JAIME ARIAS MOLINA - LAWYERS SAS

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In compliance with the provisions of Statutory Law 1581 of 2012 and

in its Regulatory Decree 1377 of 2013, the company JAIME ARIAS MOLINA – ABOGADOS SAS adopts this Policy for the Treatment and Protection of Personal Data, which will be duly communicated to all natural persons Holders of data that the entity has obtained or obtains in the future , in the exercise of its commercial activity.

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CHAPTER 1 IDENTIFICATION OF THE DATA CONTROLLER.

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1.1. NAME: JAIME ARIAS MOLINA – ABOGADOS SAS, is a company legally constituted in accordance with Colombian legislation, by means of a private document dated May 7, 2014, registered in the Medellín Chamber of Commerce for Antioquia on May 13, 2014. The company Its main activity is the provision of legal services.

1.2. ADDRESS: Calle 7 No. 39-215 Office 501, Medellín, Colombia.

1.3. EMAIL: info@jamabogados.com

1.4. RESPONSIBLE TELEPHONE: (054) 4037520.

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CHAPTER 2. LEGAL FRAMEWORK.

The Policy is based on article 15 of the Political Constitution, laws 1266 of 2008 and 1581 of 2012 and Regulatory Decrees 1727 of 2009, 2952 of 2010 and 1377 of 2013 and other regulations that may add to or modify them.

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CHAPTER 3. DEFINITIONS.

For the purposes of this Policy and in accordance with the applicable legislation, unless the context requires otherwise, the terms indicated below will have the following meaning:

3.1. Authorization: It is the legal or contractual permission or the prior, express and informed consent of the Holder to carry out the Processing of Personal Data.

3.2. Privacy Notice: It is the verbal or written communication generated by the Responsible Addressed to the Holder for the Treatment of his Personal Data, through which he is informed about the existence of the Information Treatment Policy that will be applicable, the form of access it and the purpose of the Treatment that is intended to be given to the Personal Data.

3.3. Database: It is the organized set of Personal Data that is subject to Treatment.

3.4. Successor in title: It is the person who has succeeded another due to the death of the latter (heir).

3.5. Personal Data: It is any information linked or that can be associated with one or several determined or determinable natural persons.

3.6. Public Data: It is the Personal Data that in accordance with the Constitution or the law is qualified as such and that which is not semi-private, private or sensitive. They are considered public data, among others: data related to the marital status of people, their profession or trade and their quality as a merchant or public servant. Due to its nature, public data may be contained, among others, in public records, public documents, official gazettes and bulletins, and duly executed judicial decisions that are not subject to reservation.

3.7. Private Data: It is the data that due to its intimate or reserved nature is only relevant for the Holder.

3.8. Sensitive Data: It is that data that can affect the privacy of the Holder or whose improper use can generate discrimination, such as those that reveal racial or ethnic origin, political orientation, religious or philosophical convictions, membership in unions, social, human rights organizations or that promote the interests of any political party or that guarantee the rights and guarantees of opposition political parties, as well as data related to health, sexual life, and biometric data.

3.9. Person in Charge of Treatment: It is the natural or legal person, public or private, who, by itself or in association with others, carries out the Treatment of Personal Data on behalf of the Person Responsible for Treatment.

3.10. Habeas Data: It is the fundamental right of any person to know, update and rectify the information about them that is in the database and in the files of public and private entities.

3.11. Personal Data Protection Law: It is Law 1581 of 2012 and its regulatory Decrees or the regulations that modify, complement or replace them.

3.12. Policy: this is the Personal Data Processing Policy of JAIME ARIAS MOLINA – ABOGADOS SAS

3.13. Responsible for the Treatment: It is JAIME ARIAS MOLINA – ABOGADOS SAS, which is the legal person, of a private nature that, by itself or in association with others, decides on the Database and/or the Treatment of Personal Data.

3.14. Holder: It is the natural person whose Personal Data is subject to Treatment.

3.15. Treatment: It is any operation or set of operations on Personal Data, such as the collection, storage, use, circulation or deletion.

3.16. Transfer: It is the sending, by the Responsible and/or Responsible for the Processing of Personal Data, located in Colombia, of the information or Personal Data to a receiver, who in turn is Responsible for the Treatment and is inside or outside the country.

