1. Introduction

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Privacy Policy (“Policy”) on the processing of personal data under the responsibility of C&M Development Group S.A.S., general information:

 

• C&M Development Group S.A.S.

• Bogotá, Colombia

• Telephone: (+57) 320-856-6866

• Email: ventas@sampler.com.co

• Customer service: soporte@sampler.com.co

 

This Policy is applicable to all personal data whose processing is the responsibility of, which identifies or may identify a natural person (“Personal Data”). The natural persons who are the owners of the Personal Data provided to C&M Development Group S.A.S. are defined in this Policy as the owner of the personal data (“Owner” or “You”).

 

C&M Development Group S.A.S. reserves the right to periodically review and/or alter this Policy for the purposes of complying with applicable legislation (National and/or international), and for any purpose that C&M Development Group S.A.S. deems reasonably necessary. In the event that C&M Development Group S.A.S. decides to modify the Policy, it will notify the Owners by email or publish it on the main page of the website www.sampler.com.co

 

The modifications to the Policy will be applicable to the information collected from the date on which C&M Development Group S.A.S. publish the new version of the Policy on the website www.sampler.com.co, as well as for any information existing to date. If you do not agree with any modification to the Policy, you may request the deletion of your Personal Data from the records of C&M Development Group S.A.S. through the privacy control tools established in this document by contacting the email ventas@sampler.com.co

If you have any questions regarding this Policy, please contact the delegated personal data officer through the following email: ventas@sampler.com.co

 

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2. Processing of Personal Data

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This Policy establishes the necessary guidelines for compliance with legislation regarding the Processing of Personal Data, among others, the General Data Protection Regulation (GDPR) (“Applicable Laws”).

 

This is an external policy addressed to the Owners whose Personal Data is being processed by C&M Development Group S.A.S. in the development of its main activity and the sale and provision of goods and services. Said data is collected through the following sources: marketing emails, Social Networks, surveys, sales calls, webinars, campaigns, conferences, events sponsored by C&M Development Group S.A.S. and the website www.sampler.com.co.

 

This Policy is applicable to the Processing of Personal Data over which it acts as responsible in accordance with the Applicable Laws. C&M Development Group S.A.S. is responsible when determining the purpose and means for the processing of the Personal Data of the Owners within the purposes of this Policy.

C&M Development Group S.A.S. may request the Owners' Data from natural and legal persons, for commercial purposes, for which C&M Development Group S.A.S. undertakes to maintain the confidentiality of said data.

 

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3. Personal Data

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Personal Data refers to all information of any kind related to each Owner – their name, address, email, cell phone number, etc. – that has been sent to C&M Development Group S.A.S. by the Holders.

 

The categories of Personal Data on which C&M Development Group S.A.S. performs the Treatment are the following:

• Names;

• Surnames;

• Email;

• Cellphone number;

• Company name;

• Post;

 

Policy for Minors

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C&M Development Group S.A.S. does not intentionally collect Personal Data from persons under 18 years of age. The Registry is only available to minors under 18 years of age with prior authorization from a parent or legal guardian. In the event that a person under 18 asks a question to C&M Development Group S.A.S. through the website and indicate her age, C&M Development Group S.A.S. may use the email address of said minor, for the sole purpose of answering the question asked by the minor one time only.

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However, C&M Development Group S.A.S. will not knowingly use a minor's email address to contact the minor again and will delete the minor's information from records or databases once the minor's question is answered. In the event that C&M Development Group S.A.S. learns that Personal Data has been collected from a person under 18 years of age, it will use its best efforts reasonably within its power to remove such information from its databases.

 

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4. Purposes and legal basis of Data Processing.

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The purposes of the Processing of Personal Data by C&M Development Group S.A.S. are:

• We may use Non-Identifiable Data collected to develop sales policies for types of industries and companies;

• We may use aggregated non-identifying data collected to develop new services;

• We may use your Personal Data to offer personalized services;

• We may use your Personal Data for research purposes;

• We may use your Personal Data to communicate with you by email for marketing purposes;

• We may use your personal data for statistical purposes;

• We may use aggregated non-identifiable data collected to improve customer experience (including application usage);

• Promotional and cross-selling activities;

• Offer products, services and special offers;

• Offer newsletters;

• Prevention of fraudulent activities;

• Organization of online events and seminars.

 

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Legal base

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C&M Development Group S.A.S. is obliged to carry out the Processing of Personal Data in accordance with the purposes provided for in this Policy and in compliance with the Applicable Laws. Data Processing by C&M Development Group S.A.S. It is necessary so that it can carry out its operational activities for which the Owners have provided their Personal Data granting their express authorization, as well as to execute a legitimate interest pursued by C&M Development Group S.A.S.

