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First. Purpose: This Personal Data Processing Policy (the "Treatment Policy"), aims to establish the criteria for thecollection, storage and use of personal data processed by Biotermica Innovacion S.A.S (“Biotermica”).

Second. Scope: The Treatment Policy will be applicable to the entirepersonal information that is registered in the Biotérmica databases, such asData Processing Manager.

Third. Definitions. In order to facilitate the understanding of this Treatment Policy, the following definitions will be taken into account:

a. Authorization: Prior, express and informed consent of the Owner tocarry out the Processing of personal data;

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

c.Personal data: Any information linked or that can be associated to one or
various determined or determinable natural persons;

d.Public data: Set of data related to the Holder, which due to its quality of
merchant, his profession or trade, which may be contained in records or
public documents, bulletins, judgments not subject to reservation.

e.Sensitive data: Those data that affect the privacy of the Owner or whose use
may generate their discrimination, such as those that reveal the racial or ethnic origin, political orientation, religious convictions or philosophical, belonging to unions, social organizations, rights
rights or that promotes the interests of any political party or that guarantee the rights and guarantees of opposition political parties as well as data relating to health, sexual life and biometric data.
Biotermica will not request, use, collect or store sensitive data, except
that will find itself enabled by virtue of the exceptions provided for in the
Article 6 of Law 1581 of 2012.

f.Treatment Manager: Natural or legal person, public or private,
that by itself or in association with others, performs the Data Processing
personal on behalf of the Data Controller.

g.Responsible for Treatment: Natural or legal person, public or private,
that by itself or in association with others, decides on the basis of data and/or the Data treatment. Biotérmica will be Responsible for the Treatment in the terms provided in this Treatment Policy.

h.Owner: Natural person whose personal data is subject to Treatment.

i.Processing: Any operation or set of operations on data personal, such as the collection, storage, use, circulation or suppression.

Fourth. Responsible for the Treatment.
The Data Controller will be Biotérmica Innovación S.A.S., a company domiciled in the city of Bogotá, Colombia, identified with NIT 901.477.298-3, web page, phone: 3222509934.

Fifth. Treatment and purpose. The treatment that Biotérmica will carry out with the Personal information of the Holder will be the following:

a.Manage the necessary information for your business records.

b.Respond to inquiries, requests and complaints that are made by the Headlines.

c. Comply with the contracts entered into with its clients.

d.Process by electronic means the information related to its clients and business.

e.Being able to contact natural persons with whom you have or have had relationship, including workers, suppliers, customers, shareholders, creditors and debtors.

f.Meet judicial or administrative requirements and give compliance with judicial or legal orders.

g.Register Personal Data in the information systems of Biotermica and in their commercial and operational databases.

h.Manage the Biotermica selection processes and verify their references labor and personal.

i.Make payments related to the execution of commercial contracts or labor.

j.The management of prevention of Money Laundering, Financing of Terrorism and Financing for the Proliferation of Weapons of Mass Destruction(“LA/FT/FPADM”), without being limited exclusively to the consultation in lists restrictive.

Sixth. Rights of the Holders. The Holders of the Data have the right to:

a.Free access to the Data provided that have been subject to treatment.

b.Know, update and rectify your information against partial data, inaccurate, incomplete, fractional, misleading, or those whose treatment is prohibited or has not been authorized.

c.Request proof of authorization granted.

d.Revoke the authorization and/or request the deletion of the data, as long as it is not there is a legal or contractual duty that prevents their elimination.

e.Refrain from answering questions about sensitive data.

f.Submit complaints to the Superintendence of Industry and Commerce for infractions.

Paragraph. The rights of the Holders may be exercised by (i) the Holder; (ii) by their successors in title, who must prove such quality; (iii) for the representative or proxy of the Holder, prior accreditation of said quality.

Seventh. Duties of the Treatment Manager. Biotermica declares that
knows that the Personal Data collected is the property of its Holders and only they can decide on them, therefore, Biotermica will make use of the Personal Data collected exclusively for the purposes for which it is is empowered by virtue of current regulations.

Biotermica will meet the duties provided for in article 17 of Law 1581 of 2012
and other regulations that regulate, modify or replace it.

Eighth. Attention to requests, queries and claims. 

Ninth. Procedure for exercising the rights of Data Holders Personal. Any query or claim related to the Treatment of Personal Data of the Holders will require the provision of the following information:

a.Full names and surnames.

b.Identification number.

c.Contact information (physical and/or electronic address, contact telephone number).

d.Means of notification to respond.

e.Reasons and facts that give rise to the claim or petition with a brief description of the right you wish to exercise (know, update, rectify, request proof of the authorization granted, revoke it, delete, access information).

Biotérmica will have a term of ten (10) business days to resolve its claim counted from the day following the date of receipt. In it event in which it is not possible to address the claim within the term scheduled, Biotérmica will inform the interested party of the reasons for the delay and the date in which your claim will be addressed, which in no case may exceed five (5) days working days following the expiration of the first term.

Tenth. Authorization by the Holders. Biotermica will request prior, express and informed authorization to the Holders of Personal Data on which the Treatment is required. The manifestation of will may be done through different means, such as: (i) in writing, by completing an authorization form for Treatment of Personal Data; (ii) through a telephone conversation or video call;(ii) by accepting contractual terms and conditions.

Eleventh. Information Protection. Biotermica has implemented the security measures necessary to protect the confidentiality of the Data supplied by the Holders and prevent their loss, adulteration, consultation or unauthorized use.

Twelfth. Validity. This Treatment Policy is effective as of 1st of February 2023.
The databases in which the Personal Data will be registered will have a validity equal to the time in which the information is kept and used for the purposes described in this Policy. Once these objectives are met and
provided there is no legal or contractual duty to retain your information,Your data will be removed from the Biotermica databases.

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