Personal Data Management Policy

This policy reflects the type of information that PRONTTO S.A.S. and PRONTTO LLC (hereinafter the “Company”), collects, stores, uses, transmits, processes, and transfers, as well as the purposes of its treatment, and the general guidelines that will be applied to guarantee the adequate treatment of your personal information.

• Company Name: PRONTTO S.A.S.
• N.I.T.: 901.473.141-8
• Notifications Address: Barranquilla, Colombia. Cra 43 No 76B - 25 Suite 401
• Email: legal@prontto.co
• Website: https://www.prontto.co
• Telephone: 3017705458

Likewise, you can include in your profile your academic data, work experience and skills, your location, a photograph and, additionally, you can upload your resume in Word or PDF format in Spanish or English. We store information associated with the results of your psychotechnical tests, audios, records of use of our web portal and the duration of your activity on our portal.

As a Business User, in order to create an account on our Web Portal and use our services, you must provide us, in addition to the company's identification data, the contact information of the person who will act on behalf of the company. These data are: in summary, first and last name, email and a password.

As an Employee, to join as an employee of PRONTTO S.A.S., it is necessary that you provide us with your identification data, such as full name, type and number of identification document, contact information, such as cell phone number and/or landline, address. and/or residence address, email, contact person, relationship or relationship with the contact person, sex, date of birth, age, level of education, as well as all information related to academic levels, work experience, marital status , place of birth, nationality, number of children, information related to your military record, EPS, AFP, severance fund, compensation fund, ARL, blood type, bank and bank account number and type, shirt size, pants size and shoe size, and in general any additional information.

important to the employment relationship. If the information to be collected is of a sensitive nature, we will let you know in advance, announcing that it will not be mandatory to provide said information.

As a Contractor/supplier/client/lessor/whether a natural or legal person, we collect contact data, such as landline and/or mobile phone number, commercial or judicial notification address, address, email, type and number of registration document. identity, bank certification and in general all the data related to the respective certificate of existence and legal representation, commercial registration certificate and/or RUT and additionally any information related to the purpose of the contract.

As a Private User, we collect your personal data in order to provide you with a better service. To create an account, you must provide us with information such as your first and last name, email address, phone number, as well as a password.

Likewise, you can include in your profile your academic data, work experience and skills, your location, a photograph and, additionally, you can upload your resume in word O Pdf in Spanish or English. We store information associated with the results of your psychotechnical tests, audios, records of use of our web portal and the duration of your activity on our portal.

As a Business User, in order to create an account on our Web Portal and use our services, you must provide us, in addition to the company's identification data, the contact information of the person who will act on behalf of the company. These data are: in summary, first and last name, email and a password.

As an Employee, to join as an employee of PRONTTO S.A.S., it is necessary that you provide us with your identification data, such as full name, type and number of identification document, contact information, such as cell phone number and/or landline, address. and/or residence address, email, contact person, relationship or relationship with the contact person, sex, date of birth, age, level of education, as well as all information related to academic levels, work experience, marital status , place of birth, nationality, number of children, information related to your military record, EPS, AFP, severance fund, compensation fund, ARL, blood type, bank and bank account number and type, shirt size, pants size and shoe size, and in general any additional information important to the employment relationship. If the information to be collected is of a sensitive nature, we will let you know in advance, announcing that it will not be mandatory to provide said information.

As a Contractor/supplier/client/lessor/whether a natural or legal person, we collect contact data, such as landline and/or mobile phone number, commercial or judicial notification address, address, email, type and number of registration document. identity, bank certification and in general all the data related to the respective certificate of existence and legal representation, commercial registration certificate and/or RUT and additionally any information related to the purpose of the contract.

PRONTTO S.A.S. will inform the holders of the information regarding the treatment it will give to said information, and about the purposes thereof, in the respective Privacy Notices through which it disseminates the existence of these Personal Data Processing Policies.