3.17. Transmission: Treatment of Personal Data that implies the communication of the same within or outside the territory of the Republic of Colombia when its purpose is to carry out a Treatment by the Manager on behalf of the Responsible.

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CHAPTER 4. GUIDING PRINCIPLES FOR THE PROCESSING OF PERSONAL DATA.

To the Processing of Personal Data in JAIME ARIAS MOLINA – ABOGADOS SAS, in the development, interpretation and application of the Personal Data Protection Law, the following guiding principles will be applied in a harmonious and comprehensive manner:

4.1. LEGALITY: The Treatment of Personal Data is a regulated activity that must be subject to what is established in the Personal Data Protection Law.

4.2. PURPOSE: The Treatment that is made of the Personal Data collected must obey a legitimate purpose in accordance with the Constitution and the Law, which must be informed to the Owner.

4.3. FREEDOM: The Processing of Personal Data can only be exercised with the Authorization, given by the prior, express and informed consent of the Holder or by legal authorization. Personal Data may not be obtained or disclosed without prior Authorization, or in the absence of a legal or judicial mandate that relieves consent.

4.4. TRUTH OR QUALITY: The information subject to Processing must be truthful, complete, accurate, up-to-date, verifiable and understandable. Processing of partial, incomplete, divided or misleading data will not be carried out.

4.5. TRANSPARENCY: In the Data Processing, the Holder's right to obtain from the Data Controller or the Data Processor, at any time and without restrictions, information about the existence of data that concerns him is guaranteed.

4.6. ACCESS AND RESTRICTED CIRCULATION: The Treatment of Personal Data is subject to the limits that derive from its nature, from the provisions of the law and the Constitution. In this sense, the Treatment can only be done by persons authorized by the Owner and/or by the persons provided for by law. Personal Data, except for public information, may not be available on the Internet or other means of disclosure or mass communication, unless access is technically controllable to provide restricted knowledge only to the Holders or third parties authorized by law.

4.7. SECURITY: The information subject to Treatment by the Responsible Party must be protected through the use of technical, human and administrative measures that are necessary to provide security to the records, avoiding their adulteration, loss, consultation, use or unauthorized or fraudulent access.

4.8. CONFIDENTIALITY: The Responsible is obliged to guarantee the confidentiality of the information, even after the relationship that gave rise to the work that includes the Treatment has ended, and may only supply or communicate Personal Data when this corresponds to the development of the authorized activities in the law.

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CHAPTER 5. RIGHTS THAT ASSIST THE HOLDER OF PERSONAL DATA OBJECT OF TREATMENT.

The Holders of Personal Data, which are subject to Treatment by JAIME ARIAS MOLINA – ABOGADOS SAS, directly or through a representative and/or proxy or their successors in title, may exercise the following rights:

5.1. Know, update and rectify your Personal Data against JAIME ARIAS MOLINA – ABOGADOS SAS in its capacity as Data Controller. This right may be exercised, among others, against partial, inaccurate, incomplete, fragmented, misleading data, or those whose Treatment is expressly prohibited or has not been authorized.

5.2. Request proof of the Authorization granted for the Processing of Personal Data, except when expressly excepted as a requirement for the Treatment (cases in which the Authorization is not necessary).

5.3. Be informed regarding the use of Personal Data.

5.4. Submit complaints to the Superintendence of Industry and Commerce for violations of the provisions of the Personal Data Protection Law.

5.5. Revoke the Authorization and/or request the deletion of the data when the principles, rights and constitutional and legal guarantees are not respected in the Treatment.

5.6. Free access to your Personal Data that has been processed.

FIRST PARAGRAPH: The rights of the Holders established in this policy and in the Law may be exercised by the following persons:

a) By the Holder, who must prove his identity.

b) By the successors in title of the Holder, who must prove such quality.

c) By the representative and/or proxy of the Holder, prior accreditation of the representation or power of attorney.

d) By stipulation in favor of another or for another.

e) The rights of children and adolescents will be exercised by the people who are empowered to represent them.

SECOND PARAGRAPH: In the Treatment, respect for the prevailing rights of children and adolescents will be ensured. The Treatment of Personal Data of children and adolescents is prohibited, except for those data that are of a public nature or for which express Authorization has been obtained from their representatives, prior information about the Treatment.

