CHAPTER I

Purpose, Scope of Application and Definitions




1. Article 1. Object. The purpose of this manual is to establish the policies and procedures of 1LABS SAS for the treatment of personal data, in compliance with Law 1581 of 2012 "By which general provisions are issued for the protection of personal data" and Decree 1377 of 2013 “By which Law 1581 of 2012 is partially regulated”.

2. Article 2. Scope of Application. The provisions contained in this manual apply to the personal data registered in the databases of 1LABS SAS

3. Article 3. Definitions. For the purposes of this manual, and in accordance with the provisions of article 3 of Law 1581 of 2012 and article 3 of Decree 1377 of 2013, it is understood as:

   a) Authorization: Prior, express and informed consent of the Holder to carry out the Processing of personal data;

   b) Privacy Notice: Verbal or written communication generated by the Responsible, addressed to the Holder for the Treatment of his personal data, through which he is informed about the existence of the information Treatment policies that will be applicable, the form to access them and the purposes of the Treatment that is intended to be given to personal data;

   c) Database: Organized set of personal data that is subject to Treatment;

   d) Personal data: Any information linked to or that may be associated with one or more determined or determinable natural persons;

   e) Public data: It is the data that is not semi-private, private or sensitive. Public data is considered, among others, data related to the marital status of people, their profession or trade and their quality as a merchant or public servant. Due to its nature, public data may be contained, among others, in public registries, public documents, official gazettes and bulletins and duly executed judicial sentences that are not subject to reservation;

   f) Sensitive data: Sensitive data is understood to be that which affects the privacy of the Holder or whose improper use may generate discrimination, such as those that reveal racial or ethnic origin, political orientation, religious or philosophical convictions, membership of unions, social, 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 related to health, sexual life, and biometric data;

   g) Person in Charge of Treatment: Natural or legal person, public or private, that by itself or in association with others, performs the Treatment of personal data on behalf of the Person Responsible for Treatment;

   h) 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;

   i) Owner: Natural person whose personal data is subject to Treatment;

   j) Transfer: The transfer of data takes place when the Person in Charge and/or Person in Charge of the Processing of personal data, located in Colombia, sends the information or personal data to a recipient, who in turn is Responsible for the Treatment and is within or outside the country;

   k) Transmission: Treatment of personal data that implies the communication of the same inside or outside the territory of the Republic of Colombia when its purpose is to carry out a Treatment by the Manager on behalf of the Responsible;

   l) Treatment: Any operation or set of operations on personal data, such as collection, storage, use, circulation or deletion.





CHAPTER II

Guiding Principles




4. Article 4. Principles for the Treatment of personal data. In the development, interpretation and application of Law 1581 of 2012, and in accordance with the provisions of article 4 of Law 1581 of 2012, 1LABS SAS applies, in a harmonic and comprehensive manner, the following principles:

   a) Principle of legality in terms of data processing: The processing of personal data is a regulated activity that must be subject to the provisions of Law 1581 of 2012 and the other provisions that develop it;

   b) Principle of purpose: The Treatment must obey a legitimate purpose in accordance with the Constitution and the Law, which must be informed to the Holder;

   c) Principle of freedom: Treatment can only be exercised with the prior, express and informed consent of the Holder. Personal data may not be obtained or disclosed without prior authorization, or in the absence of a legal or judicial mandate that relieves consent;

   d) Principle of veracity or quality: The information subject to Treatment must be truthful, complete, exact, updated, verifiable and understandable. The Processing of partial, incomplete, fragmented or misleading data is prohibited;

   e) Principle of transparency: In the Treatment, the right of the Owner to obtain from the Treatment Manager or the Treatment Manager, at any time and without restrictions, information about the existence of data that concerns him or her;

   f) Principle of access and restricted circulation: Treatment is subject to the limits derived from the nature of personal data, the provisions of Law 1581 of 2012 and the Constitution. In this sense, the Treatment can only be done by persons authorized by the Owner and/or by the persons provided for in Law 1581 of 2012;

   Personal data, except public information, 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 Holders or authorized third parties in accordance with Law 1581 of 2012. ;

   g) Principle of security: The information subject to Treatment by the Person Responsible for Treatment or Person in Charge of Treatment, must be handled with the technical, human and administrative measures that are necessary to grant security to the records, avoiding their adulteration, loss, consultation, use or unauthorized or fraudulent access;

   h) Principle of confidentiality: All persons involved in the Processing of personal data that are not of a public nature are obliged to guarantee the confidentiality of the information, even after the end of their relationship with any of the tasks that the Treatment comprises, being able to only supply or communicate personal data when this corresponds to the development of the activities authorized in Law 1581 of 2012 and in the terms thereof.





