INFORMATION TREATMENT POLICY
PURNIMA S.A.S.

PURNIMA S.A.S., identified with NIT 900.465.720-5, located at Carrera 15 No. 88 – 64 Office 322, Bogotá D.C., whose website is: https://timemanagerweb.com/, and telephone: + 57 (1) 718 5774, whose main purpose is to provide technological solutions to professional services firms.

Since Law 1581 was issued on October 17, 2012, by which general provisions for the protection of personal data in Colombia were issued, based on its provisions and its regulatory decrees, PURNIMA S.A.S. has adopted this policy, which informs its shareholders, customers, subscribers, suppliers and/or contractors, candidates for employees, employees, former employees and the general public, in order to sufficiently inform about its content…

CHAPTER I

DEFINITIONS

• Time Manager: IT solution that provides registration, billing and collaboration services for professional services firms.</ li>

• National Authority for the Protection of Personal Data: It is the Superintendence of Industry and Commerce – Delegation for the Protection of Personal Data.

• Authorization: Prior, express and informed consent of the Information Owner to carry out the Processing of personal data. It will be understood that the authorization meets these requirements when it is manifested (i) in writing, (ii) orally or (iii) through unequivocal conduct by the Holder that allows for the reasonable conclusion that the authorization was granted</li >

• Database: Organized set of personal data that is subject to Processing.

• Personal data: Any information linked to or that can be associated with one or more specific or determinable natural persons.

• Data Processor: Natural or legal person, public or private, who by themselves or in association with others, performs data processing on behalf of the Data Controller.

• Data Controller: Natural or legal person, public or private, who by himself or in association with others, decides on the basis of data and/or data processing.

• Information Holder: Natural person whose personal data is subject to Treatment. For example: shareholder, client, subscriber, supplier and/or contractor, employee, among others.

• Treatment: Any operation or set of operations on personal data, such as the collection, storage, use, circulation or deletion.</span >

• Transfer: The transfer of data takes place when the person in charge and/or in charge of processing personal data, located in Colombia, sends the information or personal data to a recipient, who in turn is Responsible for Treatment and is located inside or outside the country.

• Transmission: Processing of personal data that implies the communication of the same within or outside the territory of the Republic of Colombia when its purpose is the processing by the Processor on behalf of the Responsible.

CHAPTER II

TREATMENT AND PURPOSES

PURNIMA S.A.S. Performs the processing of personal data exclusively in compliance with the purpose previously established by the users of Time Manager, which corresponds to the provision of time registration, billing and collaboration services for signatures. of professional services through a technological solution for storage, processing and support.

Likewise, it will treat information of PURNIMA S.A.S., especially that of shareholders, clients, suppliers and/or contractors, candidates for employees, employees, former employees , for the following purposes:

• Inform and offer products and/or services of Time Manager to people interested or who could become so.</ li>

• Develop the contractual relationship and services that are established with the Holders of the Information. Likewise, to know, evaluate, maintain, improve and deepen the products and services acquired and used by them.

• The exercise of the rights and compliance with the duties of the shareholders of PURNIMA S.A.S.

• Evaluate candidates to be linked permanently, temporarily and/or by contract for the provision of services as officers or employees of PURNIMA S.A.S. Likewise , to develop labor relations and/or the provision of services that are held.

• Know and monitor the financial suitability and commercial behavior of its suppliers. Likewise, to develop the contractual relations that exist or come to exist with them.

• To comply with the constitutional, legal and regulatory provisions set forth in the Colombian legal system.

CHAPTER III

RIGHTS OF THE HOLDERS

• Know, update and rectify your personal data against PURNIMA S.A.S

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.< /p>

• Request proof of the authorization granted to PURNIMA S.A.S., when acting as Responsible for the information, except when expressly excepted by law as a requirement for Treatment.

• Be informed by PURNIMA S.A.S., upon request, regarding the use given to your personal data.</li >

• Submit to the Superintendency of Industry and Commerce, once the query or claim process before PURNIMA S.A.S. has been exhausted, complaints for violations of the provisions in Law 1581 of 2012 and the other regulations that modify, add or complement it.

• 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. Or when there is no legal or contractual duty that requires its conservation.

• Access free of charge to your personal data that has been processed by PURNIMA S.A.S., in the terms of the law.</span >

CHAPTER IV

EXERCISE OF THE RIGHTS OF THE HOLDERS

The Holder of the Information can exercise his right to know, access, update, rectify and delete his personal data in the terms provided in Law 1581 of 2012, and its regulatory decrees, free of charge, at least once every calendar month, and in the case of claims whenever there is a reason for it, by means of a letter accompanied by a copy of the identity document.

The Holder of the Information can exercise his right to know, access, update, rectify and delete his personal data in the terms provided in Law 1581 of 2012, and its regulatory decrees, free of charge, at least once every calendar month, and in the case of claims whenever there is a reason for it, by means of a letter accompanied by a copy of the identity document.

CHAPTER V

PROCEDURES FOR ATTENDING QUESTIONS AND CLAIMS

*Consultations. The Holders or their successors in title may consult the personal information of the Holder that resides in the automated databases or physical files of The Responsible. The Data Controller or Processor must provide them with all the information contained in the individual record or that is linked to the identification of the Holder.

The query will be formulated by the means authorized by the Data Controller or Processor, as long as proof of this can be maintained.

The inquiry will be answered within a maximum term of ten (10) business days from the date of receipt. 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 his query will be attended, which in no case may exceed five (5) business days following the expiration of the first term.

*Claims. The Owner or his successors in title who consider that the information contained in a database should be corrected, updated or deleted, or when notice the alleged breach of any of the duties contained in this law, they may file a claim with the Treatment Manager or the Treatment Manager, which will be processed under the following rules:

1. The claim will be made by means of a request addressed to the Treatment Manager or the Treatment Manager, with the identification of the Holder, the description of the facts that give rise to the claim, the address, and accompanying the documents that you want to assert. If the claim is incomplete, the interested party will be required within five (5) days after receipt of the claim 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 he has withdrawn the claim.</ Span> </ li>

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

2. Once the complete claim has been received, a legend will be included in the database that says “claim in process” and the reason for it, in a term not exceeding two (2 ) business days. This legend must be kept until the claim is decided.

3. 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 term.

CHAPTER VI

SECURITY MEASURES

PURNIMA S.A.S. will manage the information stored in its databases with the technical, human and administrative measures necessary to provide security to the records, avoiding their adulteration, loss, consultation, use or unauthorized or fraudulent access, with the purpose of safeguarding the confidentiality, availability and integrity of the personal data that has been provided.

CHAPTER VIII

MODIFICATION OF TREATMENT POLICIES

Any substantial change in the terms of the personal data protection policies will be informed through the PURNIMA S.A.S. website, or by means of a written communication. addressed to the Holders of the Information to the last address registered by them.

For this purpose, the Owners of the information are recommended to keep their contact information updated, because without them communication becomes difficult and the relationship is affected.

CHAPTER IX

DATA RETENTION