Coleóptera SAS personal data treatment and protection policy

In compliance with the provisions of articles 15 and 20 of the Political Constitution, Statutory Law 1581 of 2012 and Regulatory Decree 1377 of 2013, Coleóptera SAS adopts this policy for the processing of personal data, which is publicized through its disclosure on the website https://mentelabs.com or that which at the time is the official website of Coleóptera SAS. The objective of this document is that the owners of personal data have sufficient information regarding the treatment, that is, collection, storage, use, circulation or deletion, as well as the security, confidentiality and privacy of the information collected in by virtue of the authorization granted by the owners of the personal data to Coleóptera SAS These terms and conditions create a contract between you Coleóptera SAS, whose acceptance of the conditions is understood through the use of our services. Please read them carefully. Coleóptera SAS reserves the right to make modifications to the personal data processing and protection policy. If there are changes to this policy, Coleóptera SAS will publish the new terms on its website indicating the date of entry into force of the new regulations. If this change involves the modification of the purpose for which the information is collected, a new authorization will be requested from the owner of the personal data. I. Identification of the person responsible for the treatment. Name: Coleoptera SAS – Coleoptera SAS Address: AV CRA 45 108 27 office 606, Bogotá DC, ahio database is in black and/or whoever is delegated for this purpose.
 Email: mauricio@coleoptera.com Effective date of the information processing policy: May 27, 2019. The personal data provided by its owners will be kept as long as its deletion is not requested by the interested party and as long as there is no legal duty to keep them. II. Area of application This policy will be applicable to the personal data provided by their owners and collected by Coleóptera SAS on its platform https://deepvoicelabs.com or mobile application for Android and IOS. The data of the owners who register on the Coleóptera SAS portal and/or any of the Coleóptera SAS phases will be treated in compliance with the security policies regarding the integrity of the information.

 Coleóptera SAS and its allies may have partial knowledge of the information provided by the “USERS”, as well as with respect to the “USERS” of Coleóptera SAS, at the time of registering on the Coleóptera SAS platform with the intention of activating, notifying and/or contact them by electronic means for the management and monitoring of the different activities of Coleóptera SAS and its allies, such as promotions or rewards, among others. III. Definitions In accordance with current regulations, the following definitions will be taken into account for the application and interpretation of the rights of the owners and the duties of the person in charge of processing the personal data contemplated through this data processing policy. Authorization: Prior, express and informed consent of the Owner to carry out the Processing of personal data. Privacy notice: Verbal or written communication generated by the Data Controller, addressed to the Owner for the processing of their personal data, through which they are informed about the existence of the information processing policies that will be applicable to them, the form to access them and the purposes of the treatment that is intended to be given to personal data. Database: Organized set of personal data that is subject to processing. Incumbent: Person who has succeeded another due to the latter's death (heir). Personal data: Any information linked or that can be associated with one or several specific or determinable natural persons. Public data: It is data that is not semi-private, private or sensitive. Public data are considered, among others, data relating to the marital status of people, their profession or trade, and their status 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 rulings that are not subject to confidentiality. Sensitive data: Sensitive data is understood to be data that affects the privacy of the Owner or whose improper use may generate discrimination, such as revealing racial or ethnic origin, political orientation, religious or philosophical convictions, membership in unions, organizations. social, human rights 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. Data Processor: Natural or legal person, public or private, who, by themselves or in association with others, carries out the Processing of personal data on behalf of the Data Controller. Coleóptera SAS reserves the right to hire a third party to act as the person in charge of processing personal data, remaining in any case subject to this personal data processing policy. Responsible for the Treatment: Natural or legal person, public or private, who alone or in association with others, decides on the database and/or the Processing of the data. Owner: Natural person whose personal data is the subject of Treatment. Processing: Any operation or set of operations on personal data, such as collection, storage, use, circulation or deletion. Transfer: The transfer of data takes place when the person responsible and/or in charge of the processing of personal data, located in Colombia, sends the information or personal data to a recipient, who in turn is responsible for the treatment and is located inside or outside from the country. Transmission: Processing of personal data that involves their communication within or outside the territory of the Republic of Colombia when its purpose is to carry out processing by the person in charge on behalf of the person responsible. Automatic Mechanisms: