PERSONAL DATA PROCESSING POLICY PRESERVA COLOMBIA S. A.S.

PRESERVA COLOMBIA S.A.S. (hereinafter PRESERVA), a company that serves as a means for any organization, company or person to be linked to environmental conservation projects, whose objective is to guarantee the recovery, enrichment, protection and sustainable use of areas that, from a diagnosis of its current and potential condition, and an understanding of its vocation, achieves a positive impact for the area, its inhabitants and the region; In carrying out its commercial activity, it collects, stores and uses personal information of its clients, employees, suppliers, and natural persons who could have a contractual or legal relationship with the company.

PRESERVA is aware of the implications of the Processing of Personal Data, which is why it carries out said activity in accordance with the principles and guidelines contained in the Statute for the Protection of Personal Data – Law 1581 of 2012, the Decrees that regulate it and the Guide for implementation of the principle of demonstrated responsibility of the Superintendence of Industry and Commerce.

With a view to protecting and ensuring the holders of personal data proper processing of their information, PRESERVA issues this Personal Data Processing Policy in compliance with the relevant regulations and the principles of legality, purpose, freedom, veracity or quality, access and restricted circulation, security and confidentiality covered by Statutory Law 1581 of 2012.

I. OBJECT

PRESERVA’s Personal Data Processing policy seeks to guarantee the right to Habeas Data of natural persons who provided their personal data to society for due processing (use, collection, deletion, storage and circulation) in accordance with the purpose informed in the authorization given.

II. IDENTIFICATION OF THE RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA

PRESERVA, as responsible for the processing of personal data, is a company established by private document dated January 22, 2020, document registered in the Chamber of Commerce of Bogotá on February 11, 2020, under number 02551982 of Book IX, company identified with Nit. 901.365.444-1 and Commercial Registration 03217969 of February 11, 2020.

PRESERVA has designated within its structure a Personal Data Protection Officer according to the provisions of the Guide for the Implementation of the principle of Demonstrated Responsibility of the Superintendence of Industry and Commerce. The Personal Data Protection Officer assumes the function of protecting personal data within the company, in compliance with the regulations that govern the matter, as well as the policies established for this purpose within PRESERVA.

III. SCOPE OF THE INFORMATION PROCESSING POLICY

According to Law 1581 of 2012, holders of personal data are understood to be the “Natural Person whose personal data is the subject of Processing”, therefore PRESERVA’s policy focuses on personal data coming from natural persons.

The coverage of these policies covers all PRESERVA employees, clients, suppliers, as well as potential clients with whom the company maintains communication.

Within the company there is NO processing (collection, storage, use, circulation or deletion) of sensitive data (understanding sensitive data as those that affect the privacy of the Owner or whose improper use may generate discrimination such as: racial or ethnic origin, the political orientation, religious convictions, among others) of the owners of the personal data.

IV. PERSONAL DATA SUBJECT TO PROCESSING AND PURPOSE OF THE DATA
PRESERVA processes the personal data indicated below according to the database and according to the purposes indicated in the following table:
PERSONAL DATAPURPOSE
CUSTOMERS OR DONORSNames, surnames, identification number, company name, economic activity, address, telephone number, city, department, email, website, position, ID.Send information, promote activities, carry out satisfaction surveys, contact to offer products and services.
SUPPLIERS Names, surnames, identification number, date and place of issue, signature, NIT, company name, economic activity, address, telephone, superintendency code, city, legal representative, bank certification, department, email, website, position , bank account number, ID. Contacts of natural persons who collaborate with operational logistics processes at the national level. Account for purchase invoices, contacts for logistics operations nationwide, for payment and contracting information.
WORKERS Name, ID, address, telephone, cell phone number, date and place of issuance of CC, date of birth, age, marital status, photo, sex, blood type, educational level, EPS, AFP, severance fund, medical examinations income, periodicals and retirement, salaries, polygraph reports and home visits. Email resumes. Promotion of business events, hiring, payroll payments, social security, etc.
V. RIGHTS OF PERSONAL DATA HOLDERS

PRESERVA informs the owners of personal data processing that the rights they can exercise in accordance with Law 1581 of 2012 are the following:

