1. DATA CONTROLLER

The website (http://www.rocasalvatella.com/) is an internet domain containing a portal or website whose ownership, in compliance with the provisions of Law 34/2002 of 11 July on Information Society Services and Electronic Commerce, is informed as: ROCA SALVATELLA S.L

ROCA SALVATELLA S.L
C.I.F: B-64927304
Registered office: Av. Alcalde Barnils 64-68, edifici C, 4ª planta, 08174  Sant Cugat del Vallès, Barcelona
Telephone: (+ 34) 93.544.24.02
Registry details: Commercial Registry of Barcelona, volume 40962, folio 1, sheet 370264, 1st entry

The purpose of the ROCA SALVATELLA S.L. website is to provide users and interested parties with information regarding the entity's activities and services. With this website, the aim is to render a useful service, and therefore suggestions from users are welcome. However, if you do not agree with any of the conditions contained in this notice, you must stop using the ROCA SALVATELLA S.L. website. Access to it will be subject to the prior express acceptance of these conditions. The use of certain services offered on this site shall also be governed by the specific conditions stipulated in each case.

The conditions set forth below regulate the permitted use of the website http://www.rocasalvatella.com/.

2. WEBSITE MODIFICATIONS AND INTERRUPTIONS OR ERRORS IN ACCESS

ROCA SALVATELLA S.L. reserves the right to make modifications and updates to the information contained on the website, its configuration and presentation, and the conditions of access at any time and without prior notice.

ROCA SALVATELLA S.L. is not responsible for failures that may occur in communications, and does not guarantee the availability and continuity of the portal and services; therefore, ROCA SALVATELLA S.L. does not guarantee the absence of interruptions or errors in accessing the website or its content.

Provided that there are no causes that make it impossible or difficult to execute, and as soon as it becomes aware of any errors, disconnections, or lack of updates in the content, ROCA SALVATELLA will carry out all necessary tasks aimed at correcting the errors, restoring communication, and updating the content.

3. INTELLECTUAL PROPERTY

Unless expressly indicated otherwise, the content of the website, including images, texts, and data, is the property of ROCA SALVATELLA S.L. Furthermore, its source code, design, and navigation structure are the property of ROCA SALVATELLA S.L. ROCA SALVATELLA S.L. holds the exclusive exercise of the exploitation rights of the same in any form, and especially the rights of reproduction, distribution, public communication, and transformation. All of this material is protected by intellectual property legislation, and its misuse may be subject to sanctions, including criminal penalties.

Consulting or downloading content from the website or any software will not imply the assignment of any intellectual or industrial property rights over them. The visualization, printing, and partial downloading of the content of the website are authorized solely and exclusively if the following conditions are met:

a) It is compatible with the purposes of the website.

b) It is not formatted for commercial purposes or for distribution, public communication, or transformation.

c) None of the contents of the website are modified.

d) No graphic, icon, or image available on the website is used, copied, or distributed separately from the text or other accompanying images.

e) The source is cited.

All information received on these pages, such as comments, suggestions, or ideas, will be considered assigned free of charge. Do not send information that cannot be processed in this manner.

4. SECURITY

ROCA SALVATELLA S.L., aware of the risks derived from facing the new challenges involved in extending its services via the internet, has established demanding security measures to reduce these risks.

Nonetheless, ROCA SALVATELLA S.L. excludes any liability for damages of any nature that may be due to the presence of viruses or other elements that may cause alterations in the computer system (software and hardware), electronic documents, and files of the user or any third party, including those occurring in services provided by third parties through this portal.

Users are informed that the use of electronic data transmission systems and email does not offer absolute security guarantees. The user and ROCA SALVATELLA S.L. mutually exonerate each other from any liability arising from events such as non-receipt or delay in receipt, error, or interception of communications.

5. CONTENTS AND LINKED SITES

The information contained on this website is for informational purposes only and under no circumstances constitutes any contractual obligation. The function of the links appearing on this page is exclusively to inform the user about the existence of other sources of information on the subject on the internet, where they can expand or complete the data offered on this page.

ROCA SALVATELLA S.L. will not be responsible for the results obtained through these links. In any case, ROCA SALVATELLA S.L. assumes no responsibility derived from the contents linked from its website, nor does it guarantee the absence of viruses or other elements in them that may cause alterations in the computer system (hardware and software), documents, or files of the user, excluding any liability for damages of any kind caused to the user for this reason.

