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POLICY FOR THE TREATMENT OF PERSONAL INFORMATION

In compliance with Article 15 of the Colombian Constitution, Law 1581/2012, Regulatory Decree 1377/2013 and other regulations to amend, supplement compliment or develop them, CONFECCIONES E INVERSIONES PEPA S.A., committed to the respect and guarantee of the rights of its customers, suppliers, employees and third parties in general, publishes the policies and procedures for the Treatment of Personal Data stored or held in custody in our database, as is mandatory in all activities which entirely or partly involve the collection, storage, use, circulation and/or transfer of that information This Policy for the Treatment of Personal Data is mandatory for CONFECCIONES E INVERSIONES PEPA S.A., as responsible party, and for all its allied and affiliate companies, and those that form part of its business group.

THE LEGAL CONTEXT

This Policy for the Treatment of Personal Data is based on Article 15 of the Colombian Constitution, Law 1581/2012, Regulatory Decree 1377/2013, as follows:

  • Constitution Article 15 “All persons are entitled to their personal and family intimacy and good name, and the State must respect them and have them respected. Likewise, all are entitled to know, update and rectify information collected on them in databanks and in the files of public and private entities.
    The collection, treatment and circulation of data will respect freedom and other guarantees enshrined in the Constitution
    Correspondence and other forms of private communication are inviolable. They may only be intercepted or searched under court order, in the cases and with the formalities established
    For tax or judicial purposes, and for cases of inspection, oversight and intervention by the State, the presentation of books of account of other private documents may be required in the terms indicated in the law”
  • Statute Law 1581/2012 “with general provisions for the protection of personal data”
  • Regulatory Decree 1377/2013, “Regulating law 1581/2012″

GENERAL INFORMATION ON CONFECCIONES E INVERSIONES PEPA S.A. AS MANAGER OF THE TREATMENT OF PERSONAL DATA

Name: CONFECCIONES E INVERSIONES PEPA S.A.

Taxpayer No. NIT 860.500.012-4

Registered offices: Bogota DC

Phone: 236 5958-610 3574

webpage: www.pepapombo.com

OBJECT OF THE POLICY FOR THE TREATMENT OF PERSONAL DATA

The Policy for the Treatment of Personal Data is intended to publicise and make known to the public in general the corporate guidelines and the provisions of law under which CONFECCIONES E INVERSIONES PEPA S.A. effects the treatment of personal data, the purpose of treatment, the rights of Owners of those data, and internal and external procedures existing for the exercise of those rights with CONFECCIONES E INVERSIONES PEPA S.A., amongst other things

LEGAL DEFINITIONS

For the purposes of the execution of this Policy and in accordance with provisions of law, the following definitions apply

Authorization: Prior, express and informed consent of the Owner to effect Treatment of personal data.

Database. An organized set of personal data which may be the object of Treatment.

Owner: An individual whose personal data are the object of Treatment, whether as customer, supplier, employee or any third party, by reason of a business or legal relationship, supplying

personal data to CONFECCIONES E INVERSIONES PEPA S.A.

Treatment. Any operation or set of operations on personal data, such as the collection, storage, use, circulation or suppression of data.

Personal data. Any item of information linked to or that can be associated with one or more determinate or indeterminate individuals.

Public data. Data which are not semi-private private or sensitive. Public data are held to include amongst other things information related to marital status, profession or occupation, and status of private businessperson or public servant. By their nature, public data can be contained, amongst other places, in public records, public documents, official gazettes and bulletins, and enforceable court decisions not subject to confidentiality.

Sensitive data. Sensitive data are those that affect the intimacy of the Owner, or whose improper use may generate discrimination, such as those that reveal the racial or ethnic origin, political orientation, religious or philosophical conviction, membership of labour unions, social organisations and human rights organizations, or that promote the interests of some political

party or guarantee the rights and guarantees of opposition political parties, and those related to health, sexual life, and biometric data.

Transfer. The transfer of data takes place when the Responsible Party or the Manager of the Treatment of personal data located in Colombia sends information or personal data to a receiver who is in turn a Responsible Party or Manager for the Treatment, and is located within Colombia or elsewhere.