In general, PRONTTO S.A.S. will give the following treatment to the data it collects:

• Private User and Business User: (i) Carry out the development of the company's corporate purpose. (ii) Develop commercial and promotional campaigns. (iii) Carry out satisfaction surveys. (iv) Store a database and keep a measurement for statistical purposes of the people who enter the company's website and apply for job offers. (v) Store a database and keep a measurement for statistical purposes of the people who enter the company's website and seek the provision or supply of services by PRONTTO S.A.S. (vi) To be contacted in order to celebrate possible commercial or labor relations, depending on the user. (vii) The others provided for in this privacy policy of PRONTTO S.A.S.
• Employees: (i) Broadcast, publish, transmit, disseminate, and promote the well-being activities developed by PRONTTO S.A.S., to the work community that comprises it, and through the different social networks that PRONTTO S.A.S. Use for advertising guidelines, as well as for radio or television advertisements. (ii) to keep contact information updated, (iii) verify the data of the owner of the information, (iv) for the construction and updating of work history, (v) to verify the effective care of licenses, disabilities and conditions to health by the insurance entities of the social security system in health and pensions.
• Contractor/supplier/lessor: (i) For the execution of the respective contract or purchase order; (ii) In order to carry out compliance with its tax and accounting obligations, (iii) Execute the due diligence requested by the Superintendency of Companies in Chapter X of its External Circular, (iv) for commercial, promotional, informative; (v) to process and respond to requests, complaints, complaints, suggestions and/or congratulations.
• Shareholders: We collect the data of the company's shareholders in order to have sufficient information to carry out calls for ordinary or extraordinary meetings of the General Assembly of Shareholders, for the reporting of exogenous information addressed to the Tax and National Customs DIAN, and to carry out the due diligence requested by the Superintendency of Companies in Chapter X of its External Circular.

PRONTTO S.A.S. will retain personal data for the duration of the contractual or commercial relationship with the respective person, or with the person it represents or with whom it relates, as well as for the time necessary to comply with the Company's legal obligations. In general terms, personal data collected by the Company will be kept for the term legally applicable to the type of personal data collected, and according to the database to which it belongs, namely:

• Employment Data (Employees): during the term of the contractual relationship, plus twenty (20) additional years.
• Commercial and Accounting Data (Business Users/Private Users/Landlords/Shareholders/Contractors/Suppliers): during the term of the civil or commercial relationship, and for ten (10) more years.

The Company will transfer the data of its Employees and Private Users to Business Users, in order to comply with the contractual obligations of PRONTTO S.A.S., which will be expressly accepted by the owners of the information in the respective Privacy Notices. The Company will cause the owners of the information to be informed regarding the treatment policies that the respective Business Users will apply to the transferred data.

As the owner of the personal data provided to the Company, you have the following rights:

1. Know, update and rectify your personal data before the Company. This right may be exercised, among others, against partial, inaccurate, incomplete, fragmented, misleading data, or those whose processing is expressly prohibited or has not been authorized;
2. Request proof of the authorization granted to the Company, except for data whose processing does not require authorization, under the terms of applicable legislation;
3. Be informed by the Company, upon request, regarding the use it has given to your personal data;
4. Submit complaints to the Superintendency of Industry and Commerce for violations of the provisions of these Data Processing Policies or the law;
5. 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. The revocation and/or deletion will proceed when the Superintendence of Industry and Commerce has determined that in the processing the Company has engaged in conduct contrary to the law or the Political Constitution;
6. Access free of charge to your personal data that has been processed, all of which will be provided through magnetic media.

If you are a minor, we ask you not to provide personal information or data, since PRONTTO S.A.S. does not collect or process personal information from minors under eighteen (18) years of age.