These are those computer processes carried out to generate records of the activities of website visitors and whose purpose is to establish patterns of activity, navigation and audience, which do not imply the personal identification of those subscribers, users and/or visitors who access to the Coleóptera SAS platform Regarding these computer processes, Coleóptera SAS reserves the right to use said general information, in order to establish criteria that improve the contents of this system, in any case always dissociated from the person who left the data in its navigation. Manual Mechanisms: These are formal and express information requirements to subscribers, users and/or visitors of the portal that involve the collection of personal data such as name, surname, address, email, occupation, etc. These data are collected by Coleóptera SAS with the aim of improving the quality of information on the portal and providing better service to citizen queries. IV. Purpose of the information collected The information and recommendations contained in the Coleóptera SAS portal have the function of creating advanced digital profiles using the publicly available information of the information holders . The owners of the information have full knowledge of the purpose of collecting the information and accept that Coleóptera SAS collects this information to generate said profiles. In this sense, Coleóptera SAS does not assume responsibility for the use, application and/or processing that the different actors who own the personal data may give to said information nor provide a guarantee regarding the accuracy of its contents. The registration of the “USER” on the Coleóptera SAS portal will be considered their acceptance of the personal data processing policy. The data provided by the user must be correct, truthful and complete, so the USER will assume all responsibility for the lack of truthfulness or accuracy in the provision of the data. Coleóptera SAS will use this information to identify the owner of the personal data, and carry out the management of internal and external processes with allied entities and public and private entities with which Coleóptera SAS has contracts, alliances and agreements, which are part of the execution of the advanced digital profile of Coleóptera SAS and other services provided through the platform. In the event that the data provided by a user is false, inaccurate or misleading, Coleóptera SAS will be entitled, without prejudice to other legal measures at its disposal, to withdraw, deny or suspend the benefits granted to the user by this data processing policy. personal. The use of the services offered by Coleóptera SAS or by third parties on the Coleóptera SAS platform does not grant the user intellectual property rights, nor any right over copyright over the Coleóptera SAS services or with respect to the content. to which you access. The user may not use the content of the Coleóptera SAS services unless the corresponding permission is obtained or unless it is permitted by law. These conditions do not grant the user the right to use the Coleóptera SAS brand or any logo used in the Coleóptera SAS services, so the user must not eliminate, obscure, or modify any legal notice displayed in the Coleóptera SAS services. or next to them. The services offered on the Coleóptera SAS platform that are provided by third parties are the exclusive responsibility of the entity that makes them available. However, Coleóptera SAS may review the content to determine if the content provided by the third party is illegal or if it violates our policies, and Coleóptera SAS is empowered to eliminate or reject the display of said content, which does not mean that Coleóptera SAS reviews content. Regarding the delivery of information collected through the automatic mechanisms indicated in the “definitions” section and that do not contain personal identification of subscribers, users and/or visitors of the page, it may be used to inform public entities, government or third parties about activity patterns, navigation, audience and general characterization of this system. In relation to the personal data of users, collected through manual mechanisms or other means, these will be processed in order to improve the quality of Coleóptera SAS information and create a more precise advanced digital profile of the “USER”; for your advanced Digital Profile. V. Customer Support and Service It refers to any support or advice provided to the user by virtue of their participation in Coleóptera SAS through its portal. Coleóptera SAS guarantees that support to users will be provided with diligence and professional skills, keeping in mind that the response time for each request or request may take up to fifteen (15) business days counted from the day following receipt of the request. petition or request, depending on the severity of the case as indicated by Law 1755 of 2015, Statutory Law of the Fundamental Right to Petition. SAW. Use of the platform Coleóptera SAS reserves the right to eliminate and activate Users for the use of the platform, those who demonstrate harmful behavior for the entrepreneurship community and/or use offensive language in the forums and communications services provided by the platform. . The User may only use the Coleóptera SAS platform under the terms of this personal data processing policy. Consequently, the user may not reverse engineer, decompile, disassemble or circumvent the technical limitations of the product, unless applicable law allows it despite this limitation. Likewise, the user may not deactivate, alter or, in any other way, try to circumvent any security mechanism with the intention of knowing, altering and/or attacking the security of the information and services provided by