Transmission. Treatment of personal data that implies communication of the same within the territory of the Republic of Colombia or elsewhere, where the purpose of doing so is to effect

Treatment by the Data Manager, for account of the Responsible Party.

When a term used is defined in this Policy for the Treatment of Personal Data, that definition will apply. Likewise, where a term used is not expressly defined in this Policy or in applicable law, the literal sense of the stipulation will be taken, provided that such an interpretation is consistent with the object of the Policy for the Treatment of Personal Data.

PRINCIPLES GOVERNING THE ACTION OF CONFECCIONES E INVERSIONES PEPA S.A. IN THE TREATMENT OF PERSONAL DATA

The principles governing the Treatment of personal data by the CONFECCIONES E INVERSIONES PEPA S.A., are the following:

Principle of legality. The Treatment of personal data is a regulated activity, subject to the provisions of Law 1581/2012 and Decree 1377/2013 and subsequent enactments.

Principle of finality. The purpose of Treatment must be legitimate, and informed to the Owner.

Principle of reasonable limits. The storage and processing of personal data will be limited to that which is essentially necessary to comply with the purposes previously specified for the business relationship, and compliance with the purposes authorised by the Owner.

Principle of liberty. Personal data may only be treated with the prior, express and informed consent of the Owner, or by mandate of the law or a court order.

Principle of veracity. Data must be true, complete, precise, updated, provable and comprehensible.

Principle of transparency. The right of the Owners to obtain information on their personal data, whose Treatment is to be undertaken by CONFECCIONES E INVERSIONES PEPA S.A., must be guaranteed

Principle of access and restricted circulation. Treatment may only be effected by persons authorized by the Owner or persons provided for in the law.

Principle of security. The data must be handled with the measures necessary to provide security of records, and to avoid adulteration or loss, or unauthorised or fraudulent inquiries, use or access.

Principle of confidentiality. Personal data which are not public data are confidential, and may confidential and may only be supplied as permitted by law

Principle of systematic incorporation. The principles of Personal Data Protection will be implemented into all processes and procedures of the business activities of CONFECCIONES E INVERSIONES PEPA S.A.

RIGHTS OF OWNERS OF PERSONAL DATA

An Owner is entitled to know, update and rectify personal data held by a Responsible Party or a Data Manager. This right may be exercised amongst other things in the case of partial, inaccurate, incomplete, fragmented or misleading data, or data whose Treatment is expressly prohibited or has not been authorized.

An Owner may request evidence of the authorization given to the Responsible Party except where expressly accepted as a requirement for Treatment, in accordance with the terms of article 10 of this Law.

An Owner in entitled to be informed by the Responsible Party or the Data Manager upon request, with regard to the use given to the Owner’s personal data.

An Owner may present complaints for breaches of the terms of this Law and other regulations to amend, supplement or complement it, to the Superintendency of Industry and Trade.

An Owner may revoke the authorization and/or request the suppression of data where Treatment does not respect the principles, rights and guarantees of the Constitution and the law. Revocation or suppression will be in order when the Superintendency of Industry and Trade has decided that the Responsible Party or the Data Manager of the Treatment has engaged in conduct contrary to this Law and the Constitution.

An Owner is entitled to free access to the Owner´s personal data which have been the object of Treatment.

AUTHORIZATION FOR THE TREATMENT OF PERSONAL DATA

CONFECCIONES E INVERSIONES PEPA S.A., acting as Responsible Party for Treatment, has adopted procedures to act, and the latest at the moment of collecting your personal data, will request your authorization for the Treatment of the same and inform you what personal data will be collected, and all the specific purposes of Treatment for which your consent is obtained.

It will be understood that the Owner has granted CONFECCIONES E INVERSIONES PEPA S.A., authorization for the Treatment of the Owner’s personal data when the Owner states (i) in writing (ii) orally, or (iii) through unequivocal conduct of the Owner that allows the reasonable conclusion that the Owner has granted CONFECCIONES E INVERSIONES PEPA S.A., the respective authorization. In no case will silence be understood to be “unequivocal conduct”.

Notwithstanding the foregoing, Owner’s authorisation will not be necessary when (i) information is required by a public administrative entity, in the exercise of its functions, or by court order; (ii) the data are of a public nature; (iii) there is a case of medical or health-related urgency; (iv) the Treatment of information is authorized by the law for historical, statistical or scientific purposes; or (v) the data relate to the Civil Registry records of the individual.