Unless we specifically request or invite you, we ask that you do not send us, and that you do not disclose, sensitive personal data. Where we may request or invite you to provide confidential or sensitive information, we will do so with your prior express consent. The owner has the right to choose not to provide any sensitive information requested by PRONTTO S.A.S., related, among others, to data on their racial or ethnic origin, membership in unions, social or human rights organizations, political, religious, sexual life, biometrics or health data, unless required for the exercise of legal functions or when there is an order from an administrative or judicial authority.

For security purposes and compliance with its obligations, PRONTTO S.A.S. will use various means of video surveillance installed in different internal and external locations of our facilities or offices. At the entrance to our facilities, the corresponding privacy notices will be posted, which establishes the purpose of processing the data collected by said means, and notes the sensitive nature of said information, as well as the voluntary nature of providing it.

To make queries or requests aimed at knowing, updating, rectifying, deleting the data or revoking the authorization granted, the owner or his successors may use any of the following communication channels:

Any request received by these means, outside the hours established for customer service, will be deemed received on the following business day.

To exercise the right of the owners in relation to their personal data, written communication must be sent in physical or electronic medium which must contain:

• Full names and surnames of the data owner or his representative or attorney-in-fact.
• Type and number of the applicant's identity document.
• The electronic or physical address where you will receive correspondence and the telephone number.
• The purpose of the request and the reasons on which you base your request.
• Photocopy of the identification document of the owner and his representative or attorney-in-fact, when applicable.
• Authenticated document that proves the representation of the owner, when applicable.
• The signature of the petitioner or representative, when applicable.

If the query or request is incomplete, PRONTTO S.A.S. will require the interested party within five (5) days following receipt to correct any deficiencies. After two (2) months from the date of the request, without the petitioner presenting the requested information, it will be understood that he or she has abandoned the respective query or request.

Once the complete query or request is received, the Company will include, in the respective database, a legend that says “application in process” and the reason for it, within a period of no more than two (2) business days from its date. complete reception. This legend will remain until the request is decided.

Queries will be answered within a maximum period of ten (10) business days, counting from the day following the date of receipt. When it is not possible to attend to the query within said term, the interested party will be informed, expressing the reasons for the delay and indicating the date on which their query will be attended to, which in no case may exceed five (5) business days following the expiration of the first term.

The owners or their successors who consider that the information contained in a database of PRONTTO S.A.S. must be corrected, updated or deleted, or who notice the alleged breach of any of the duties contained in Law 1581 of 2012, may submit a request or claim to PRONTTO S.A.S., in accordance with the mechanisms provided in this Data Treatment Policy. Data.

The maximum term to address the claim will be fifteen (15) business days counted from the day following the date of receipt. When it is not possible to address the claim within said term, the interested party will be informed of the reasons for the delay and the date on which their claim will be addressed, which in no case may exceed eight (8) business days following the expiration of the first term.

As long as the Superintendency of Industry and Commerce has determined that in the treatment, the Company has engaged in conduct contrary to this Policy, the law and/or the Political Constitution; The owner of personal data will have the right to request PRONTTO S.A.S. the deletion of your personal data, or to revoke the authorization for its processing; not without losing sight of the fact that the right of deletion or revocation is not an absolute right, and the Company, as responsible for the processing of personal data, may deny or limit its exercise when:

• The data owner has a legal or contractual duty to remain in the respective database.
• The deletion of data hinders judicial or administrative actions linked to tax obligations, the investigation and prosecution of crimes or the updating of administrative sanctions.
• The data is necessary to protect the legally protected interests of the owner; to carry out an action based on the public interest, or to comply with an obligation legally acquired by the owner.

Notwithstanding the above, it will be guaranteed that the data is used exclusively for the requested purpose, and the corresponding reservation is given to the information.

This Policy takes effect from its issuance. This Policy may be modified at any time, and its modifications will be made in accordance with current regulations. The Company will inform the holders of the information that a modification will be made to this Policy, in the event that said modification implies substantial changes to it, publishing the proposed modification text on the following web page: https://www.prontto.co for a period of ten (10) business days, prior to starting your application.

January 26, 2024