CHAPTER III

Rights and Legal Conditions for Data Processing




5. Article 5. Rights of the Holders. In accordance with the provisions of article 8 of Law 1581 of 2012, the Holder of personal data has the following rights:

   a) Know, update and rectify your personal data against 1LABS SAS This right can be exercised, among others, against partial, inaccurate, incomplete, fragmented, misleading data, or those whose Treatment is expressly prohibited or has not been authorized ;

   b) Request proof of the authorization granted to 1LABS SAS except when expressly excepted as a requirement for Treatment, in accordance with the provisions of article 10 of Law 1581 of 2012;

   c) Be informed by 1LABS SAS, upon request, regarding the use that has been given to your personal data;

   d) Submit complaints to the Superintendency of Industry and Commerce for violations of the provisions of Law 1581 of 2012 and other regulations that modify, add or complement it;

   e) Revoke the authorization and/or request the deletion of the data when the principles, rights and constitutional and legal guarantees are not respected in the Treatment. The revocation and/or deletion will proceed when the Superintendence of Industry and Commerce has determined that in the Treatment 1LABS SAS has incurred in conduct contrary to Law 1581 of 2012 and the Constitution;

   f) Free access to personal data that has been processed by 1LABS SAS

6. Article 6. Authorization of the Holder. In accordance with the provisions of article 9 of Law 1581 of 2012, without prejudice to the exceptions provided by law, the Treatment requires the prior and informed authorization of the Holder, which must be obtained by any means that may be object of subsequent consultation. Chapter IX describes the means used by 1LABS SAS for the authorization of the Holder.

7. Article 7. Cases in which authorization is not necessary. In accordance with the provisions of article 10 of Law 1581 of 2012, the authorization of the Holder is not necessary when it comes to:

   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.

   Whoever accesses personal data without prior authorization must in any case comply with the provisions contained in Law 1581 of 2012.

8. Article 8. Provision of information. In accordance with article 11 of Law 1581 of 2012, the requested information may be provided by any means, including electronic means, as required by the Owner. The information must be easy to read, without technical barriers that prevent its access and must fully correspond to what is stored in the database. Chapter IX describes the means used by 1LABS SAS to supply information. para el suministro de la

9. Article 9. Duty to inform the Holder. In accordance with article 12 of Law 1581 of 2012, 1LABS SAS, when requesting authorization from the Owner, clearly and expressly reports the following:

   a) The Treatment to which your personal data will be subjected and the purpose of the same;

   b) The optional nature of the answer to the questions that are asked, when they deal with sensitive data or the data of children and adolescents;

   c) The rights that assist you as Holder;

   d) The identification, physical or electronic address and telephone number of 1LABS SAS as Data Controller.

   1LABS SAS keeps proof of compliance with the provisions of article 12 of Law 1581 of 2012 and, when the Holder requests it, it must deliver a copy of it.

10. Article 10. Persons to whom the information may be provided. In accordance with article 13 of Law 1581 of 2012, the information that meets the conditions established in Law 1581 of 2012 can be provided to the following people:

    a) To the Holders, their successors in title or their legal representatives;

    b) To public or administrative entities in the exercise of their legal functions or by court order;

    c) To third parties authorized by the Holder or by law.





CHAPTER IV

Exercise of the Rights of the Holders




11. Article 11. Legitimation for the exercise of the rights of the owner. In accordance with article 20 of decree 1377 of 2013. The rights of the Holders established in the Law, may be exercised by the following persons:

    a) By the Holder, who must sufficiently prove his identity by the different means made available by the person in charge.

    b) By their successors in title, who must certify such quality.

    c) By the representative and/or proxy of the Holder, prior accreditation of the representation or power of attorney.

    d) By stipulation in favor of another or for another.