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CHAPTER 6. DUTIES OF JAIME ARIAS MOLINA – ABOGADOS SAS REGARDING THE PROCESSING OF PERSONAL DATA.

Without prejudice to the provisions set forth in the Personal Data Protection Law, by virtue of this Policy, the duties of JAIME ARIAS MOLINA – ABOGADOS SAS, both in its capacity as Data Controller and Data Processor, if applicable, are the following:

6.1. Request and keep, under the conditions provided in this policy, a copy of the Authorization granted by the Holder for the Treatment of Personal Data.

6.2. Inform the Holder in a clear and sufficient manner about the purpose of the collection and the rights that assist him by virtue of the Authorization granted.

6.3. Inform at the request of the Owner about the use given to their Personal Data.

6.4. Process queries and claims formulated in the terms indicated in this policy and in the Personal Data Protection Law.

6.5. Ensure that the information is true, complete, accurate, updated, verifiable and understandable.

6.6. Maintain the confidentiality of the information in the terms established in this policy and in the Law.

6.7. Keep the information under the necessary security conditions to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access.

6.8. Update the information when necessary. In the events in which it acts as Treatment Manager, said update must be made within five (5) business days from receiving the request.

6.9. Rectify Personal Data when appropriate.

6.10. Establish that the Data Controller is authorized to supply the Personal Data that I will treat as Manager.

6.11. Perform timely updating, rectification or deletion of data.

6.12. In the events in which you act as Data Manager, you must register in the respective database the legend "claim in process" in the manner established in this policy and in the law.

6.13. In the events in which you act as Data Manager, you must insert in the database the legend "information under judicial discussion" once notified by the competent authority about judicial processes related to the quality of the Personal Data.

6.14. Refrain from circulating information that is being controversial by the Holder and whose blocking has been ordered by the Superintendence of Industry and Commerce.

6.15. Allow access to information only to persons authorized by the Holder or empowered by law for that purpose.

6.16. Inform the Superintendence of Industry and Commerce when there are violations of the security codes and there are risks in the administration of the information of the Holders.

6.17. Comply with the instructions and requirements issued by the Superintendence of Industry and Commerce.

6.18. Provide to those in charge of the Treatment only the Personal Data whose Treatment is previously authorized. For the purposes of the national or international transmission of data, a Personal Data transmission contract must be signed or contractual clauses agreed upon as established in article 25 of Decree 1377 of 2013.

6.19. Guarantee that the information provided to the Treatment Manager is true, complete, accurate, updated, verifiable and understandable.

6.20. Communicate in a timely manner to the Treatment Managers all the news regarding the data that you have previously provided and adopt the other necessary measures so that the information provided to it is kept up to date.

6.21. Inform in a timely manner the Treatment Managers of the rectifications made on the Personal Data so that they can proceed to make the pertinent adjustments.

6.22. Require Treatment Managers, at all times, to respect the security and privacy conditions of the Holder's information.

6.23. Inform the Treatment Managers when certain information is under discussion by the Holder, once the claim has been filed and the respective procedure has not been completed.

6.24. Comply with the instructions and requirements issued by the Superintendence of Industry and Commerce.

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CHAPTER 7. AUTHORIZATIONS AND CONSENT OF THE HOLDER.

Without prejudice to the exceptions provided for in the Law, in the Treatment of Personal Data of the Holder, the prior and informed Authorization of the latter is required, which must be obtained by any means that may be subject to subsequent consultation.

PARAGRAPH: The Authorization of the Holder of the information will not be necessary in the following cases:

a) When the information is required by a public or administrative entity in the exercise of its legal functions or by court order.

b) When the data is of a public nature.

c) When a case of medical or health emergency arises.

d) When the processing of information is authorized by law.

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CHAPTER 8.  TREATMENT TO WHICH THE DATA WILL BE SUBJECTED AND PURPOSE OF THE SAME.

JAIME ARIAS MOLINA – ABOGADOS SAS may make use of Personal Data, prior legal or express Authorization of the Holder for the following purposes:

8.1. Execution of existing contractual relations with its shareholders, administrators, workers, clients, suppliers, including the payment of obligations.

