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Personal data treatment policy creaciones segar s.a.

This personal data treatment policy is prepared in accordance with the provisions of the Political Constitution of Colombia, Law 1581 of 2012, and Regulatory Decree 1377 of 2013 and will be applied by CREACIONES SEGAR SA, regarding the collection, storage, use , circulation, deletion, transfer and all those activities that constitute the processing of personal data supplied to this company. 


The right of HÁBEAS DATA is the one that everyone has to know, update and rectify the information that has been collected about them in files and databases of a public or private nature and guarantees all citizens the power of decision and control over their personal information. Therefore, CREACIONES SEGAR S.A accepts such provisions taking into account that for the development of its corporate purpose, it is continuously compiling and processing various databases of both customers, shareholders, suppliers, business partners and employees. 


1. DEFINITIONS

Authorization: consent that the owner of any personal data issues in a prior, express and informed manner for the company to carry out the processing of your personal data.

Owner: natural person whose data is processed by the company.

Database: set of personal data.

Personal data: information that is linked to a person. It is any piece of information linked to one or more specific or determinable persons or that may be associated with a natural or legal person. Personal data can be public, semi-private or private.

Treatment: any operation or set of operations on personal data within which its collection, storage, use, circulation or deletion can be included.

Person in charge of the treatment: natural or legal person, public or private, that by itself or in association with others, carries out some treatment on personal data on behalf of the person responsible for the treatment.

Responsible for the treatment: natural or legal person, public or private, that by itself or in association with others, decides on the database and / or the treatment of the data.

Public data: It is that data qualified as such according to the mandates of the law or the Political Constitution. They are public, among others, the data contained in public documents, finalized judicial decisions that are not subject to reservation and those related to the civil status of the people.

Semi-private data: The data that is not intimate, reserved, or public in nature and whose knowledge or disclosure may interest not only its owner but also a certain sector or group of people or society in general, such as the financial and credit data of Comercial activity.

Creaciones Segar S.A. PBX: (574) 377 18 59 National Free Line info@fajasmariae.com Calle 79 No 52D - 134 Medellín - Colombia 01 8000 423 670 www.fajasmariae.com

Private data: It is the data that due to its intimate or reserved nature is only relevant for the owner.

Sensitive data: those related to racial or ethnic origin, membership in unions, social or human rights organizations, political, religious, sexual life, biometric or health data convictions. This information may not be provided by the Owner of these data.

Privacy notice: physical, electronic document generated by the person in charge of the treatment that is made available to the owner with the information related to the existence of the information treatment policies that will be applicable, the way to access them and the characteristics of the Treatment that is intended to be given to personal data. 

2. IDENTIFICATION OF THE RESPONSIBLE AND PERSON IN CHARGE OF THE INFORMATION PROCESSING 
CREACIONES SEGAR S.A. located at Calle 79 No. 52D - 134, Itagüí - Antioquia, website www.fajasmariae.com, email info@fajasmariae.com and telephone (574) 377 18 59. 

3. DUTIES OF CREACIONES SEGAR S.A. REGARDING THE DATA HOLDERS 
Creaciones Segar S.A. acknowledges that personal data are the property of the owners thereof and that only such persons may decide on them. In this sense, it will make exclusive use for those purposes for which it is empowered in the terms of the law and for the sake of the above it is allowed to inform the duties that it assumes in its capacity as data controller: 

a) The company must seek the means through which to obtain express authorization from the owner of the data to carry out any type of treatment.

b) The company must clearly and expressly inform its clients, employees, suppliers and third parties in general from whom it obtains databases the treatment to which they will be subjected and the purpose of said treatment. For this, the company must design the strategy through which for each event, mechanism or request for data that is made, it will inform them of the respective treatment in question. Some of these means may be sending text messages, filling out physical formats, through the website fajasmariae.com

c) The company must inform the owners of the data for each case, the optional nature of responding and granting the respective information requested. d) In all cases in which data is collected, the rights that all holders have regarding their data must be informed. e) The company must inform the identification, physical or electronic address and telephone number of the person or area that will be responsible for the treatment, within which the web page fajasmariae.com can be found.

Creaciones Segar S.A. PBX: (574) 377 18 59 National Free Line info@fajasmariae.com Calle 79 No 52D - 134 Medellín - Colombia 01 8000 423 670 www.fajasmariae.com

f) The company must guarantee at all times to the owner of the information, the full and effective exercise of the right to habeas data and petition, that is, the possibility of knowing the information that exists or resides in the data bank. , request the update or correction of data and process inquiries, all of which will be done through the mechanisms of inquiries or claims provided for in this policy.

g) The company must keep the records of stored personal data with due security to prevent their deterioration, loss, alteration, unauthorized or fraudulent use and periodically and timely update and rectify the data, each time the holders of the themselves report news or requests. 


