Privacy Policy

Personal Data Policy

In compliance with the provisions of Statutory Law 1581 of 2012 and its Regulatory Decree 1377 of 2013, MEDCOLCANNA S.A.S. adopts this Personal Data Treatment Policy, which will be informed to all owners of the data collected or that in the future are obtained. In this way, MEDCOLCANNA S.A.S. declares that it guarantees the right to Habeas Data in the Processing of Personal Data, which includes the collection, storage, use, circulation, deletion, transfer, transmission, and assignment of personal information of its clients, workers, suppliers, and doctors, as well as Natural persons who could have a contractual or legal relationship with the company. MEDCOLCANNA S.A.S. is aware of the implications of the Processing of Personal Data in the development of its commercial activity, therefore it carries out said activity following the principles and guidelines contained in the Personal Data Protection Regime – Law 1581 of 2012, the Decrees that regulate it and the recommendations of the Superintendency of Industry and Commerce. To protect and ensure the owners of personal data a due treatment of their information, MEDCOLCANNA S.A.S. issues this Personal Data Treatment Policy.

I. Purpose. The Personal Data Treatment Policy of MEDCOLCANNA S.A.S. seeks to guarantee the right to habeas data of natural persons who have deposited their information in the company’s databases.

II. Identification of the Person in Charge and the Person in Charge of the Treatment of personal data MEDCOLCANNA SAS, as the person in charge and charge of the treatment (“Person in charge of the Treatment” and “Person in Charge of the Treatment”) of personal data, is a company established by private document dated March 4, 2016, registered in the Bogotá Chamber of Commerce on December 19, 2016, under number 02167642 of Book IX. Medcolcanna is identified with Nit. 901.035.709-2 and Commercial Registration No. 2761802 of December 19, 2016, its business address is Carrera 49B No. 93-62 of the city of Bogotá DC, telephone (57) (1) 642-9113 and email info@medcolcanna.com MEDCOLCANNA SAS, has appointed within its administrative structure a Data Protection Officer, who assumes the function of personal data protection and is responsible for the effective implementation of this Personal Data Treatment Policy, and the other policies for the protection of personal data implemented by MEDCOLCANNA SAS

III. Scope of the Information Treatment Policy Following Law 1581 of 2012, the holders of personal data are understood to be the “Natural person whose personal data is subject to Treatment”, therefore, the policy of MEDCOLCANNA S.A.S. focuses on personal data from natural persons. The coverage of these policies covers all workers, clients, suppliers of MEDCOLCANNA S.A.S., as well as potential clients with whom the company maintains communication. IV. Personal Data Susceptible to Treatment and Purpose of the Data. MEDCOLCANNA S.A.S. treats the following personal data according to the database and the purposes indicated below:

Clients

Personal Data

Names, surnames, type, and ID number, city, and address of business address, landline, cell phone, email, financial and credit data.

Use

a) Contact for commercial purposes and new businesses.

b) Fulfillment of obligations derived from the acquisition of products or services of MEDCOLCANNA S.A.S.

c) Promotion, marketing, and sale of products and services of MEDCOLCANNA S.A.S.

d) Promotion, marketing, and sale of Third Party Products and Services.

e) Execution of projects and monitoring of their operation.

f) Manage authorizations for members of MEDCOLCANNA S.A.S. and third parties in the execution of projects.

g) Establish a communication channel to know the subsequent impact of the products delivered and the services provided.

h) For the determination of pending obligations, the consultation of financial information and credit history and the report to information centers of defaulted obligations, concerning its debtors. i) Register your data in the information systems of MEDCOLCANNA S.A.S.

j) Allow companies related to MEDCOLCANNA S.A.S., with which it has entered into contracts that include provisions to guarantee the protection and adequate treatment of the personal data processed, contact the Holder to offer goods or services of interest;

k) Transmitting and/or Transferring Personal Data to third parties in Colombia and/or abroad that are related companies of MEDCOLCANNA S.A.S. for commercial, administrative, and/or operational purposes.

Providers

Personal Data

Names, surnames, type and ID number, city, and address of business address, landline, cell phone, email, and Bank Data.

Use

a) To invite them to participate in selection processes and events organized or sponsored by MEDCOLCANNA S.A.S.

b)
For the evaluation of the fulfillment of its obligations.

c)
To process your payments and verify outstanding balances.

d)
Register your data in the information systems of MEDCOLCANNA S.A.S.

e) Transmit and/or Transfer Personal Data to third parties in Colombia and/or abroad that are related companies of ME

Workers

Personal Data

Names, surnames, type and ID number, telephone, cell phone, address, financial information, email, work and personal references, psycho-technical tests, family composition, photography, health, and safety certificates at work.

Use

a) Manage and operate, directly or through third parties, the personnel selection and hiring processes, including the evaluation and qualification of the participants and the verification of work and personal references, and the performance of safety studies.

b) Develop the activities of Human Resources management within MEDCOLCANNA S.A.S., such as payroll, affiliations to entities of the general social security system, occupational health, and welfare activities, exercise of the employer’s sanctioning power, among others.

c) To comply with the obligations contracted by MEDCOLCANNA S.A.S., concerning the payment of salaries, social benefits, and others enshrined in the employment contract and labor legislation.

d) Contract employment benefits with third parties, such as life insurance, medical expenses, among others.

e) Notify authorized contacts in case of emergencies during working hours or the development of the same.

f) Register your data in the information systems of MEDCOLCANNA S.A.S.

g) Use of an image in corporate events and advertising of MEDCOLCANNA S.A.S.

h) Transmit and/or Transfer Personal Data to third parties in Colombia and/or abroad that are related companies of MEDCOLCANNA S.A.S. for administrative and/or operational purposes.

Final Uses

a) Evaluate the quality of the service, carry out market studies on consumption habits, and statistical analysis for internal uses.

b) Allow the participation of the Holders in marketing and promotional activities (including participation in contests, raffles, and raffles) carried out by MEDCOLCANNA S.A.S.

c) Control access to the offices of MEDCOLCANNA S.A.S. and establish security measures, including the establishment of video surveillance zones.

d) Respond to queries, requests, complaints, and claims that are made by the Holders and control bodies and transmit the Personal Data to the other authorities that under applicable law must receive the Personal Data.

e) Transfer the information collected to different areas of MEDCOLCANNA S.A.S. and its related companies in Colombia and abroad when it is necessary for the development of their operations (collection of portfolio and administrative charges, treasury, accounting, among others).

f) Register your personal data in the information systems of MEDCOLCANNA S.A.S. and its commercial and operational databases.

g) For the attention of judicial or administrative requirements and the fulfillment of judicial or legal orders.

h) To eventually contact, via email, or by any other means, natural persons with whom it has or has had a relationship, such as, without the enumeration being exhaustive, workers and their families, consumers, clients, distributors, suppliers, creditors, and debtors, for the aforementioned purposes.

i) Any other activity of a similar nature to those described above that is necessary to develop the corporate purpose of MEDCOLCANNA S.A.S.