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QBO CONSTRUCTORES S.A.S.

DATA PROTECTION AND PRIVACY POLICY LAST UPDATED DECEMBER 18, 2025

 

This Privacy Policy aims to provide the necessary and sufficient information to the different stakeholder groups of QBO CONSTRUCTORES S.A.S. regarding the Processing of Personal Data and, in general, to all individuals whose Personal Data the Company collects and processes (hereinafter the “Data Subject(s)”). Likewise, it seeks to establish the guidelines that ensure the protection of Personal Data subject to Processing and the rights of Data Subjects, setting the criteria for the collection, storage, use, circulation, and deletion of the personal information collected.

RESPONSIBLE PARTY INFORMATION bdqbo@qbo.co

Legal Name QBO CONSTRUCTORES S.A.S.
Tax ID (NIT) 900.371.677-1
Principal Address Calle 93A No. 13 24 Piso 7
Phone 601 7480505
Email
Website https://www.qbo.co/

 

  1. PURPOSE

This Policy regulates and establishes the general guidelines and principles for the protection and Processing of Personal Data within QBO CONSTRUCTORES, thereby strengthening the level of trust between the Data Controller and Data Subjects with respect to the collection, recording, management, transfer, exchange, and Processing of personal data carried out by QBO in the ordinary course of its business activities.

  1. SCOPE

This Personal Data Processing and Protection Policy shall apply to all databases and/or files that include Personal Data subject to Processing by QBO CONSTRUCTORES as the Data Controller, and its scope covers:

2.1 The manner in which the respective Data Subjects authorize or prohibit QBO CONSTRUCTORES from using, managing, transferring, exchanging, and processing their personal information and data.

2.2 The personal information and data that QBO CONSTRUCTORES collects, captures, stores, uses, discloses, circulates, compiles, manages, processes, transmits, and exchanges through its website, email accounts, physical and digital correspondence and files, contact points, and databases in general.

2.3 The rights of Data Subjects with respect to the use, management, and processing of their personal information and data by QBO CONSTRUCTORES.

2.4 The purposes for which QBO CONSTRUCTORES collects, captures, stores, uses, discloses, circulates, compiles, manages, processes, transmits, and exchanges the personal information and data of individuals who consent to authorize the management and processing of such data.

2.5 The ways in which QBO CONSTRUCTORES will use, manage, and process the personal information and data for which the respective Data Subjects have granted such authorization.

2.6 The security measures adopted by QBO CONSTRUCTORES to generally protect the personal information and data of Data Subjects.

2.7 The channels, means, mechanisms, systems, and methods through which Data Subjects may exercise and enforce their rights as holders of personal information and data used, managed, and processed by QBO CONSTRUCTORES.

As a Data Subject whose personal information and data may be used, managed, and processed by QBO CONSTRUCTORES, YOU must read this Privacy and Personal Data Processing Policy carefully and attentively. It is also recommended that you read QBO CONSTRUCTORES’ Personal Data Management and Processing Manual, all of which are available at the link /privacy-policy/ on the website
https://www.qbo.co/,
where YOU may access and learn all the specific rules governing QBO CONSTRUCTORES’ activities related to the use, management, and processing of personal information and data.

Additionally, as a Data Subject whose personal information and data may be used, managed, and processed by QBO CONSTRUCTORES, you are advised to read and familiarize yourself with the legal regulations governing habeas data and personal data protection, including, but not limited to: 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.

Given that QBO CONSTRUCTORES’ privacy and personal data processing policies contained in this document are periodically updated, YOU must always check the update date located at the beginning of this document to verify that you are reading the latest version. If YOU have authorized the use, management, and processing of your personal information and data, upon your request, we will send you by email all modified versions of this Privacy and Personal Data Processing Policy so that YOU may determine, based on changes to the policy, whether to maintain or revoke the authorization granted to QBO CONSTRUCTORES to collect, capture, store, use, disclose, circulate, compile, manage, and process your personal information and data. When YOU authorize these activities, you will also authorize the sending of updates to the respective QBO CONSTRUCTORES Privacy and Personal Data Processing Policy to your email address.

