QBO CONSTRUCTORES S.A.S.

PRIVACY POLICY AND DATA PROCESSING LAST UPDATED AUGUST 02, 2021

This Privacy Policy and Personal Data Processing of QBO CONSTRUCTORES S.A.S. (hereinafter “QBO CONSTRUCTORES”), updated on MAY 26, 2021, describes:

The manner in which the respective Information and Personal Data Owners authorize or prohibit QBO CONSTRUCTORES from using, handling, and processing them.
The information and personal data that QBO CONSTRUCTORES collects, captures, stores, uses, discloses, circulates, compiles, handles, processes, and exchanges through its website, emails, correspondence, and physical and digital files, its contact points, and in general, its databases.
The rights of users who are Owners of personal data in relation to the use, handling, and processing of their information and personal data by QBO CONSTRUCTORES.
The purposes for which QBO CONSTRUCTORES collects, captures, stores, uses, discloses, circulates, compiles, handles, processes, and exchanges the information and personal data of individuals who consent to authorize the handling and processing of said data.
The ways in which QBO CONSTRUCTORES will use, handle, and process the information and personal data for which the respective Owners grant the aforementioned authorization.
The security measures adopted by QBO CONSTRUCTORES to protect the information and personal data of the Owners in general.
The channels, means, mechanisms, systems, and forms through which Owners can exercise and enforce their rights as owners of the information and personal data that are used, handled, and processed by QBO CONSTRUCTORES.

In your capacity as a Personal Data Holder that could be used, handled, and processed by QBO CONSTRUCTORES, YOU must carefully read this Privacy Policy and Personal Data Processing document, and it is also recommended that you read QBO CONSTRUCTORES’ Data Handling and Processing Manual, which are visible at the link https://gbo.co/wp-content/uploads/2018/10/OBO-HabeasData.pdf on the page www.qbo.co, where YOU will be able to access and know all the specific rules that govern QBO CONSTRUCTORES for all activities it develops regarding the use, handling, and processing of information and personal data.

Also, in your capacity as the Owner of Personal Data that may be used, handled, and processed by QBO CONSTRUCTORES, it is recommended that you read and familiarize yourself with the legal regulatory norms on the subject of habeas data and personal data protection, among which the following stand out: Article 15 of the Political Constitution, Law 1266 of 2008, Law 1581 of 2012, Regulatory Decrees 1727 of 2009 and 2952 of 2010, and Partial Regulatory Decree No. 1377 of 2013.

Considering that the privacy policies and personal data processing of QBO CONSTRUCTORES contained in this document are updated periodically, YOU should always check the update date of this document located at the beginning of the text to verify if YOU are indeed aware of it in its latest version. In case YOU have authorized the use, handling, and processing of your information and personal data, we will send you by email all modified versions of this Privacy Policy and Personal Data Processing so that YOU can determine, due to changes in said policy, whether to maintain or revoke the authorization granted to QBO CONSTRUCTORES to collect, capture, store, use, disclose, circulate, compile, handle, and process your information and personal data. When YOU authorize these activities, YOU will also authorize the sending to your email of updates to the respective Privacy Policy and Personal Data Processing of QBO CONSTRUCTORES.

Authorization for Use, Handling, and Processing of your Information and Personal Data

When YOU provide, send, communicate or make available to us, through our contact points, our website, our emails and other correspondence means of QBO CONSTRUCTORES, your personal information and data, we will have sent you via email or will have shown you this document, and the above will mean that YOU agree, accept, consent and authorize in advance, expressly and unequivocally the uses, handling and processing, by QBO CONSTRUCTORES, of the information and personal data of which YOU are the owner and which are sent, collected and/or captured by QBO CONSTRUCTORES, since YOU expressly and unequivocally acknowledge that you have read, understood and accepted the terms set forth above and the terms of this Privacy Policy and consequently confer and consent to the aforementioned authorizations for the use, handling and processing of your information and personal data by QBO CONSTRUCTORES under these terms. If you do not agree with this, you have the option of not providing any personal information and generally omitting the sending of personal information and data to our emails, our website and other contact points. And you also have the right to expressly and unequivocally inform that you do not grant QBO CONSTRUCTORES your authorization and consent for the use, handling and processing of your personal information and data. This authorization that YOU grant us includes the authorization for your mentioned authorized information and personal data to be equally used, handled and processed, under the terms of this Privacy Policy, by natural or legal persons that QBO CONSTRUCTORES may define as responsible for their use, handling and processing and/or in general by the persons to whom QBO CONSTRUCTORES would allow access to the information and personal data, including document management and storage companies.

Without prejudice to the above, we may request YOU to ratify these authorizations granted in the specific segments of our contact points, our website and emails in which YOU include and grant your personal information and data and/or at the time of doing so. In addition, we may request from YOU, through a prior, express and written request via your email, a specific and concrete authorization to use, handle and process your personal information and data outside the parameters and limits initially authorized and agreed upon and regarding which YOU had not expressed your prior and express authorization and consent.