Revocation of authorisation and/or suppression of data

The Owner of personal data may at any time request CONFECCIONES E INVERSIONES PEPA S.A., as

Responsible Party for Treatment, to suppress personal data and/or to revoke the authorization given for the Treatment of the same, by presenting a claim in that respect, as provided for in

Article 15 of Law 1581/2012.

We nonetheless note that a request to suppress inflammation and/or revoke authorization will not be in order when the Owner of personal data has a legal or contractual duty by virtue of which the data must remain in the CONFECCIONES E INVERSIONES PEPA S.A., database.

PURPOSE OF TREATMENT OF THE PERSONAL DATA

CONFECCIONES E INVERSIONES PEPA S.A. will effect Treatment of personal data for the following purposes:

  • To undertake, through any means, and directly or through third parties, activities in marketing, promotion and/or publicity of its own or for third parties, the sale, billing, and management, collection, programming, technical support, market intelligence, improvement of service, verification and inquiries, control, behaviour, habits, enabling of means of payment, fraud prevention, and any other purpose related to our products and services now or in the future, in order to comply with contractual obligations and our corporate objects.
  • To generate optimal communications in relation to our services, products, promotions, billing and other activities.
  • To evaluate the quality of our products and services, and to undertake studies of consumer habits, preferences, interests and purchasing, product testing, opinions, evaluation of the service, satisfaction and other factors related to our products and services.
  • To provide assistance, service and technical support for our products and services.
  • To undertake actions required to comply with obligations inherent in the services provided by CONFECCIONES E INVERSIONES PEPA S.A.
  • To comply with obligations contracted with our customers, allies, users, suppliers, affiliates, distributors, subcontractors and other persons related directly or otherwise related to the corporate purposes of the CONFECCIONES E INVERSIONES PEPA S.A. and
  • To control and prevent fraud in all its forms.

PROCEDURE TO ATTEND TO REQUESTS AND INQUIRIES RELATED TO PERSONAL DATA

An Owner of personal data or a person authorized by an Owner, may:

  • Make requests and inquiries to discover the personal data of the Owner held by CONFECCIONES E INVERSIONES PEPA S.A.
  • Request the updating, amendment, rectification or suppression of data of the Owner, where appropriate and in accordance with the terms of this policy and applicable law.
  • Request a copy of the authorization granted by the Owner to CONFECCIONES E INVERSIONES PEPA S.A., to effect Treatment of the Owner’s personal data. These consultations may be made free of charge at least once every calendar month, and on every occasion where substantial modifications have been made to the Policy for the Treatment of Personal Data that give rise to new inquiries.
    The Owner or a person authorized by the Owner, may make inquiries with CONFECCIONES E INVERSIONES PEPA S.A. on the personal data of the Owner through the following mechanisms:

    • Verbally, at the Customer Helpline 2365958 – 6103574
    • In writing, to Cra 14 No., 83-46 Bogotá DC
    • By email to José@www.pepapombo.com.

Inquiries will be replied to within ten working days from the date of receipt

If it is not possible to attend to an inquiry within that time, CONFECCIONES E INVERSIONES PEPA S.A will so inform the interested party, explaining reasons, and indicating the date by

which the reply will be ready, at most within five working days following expiry of the ten-day initial period.

PROCEDURES TO ATTEND TO CLAIMS AND THE REVOCATION OF AUTHORIZATIONS FOR THE TREATMENT OF PERSONAL DATA

The following procedure will be used by the Owner or the person duly authorized by the Owner to do so:

