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Data Processing Policy

Purpose

To establish the criteria for the collection, storage, use, circulation and deletion of personal data processed by TARGET INSIGHTS SAS.

Scope

This policy applies to all personal information recorded in the databases of TARGET INSIGHTS SAS, which acts as the Data Controller responsible for processing personal data.

Obligations

This policy is mandatory and strictly binding for TARGET INSIGHTS SAS.

Data Controller

TARGET INSIGHTS SAS, a commercial company legally incorporated under NIT 900.096.224-1, with its principal domicile at Calle 95 # 13-55, of. 307 in the city of Bogotá, Republic of Colombia. Website www.timr.com.co. Phone (601) 7448587 in the city of Bogotá.

Definitions

  • Authorization: the Data Subject's prior, express and informed consent to carry out the Processing of personal data.
  • Database: an 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 identified or identifiable natural persons.
  • Semi-private data: data that is neither intimate, reserved nor public in nature, and whose disclosure may be of interest not only to the data subject but to a certain sector or group of people, or to society in general, such as financial and credit data.
  • Private data: data that, due to its intimate or reserved nature, is relevant only to the Data Subject.
  • Sensitive data: data that affects the Data Subject's privacy or whose misuse may lead to discrimination against them, such as data revealing racial or ethnic origin, political affiliation, religious or philosophical beliefs, membership in unions or human-rights or social organizations, as well as data concerning health, sex life, and biometric data.
  • Data Processor: a natural or legal person who carries out the Processing of personal data on behalf of the Data Controller.
  • Data Controller: a natural or legal person who makes decisions regarding the database and/or the Processing of the data.
  • Data Subject: the natural person whose personal data is subject to Processing.
  • Processing: any operation performed on personal data, such as collection, storage, use, circulation or deletion.

Processing is governed by the principles of legality, purpose, freedom, truthfulness or quality, transparency, restricted access and circulation, security and confidentiality, in accordance with Colombian Law 1581 of 2012.

Processing and Purpose

To carry out the actions relevant to the company's corporate purpose as they relate to fulfilling the contract entered into with the Data Subject.

To conduct satisfaction or opinion surveys regarding the services offered by TARGET INSIGHTS SAS and any third party with which it has a contractual relationship for carrying out such activities. To contact the Data Subject by phone, email and/or WhatsApp to conduct surveys, studies and/or confirm personal data. To share information with third parties with which a contractual relationship exists, where necessary to fulfill the contracted purpose.

Rights of Data Subjects

As the subject of your personal data, you have the right to: (i) access, free of charge, the data subject to processing; (ii) know, update and correct your information; (iii) request proof of the authorization granted; (iv) file complaints with the Superintendency of Industry and Commerce (SIC); (v) revoke the authorization and/or request deletion of the data, provided there is no legal or contractual duty preventing it; (vi) refrain from answering questions about sensitive data; (vii) be informed, upon request, of the use given to your personal data.

Handling of Requests, Inquiries and Complaints

(Articles 14 and 15 of Law 1581 of 2012). Data Subjects or their successors may consult, access, update, correct and delete data, or revoke authorization over personal information held in any database of TARGET INSIGHTS SAS, by writing to tecnologia@timr.com.co.

Inquiries will be answered within a maximum of ten (10) business days. Complaints will be answered within a maximum of fifteen (15) business days from the day after they are received, extendable as provided by law.

Procedure for Exercising Habeas Data Rights

To submit and process your request, please provide: your full name, contact details (physical and/or email address and phone numbers), how you would like to receive a response, the reason(s) for the complaint with a brief description of the right you wish to exercise, signature (if applicable), and identification number. Once the terms of Law 1581 of 2012 have been exhausted, the Data Subject may bring the matter before the Superintendency of Industry and Commerce — Data Protection Bureau.

Document G-P01-A4, Version 02.