8.2. Provision of services and/or distribution of products required by customers.

8.3. Communication of commercial, advertising, promotional information about products and services.

8.4. Evaluation of the quality of the service.

8.5. Realization of marketing studies, big data and direct marketing.

8.6. Development of the process of section, evaluation and recruitment of personnel.

8.7. Support of audit processes.

8.8. Supply, sending and delivery of personal data to its affiliates, linked or subordinate or to third parties in charge of data processing, located in Colombia or abroad, when necessary for the Treatment and provided that the third party has adequate data protection policies. data in accordance with the law and have the proper Authorization by the Owner.

8.9. Surveillance to ensure the safety of people, property and company facilities.

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CHAPTER 9. INTERNATIONAL TRANSFER AND TRANSMISSION OF PERSONAL DATA.

JAIME ARIAS MOLINA – ABOGADOS SAS in compliance with the development of its business purpose may transfer and transmit Personal Data of the Holders.

For the International Transfer of Personal Data of the Holders, JAIME ARIAS MOLINA – ABOGADOS SAS will take the necessary measures so that third parties know and commit to observe this Policy, under the understanding that the personal information they receive may only be used for matters directly related to the link that said third parties have with JAIME ARIAS MOLINA – ABOGADOS SAS and may not be used or intended for a different purpose or purpose. For the international transfer of Personal Data, the provisions of article 26 of Law 1581 of 2012 will be observed.

The international Transmissions of Personal Data carried out by JAIME ARIAS MOLINA – ABOGADOS SAS, will not require to be informed to the Owner or have their consent when there is a Personal Data transmission contract in accordance with article 25 of Decree 1377 of 2013.

By accepting this policy, the Owner expressly authorizes the transfer and transmission of Personal Information. The information will be transferred and transmitted, for all relationships that may be established with JAIME ARIAS MOLINA – ABOGADOS SAS

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CHAPTER 10. PROCEDURE FOR ATTENDING INQUIRIES, CLAIMS AND REQUESTS

10.1. PERSON OR AREA RESPONSIBLE FOR THE ATTENTION OF REQUESTS, INQUIRIES AND CLAIMS. JAIME ARIAS MOLINA – ABOGADOS SAS has designated the customer service area as the area responsible for ensuring compliance with this policy within the institution. This dependency will be attentive to resolve requests, queries and claims by the Holders and to carry out any update, rectification and deletion of Personal Data, through the email info@jamabogados.com.

10.2. PROCEDURE FOR DATA CONSULTATION. The Holders of information or their Successors in title and/or their duly accredited representatives or proxies, may consult the personal information of the Holder that rests with JAIME ARIAS MOLINA – ABOGADOS SAS, who will provide all the information contained in the individual record or that is linked to the Identification of the Holder.

The consultation request will be made through the email info@jamabogados.com, or by written communication addressed to the company located in the company offices located at Calle 7 No. 39-215 Office 501 in Medellín.

The request will be addressed within a maximum term of ten (10) business days from the date of filing of the same. When it is not possible to attend the query within said term, the interested party will be informed, stating the reasons for the delay and indicating the date on which their query will be attended, which in no case may exceed five (5) business days following the expiration of the first term.

10.3. PROCEDURE FOR THE PRESENTATION OF CLAIMS. The Holder or his successors in title and/or his duly accredited representatives or proxies, who consider that the information contained in a database should be subject to correction, updating or deletion, or when they notice the alleged breach of any of the duties contained in the law, they may file a claim with JAIME ARIAS MOLINA – ABOGADOS SAS, which will be processed under the following rules:

10.3.1. The Holder's claim will be made through a request addressed to the company, in writing, sent to the email info@jamabogados.com or filed directly at the company's offices located at: Calle 7 No. 39-215 Office 501 in Medellín. The document must contain the full identification of the Holder, the description of the facts that give rise to the claim, the address, and must be accompanied by the documents that are to be asserted.

10.3.2. If the claim request is incomplete, the interested party will be required within five (5) days after receipt of the request to correct the faults. After two (2) months from the date of the request, without the applicant submitting the required information, it will be understood that the claim has been withdrawn.

10.3.3. In the event that the person receiving the claim is not competent to resolve it, it will be transferred to the appropriate person within a maximum term of two (2) business days and the interested party will be informed of the situation.