12. Article 12. Of the right of access. In accordance with article 21 of Decree 1733 of 2013, 1LABS SAS establishes simple and agile mechanisms that are permanently available to the Holders so that they can access the personal data that is under the control of 1LABS SAS and exercise their rights over them.

    The Holder can consult his personal data free of charge: (i) at least once every calendar month, and (ii) every time there are substantial modifications of the Information Treatment Policies that motivate new consultations.

    For consultations whose periodicity is greater than one per calendar month, 1LABS SAS can only charge the owner the costs of sending, reproducing and, where appropriate, document certification. The reproduction costs may not be greater than the recovery costs of the corresponding material. For this purpose, 1LABS SAS must demonstrate to the Superintendence of Industry and Commerce, when it so requires, the support of said expenses.

13. Article 13. Of the right to update, rectify and delete. In accordance with article 22 of Decree 1733 of 2013, in development of the principle of veracity or quality, in the treatment of personal data, reasonable measures must be taken to ensure that the personal data that rests in the databases are accurate and sufficient. and, when requested by the Holder or when 1LABS SAS has been able to notice it, they are updated, rectified or deleted, in such a way that they satisfy the purposes of the treatment.

14. Article 14. Means for the exercise of rights. In accordance with article 23 of Decree 1733 of 2013, 1LABS SAS designates the person or area that assumes the function of personal data protection, which processes the requests of the Owners, for the exercise of the rights referred to. Law 1581 of 2012 and Decree 1733 of 2013, which is described in Chapter VII.





CHAPTER V

Duties of Data Controllers and Data Processors




15. Article 15. Duties of the Data Controller. In accordance with article 17 of Law 1581 of 2012, 1LABS SAS, as the Data Controller, complies with the following duties, without prejudice to the other provisions set forth in Law 1581 of 2012 and in others that govern its activity:

    a) Guarantee the Holder, at all times, the full and effective exercise of the right of habeas data;

    b) Request and keep, under the conditions provided in Law 1581 of 2012, a copy of the respective authorization granted by the Holder;

    c) Duly inform the Holder about the purpose of the collection and the rights that assist him by virtue of the authorization granted;

    d) Keep the information under the necessary security conditions to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access;

    e) Guarantee that the information provided to the Treatment Manager is true, complete, accurate, updated, verifiable and understandable;

    f) Update the information, promptly communicating to the Person in Charge of the Treatment, all the news regarding the data that has previously been provided and adopt the other necessary measures so that the information provided to it is kept up to date;

    g) Rectify the information when it is incorrect and communicate what is pertinent to the Treatment Manager;

    h) Provide the Person in Charge of Treatment, as the case may be, only data whose Treatment is previously authorized in accordance with the provisions of Law 1581 of 2012;

    i) Require the Treatment Manager at all times to respect the security and privacy conditions of the Holder's information;

    j) Process queries and claims formulated in the terms indicated in Law 1581 of 2012;

    k) Adopt an internal manual of policies and procedures to guarantee adequate compliance with Law 1581 of 2012 and especially, for the attention of queries and claims;

    l) Inform the Person in Charge of Treatment when certain information is under discussion by the Holder, once the claim has been filed and the respective procedure has not been completed;

    m) Inform at the request of the Owner about the use given to their data;

    n) Inform the data protection authority when there are violations of the security codes and there are risks in the administration of the Holders' information.

    o) Comply with the instructions and requirements issued by the Superintendence of Industry and Commerce.

