Privacy Policy

PERSONAL DATA PROTECTION POLICY

+ Green Lots

Personal Data Protection Policy - + Green Lots

1. Scope: This policy applies to + Verde Lotes
2. Object: The purpose of this document is to regulate the policies and procedures that will be applicable to the handling of personal data by the Companies, in accordance with the provisions contained in Law 1581 of 2012 and Decree 1377 of 2013.
3. Data controllers: Company Name Main Office Telephone Fax Website Email Contact Person, + Verde Lotes Carrera 41 aa# 18 b sur 36 Office 102, gerencia@masverdelotes.com

It is regulated by applicable personal data protection regulations. Processing to which personal data will be subjected and the purpose of the processing: Processing is any operation or set of operations on personal data, such as collection, storage, retention, recording, use, circulation, or deletion. The information collected by the Companies in the provision of their services and in general in the development of their corporate purpose, is mainly used to identify, maintain a record and control of suppliers, clients, shareholders, contractors, employees of the Companies, in order to comply with the obligations arising from the legal, commercial, contractual or any other relationship that exists with the Companies, as well as the enforceability of the rights that the parties have by virtue of the same, to keep the owners of personal data informed regarding the goods and services provided by the Companies, to send them advertising, commercial and marketing information, events and in general information related to the development of the corporate purpose of the Companies and finally to transfer personal data to third parties designated by them for the provision of the services offered and the enforceability of the rights generated by virtue of the existing legal, contractual or commercial relationship.

General processing and purposes of information:

– Processing and confirmation of personal data.

– Provide services and/or products purchased directly or with the participation of third parties. – Promote and advertise our activities, products, and services.

– Carry out derived accounting and administrative transactions
from the ordinary course of business of the Company.
– Make reports with the different national administrative control and surveillance authorities, police or judicial authorities, entities
Financial and/or insurance companies. – Internal administrative and/or commercial purposes such as market research, audits, accounting reports, statistical analysis, or billing.
– Carry out accounting records relating to operations carried out in the course of business of the companies.
– Sending and receiving correspondence.
– Fraud identification and prevention of money laundering and other criminal activities.

Regarding information for Shareholders and Board members: – Control of shareholding and publication of the shareholders with the largest stake in accordance with the regulations issued for this purpose by the Colombian Financial Superintendency.
– Compliance with judicial decisions and administrative, legal, fiscal, and regulatory provisions.
– Compliance with legal obligations and exercising the rights arising from the status of shareholder and member of the Board of Directors of the Companies.
– Sending information related to the Companies, as well as calls for meetings of the General Shareholders' Meeting and the Board of Directors.

Regarding information from suppliers and creditors:
– Compliance with judicial decisions and administrative, legal, fiscal, and regulatory provisions.
– Compliance with contractual obligations and enforceability of rights arising from the contractual relationship, for which reason information may be transferred to third parties, such as financial institutions, notaries, restrictive lists for the prevention of money laundering and terrorist financing, lawyers, among others.

– Consultation of the supplier against restrictive lists for the prevention of money laundering, criminal records, and other public information considered relevant to assessing the suitability of contracting the supplier.
– Carrying out the accounting and administrative processes in which suppliers are involved.

– Transmission of information and personal data in audit processes.
– Collection, storage, and use of personal information of employees and contractors of suppliers for the purpose of fulfilling obligations arising from the contractual or legal relationship existing with them.

– Any other use that the supplier or creditor authorizes in writing for the use of your information.

Regarding customer and visitor information:
– Sending commercial, advertising and marketing information.

– Compliance with contractual or legal obligations, for which reason information may be transferred to third parties, such as financial institutions, notaries, restrictive lists for the prevention of money laundering and terrorist financing, lawyers, among others.

– Compliance with judicial decisions and administrative, legal, fiscal, and regulatory provisions.
– Transmission of information and personal data in audit processes.
– Billing for goods and services provided by the Companies to customers

– Access control and video surveillance of visitors to the Companies' facilities as a security measure.

Regarding information on employees, retired workers, pensioners, and candidates for vacancies:

– For purposes relevant to the employment relationship (Affiliation and compliance with obligations arising from affiliation with EPS, ARL, pension and severance funds, family compensation funds, among others)
– Compliance with judicial, administrative and legal requirements.