  1. AUTHORIZATION FOR THE USE, MANAGEMENT, AND PROCESSING OF YOUR PERSONAL INFORMATION AND DATA

When YOU provide, send, communicate, or make available your personal information and data to QBO CONSTRUCTORES through our contact points, website, email accounts, or other means of correspondence, we will have sent you via email or displayed this document to you through any available means, including our website. This shall mean that YOU agree to, accept, consent to, and expressly, unambiguously, and in advance authorize QBO CONSTRUCTORES to use, manage, and process the personal information and data of which YOU are the owner and which are sent, collected, and/or captured by QBO CONSTRUCTORES, since YOU expressly and unambiguously acknowledge that you have read, understood, and accepted the terms set forth herein and the terms of this Privacy Policy, and consequently grant and consent to the aforementioned authorizations for the use, management, and processing of your personal information and data by QBO CONSTRUCTORES under the present terms. If YOU do not agree, you have the option of not providing any personal information and, in general, of refraining from submitting personal information and data to our email accounts, website, and other contact points. YOU also have the right to expressly and unambiguously inform us that you do not grant QBO CONSTRUCTORES your authorization and consent for the use, management, and processing of your personal information and data. The authorization YOU grant us also includes authorization for the aforementioned personal information and data to be used, managed, and processed, under the terms of this Privacy Policy, by any natural or legal persons that QBO CONSTRUCTORES may designate as responsible for such use, management, and processing, and/or in general by persons to whom QBO CONSTRUCTORES grants access to said personal information and data, including document management and storage companies.

Notwithstanding the above, we may ask YOU to ratify these authorizations at specific sections of our contact points, website, and email accounts where YOU include or provide your personal information and data, and/or at the time of doing so. Additionally, we may request, through a prior, express, and written request via your email address, a specific and concrete authorization to use, manage, and process your personal information and data beyond the parameters and limits initially authorized and agreed upon, and for which YOU have not previously given your express prior consent.

Your authorization as the Data Subject will not be required in the cases specifically set forth by law, including:

  1. When the information is required by a public or administrative authority in the exercise of its legal functions.
  2. When the information is required by court order.
  3. When the information is of a public nature.
  4. In cases of medical or health emergencies.

 

  1. PERSONAL INFORMATION AND DATA SUBJECT TO YOUR AUTHORIZATION FOR USE, MANAGEMENT, AND PROCESSING BY QBO CONSTRUCTORES

“Personal Information” or “Personal Data” means all information that can be used to identify an individual and includes, among others, the following:

  1. Name, address, phone numbers, email address, date of birth, nationality.
  2. Financial information, such as bank account numbers and related data, and credit card information.
  3. Information related to tax status.
  4. Information related to your profession, employment, occupation, and any information typically found in your resume or CV, job applications, background check information, or employment references.
  5. Information related to your hobbies, interests, pastimes, skills, and talents.
  6. Information related to the products and services you regularly purchase or would like to purchase.
  7. Information requested and required by the Self-Control and Comprehensive Risk Management System for Money Laundering and Terrorism Financing (SAGRILAFT) implemented by QBO, which the Data Subject acknowledges being aware of, published on QBO’s website. This includes, among others: (i) information about the origin, status, location, and destination of the Data Subject’s assets, liabilities, income, resources, property, investments, and securities; (ii) the products, services, companies, and/or activities that are part of the Data Subject’s business or with which the Data Subject has any type of relationship; (iii) the channels, means, and mechanisms through which the Data Subject conducts their activities, businesses, companies, services, and products; (iv) the countries, locations, and jurisdictions in which the Data Subject conducts their activities, businesses, companies, services, and products; (v) the origin of the services, products, companies, and businesses with which the Data Subject is associated; (vi) information about the Data Subject’s suppliers, contractors, contracting parties, and clients, or those with whom the Data Subject has any type of relationship; (vii) information about donations received or made by the Data Subject, or about free transfers, assignments, or transmissions of rights, assets, or securities by the Data Subject; (viii) information about the Data Subject’s investments, businesses, assets, or securities held abroad.
  8. Information requested and required by the rules, regulations, and codes of ethics and conduct implemented by QBO, which the Data Subject acknowledges being aware of. This includes, among others: (i) information about the Data Subject’s current or past participation in Shareholders’ Meetings, Boards of Directors, and governance, management, and decision-making bodies of legal entities; (ii) information about the Data Subject’s suppliers, contractors, contracting parties, and clients, or those with whom the Data Subject has or had any type of relationship; (iii) information about donations received or made by the Data Subject, or about free transfers, assignments, or transmissions of rights, assets, or securities by the Data Subject.

YOU authorize QBO CONSTRUCTORES to use, manage, and process your personal information and data provided and communicated through our contact points, email accounts, physical correspondence, and other means established by QBO CONSTRUCTORES for this purpose, which may include the personal information and data listed above.

QBO CONSTRUCTORES may also collect and capture, with your authorization as described above, aggregated or related information and data that is not of a personal nature because it cannot be used to identify and associate a specific individual.