 

The Owner of Personal Data has the right to revoke his authorization at any time. The legitimate interests for which C&M Development Group S.A.S. carries out the Processing of Personal Data are the following: direct marketing, improvement of customer experience, newsletters, customer service, research, promotion and cross-selling of activities and identification.

 

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Retention Period

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C&M Development Group S.A.S. will not store, use and generally carry out the Processing of Personal Data for longer than required to fulfill the purposes set out in this Policy, and will delete the Personal Data collected once the period necessary to achieve the purposes described in this Policy has elapsed, or to fulfill contractual obligations or as permitted or required by Applicable Laws. In Annex 1 you will find the Retention Periods of C&M Development Group S.A.S.

 

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5. Limitation of Purposes

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Personal Data may only be used for the purposes described in this Policy. In principle, Personal Data cannot be processed for purposes other than those for which it was collected. If there is a need to carry out Personal Data Processing for purposes other than those described here, C&M Development Group S.A.S. You must study this possibility and determine whether the purpose of the required Data Processing is compatible with the original purpose. C&M Development Group S.A.S. will provide the Owner with information about the new purpose prior to carrying out the corresponding Treatment.

 

 

6. Security of Personal Data

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C&M Development Group S.A.S. Processes Personal Data carefully and confidentially. Use all appropriate physical, administrative and technical security measures to maintain the integrity and security of Personal Data.

 

C&M Development Group S.A.S. rigorously complies with generally accepted industry practices and standards for the purposes of protecting the Personal Data collected. The above, said collection process, as at the time when C&M Development Group S.A.S. receives the Data.

 

The above, taking into account that no collection or storage method through the Internet or electronic method is 100% secure. Therefore, to the extent that C&M Development Group S.A.S. strives to use all commercially acceptable means to protect the Personal Data for which it is responsible, C&M Development Group S.A.S. cannot guarantee its absolute safety.

 

If you decide to contact C&M Development Group S.A.S. through the website www.sampler.com.co, you should keep in mind that any information sent electronically will not be secure. In addition to legal obligations under the Applicable Laws, C&M Development Group S.A.S. does not assume any responsibility for the loss of information that you send to C&M Development Group S.A.S. electronically.

 

By communicating with you, C&M Development Group S.A.S. You may send decrypted emails, as long as it is known to C&M Development Group S.A.S. that most people cannot easily process encrypted emails. This is done for your convenience, but with the security concern that if misrouted or intercepted, it could be read more easily than encrypted email.

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7. Transfer of Personal Data

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The Personal Data is being accessed or transferred by C&M Development Group S.A.S. and other third parties, such as website developers, customer service agencies, support agencies, social networks, data analysis, companies that personalize the website, digital registration tools (customer service registration tool), registration agency analysis of websites, companies that make customer service accessible through social networks.

*These third parties are listed in 3 of this Policy.

 

C&M Development Group S.A.S. Additionally, disclose personal data in the event that such disclosure is required under Applicable Laws or is reasonably considered essential to protect and safeguard the rights, property and safety of other parties. In certain circumstances, Personal Data may be subject to disclosure pursuant to subpoenas, orders or at the request of competent government authorities.

 

Regarding storage, C&M Development Group S.A.S. uses various applications to obtain and store certain data. To ensure your privacy, these applications are subject to strict regulations. Most of the data and the website is stored within Colombia. With respect to data sent to other countries, C&M Development Group S.A.S. only uses companies that provide sufficient protection in accordance with Colombian legislation.

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8. Rights of the Owners

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The Holders of Personal Data have the right to information, access, rectification, addition and deletion of their Personal Data, and the right to oppose or restrict the Processing of their personal data (or revoke prior consent), as well as the right to data portability. The procedure of C&M Development Group S.A.S. is described below. which allows the Owners to exercise these rights:

 

Data Subjects may submit an access request with C&M Development Group S.A.S. and it will respond as soon as possible, and in any case within one (1) month, approximately:

 

1. If C&M Development Group S.A.S. retains any Personal Data related to the respective Owner; and,

2. If yes, information is provided on the purposes of the processing, the categories, the recipients (if applicable), the planned period for which the Personal Data will be stored or the criteria used, the existence of the right to request rectification, erasure, or to object to such processing, the right to lodge a complaint with a supervisory authority, the existence of automated decision-making, where data is transferred to a third country, the appropriate safeguards and the source(s) ) of Personal Data.

3. After an Owner has accessed the Personal Data, he/she may request C&M Development Group S.A.S. that restricts, modifies, adds, deletes and/or transfers your Personal Data. C&M Development Group S.A.S. will inform the Owner, within one (1) month following receipt of said request, whether it will be fulfilled (on time) and, if not, will accompany its response with the justification for the delay or rejection.