4. PURPOSES OF THE COLLECTION OF PERSONAL DATA 
The personal data provided by you to CREACIONES SEGAR S.A. will be stored in our databases and will be used for any of the following purposes: 

4.1. With Clients: 

a) Execute the existing contractual relationship

b) Provide the required products

c) Inform about new products, or about changes in them

d) Exercise control in the delivery of products

e) Evaluate the quality of the service

f) Carrying out statistical, commercial, strategic, financial analyzes that concern the corporate purpose of CREACIONES SEGAR S.A.

g) Send to physical, electronic, cell phone or mobile device, via text messages (SMS and / or MMS) or through any other analog and / or digital means of communication, commercial, advertising or promotional information about products, events and / or promotions of a commercial nature, in order to promote, invite, direct, execute, inform and in general, carry out campaigns, promotions or contests of a commercial or advertising nature, carried out by CREACIONES SEGAR SA and / or by third parties.

h) Transmission, assignment, commercialization and / or sale of the database to third parties for statistical, commercial, strategic and financial purposes.

i) Share databases with companies related to CREACIONES SEGARS S.A.

j) Supply, share, send, assign and deliver your personal data that are necessary for the recognition, exercise or defense of a right in a judicial process.

k) Attend internal or external audit processes. 

4.2. With Employees, service providers and applicants: 

a) Advance processes of linking, execution and termination of the employment relationship and / or the provision of services.

b) Develop the process of selection, evaluation, employment and / or provision of services.

c) Carry out the social security affiliation processes.

d) Attend internal or external audit processes.

Creaciones Segar S.A. PBX: (574) 377 18 59 National Free Line info@fajasmariae.com Calle 79 No 52D - 134 Medellín - Colombia 01 8000 423 670 www.fajasmariae.com

e) Supply, share, send or deliver your personal data to affiliated, related, or subordinate companies of CREACIONES SEGAR S.A., and / or and third parties, in the event that said companies require the information for contractual purposes.

f) Supply, share, send, assign and deliver your personal data that are necessary for the recognition, exercise or defense of a right in a judicial process. 

4.3. With Suppliers and Contractors 

a) Execute the existing contractual relationship.

b) Contact and contract new products and / or services that CREACIONES SEGAR S.A. required for the normal operation of its operation.

c) Supply, share, send, assign and deliver your personal data to affiliated, linked, or subordinate companies of CREACIONES SEGARS S.A., and / or third parties in the event that said companies require the information for their purposes.

d) Attend internal or external audit processes.

e) Supply, share, send, assign and deliver your personal data that are necessary for the recognition, exercise or defense of a right in a judicial process. 

4.4. With shareholders 

a) Execute the existing corporate relationship. b) Send summons to ordinary and extraordinary shareholders' meetings. 


5. TREATMENT OF SPECIAL DATA 

Regarding the treatment of sensitive data or data whose owner is a minor CREACIONES SEGAR S.A. adapts all the necessary measures for their protection and indicates the following: 

5.1. Sensitive data: CREACIONES SEGAR S.A. warns the Holder of sensitive data that he has the right to choose not to supply any sensitive information requested, related, among others, to data on his racial or ethnic origin, membership in unions, social or human rights organizations, political or religious beliefs, of sex life, biometric or health data. 

5.2. Data of minors: The provision of personal data whose owner is a minor is optional, and must be done with the authorization of the minor's parents or legal representatives. CREACIONES SEGAR S.A. It will only use, store and process the personal data of minors who are children, descendants or who depend on or are in charge of the employees or contractors of CREACIONES SEGAR S.A., and that are of a public nature. The purpose of said treatment will only be to plan and carry out activities related to the personal and family well-being of employees and minors. And that of affiliations as a dependent to the social security system. For such purposes, CREATIONS

Creaciones Segar S.A. PBX: (574) 377 18 59 National Free Line info@fajasmariae.com Calle 79 No 52D - 134 Medellín - Colombia 01 8000 423 670 www.fajasmariae.com 
SEGAR S.A. will take into account the respect and prevalence of the rights of minors, their best interests and their fundamental rights. 

