POLICY ON THE PROCESSING OF PERSONAL DATA INMOBILIARIA PROACTIVA S.A. - PROJECT CARMEN APARTMENTS CAMPESTRES

Last update: December 4, 2020

Company name: INMOBILIARIA PROACTIVA S.A.
Nit: 811.023.187-1
Address: CRA 43 A- 1 A Sur 69 Medellín, Antioquia Telephone: (4) 4482011.
Emails: info@carmen.com.co and info@proactiva.co
Website: project.carmen.com.co and www.carmen.com.co

1. POLICY:

INMOBILIARIA PROACTIVA S.A. establish procedures, measures and controls in order to treat adequate to the personal data of its holders, in compliance with the General Data Protection Regime Personal, established in the applicable legal system.

2. REGULATION:

The personal data treatment policy is prepared in accordance with the Political Constitution, the Law 1581 of 2012, Regulatory Decree 1377 of 2013 and other provisions that complement it.

3. APPLICATION:

INMOBILIARIA PROACTIVA S.A. will apply these policies, against the information to which it accesses, collects, stores, uses, shares and updates and in general of that information that involves processing of personal data, in the development of their professional activity.

4. GLOSSARY:

For the purposes of this policy and in accordance with the regulations applicable to the matter, the following are included following definitions:
a) Authorization: Prior, express and informed consent of the Holder to carry out the Data Processing personal; for b) Privacy notice: Physical, electronic document or in any other format generated by the Responsible Party that is makes available to the Holder for the treatment of her personal data. In the Privacy Notice, the Holder of the information regarding the existence of the information treatment policies that will be applicable, the way to access them and the purpose of the treatment that is intended to give the personal data; for c) Database: Organized set of personal data that is subject to Treatment; for d) Personal data: Any information linked or that may be associated with one or more natural persons determined or determinable; for e) Public data: It is the data classified as such according to the mandates of the law or the Political Constitution and that what not be semi-private, private or sensitive. The data relating to the marital status of the persons, to his profession or trade, to his quality of merchant or public servant and those that can be obtained without reservation any. By its nature, public data may be contained, among others, in public records, documents public, gazettes and official gazettes; for f) Private data: It is the data that due to its intimate or reserved nature is only relevant for the owner; for g) Sensitive data: Sensitive data is understood to be those that affect the privacy of the Owner or whose use improper may generate your discrimination, such as those that reveal racial or ethnic origin, political orientation, religious or philosophical convictions, membership in trade unions, social organizations, human rights or that promotes the interests of any political party or that guarantees the rights and guarantees of parties politicians opposition, as well as data related to health, sexual life and biometric data; for h) Company - Company: Inmobiliaria Proactiva S.A. for i) Responsible for the Treatment: Natural or legal person, public or private, that by itself or in association with others, carry out the Processing of personal data on behalf of the Data Controller; for j) Responsible for the Treatment: Natural or legal person, public or private, that by itself or in association with others, decide on the database and / or the treatment of the data; for k) Owner: Natural person whose personal data are subject to Treatment; for l) Treatment: Any operation or set of operations on personal data, such as the collection, storage, use, circulation or deletion of the same.

5. GUIDING PRINCIPLES FOR TATAM IENTO OF PERSONAL DATA:

The following principles shall be applied in a harmonious and comprehensive manner:

a) Principle of legality regarding data processing: The processing of personal data must be subject to the established in the applicable legislation on the matter; for b) Principle of purpose: The Treatment must obey a legitimate purpose in accordance with the Constitution and the Law, which must be informed to the Holder; for c) Principle of freedom: Treatment can only be exercised with the prior, express and informed consent of the Headline. Personal data may not be obtained or disclosed without prior authorization, or in the absence of a mandate. legal or judicial that relieves consent; for d) Principle of veracity or quality: The information subject to Treatment must be truthful, complete, accurate, updated, verifiable and understandable. The Processing of partial, incomplete, fractioned data or that induces error; for e) Principle of transparency: Treatment must guarantee the right of the Holder to obtain from the Responsible of Treatment or the Person in Charge of Treatment, at any time and without restrictions, information about the existence of data concerning you; for f) Principle of access and restricted circulation: The Treatment is subject to the limits derived from the nature of personal data, of the provisions of applicable laws and the Constitution. Personal data, except the public information, will not be published on the Internet or other means of dissemination or mass communication, unless the access is technically controllable to provide restricted knowledge only to the Holders or authorized third parties according to the applicable regulations; for g) Principle of security: The information subject to Treatment by the Responsible or Manager, must be handled with the 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; for h) Principle of confidentiality: All persons involved in the Processing of personal data who do not have the nature of the public are obliged to guarantee the reservation of information, even after finished their relationship with any of the tasks that the Treatment comprises, being able to only supply or communicate of personal data when this corresponds to the development of the activities authorized in the applicable legislation and in the terms of it.

