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POLICY OF TREATMENT OF PERSONAL DATA CREACIONES SEGAR S.A.

This policy of Processing of personal data 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, suppression, cession and of all those activities that constitute the processing of personal data supplied to this company.

The right of HÁBEAS DATA is the one that every person has to know, update and rectify the information that has been collected on it in files and databases of a public or private nature and guarantees to all citizens the power of decision and control over their personal information. Therefore, CREACIONES SEGAR S.A welcomes such provisions taking into account that for the development of its corporate purpose, is continuously compiling and performing various treatments to databases of customers, shareholders, suppliers, commercial allies and employees.


1. DEFINITIONS

Authorization: prior, express and informed consent issued by the owner of some personal data for the company to carry out the processing of their personal data.

Holder: natural person whose data are subject to treatment 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 persons determined or determinable or who may associate with a natural or legal person. Personal data may be public, semi-private or private.

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

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

Responsible for the treatment: natural or juridical person, public or private, that by itself or in association with others, decides on the data base 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. Public, among others, the data contained in public documents, enforced judicial sentences that are not subject to reservation and those related to the marital status of the persons.

Semiprivate data: Semiprivate information 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 persons or society in general, such as the financial and credit data of Comercial activity.

Creaciones Segar S.A. PBX: (574) 377 18 59 Free National 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 by its intimate or reserved nature is only relevant for the holder.

Sensitive details: those related to racial or ethnic origin, membership of trade unions, social or human rights organizations, political, religious, sexual, biometric or health beliefs. This information may not be granted by the owner of this data.

Privacy Notice: physical document, electronic generated by the person in charge of the treatment that is made available to the owner with the information regarding the existence of the policies of treatment of information that will be applicable to him, how to access them and the characteristics Of the Treatment that is intended to give the personal data.

2. IDENTIFICATION OF THE RESPONSIBLE AND RESPONSIBLE FOR THE TREATMENT OF INFORMATION
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 THAT HAVE CREATIONS FOLLOW S.A. REGARDING THE DATA HOLDERS
Creaciones Segar S.A. Recognizes that the personal data are the property of the owners of the same and that only such persons can decide on these. In this sense, it will make exclusive use for those purposes for which it is authorized under the terms of the law and for the sake of the foregoing it is permitted to inform the duties it assumes as the person in charge of the treatment:

A) The company must seek the means through which to obtain the express authorization by the holder of the data to carry out any type of treatment.

B) The company must clearly and expressly inform its customers, employees, suppliers and third parties in general of those who obtain 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, mechanics or request of data that is made, it will inform them the respective treatment in question. Some of these media can be the sending of 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 facultative character of responding and granting the respective requested information. D) In ​​all cases in which data are collected, the rights that all holders should be informed regarding their data. E) The company must inform the identification, physical or electronic address and telephone number of the person or area that will be the person in charge of the treatment, within which it will be possible to have the website fajasmariae.com

Creaciones Segar S.A. PBX: (574) 377 18 59 Free National 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 the holder 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 rests in the data bank , Request the update or correction of data and process consultations, all of which will be done through the consultation mechanisms or claims provided in this policy.

G) The company shall keep with due security the records of personal data stored to prevent its deterioration, loss, alteration, unauthorized or fraudulent use and periodically and in a timely manner to update and rectify the data, whenever the owners of the data Reports or requests.


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

4.1. With Customers:

A) Execute the existing contractual relationship

B) Provide the required products

C) Report on new products, or on changes in them

D) To exercise control in the delivery of products

E) Evaluate the quality of the service

F) Statistical, commercial, strategic and financial analyzes related to the corporate purpose of CREACIONES SEGAR S.A.

G) To send physical, electronic, cellular or mobile device, via text messages (SMS and / or MMS) or through any other analogous and / or digital means of communication, commercial, advertising or promotional information about the products, events And / or promotions of a commercial type, with the purpose of promoting, inviting, directing, executing, informing and in general carrying out campaigns, promotions or competitions of a commercial or advertising character, advanced by CREACIONES SEGAR SA And / or by third persons.