Although links are regularly monitored to prevent this from happening, in the event that any user or third party considers that the content or services provided by the linked sites are unlawful, violate constitutional values or principles, or harm the property or rights of the user or a third party, they are requested to immediately notify ROCA SALVATELLA S.L. of this circumstance, especially if the links consist of:
a) Activities or contents susceptible to being considered criminal under Spanish criminal law.
b) Activities or contents that violate intellectual or industrial property rights.
c) Activities or contents that endanger public order, criminal investigation, public security, and national defence.
d) Activities or contents that endanger the protection of public health, respect for human dignity, the principle of non-discrimination, the protection of health and childhood, or any other constitutional value or principle.

6. PROTECTION OF PERSONAL DATA

The personal data linked to this website complies with the requirements of current legislation on personal data protection. ROCA SALVATELLA S.L. will process the personal data collected through this website in compliance with current regulations on data protection.
a) Inclusion in files is absolutely voluntary and is duly announced.
b) The files into which personal data are incorporated will be protected by the security measures required by legislation.
c) The data will only be used for the purpose for which they were collected.
d) All individuals incorporated into the created file may exercise their rights of access, rectification, objection, limitation of processing, erasure, and data portability.

7. THIRD-PARTY LINKS TO THE WEBSITE

Any third-party link to the website must be directed to its home page, with deep linking, framing, and any other exploitation of the website content in favour of unauthorized third parties being expressly prohibited.

8. MINOR PROTECTION POLICY

Access and use of this website by minors under 13 years of age who are not duly authorized is prohibited. ROCA SALVATELLA S.L. understands that from the moment a minor accesses this website, they have the permission of their parents, guardian, or legal representative.

ROCA SALVATELLA S.L. reminds adults who are responsible for minors that it will be their exclusive responsibility if a minor submits their data to request any service.

9. DATA PROTECTION POLICY

In compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and its developing regulations, you are informed that the personal data provided by Users will be incorporated into an automated database owned by and under the responsibility of ROCA SALVATELLA, S.L.

The processing of personal data affects all personal data provided by the User to ROCA SALVATELLA S.L. at the time of registration on the web portal, as well as all those provided to access any of the services of other pages or services of said company.

ROCA SALVATELLA S.L. is subject to compliance with its obligation of secrecy regarding personal data and its duty to treat them confidentially, and assumes, for these purposes, the technical, organizational, and security measures necessary to prevent their alteration, loss, unauthorized processing, or access, in accordance with the provisions of the aforementioned regulation and other applicable legislation.

The collection and processing of personal data have the following purposes: provision of services requested by the user; management of potential incidents; checking and verification of the quality of the services offered; sending general information about the development and operation of the service or product requested or contracted by the user. The user of these services is aware that, for the provision of the service, it is required that the management, maintenance, and interconnection services with mobile operators of the technical platform used for the storage and processing of personal data and the provision of the service, as well as the creation and preservation of backup copies, be provided by ROCA SALVATELLA S.L.

In the registration process, the User will grant their express authorization and consent to ROCA SALVATELLA S.L. for the processing of their data in accordance with the current legislation applicable to personal data protection. The provision of certain data (phone number or email address), required for registration as a CONTACT on the websites of ROCA SALVATELLA S.L., is mandatory, and ROCA SALVATELLA S.L. may deny registration to any interested party who does not provide such data.

Under no circumstances will ROCA SALVATELLA S.L. use the personal data of the interested parties for purposes other than those mentioned above, nor will it disclose them to third parties without the prior and express consent of the affected party, committing to maintain due professional secrecy and to establish the technical and organizational measures necessary to safeguard the information in accordance with the requirements set by the aforementioned Regulation.

Personal data will be stored in our records for a period of one year following the termination of the commercial relationship, with ROCA SALVATELLA S.L. also maintaining its duty of secrecy and confidentiality of the data during that period of time.