Coleóptera SAS. Likewise, the user may not upload, send or otherwise transmit any content that may be contrary to the law, public order, harmful, abusive, derogatory, defamatory, vulgar, obscene, invasive or private, racist, xenophobic, or any objectionable behavior. Nor may you upload, send or transmit any content without legally accrediting the necessary rights to do so (for example, information within a company, proprietary and confidential learned or disclosed as part of employment relationships or under the terms of a contract agreement). ). Likewise, the User is prohibited from sending, uploading or transmitting any commercial or advertising content. The user is the owner of the information collected by Coleóptera SAS under this data processing policy but not of the inferences made by the platform using its publicly available information; Coleóptera SAS is the owner of all inferences, conclusions, calculations , suggestions and others information produced by the platform for “USERS”. Finally, the user may not upload, send or transmit any material that contains viruses or any computer code such as files or programs designed to interrupt, destroy or limit the functionality of any software, hardware or telecommunications equipment. VII. Responsibility for the use and information of user accounts on the Coleóptera SAS platform Users shall be responsible for maintaining the confidentiality of any non-public authentication credentials related to their use of the Services. Likewise, the User will also be responsible for providing correct, truthful, reliable and verifiable information, with the understanding that the work of Coleóptera SAS is limited to collecting the information provided by the owner of the information. Coleóptera SAS will use and process the personal data contained in its databases correctly, avoiding unauthorized access to third parties who may know or violate, modify, disclose and/or destroy the information stored there. In this sense, Coleóptera SAS has security protocols and access to information, storage and processing systems, including physical measures to control security risks. Likewise, access to the different databases is restricted even for officials and contractors of Coleóptera SAS. Likewise, all Coleóptera SAS collaborators have been instructed about this personal data processing policy within the Coleóptera SAS platform The personal information provided by the Users of the Coleóptera SAS platform is secured by an access code that only the User can access and that only he or she knows; The User is solely responsible for the management of said password. Without prejudice to the measures adopted to guarantee the security of the information stored in the databases, Coleóptera SAS is not responsible for any consequences derived from improper or fraudulent entry by third parties into the database and/or for any technical failure. in operation. VIII. Rights of the owners of the information. At all times, the user may exercise the rights recognized by Statutory Law 1581 of 2012, especially those contemplated in article 8, namely: Know, update and rectify your personal data in front of the Data Controllers or Data Processors. This right may be exercised, among others, against partial, inaccurate, incomplete, fragmented, misleading data, or those whose Processing is expressly prohibited or has not been authorized; Request proof of the authorization granted to the Data Controller except when it is expressly excepted as a requirement for the Treatment, in accordance with the provisions of article 10 of Law 1581 of 2012; Be informed by the Data Controller or Data Processor, upon request, regarding the use that any of these have given to your personal data; Submit complaints to the Superintendency of Industry and Commerce for violations of the provisions of this law and other regulations that modify, add or complement it; Revoke the authorization and/or request the deletion of the data when the processing does not respect constitutional and legal principles, rights and guarantees. The revocation and/or deletion will proceed when the Superintendence of Industry and Commerce (SIC) has determined that in the Treatment the Controller or Processor has engaged in conduct contrary to the law and the Constitution; Free access to your personal data that has been processed. To exercise their rights, the user may contact Coleóptera SAS, located at AV CARRERA 45 108 27, Bogotá, Colombia. You can also send an email to the address mauricio@coleoptera.com IX. Persons to whom information may be provided The information that meets the conditions established by law may be provided to the following people: To the owners, their successors (when those are missing) or their legal representatives. To public or administrative entities in the exercise of their legal functions or by court order. To third parties authorized by the owner or by law. X. Duties of Coleóptera SAS as responsible and in charge of processing personal data In the processing and protection of personal data, Coleóptera SAS will have the following duties, without prejudice to others provided for in the provisions that regulate or come to regulate this matter: Guarantee the holder, at all times, the full and effective exercise of the right of habeas data. Request and keep a copy of the respective authorization granted by the owner for the processing of personal data. Duly inform the owner about the purpose of the collection and the rights granted to him by virtue of the authorization granted. Preserve the information under the security conditions necessary to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access. Guarantee that the information is true, complete, accurate, up-to-date, verifiable and understandable. Timely update