16. Article 16. Duties of the Treatment Managers. In accordance with article 18 of Law 1581 of 2012, 1LABS SAS, as Treatment Manager, complies with the following duties, without prejudice to the other provisions set forth in Law 1581 of 2012 and in others that govern its activity:

    a) Guarantee the Holder, at all times, the full and effective exercise of the right of habeas data;

    b) Keep the information under the necessary security conditions to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access;

    c) Perform timely updating, rectification or deletion of data under the terms of Law 1581 of 2012;

    d) Update the information reported by the Treatment Managers within five (5) business days from its receipt;

    e) Process queries and claims made by the Holders in the terms indicated in Law 1581 of 2012;

    f) Adopt an internal manual of policies and procedures to guarantee adequate compliance with Law 1581 of 2012 and, especially, for the attention of queries and claims by the Holders;

    g) Register in the database the legend "claim in process" in the manner in which it is regulated in Law 1581 of 2012;

    h) Insert in the database the legend "information under judicial discussion" once notified by the competent authority about judicial processes related to the quality of personal data;

    i) Refrain from circulating information that is being controversial by the Holder and whose blocking has been ordered by the Superintendence of Industry and Commerce;

    j) Allow access to information only to people who can have access to it;

    k) Inform the Superintendence of Industry and Commerce when there are violations of the security codes and there are risks in the administration of the information of the Holders;

    l) Comply with the instructions and requirements issued by the Superintendency of Industry and Commerce.





CHAPTER VI

Authorization




17. Article 17. Collection of personal data. In development of the principles of purpose and freedom, and in accordance with the provisions of article 4 of Decree 1377 of 2013, the data collection carried out by 1LABS SAS is limited to those personal data that are pertinent and adequate for the purpose for which it is collected. which are collected or required in accordance with current regulations. Except in cases expressly provided by law, 1LABS SAS does not collect personal data without authorization from the Holder.

    At the request of the Superintendence of Industry and Commerce, 1LABS SAS will provide a description of the procedures used for the collection, storage, use, circulation and deletion of information, as well as the description of the purposes for which the information is collected and an explanation on the need to collect data in each case.

    1 LABS SAS does not use deceptive or fraudulent means to collect and process personal data.

18. Article 18. Authorization. In accordance with the provisions of article 5 of Decree 1377 of 2013, 1LABS SAS adopts procedures to request, at the latest at the time of collection of your data, the authorization of the Holder for the Treatment of the same and inform the personal data that will be collected as well as all the specific purposes of the Treatment for which consent is obtained.

    Personal data found in publicly accessible sources, regardless of the means by which it is accessed, understood as those data or databases that are available to the public, can be processed by anyone as long as, by their nature, they are public data.

    In case there are substantial changes in the content of the Treatment policies referred to in Chapter VII of this manual, referring to the identification of 1LABS SAS, as Responsible, and to the purpose of the Treatment of personal data, which may affect the content of the authorization, 1LABS SAS will communicate these changes to the Holder before or at the latest when implementing the new policies. In addition, 1LABS SAS will obtain a new authorization from the Holder when the change refers to the purpose of the Treatment.

19. Article 19. How to obtain authorization. For the purposes of complying with the provisions of article 9 of Law 1581 of 2012, and in accordance with the provisions of article 7 of Decree 1377 of 2013, 1LABS SAS establishes the mechanisms to obtain the authorization of the owners or who is legitimized in accordance with the provisions of article 20 of Decree 1377 of 2013, which guarantee their consultation. These mechanisms can be predetermined through technical means that facilitate the Automated manifestation of it to the Holder. It is understood that the authorization meets these requirements when it is manifested (i) in writing, (ii) orally or (iii) through unequivocal conduct by the owner that allows the reasonable conclusion that the authorization is granted. In no case can silence be assimilated to unequivocal behavior.

20. Article 20. Proof of authorization. In accordance with the provisions of article 8 of Decree 1377 of 2013, 1LABS SAS retains proof of the authorization granted by the Holders of personal data for the Treatment of the same.

21. Article 21. Revocation of the authorization and/or deletion of the data. In accordance with the provisions of article 9 of Decree 1377 of 2013, the Holders may at any time request 1LABS SAS the deletion of their personal data and/or revoke the authorization granted for their Treatment, by submitting a claim, in accordance with the provisions of article 15 of Law 1581 of 2012.

    The request to delete the information and the revocation of the authorization will not proceed when the Holder has a legal or contractual duty to remain in the database.

    1LABS SAS makes available to the Holder free and easily accessible mechanisms to submit the request for data deletion or the revocation of the authorization granted.

    If the respective legal term expires, 1LABS SAS does not delete the personal data, the Holder will have the right to request the Superintendency of Industry and Commerce to order the revocation of the authorization and/or the deletion of the personal data. For these purposes, the procedure described in article 22 of Law 1581 of 2012 will be applied.

