PERSONAL DATA PROCESSING POLICY

1. LEGAL REGULATIONS AND SCOPE OF APPLICATION:

This personal data processing policy is prepared in accordance with the provisions of the Political Constitution, Law 1581 of 2012, Regulatory Decree 1377 of 2013 and other complementary provisions and will be applied by QUICK HELP S.A.S., with respect to the collection, storage, use, circulation, deletion and all those activities that constitute the processing of personal data.

2. DEFINITIONS:

For the purposes of the execution of this policy and in accordance with legal regulations, the following definitions will apply:

1. Authorization: Prior, express and informed consent of the Owner to carry out the Processing of personal data;
2. Privacy Notice: Physical, electronic or any other format document generated by the Controller that is made available to the Data Subject for the processing of his/her personal data. The Privacy Notice informs the Data Subject of the information regarding the existence of the information processing policies that will be applicable to him/her, the way to access them and the purpose of the processing that is intended to be given to the personal data;
3. Database: Organized set of personal data that is subject to processing;
4. Personal data: Any information linked to or that can be associated with one or more specific or identifiable natural persons;
5. Public data: 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. Public data includes, among others, data relating to the civil status of persons, their profession or occupation, their status as a merchant or public servant and those that can be obtained without reservation. By their nature, public data may be contained, among others, in public records, public documents, gazettes and official bulletins;
6. Private data: This is data that, due to its intimate or reserved nature, is only relevant to the owner;
7. Sensitive data: Sensitive data is understood to be data that affects the privacy of the Data Subject or whose misuse may lead to discrimination, such as data that reveals racial or ethnic origin, political orientation, religious or philosophical beliefs, membership in unions, social organizations, human rights organizations or that promote 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;
8. Data Processor: Natural or legal person, public or private, who by itself or in association with others, carries out the processing of personal data on behalf of the Data Controller;
9. Data Controller: Natural or legal person, public or private, who by itself or in association with others, decides on the database and/or the processing of the data;
10. Owner: Natural person whose personal data is subject to processing;
11. Treatment: Any operation or set of operations on personal data, such as collection, storage, use, circulation or deletion thereof.

3. PURPOSE FOR WHICH PERSONAL DATA IS COLLECTED AND PROCESSED:

QUICK HELP S.A.S., may use personal data to:

1. Execute the existing contractual relationship with its clients, suppliers and employees, including the payment of contractual obligations;
2. Provide the services and/or products required by its users;
3. To inform about new products or services and/or changes to them;
4. Evaluate the quality of service;
5. Conduct internal studies on consumer habits;
6. Send to the physical, electronic, cell phone or mobile device, via text messages (SMS and/or MMS) or through any other analogous and/or digital means of communication created or to be created, commercial, advertising or promotional information about the products and/or services, events and/or promotions of a commercial or non-commercial nature of these, in order to promote, invite, direct, execute, inform and in general, carry out campaigns, promotions or contests of a commercial or advertising nature, advanced by QUICK HELP S.A.S., and/or by third parties;
7. Develop the selection, evaluation, and employment placement process;
8. Support internal or external audit processes;
9. Record the information of employees and/or pensioners (active and inactive) in the databases of QUICK HELP S.A.S.; i) Those indicated in the authorization granted by the data owner or described in the respective privacy notice, as the case may be;
10. Provide, share, send or deliver your personal data to subsidiaries, affiliates, or subordinate companies of QUICK HELP S.A.S., located in Colombia or any other country in the event that said companies require the information for the purposes indicated here.

Regarding data (i) collected directly at security checkpoints, (ii) taken from documents provided by individuals to security personnel, and (iii) obtained from video recordings made inside or outside the facilities of QUICK HELP S.A.S., these will be used for the security of individuals, property, and facilities of QUICK HELP S.A.S. and may be used as evidence in any type of proceeding. If personal data is provided, such information will be used only for the purposes stated herein and, therefore, QUICK HELP S.A.S. will not sell, license, transmit, or disclose it, unless: (i) there is express authorization to do so; (ii) it is necessary to allow contractors or agents to provide the services entrusted; (iii) it is necessary in order to provide our services and/or products; (iv) it is necessary to disclose it to entities that provide marketing services on behalf of QUICK HELP S.A.S., or other entities with which joint marketing agreements are in place; (v) the information is related to a merger, consolidation, acquisition, divestiture, or other corporate restructuring process; (vi) it is required or permitted by law. QUICK HELP S.A.S., may subcontract third parties to process certain functions or information. When the processing of personal information is actually subcontracted to third parties or personal information is provided to third-party service providers, QUICK HELP S.A.S., warns said third parties about the need to protect said personal information with appropriate security measures.