6. CASES IN WHICH AUTHORIZATION IS NOT REQUIRED: 

The authorization of the Holder will not be necessary in the case of: 

a) Information required by a public or administrative entity in the exercise of its legal functions or by court order.

b) Data of a public nature. c) Cases of medical or health emergency.

d) Information processing authorized by law for historical, statistical or scientific purposes.

e) Data related to the Civil Registry of Persons. 


7. TO WHOM INFORMATION MAY BE DELIVERED BY CREACIONES SEGAR S.A. NO NEED TO HAVE AUTHORIZATION FROM THE DATA HOLDERS: 

a) To the owners of the data, their heirs or representatives at any time and through any means when requested to Creaciones Segar S.A.

b) To judicial or administrative entities in the exercise of functions that raise any requirement to the company for the information to be delivered.

c) To third parties that are authorized by any law of the Republic of Colombia. 

8. RIGHTS OF THE HOLDERS. 

The owners of personal data handled by CREACIONES SEGAR S.A by themselves or through their representative and / or attorney-in-fact or their successor in title may exercise the following rights in such a way that the purposes of the law are satisfied: 

a) Right to know: By virtue of which you can access the personal data that are under the power of CREACIONES SEGAR SA, for the purposes of consulting them, whenever they consider it relevant, or whenever there are substantial modifications to the Treatment Policies of the information that motivate new consultations.

b) Right to update: The owner of the information has the right to update their personal data when they are partial, fractioned or incomplete.

c) Right of rectification: The owner of the information has the right to rectify their personal data when they are inaccurate or misleading.

d) Right of deletion or revocation: The owner of the information may revoke the authorization and / or request the deletion of the data when the principles, rights and constitutional and legal guarantees are not respected. The revocation will not proceed when the owner has a legal or contractual duty of permanence in the database.

e) Right to request proof of authorization: except in events in which, according to current legal regulations, authorization is not required to carry out the treatment.

Creaciones Segar S.A. PBX: (574) 377 18 59 National Free Line info@fajasmariae.com Calle 79 No 52D - 134 Medellín - Colombia 01 8000 423 670 www.fajasmariae.com


f) Right to be informed regarding the use of personal data.

g) Right to file complaints with the Superintendency of Industry and Commerce: for infractions of the provisions of current regulations on the processing of personal data. 


9. AUTHORIZATIONS 

In order to carry out the aforementioned purposes, Creaciones Segar S.A. It requires freely, prior, expressly and duly informed authorization by the data owners and for this it has provided suitable mechanisms guaranteeing for each case that it is possible to verify the granting of said authorization. It may appear in any medium, be it a physical or electronic document or in any format that guarantees its subsequent consultation through technical and technological tools and computer security developments. 

The authorization is a statement that informs the owner of the data the following information: 

Who is responsible or in charge of collecting the information

Data collected  Purposes of the treatment

Procedure for the exercise of the rights of access, correction, updating or deletion of data

Information on sensitive data collection 


10. DATA COLLECTED BEFORE THE ISSUANCE OF DECREE 1377 OF 2013 

For the purposes of complying with the provisions of Article 9 of Law 1581 of 2012, those Responsible for the processing of personal data will establish mechanisms to obtain the Authorization of the holders or of whoever is legitimized in the terms of the Law. These mechanisms They may be predetermined through technical means that provide the owner with their automated manifestation. The Authorization may be granted according to any of the following options: (i) In writing, (ii) Verbally or (iii) Through unequivocal conduct of the holder that allows a reasonable conclusion that the authorization was granted. In no case may silence be assimilated to unequivocal conduct. 

If within thirty (30) business days from the implementation of the previous mechanism, the owners have not contacted the CONTROLLER or MANAGER to request the deletion of their personal data, the CONTROLLER and MANAGER may continue to process personal data contained in its databases for the purpose or purposes foreseen and indicated in the information treatment policy. 

Creaciones Segar S.A. PBX: (574) 377 18 59 National Free Line info@fajasmariae.com Calle 79 No 52D - 134 Medellín - Colombia 01 8000 423 670 www.fajasmariae.com

11. PROCEDURE TO EXERCISE THE RIGHTS 

To exercise your rights as the owner, you can contact us from Monday to Friday from 8:00 am to 12:00 pm and 2:00 pm to 5:00 pm by calling (4) 377 18 59 or at our facilities located on Calle 79 No 52D - 134 Itagüí-Antioquia. You can also do it through our email info@fajasmarie.com. 

