Information and Data Treatment Policy of Boing Marketing SAS

1. General Provisions

The Political Constitution of Colombia established in its article 20, the access to information as a  fundamental human right; However, in turn, it establishes, in its article 15, rights and guarantees to those who hold the ownership of said information, such as the protection of personal and family privacy, good name, and to know, update and rectify the information that about them has been collected, stored, or has been subject to use, circulation or suppression of the databases and files of public and private entities. By virtue of the aforementioned article – Art. 15 CP- Statutory Law 1581 of October 17, 2012 is issued, which establishes the principles and provisions applicable to the processing of personal data that are registered in any database of both public and private entities. paragraph k) of article 17 and paragraph f) of article 18 of the aforementioned law, establish as the duty of those responsible and in charge of data processing, to adopt an internal manual of policies and procedures to guarantee adequate compliance with the law, and especially for the attention of queries and claims by the owners. In order to facilitate the implementation of the law and the policy manual for data processing, in Title II, Chapter 25 of Decree 1074 of May 26, 2015 Sole Regulatory Decree of the Commerce, Industry and Tourism Sector; Law 1581 of 2012 was partially regulated, which establishes and adds requirements for the adequate treatment of personal data registered in public and private databases. Similarly, Law 1712 of 2014 on transparency and regulation of the right of access to national public information is issued, adding new principles, concepts and procedures for the exercise and guarantee of said right; together with the provisions of Part VIII, Title III of Decree 1080 of May 26, 2015, which establishes new provisions and clarifies issues related to the management of public information regarding its disclosure, publication, reception, classification and reservation , as well as the development of information management and monitoring instruments.

Finally, Law 1755 of June 30, 2015, through which the Right to Petition is regulated, incorporates in its Article 24 information with a reserved nature, among other things, the one referring to human genetic data (Sensitive Data). BOING MARKETING SAS A private entity, duly constituted, issues this internal policy of personal data management in compliance with the current regulations referenced above.

1. General Objective: To guarantee the reservation of information and security regarding the treatment that will be given to the physical and digital databases of our employees, clients, suppliers and from whom BOING MARKETING SAS has legally obtained information and personal data in accordance with the guidelines established by the law regulating the right of Habeas Data, and will be applied by the Company regarding the collection, storage, use, circulation, deletion and all those activities that constitute the processing of personal data.
2. Authorization request to the owner of the personal data: In advance and / or at the time of collecting the personal data, the Company will request the owner of the data their authorization to carry out its collection and treatment, indicating the purpose for which the data is requested , using for these purposes, automated technical means, written or oral, that allow keeping proof of the authorization and / or unequivocal conduct described in article 7 of Decree 1377 of 2013. Such authorization will be requested for as long as is reasonable and necessary to satisfy the needs that gave rise to the request for the data and, in any case, in compliance with the legal provisions that govern the matter.
3. Definitions: In accordance with current legislation on the matter, the following definitions are established, which will be applied and implemented according to the interpretation criteria that guarantee a systematic and comprehensive application, which govern the fundamental rights that surround the right to habeas data. and protection of personal data.

AUTHORIZATION: Consent of the owner of the data to treat them in accordance with internal policy. PRIVACY NOTICE: Communication either written or verbal where it is reported that BOING MARKETING has a data processing policy and that it is in turn responsible for the treatment of the same. PERSONAL DATA: Any type of information linked to a person. SENSITIVE DATA: That which affects the privacy of the owner or whose improper use may generate discrimination, such as sexual orientation, racial or ethnic origin, political orientation, religious convictions, health status, etc. MANAGER OF THE TREATMENT: It refers to the person, either natural or legal, who by himself or in association with others performs the managing of personal data. HOLDER: Natural or legal person whose personal data is subject to treatment. TREATMENT: Operation or operations on personal data, such as the collection, storage, use, circulation, or deletion.

2. General Principles for the processing of personal data.

Boing Marketing SAS will apply the following general principles that constitute the rules to follow in the collection, handling, use, treatment, storage and exchange of personal data: a) Principle of transparency: in the use, capture, collection and processing of personal data The right of the Holder must be guaranteed to obtain from BOING MARKETING SAS, at any time and without restrictions, information about the existence of any type of information or personal data that is of interest to him. b) Principle of freedom: The collection, use and processing of personal data can only be exercised with the prior, express, and informed consent of the owner. Personal data may not be obtained or disclosed without prior authorization, or in the absence of a legal or judicial mandate that reveals consent. c) Principle of truthfulness: The information subject to treatment must be truthful, complete, exact, updated, verifiable and understandable. The processing of partial, incomplete, fractioned, or misleading data is prohibited. d) Principle of legality: In the use, capture, collection and processing of personal data, the current provisions that govern the processing of personal data and other related fundamental rights will be applied. e) Principle of confidentiality: Each and every one of the people who administer, handle, update or have access to information of any kind found in databases, undertake to keep, and keep it confidential and not reveal to third parties, all personal, commercial, accounting, technical information, or of any other type supplied in the execution and exercise of their functions. All people who currently work and those who are linked in the future for this purpose, in the administration and management of databases, must sign the confidentiality form established by BOING MARKETING SAS in order to ensure such commitment. This obligation persists and is maintained even after the end of your relationship with any of the tasks that comprise the treatment.