The user may access their data at any time and exercise the rights established by law and listed below: access, rectification, erasure, and portability of data, as well as the limitation of or objection to the processing of the same, being able to exercise any of these actions in writing by post or email to the following address:

ROCA SALVATELLA, S.L. Avda Alcalde Barnils 64-68, 08174 Sant Cugat del Valles. Customer Service Telephone: 93 544 24 02 email: info@rocasalvatella.com

In the request, the following information must be attached:

- Name, surname, and DNI (ID card), or the company to which you belong, where applicable.
- Right you wish to request and copy of your petition.
- Telephone number / email address regarding which you want to exercise that right.
- Address for notification purposes.

Furthermore, we inform you that if you consider that your rights are not being respected in the processing of your data, you can file a complaint with the Spanish Data Protection Agency.

10. JURISDICTION

ROCA SALVATELLA S.L. and the user, expressly waiving any other jurisdiction, submit to the Courts and Tribunals of the city of Sant Cugat del Vallés for any dispute that may arise from access to or use of the Website.

—————

COOKIES POLICY

This website uses its own and third-party cookies to offer you a better experience and service. By navigating or using our services, the user accepts our use of cookies.

1. WHAT ARE COOKIES?

Cookies are small text files that are installed in the User's computer browser, sending an anonymous identification stored within it, allowing a webpage, among other things, to store and retrieve information about the browsing habits of a user or their equipment. Additionally, they improve your browsing process as they allow the webpage to offer the user information that may be of interest to them based on how they use its content.

ROCA SALVATELLA S.L. will endeavour at all times to establish adequate mechanisms to obtain the User's consent for the installation of cookies that require it. Notwithstanding the foregoing, it must be taken into account that, in accordance with the Law, it will be understood that (i) the User has given consent if they modify the browser configuration by disabling the restrictions that prevent the entry of cookies and (ii) that said consent will not be necessary for the installation of those cookies that are strictly necessary for the provision of a service expressly requested by the User (by prior registration).

2. THE COOKIES WE USE

Depending on the purpose for which the data obtained through cookies are processed, the Website may use:

- Own cookies:

These are sent to the user's terminal equipment from a computer or domain managed by the editor itself and from which the service requested by the user is provided.

- Third-party cookies:

These are sent to the user's terminal equipment from a computer or domain that is not managed by the editor, but by another entity that processes the data obtained through the cookies.

- Technical cookies:

These allow the user to navigate through the website or application and use the different options or services that exist on it. For example, controlling traffic and data communication, identifying the session, accessing restricted web areas, remembering the elements that make up an order, applying for registration or participation in an event, using security elements during navigation, and storing content for the dissemination of videos or sound.

- Customization cookies:

These allow the user to access the service with some predefined general characteristics on their terminal or defined by the user themselves. For example, the language, the type of browser through which they access the service, the selected content design, the geolocation of the terminal, and the regional configuration from which the service is accessed.

- Analysis cookies:

These allow the monitoring and analysis of the behaviour of users on websites. The information collected through this type of cookies is used to measure the activity of the websites, application, or platform and for the preparation of browsing profiles of the users of said sites, in order to introduce improvements to the service based on the usage data made by the users.

- Advertising cookies:

These allow the effective management of the advertising spaces included on the website or application from which the service is provided. They allow the advertising content to be matched so that it is relevant to the user and to avoid showing ads that the user has already seen.

- Behavioural advertising cookies:

These allow the most effective management possible of the advertising spaces that, where applicable, the editor has included on a webpage, application, or platform from which they provide the requested service. These cookies store information on user behaviour obtained through the continuous observation of their browsing habits, allowing a specific profile to be developed to display advertising based on it.

(The cookies we use do not store any personal data or any type of information that can identify you, unless you wish to register voluntarily in order to use the services we make available or to receive information about promotions and content of interest to you.)

Below, we attach a list of the main cookies used by this Website:

a) Cookie Name

b) Source

c) Purpose

3. HOW TO MANAGE COOKIES?

The user has the option to allow, block, or delete the cookies installed on their equipment by configuring their browser options:

-  If you use Microsoft Internet Explorer, in the Tools menu option, select Internet Options and access Privacy.

-  If you use Firefox, for Mac in the Preferences menu option, select Privacy, and access the Show Cookies section, and for Windows in the Tools menu option, select Options, access Privacy, and then choose Use custom settings for history.

-  If you use Safari, in the Preferences menu option, select Privacy.

-  If you use Google Chrome, in the Tools menu option, select Options (Preferences on Mac), access Advanced, and then choose Content Settings in the Privacy section, and finally check Cookies in the Content Settings dialog.