4. PRINCIPLES APPLICABLE TO THE PROCESSING OF PERSONAL DATA:

The processing of personal data at QUICK HELP S.A.S. will be governed by the following principles:

1. Purpose principle: The processing of personal data collected must obey a legitimate purpose, which must be informed to the Owner;
2. Principle of freedom: The Processing may only be carried out with the prior, express and informed consent of the Data Subject. Personal data may not be obtained or disclosed without prior authorization, or in the absence of a legal or judicial mandate waiving consent;
3. Principle of truthfulness or quality: The information subject to processing must be truthful, complete, accurate, up-to-date, verifiable and understandable. Partial, incomplete, fractional or misleading data will not be processed;
4. Principle of transparency: In the Treatment, the right of the Owner to obtain from **QUICK HELP S.A.S., **at any time and without restrictions, information about the existence of data that concerns him/her must be guaranteed;
5. Principle of restricted access and circulation: The Processing is subject to the limits arising from the nature of the personal data, the provisions of this law and the Constitution. Personal data, except for public information, and the provisions of the authorization granted by the data owner, may not be available on the Internet or other means of dissemination or mass communication, unless access is technically controllable to provide restricted knowledge only to the Owners or authorized third parties;
6. Security principle: The information subject to processing by QUICK HELP S.A.S., must be protected through the use of the technical, human and administrative measures that are necessary to provide security to the records, avoiding their adulteration, loss, consultation, use or unauthorized or fraudulent access;
7. Principle of confidentiality: All persons involved in the processing of personal data are obliged to guarantee the confidentiality of the information, even after their relationship with any of the tasks that comprise the processing has ended.

FIRST PARAGRAPH: In the event that sensitive personal data is collected, the Owner may refuse to authorize its Processing.

5. CONTROLLER OF PERSONAL DATA:

Pursuant to Law 1581 of 2012 and its Regulatory Decree 1377 of 2013, the following information is provided regarding the party responsible for the processing of personal data:

1. Company name of the data controller: QUICK HELP S.A.S. with NIT. 830.124.778-5 , Address of the data controller: Tv. 93 No. 51-98 Und. 24 and 25 Bogotá, Colombia
2. Email of the person responsible for the treatment: sac@quickmexico.mx
3. Telephone number of the person responsible for the treatment: +571 7470547
4. Period of validity of the database: All information collected about users will be stored by the data controller (QUICK HELP S.A.S.) for a period of 5 years, counted from the same day in which the information is provided. After five (5) years, the information will be deleted by the data controller.

6. RIGHTS OF THE OWNERS OF PERSONAL DATA PROCESSED BY DEQUICK HELP S.A.S.:

The holders of personal data, either themselves or through their representative and/or agent or their successor in title, may exercise the following rights with respect to the personal data that are subject to processing by: QUICK HELP S.A.S.:

1. Right of access: By virtue of which you may access the personal data that is under the control of QUICK HELP S.A.S., in order to consult it free of charge at least once each calendar month, and each time there are substantial modifications to the Information Treatment Policies that motivate new consultations;
2. Right to update, rectification and deletion: By virtue of which you may request the update, rectification and/or deletion of the personal data being processed, in such a way that the purposes of the processing are met;
3. 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;
4. Right to be informed regarding the use of personal data;
5. Right to file complaints with the Superintendency of Industry and Commerce for violations of the provisions of current regulations on the processing of personal data;
6. Right to require compliance with orders issued by the Superintendency of Industry and Commerce.

Revoke at any time the authorization of personal data granted to the person responsible, provided that there is no legal or contractual obligation to remain in the database.