Your authorization as the Owner of the information and personal data will not be required in the cases specifically indicated by law, including:

When the information is required by a public or administrative authority in the exercise of its legal functions.
When the information is required by judicial order.
When the information is of a public nature.
In cases of medical or health emergency.

Information and Personal Data that are Subject to your Authorization for Use, Handling, and Processing by QBO CONSTRUCTORES

“Personal Information” or “Personal Data” is understood as all information that can be used to identify a person and includes, among others, the following data:

Name, address, phone numbers, email address, date of birth, nationality.
Financial information, such as the number and data related to bank account numbers and credit cards.
Information related to tax qualifications.
Information related to your profession, employment, occupation, and all that information that could usually be found in your resume or CV, applications, background check information or employment references.
Information related to your hobbies, likes, pastimes, skills, and talents.
Information related to the products and services you usually purchase or would like to purchase.

YOU authorize QBO CONSTRUCTORES to use, handle and process your personal information and data provided and communicated through our contact points, our emails, our physical correspondence and other means established for this purpose by QBO CONSTRUCTORES, among which may be included the information and personal data listed above.

QBO CONSTRUCTORES may also collect and capture, with your authorization under the terms referred to above, aggregated or related information and data that are not personal in nature because a specific person cannot be identified and associated with them.

The authorizations granted by YOU as the Data Subject, which have been referred to, include the possibility of transmitting your personal data and information abroad, with the understanding that the foreign countries in which said personal data is used, handled, and processed have regulations in the matter that do not confer the same protections and rights granted in Colombian legislation.

Sensitive Data: QBO CONSTRUCTORES or whoever it designates to collect or process your personal information and data, will not collect, handle, or process data considered sensitive, understood as all those that affect the privacy of the data subject or whose improper use may generate discrimination, such as racial or ethnic origin, political, religious or philosophical orientation, among others. The only sensitive personal data that QBO CONSTRUCTORES will use and process are:

Those related to the health of employees working in the company and of other people who enter the facilities, headquarters, offices, and other operating locations of the company for security and biosecurity reasons.
Those related to biometric identification authentication of company employees and other people who enter the facilities, headquarters, offices, and other operating locations of the company for security and biosecurity reasons.

QBO CONSTRUCTORES does not collect personal information from children under 13 years of age, and does not use this information if it discovers that it has been provided. To respect children’s privacy and comply with relevant legal standards, children under 13 years of age should not provide any personal information to QBO CONSTRUCTORES. We ask parents of these minors to supervise their children while they are online.

Rights of the Data Subject Regarding the Handling and Processing of Their Personal Information and Data

As the Data Subject of your personal information and data, YOU will have the rights to:

Authorize or prohibit Personal Data Handling and Processing activities carried out by QBO CONSTRUCTORES.
Revoke the authorizations granted regarding Personal Data Handling and Processing activities carried out by QBO CONSTRUCTORES.
Access your personal information and data free of charge, which are subject to Personal Data Handling and Processing activities carried out by QBO CONSTRUCTORES.
Update, correct, modify, exclude, delete, rectify your personal information and data, which are subject to Personal Data Handling and Processing activities carried out by QBO CONSTRUCTORES.
Formulate questions, comments, requests, and complaints regarding Personal Data Handling and Processing activities carried out by QBO CONSTRUCTORES.
Request reports on Personal Data Handling and Processing activities carried out by QBO CONSTRUCTORES regarding your personal information and data.
Request proof of the authorization granted for Personal Data Handling and Processing activities carried out by QBO CONSTRUCTORES
Modify and revoke the authorization granted for Personal Data Handling and Processing activities carried out by QBO CONSTRUCTORES.
Appeal to legally constituted authorities, especially to the Superintendence of Industry and Commerce, and file complaints for violations of the provisions in current regulations in applicable norms, after consultation or request to the Data Controller.
Know the efficient mechanisms, means, and channels for exercising your duties referred to in the previous paragraphs, which will be informed by QBO CONSTRUCTORES in the Privacy Notice.

Your requests for information, claims, complaints, rectification, modification, deletion, or updates will be processed free of charge and quickly by QBO CONSTRUCTORES, and they must contain at least the following:

The personal information and data subject to your request.
The consultations, updates, rectifications, modifications, deletions, complaints, and/or claims that are the subject of your request.
The reasons that motivate your respective request.
The documents that support your respective request.
The identification, address, and contact details of the Data Subject, their representative and/or their proxy, to receive responses to the request.