However, disabling cookies could modify the operation of the Website. Please consult your browser's instructions and manuals for further information.

If you block the use of cookies in your browser, it is possible that some services or functionalities of the Website may not be available.

4. COOKIES POLICY UPDATE

It is possible that, due to new interpretations made by the competent regulatory body, judges, or Courts, this cookies policy may undergo some modification, so the user is requested to check its content regularly.

Last review: 25 May 2018

 

POLICIES AND PROCEDURES MANUAL FOR FOR THE PROCESSING OF INFORMATION OF ROCA SALVATELLA BOGOTA SAS

ROCA SALVATELLA BOGOTA SAS, domiciled at Calle 93 A No 14-17, office 704, in the city of Bogotá and telephone number (+57-1) 3473612 (hereinafter "RS BOGOTA"), hereby informs the Data Subjects whose Personal Data is processed in any manner by RS BOGOTA, of this Policies and Procedures Manual for the Processing of Information (the "Policy"), in compliance with Law 1581 of 2012 and Decree 1377 of 2013.

The main objective and purpose of this Policy is to inform the Data Subjects of their rights, as well as the procedures and mechanisms provided by RS BOGOTA to make these rights effective, and to inform them of the scope and purpose of the Processing to which the Personal Data will be subjected in the event that the Data Subject grants their prior, express, and informed authorization.

1. KEY DEFINITIONS

The following expressions used in this Policy shall have the definition granted below, or the meaning given to them by the applicable law or jurisprudence, as said law or jurisprudence may be modified from time to time.

a) "Authorization": Prior, explicit, and informed consent of the Data Subject to carry out the Processing of their Personal Data.

b) "Database": Organised set of Personal Data that is subject to Processing, whether electronic or not, regardless of the method of its formation, storage, organization, and access.

c) "Financial Data": Any Personal Data referring to the rise, execution, and termination of monetary obligations, regardless of the nature of the contract from which they originate, whose Processing is governed by Law 1266 of 2008 or the regulations that complement, modify, or add to it.

d) "Personal Data": Any information of any kind connected or associated with one or more specific or identifiable natural or legal persons.

e) "Public Data": Personal Data classified as such according to the mandates of the law or the Political Constitution and that which is not semi-private, private, or sensitive. Examples of public data include database details relating to the civil status of persons, profession or trade, status as a merchant or public servant, and those that can be obtained without any reserve.

f) "Sensitive Data": Personal Data that affects the privacy of the Data Subject or whose misuse may lead to discrimination, such as data revealing trade union affiliations, racial or ethnic origin, political orientation, religious, moral, or philosophical convictions, membership in trade unions, social organizations, human rights organizations or those promoting the interests of any political party or guaranteeing corporate rights and guarantees of opposition political parties, as well as data relating to health, sexual life, and biometric data.

g) "Data Processor": Natural or legal person, public or private, who, acting individually or jointly with others, processes Personal Data on behalf of the Data Controller.

h) "Authorized Party": RS BOGOTA and all persons under the responsibility of RS BOGOTA who, by virtue of the Authorization and this Policy, are authorized to Process the Personal Data of the Data Subject. The Authorized Party includes the category of Enabled Parties.

i) "Enablement": Explicit and written legitimization, by contract or equivalent document, granted by RS BOGOTA to third parties, in compliance with applicable law, for the Processing of Personal Data, converting such third parties into Data Processors of the Personal Data delivered or made available.

j) "Data Controller": Natural or legal person, public or private, who, individually or jointly with others, decides on the Database and/or the Processing of Personal Data.

k) "Data Subject": Natural or legal person to whom the information in a Database refers, who is the subject of the right to habeas data.

l) "Transfer": Processing of Personal Data that involves the communication thereof within or outside the territory of the Republic of Colombia when its purpose is the performance of Processing by the Data Processor on behalf of the Data Controller.

m) "Transmission": Activity of Processing Personal Data by which they are communicated, internally or with third parties, within or outside the territory of the Republic of Colombia, when such communication is for the purpose of carrying out any Processing activity by the recipient of the Personal Data.

n) "Processing of Personal Data": Any operation and systematic procedure, electronic or not, allowing the collection, conservation, sorting, storage, modification, linking, use, dissemination, evaluation, blocking, destruction, and generally processing of Personal Data, as well as its transfer to third parties through communications, queries, interconnections, assignments, or data messages.
o) "Habeas Data": Fundamental right of any person to know, update, rectify, and/or cancel the information and personal data collected and/or processed about them in public or private databases, in accordance with the law and other applicable regulations.