22. Article 22. Temporary limitations to the processing of personal data. In accordance with the provisions of article 11 of Decree 1377 of 2013, 1LABS SAS only collects, stores, uses or circulates personal data for as long as is reasonable and necessary, in accordance with the purposes that justified the treatment, attending to the provisions applicable to the matter in question and to the administrative, accounting, fiscal, legal and historical aspects of the information. Once the purpose or purposes of the treatment have been fulfilled and without prejudice to legal regulations that provide otherwise, 1LABS SAS proceeds to delete the personal data in its possession. Notwithstanding the foregoing, personal data must be kept when required to comply with a legal or contractual obligation.

    1LABS SAS documents the procedures for the Treatment, conservation and deletion of personal data in accordance with the provisions applicable to the matter in question, as well as the instructions given in this regard by the Superintendency of Industry and Commerce.





CHAPTER VII

Treatment Policies




23. Article 23. Information Treatment Policies. In accordance with the provisions of article 13 of Decree 1377 of 2013, 1LABS SAS develops its policies for the treatment of personal data and ensures full compliance with them.

    The Information Treatment policies appear in physical and electronic media, in clear and simple language and are made known to the Holders.

24. Article 24. Responsible for processing the information. In accordance with the provisions of article 13 of Decree 1377 of 2013, 1LABS SAS is Responsible for Treatment, with address at Transversal 6 No. 27 – 10 Office 303 of Bogotá DC Colombia, with email ideas@1labs.co and telephone (+57)3173708605.

25. Article 25. Treatment of information. In accordance with the provisions of article 13 of Decree 1377 of 2013, 1LABS SAS collects, stores, consults, updates, rectifies, deletes, circulates, transfers, uses and keeps the personal data of its clients, to:

    a) The offer and adequate provision of the products and services of 1LABS SAS

    b) Address the requests of the Owner to access or consult their personal data.

    c) Address the claims of the Holder to correct, rectify, update or delete their personal data or revoke their authorization for the processing of personal data.

    d) Respond to requests for information related to the offer, acquisition or renewal of products and services of 1LABS SAS

    e) Plan, innovate, design, redesign, implement, offer and advertise products or services of 1LABS SAS

    f) Carry out surveys or polls, improve, evaluate and monitor the quality, behavior and consumption of the products or services of 1LABS SAS

    g) Send editorial, commercial, promotional, advertising information, invitations or attention related to promotions, offers, news, news, alliances, studies, events, contests, benefits, content by area of ​​interest, changes, products and services, among others. , from 1LABS SAS

    h) Perform segmentation and market analysis of 1LABS SAS

    i) Comply with obligations contracted by contracts, agreements, and alliances, with clients, suppliers or employees, among others.

    j) Comply with the regulations in force in Colombia, and with the provisions of the Colombian legal system in labor and social security matters, which is applicable to 1LABS SAS

26. Article 26. Rights that assist you as Holder. In accordance with the provisions of article 13 of Decree 1377 of 2013, the rights that assist you as Holder are described in Chapter III of this manual.

27. Article 27. Responsible for care. In accordance with the provisions of article 13 of Decree 1377 of 2013, the General Manager of 1 LAB SAS is the person or area responsible for the attention of requests, queries and claims before which the owner of the information can exercise their rights to Know, update, rectify and delete the data and revoke the authorization.

28. Article 28. Procedures. In accordance with the provisions of article 13 of Decree 1377 of 2013, the procedures so that the owners of the information can exercise the rights to know, update, rectify and delete information and revoke the authorization are mentioned in Chapter IX of this manual.

29. Article 29. Date of entry into force. In accordance with the provisions of article 13 of Decree 1377 of 2013, the date of entry into force of the information treatment policy of 1LABS SAS is June 30, 2016, and the validity period of the database is from June 30, 2016 onwards.

    Any substantial change in the treatment policies and in what is contained in this manual, in the terms described in article 5 of Decree 1733 of 2013, will be communicated in a timely manner to the owners of the personal data in an efficient manner, before implementing the changes. new policies.