10.3.4. Once the request is received with the complete information or the requirement has been met, the Holder's data will be labeled with the inscription "claim in process", and the reason for the claim must be indicated. Said registration must be made within a term not exceeding two (2) business days from the receipt of the request and will be maintained until the claim is decided.

10.3.5. The maximum term to address the claim will be fifteen (15) business days from the day following the date of receipt. When it is not possible to address the claim within said term, the interested party will be informed of the reasons for the delay and the date on which his claim will be addressed, which in no case may exceed eight (8) business days following the expiration of the first finished.

FIRST PARAGRAPH: This procedure will be applicable to requests for rectification and/or updating of information, which in the opinion of the Holder turns out to be incomplete or inaccurate. In this case, the Holder must indicate in the request the update, rectification and deletion of the data that he requires and will provide the documentation that supports his request.

SECOND PARAGRAPH: Through this same procedure, the Holders of the Personal Data can revoke their consent to the Processing of their Personal Data at any time, as long as it is not prevented by a legal or contractual provision.

THIRD PARAGRAPH: If the respective legal term has expired, JAIME ARIAS MOLINA – ABOGADOS SAS has not eliminated the Personal Data of the Owner, the latter will have the right to request the Superintendency of Industry and Commerce to order the revocation of the Authorization and/or the deletion of Personal information. For these purposes, the procedure described in article 22 of the Personal Data Protection Law will be applied.

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CHAPTER 11. SAFETY MEASURES.

In development of the security principle established in Law 1581 of 2012, JAIME ARIAS MOLINA – ABOGADOS SAS will adopt the technical, human and administrative measures that are necessary to grant security to the records avoiding their adulteration, loss, consultation, use or unauthorized access. or fraudulent. The personnel who carry out the Processing of Personal Data will execute the protocols that are established in order to guarantee the security of the information.

PRIVACY NOTICE, DECLARATION AND AUTHORIZATION FOR THE PROCESSING OF PERSONAL DATA

The undersigned, identified as it appears next to my signature, acting on my own behalf voluntarily and giving full certainty that everything stated here is accurate, truthful and verifiable, declares:

That, in accordance with the provisions of current legislation on the protection of personal data and the Personal Data Processing Policy of JAIME ARIAS MOLINA ABOGADOS SAS, I have been duly informed by this company that it will use and process my personal data to the purposes described in its Personal Data Processing Policy available at the main office of the company located at Calle 7 No. 39-215, office 501, Medellín, Colombia, which are summarized below:

1. Execution of the existing contractual relations with its shareholders, administrators, workers, clients, suppliers, including the payment of obligations.

2. Provision of services and/or distribution of products required by customers.

3. Communication of commercial, advertising, promotional information about products and services.

4. Evaluation of the quality of the service.

5. Realization of marketing studies, big data and direct marketing.

6. Development of the process of section, evaluation and recruitment of personnel.

7. Support of audit processes.

8. Supply, sending and delivery of personal data to its subsidiaries, affiliates or subordinates or to third parties in charge of Data Processing, located in Colombia or abroad, when necessary for the Treatment and provided that the third party has adequate data processing policies. data protection in accordance with the law and have the proper Authorization by the Owner.

9. Surveillance to ensure the safety of people, property and company facilities.

10. That my rights are those provided for in the Political Constitution, Law 1581 of 2012 and its regulatory decrees, which are based on the fact that JAIME ARIAS MOLINA ABOGADOS SAS is the Responsible for the Treatment of my personal data and that as the owner of these, I can consult them at the main office of the company; I am not required to provide sensitive data. Likewise, JAIME ARIAS MOLINA ABOGADOS SAS guarantees the confidentiality, veracity, transparency, accessibility, security, and restricted circulation of the processing of my personal data.

11. In addition, I declare that I have been informed that JAIME ARIAS MOLINA ABOGADOS SAS reserves the right to modify its Personal Data Processing Policy, informing and publishing such modification in a timely manner.

12. Likewise, to request information, update, rectify, delete the information contained in the databases or resolve any concern related to the processing of my personal data, I may contact the Company Management at email_cc781905-5cde- 3194-bb3b-136bad5cf58d_ info@jamabogados.com  o at Calle 7 No. 39-215, office 501, Medellín, Colombia.

For the purposes of this authorization, I declare that the personal data that I will deliver to be submitted to Treatment are true and that I have provided them voluntarily.