the information, thus addressing all new developments regarding the owner's data. Additionally, all necessary measures must be implemented so that the information is kept up to date. Rectify information when it is incorrect and communicate what is pertinent. Respect the security and privacy conditions of the owner's information. Process queries and claims made in the terms established by law. Identify when certain information is under discussion by the owner. Inform at the request of the owner about the use given to their data. Inform the data protection authority when violations of security codes occur and there are risks in the administration of the owners' information. Comply with the requirements and instructions issued by the Superintendency of Industry and Commerce on the particular topic. Only use data whose processing is previously authorized in accordance with the provisions of Law 1581 of 2012. Ensure the appropriate use of the personal data of children and adolescents, in those cases in which the processing of their data is authorized. Register in the database the legend "claim in process" in the manner in which it is regulated by law. Insert the legend "information under judicial discussion" into the database once notified by the competent authority about judicial processes related to the quality of personal data. Refrain from circulating information that is being controversial by the owner and whose blocking has been ordered by the Superintendence of Industry and Commerce (SIC). Allow access to information only to people who can have access to it. Use the personal data of the owner only for those purposes for which it is duly authorized and respecting in all cases the current regulations on the protection of personal data. XI. Responsibility of Coleóptera SAS Except as expressly established in these conditions or in additional conditions, neither Coleóptera SAS, nor its allies, nor its suppliers or distributors make any specific promise about the services. In this way, Coleóptera SAS does not assume any commitment regarding the content of the services, the specific function of the services, or their reliability, availability or ability to satisfy your needs, therefore, the services are provided “as is”. XII. Authorization. At the time of using the Coleóptera SAS platform, Users declare that they have carefully read, know and accept this Personal Data Processing Policy, in accordance with the provisions of the current regulations applicable to the matter. Therefore, to register as a User on the platform, you must accept the Personal Data Processing Policy of Coleóptera SAS, a requirement without which you will not be able to complete the registration. In any case, the authorization requested must be prior to the processing of personal data. Proof of the authorization may be recorded in physical or electronic files, provided that the record of the form of authorization, date and time of the authorization can be determined. In the case of minors, it must be taken into account that the processing of personal data of children and adolescents is prohibited except when it involves data of a public nature, and when said processing meets the following parameters and/or requirements: a) that they respond and respect the best interests of children and adolescents; b) that respect for their fundamental rights is ensured. XIII. Revocation of authorization. The owners of personal data may, at any time, revoke the authorization granted to Coleóptera SAS and its allies for the processing of their personal data or request its deletion, as long as it is not prevented by a legal or contractual provision. Coleóptera SAS will establish simple and free mechanisms that allow the owner to revoke their authorization or request the deletion of their personal data, at least by the same means by which it was granted. For the above, it must be taken into account that the revocation of consent can be expressed entirely in relation to the authorized purposes and, therefore, Coleóptera SAS must cease any data processing activity. On the other hand, the revocation of the authorization may also be partial in relation to certain types of processing, in which case these will be the ones on which the processing activities will cease, such as for advertising purposes, among others. In the latter case, Coleóptera SAS may continue processing personal data for those purposes in relation to which the owner has not revoked his or her consent. XIV. Events in which the authorization of the owner of the personal data is not necessary The authorization of the owner of the information will not be necessary when it comes to: Information required by a public or administrative entity in the exercise of its legal functions or by court order. Public data. Medical or health emergency cases. Processing of information authorized by law for historical, statistical or scientific purposes. Data related to the Civil Registry of people. Creation of anonymous groups or groupings with inferences from the information of the “USERS” for commercial purposes, anonymizing the identity of the “USERS” of the Coleóptera SAS platform and not sharing sensitive data. Market to third parties the inferences, calculations , measurements, suggestions and others information produced from the analyzed information of the “USERS” previously anonymized the identity and sensitive data of the “USERS” XV. Processing of personal data The processing of personal data of Coleóptera SAS users will be carried out in accordance with current regulations in the Colombian legal system. So, the data collected by Coleóptera SAS may be used to carry out any of the following activities: Send information related to programs, activities, news, content by area of interest, products