DATA TREATMENT AND PROTECTION POLICY

The Treatment Policy issued by the company KOALIMENTOS S.A.S., is governed under the guidelines and directives established in the Personal Data Protection Regime, ensuring proper control and management of personal information in our care and in harmony with the principles and regulations governing the matter; specifically, as provided in Articles 15 and 20 of the National Constitution, Law 1266 of 2008, Law 1581 of 2012, Chapter 25 of Decree 1074 of 2015, the sentence C-748 of 2011 and Circular 002 of 2015 of the Superintendence of Industry and Commerce.

CHAPTER I

GENERAL PROVISIONS 

1.1. IDENTIFICATION OF THE PERSON RESPONSIBLE FOR AND/OR IN CHARGE OF THE TREATMENT

To guarantee the exercise of the rights of the holders of the information, KOALIMENTOS S.A.S., in quality of Responsible and/or Responsible for the treatment of Personal Data, proceeds to extract the identification data and information channels for reception of consultations and claims:

1.2. POLICY OBJECTIVE

The purpose of this Policy is to publicize the guidelines and directives that frame the treatment of personal data implemented by the person in charge and/or responsible, guaranteeing the due control of the databases, physical and digital files under KOALIMENTOS S.A.S. safekeeping.

In consideration of the above, the Policy of Treatment of Personal Data extracts the mechanisms established to exercise the right to Habeas Data by the owners of the information, as well as the security measures implemented in pursuit of their protection.

1.3. POLICY BENEFICIARIES

The Personal Data Treatment Policy is addressed to the following owners:

End users: defined as those stakeholders (suppliers and customers) who have business relationship with KOALIMENTOS S.A.S. in the exercise of its corporate purpose or any associated lawful activity.

People linked by work contract with KOALIMENTOS S.A.S. and, in general, any holder of information, either acting in his own name or as legal representative, that due to the activities he is linked with KOALIMENTOS S.A.S., his personal information is required for the development of the same.

CHAPTER II

TREATMENT OF PERSONAL DATA EXERCISED BY KOALIMENTOS S.A.S.

2.1. DATABASES SUBJECT TO PROCESSING

The data bases that are object of collection and treatment by KOALIMENTOS S.A.S. are classified and defined as follows:

2.2. TREATMENT OF PERSONAL DATA

The personal data object of treatment by KOALIMENTOS S.A.S., in its capacity as responsible and/or in charge, are subject to a process of collection, storage, use, circulation and suppression, in the terms that are warned below:

2.2.1 COLLECTION OF PERSONAL DATA

KOALIMENTOS S.A.S. collects personal information through different activities related to its corporate purpose and obligations as an employer.

Depending on its corporate purpose, the information collected may originate from the supply of information by stakeholders (suppliers and customers) in order to establish the activities necessary for the execution of its functions. Interested parties may consult additional information directly with the owners or end users, in compliance with the requirements established in the applicable regulations on personal data protection.

2.2.2. STORAGE OF PERSONAL DATA

The storage of the personal information contained in the data bases compiled by KOALIMENTOS S.A.S. or delivered by order by groups of interest, is located in the internal servers and has all the physical, technical and administrative security measures, and has access controls to the information, guaranteeing the principle of access and restricted circulation.

2.2.3. USE OF PERSONAL DATA

The use and purpose of the information collected and stored in the databases, has different objectives, among them, are:

• To comply with the obligations agreed with stakeholders for the effective marketing of its products, and as a result of the commissioning of information provided or data collected directly as a participant in the market of products of its corporate purpose.
• Management and accounting analysis of financial information that allows generating risk profiles for the opening of quotas and credits to customers.
• Management of internal statistics, reports and reports in compliance with the goals and commercial objectives for KOALIMENTOS S.A.S.
• Administrative procedures, information systems administration, password management, user administration, operational development.
• Invoicing management, accounting management, management of suppliers and contractors, economic and accounting management, history of commercial relations, requirements by control agencies.
• Schedule control, personnel training, personnel management, temporary work management, social benefits, occupational risk prevention, promotion and selection of personnel.
• Accounting, fiscal and administrative management: requirements by control bodies, private and sensitive data, attention and follow-up of judicial or administrative authority requirements.
• Management of basic administrative tasks and respond to specific requests from end users and other commercial purposes directly or indirectly related to the activity itself KOALIMENTOS S.A.S.