  1. Know, update and rectify your personal data in front of the Data Controllers or Data Processors. This right may be exercised against partial, inaccurate, incomplete, fragmented, misleading data, or those whose Processing is expressly prohibited or has not been authorized.
  2. Request proof of the authorization granted to the Data Controller except when it is expressly excepted as a requirement for the Treatment, in accordance with the provisions of article 10 of Law 1581 of 2012.
  3. Be informed by the Data Controller or the Data Processor, upon request, regarding the use given to the Owner’s personal data.
  4. Submit complaints to the Superintendency of Industry and Commerce for violations of the provisions of this law and other regulations that modify, add or complement it.
  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. The revocation and/or deletion will proceed when the Superintendency of Industry and Commerce has determined that in the Treatment the Controller or Processor has engaged in conduct contrary to this law and the Constitution.
  6. Free access to your personal data that has been processed.
VI. AREA RESPONSIBLE FOR ATTENTION TO QUERIES AND COMPLAINTS

At PRESERVA, the area responsible for handling requests, queries and complaints will be the Data Protection Officer through the following channels of attention to the owner of the personal data:

  1. TELEPHONE ATTENTION:

Telephone attention to the owner of the data for queries or complaints will be at number (+57) 311 8988913 between 9 a.m. and 9 a.m. to 5 p.m. (Continuous schedule). The call will be answered by the area in charge, who will forward it to the Personal Data Protection Officer designated within the company.

  1. ATTENTION VIA WEBSITE

Service through the website will be attended to through the following address info@preserva.bio according to the parameters established in the following chapter.

VII. CONSULTATION PROCEDURE

The owners of personal data or their successors in title may request consultation of their personal data through the channels described in the previous chapter.

Queries by email must contain at least: i) the complete identification of the owner, ii) the personal data that they want to be consulted, ii) address, iii) email, and; iv) if they are successors in title, attach the respective document that proves it. The query will be answered by PRESERVA, within a maximum period of ten (10) business days from the date of receipt of the email or physical document. When it is not possible to attend to the query within said PRESERVA term. It will inform the interested party, expressing the reasons for the delay and will indicate the date on which their request will be attended to within a maximum of 5 business days following the expiration of the first term.

When the query is not clear, is not understood, or does not meet the necessary requirements to develop a response from PRESERVA, will inform the owner or successor in title so that he or she can submit the query again no later than within five (5) business days following the request by the company. After two (2) months from the date of the request, without the applicant presenting the required information, PRESERVA will understand that the owner or successor in title has withdrawn from the consultation.

In the event that the person who receives the claim is not competent to resolve it, he or she will forward it to the appropriate party within a maximum of 2 business days and will inform the interested party of the situation.

Thus, then the maximum period to respond to the query will be 15 business days, as long as within 10 business days following receipt of the query by any means provided for this purpose, the owner is informed of the reason for the delay, Otherwise, the maximum term will be 10 business days.

VIII. CLAIM PROCEDURE

When the owner or successor in title considers that the information contained in our database should be subject to correction, authorization, deletion or revocation of authorization, they may submit a claim to the service channels provided for this purpose in the previous chapter.

This claim must contain at least: i) the complete identification of the owner, ii) description of the facts that give rise to the claim, iii) home address, iv) email, and; v) accompanying documents that the owner or assignee wants to assert.

If the claim is incomplete, PRESERVA will require the interested party to correct the deficiencies within five (5) business days following receipt of the claim. After two (2) months from the date of the request, without the applicant presenting the required information, PRESERVA will understand that the owner or successor in title has withdrawn from the claim.

PRESERVA will respond to the claim within a maximum period of fifteen (15) business days 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 within 8 business days following the expiration of the first term.

OWNERS OF PERSONAL DATA ARE INFORMED THAT THE DELETION OR REVOCATION OF DATA PROCESSING AUTHORIZATION WILL NOT APPLY WHEN THE OWNER HAS A LEGAL OR CONTRACTUAL DUTY TO REMAIN IN THE PRESERVA DATABASE.

IX. TEMPORARY LIMITATIONS ON THE PROCESSING OF PERSONAL DATA

In accordance with Decree 1377 of 2013, PRESERVA may only collect, store, use or circulate a person’s personal data for as long as is reasonable and necessary, in accordance with the purposes that justified the treatment, in accordance with the applicable provisions. to the matter in question and to the administrative, accounting, fiscal, legal and historical aspects of the information. Once the purpose(s) of the Treatment have been fulfilled and without prejudice to legal regulations that provide otherwise, PRESERVA must proceed to delete the personal data in its possession.

As an exception to the above, PRESERVA may retain personal data when required to comply with a legal or contractual obligation.

X. VALIDITY OF THE INFORMATION PROCESSING POLICY

This treatment policy developed by the PRESERVA company begins its validity from March 1, 2020.