2. PRINCIPLES

RS BOGOTA, in the performance of its commercial activities, will collect, use, store, transmit, and carry out various operations on the personal data of the Data Subjects. In all Processing of Personal Data carried out by RS BOGOTA, the Controllers, Processors, and/or third parties with whom Personal Data is shared must comply with the principles and rules established by law and in this Policy, in order to guarantee the Data Subjects' right to Habeas Data and thus comply with the legal obligations of RS BOGOTA.

These principles are:

a) Prior Authorization: All Processing of Personal Data will be carried out once the prior, express, and informed Authorization of the Data Subject has been obtained, unless the Law establishes an exception to this rule. In the event that the Personal Data was obtained prior to the Law, RS BOGOTA will seek the relevant ordinary and alternative means to contact the Data Subjects and obtain their retroactive authorization, following the provisions of Decree 1377 of 2013 and concordant regulations.

b) Authorized Purpose: Any Personal Data Processing task will be carried out for the purposes outlined in this Policy, in the Authorization granted by the Data Subject, or in the specific documents regulating each type or process of Personal Data Processing. The specific purpose of the Processing of a Personal Data item must be informed to the Data Subject at the time of obtaining their Authorization. Personal Data may not be processed outside of the purposes informed to and consented to by the Data Subjects.

c) Data Quality: The Personal Data subjected to Processing must be true, complete, accurate, updated, verifiable, and understandable. When dealing with partial, incomplete, fractioned, or misleading Personal Data, RS BOGOTA must refrain from Processing it, or request the owner to complete or correct the information.

d) Provision of Information to the Data Subject: When requested by the Data Subject, RS BOGOTA must deliver information regarding the existence of Personal Data concerning the applicant. This provision of information will be carried out by the RS BOGOTA department in charge of personal data protection.

e) Restricted Circulation: Personal Data may only be Processed by those RS BOGOTA personnel authorized to do so, or by those whose functions include carrying out such activities. Personal Data may not be delivered to those who do not have Authorization or have not been Enabled by RS BOGOTA to carry out the Processing.

f) Temporality: RS BOGOTA will not use the owner's information beyond the reasonable period required by the purpose that was informed to the Data Subject.

g) Confidentiality: RS BOGOTA must always carry out the Processing using the technical, human, and administrative measures necessary to maintain the confidentiality of the data and to prevent it from being altered, modified, consulted, used, accessed, deleted, or known by unauthorized persons, or by authorized and unauthorized persons in a fraudulent manner, or from being lost. Any new project involving the Processing of Personal Data must consult this Processing Policy to ensure compliance with this rule.

i) Confidentiality and Subsequent Processing: Any Personal Data that is not Public Data must be treated by the Controllers as confidential, even when the contractual relationship or bond between the Data Subject and RS BOGOTA has ended. Upon termination of said bond, such Personal Data must continue to be processed in accordance with this Policy and the law.

j) Individuality: RS BOGOTA will maintain databases in which it acts as Processor separate from those databases for which it is the Controller.

k) Necessity: Personal Data may only be Processed during the time and to the extent that the purpose of its Processing justifies.

3. PROCESSING AND PURPOSES

The Personal Data collected and processed by RS BOGOTA must be subjected strictly and solely to the purposes set forth below. Likewise, Processors or third parties who have access to Personal Data by virtue of law or contract, shall maintain the Processing within the following purposes:

a) Manage all information necessary for compliance with tax obligations and commercial, corporate, and accounting registries of RS BOGOTA.

b) Comply with the internal processes of RS BOGOTA regarding the administration of suppliers and contractors.

c) Incorporation into databases or automated personal data files of which RS BOGOTA is the owner and controller. For this purpose, the Data Subject will be provided with appropriate technical resources so that they can access the Privacy Notice, this Policy, or any other relevant information beforehand, and grant their consent for the automated processing of their Personal Data.

d) Use Personal Data for marketing and/or commercialization of new services or products.