H) Transmission, transfer, sale and / or sale of database to third parties for statistical, commercial, strategic and financial purposes.

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

J) Provide, share, send, transfer 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) To advance processes of connection, execution and termination of the employment relationship and / or service provision.

B) Develop the process of selection, evaluation, employment relationship and / or service delivery.

C) To carry out the processes of affiliation to the social security.

D) Attend internal or external audit processes.

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

E) Provide, share, send or deliver your personal data to subsidiaries, affiliates, or subordinates of CREACIONES SEGAR S.A., and / or third parties, in the event that such companies require the information for contractual purposes.

F) Supply, share, send, transfer 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 CREACIONES SEGAR S.A. Require for the normal operation of your operation.

C) Provide, share, send, transfer and deliver your personal data to CREACIONES SEGARS S.A., affiliated or subordinated companies, and / or third parties in the event that such companies require the information for their purposes.

D) Attend internal or external audit processes.

E) Provide, share, send, transfer 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 meetings of shareholders.


5. TREATMENT OF SPECIAL DATA

Regarding the processing of sensitive data or data whose holder is a minor CREACIONES SEGAR S.A. Adecúa all the necessary measures for its protection and it 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 requested sensitive information, including, inter alia, information on racial or ethnic origin, membership of trade unions, social or human rights organizations, political, religious, Of sex life, biometrics or health data.

5.2. Data of minors: The provision of personal data whose holder is a minor is optional, and must be done with the permission of the parents or legal representatives of the minor. CREACIONES SEGAR S.A. Will only use, store and process personal data of minors who are children, descendants or who depend or are in charge of the employees or contractors of CREACIONES SEGAR S.A., and who are of a public nature. The purpose of such treatment will be solely 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 these purposes, CREATIONS

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

6. CASES IN WHICH THE AUTHORIZATION IS NOT REQUIRED:

The authorization of the Holder is not necessary when it is:

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) Treatment of information authorized by law for historical, statistical or scientific purposes.

E) Data related to the Civil Registry of Persons.

7. TO THOSE WHO CAN DELIVER INFORMATION FROM CREATIONS SEGAR SA. WITHOUT REQUIRING THE AUTHORIZATION OF THE DATA HOLDERS:

A) To the data owners, their heirs or representatives at any time and through any means when they so request to Creaciones Segar S.A.

B) To the judicial or administrative entities in exercise of functions that raise some requirement to the company so that the information is given to him.

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

8. RIGHTS OF THE HOLDERS.

Holders of personal data handled by CREACIONES SEGAR S.A by itself or through its representative and / or proxy or its successor in title may exercise the following rights in such a way as to satisfy the purposes of the law:

A) Right of knowledge: By virtue of which you may access personal data held by CREACIONES SEGAR SA, for the purpose of consulting them, whenever they deem it relevant, or whenever there are substantial changes to the Treatment Policies Of the information that motivate new consultations.

B) Right of update: The holder of the information has the right to update his personal data when they are partial, split or incomplete.

C) Right of rectification: The holder of the information has the right to rectify his personal data when those are inaccurate or misleading.

D) Right of suppression or revocation: The holder of the information may revoke the authorization and / or request the deletion of the data when in the treatment the principles, rights and constitutional and legal guarantees are not respected. The revocation will not proceed when the holder 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 the current legal norms, authorization to perform the treatment is not required.

Creaciones Segar S.A. PBX: (574) 377 18 59 Free National 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 complain to the Superintendency of Industry and Commerce: for violations 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. Requires in a free, prior, express and duly informed manner the authorization by the data owners and for this purpose has established suitable mechanisms guaranteeing for each case that it is possible to verify the granting of such authorization. It may be recorded in any medium, whether it is a physical document, electronic or in any format that guarantees its subsequent consultation through technical tools, technology and developments of computer security.

