.2.7 Survey Respondents

The personal information of survey respondents, which in all cases is public information, will be processed for statistical and informational purposes that account for the opinions of different sectors of society, and particularly for:

  • Enabling the execution of projects contracted by clients.
  • Contacting and asking for opinions on topics related to the execution of projects carried out by the company for its clients.
  • Convening events organized by the company.
  • Sending information about events via email, text messages (SMS and/or MMS), or any other means of communication to maintain efficient communication.

In the case of survey respondents, personal information will be kept for an initial period of two (2) years from the first contact with the respondent, taking into account the respondent’s expression of remaining in the database for contact in future surveys or being immediately removed from our database. This is subject to legal or contractual circumstances that may necessitate the processing of data for an additional period.

  • 6.3 Processing of Data of Children and Adolescents

When JAIME ARTEAGA Y ASOCIADOS S.A.S. processes the personal data of minors, it will ensure respect for the prevailing rights of minors and will request the respective authorizations from the minors’ representatives or guardians, in addition to adapting the necessary security measures to ensure the confidentiality and privacy of personal data.

  • 6.4 Processing of Sensitive Data

When JAIME ARTEAGA Y ASOCIADOS S.A.S. processes sensitive personal data, it undertakes to have high security systems that guarantee its security, restricted circulation, and confidentiality, as well as prevent unauthorized use.

The use and processing of personal data classified as sensitive may occur when:

  • The data subject has given explicit authorization for such processing, except in cases where the granting of such authorization is not required by law.
  • The processing is necessary to safeguard the vital interest of the data subject and the data subject is physically or legally incapacitated. In these events, legal representatives must grant their authorization.
  • The processing is carried out in the course of the legitimate activities and with the appropriate safeguards by a foundation, NGO, association, or any other non-profit organization whose purpose is political, philosophical, religious, or trade union-related, provided that it refers exclusively to its members or to persons who maintain regular contact by reason of their purpose. In these events, the data may not be supplied to third parties without the authorization of the data subject.
  • The processing relates to data that is necessary for the recognition, exercise, or defense of a right in a judicial process.
  • The processing has a historical, statistical, or scientific purpose. In this event, measures leading to the suppression of the identity of the data subjects must be adopted.
  • 6.5 National and International Transfer and Transmission of Personal Data
  • 6.5.1 National Transfer and Transmission

JAIME ARTEAGA Y ASOCIADOS S.A.S. may circulate personal information with third parties outside the organization located within the national territory, whether these are governmental or other public authorities (including, among others, judicial or administrative authorities, tax authorities, and criminal, civil, administrative, disciplinary, and fiscal investigation bodies), third parties involved in legal proceedings, accountants, auditors, lawyers, and other advisors and representatives whose function is necessary to: a) comply with current laws; b) attend to legal processes; c) respond to requests from public and government authorities; d) receive professional or specialized advice; e) protect the organization’s operations.

JAIME ARTEAGA Y ASOCIADOS S.A.S. will take the necessary measures to ensure that the third-party Data Processors of the organization are aware of and commit to observing this Policy, under the understanding that the personal information they receive may only be used for matters directly related to the corporate purpose of JAIME ARTEAGA Y ASOCIADOS S.A.S. and for the purpose for which it was collected, and may not be used or intended for any other purpose or end.

  • 6.5.2 International Transfer and Transmission

The personal information of any individual whose personal data is processed by JAIME ARTEAGA Y ASOCIADOS S.A.S. will not be transferred internationally for any reason. On the other hand, JAIME ARTEAGA Y ASOCIADOS S.A.S. carries out international data transmission in connection with the delegation to third parties of the information storage service on servers external to the company, which are located outside the country. In such cases, JAIME ARTEAGA Y ASOCIADOS S.A.S. ensures that the country to which the data is transmitted provides adequate levels of data protection, which in no case may be lower than those established in Colombia by Statutory Law 1581 of 2012; and will take the necessary measures to ensure that third parties acting as Data Processors may only use the information provided for the purpose for which it was collected and may not use or intend it for any other purpose or end. Likewise, in the international transmission of data, it will sign an agreement under the terms of Article 25 of Decree 1377 of 2013, or failing that, it will inform the respective data subjects to obtain their consent.

7. RIGHTS OF DATA SUBJECTS

In accordance with the provisions of current and applicable regulations on habeas data or personal data protection, the data subject has the following rights:

  • To know, rectify, and update their personal data before JAIME ARTEAGA Y ASOCIADOS S.A.S., in its capacity as Data Controller.
  • To request proof of the authorization granted to JAIME ARTEAGA Y ASOCIADOS S.A.S., in its capacity as Data Controller.
  • To receive information from JAIME ARTEAGA Y ASOCIADOS S.A.S., upon request, regarding the use that has been made of their personal data.
  • To file complaints with legally constituted authorities, especially with the Superintendence of Industry and Commerce, for violations of the provisions of current and applicable regulations, after having pursued the consultation or request process with the Data Controller.
  • To modify and revoke the authorization and/or request the deletion of their personal data when the processing does not respect the principles, rights, and constitutional and legal guarantees in force.

To know and access their personal data that has been processed free of charge.