CHAPTER VIII

Notice of Privacy




30. Article 30. Privacy notice. In accordance with the provisions of article 14 of Decree 1377 of 2013, in cases in which it is not possible to make information treatment policies available to the Owner, 1LABS SAS informs the owner by means of a privacy notice about the existence of such policies and the way to access them, in a timely manner and in any case no later than the time of the collection of personal data. personales.

31. Article 31. Duty to prove the availability of the privacy notice and the information processing policies. In accordance with the provisions of article 16 of Decree 1377 of 2013, 1LABS SAS retains the model of the Privacy Notice that it uses to comply with its duty to inform the Holders of the existence of information treatment policies and the way to access them, while personal data is processed in accordance with it and the obligations derived from it endure. For the storage of the model, 1LABS SAS uses computer, electronic or any other technology that guarantees compliance with the provisions of Law 527 of 1999.

32. Article 32. Means of dissemination of the privacy notice and information treatment policies. In accordance with the provisions of article 17 of Decree 1377 of 2013, for the dissemination of the privacy notice and the information treatment policy, 1LABS SAS uses documents, electronic formats, verbal means or any other technology, always and when it guarantees and complies with the duty to inform the holder./p>

33. Article 33. Procedures for the proper processing of personal data. In accordance with the provisions of article 18 of Decree 1377 of 2013, the procedures for access, updating, deletion and rectification of personal data and revocation of the authorization are made known or are easily accessible to the Holders of the information and are included in the information treatment policy.





CHAPTER IX

Procedures




34. Article 34. Authorization. In accordance with the provisions of article 5 of Decree 1733 of 2013, 1LABS SAS requests prior, express and informed consent from the Holder to carry out the Processing of their personal data and inform them of the personal data that will be collected as well as all the specific purposes of the Processing for which consent is obtained.

    The authorization is formulated by the following means enabled by 1LABS SAS:

    a) Physical Authorization: The Holders may authorize the Processing of their personal data through the completion and delivery of the physical authorization form provided by 1LABS SAS for such purpose.

    b) Digital Authorization: The Holders may authorize the Processing of their personal data by filling out and sending the digital authorization form provided by 1LABS SAS for such purpose. The digital authorization form is published mainly on the websites and digital tools of its products and services.

    1LABS SAS retains proof of authorization.

35. Article 35. Collection. 1LABS SAS collects the personal information of its clients through:

    a) Physical or electronic registration of clients, which is carried out when the client consults, acquires, renews or cancels a product or service of 1LABS SAS, prior authorization.

    b) Reception of questions, complaints, claims, and requests related to the products and services of 1LABS SAS, in physical or electronic means, and through the websites of the products and services of 1LABS SAS

    c) Subscription, consultation or unsubscription of the 1LABS SAS newsletter or any of its products or services.

36. Article 36. Storage and conservation. 1LABS SAS stores and preserves the information and personal data of its clients in secure, durable, highly scalable storage mechanisms, with access control and registration, under the necessary security conditions to prevent its adulteration, loss, consultation, use or unauthorized access. authorized or fraudulent.

37. Article 37. Access and consultation. In accordance with the provisions of article 14 of Law 1581 of 2012, the Holders or their successors in title can consult the personal information of the Holder that rests in the databases of 1LABS SAS, prior accreditation of her identity.

    Access and consultation is formulated by the following means enabled by 1LABS SAS:

    a) Access or consultation by email: The Holders may request access and consultation of their personal data by sending an email to ideas@1labs.co.

    b) Access or physical consultation: The Holders can request access and consultation of their personal data by sending a physical request to the address of 1LABS SAS

    Access and consultation can only be exercised by:

    a) The holder or his successors in title, after proof of his identity, or through electronic instruments that allow him to identify himself.

    b) Your representative, prior accreditation of the representation.

    When the query is formulated by a person other than the owner and it is not proven that the same acts on behalf of the former, it will be considered as not presented.

    As a result of the consultation, 1LABS SAS provides the Holders with all the information contained in the individual registration or that is linked to the identification of the Holder.

