PRESENTATION
In order to comply with current legislation on data protection, especially Law No. 1581 of 2012 (and other regulations that modify, add, complement or develop it) and Decree No. 1377 of 2013, to Below we inform you of the relevant aspects in relation to the collection, use, transmission and transfer, if applicable, of personal data that SICAM INVERSIONES S.A.S. (hereinafter “SICAM”), legally constituted company, identified with NIT. 900.778.183-3 performs your personal data, by virtue of the applicable law or the authorization granted by you to advance said treatment, as well as the handling of said information.
In this personal data processing policy (the “Policy”) you will find the corporate and legal guidelines under which SICAM processes your data, the purpose, your rights as the owner, as well as the internal and external procedures for the exercise of such rights.
In accordance with the provisions of article 15 of the Political Constitution of Colombia and the applicable legislation (Law 1266 of 2008, Law 1581 of 2012, Decree 1377 of 2013 and all those regulations that regulate, add, repeal or modify), we have a clear privacy policy and protection of your personal data: we do not obtain personal information from third parties that have a commercial or legal relationship with SICAM, including you, as a User of the SICAM online website, unless they have provided it voluntarily through your prior, express and qualified consent.

DEFINITIONS
For the interpretation of this Policy, we ask you to take into account the following definitions:
– Personal data: Any information linked or that can be associated with one or several determined or determinable natural persons.
– Sensitive data: Those data that affect the privacy of the Holder or whose improper use can generate discrimination.
– Data Processor: Natural or legal person, public or private, that by itself or in association with others, performs the Processing of personal data on behalf of SICAM as data controller.
– Treatment Policy or Policy: Refers to this document, as a personal data treatment policy applied by SICAM in accordance with the guidelines of current legislation on the matter.
– 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, for the purposes of this policy, will act as Responsible, in principle, SICAM.
– Owner: Natural person whose personal data is subject to Treatment, whether it is a client or any third party that, due to a commercial or legal relationship, provides personal data to SICAM.
– Transfer: Refers to the sending by SICAM as responsible for the Treatment or a Data Manager, to a third agent or natural/legal person (receiver), inside or outside the national territory for the effective treatment of personal data.
– Transmission: refers to the communication of personal data by the person in charge to the person in charge, located inside or outside the national territory, so that the person in charge, on behalf of the person in charge, processes personal data.
– Treatment: Any operation or set of operations on personal data, such as collection, storage, use, circulation or deletion.

For the understanding of the terms that are not included in the previous list, you must refer to the current legislation, especially Law No. 1581 of 2012 and Decree No. 1377 of 2013, giving the meaning used in said norm to the terms of whose definition where there is any doubt.
Before storing or handling personal data, SICAM declares that it meets the following requirements:
-The Holder must give his explicit authorization to said treatment, except in cases where the granting of said authorization is not required by law.
-In the event that the owner is physically or legally incapacitated, the legal representatives must grant his authorization.
-Inform the owner of the reason why he will use his data and delimiting the limits of said treatment

PURPOSES OF TREATMENT
The purpose of the databases of clients and/or Users of the SICAM online website is to use the data for the proper provision of the service by SICAM, as well as the strengthening of commercial communication channels for the benefit of the holders.
The personal data collected through the SICAM online website of Users will be processed for pre-contractual, contractual, post-contractual, commercial, customer service and marketing purposes, Offers, mailing campaigns, communication of launches and activations and brand campaigns. Specifically, SICAM will process personal data to:
– Carry out the pertinent procedures for the development of the pre-contractual, contractual and post-contractual stage with SICAM INVERSIONES S.A.S. and third parties that contract with him through the online website, regarding any of the products and/or services offered by SICAM INVERSIONES S.A.S. that it has or has not acquired or, with respect to any business or commercial relationship that it has with SICAM INVERSIONES S.A.S., as well as complying with Colombian or foreign law and the orders of judicial or administrative authorities.
– Manage procedures (requests, complaints, claims), carry out risk analysis, carry out satisfaction surveys regarding the services offered SICAM INVERSIONES S.A.S.
– Provide contact information and relevant documents to the commercial force and/or distribution network, telemarketing, market research and any third party with which SICAM INVERSIONES S.A.S. has a contractual relationship of any kind
– Disclose, transfer and/or transmit my personal data inside and outside the country, to any company or to third parties as a result of a contract, law or lawful link that requires it, or to implement cloud computing services.
– Create databases for the purposes described in this authorization.