2.2.4. MOVEMENT OF PERSONAL DATA

As a general rule, KOALIMENTOS S.A.S. does not share the personal data it collects with third parties. However, for the effective fulfillment of the obligations agreed with customers receiving the input offered by KOALIMENTOS S.A.S., the company can deliver the personal data collected through orders, to its external suppliers or strategic allies that are hired for this specific purpose, covered by paragraph e) of Article 26 of Law 1581 of 2016 which states that the transfer of personal data is permitted when it is necessary for the execution of a contract between the owner and the controller, or for the execution of pre-contractual measures as long as it has the authorization of the owner.

2.2.5. REMOVAL OF PERSONAL DATA

The personal information requested for compliance with legal, contractual, tax, auditing purposes, among other related aspects, will remain stored in accordance with the maximum times established in the Colombian legislation for its retention.

The suppression of the personal information collected in data bases will be made once the purpose of its collection has been fulfilled, according to the authorizations, contracts and/or agreements that the holder of the information has previously agreed with KOALIMENTOS S.A.S. or with the corporate clients that act as responsible for the information; nevertheless, some information may be kept for auditing purposes.

2.3. AUTHORIZATION FOR THE TREATMENT OF PERSONAL DATA

In relation to the personal data bases treated as responsible, KOALIMENTOS S.A.S. requests in a free, prior, express and duly informed manner, the authorization by the owners of the data and for this purpose has provided suitable mechanisms and communication channels ensuring for each case that it is possible to verify the granting of such authorization. This authorization may be recorded in any medium, whether a physical or electronic document or in any format that guarantees its subsequent consultation through technical tools, complying with the requirements established by law.

2.4. PERSONAL DATA PROTECTION MEASURES

KOALIMENTOS S.A.S. has adopted technical, legal, human and administrative measures necessary to ensure the security of personal data protecting the confidentiality, integrity, use, unauthorized access and / or fraudulent. Also, internally KOALIMENTOS S.A.S. has implemented security protocols of mandatory compliance for all staff with access to personal data and information systems.

The internal security policies under which the holder's information is kept to prevent adulteration, loss, consultation, use or unauthorized or fraudulent access, are as follows:

Personal Data Treatment Policies

• Restricted access by magnetic media and personalized password to physical and digital files.
• Information restriction.
• Information security controls and restrictions for validation of output data.
• Controls for the final disposition of information.
• Restriction of users for access to personal information.
• Procedures for assigning responsibilities and authorizations in the treatment of personal information.
• Confidentiality agreements for all staff and outsiders who have access to personal information
• Controls on the monitoring of database access queries.

2.5 OBLIGATIONS OF PERSONAL DATA PROCESSORS

The companies and/or persons external to KOALIMENTOS S.A.S., that by virtue of a commercial relationship, process personal data on behalf of KOALIMENTOS S.A.S., shall comply with the following obligations:

• Guarantee the holder access, consultation, updating, rectification of their personal data.
• Keep the information under security conditions that prevent adulteration, loss, consultation, use or unauthorized or fraudulent access.
• Adopt an internal manual of policies and procedures to ensure compliance with Law 1581 of 2012, regarding the protection of personal data.
• Allow access to information only to persons who may have access to it.
• Comply with the obligations established in Article 18 of Law 1581 of 2012, and its respective regulatory decrees, regarding the protection of personal data.

2.6. OBLIGATIONS OF KOALIMENTOS S.A.S. - AS INFORMATION OFFICER

Regarding the information provided to KOALIMENTOS S.A.S. by the groups of interest by virtue of a commercial or work relationship, the responsible of the information shall request and keep the authorization of the holder of the information for the treatment of the personal data by KOALIMENTOS S.A.S., so it is presumed that the responsible of the information has the previous and express authorizations of the holders with whom it has contact, to make use of their personal data and will provide copy of such authorizations in case KOALIMENTOS S.A.S. requires it, for the purposes enshrined in the policy of treatment of personal data.

2.7. COOKIES MANAGEMENT

KOALIMENTOS SAS websites use cookies to record the above mentioned data. You can delete, reject or prevent the use of such cookies by deleting the existing ones or by configuring your browser and disabling JavaScript codes in the security settings of your browser.