and other goods or services offered by Coleóptera SAS Comply with regulations applicable to suppliers and contractors, including, but not limited to, tax and trade regulations. Conduct surveys related to the services or goods of Coleóptera SAS Inform about fairs, seminars or other events at a local and international level. Fulfill all your contractual commitments. XVI. Treatment of sensitive data. As a general rule, the processing of sensitive data is prohibited and therefore, Coleóptera SAS will not request information relating, among other aspects, to: racial or ethnic origin, political orientation, religious or philosophical convictions, membership in unions, social organizations. , human rights 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. It will be understood that the criteria listed here are enunciative and not exhaustive and, consequently, any other factor may be framed as sensitive data. Likewise, it is reported that the delivery of sensitive data is the power of the owner of the information, who will not be obliged to provide it. However, in the event of collecting sensitive data with due authorization from the owner, Coleóptera SAS may use it when: The owner has given explicit authorization, except in cases where the granting of said authorization is not required by law. The treatment is necessary to safeguard the vital interest of the Owner and the Owner is physically or legally incapacitated. In these events, legal representatives must grant their authorization. The processing is carried out in the course of legitimate activities and with due guarantees by a foundation, NGO, association or any other non-profit organization, whose purpose is political, philosophical, religious or union, provided that they refer exclusively to to its members or to people who maintain regular contacts due to their purpose. In these events, the data cannot be provided to third parties without the authorization of the owner. The Treatment refers to data that is necessary for the recognition, exercise or defense of a right in a judicial process. The Treatment has a historical, statistical or scientific purpose. In this event, measures must be adopted leading to the deletion of the identity of the owners. Without prejudice to the exceptions provided for in the law, the processing of sensitive data requires the prior, express and informed authorization of the owner, which must be obtained by any means that can be subject to subsequent consultation and verification. XVII. Guarantees of access by the owner of the information to their personal data. The owner of the information may access their personal data as long as they previously prove their identity, free of charge, directly or through their representative or attorney-in-fact, in a detailed and detailed manner, including the information contained in physical or electronic files. The owner of the information will also be guaranteed the right to update their personal data whenever they wish. XVIII. Procedure for handling queries, complaints, requests for rectification, updating and deletion of personal data. In accordance with the current regulations on the matter, the procedure for meeting the different requirements that are submitted by the owner of the personal data to Coleóptera SAS is described below.

to. Inquiries: The owners or their successors may consult the personal information of the owner that resides in Coleóptera SAS, who will provide all the information contained in the individual record or that is linked to the identification of the Owner. In relation to the attention of requests for consultation of personal data Coleóptera SAS guarantees the following: Enable electronic or other means of communication that you consider relevant. Establish simplified forms, systems and other methods, which must be reported in the privacy notice. Use the customer service or complaints services that you have in operation. In any case, regardless of the mechanism implemented to respond to consultation requests, they will be responded to within a maximum period of ten (10) business days from the date of receipt. When it is not possible to attend to the query within said term, the interested party will be informed before the expiration of 10 days, expressing the reasons for the delay and indicating the date on which their query will be attended to, which in no case may exceed five days. (5) business days following the expiration of the first term. Queries can be made to the email mauricio@coleoptera.com b. Claims: The Owner or his successors who consider that the information contained in a database should be corrected, updated or deleted, or when they notice the alleged breach of any of the duties contained in the law, may file a claim with Coleóptera. SAS, which will be processed under the following rules: The Owner's claim will be formulated by means of a request addressed to Coleóptera SAS at the email mauricio@coleoptera.com or by written communication containing the identification of the owner, the description of the facts that give rise to the claim, the address, accompanying the documents provided. wish to assert and addressed to Coleóptera SAS located at AV CARRERA 45 108 27 Bogotá DC If the claim is incomplete, the interested party will be required within five (5) days following receipt of the claim to correct the deficiencies. After two (2) months from the date of the request, without the applicant presenting the required information, it will be understood that the claim has been abandoned. In the event that the person who receives the claim is not competent to resolve it, he or she will forward it to the appropriate person within a maximum period of two (2) business days and will inform the interested party of the situation. Once the complete