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

Who is responsible or responsible for collecting the information

Data collected  Purposes of treatment

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

Information about collecting sensitive data


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

In order to comply 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 who is legitimized under the terms of the Law. May be predetermined through technical means that facilitate the owner's automated manifestation. The Authorization may be granted in accordance with one of the following options: (i) In writing, (ii) Verbal or (iii) Through unequivocal conduct by the licensee that allows the reasonable conclusion that the authorization was granted. In no case can silence be assimilated to unequivocal conduct.

If within thirty (30) working days after the implementation of the previous mechanism, the holders did not contact the RESPONSIBLE or CHARGED to request the deletion of their personal data, the RESPONSIBLE and the MANAGER may continue processing the personal data Contained in its databases for the purpose or purposes foreseen and indicated in the information processing policy.

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

11. PROCEDURE FOR EXERCISING RIGHTS

To exercise your rights as an owner you can contact us from Monday to Friday from 8:00 a.m. to 12:00 p.m. and 2:00 p.m. to 5:00 p.m. at (4) 377 18 59 or at our premises located at Calle 79 No 52D - 134 Itagüí-Antioquia. You can also do it through our email info@fajasmarie.com.

For the purpose of an 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 process.

C) The physical or electronic address to send the response and inform about the status of the process.

D) The documents and other evidence that they intend to assert in case of any.

Consultations: 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 this term, the interested party will be informed before the expiration of the 10 days, stating the reasons for the delay and indicating the date on which his request will be taken, 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 observing the alleged breach of any of the legal duties, may submit a claim through any of the channels of communication noted above. Once received the respective claim CREACIONES SEGAR S.A. Will have the term of ten (10) business days to resolve it, counted from the day after the date of its receipt. In case CREACIONES SEGAR S.A is not competent to resolve the claim presented, it will transfer to whoever corresponds in a maximum term of five (5) business days and 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 following receipt to remedy the faults. After two (2) months from the date of the request, without the petitioner submitting the requested information, it will be understood that he has withdrawn from the request. Once received the claim, CREACIONES SEGAR S.A, will include in the respective database a legend that says "reclamation in process" and the reason of the same, in a term no more than five (5) business days. This legend will be maintained until the claim is decided.


12. ASSIGNMENT OF DATA.

When, for contractual reasons, CREACIONES SEGAR S.A SUPPLIERS request the assignment of the databases that the company handles, it 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 Free National Line info@fajasmariae.com Calle 79 No 52D - 134 Medellín - Colombia 01 8000 423 670 www.fajasmariae.com
Facilities located at 79 Street No 52D - 134, Itagüí - Antioquia; In such document must clearly and unequivocally express the need that motivates said request, confirm that for the use of that database will be in accordance with 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 the 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 thereof. Access to personal data is restricted to employees, contractors, representatives and agents CREACIONES SEGAR S.A., responsible for the processing of personal data and / or who need to know the same to perform their functions and develop the corporate purpose of the company.

14. EFFECT OF THE DATABASE

The personal data incorporated in the CREACIONES SEGAR S.A Database will be valid for the period necessary to fulfill its purposes and to enable compliance with its legal and contractual obligations. Once these terms expire and according to the provisions of article 28 of Law 962 of 2005, the data will rest for a period of ten (10) years counted from the end of the relationship with CREACIONES SEGAR S.A; Then the removal of the physical and / or magnetic files containing the personal information, as well as the personal data contained in the databases, will proceed.

The deadline given here is the exception of the databases corresponding to labor relations, which must be kept during the legal term of the company. In case of liquidation of the company the liquidator must deliver to all employees, a copy of the employment history.

Paragraph: Once the deadlines stipulated herein have been fulfilled or the deadlines established by law for the preservation of documents, 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 physically or electronically; Or orally, or by any means or unequivocal conduct that reasonably concludes that such authorization or consent is revoked.

In the event that you have any comments and / or comments on the handling and use of your personal data, or if you believe that the company has used contrary to the authorized and applicable laws, Or you do not wish to continue receiving information related to the company, according to this document, you may contact us

Creaciones Segar S.A. PBX: (574) 377 18 59 Free National 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.