  • Revocation of an Authorisation for the Treatment of Data;
  • Presentation of claims, where it is considered there is an alleged breach of duty by CONFECCIONES E INVERSIONES PEPA S.A., related to Treatment of Personal Data, in accordance with the terms of this Policy or the Personal Data Protection Law;
    Revocation of an Authorization of the Owner for the Treatment of Personal Data
    The Owner may revoke an Authorization and request the suppression of the Owners data in the following cases:
  • Free and voluntary unilateral decision of the Owner of the Personal Data, where there is no legal or contractual obligation imposed on the Owner of the duty to remain on the database.
  • In the event that the principles, rights, or guarantees of Constitutional or the law are not respected, provided that the Superintendency of Industry and Trade has determined that the Responsible Party or the Data Manager for Treatment has engaged in conduct contrary to the law:
    The foregoing, without prejudice to the regulations that CONFECCIONES E INVERSIONES PEPA S.A., must observe in relation to retention of documents to comply with formal obligations. Therefore, CONFECCIONES E INVERSIONES PEPA S.A., will suppress data or suspend their use where appropriate, respecting applicable regulations on the conservation of documents.
    The procedure for attending to complaints about personal data of the Owner is as follows:
    The Owner, or a person duly authorized by the Owner to do so, may make a complaint to CONFECCIONES E INVERSIONES PEPA S.A., in relation to the Treatment of Personal Data, in the following events:
    If the Owner considers that the Data of the Owner contained in the database should be the object of correction, update or suppression; or where it is noted that an alleged breach of any of the duties of the Data Protection Law has taken place claims should be made through any of the following channels:
  • Verbally, on the Customer Helpline in Bogotá, 236 5958-610 3574 In writing, to Cra. 14 No. 83-46, Bogota, or by email to José@prepapombo.com
    A complaint made by the Owner or the person authorized by the Owner to make it, should contain at least the following information: (i) identification of the Owner of the Personal Data; (ii) Description of the events of give rise to the complaint; (iii) contact data and location of the Owner of the Personal Data (address, phone, mobile, email, etc); and (iv) documents or evidence supporting the complaint. If this information is not made available, it will be understood that the complaint is not complete.
    If the complaint is not complete, CONFECCIONES E INVERSIONES PEPA S.A., will ask the complainant to provide the missing material or send the information or documentation required within five working days following receipt of the complaint by CONFECCIONES E INVERSIONES PEPA S.A., If two months have elapsed since the date of that request and the complainant has not provided the information required, it will be understood that the complaint has been abandoned, and the file will be closed.
    CONFECCIONES E INVERSIONES PEPA S.A., will have 15 working days to attend to the complaint, counting from the working day following that on which it receives that complaint.
    If it is not possible to attempt to attend to the matter within this time, CONFECCIONES E INVERSIONES PEPA S.A., people will inform interested party of the reasons for the delay, and the date on which the matter will be attended to, which may not be more than eight working days following expiry of the initial 15 days.

AREA RESPONSIBLE FOR ATTENDING TO REQUESTS, INQUIRIES AND COMPLAINTS

The Customer Service area of CONFECCIONES E INVERSIONES PEPA S.A., is responsible for receiving requests, inquiries and complaints from the Owner of Personal Data, related to the Owner’s rights to know, update rectify and suppress Personal Data and to revoke related authorization. The Customer Service area will ensure that each of the Areas of CONFECCIONES E INVERSIONES PEPA S.A., will promptly and appropriately reply to requests, inquiries and complaints received from Owners pf ¨Personal Data.

DURATION OF THE POLICY ON THE TREATMENT OF PERSONAL DATA

This Policy on the Treatment of Personal Data comes into effect on 3 May 2019, and will be valid until expressly revoked or amended.

The entire content of this page (including, but not limited to text, logos, content, photos, audio, tabs, trade names, drawings and videos) is subject to intellectual property rights regulated by the rules for copyright and other related legislation.

All rights reserved

No part of this service may be copied, reproduced, distributed, published, transmitted, disseminated or in any way exploited without the prior authorisation of CONFECCIONES E INVERSIONES PEPA S.A.

In the case of payment platforms, information and security will be guaranteed by these platforms themselves, and they are responsible for the transaction and confidentiality of your data. The Company is not liable for procedures followed on those platforms.

The entire content of this page (including, but not limited to text, logos, content, photos, audio, tabs, trade names, drawings and videos) is subject to intellectual property rights regulated by the rules for copyright and other related legislation.

All rights reserved

No part of this service may be copied, reproduced, distributed, published, transmitted, disseminated or in any way exploited without the prior authorisation of CONFECCIONES E INVERSIONES PEPA S.A.

In the case of payment platforms, information and security will be guaranteed by these platforms themselves, and they are responsible for the transaction and confidentiality of your data. The Company is not liable for procedures followed on those platforms.