8. EXERCISE OF RIGHTS BY DATA SUBJECTS

JAIME ARTEAGA Y ASOCIADOS S.A.S. has an administrative organization that allows it to address requests, inquiries, and claims in general that arise regarding the processing of personal data carried out within the organization. For this purpose, the person or area responsible for carrying out the function of personal data protection and the service channel are designated for data subjects to submit Consultations and Claims:

Area designated to perform the data protection function: Administrative and Welfare Sub-directorate.

Service channel: Written communication to the email address: [email protected].

  • 8.1 Consultations

Data subjects, as well as their duly accredited successors, representatives, and/or attorneys-in-fact, may consult the personal information of the data subject that is held in any database of JAIME ARTEAGA Y ASOCIADOS S.A.S. Consequently, JAIME ARTEAGA Y ASOCIADOS S.A.S. will guarantee the right of consultation and access, providing data subjects with all the information contained in the individual record or that is linked to the identification of the data subject.

Consultations will be addressed within a maximum period of ten (10) business days from the date of receipt. When it is not possible to address the consultation within said period, the interested party will be informed before the expiration of the ten (10) days, stating the reasons for the delay and indicating the date on which their consultation will be addressed, which in no case may exceed five (5) business days following the expiration of the first term.

  • 8.2 Claims

Data subjects, as well as their duly accredited successors, representatives, and/or attorneys-in-fact, who consider that the information contained in a database should be corrected, rectified, updated, or deleted, or when they detect the alleged breach of any of the duties contained in the law, may file a Claim with JAIME ARTEAGA Y ASOCIADOS S.A.S., by submitting it through the area designated to perform the function of personal data protection within the organization.

A Claim may be filed free of charge, upon prior accreditation of the identity of the data subject, successor, representative, or attorney-in-fact.

Claims will be addressed within a maximum period of fifteen (15) business days from the day following their receipt. When it is not possible to address the claim within said period, the interested party will be informed before the expiration of the fifteen (15) days, stating the reasons for the delay and indicating the date on which their consultation will be addressed, which in no case may exceed eight (8) business days following the expiration of the first term.

  • All claims must contain at least the following information, in accordance with Article 15 of Law 1581 of 2012:
  • Identification of the data subject. Documents proving the identity or legal standing of the data subject, successor, representative, or attorney-in-fact.
  • A description of the facts giving rise to the claim, with a clear and precise description of the personal data regarding which the data subject seeks to exercise any of their rights.
  • A notification address or any other means of receiving a response.
  • The documents that the claimant wishes to present as evidence.

If a claim is incomplete, the interested party will be requested to provide the missing information within five (5) business days following its receipt. If two (2) months pass from the date of the request without the applicant submitting the required information, it will be understood that they have withdrawn the claim.

  • 8.3 Data Deletion

Data subjects have the right, at any time, to request the deletion of their personal data. This deletion implies the total or partial elimination of personal information in accordance with the data subject’s request. The deletion of personal data is not an absolute right, and JAIME ARTEAGA Y ASOCIADOS S.A.S., as the Data Controller, may refuse its exercise when:

  1. The data subject has a legal or contractual duty to remain in the database.
  2. The deletion of the data would hinder the exercise of judicial or administrative actions.
  • 8.4 Revocation of Authorization

Data subjects may revoke their consent to the processing of their personal data at any time, provided that a legal or contractual provision does not prevent it.

The revocation of consent can occur in two ways: first, it can be for all the consented purposes, meaning that JAIME ARTEAGA Y ASOCIADOS S.A.S. must completely cease processing the data subject’s data; second, it is the partial revocation of consent, which can occur for specific purposes, such as for advertising or market research purposes, while maintaining other processing purposes in accordance with the authorization granted by the data subject.

  • 8.5 Requirement of Prior Procedure

The filing of complaints for the exercise of rights before the Superintendence of Industry and Commerce will only be admissible once the interested party has exhausted the Consultation or Claim procedure directly with JAIME ARTEAGA Y ASOCIADOS S.A.S. as the Data Controller.

9. PRIVACY NOTICE

The privacy notice is the physical, electronic, or any other known or future format document that is made available to the data subject by JAIME ARTEAGA Y ASOCIADOS S.A.S. for the processing of their personal data. Through this document, the data subject is informed about the existence of the information processing policies that will apply to them, how to access them, and the characteristics of the processing intended for their personal data.

JAIME ARTEAGA Y ASOCIADOS S.A.S. will use privacy notices to address the right of data subjects to be informed, which will be provided in electronic communications and in visible places during any event or meeting where personal data is collected, to inform data subjects about the processing.

10. EFFECTIVENESS AND MODIFICATION OF THE POLICY

This policy is effective as of June 17, 2021, and supersedes any special regulations or manuals that may have been issued previously. In any case, JAIME ARTEAGA Y ASOCIADOS S.A.S. reserves the right to modify it at any time, duly notifying interested parties of its entry into force.

Approved by
Ximena Ortiz Ferro
General Manager
Reviewed by
Andrea Pedraza
Deputy Director of Administration and Wellbeing		Prepared by
External Consultant
Chamber of Commerce Advisory