SENSITIVE DATA OF CHILDREN AND ADOLESCENTS, in the event that data from minors is received, the company will follow the parameters established by the regulations. It is made clear that the handling of data of minors will always be done for their benefit and in any case with respect for the best interests of children and adolescents and their fundamental rights. QUICK HELP S.A.S., as far as possible, does not process sensitive data, however, if required, it has established the possibility that the owner of the data does not have to answer questions or circumstances that may involve this category of data.

FIRST PARAGRAPH: For the purposes of exercising the rights described above, both the owner and the person representing him must prove their identity and, if applicable, the capacity by virtue of which they represent the owner.

SECOND PARAGRAPH: The rights of minors will be exercised through the persons who are authorized to represent them, who will guarantee the defense of their rights.

7. DUTIES OF QUICK HELP S.A.S.:

All those required to comply with this policy must bear in mind that QUICK HELP S.A.S., is obliged to comply with the duties imposed by law in this regard. Consequently, the following obligations must be fulfilled: A. Duties when acting as responsible: (i) Request and retain, under the conditions provided in this policy, a copy of the respective authorization granted by the owner. (ii) Clearly and sufficiently inform the owner of the purpose of the collection and the rights that assist him by virtue of the authorization granted. (iii) Inform, at the request of the owner, about the use given to his personal data. (iv) Process the queries and claims made in the terms indicated in this policy. (v) Ensure that the principles of veracity, quality, security and confidentiality in the terms established in the following policy. (vi) Keep the information under the necessary security conditions to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access. (vii) Update the information when necessary. (viii) Rectify personal data when appropriate. B. Duties when acting as Data Processor. If you process data on behalf of another entity or organization (Data Controller), you must comply with the following duties: (i) Establish that the Data Controller is authorized to provide the personal data that you will process as Data Processor. (ii) Guarantee the owner, at all times, the full and effective exercise of the right to habeas data. (iii) Keep the information under the security conditions necessary to prevent its adulteration, loss, consultation, unauthorized or fraudulent use or access. (iv) Carry out the timely update, rectification or deletion of the data. (v) Update the information reported by the Data Controllers within five (5) business days from its receipt. (vi) Process the queries and claims made by the owners in the terms indicated in this policy. (vii) Register the legend “claim in process” in the database in the manner established in this policy. (ix) Insert the legend “information under judicial discussion” in the database once notified by the competent authority about judicial proceedings related to the quality of personal data. (x) Refrain from circulating information that is being disputed by the owner and whose blocking has been ordered by the Superintendency of Industry and Commerce. (xi) Allow access to the information only to persons authorized by the owner or empowered by law for this purpose. (xii) Inform the Superintendency of Industry and Commerce when violations of security codes occur and there are risks in the administration of the information of the owners. (xiii) Comply with the instructions and requirements issued by the Superintendency of Industry and Commerce. C. Duties when processing through a Manager (i) Provide the Manager of the processing only with personal data whose processing is previously authorized. For the purposes of national or international data transmission, a personal data transmission contract must be signed or contractual clauses agreed upon as established in article 25 of decree 1377 of 2013. (ii) Guarantee that the information provided to the Data Processor is true, complete, accurate, updated, verifiable and understandable. (iii) Communicate in a timely manner to the Data Processor all new developments regarding the data previously provided and adopt other necessary measures so that the information provided to the Data Processor remains up to date. (iv) Inform in a timely manner the Data Processor of any corrections made to personal data so that the Data Processor may proceed to make the relevant adjustments. (v) Demand from the Data Processor, at all times, respect for the security and privacy conditions of the owner's information. (vi) Inform the Data Processor when certain information is being disputed by the owner, once the claim has been submitted and the respective process has not been completed. D. Duties with respect to the Superintendency of Industry and Commerce (i) Inform it of any possible violations of security codes and the existence of risks in the management of the information of the holders. (ii) Comply with the instructions and requirements issued by the Superintendency of Industry and Commerce.

The transfer of personal data of any kind to countries that do not provide adequate levels of data protection is prohibited. A country is deemed to offer an adequate level of data protection when it complies with the standards set by the Superintendence of Industry and Commerce on the subject, which in no case may be lower than those required by this law for its recipients.