The authorizations YOU grant as Data Subject, as referenced herein, include the possibility of transferring your personal data and information abroad, with the understanding that the foreign countries in which such personal data is used, managed, and processed may have regulations that do not provide the same level of protection and rights afforded under Colombian law.

 

  1. SENSITIVE DATA

QBO CONSTRUCTORES, or any party designated by QBO CONSTRUCTORES to collect or process your personal information and data, will not collect, manage, or process data considered sensitive, defined as data that affects the privacy of the Data Subject or whose improper use may lead to 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:

  1. Data relating to the health of employees working at the company and other individuals entering the company’s facilities, offices, and other operating locations, for security and biosecurity purposes.
  2. Data relating to biometric identification authentication of company employees and other individuals entering the company’s facilities, offices, and other operating locations, for security and biosecurity purposes.
  3. Data relating to disciplinary, criminal, and penal records, and all data related to investigations initiated against the Data Subject in connection with money laundering, terrorism, corruption, and generally prohibited conduct under the law.

QBO CONSTRUCTORES does not collect personal information from children under the age of 13 and does not use such information if it is discovered to have been provided. To respect children’s privacy and comply with applicable legal standards, children under the age of 13 must not provide any personal information to QBO CONSTRUCTORES. We ask parents of such minors to supervise their children while online.

 

  1. DATA SUBJECT RIGHTS REGARDING THE MANAGEMENT AND PROCESSING OF PERSONAL INFORMATION AND DATA

As a Data Subject, YOU have the right to:

  1. Authorize or prohibit the Personal Data Management and Processing activities carried out by QBO CONSTRUCTORES.
  2. Revoke authorizations granted with respect to Personal Data Management and Processing activities carried out by QBO CONSTRUCTORES.
  3. Access, free of charge, your personal information and data subject to Personal Data Management and Processing activities carried out by QBO CONSTRUCTORES.
  4. Update, correct, modify, exclude, delete, or rectify your personal information and data subject to Personal Data Management and Processing activities carried out by QBO CONSTRUCTORES.
  5. Submit questions, comments, requests, and complaints regarding the Personal Data Management and Processing activities carried out by QBO CONSTRUCTORES.
  6. Request reports on the Personal Data Management and Processing activities carried out by QBO CONSTRUCTORES with respect to your personal information and data.
  7. Request proof of the authorization granted for the Personal Data Management and Processing activities carried out by QBO CONSTRUCTORES.
  8. Modify and revoke the authorization granted for the Personal Data Management and Processing activities carried out by QBO CONSTRUCTORES.
  9. Appear before legally established authorities, particularly the Superintendence of Industry and Commerce, and file complaints regarding violations of the applicable regulations, following prior consultation or request submitted to the Data Controller.
  10. Be informed of the efficient mechanisms, means, and channels for exercising the rights referenced in the preceding sections, which will be communicated by QBO CONSTRUCTORES in the

 

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

  1. The personal information and data that is the subject of your request.
  2. The queries, updates, rectifications, modifications, deletions, complaints, and/or claims that are the subject of your request.
  3. The reasons supporting your request.
  4. The documents supporting your request.
  5. The identification, address, and contact information of the Data Subject, their representative, and/or their authorized agent, for the purpose of receiving responses to the request.

 

  1. PURPOSES FOR THE USE, MANAGEMENT, AND PROCESSING OF YOUR PERSONAL INFORMATION AND DATA, AND THE WAYS IN WHICH IT WILL BE USED, MANAGED, AND PROCESSED

