AMERICAN SMART SYSTEMS & NETWORKS LTDA ( hereinafter referred to as “AS-NET“The company, identified with NIT No. 800.231.706-4, domiciled at Carrera 49 A N° 91-31 in the city of Bogotá D.C., for the proper development of its commercial activities, as well as to strengthen its relations with third parties, requests, collects, stores, uses, circulates and deletes personal data.

Taking into account the above, AS-NET acts as responsible for the processing of personal data corresponding to natural persons with whom it has or has had some kind of relationship. When AS-NET acts as a processor of personal data, it must comply with the guidelines that are communicated to it, by means of a written document, by the data controller, provided that it is complying with the legislation in force. Likewise, the rights of the owners of the information regarding access and knowledge of the information, rectification, updating, suppression and revocation of the same will be applied; the above in accordance with the provisions of Article 8 of Law 1581 of 2012 and other concordant rules.

PROCESSING OF PERSONAL DATA

1. Without prior authorization

AS-NET may process personal data without prior authorization from the owner in all cases where such data is of a public nature. In other words, all data collected through public records or documents for public use will not require the owner’s authorization for processing. The foregoing in accordance with the provisions of Article 10 of Law 1581 of 2012.

1. With prior authorization

Apart from the data collected through the provision of services, AS-NET collects and processes other personal data different and necessary for the fulfillment of other functions proper to its nature and objectives.

PURPOSES OF THE PROCESSING OF PERSONAL DATA

The purposes for which the personal data of natural persons who have or have had some kind of relationship with AS-NET may be processed are listed below:

1. Execution of the contract signed with AS-NET, as client, supplier and/or collaborator.
2. Payment of contractual obligations.
3. Disclosure of information to governmental or judicial entities by express request of the

same.

1. Support in external/internal audit processes.
2. Sending/receiving messages for commercial, advertising and/or customer service purposes.

1. Registration of the information of candidates, clients, employees and/or suppliers in the Company’s databases.
2. Contact with candidates, clients, employees or suppliers to send information related to the contractual, commercial or obligatory relationship that takes place.
3. Fulfillment of the duties that AS-NET has as responsible for the information and personal data.
4. For security or fraud prevention purposes.
5. To provide you with effective customer service.
6. Any other purpose resulting from the development of the contract or the relationship between the owner of the data and AS-NET. And all those purposes that are specified prior to the time of data collection.

RIGHTS OF THE OWNERS

• Know, update and rectify your personal data*.
• To revoke the authorization granted for the processing of your personal data*.
• Request the deletion of your personal data*.
• Request proof of the authorization granted.
• Be informed about the use given to your data.
• File complaints before the Superintendence of Industry and Commerce (SIC) for violations to the provisions of the Personal Data Protection Law once the consultation or complaint process before AS-NET has been exhausted.
• Access free of charge to your personal data being processed.

TRANSFER OF PERSONAL DATA TO THIRD PARTIES
AS-NET may transfer your personal data to third parties with whom it has an operational relationship that provide services necessary for its proper functioning, or in accordance with the functions established by law. In such cases, we inform you that AS-NET will adopt the necessary measures so that the persons who have access to your personal data comply with the Personal Data Processing Policy_SIPO-04 adopted by AS-NET .

MODIFICATIONS TO THE PRIVACY NOTICE

You will be notified of any changes to this Notice by any of the following means: A written notice sent to your address or delivered to you at AS-NETa message sent to your e-mail address or to your cell phone; a message made known through the web page https://asnetla.com/en/ or any electronic means you use to enter into transactions with AS-NETor through advertisements published in the different communication channels.

INFORMATION SECURITY
AS-NET has adopted the technological, legal and procedural measures possible and necessary for the protection of your personal data, in order to guarantee the attributes of confidentiality, authenticity, integrity and availability of the information. For more information about the processing of your personal data, please contact us by e-mail at
sgsi@asnet-multisite.local/en.

Remember that AS-NET, has collected personal data from its customers that are necessary for the proper performance of its functions. For this reason, our customers should be aware that, in order to provide them with our services, their personal data are required and will be treated with the utmost care. Consequently, the request for suppression of personal data and the revocation of the authorization for the processing of personal data Authorization for the processing of personal data_SIF-04 shall not proceed when the Data Subject has a legal or contractual duty to remain in the database and/or files of AS-NETThe data subject’s personal data will not be used by the Company, nor while the relationship between the data subject and the Company, by virtue of which the data were collected, is still in force. When the request to update, rectify or delete personal data or revoke the processing authorization granted, the following form must be filled out and sent to the following address Request for the Exercise of the Rights of the Data Subject_SIF-48, format, which may be requested by sending an e-mail to sgsi@asnet-multisite.local/en.