The Firm may collect Personal Information from employees, natural person suppliers or clients or their natural person representative, that includes but is not limited to name (including any former names); contact information (address, phone number and email); citizenship card number; unique tax record; tax identification number; social security contribution form; bank account number and other banking and financial details; court records; and commercial and labor references.

 

The Firm may collect, store, use, circulate, transmit and transfer personal data of its employees, suppliers, or clients or their natural person representative for purposes of control, security, establishment of commercial or legal relationships, judicial processes, and requirements of administrative authorities and for future references.

 

The Firm may use the aforementioned Personal Information for the following purposes (hereinafter "Purpose of the Processing"):

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• Execute the corporate purpose of the Firm.

• Comply with legal obligations of the Firm, due to the development of its commercial activity.

• Contact in emergency situations or related to the execution of the employment contract or during the personnel selection process, obtain references and verify them, indicated in resumes, forms or documents presented in the selection process and/or during the execution of the employment contract.

• Manage internal affairs of the Firm, including but not limited to accounting, financial and management reports, calculation, presentation and payment of taxes, tax obligations, commercial and corporate records, and compliance reports.

• Provide services to clients, including but not limited to contact for activities related to the billing of professional services offered or performed by the Firm, verification of documents and affiliations, among others.

• Marketing within the existing network of clients and candidates, including invitations to events, referral of promotions, product offerings, and sending of communications, among others.

• Manage relationships with third parties with whom they have business relationships, including subcontractors who perform services to customers.

• Process, manage and send necessary information for processing of payroll, payments, income, records, news and other requirements of the social security system in accordance with Colombian legislation. 

• Pay contractual and non-contractual obligations. 

• Send information to government or judicial entities, at their express request, in accordance with legal provisions. 

• Register supplier information in the company database. 

• Validate, verify and contract the information collected that is related to academic, labor, banking, commercial and professional references. 

• Contact clients, employees, candidates and/or suppliers to send information related to contractual, commercial and legal relationships that may apply. 

• Comply with internal or external precautionary procedures, programs and systems related to safety, care, prevention and protection of the worker's health and biosafety. 

• Identify and control the people who have access to the Firm's own, leased, shared, or horizontally owned facilities. 

• Carry out the "Know Your Client" or "Client Due Diligence" process, which consists of the set of procedures for the identification and acceptance of clients.

• Perform security analysis, prevention, investigation and prosecution of fraud, money laundering and financing of terrorism, reviewing OFAC, CFSP, BOE lists, among others, as well as all the information necessary to comply with SARLAFT, SAGRILAFT and other systems risk management as appropriate.

• Validate, verify and contrast the information collected with criminal record databases, public databases, financial, commercial, credit databases, risk centers, among others. 

• Verify, request and/or search the Personal Information of the Data Subjects in risk lists - restrictive and non-restrictive - and binding and non-binding for Colombia, through any search engine such as, but not limited to, the platforms of the Administrative Entities of the Comprehensive Social Security System, the Judicial Authorities and the National Police, the Procuraduria General de la Republica, the Comptroller General's Office or any other legally constituted source of information or through other search engines designed to verify their current employment status, academic qualifications, and other pertinent information for the aforementioned purposes to establish whether its employees, partners, family members or close people qualify as Politically Exposed Persons (hereinafter "PEP"). 

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The Firm may carry out these processes directly, or through its strategic allies with whom it agrees to carry out these activities. Additionally, in accordance with the law, the Data Subject is informed that in the event that a family member or close person holds the capacity of PEP or acquires it, the Data Subject must notify the Firm of this situation, indicating the identification data of said relative or  close person, including their full name and the

 

relationship they have and the position they hold or performed within the previous two (2) years.

 

In the cases in which the Firm must carry out the processing of Personal Data of third parties provided by the Data Subject, the latter must have the authorization of those persons for their Personal Information to be delivered to the Firm and to be processed in accordance with the Processing Policy.

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• Store, file and update the data that the Firm has collected by any means and with due authorization in its own Databases or those of third parties. 

• Any other purpose that results in the development of the Firm, negotiation and/or execution of the contract or any type of relationship between the Data Subject of the information and the Firm.

• The other purposes specified in the respective authorizations granted by each of the Data Subjects.