    The query will be answered within a maximum term of ten (10) business days from the date of receipt of the query. When it is not possible to attend the query within said term, the interested party will be informed, stating the reasons for the delay and indicating the date on which his query will be attended, which in no case may exceed five (5) business days following the expiration of the first term.

38. Article 38. Claims. In accordance with the provisions of article 15 of Law 1581 of 2012, the Holder or his successors in title who consider that the information contained in the databases of 1LABS SAS must be subject to correction, rectification, updating or deletion, or to consult test or revoke the authorization for the processing of personal data, or when they notice the alleged breach of any of the duties contained in Law 1581 of 2012, they may file a claim with 1LABS SAS which will be processed under the following rules:

    a) The claim will be formulated through a request addressed to 1LABS SAS, with the identification of the Holder, the description of the facts that give rise to the claim, the address, and accompanying the documents that you want to assert. If the claim is incomplete, the interested party will be required within five (5) days after receipt of the claim to correct the faults. After two (2) months from the date of the request, without the applicant submitting the required information, it will be understood that he has withdrawn the claim.

    In the event that the person who receives the claim is not competent to resolve it, he or she will transfer it to the appropriate person within a maximum term of two (2) business days and will inform the interested party of the situation.

    b) Once the complete claim is received, a legend will be included in the database that says "claim in process" and the reason for it, in a term not exceeding two (2) business days. Said legend must be kept until the claim is decided.

    c) The maximum term to address 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 their claim will be addressed, which in no case may exceed eight (8) business days following the expiration of the first finished.

    The claim can be submitted through the following means enabled by 1LABS SAS:

    a) Submitting a claim by email: The Holders can submit claims by sending an email to ideas@1labs.co.

    b) Presentation of a physical claim: The Holders can present claims by sending a physical request to the address of 1LABS SAS

    Claims corresponding to requests for correction, rectification, updating or deletion of personal data may only be exercised by:

    a) The holder or his successors in title, after proof of his identity, or through electronic instruments that allow him to identify himself.

    b) Your representative, prior accreditation of the representation.

    When the request is made by a person other than the holder and it is not proven that the same acts on behalf of the former, it will be deemed not submitted.

    In requests for correction, rectification, and updating of personal data, the Owner must indicate the corrections, rectifications, and updates to be made and provide the documentation that supports their request.

    In requests for deletion of personal data, it is important to bear in mind that the right of deletion is not absolute and 1LABS SAS may deny the exercise of the same when:

    a) The Holder has a legal or contractual duty to remain in the database.

    b) The elimination of data hinders judicial or administrative actions related to tax obligations, the investigation and prosecution of crimes or the updating of administrative sanctions.

    c) The data is necessary to protect the legally protected interests of the owner; to carry out an action based on the public interest, or to comply with an obligation legally acquired by the Holder.

    If the deletion is appropriate, 1LABS SAS performs the total deletion of personal data, guaranteeing the non-recovery of the information.

39. Article 39. Treatment, use and circulation. 1LABS SAS collects, stores, consults, updates, rectifies, deletes, circulates, transfers, uses and keeps the personal data of its clients, to:

    a) The offer and adequate provision of the products and services of 1LABS SAS

    b) Address the requests of the Owner to access or consult their personal data.

    c) Address the claims of the Holder to correct, rectify, update or delete their personal data or revoke their authorization for the processing of personal data.

    d) Respond to requests for information related to the offer, acquisition or renewal of products and services of 1LABS SAS

    e) Plan, innovate, design, implement and offer new products and services of 1LABS SAS

    f) Carry out surveys or polls, improve, evaluate and monitor the quality, behavior and consumption of the products and services of 1LABS SAS

    g) Send editorial, commercial, promotional, advertising information, invitations or attention related to promotions, offers, news, news, alliances, studies, events, contests, benefits, content by area of ​​interest, changes, products and services, among others. , from 1LABS SAS

    h) Perform market segmentation.

    i) Comply with obligations contracted by contracts, agreements, and alliances, with clients, suppliers or employees, among others.

    j) Comply with the regulations in force in Colombia, and with the provisions of the Colombian legal system in labor and social security matters, which is applicable to 1LABS SAS

    The personal data of the Holder is not subject to circulation by 1LABS SAS

Last update: June 30, 2016.