POLICY ON THE TREATMENT OF PERSONAL DATA

• GAMMA INGENIEROS S.A.S, established since 1983, is a Colombian company that provides its clients with services and solutions in Technology, Consulting, and Engineering with innovation and sustainability, supported by excellent human capital.
  Identification data: GAMMA INGENIEROS S.A.S. NIT 891.501.783-1.
• Contact information: Address: Calle 166 #20-45, Bogotá. Tel .: (601) 4076000
• Website: www.gammaingenieros.com Email: protecciondatos@gammaingenieros.com

• Authorization: Refers to the expression of the prior, express, and informed consent of the Owner for GAMMA INGENIEROS S.A.S., or its Processors to carry out the Treatment of the Owner’s Personal Data.
• Privacy Notice: It is the physical, electronic, or any other format document generated by GAMMA INGENIEROS S.A.S., made available to the Owner for the Treatment of their Personal Data. It communicates to the Owner information regarding the existence of the Policies on the Treatment of Personal Data that will be applicable, how to access them, and the characteristics of the Treatment intended for Personal Data.
• Database: Consists of an organized set of Personal Data that is the subject of Treatment, including physical and electronic files. GAMMA INGENIEROS S.A.S.’s databases are detailed in section VI of these policies.
• Personal Data: According to Law 1581 of 2012, it is any information linked or that can be associated with one or more specific or determinable natural persons.
• Public Data: Personal Data classified as public by law or the Political Constitution. Public data includes, among others, information related to the civil status of individuals, their profession or occupation, their status as a merchant or public servant.
• Sensitive Data: Personal Data whose use affects the privacy of the Owner or whose misuse could lead to discrimination. This includes data revealing racial or ethnic origin, political orientation, religious or philosophical beliefs, membership in unions, social organizations, human rights organizations, or that promotes the interests of any political party or guarantees the rights and guarantees of opposition political parties, as well as data related to health, sexual life, and biometric data.
• Owner: Natural person whose personal data is the subject of Treatment.
• Treatment: Any operation or set of operations on Personal Data carried out by GAMMA or the Processors on behalf of the company, such as collection, storage, use, circulation, or deletion.
• Transfer: Sending Personal Data to a recipient who, in turn, is responsible for the Treatment in accordance with the terms of Law 1581 of 2012.
• Transmission: Communication of Personal Data to the Processor, inside or outside the territory of the Republic of Colombia, for the purpose of carrying out Treatment on behalf of GAMMA INGENIEROS S.A.S.

The personal data collected or present in our databases will be processed for the following purposes:

• Salesforce Clients: Salesforce is a CRM (Customer Relationship Management) application for managing customer relationships focused on sales and customer service. It generates reports related to sales to measure performance indicators (KPIs – Key Performance Indicators). Additionally, it centralizes customer information (contact, business opportunities, documents related to the service provided, generate future projections). It also allows tracking users’ activities within the platform (sales, daily task and event registration, technical support case tracking) according to their assigned profile.
• Clients: Data collection for commercial activities and market exploration, allowing the identification of business opportunities for subsequent contact, direct contact with clients, sending information related to the company’s services, advertising campaigns, information about events, customer loyalty, information to evaluate their financial and economic status, customer prospecting for future business.
• Potential Clients: Database consisting of records of natural persons or contacts from potential companies that have not yet acquired products or services from the company but could be within its market. It is used for commercial activities, customer prospecting, identification of business opportunities, meetings with clients, sending commercial proposals related to the company’s services and products, advertising campaigns, information about events, sending information about the company’s portfolio, customer loyalty, information to evaluate their financial and economic status.
• End Clients: GAMMA INGENIEROS S.A.S. will use the information provided to:
  1. Carry out the relevant procedures for the development of the pre-contractual, contractual, and post-contractual stage with GAMMA regarding any products offered by the company, whether acquired or not, or regarding any underlying contractual relationship it has with it. Also, to comply with Colombian or foreign law and orders from judicial or administrative authorities;
  2. Manage processes (requests, complaints, claims), conduct risk analysis, conduct satisfaction surveys regarding the company’s goods and services, as well as its commercial partners;
  3. Provide contact information and relevant documents to the commercial force and/or distribution network, telemarketing, market research, and any third party with which the company has a contractual relationship of any kind;
  4. Disclose, transfer, and/or transmit my personal data within and outside the country to third parties as a result of a contract, law, or lawful bond requiring it or to implement cloud computing services.
  5. Carry out, through any means, directly or through third parties, programming and provision of technical service, sale, purchase, billing, portfolio management, product performance monitoring, collection, business intelligence, marketing activities, promotion or advertising, service improvement, collection monitoring, verification, consultation, and control, payment means enablement, as well as any other related to our current and future products and services, for the fulfillment of contractual obligations and the company’s social purpose.
  6. For the sending and receiving of goods or advertising material according to the requirements of the demanded functions and the sustainability of the company’s businesses.
  7. Control and prevent fraud in any of its modalities.
• Technology UEN Suppliers: Used to issue purchase orders and initiate business agreements to acquire goods or services from the technology unit, then keep track and payments for the goods and services received by Gamma Ingenieros S.A.S.
  
  Some of these tasks are carried out in compliance with a legal and contractual duty, and therefore, the processing of personal data is understood to be included in them.
  