e) Other purposes determined by the Controllers in processes of obtaining Personal Data for its Processing and which are communicated to the Data Subjects at the time of collecting the personal data.

f) Control and prevention of fraud and money laundering, including, but not limited to, consulting restrictive lists, and all necessary information required for SARLAFT.

g) Archiving process, updating systems, protection, and custody of information and databases of RS BOGOTA.

h) Internal processes within RS BOGOTA for development or operational purposes and/or systems administration.

i) Transmission of data to third parties with whom contracts have been signed for this purpose, for commercial, administrative, marketing, and/or operational purposes, including, but not limited to, the issuing of ID cards, personalized certificates, and certifications to third parties, in accordance with applicable legal provisions.

j) Maintain and process by computer or other means any type of information related to the customer's business in order to provide the relevant services and products.

k) Other purposes determined by the Controllers in processes of obtaining Personal Data for its Processing, in order to comply with legal and regulatory obligations, as well as RS BOGOTA policies.

4. RIGHTS OF THE DATA SUBJECT

In accordance with the law, Data Subjects have the following rights:

a) Know, update, and rectify their Personal Data with RS BOGOTA or the Processors thereof. This right may be exercised, among others, against partial, inaccurate, incomplete, fractioned, or misleading data, or data whose Processing is expressly prohibited or has not been authorized.

b) Request proof of the Authorization granted to RS BOGOTA, except when the law indicates that such Authorization is not necessary.

c) Present requests to RS BOGOTA or the Data Processor regarding the use made of their Personal Data, and to have them provide such information.

d) File complaints for violations of the law with the Superintendence of Industry and Commerce.

e) Revoke their Authorization and/or request the deletion of their Personal Data from the databases of RS BOGOTA, when the Superintendence of Industry and Commerce has determined through a definitive administrative act that RS BOGOTA or the Data Processor has engaged in conduct contrary to the Law, or when there is no legal or contractual obligation to maintain the Personal Data in the Controller's database.

f) Request access and free-of-charge access to their Personal Data that has been processed in accordance with Article 21 of Decree 1377 of 2013.

g) Be informed of any modifications to the terms of this Policy in a prior and efficient manner before the implementation of the new modifications or, failing that, the new information processing policy.

h) Have easy access to the text of this Policy and its modifications.

i) Access Personal Data registered in RS BOGOTA in an easy and simple manner to effectively exercise the rights granted to Data Subjects by the Law.

j) Know the department or person authorized by RS BOGOTA before whom they can present complaints, queries, claims, and any other requests regarding their Personal Data.

Data Subjects may exercise the rights granted to them by law and carry out the procedures established in this Policy by presenting their original citizenship card or identification document. Minors may exercise their rights personally or through their parents or adults holding parental authority, which must be demonstrated with the relevant documentation. Likewise, rights of the Data Subject may be exercised by successors-in-title who prove such status, the representative and/or proxy of the owner with corresponding accreditation, and those who have made a stipulation in favour of or for another.

5. DEPARTMENT RESPONSIBLE FOR HANDLING PETITIONS, QUERIES, AND CLAIMS

RS BOGOTA has designated the Management Area as responsible for receiving and addressing petitions, complaints, claims, and queries of all kinds related to Personal Data. The person or department in charge will process queries and claims under personal data matters in accordance with the law and this policy.

Some of the specific functions of this department in relation to Personal Data include:

a) Receive requests from Data Subjects, process, and respond to those based on the Law or these Policies, such as: requests to update Personal Data; requests to know Personal Data; requests to delete Personal Data when the Data Subject presents a copy of the decision of the Superintendence of Industry and Commerce in accordance with the Law; requests for information on the use given to their Personal Data; requests to update Personal Data; requests for proof of the Authorization granted, when applicable under the Law.

b) Respond to Data Subjects regarding requests that do not proceed in accordance with the Law.

Customer Service contact details are:

Physical address: Calle 93 A No 14-17, office 704

Email address: carolsanchez@rocasalvatella.com

Telephone: (+57-1) 3473612

6. PROCEDURES FOR EXERCISING THE RIGHTS OF DATA SUBJECTS

6.1. QUERIES

RS BOGOTA will provide mechanisms for the Data Subject, their successors-in-title, their representatives and/or proxies, those for whom a stipulation has been made in favour of or for another, and/or the representatives of minor Data Subjects, to submit queries regarding the Personal Data of the owner residing in the Databases of RS BOGOTA.