 

The information provided will be free. The Owners may exercise these rights at reasonable intervals. The Owners can exercise their rights by contacting the delegated data protection officer in writing by email to: ventas@sampler.com.co

 

C&M Development Group S.A.S. will comply with the Owner's request for correction, restriction or deletion, if the Personal Data is in fact incorrect, incomplete or irrelevant for the purposes of the data processing, or is otherwise processed in violation of Applicable Laws.

 

With respect to a request for the deletion of Personal Data, it should be noted that C&M Development Group S.A.S. will not comply with said request, if it is incompatible with any legal obligation of C&M Development Group S.A.S. in accordance with applicable laws.

 

In the event that an application is approved, C&M Development Group S.A.S. will carry out the correction, deletion, and/or transfer of the Personal Data as soon as possible.

 

The Owners may at any time opt out of receiving newsletters from C&M Development Group S.A.S. to those who have subscribed, through email: ventas@sampler.com.co

 

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9. Website

www.sampler.com.co

 

When you use the website www.sampler.com.co, your personal data will be processed. C&M Development Group S.A.S. undertakes to safeguard your privacy for these purposes. This paragraph describes the types of Personal Data that are processed by C&M Development Group S.A.S. and that are related to the use of the website, how C&M Development Group S.A.S uses. the Data and who you share it with.

 

As a general policy, no Personal Data is collected automatically when visiting the Website. However, in certain circumstances, such as when the Owner registers on the Website, you may be asked to provide us with specific information to use certain functions of the Website and to take advantage of certain opportunities offered by C&M Development Group S.A.S. or that may be offered through the Website.

 

In Annex 1 of the Personal Data you can find the collection of Personal Data through the use of these functions, the purposes of processing this Personal Data and the retention time.

 

The Website contains links to other websites that are not owned or controlled by C&M Development Group S.A.S. Please note that C&M Development Group S.A.S. is not responsible for the content or privacy practices of other websites. When you leave the Website, you should read the privacy statement of the website to which you have linked.

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 Processing activities, purposes, legal basis and retention periods

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C&M Development Group S.A.S. never collects your personal identity number on the Website. Please do not provide your personal identification number on the website or to any third party indicating that it is from the website.

 

The legal process requires that C&M Development Group S.A.S. disclose or allow access to your personal information such as your account, invoices, payments and physical address. Likewise, C&M Development Group S.A.S. uses and discloses your Personal Data without your consent for the purposes of protecting other customers, employees, or property; to enforce the rights of C&M Development Group S.A.S. in court or elsewhere, or directly with You, for violations of the terms, conditions or policies of the service, and/or as required by law, for example, as part of a regulatory proceeding.

 

• Annex 1: Describes the Personal Data Processing activities, the purposes of the processing, the legal basis and retention periods in greater detail.

• Annex 2: Describes the specific uses of the information collected on the website.

 

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Third parties

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C&M Development Group S.A.S. shares your Personal Data with third parties, but never sells it to any of them. Additionally, C&M Development Group S.A.S. links non-identifiable data (such as analytics and other aggregated data sources) with data that is part of your Personal Data in order to improve your customer experience (for example, cross-referencing your Personal Data with demographic data sources and added to personalize your experience on the website). C&M Development Group S.A.S. also uses the same cross-referencing technique in order to evaluate advertising strategies.

 

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10. Profile

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C&M Development Group S.A.S. stores information that is collected through log files and/or third-party sources to create a profile of the Data Subjects' preferences. C&M Development Group S.A.S. links personal data in order to provide tailored promotions and marketing offers and to improve the content of the website.

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11. Questions and queries

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For questions and queries about this Policy, please contact the delegated data protection officer at: ventas@sampler.com.co

 

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12. Annexes

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• Annex 1: Summary of processing activities, personal data, processing purposes, legal basis and retention periods

• Annex 2: Summary of more specific uses of the information collected on the website

• Annex 3: Third parties

• Annex 4: COLOMBIA LEGAL NOTICE:

 

For Owners or users whose data is processed in Colombia, the provisions of the Privacy Policy for the Protection of Personal Data govern and, where pertinent, this Annex is complemented and forms part of it.

 

By virtue of the above, the Treatment to which the Personal Data is subjected, its Purposes and the date of entry into force, will be those determined in the Privacy Policy.

 

• Applicable Legislation: Law 1581 of 2012, Decree 1377 of 2013 and other regulations that complement, modify and/or add them.

• Identity of the person responsible: C&M Development Group S.A.S.