6. PURPOSE WITH WHICH THE COLLECTION OF PERSONAL DATA AND TREATMENT OF THE SAME IS CARRIED OUT:

PROACTIVA S.A may use personal data for:

a) The correct provision of its services, in the development of its corporate purpose, the foregoing implies the administration of direct contractual and non-contractual relationships, as well as those where he acts as a partner, contractor or Settlor.
b) The administration of the relationship with its suppliers and employees; for c) Carrying out commercialization, promotion and marketing tasks, for the offering of their goods and services and the improvement in the provision of the latter; for d) Maintain constant communication with the owners of personal data; for e Inform about new products or services and / or modifications in them; for f) Carry out processes of knowledge of potential clients or update information of their clients or users; for g) Consult database centrals or Information and Risk Operators, or any other entity that manages or manage databases and reports of credit capacity and behavior; for h) Report to the information centers mentioned in the previous paragraph the behavior (present, past and future) of the clients, indebtedness, and especially the birth, modification, extinction of the obligations contracted with the Business; for i) Send to physical, electronic mail, social networks or mobile device, via text messages (SMS and / or MMS) or through any other means of communication existing or that will come to exist, institutional information, advertising or commercial information about the products and / or services of the Company, its commercial partners or projects in which participates; for j) Carry out studies, research and market, financial, statistical and risk reports, among others; for k) Develop the process of selection, evaluation, and employment relationship; j) Evaluate the quality of services or products supplied; for l) Supply, share, send or deliver your personal data to insurance companies, legal advisors, providers of software, tax authorities, subcontractors that process, administer or use the information, in the event in what said companies require the information for the purposes indicated here, in which case the need to to protect said personal information and maintain the obligation of confidentiality about it; for m) Disclose and deliver customer information in case of portfolio sale or assignment of obligations, in the case of which the Assigned obligations retain legal actions and may be exercised by the assignee of the obligation. for n) Those indicated in the authorization granted by the data owner or described in the privacy notice respective, according to the case. for o) General compliance with the legal and contractual obligations that assist the company. for

7. RIGHTS OF THE OWNER OF PERSONAL DATA:

a) Know, update and rectify your personal data in front of INMOBILIARIA PROACTIVA S.A. This right may be exercise, among others, against partial, inaccurate, incomplete, fractioned, misleading data, or those whose treatment is expressly prohibited or has not been authorized; for b) Request proof of authorization, except when expressly excepted by law; for c) Be informed regarding the use that has been given to personal data, upon express request by the headline; for d) Present before the Superintendency of Industry and Commerce complaints for infractions to the provisions of the legislation
applicable to the processing of personal data
e) Right to require compliance with the orders issued by the Superintendency of Industry and Commerce. for f) Free access to personal data that have been subject to Treatment.
for PARAGRAPH: In order to enforce the rights of the owner, INMOBILIARIA PROACTIVA S.A. will request your identity or that of whoever represents their rights and the legal support of said representation. for INMOBILIARIA PROACTIVA S.A. will refrain from marketing, disclosing, publishing, personal data, unless exist express authorization to do so, is necessary to fulfill the functions and obligations that are in the head of INMOBILIARIA PROACTIVA S.A. by virtue of any contractual or commercial relationship, or that said functions and obligations have been entrusted to a contractor, when a merger, spin-off, acquisition, or any other process of restructuring of the company or it participates as a partner in a project, and is responsible for treating data personal. for INMOBILIARIA PROACTIVA S.A. collect, store, use and / or circulate personal data for as long as be reasonable and necessary, in accordance with the provisions applicable to the matter, with the purposes that justify the Treatment and taking into account the duties, obligations and legal or contractual relationships that the Headlines, for the purpose of whether or not they must remain in the company's databases.