3. Purpose with which the collection of personal data and their treatment is carried out:

The Company may make use of personal data to: a) To execute the existing contractual relationship with its clients, suppliers and workers, including the payment of contractual obligations; b) To provide the services and / or products required by its users; c) To inform about new products or services and / or about changes in them; d) To evaluate the quality of the service; e) To carry out internal studies on consumer habits; f) To send to physical or electronic mail, cell phone or mobile device, via text messages (SMS and / or MMS) or through any other analog and / or digital means of communication created or to be created, commercial, advertising or promotional information about the products and / or services, events and / or promotions of a commercial nature or not, in order to promote, invite, direct, execute, inform and in general, to carry out campaigns, promotions or contests of a commercial nature or advertising, advanced by The Company and / or by third parties.

4. Duties of the person in charge of the data treatment:

The duties that the person in charge of the data treatment will have on the part of BOING MARKETING SAS:

1. To keep the information under the necessary security conditions to prevent its adulteration, loss, or fraudulent use.
2. To communicate and encourage data protection within the organization.
3. To guarantee the owner, at all times, the full and effective exercise of the right to Habeas Data.
4. To request and to keep a copy of the respective authorization granted by the owner.
5. To rectify the information when it is incorrect and communicate the pertinent to the person in charge.
6. To process inquiries and / or claims by the Holder.
7. To inform in a proper way, to the owner about the purpose of the collection and the rights he has under the authorization granted.

5. Rights of the holders:

The rights of the holders of personal data who have some type of relationship with BOING MARKETING SAS are disclosed below, which by themselves or through their representative and / or attorney-in-fact or their successor in title may exercise the following rights: I) Consultation: The owner of the data may at any time request BOING MARKETING information regarding the use and purpose of their personal data. II) Complaints and claims: The law refers to 4 types of claims. III) Correction claim: Corresponds to the right of the Holder to request that incomplete, inaccurate, partial data that may lead to error be updated, rectified, or modified, or those whose treatment is expressly prohibited or has not been authorized. IV) Suppression claims: It is the right of the owner to have data that is inappropriate, excessive or that does not respect constitutional and legal principles, rights and guarantees to be deleted. V) Revocation claims: Refers to the right of the owner to revoke the previously signed authorization for the processing of their personal data. VI) Claim of infringement: Indicates the right of the owner of the data to request that the breach of the regulations on Data Protection be remedied. VII) Signed authorization request. The owner may request a copy of the signed authorization at any time to verify the data entered. VIII) Right of access: By virtue of which you can access the personal data that are under the control of the Company, for the purpose of consulting them for free at least once every calendar month, and each time there are substantial modifications to the Policies of Treatment of the information that motivate new consultations; IX) Right to update, rectification and deletion: By virtue of which you may request the updating, rectification and / or deletion of the personal data being processed, in such a way that the purposes of the treatment are satisfied;

1. X) Right to request proof of authorization: except in events in which, according to current legal regulations, authorization is not required to carry out the treatment; XI) Right to be informed regarding the use of personal data; XII) Right to file complaints with the Superintendency of Industry and Commerce: for infractions of the provisions of current regulations on the processing of personal data; XIII) Right to require compliance with the orders issued by the Superintendency of Industry and Commerce.

6. Responsible area and procedure for the exercise of the rights of the holders of personal data:

The administrative area of the Company will be responsible for responding to the requests, complaints and claims made by the owner of the data in exercise of the rights contemplated in the present policy. For such purposes, the owner of the personal data or whoever exercises their representation, may send their request, complaint or claim from Monday to Friday from 8:00 am to 5:00 pm to the email: contacto@boingconcept.com, call the telephone line of the Company, city BOGOTÁ DC telephone (1) 7030747, or file them at the following address corresponding to our offices TV 3 # 53C 63 in Bogotá.

7. Effective date:

This Personal Data Policy was created on February 1, 2021 and becomes effective as of March 1, 2021. Any change that occurs with respect to this policy will be reported through the electronic address: www.boingmarketing.co

Sincerely,

BOING MARKETING SAS

NIT 900.510.326-9