• Registration: NIT. 900.378.474-5

• Address: Bogotá, Colombia

• Telephone: (+57) 320-856-6866

• Email: ventas@sampler.com.co; soporte@sampler.com.co

• Person or area responsible for the attention of habeas data rights: delegated personal data official

 

Rights of the Owner: In accordance with article 8 of Law 1581 of 2012, the rights that assist you as the Owner in relation to your personal data are:

 

• Know, update and rectify your personal data in front of C&M Development Group S.A.S., as responsible or in charge of the treatment. This right may be exercised, among others, against partial, inaccurate, incomplete, fragmented, misleading data, or data whose processing is expressly prohibited or has not been authorized;

• Request proof of the authorization granted to C&M Development Group S.A.S. as responsible for the treatment except when expressly excepted as a requirement for the Treatment;

• Be informed by C&M Development Group S.A.S., as data controller or by the data processor, upon request, regarding the use that has been given to your personal data;

• Submit queries and complaints about personal data. Your queries or claims will be responded to within a maximum of ten (10) business days. If it is not possible to resolve your query or claim within this period, you will be informed of this situation and the response period may be extended for up to five (5) additional business days. The response to the queries or claims that you present may be delivered by any physical or electronic means;

• Submit complaints to the Superintendency of Industry and Commerce for violations of the provisions of this law and other regulations that modify, add or complement it;

• Revoke the authorization and/or request the deletion of the data when the processing does not respect the constitutional and legal principles, rights and guarantees, or when a use other than those authorized is carried out;

• Access free of charge to your personal data that has been processed.

• Procedure for exercising your rights as the owner: If you have questions about this Policy, or any concern or claim, or in the event of a complaint, rectification, update, query, or request for access or data theft, or With respect to the administration of the Policy, please contact us through the channels determined in this annex and, in particular, through the following email address of the personal data delegate ventas@sampler.com.co

 

Keep in mind that once you inform the responsible area within C&M Development Group S.A.S. The query, request or complaint will be processed. Your request or request in relation to your Personal Data must be responded to within a maximum period of fifteen (15) business days from receipt of the request or request.

 

For the correct and complete consideration of your request, request or claim, we ask you to provide the identity of the applicant, their identification number, the notification/response address and the documents they wish to assert.

 

If your request or request does not have sufficient data and facts to allow C&M Development Group S.A.S. to attend to it correctly and completely, you will be required within five (5) days following receipt of the request, request or claim to correct its deficiencies. After fifteen (15) days from the date of the request, if you as the applicant have not corrected as required, C&M Development Group S.A.S. understands that you have withdrawn your application.

 

Consultation: The Holders' queries and requests will be responded to within a maximum period of ten (10) business days, counted from the date of receipt of these, as long as they meet the minimum requirements mentioned above. In the event that it is not possible to resolve the query within this term, the Owner will be informed of said situation at the notification address that has been included in the respective query, and the response term may be extended for up to five (5) days. additional skills. The response to the queries or claims that the Owners present may be delivered by any physical or electronic means.

 

Rectifications and Claims: When the Information Owner, his representative or his successors consider that his information should be corrected, updated or deleted, or when they notice an alleged non-compliance by C&M Development Group S.A.S. of their duties regarding the protection of personal data contained in the Applicable Legislation and in this Privacy Policy, they may file a claim in the following way:

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• A written request must be submitted in response to the specific requirement;

• If the claim is incomplete, C&M Development Group S.A.S. will require the interested party within five (5) days following receipt of the request to complete and correct their request. If fifteen (15) business days pass from the date of the request without the applicant having provided a response, the claim will be deemed withdrawn.

• If the person receiving the claim is not competent to resolve it, he or she will notify the person who is competent to resolve it within a maximum period of two (2) business days and will inform the applicant of such fact.

• If the claim is received in full or has subsequently been completed, a “legend” must be included in the database indicating “CLAIM IN PROCESS” within the next two (2) business days.

 

C&M Development Group S.A.S. will resolve the claim within a maximum period of ten (10) business days from the day following receipt of the claim. If it is not possible to resolve the query within this term, the Owner will be informed of the delay, the reasons and the response date at the notification address that has been included in the respective claim. In any case, the response period may not exceed five (5) business days following the expiration of the first period. The response to the claims that the Owners present may be carried out by any physical or electronic means.

 

Data Deletion Request: When data deletion is requested, it cannot be done in the following cases:

• When it is a legal obligation to keep them;

• When the Owner has been contractually obliged to allow its use;

• When keeping the data is necessary to safeguard the interests of the Owner or the Public Interest;

• When the deletion hinders or hinders the exercise of the functions of the administrative or judicial authorities.

 

Revocation of Authorization: When a Holder wants to revoke the authorization that he has given for the use of his personal data, he must inform the person responsible for the treatment in a clear manner, whether the revocation is total or partial. The revocation of the authorization is partial when the Owner of the information states that they wish to revoke their authorization for the Processing of their Personal Data for certain specific purposes, such as sending advertising information, communications, news, among others. The revocation of the authorization will be total when the Owner of the information requests that the Processing of personal data completely cease for all authorized purposes.

 

Bogotá, January 2024, Version 2