In order to comply with Law 1581 of 2012, its regulatory decrees, and any subsequent regulations that modify or complement them, the company PUPPIES PET GROUP SAS, identified with NIT. 901458470-3, with address at Carrera 4 # 10-44 office 804 of the city of Cali, whose telephone number is 3008458733, and whose contact email is puppies_pet@outlook.com adopts the following personal data processing policy (in forward The Policy).

1. DEFINITIONS: For the implementation of the Policy, the following definitions will be taken into account: Authorization: Prior, express and informed consent of the owner to carry out the data processing personal. Privacy notice: Verbal or written communication generated by the person in charge, addressed to the owner for the treatment of their personal data, through which they are informed about the existence of the information treatment policies that will be applicable, the way to access to them and the purposes of the treatment that is intended to give personal data. Database: Organized set of personal data that is subject to treatment. Successor in title: Person who has succeeded another due to the latter’s death. (Inheritor). Company or Enterprise: Refers to the company PUPPIES PET GROUP SAS.

Personal data: Any information linked to or that may be associated with one or more specific or determinable natural persons.

< p>Public data: It is the data that is not semi-private, private or sensitive. Public data is considered, among others, data related to the marital status of people, their profession or trade and their quality as a merchant or public servant. Due to its nature, public data may be contained, among others, in public records, public documents, official gazettes and bulletins and duly executed judicial decisions that are not subject to reservation.

Sensitive data: It is understood by sensitive data those that affect the privacy of the owner or whose improper use may generate discrimination, such as revealing racial or ethnic origin, political orientation, religious or philosophical convictions, membership in trade unions, social organizations, human rights or that promotes the interests of any political party or that guarantees the rights and guarantees of opposition political parties, as well as data related to health, sexual life, and biometric data.

Responsible for the treatment: natural or legal person, public or private, that by itself or in association with others, performs the processing of personal data on behalf of the person responsible for the treatment.

Responsible for the treatment: Natural or legal person, public or private, that by itself or in association with others, decides on the database and/or the treatment of the data.

Owner: Natural person whose personal data is processed.

Treatment: Any operation or set of operations on personal data, such as the collection, storage, use, circulation or deletion. Transfer: The transfer of data takes place when the person in charge and/or in charge of the treatment of personal data, located in Colombia or abroad, sends the information or personal data to a receiver, who in turn is responsible for the treatment and is outside the country. Transmission: Treatment of personal data that implies the communication of the same within or outside the territory of the Republic of Colombia when its purpose is to carry out a treatment by the person in charge on behalf of the person in charge

2. PURPOSE OF THE POLICY: Establish the criteria for the collection, storage, use, circulation and deletion of personal data processed by PUPPIES PET GROUP SAS.
3. SCOPE: The Policy applies to all information personnel registered in the databases of PUPPIES PET GROUP SAS., who acts as the person responsible for the processing of personal data.
4. OBLIGATIONS: The Policy is mandatory and strict compliance for PUPPIES PET GROUP SAS and all its employees.
5. RESPONSIBLE FOR THE TREATMENT: PUPPIES PET GROUP SAS, a legally constituted commercial company, identified with the NIT. 901458470-3, with main address at Carrera 4 3 10-44, office 804 in the city of Cali, Republic of Colombia, whose telephone number is 3008458733, and whose contact email is puppies_pet@outlook.com
6. TREATMENT AND PURPOSE: PUPPIES PET GROUP SAS will carry out the storage, use, processing, circulation, and in general the treatment of personal information for the following purposes:

6.1. Regarding customer and consumer data:

• Provide services and/or products required by our customers and/or advertised to them. ● Inform about new products or services that are related or not, with the one contracted or acquired by the Holder. ● Comply with obligations contracted with the Holder. ● Carry out the pertinent steps for the development of the corporate purpose of the company in what has to do with the fulfillment of the object of the contract entered into with the Owner of the information. ● Inform about changes in products or services. ● Evaluate the quality of products or services. ● Develop advertising, marketing or promotional activities. ● Carry out internal studies on compliance with commercial relations and market studies at all levels. ● Allow the participation of data subjects in loyalty programs with benefits, marketing and promotional activities (sweepstakes). ● Contact the holder by telephone (through calls and/or text messages such as SMS and/or MMS), physical or electronic mail, or digital media (such as instant messaging applications and social networks, such as Facebook, Instagram and WhatsApp, etc.) to: (i) send commercial, advertising or promotional information about the products and/or services, events and/or promotions of a commercial or non-commercial nature, in order to promote, invite, direct, execute, inform and in general, carry out campaigns, promotions or contests of a commercial or advertising nature; (ii) carry out satisfaction surveys; (iii) send information about the products or services required and their status; and (iv) in general for all the purposes established in these policies. ● Provide contact information to the commercial force and/or distribution network, telemarketing, market research and any third party with which PUPPIES PET GROUP SAS has a contractual relationship for the development of such activities (market research and telemarketing, etc.) for the execution of the same. ● Transfer and/or transmit the personal data collected with third parties that have the quality of commercial and/or business allies so that they can offer products and/or services that allow improving the value offer destined to the clients of PUPPIES PET GROUP SAS, in accordance with the purposes established in this policy. ● Send information from electronic means of payment to digital payment platforms to process payments and purchases. ● Facilitate identification and provide a complete service experience, for example, by using cookies. ● Perform accounting, tax and administrative management of clients. ● Verify business background and reputation of customers. ● Manage communication activities and customer loyalty, as well as the timely attention of all requests, complaints, claims and suggestions (PQRS). ● Respond to legal requirements of administrative and judicial entities. ● Consult cardholder information in risk centers. ● Consult or receive information, via transmission or transfer contracts, that is contained in third-party databases to complete or update the personal data of the owners.

6.2. Regarding the data of providers of goods and services:

• Obtain services and goods. ● Carry out the accounting, fiscal and administrative management of suppliers. ● Verify business history, reputation and possible financial risks, and relationships associated with money laundering and financing of terrorism. ● Formalize the contractual relationship with the supplier. ● In general, all those necessary for the materialization and management of the contractual relationship of the company with the owner and future contractual relationships.

6.3. Regarding the data associated with the administration of human talent:

• In the framework of calls to participate in positions or positions, such as: evaluating the job profile of the applicants, verifying the applicant’s background and environment , and manage affiliation or report of news associated with the general social security system and other mandatory records related to social benefits. ● Perform management of human resources and collaborators, such as, but not limited to: registration in computer systems, management of time control and spatial location in working hours, staff training, settlement management and payroll payment, management of personnel, management of temporary work, social benefits, prevention of occupational risks, promotion and management of employment, promotion and selection of personnel, and promotion of the development of activities of well-being and integral development of the worker and his work and family environment. ● Offer benefits and extralegal assistance to employees and their families. ● Manage everything related to agreements, commitments and obligations derived from unions, pacts or collective bargaining. ● Manage the procedures for dismissal or retirement from work, as well as the fulfillment of the corresponding financial obligations. ● All other steps required to comply with the obligations, rights and guarantees in favor of employees that are provided by law, collective agreement, collective agreement and respective employment contracts. ● Occupational health, sanitation and health management, including, but not limited to: Sanitary control in the company’s facilities, entrance and exit examinations of employees, and other examinations established by the norms, internal labor regulations, pacts or collective labor agreements. ● Inform third parties about the performance of job functions. ● Carry out access controls and identity verification in the company’s offices. ● Guarantee security through the video surveillance system. ● In general, all those necessary for the materialization and management of the contractual relationship between the company and the owner and future contractual relationships.

6.4. Regarding data related to security and corporate ethics (including sensitive data such as biometric data):

• Manage the security of the facilities, company perimeter and protect the integrity of people. ● Perform access control to buildings. ● Verify, control and monitor the development of processes, activities and products in accordance with corporate guidelines and objectives and based on quality control and assurance. ● Manage the development of jurisdictional, disciplinary, administrative or extra-procedural actions or actions.

Paragraph. The treatment that PUPPIES PET GROUP SAS will carry out with the personal information will consist of the collection, storage, use, and circulation of the data for the purposes listed above. In addition, you may transmit said data to third parties in Colombia or abroad so that they process it on behalf of PUPPIES PET GROUP SAS for the development of the purposes stated above. You may also send the data to parent, subsidiary, or related companies of PUPPIES PET GROUP SAS, in Colombia and abroad, or with commercial allies so that they process the information for the same purposes for which it was collected.