– Payroll accounting and payment.
– Recruit and select personnel to fill vacancies, either directly or through third parties contracted for this purpose.

– Process, confirm, and comply with legal and extralegal labor obligations arising from the employment contract.
– Make transactions.
– Payment of extra-legal benefits.

– Conducting audits and skills assessments for our employees and candidates for vacancies.
– Consultation of employees and candidates for vacancies on restrictive lists for money laundering and terrorist financing

– Statistical analysis.
– Development of training and development programs directly or through third parties contracted for this purpose.
– Sharing personal data with banks and other companies that offer benefits and wellness programs to our active employees, among others.

The Company recognizes the importance of the security, privacy and confidentiality of the personal data provided by individuals and is therefore committed to its protection and proper handling, in accordance with the legal regime for the protection of personal data and in particular as provided in this policy. Therefore, only Company officials who, by virtue of their position, must know and use it to fulfill the purposes indicated will have access to the information contained in the aforementioned databases.

The Companies will retain the personal information of the data subjects in the aforementioned databases as long as it is used to fulfill the purpose indicated in this policy. Once such use ends, the information will be blocked in the Company's information system, remaining only as historical data of the transactions carried out with the data subject, but no transactions or use of said data may be made.

The above is a security measure against potential fraud and in accordance with the principle of comprehensiveness of the information system that the Company has adopted for the purposes of managing its operations.

4. Rights of the Holder: The Data Subject is a natural person whose personal data is collected, stored, or used by the Data Controller. The Data Subject shall have the following rights: a) To know, update, and rectify their personal data with the Data Controller when the data is partial, inaccurate, incomplete, fragmented, or misleading. In all cases, the Data Subject is obligated to provide truthful information. b) To request proof of the authorization granted to the Data Controller, unless expressly exempted as a requirement for processing. c) To be informed, upon request addressed to the Data Controller, regarding the use that has been given to their personal data. d) To file complaints with the Superintendency of Industry and Commerce for violations of the provisions of Law 1581 of 2012 and its regulatory decrees and other regulations that modify, add to, or complement it. e) Revoke authorization and/or request deletion of data when the processing does not respect constitutional and legal principles, rights, and guarantees, provided that the Data Subject does not have a legal or contractual obligation to remain in the database. f) Access free of charge to your personal data that has been processed by the Controller.
5. Procedure for inquiries, data updates, and complaints. Inquiries : : The Holders or their successors in title may consult the Holder's personal information that is stored in the Companies' database. The query must be submitted in writing to the address Carrera 41 aa # 18b sur 36 office 102. The query will be answered within a maximum period of ten (10) business days from the date of receipt thereof. When it is not possible to answer 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 answered, which in no case may exceed five (5) business days following the expiration of the first term. Claims: The Holder or their successors in title who consider that the information contained in the + Verde Lotes database should be subject to correction, updating or deletion, or when they notice the alleged non-compliance with any of the duties contained in this document or in the law, may file a claim. The claim will be made by means of a request to the address Carrera 41 aa # 18b sur 36 office 102, which must include: name and identification of the Holder, the description of the facts that give rise to the claim, the address, email, and accompanying the documents that you want to assert.

If the claim is incomplete, the interested party will be required to correct the deficiencies within five (5) days of receipt. After two (2) months from the date of the request, if the applicant does not submit the required information, it will be understood that the claim has been withdrawn. Once the complete claim has been received, a legend stating "claim in process" and the reason for it will be included in the database within a period of no more than two (2) business days. This legend must remain in effect until the claim is decided.

The maximum term for addressing 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 this 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. Requirement of admissibility. The Holder or legal successor may only file a complaint with the Superintendency of Industry and Commerce once they have exhausted the consultation or claim process with the Companies.

6. Changes to the privacy policies: The Companies reserve the right to make changes or updates to this Privacy Policy at any time to address legislative developments, internal policies, or new requirements for the provision or offering of their services or products. These changes will be publicly available on the website www.masverdelotes.com.
7. Acceptance: Data Subjects agree to the processing of their personal data in accordance with the terms of this policy when providing their data.
8. Validity: This General Privacy Policy is effective from the date of its publication in September 2023.

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