Any person in their capacity as owner or legitimately authorized, in relation to the processing of their personal data has the right to:

1. Exercise their right of habeas data consisting of knowing, updating, rectifying, opposing and canceling the information collected about them, in those cases in which it is appropriate.
2. Evidencing the existence of the consent given.
3. Exercise the actions that the law recognizes in terms of personal data protection and habeas data.

For the exercise of habeas data, the holder of the personal data or whoever demonstrates a legitimate interest as indicated in the current regulations, may do so by contacting KOALIMENTOS SAS through email koalimentos@gmail.com, by going to the web address http://www.Koalimentos.co/habeas-data, or by sending a communication to Calle 16 # 59 31 Medellin, Antioquia Colombia. The person exercising the habeas data must accurately provide the requested contact information in order to process and attend his request and deploy the charges for the exercise of his rights.

Once KOALIMENTOS SAS receives the request, will respond within the legal term of fifteen (15) working days, which may be extended for eight (8) additional days, prior communication to the person who has exercised this right.

The treatment of personal data made by KOALIMENTOS SAS according to this policy, will be based on the rules, procedures and instructions adopted by the company to comply with the legislation applicable to the protection of personal information.

CHAPTER III

RIGHTS OF OWNERS AND/OR STAKEHOLDERS

3.1. INQUIRIES AND COMPLAINTS

The holders and / or stakeholders of information may request KOALIMENTOS S.A.S. access to their personal information contained in the databases and have the consultation channels defined in this policy for the purpose of raising queries and claims regarding their personal data. The requests and claims to submit must contain the minimum requirements established in Law 1755 of 2.015 regarding identification, and will be subject to response in the terms provided in the aforementioned legal regulation.

3.2. RIGHTS OF THE OWNERS

In reason to the established legal protection, the holders of the information will be able to exercise before KOALIMENTOS S.A.S. the rights that are discriminated::

• To know, update and rectify personal data. In order to guarantee this right, the identity of the holder or the quality of legitimate, in order to prevent unauthorized third parties from accessing personal information must be accredited.
• Obtain a copy of the authorization granted by them as data owners.
• To know the treatment that is being carried out on the personal data by KOALIMENTOS S.A.S.
• Formulate queries and claims to safeguard their right to the protection of personal data in accordance with the guidelines established by law and in the terms of this policy.
• Request the deletion of personal data or revoke the authorization granted when through a judicial or administrative process it is determined that the processing of your information violated the legal and constitutional provisions on the matter.
• Access free of charge to their personal data at least once every calendar month, and every time there are substantial changes in this Policy that motivate new consultations. The information requested by the holder may be provided by any means that allows him/her to know it, including electronic means.

3.3. RESTRICTIONS ON THE HOLDER'S RIGHTS

The revocation of the authorization and/or request of suppression of personal data will not be applicable when the holder has a legal or contractual obligation that requires its permanence in the data bases of KOALIMENTOS S.A.S.

3.4. ATTENTION CHANNELS FOR THE EXERCISE OF THE HOLDER'S RIGHTS

For the exercise of the rights on the part of the holders of the information and in the referring thing to consultation, update, rectification and suppression, KOALIMENTOS S.A.S. has enabled to disposition of the holders of information the following channels of attention:

CHAPTER IV

FINAL PROVISIONS

4.1 PERMANENT MEASURES

In the treatment of personal data, KOALIMENTOS S.A.S. will permanently verify in its processes, protocols, procedures and policies, that the right of habeas data to the holders of the information is guaranteed and that the authorization of the holder for the treatment of personal data is obtained with the requirements of law.

4.2 BINDING NATURE OF THE POLICY

Any holder of the information that has any relationship with KOALIMENTOS S.A.S., must abide by this policy. The holders of the information, other than end users, must comply with the internal manual of procedures and policies relating to the protection of personal data, depending on each specific case.

4.3 COMPLIANCE WITH THE PRINCIPLES FOR THE PROCESSING OF PERSONAL DATA

KOALIMENTOS S.A.S. guarantees the principles of legality, purpose, freedom, truthfulness or quality, transparency, restricted access and circulation, security and confidentiality of the data contained in its databases.

4.4. VALIDITY

This Personal Data Processing Policy is effective as of January first (01), two thousand twenty-three (2,024).

Signature

JUAN CAMILO DIAZ RIVERA 

C.C. 1.017.183.830 

Legal Representative
KOALIMENTOS S.A.S.