  In the case of the processing of personal data for advertising, marketing, or commercial prospecting purposes, the Superintendency of Industry and Commerce has Circular No. 006 of the year 2022, which indicates the protection of consumer information obtained through commercial mechanisms, advertising campaigns, and marketing. As a first measure, the organization must comply with the regulations on the processing of personal data; second, it must verify that personal data was obtained lawfully and can be used for advertising, marketing, commercial prospecting, or any other purpose for which the organization wishes to use them; third, individuals who do not wish to receive more advertising should not be contacted, and their contact details should be deleted upon request. Fourth, effective mechanisms must be implemented for the exercise of the rights of data subjects. Fifth, timely and duly respond to queries or claims from data subjects. Sixth, do not contact people on days or at times that affect their peace of mind.
  Gamma CyberAcademy Platform: Used to provide cybersecurity training services within the platform, keep track of progress, generate management reports, disclose information associated with the service provided, oriented oriented to employees, clients, and potential clients of the organization.
  Gamma Learns Platform: Used to provide educational services and training in technologies such as programming, databases, networking, and software development, generate management reports, disclose information associated with the service provided, oriented to employees, clients, and potential clients of the organization.
  Biometric System: It is used for physical access control to the company’s offices. It keeps a record of the people entering and leaving the facilities for security purposes.
  Technology Products and Services: Used to manage and control the sales of technological products and services offered by the company to its clients. It includes the generation of commercial proposals, orders, invoicing, collection, delivery control, and after-sales service.
  Human Resources Database: It is used to manage and control personnel information, including recruitment processes, employment contracts, payroll, social security, employee benefits, training, performance evaluations, and any other activity related to human resources management.
  Vendor and Contractor Database: It is used to manage and control information related to suppliers and contractors, including the evaluation of their products and services, the management of contracts, payments, and any other activity related to the relationship with vendors and contractors.
  Customer Service: Data collected for customer service purposes, including the management and resolution of inquiries, complaints, and claims.
  Legal and Regulatory Compliance: Data collected to ensure compliance with legal and regulatory requirements applicable to GAMMA INGENIEROS S.A.S.

The Owner of the Personal Data has the following rights, which can be exercised by themselves or by an accredited person before GAMMA INGENIEROS S.A.S., or the person in charge of processing:

a) Right to Access: The Owner has the right to obtain from GAMMA INGENIEROS S.A.S. confirmation of whether or not their Personal Data is being processed and, if so, the right to access it.
b) Right to Rectification: The Owner has the right to request GAMMA INGENIEROS S.A.S. to rectify their Personal Data when it is inaccurate or incomplete.
c) Right to Delete: The Owner has the right to request GAMMA INGENIEROS S.A.S. to delete their Personal Data when, among other reasons, it is no longer necessary for the purposes for which it was collected.
d) Right to Object: The Owner has the right to object to the processing of their Personal Data by GAMMA INGENIEROS S.A.S. in certain situations, such as the processing of data for direct marketing purposes.
e) Right to Restriction of Processing: The Owner has the right to request GAMMA INGENIEROS S.A.S. to restrict the processing of their Personal Data in certain situations, such as when the accuracy of the data is contested.
f) Right to Portability: The Owner has the right to receive their Personal Data in a structured, commonly used, and machine-readable format and to transmit it to another data controller when the processing is based on consent or a contract.
g) Right to Revoke Consent: The Owner has the right to revoke their consent at any time when the processing is based on consent. The revocation of consent will not affect the lawfulness of the processing carried out before the revocation.
The rights of the Owner may be exercised by sending a written communication to GAMMA INGENIEROS S.A.S., addressed to the email protecciondatos@gammaingenieros.com, specifying the right they wish to exercise and providing the necessary information to verify their identity.

GAMMA INGENIEROS S.A.S. undertakes to comply with the following obligations:

a) Guarantee the Owner, at all times, the full and effective exercise of their rights.
b) Request and keep a copy of the authorization granted by the Owner for the processing of their Personal Data.
c) Inform the Owner, upon request, regarding the use given to their Personal Data.d) Keep the information under the necessary security conditions to prevent its adulteration, loss, consultation, use, or unauthorized or fraudulent access.
e) Update the information in a timely manner.f) Rectify the information when it is incorrect.
g) Handle requests and complaints made by the Owner regarding the processing of their Personal Data.
h) Inform the data protection authority when there are violations of the security codes and there are risks in the administration of the information of the Owners.
i) Comply with the requirements and instructions issued by the Superintendency of Industry and Commerce.

GAMMA INGENIEROS S.A.S. informs that it has the following databases, each with specific purposes:

a) Salesforce Clients: Database of clients managed through the Salesforce platform.
b) Clients: Database of clients, including contact information and business history.
c) Potential Clients: Database of potential clients, including contact information and market data.
d) End Clients: Database of end clients, including contact information and information related to contractual relationships.
e) Technology UEN Suppliers: Database of suppliers of technology products and services.
f) Gamma CyberAcademy Platform: Database of users of the cybersecurity training platform.
g) Gamma Learns Platform: Database of users of the educational platform for technology training.
h) Biometric System: Database of biometric data for access control.
i) Technology Products and Services: Database of sales and customer information related to technology products and services.
j) Human Resources Database: Database of employee information.
k) Vendor and Contractor Database: Database of information related to vendors and contractors.
l) Customer Service: Database of customer service interactions.
m) Legal and Regulatory Compliance: Database of information related to legal and regulatory compliance.

Data Processors: GAMMA INGENIEROS S.A.S. may use third-party processors to carry out certain processing activities on its behalf, such as cloud service providers, marketing agencies, and IT support services. In such cases, GAMMA INGENIEROS S.A.S. will ensure that the processors comply with the data protection regulations and implement the necessary security measures to protect the Personal Data.

For any questions, concerns, or requests related to the Treatment of Personal Data, the Owner can contact GAMMA INGENIEROS S.A.S. through the following contact information:

Email: protecciondatos@gammaingenieros.com
Address: Calle 166 #20-45, Bogotá
Telephone: (601) 4076000