This prohibition shall not apply in the case of:

1. Information for which the Owner has given his express and unequivocal authorization for the transfer;
2. Exchange of medical data, when required for the Treatment of the Owner for reasons of public health or hygiene;
3. Bank or stock transfers, in accordance with the applicable legislation;
4. Transfers agreed upon within the framework of international treaties to which the Republic of Colombia is a party, based on the principle of reciprocity;
5. Transfers necessary for the execution of a contract between the Owner and the Data Controller, or for the implementation of pre-contractual measures, provided that the Owner's authorization is obtained;
6. Transfers legally required to safeguard the public interest, or for the recognition, exercise or defence of a right in a judicial process.

8. REQUEST FOR AUTHORIZATION FROM THE OWNER OF THE PERSONAL DATA:

Prior to and/or at the time of collecting personal data, QUICK HELP S.A.S. will request the owner of the data for authorization to collect and process it, indicating the purpose for which the data is requested, using for these purposes automated technical means, written or oral, that allow for the preservation of proof of the authorization and/or the unequivocal conduct described in article 7 of Decree 1377 of 2013. Said authorization will be requested for as long as is reasonable and necessary to satisfy the needs that gave rise to the request for the data and, in any case, in compliance with the legal provisions governing the matter.

9. PRIVACY NOTICE:

In the event that QUICK HELP S.A.S., is unable to make this information processing policy available to the owner of the personal data, it will publish the privacy notice attached to this document, the text of which will be kept for later consultation by the owner of the data and/or the Superintendence of Industry and Commerce.

10. TEMPORARY LIMITATIONS ON THE PROCESSING OF PERSONAL DATA:

QUICK HELP S.A.S., may only collect, store, use or circulate personal data for as long as is reasonable and necessary, in accordance with the purposes that justified the processing, taking into account the provisions applicable to the subject matter in question and the administrative, accounting, tax, legal and historical aspects of the information. Once the purpose(s) of the processing have been fulfilled and without prejudice to legal regulations that provide otherwise, it will proceed to delete the personal data in its possession. Notwithstanding the foregoing, personal data must be retained when required to comply with a legal or contractual obligation.

11. AREA RESPONSIBLE AND PROCEDURE FOR THE EXERCISE OF THE RIGHTS OF THE OWNERS OF PERSONAL DATA:

The ADMINISTRATIVE AREA of QUICK HELP S.A.S. will be responsible for addressing the requests, complaints and claims made by the data owner in exercising the rights contemplated in section 5 of this policy, with the exception of those described in literal e). For such purposes, the owner of the personal data or whoever exercises his or her representation may send his or her request, complaint or claim to our offices or through the website.

The request, complaint or claim must contain the identification of the Holder, the description of the facts that give rise to the claim, the address, and accompanying documents that the claimant wishes to assert. If the claim is incomplete, the interested party will be required within five (5) days following receipt of the claim to correct the deficiencies. After two (2) months from the date of the request, if the applicant does not submit the required information, it will be understood that the claim has been withdrawn. In the event that the person receiving the claim is not competent to resolve it, he/she will forward it to the appropriate person within a maximum period of two (2) business days and will inform the interested party of the situation. Once the complete claim has been received, a legend stating “claim in process” and the reason for it will be included in the database within a period of no more than two (2) business days. This legend must be maintained until the claim is decided. The maximum period for addressing the claim will be fifteen (15) business days counted from the day following the date of receipt. When it is not possible to address the claim within said term, the interested party will be informed of the reasons for the delay and the date on which his claim will be addressed, which in no case may exceed eight (8) business days following the expiration of the first term.

12. SECURITY MEASURES:

In accordance with the security principle established in Law 1581 of 2012, QUICK HELP S.A.S. will adopt the technical, human and administrative measures necessary to ensure the security of the records, preventing their alteration, loss, consultation, unauthorized or fraudulent use or access. The personnel who process the personal data will execute the established protocols in order to guarantee the security of the information.

13. LAW AND JURISDICTION:

Any interpretation, judicial or administrative action arising from the processing of personal data will be subject to the personal protection regulations established in the Republic of Colombia and the administrative or jurisdictional authorities competent to resolve any concern, complaint or claim regarding the same will be those of the Republic of Colombia.

14. EFFECTIVE DATE:

This Personal Data Policy enters into force as of June 1, 2018.