8. DUTIES:

INMOBILIARIA PROACTIVA S.A. is obliged to comply with the duties imposed by the applicable regulations regarding the processing of personal data, when you act:
for I) As Responsible for the treatment: (a) Guarantee the Holder the exercise of the right to habeas data; (b) Request and keep, under the conditions set forth herein, a copy of the respective authorization granted by the owner; (c) Report clearly to the owner about the purpose of the collection and the rights that assist him under the authorization granted and the use that will be given to your personal data; (d) Keep the information under secure conditions what prevent their adulteration, loss, consultation, use or unauthorized or fraudulent access; (e) Update information of the holders and rectify it when it is incorrect; (f) Process inquiries and claims made by the Headlines of the information; (g) Ensure that the principles of veracity, quality, security and confidentiality in the terms established in the following policy; (h) Demand respect for the security and privacy conditions of the information of the Holder and Inform the data protection authority when there is a violation of the security of the herself and when there are risks in the administration of the information; (i) Comply with the instructions and requirements that impart theSuperintendency of Industry and Commerce. for II) As Managers of the processing of personal data, when it comes to carry out the treatment on behalf of another entity or organization (Responsible for the treatment) must: a) Guarantee the Holder, the exercise of the right of habeas data; b) Keep the information under the necessary security conditions to prevent its adulteration, loss, query, unauthorized or fraudulent use or access; c) Timely update, rectify or delete the data in the terms of this law; updating the information reported by those in charge of the Treatment, It must be carried out within five (5) business days counted from its receipt; d) Process inquiries and the claims made by the Holders in the terms indicated in the applicable legislation; e) Register in the database of data in the legend "claim in process" in the manner in which it is regulated in the applicable regulations; f) Insert in the base of data the legend "information in judicial discussion" once notified by the competent authority on judicial processes related to the quality of personal data; g) Refrain from circulating information that is being controversial by the Holder and whose blocking has been ordered by the Superintendency of Industry and Commerce; h) Allow access to information only to people who can have access to it; i) Inform the Superintendency 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; j) Comply with the instructions and requirements issued the Superintendency of Industry and Commerce.

9. REQUEST FOR AUTHORIZATION TO THE HOLDER OF PERSONAL DATA:

Previously and / or at the time of collecting personal data, INMOBILIARIA PROACTIVA S.A. will request authorization to the owner of the data, for its collection and treatment, communicating the purpose of its obtaining, to through automated technical means, oral or written, that allow to keep proof of authorization and / or the unequivocal conduct described in article 7 of Decree 1377 of 2013.

10. RESPONSIBLE AREA AND PROCEDURE FOR THE EXERCISE OF THE RIGHTS OF THE HOLDERS OF PERSONAL DATA:

Administrative will be responsible for meeting the requests, complaints and claims of the owners of the data, of according to the rights that correspond to it according to numeral 7 of this policy and the legislation applicable.
for The owner of the personal data or whoever represents him may submit his request, complaint or claim from Monday to Friday from 8:00 a.m. to 5:00 p.m. to the email info@proactiva.in or contact the telephone line of INMOBILIARIA PROACTIVA S.A, Medellín telephone (4) 4482011, or place it at our office at the address: Calle 43 A N # 1 A Sur-69 Ofc 203 Edificio Tempo. This complaint will be resolved by the responsible for area, in charge of handling the owner's data, according to the quality in which he acts in front of the company, of agreement to its different lines of business (client, tenant, owner, etc.). for The petition, complaint or claim must contain the identification of the Holder, the detailed facts in which I know supports the same, contact information, such as address, telephone and email, along with the documents (annexes) that he considers important. If incomplete or inaccurate information is presented, the interested party will be required within the five (5) business days after receipt of the request, complaint or claim to correct or complete the herself. If after two (2) months from the date of the request, the applicant does not correct or submit the information required, it will be understood that he has withdrawn the request. Once the complete request is received, it will be included in the data the legend "claim in process" and the reason for it, in a term that will not exceed three (3) business days. Bliss legend must be maintained until the claim is resolved. The maximum term to meet the requirement will be fifteen (15) business days from the day following the date the information was received complete and correct. When it is not possible to address the claim within said period, the interested party will be informed of the reasons of the delay and the date in which your request will be attended, which in no case may exceed eight (8) days skillful following the expiration of the first term mentioned above.

11. SECURITY MEASURES:

In development of the security principle established in Law 1581 of 2012, INMOBILIARIA PROACTIVA S.A. will adopt the technical, human and administrative measures that are necessary to provide security to the records avoiding its adulteration, loss, consultation, use or unauthorized or fraudulent access. The personnel who carry out the treatment of personal data will execute the protocols established in order to guarantee the security of the information. Additionally, audits will be established for the purposes of monitoring compliance with the policy and procedures derived from its implementation.

12. DATE OF ENTRY INTO EFFECT:

The Personal Data Policy becomes effective as of December 4, 2020. Any changes made present regarding this policy, you will be informed through the electronic address: www.proactiva.co