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

  1. To respond to customer service inquiries.
  2. For internal organizational and administrative management, including matters related to accounting records and databases, tax compliance, invoicing, and payments.
  3. To create personalized promotions by combining your personal information with your non-personal information.
  4. To communicate with YOU regarding orders or purchases, contests, or sweepstakes you have entered or may enter.
  5. To communicate with YOU regarding specific job positions, employment opportunities, and general employment information at QBO CONSTRUCTORES.
  6. To communicate with YOU about our brands, products, events, or other promotional purposes, including branded offers. YOU may opt out of receiving marketing information at any time by changing your communication preference settings, following the links and through the contact points referenced in this document and in the Privacy Notice to unsubscribe from any marketing communications sent to you.
  7. To communicate with YOU about brands, products, events, or other promotional purposes of third parties affiliated with us, including branded offers. YOU may opt out of receiving marketing information at any time by changing your communication preference settings, following the links and through the contact points referenced in this document and in the Privacy Notice to unsubscribe from any marketing communications sent to you.
  8. To share information with companies that provide us with 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 perform 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 herein.
  9. In the event of the sale of part or all of our business, we may disclose personal information and data to the parties involved in the transfer of all or part of our business or assets. Should such an event occur, QBO CONSTRUCTORES will ensure that the recipient manages and processes your personal information in accordance with this privacy, data management, and processing policy.
  10. To use your email address and other contact information you provide to send you communications, content, and materials, whether our own or from third parties. If YOU do not wish to receive this type of promotional information, you may change your communication preferences and unsubscribe from our email list at any time.
  11. QBO CONSTRUCTORES may also exchange and transfer your personal information and data with government or other public authorities (including, among others, judicial or administrative authorities, tax authorities, and criminal, civil, administrative, disciplinary, and fiscal investigative bodies), and third parties involved in civil legal proceedings and their accountants, auditors, attorneys, and other advisors and representatives, when necessary or appropriate: (i) to comply with applicable laws, including laws other than those of your country of residence; (ii) to comply with legal processes; (iii) to respond to requests from public and government authorities, including those outside 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, or those of others; and (vii) to obtain applicable remedies or limit damages that may affect us.
  12. By authorizing the collection, use, and disclosure of personal information and data, YOU also authorize such personal information and data to be transferred, exchanged, and transmitted to countries other than your country of origin, with the understanding that such countries may not provide an equivalent level of protection as the data protection laws of your country of origin.
  13. To evaluate and examine them based on the rules and regulations of the Self-Control and Comprehensive Risk Management System for Money Laundering and Terrorism Financing (SAGRILAFT) implemented by QBO. Based on the evaluations conducted through QBO’s SAGRILAFT system, to transmit them to compliance officers, authorities, or other third parties.
  14. To evaluate and examine them based on the regulations and codes of ethics and conduct implemented by QBO. Based on the evaluations conducted under QBO’s regulations and codes of ethics and conduct, to transmit them to compliance officers, authorities, or other third parties.
  15. To transmit, share, communicate, and allow the use, storage, and processing of such data by third parties with whom QBO is part of or has relationships in the form of consortiums, temporary joint ventures, or joint ventures.
  16. To use, store, process, and transmit them in the execution of temporary joint venture agreements, consortiums, and joint ventures of which QBO is a part.

 

  1. 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 personal information and data collected, used, managed, and processed by QBO CONSTRUCTORES, and for which YOU have granted the respective authorization.

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

The channels, means, mechanisms, systems, and methods through which users may exercise and enforce their rights as Data Subjects of personal information and data used, managed, and processed by QBO CONSTRUCTORES are as follows:

The contact information for QBO CONSTRUCTORES for all matters related to the use, management, and processing of personal information and data is:

Email: bdqbo@qbo.co

Through these contact points, the Data Subject of personal information and data used, managed, and processed by QBO CONSTRUCTORES may find, contact, and communicate with the designated administrative department and staff of QBO CONSTRUCTORES specifically assigned to handle matters related to the management and processing of personal information and data.

Through these contact points, and under the terms set forth in this document, YOU may submit to QBO CONSTRUCTORES all your requests for information, claims, complaints, rectification, modification, deletion, or updates relating to your personal information and data that are subject to use, management, and processing by QBO CONSTRUCTORES pursuant to your prior, express, and informed authorization.

YOU hereby state the following: “I consent to and authorize, in a prior, express, informed, and unambiguous manner, that my personal information and data delivered, communicated, and/or sent by me to QBO CONSTRUCTORES via physical mail, email, or other means of contact and communication, be collected, captured, stored, used, disclosed, compiled, circulated, exchanged, managed, and processed by QBO CONSTRUCTORES or persons 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 Personal Data Privacy and Processing Policy of QBO CONSTRUCTORES, the Internal Personal Data Management and Processing Manual, and the Privacy Notice of QBO CONSTRUCTORES, which have been sent to me via email and are available at the link /privacy-policy/ on the website https://www.qbo.co/.”

  1. POLICY MODIFICATIONS

QBO CONSTRUCTORES reserves the right to modify this Personal Data Processing and Protection Policy at any time. However, any modification will be communicated in a timely manner to Data Subjects through the usual means of contact, with ten (10) business days’ notice prior to its entry into force.

In the event that a Data Subject disagrees with the new general or specific policy and has valid reasons constituting just cause to discontinue the authorization for Personal Data Processing, the Data Subject may request that the company remove their information through the channels indicated in Title V of this document. However, Data Subjects may not request the removal of their Personal Data when the company has a legal or contractual obligation to process such data.

 

CAMILO AVILA CARDENAS

QBO CONSTRUCTORES S.A.S.

 

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