15. PRIVACY NOTICE

15.1 PURPOSE FOR WHICH PERSONAL DATA IS COLLECTED AND PROCESSED:

QUICK HELP S.A.S., may use personal data to:

1. Execute the existing contractual relationship with its clients, suppliers and employees, including the payment of contractual obligations;
2. Provide the services and/or products required by its users;
3. To inform about new products or services and/or changes to them;
4. Evaluate the quality of service;
5. Conduct internal studies on consumer habits;
6. Send to the physical, electronic, cell phone or mobile device, via text messages (SMS and/or MMS) or through any other analogous and/or digital means of communication created or to be created, commercial, advertising or promotional information about the products and/or services, events and/or promotions of a commercial or non-commercial nature of these, in order to promote, invite, direct, execute, inform and in general, carry out campaigns, promotions or contests of a commercial or advertising nature, advanced by QUICK HELP S.A.S., and/or by third parties;
7. Develop the selection, evaluation, and employment placement process;
8. Support internal or external audit processes; i) Record employee and/or retiree information (active and inactive) in the databases of QUICK HELP S.A.S.:
9. Los indicados en la autorización otorgada por el titular del dato o descritos en el aviso de privacidad respectivo, según sea el caso;
10. Provide, share, send or deliver your personal data to subsidiaries, affiliates, or subordinate companies of QUICK HELP S.A.S., located in Colombia or any other country in the event that said companies require the information for the purposes indicated here.

Regarding the data (i) collected directly at security checkpoints, (ii) taken from documents provided by individuals to security personnel, and (iii) obtained from video recordings made inside or outside the facilities of QUICK HELP S.A.S., these will be used for the security of the individuals, property, and facilities of QUICK HELP S.A.S. and may be used as evidence in any type of process.

If personal data is provided, such information will be used only for the purposes stated herein, and therefore QUICK HELP S.A.S., will not sell, license, transmit, or disclose it, unless: (i) there is express authorization to do so; (ii) it is necessary to allow contractors or agents to provide the services entrusted; (iii) it is necessary in order to provide our services and/or products; (iv) it is necessary to disclose it to entities that provide marketing services on behalf of QUICK HELP S.A.S., or to other entities with which we have joint marketing agreements; (v) the information is related to a merger, consolidation, acquisition, divestiture, or other corporate restructuring process; (vi) it is required or permitted by law.

QUICK HELP S.A.S., may subcontract third parties to process certain functions or information. When personal information processing is actually subcontracted to third parties or personal information is provided to third-party service providers, QUICK HELP S.A.S., warns such third parties of the need to protect such personal information with appropriate security measures, prohibits the use of the information for their own purposes, and requests that the personal information not be disclosed to others.

15.2 RIGHTS OF PERSONAL DATA OWNERS:

The holders of personal data, either themselves or through their representative and/or agent or their successor in title, may exercise the following rights with respect to the personal data that are subject to processing by: QUICK HELP S.A.S.:

1. Right of access: By virtue of which you may access the personal data that is under the control of QUICK HELP S.A.S., in order to consult it free of charge at least once each calendar month, and each time there are substantial modifications to the Information Treatment Policies that motivate new consultations;
2. Right to update, rectification and deletion: By virtue of which you may request the update, rectification and/or deletion of the personal data being processed, in such a way that the purposes of the processing are met;
3. Derecho a solicitar prueba de la autorización: salvo en los eventos en los cuales, según las normas legales vigentes, no se requiera de la autorización para realizar el tratamiento;
4. Right to be informed regarding the use of personal data;
5. Right to file complaints with the Superintendency of Industry and Commerce: for violations of the provisions of current regulations on the processing of personal data;
6. Right to require compliance with orders issued by the Superintendency of Industry and Commerce.

15.3 PERSONAL DATA PROCESSING POLICY:

It can be consulted at the physical facilities of QUICK HELP S.A.S. o en su página web.

The ADMINISTRATIVE AREA of QUICK HELP S.A.S. will be responsible for addressing the requests, complaints and claims made by the data owner in exercising the rights contemplated in section 5 of the personal data processing policy, with the exception of those described in section e). For such purposes, the owner of the personal data or whoever exercises his or her representation may send his or her request, complaint or claim through the website.