Privacy Policy

ACT 1581 OF 2012 AND REGULATORY DECREE 1377 OF 2013

NAME: DECODING S.A.S.

COMPANY ID (TIN): 900528092-1

ADDRESS: CALLE 65 #55-30 INTERIOR 1418, MEDELLÍN, COLOMBIA

EMAIL ADDRESS: This email address is being protected from spambots. You need JavaScript enabled to view it.

WEB SITE: www.decoding.com.co

TELEPHONE NUMBER: +57 350 202 9777

In accordance with Act 1581 of October 17th of 2012, in which the general data protection dispositions are rendered, DECODING S.A.S., as the information keeper and solely responsible, creates the following policy treatment manual in order to make an appropriate use of the personal data obtained from clients, suppliers, employees and people affiliated to the company in a commercial or occupational manner:

1. All people who have been freely asked for their personal information through emails, phone calls or direct personal contact have a constitutional right to know, update, verify and suppress their data and other constitutional rights, freedoms and guarantees that Article 15 of the Political Constitution renders. In addition, they will be able to:

• Request proof of the authorization granted to the person responsible for the treatment of data except in the case of this not being solicited as a treatment requirement, in compliance with Article 10 of Act 1581 of 2012.

• Be informed by the person responsible for the treatment of data upon request about the usage given to their personal data.

• Submit before the Industry and Commerce Superintendence any claim related to an infringement on Act 1581 of 2012 and any other rule that can modify, complete and/or complement the aforementioned act.

• Revoke the authorization and/or solicit the deletion of the data when the treatment does not respect the constitutional and legal principles, rights and guarantees. The revocation and/or suppression will proceed when the Industry and Commerce Superintendence had determined that the responsible for the treatment of the data has incurred in conducts contrary to Act 1581 of 2012 and the Political Constitution.

• Access their personal data free of charge when these have been subject to treatment.

2. Under the rules of law, purpose, freedom, truthfulness, security, confidentiality, transparency and every other ruling principle established under Act 1581 of 2012 and its regulatory decree 1377 of 2013, DECODING S.A.S. protects each one of the personal data acquired.

3. The entire personal information will be distributed and managed by DECODING S.A.S. as responsible upon authorization from the people who have provided this information through any mean.

4. The requested information has the following means and purposes of legal use:

• To fulfill contracted obligations with clients.

• To inform about changes and evaluate the quality of our products or services.

• To inform about our new products or services whether related or not to the agreement acquired by you.

• To send commercial or promotional advertising about our products and/or services, events and or commercial sales or not, with the sole purpose of launching, inviting, approaching, executing or informing in a general manner. Also to conduct contests or campaigns for commercial or advertising purposes.

These activities will be performed via physical mail, electronic mail, text messages or any other analog or digital means of communication known and yet to be known.

5. The collected data will be treated in accordance with its legal, contracted or not contracted purpose that led to the initial collection.

6. All people to whom this information has been requested from are in their right to revoke authorization and/or request suppression of their data while in treatment if principles, rights and/or constitutional guarantees are not being respected or when the reason to be treated is considered to have expired.

This suppression could be partial or complete, according to the request made by the data owner. Nonetheless, this will not apply when the order of suppression or revoke interferes with the owner’s previous contracted legal duties with the company.

Furthermore, in compliance with Article 15th of the 1581/2012, the titleholder or successors in title who consider that retained database information should be corrected, updated, suppressed, revoked, or that the contracted duties in Act 1581 of 2012 are not being fulfilled, are in their right to issue a claim before the treatment responsible or manager. This document will be processed under the following regulations to the established mail in the previous article.

1. The claim will be placed through a request addressed to the treatment responsible or manager files in the previously mentioned mail with the titleholders ID, facts of the claim, description, address and documents needed to attach. If the claim is not done to completion, the interested party will be solicited upon the next five days following the claim submission to amend the faults. If this process is not complete with the requested information after two months, it will be seen by the recipient as an abandoned claim and it will be deleted.

In the event that the person receiving the claim is not competent enough to solve it, it will be forwarded to the right person within a two-working-day period and this situation will be properly informed to the interested party.

2. Upon receipt of the complete claim, a caption that reads “claim in progress” shall be included in the database along with the reason for it within a two-working-day period. This caption should be kept until the claim is settled.

3. No later than 15-working-days following receipt of the claim, it shall be settled. When this is not possible, the interested party shall be informed of the reasons for the delay and the date in which his/her claim will be settled, which in no case shall exceed 8 working days following the expiration of the first deadline.

7. A person can freely access the personal data she/he supplied, which have been used by our company, by calling at the phone number indicated in item 9.

8. Personal data freely supplied by a person will be used by our Communications and Human Resources areas. It could also be shared with other areas if necessary. In the case of mass mailings, this information will be provided to an outsourcing service company assigned by the company.

9. People willing to know about how their information is treated within our company can call us at the following phone number: 422 36 72 in the city of Medellín (Antioquia), contact the Communications or Human Resources areas, and they will be informed about the procedures that must be followed to address their requests.

10. For the purposes mentioned above, we collect your information as follows:

• Through our contact forms.

• Via telephone calls.

• When supplied in person or in any other way in our headquarters.

11. The access to this website may imply the use of cookies. Cookies are small pieces of information sent to your browser and stored on your computer’s hard drive. This information allows the website to identify you as a specific user and store your personal preferences, as well as technical information, such as some of the searches you perform. Users who are not interested in receiving cookies or want to be notified before they are stored on their computer can set their browser to do so.

• Most of current browsers allow users to set cookies in three different ways:

• Never allow cookies to be saved on the computer.

• Ask whether or not allow a cookie to be saved on the computer.

• Always allow cookies to be saved on the computer.

• The browser may also include the option to define the kind of cookies that can be accepted and the ones that cannot. Specifically, the user can select one of the following options: Reject cookies from certain domains, reject third-party cookies, allow session cookies (cookies that are deleted from the computer when the browser is closed), and allow the server to create cookies for a different domain. Moreover, browsers can also allow users to see and delete cookies individually.

• For more information about cookies, visit: https://en.wikipedia.org/wiki/HTTP_cookie.

12. In some cases, we share information with third parties (advertisers, sponsors, auditors) about our visitors, in an anonymous way and with the only purpose of improving our services. All these data processing tasks will be regulated according to legal standards and data protection rights will be respected in compliance with current regulations.

• This website measures traffic with different solutions that may use cookies or web beacons to analyze what happens in our pages. We currently use the following solutions for traffic measurement of this site. You can read more about the privacy policy of each solution used: Google (Analytics)

• Google Analytics features are used to show ads of the display network (Remarketing) in third-party websites.

• We use collected information to optimize and show ads based on the previous visits to the website.

13. DECODING S.A.S. is located at CARRERA 46 #63A-12 INTERIOR 702, MEDELLÍN, COLOMBIA.