DUTIES OF THE RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA
Under the understanding that SICAM acts as responsible for the processing of personal data, in accordance with the definitions of Law No. 1581 of 2012, it undertakes to:
a) Guarantee the Holder, at all times, the full and effective exercise of the right of habeas data;
b) Request and keep, the copy of the respective authorization granted by the Holder in accordance with the provisions of Law 1581/2012;
c) Duly inform the Holder about the purpose of the collection and the rights that assist him by virtue of the authorization granted to SICAM.
d) Keep the information under the necessary security conditions to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access;
e) Guarantee that the information provided to the Treatment Manager, in the cases in which it applies, is true, complete, exact, updated, verifiable and understandable;
f) Update the information, communicating in a timely manner to the Treatment Manager, all the news regarding the data that has previously been provided and adopt the other necessary measures so that the information provided to it is kept updated in the cases in which it applies. ;
g) Rectify the information when it is incorrect and communicate what is pertinent to the Treatment Manager in the cases in which it applies;
h) Provide the Treatment Manager, as the case may be, only data whose Treatment is previously authorized in accordance with the provisions of Law 1581/2012;
i) Demand from the Treatment Manager at all times, respect for the security and privacy conditions of the Holder’s information, in the cases in which it applies;
j) Process the queries and claims formulated in the terms indicated by Law 1581/2012;
k) Adopt an internal manual of policies and procedures to guarantee adequate compliance with the Colombian regulatory framework on personal data protection, for the attention of queries and claims;
l) Inform the Treatment Manager, if applicable, when certain information is under discussion by the Owner, once the claim has been filed and the respective procedure has not been completed;
m) Inform at the request of the Owner about the use given to their data;
n) Inform the data protection authority when there are violations of the security codes and there are risks in the administration of the information of the Holders.
o) Comply with the instructions and requirements issued by the Superintendence of Industry and Commerce.

RIGHTS OF HOLDERS

The rights of the owners of the information are:
Know, update and rectify your personal data in front of those responsible for the Treatment or Treatment Managers. This right may be exercised, among others, against partial, inaccurate, incomplete, fractioned, misleading data, or those whose Treatment is expressly prohibited or has not been authorized under the terms of Law No. 1581 of 2012 (or in its defect with the norms that regulate, add, execute, complement, modify, delete or repeal it).
Request proof of the authorization granted to the person responsible for Treatment except when expressly excepted as a requirement for Treatment, in accordance with the provisions of article 10 of Law No. 1581 of 2012 (or failing that with the regulations that regulate it, add, execute, complement, modify, delete or repeal) or when the continuity of the treatment has been presented in accordance with article 10 numeral 4 of Decree No. 1377 of 2013.
Be informed by the person in charge of the Treatment or the Treatment Manager, upon request, regarding the use that has been given to your personal data.
Submit to the Personal Data Protection Authority of Colombia complaints for violations of the provisions of Law No. 1581 of 2012 (or failing that, with the regulations that regulate, add, execute, complement, modify, delete or repeal it).
Revoke the authorization and/or request the deletion of the data when the Treatment does not respect the constitutional and legal principles, rights and guarantees. The revocation and/or deletion will proceed when the Personal Data Protection Authority of Colombia has determined that in the Treatment the person in charge or in charge has incurred in conduct contrary to Law No. 1581 of 2012 (or failing that with the regulations that the regulate, add, execute, complement, modify, suppress or repeal) and/or the Constitution. The request to delete the information and the revocation of the authorization will not proceed when the Owner has a legal or contractual duty to remain in the database or the person in charge has a legal or contractual duty to continue with the treatment.
Free access to your personal data that has been subject of Treatment . The holder can consult his personal data free of charge: (i) at least once each calendar month, and (ii) whenever there are substantial modifications to the information treatment guidelines that motivate him to make new consultations.

COMMUNICATION CHANNELS FOR THE EXERCISE OF RIGHTS / QUESTIONS, COMPLAINTS AND CLAIMS
In case you have questions, concerns or complaints regarding the administration of the Privacy Policy by SICAM, please contact us through any of the following means: asistente@sicaminversiones.com
Calle 50 # 39 – 144 Copacabana, Antioquia – Colombia
In the case of a complaint, rectification, update, consultation, or request for access or data theft, you must send it to: asistente@sicaminversiones.com
Keep in mind that once you inform the responsible area within the Company, depending on which of them your request is directed to, the query, request or complaint will be processed.
Your request or request in relation to your personal data must be addressed within a maximum term of five (5) business days from the receipt of the request or the request itself. For the correct and complete consideration of your petition, request or claim, we ask you to provide the identity of the requester, his identification number, the address for notifications/responses and the documents he wishes to assert.

MODIFICATION OF THIS POLICY
This policy may be modified at any time, which is why we recommend you review it regularly or periodically on our website, through the intranet from which the latest version of this Policy or the mechanisms to obtain a copy will be made available to you.