claim is received, it will be cataloged with the label "claim in process" and the reason for it, within a period of no more than two (2) business days. This label will remain until the claim is decided. The maximum term to address the claim will be fifteen (15) business days counted 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 their claim will be addressed, which in no case may exceed eight (8) business days following the expiration of the first term. Request for update and/or rectification: Coleóptera SAS will rectify and update, at the request of the owner, the information of the owner that turns out to be incomplete or inaccurate, in accordance with the procedure and terms indicated above, for which the following will be taken into account: The owner must send the request to Coleóptera SAS by email or in physical form addressed to Coleóptera SAS located at AV CARRERA 45 108 27 Bogotá DC, indicating the update and/or rectification to be made and will provide the documentation that supports their request. Coleóptera SAS may enable mechanisms that facilitate the exercise of this right by the owner, as long as these benefit the owner. Consequently, electronic or other means that are considered relevant may be enabled, which will be informed in the privacy notice and will be made available to interested parties on the website. d. Request for data deletion: The owner of personal data has the right to request Coleóptera SAS for its deletion (elimination) in any of the following events: When you consider that they are not being treated in accordance with the principles, duties and obligations provided for in current regulations. When they are no longer necessary or relevant for the purpose for which they were collected. When the period necessary to fulfill the purposes for which the data was collected has passed. This deletion implies the total or partial elimination of personal information in accordance with what is requested by the owner in the records, files, databases or treatments carried out by Coleóptera SAS. However, this right of the owner is not absolute and consequently Coleóptera SAS may deny the exercise of the same when: The owner has a legal or contractual duty to remain in the database. The deletion of data hinders judicial or administrative actions linked to tax obligations, the investigation and prosecution of crimes or the updating of administrative sanctions. The data is necessary to protect the legally protected interests of the owner; to carry out an action based on the public interest, or to comply with an obligation legally acquired by the owner. XIX. National Registry of Coleoptera SAS Databases In accordance with the provisions of current regulations, Coleóptera SAS will register the databases under its charge in the national registry of databases maintained by the Superintendence of Industry and Commerce (SIC). XX. Information security and security measures. In compliance with the security principle established in current regulations, Coleóptera SAS will adopt the technical, human and administrative measures that are necessary to provide security to the records, preventing their adulteration, loss, consultation, unauthorized or fraudulent use or access. XXI. Use and international transfer of personal data and personal information by Coleóptera SAS Coleóptera SAS in compliance with the functions assigned in Resolution 3361 of 2017, as well as in the regulations that modify or replace it and, taking into account the nature of the permanent or occasional relationships that any person holding personal data may have with Coleóptera SAS. , may carry out the transfer and transmission, even internationally, of all personal data, as long as the applicable legal requirements are met and, consequently, the owners, with the acceptance of this policy, expressly authorize the transfer and transmission, even internationally, personal data. In that case, personal data will be transferred, for all relationships that may be established with Coleóptera SAS.
For the international transfer of personal data of the owners, Coleóptera SAS will take the necessary measures so that third parties are aware of and agree to observe this policy, with the understanding that the personal information they receive may only be used for matters directly related to Coleóptera SAS and only while it lasts and cannot be used or destined for a different purpose or purpose. In the case of international transfer of personal data, the provisions of article 26 of Law 1581 of 2012 will be observed. On the other hand, international transmissions of personal data carried out by Coleóptera SAS will not require the owner to be informed or have his consent when there is a contract for the transmission of personal data in accordance with article 25 of Decree 1377 of 2013. Finally, Coleóptera SAS may also exchange personal information with governmental or other public authorities (including, among other judicial or administrative authorities, tax authorities and criminal, civil, administrative, disciplinary and fiscal investigation bodies), and third parties participating in procedures. civil legal representatives and their accountants, auditors, lawyers and other advisors and representatives, when necessary: to comply with applicable laws, including laws other than those of your country of residence; to comply with legal processes; to respond to requests from public and government authorities, and to respond to requests from public and government authorities other than those in your country of residence; to enforce our terms and conditions; to protect our operations; to protect our rights, privacy, safety or property, yours or others; and obtain the applicable compensation or limit the damages that may affect us.