Purposes of the Use, Handling, and Processing of your Personal Information and Data and Ways in which They Will be Used, Handled, and Processed

QBO CONSTRUCTORES may use the information and personal data provided by YOU and for which authorization has been granted, in the following ways:

Respond to customer service inquiries.
Internal and administrative organization and management, including aspects related to files and accounting databases, compliance with tax regulations, invoicing, and payments.
Create personalized promotions by combining your personal information with your non-personal information.
Communicate with YOU about orders or purchases, contests, or sweepstakes that you have entered or may enter.
Communicate with YOU about certain job positions, work opportunities, and general information about employment at QBO CONSTRUCTORES.
Communicate with YOU about our brands, products, events, or other promotional purposes, including brand offers. YOU can opt out of receiving marketing information at any time by changing your communication preferences settings, following the links, and through the contact points referred to in this document and in the Privacy Notice to unsubscribe from any marketing operation sent to you.
Communicate with YOU about brands, products, events, or other promotional purposes of third parties associated with us, including brand offers. YOU can opt out of receiving marketing information at any time by changing your communication preferences settings, following the links, and through the contact points referred to in this document and in the Privacy Notice to unsubscribe from any marketing operation sent to you.
Share information with companies that offer us support services (such as credit card processors, mailing houses, or Internet hosts), that help us market our products and services (such as email vendors), or with our strategic partners. These companies may need information about YOU in order to fulfill their functions. These companies are not authorized to use the personal information and data we share with them for any purpose other than those mentioned here.
In the event of the sale of part or all of our business, we may disclose personal information and data to the persons involved in the transfer of all or part of our business or assets. If such an event occurs, QBO CONSTRUCTORES will guarantee that the recipient will handle and treat your personal information as described in this privacy policy, handling, and treatment of personal data.
Use your email address and other contact information you provide to send you communications, content, and materials, ours or from third parties. If YOU do not wish to receive this type of promotional information, you can change your communication preferences and unsubscribe from our email list at any time.
QBO CONSTRUCTORES may also exchange your personal information and data with governmental or other public authorities (including, among others, judicial or administrative authorities, tax authorities, and criminal, civil, administrative, disciplinary, and fiscal investigation bodies), and third parties participating in civil legal proceedings and their accountants, auditors, lawyers, and other advisors and representatives, because it is necessary or appropriate: (i) to comply with current laws, including laws other than those of your country of residence; (ii) to comply with legal processes; (iii) to respond to requests from public authorities and the government, and to respond to requests from public authorities and the government other than those of your country of residence; (iv) to enforce our terms and conditions; (v) to protect our operations; (vi) to protect our rights, privacy, security, or property, yours or those of third parties; and (vii) obtain applicable compensation or limit damages that may affect us.
By authorizing the collection, use, and disclosure of personal information and data that YOU confer to us, YOU also authorize that this information and personal data may be transferred and transmitted to countries other than your country of origin, being YOU aware that those countries may not provide an equivalent level of protection as the data protection laws in your aforementioned country of origin.

Security and Protection of your Personal Information and Data

QBO CONSTRUCTORES will make its best efforts to maintain the physical, technical, and administrative security of its offices and information systems, in order to prevent the loss, misuse, unauthorized access, disclosure, or modification of all your personal information and data that are collected, used, handled, and treated by QBO CONSTRUCTORES, and for which YOU have conferred the respective authorization.

While we strive to protect your information and personal data from the moment we receive it, it is not possible to guarantee this care as an obligation of result, but of means, since the use, handling, and transmission of data can never be guaranteed as 100% secure.

The channels, means, mechanisms, systems, and forms through which users can exercise and enforce their rights as owners of the information and personal data that are used, handled, and processed by QBO CONSTRUCTORES

The contact details of QBO CONSTRUCTORES for all purposes related to the use, handling, and processing of the aforementioned information and personal data are as follows:

Email: bdqbo@qbo.co

At these contact points, the owner of the information and personal data used, handled, and processed by QBO CONSTRUCTORES can find, contact, and communicate with the department and officials of QBO CONSTRUCTORES specifically designated for handling matters related to the management and processing of their information and personal data, who are identified as follows:

David Alberto Cabrera Santos.

Through these contacts, in the terms that have been set out in this document, YOU may send to QBO CONSTRUCTORES all your requests for information, claims, complaints, rectification, modification, deletion, or updates, related to your information and personal data that are subject to use, handling, and processing by QBO CONSTRUCTORES by virtue of your prior, express, and informed authorization.

YOU state the following: “I consent and authorize in a prior, express, informed, and unequivocal manner that my information and personal data delivered, communicated, and/or sent by me to QBO CONSTRUCTORES through physical mail, email, or other means of contact and communication, be collected, captured, stored, used, disclosed, compiled, circulated, exchanged, handled, and processed by QBO CONSTRUCTORES or the persons in charge designated by QBO CONSTRUCTORES, in accordance with the provisions of this document and/or authorization. I declare that I have read, understood, and approved this Privacy Policy and Personal Data Processing document of QBO CONSTRUCTORES, the Internal Manual for Handling and Processing Personal Data, and the Privacy Notice Document of QBO CONSTRUCTORES, which have been sent to me via email and are visible at the link https://gbo.co/wp-content/uploads/2018/10/OBO-Habeas-Data.pdf on the website www.qbo.co.”

CAMILO ANDRES FERNANDEZ SANCHEZ

QBO CONSTRUCTORES S.A.S.