For the purposes of agile and correct attention, keep in mind that in all cases you must indicate the following information: 

a) Name and identification of the Holder.

b) The precise and complete description of the facts that originate the procedure.

c) The physical or electronic address to send the response and report on the status of the process.

d) The documents and other evidence that are intended to be enforced, if any. 

Queries: They will be resolved within a maximum term of ten (10) business days from the day following the date of receipt. When it is not possible to answer the query within said term, the interested party will be informed before the expiration of 10 days, stating the reasons for the delay and indicating the date on which their request will be attended, which in no case may exceed five (5) business days following the expiration of the first term. 

Claims: When it is noticed that the information contained in a database of CREACIONES SEGAR S.A. must be subject to correction, updating, deletion, rectification or the alleged breach of any of the legal duties is observed, they may file a claim through any of the communication channels indicated above. Once the respective claim has been received, CREACIONES SEGAR S.A. It will have a term of ten (10) business days to resolve it, counted from the day following the date of receipt. In the event that CREACIONES SEGAR S.A, is not competent to resolve the claim presented, it will transfer to the corresponding person within a maximum term of five (5) business days and will inform the interested party of the situation. If the claim is incomplete, CREACIONES SEGAR S.A, will require the interested party within five (5) days of receipt to correct the failures. After two (2) months from the date of the request, without the petitioner presenting the requested information, it will be understood that he has withdrawn from it. Once the claim is received, CREACIONES SEGAR S.A, will include in the respective database a legend that says "claim in process" and the reason for it, within a term not exceeding five (5) business days. This legend will remain until the claim is decided. 


12. TRANSFER OF DATA. 

When, for contractual reasons, the PROVIDERS of CREACIONES SEGAR S.A, request the transfer of the databases managed by the company, they must request it by means of a written document sent to the email info@fajasmariae.com or to our

Creaciones Segar S.A. PBX: (574) 377 18 59 National Free Line info@fajasmariae.com Calle 79 No 52D - 134 Medellín - Colombia 01 8000 423 670 www.fajasmariae.com 
facilities located at Calle 79 No 52D - 134, Itagüí - Antioquia; In such document, it must clearly and unequivocally express the need that motivates said request, it will confirm that for the use of this database, it will adhere to the policy for the processing of personal data implemented by CREACIONES SEGAR SA, and will make known the security measures used once the requested database is delivered. 


13. INFORMATION SECURITY 

CREACIONES SEGAR S.A. has human, administrative and technical security measures to protect the information of the Holders, and prevent unauthorized access to their data or any unauthorized modification, disclosure or destruction of them. Access to personal data is restricted to employees, contractors, representatives and agents of CREACIONES SEGAR S.A., in charge of the processing of personal data and / or who need to know them to perform their functions and develop the company's corporate purpose. 

14. VALIDITY OF THE DATABASE 

The personal data included in the Database of CREACIONES SEGAR S.A, will be valid for the period necessary to fulfill its purposes and to allow the fulfillment of its legal and contractual obligations. Once these terms have expired and in accordance with the provisions of article 28 of Law 962 of 2005, the data will remain for a period of ten (10) years from the end of the relationship with CREACIONES SEGAR S.A; Subsequently, the physical and / or magnetic files that contain the personal information, as well as the personal data that appear in the databases, will be eliminated. 

The databases corresponding to employment relationships are excepted from the period indicated here, which must be kept during the legal term of the company. In the event of liquidation of the company, the liquidator must deliver to all employees a copy of the employment history. 

Paragraph: Once the terms stipulated here or the terms provided by law for the conservation of documents have been fulfilled, CREACIONES SEGAR S.A, will proceed with the physical and / or magnetic destruction of the information contained in its databases. 

If you do not want your personal data to be used by CREACIONES SEGAR S.A., you may partially or totally revoke such authorization expressly and unequivocally, directly, expressly and in writing, either in physical or electronic means; or orally, or by any means or unequivocal conduct that allows a reasonable conclusion that such authorization or consent is revoked. 

In the event that you have any observation and / or comment about the handling and use of your personal data, or in the event that you consider that the company used a use contrary to the authorized and applicable laws; or you do not want to continue receiving information related to the company, according to this document, you can contact us at

Creaciones Segar S.A. PBX: (574) 377 18 59 National Free Line info@fajasmariae.com Calle 79 No 52D - 134 Medellín - Colombia 01 8000 423 670 www.fajasmariae.com 
Through a communication addressed to the Office located in the municipality of Itagüí, department of Antioquia: Calle 79 No 52D - 134, email: info@fajasmariae.com, telephone: (4) 377 18 59.

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