These mechanisms can be physical, electronic, through the email of the department in charge (Carol Sánchez), or by telephone at the service line (+57-1) 3473612.

Whichever the channel, RS BOGOTA will keep proof of the query and its response.

a) If the applicant has the capacity to submit the query, in accordance with the accreditation criteria established in Law 1581 of 2012 and Decree 1377 of 2013, RS BOGOTA will compile all information on the Data Subject contained in the individual register of that person or linked to the identification of the Data Subject within the databases of RS BOGOTA, and make it known to the applicant.

b) RS BOGOTA will respond to the applicant as long as they have the right to do so by being the Data Subject, their successor-in-title, proxy, representative, a stipulation has been made by or for another, or they are the legal representative in the case of minors. This response will be sent within ten (10) business days from the date on which the request was received by RS BOGOTA.

c) In the event that the request cannot be addressed within the period established in the previous clause, the applicant will be contacted to communicate the reasons why their request is in progress. The same or a similar channel used by the applicant to submit their request will be used for this communication.

d) The final response to all requests will not take more than fifteen (15) business days from the date on which the initial request was received by RS BOGOTA.

6.2. PETITIONS AND CLAIMS

RS BOGOTA provides mechanisms for the Data Subject, their successors-in-title, representative and/or proxies, those who made a stipulation for or on behalf of another, and/or the representatives of minor Data Subjects, to submit petitions or claims regarding (i) Personal Data processed by RS BOGOTA that must be subject to correction, update, or deletion, or (ii) alleged non-compliance with the duties imposed by law on RS BOGOTA.

These mechanisms can be physical, electronic, through the email of the department in charge (carolsanchez@rocasalvatella.com), or by telephone on the helpline (+57-1) 3473612.

a) The petition or claim must be presented by the Data Subject, their successors-in-title, representatives, or accredited persons in accordance with Law 1581 of 2012 and Decree 1377 of 2013, as follows:

- It must be sent to RS BOGOTA electronically to the email address carolsanchez@rocasalvatella.com; physically to Calle 93 A No 14-17, office 704 in Bogotá; or by telephone at the helpline (+57-1) 3473612.

- It must contain the name and identification document of the Data Subject.

- It must contain a description of the facts giving rise to the petition or claim and the objective pursued (update, correction, deletion, or compliance with duties).

- It must indicate the address and contact and identification details of the claimant.

- It must be accompanied by all documentation the claimant wishes to assert.

- Before addressing the petition or claim, RS BOGOTA will verify the identity of the Data Subject, their representative and/or proxy, or the accreditation that a stipulation was made for or on behalf of another. For this purpose, it may request the citizenship card or original identification document of the Data Subject, and special, general powers, or necessary documents as the case may be.

b) If the petition, claim, or additional documentation is incomplete, RS BOGOTA will request the applicant once, within five (5) days following receipt of the claim, to correct the deficiencies. If the applicant does not submit the required documentation and information within two (2) months following the date of the initial request, it will be understood that they have withdrawn the request.

c) If for any reason the person receiving the petition or claim within RS BOGOTA is not competent to resolve it, they will transfer it to the competent department within two (2) business days of receiving the claim, and inform the applicant of said referral.

d) Once the petition or claim has been received with the complete documentation, a tag stating "petition in process" or "claim in process" and the reason for it will be included in the Database of RS BOGOTA where the data of the Subject under claim resides, within a period not exceeding two (2) business days. This tag must be maintained until the request is decided.

e) The maximum term to address the petition or claim will be fifteen (15) business days starting from the day following the date of its receipt. When it is not possible to address the request within said term, the interested party will be informed of the reasons for the delay and the date on which their request will be addressed, which in no case may exceed eight (8) business days following the expiration of the first term.

6. Security measures for the protection of Personal Data

We have adopted the security levels necessary for the protection of the Personal Data you provide as a customer and have installed all technical means and measures to prevent the loss, misuse, alteration, unauthorized access, and theft of the registered information.

7. VALIDITY

This Policy is effective as of 1 August 2019. The Personal Data stored, used, or transmitted will remain in our Database, based on the criteria of temporality and necessity, for as long as necessary for the purposes mentioned in this Policy, or for which they were collected.