FINUP COLOMBIA SAS PRIVACY NOTICE

In order to comply with current data protection legislation, we inform you that FINUP COLOMBIA SAS, hereinafter referred to as FINUP, a legally constituted commercial company with its registered office in Bogotá, D.C., and considered the controller and/or processor of personal data, has developed its PERSONAL DATA PROCESSING POLICY. This policy outlines the company's policies governing the processing of your data, the purpose of the processing, your rights as the data subject, and the legal mechanisms for exercising those rights. This policy will be available on the company's website at the following link: https://finupcolombia.co/nuestro-sistema/ or upon written request addressed to FINUP or to the email address provided in this document. FINUP also informs that the Data Subject has the right to privacy of their personal data. Therefore, the Data Subject is informed that the personal data collected is stored using secure and reliable technological means. FINUP acts diligently in its use and preservation, ensuring the prevention and avoidance of risks such as theft and data leakage. The following processing activities will be carried out: (i) Collecting, storing, and verifying personal data (name, identification, telephone number, email address, contact address); (ii) Using or circulating personal data for the time that is reasonable and necessary; (iii) Transferring personal data to third parties for marketing purposes or the execution of the platform, especially to natural language processors or third-party technology providers and contractors for the proper provision of the service, who will act as Data Processors, in accordance with the purposes authorized by our data processing policy. (iv) to verify data to ensure its suitability and/or to process payments, as well as for the operation of the platform itself, and to share/consult information with credit bureaus if necessary; (v) to update and delete information if it is no longer needed. FINUP will process the collected data for the following purposes: (i) For storage in FINUP databases; (ii) To execute the existing contractual relationship with its clients, contractors, and employees, including the payment of contractual obligations, in particular, the development of platform operations, the preparation of documents, digital or electronic signatures, and for data processing for natural language applications (ChatGPT or other providers); (iii) To ensure the effectiveness and security of transactions carried out with FINUP; (iv) To ensure the protection and exercise of its rights, as well as those of FINUP and/or its contractors, to the extent possible in accordance with the processing carried out by FINUP; (v) To fully comply with the contracted services; (vi) to carry out activities necessary to manage inquiries and complaints submitted and direct them to the responsible area; (vii) to send information on commercial offers of FINUP services, as well as to develop marketing, statistical, research, commercialization, and/or other commercial service purposes that are provided or that may be provided or offered, provided that they do not contravene Colombian legislation, especially Law 2300 of 2023, with which the Data Subject may modify the frequency and segmentation of advertising and commercial messages; (viii) to strengthen commercial relationships by sending relevant information, advice, attending to requests, complaints and claims, as well as to carry out quality evaluations; (ix) to verify balances, proceed to invoice and collect contracted services; (x) to verify compliance with legal and/or contractual obligations; (xi) to improve and promote the service provided by FINUP; (xii) to address judicial or administrative requests and to comply with judicial or legal mandates; (xiii) to transmit personal data to third parties with whom contracts have been entered into for the purpose of performing and fulfilling the service offered through FINUP; (xiv) to manage all the information necessary for compliance with tax obligations and commercial, corporate, and accounting records; (xv) to send information about new products or services, news, and other information that FINUP deems appropriate. FINUP will ensure that the policies of third parties have standards similar to those of its Data Processing Policy, through the signing of agreements, contracts, and/or other contracts. Every User of the FINUP platform, in any of its functionalities, accepts the processing of their personal data when using the platform, including their personal information, contact information, financial information, biometric data, their face if necessary, as well as the processing of their identity document or identification data, whether they are a natural or legal person. Regarding sensitive data, FINUP will only collect this type of data with prior authorization, when such authorization is necessary and proportionate for the execution of the contractual relationship between the User and the third parties from whom the required products and/or services are purchased and offered, provided that the law permits access to sensitive information. The Data Subject acknowledges and accepts that their personal data may be made available to the personnel in charge of the corresponding area within FINUP's internal structure in strict accordance with the contractual relationship and the purposes of the processing, without excluding the possibility of transferring it to Processors, consultants, advisors, external persons, and offices as necessary to fulfill the aforementioned purposes. At any time, the Data Subject may exercise the rights granted by law, including: (i) knowing, updating, and rectifying their personal data with the data controllers or data processors; (ii) requesting proof of the authorization granted to the data controller, except when expressly exempted as a requirement for processing, in accordance with the provisions of current legislation; (iii) to be informed by the data controller or processor, upon request, regarding the use given to their personal data; (iv) to revoke authorization and/or request the deletion of data when the processing does not respect constitutional and legal principles, rights, and guarantees; (v) to file complaints with the Superintendency of Industry and Commerce for violations of the provisions of Law 1581 of 2012; and (vi) to access their personal data that has been processed, free of charge. Likewise, the Data Subject may access or consult the Personal Data Processing Policies, as well as the consultation and complaint procedures that will allow them to exercise their rights to access, consultation, rectification, updating, and deletion of data by sending a communication to FINUP, located at Carrera 15 93 A 62 Office 601 Bogotá, Colombia, or to the email address info@finupcolombia.co.