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DATA AND RIGHTS OF CHILDREN AND ADOLESCENTS : In accordance with the personal data protection regulations, the personal information of children and adolescents is subject to special protection by PUPPIES PET GROUP SAS. This information may be processed in the development of social, promotional and promotional activities. Benefits to employees’ children. The authorization of the treatment must be previously granted by the legal representative of the minor, after the minor exercises his right to be heard according to the reasonable determination of his level of maturity, autonomy and capacity to understand the matter.

The processing of this special type of data is subject to compliance with the conditions set by the personal data protection regulations, such as the following:

(i) Ensuring that the processing respects the superior interest, prevailing rights and fundamental rights of children and adolescents. (ii) Deal exclusively with data that is of a public nature or if private or semi-private data is processed, it is done in the terms of judgment C-748 of 2011 of the Constitutional Court. (iii) Inform the minor and his legal representative about the terms and conditions of the respective activity.

For authorization purposes, the legal representative of the child or adolescent may give it, guaranteeing that to the extent As far as possible, the minor will be heard and his opinion will be valued taking into account his maturity, autonomy and ability to understand the matter.

9. DATA AND RIGHTS OF HOLDERS REGARDING THE PROCESSING OF SENSITIVE DATA: Sensitive data will be collected and processed for the purposes listed in this policy. PUPPIES PET GROUP SAS is committed to protecting privacy during the processing of your personally identifiable and sensitive data. When the holders of the information expressly authorize the use of sensitive data, PUPPIES PET GROUP SAS. will use these with special care and in accordance with the rules established in the data protection legislation and its regulatory decrees.

In the event of sensitive data collection, we will always proceed guaranteeing the except for the following actions:

(i) Inform the Holder that, since it is sensitive data, he is not obliged to authorize its treatment. (ii) Inform the Holder explicitly and in advance, in addition to the general requirements of the authorization for the collection of any type of personal data, which of the data that will be subject to Treatment are sensitive and the purpose of the Treatment, as well as obtaining your express consent. (iii) No activity may be conditioned on the Holder providing sensitive personal data.

10. RIGHTS OF THE HOLDERS: As the holder of your personal data, you have the right to:

(i) Free access to the data provided that have been processed. (ii) Know, update and rectify your information against partial, inaccurate, incomplete, fragmented, misleading data, or those whose treatment is prohibited or has not been authorized. (iii) Request proof of the authorization granted. (iv) Submit to the Superintendency of Industry and Commerce (SIC) complaints for violations of the provisions of current regulations. (v) Revoke the authorization and/or request the deletion of the data, provided that there is no legal or contractual duty that prevents their deletion. (vi) Refrain from answering questions about sensitive data. The answers that deal with sensitive data or data of children and adolescents will be optional.

11. REQUESTS, INQUIRIES AND CLAIMS ATTENTION: The PUPPIES PET GROUP SAS Customer Service Area is the unit in charge of processing the requests of the owners to make their rights effective.
12. Queries: The holders or their assignees may consult the personal information of the holder that rests in the databases of PUPPIES PET GROUP SAS., who agrees to provide all the information contained in the individual record or that is linked to the identification of the holder. and therefore guarantees:

(i) Enable electronic means of communication or others that it considers pertinent. (ii) Establish forms, systems and other simplified methods. (iii) Use the customer service or claims services that you have in operation. (iv) In any case, regardless of the mechanism implemented to address query requests, they will be addressed within a maximum term of ten (10) business days from the date of receipt. When it is not possible to attend the query within said term, the interested party will be informed before the expiration of 10 days, stating the reasons for the delay and indicating the date on which his query will be attended, which in no case may exceed five (5) business days following the expiration of the first installment. (v) Requests, inquiries may be made to the email puppies_pet@outlook.com or to the telephone number 3008458733.

1. Claim: The owner or his successors in title who consider that the information contained in a database should be corrected, updated or deleted, or when they notice the alleged breach of any of the duties contained in the law or in this treatment policy, may submit a claim to the customer service area and/or to the email address puppies_pet@outlook.com, which will be processed under the following rules:

(i) The owner’s claim is formulated by request addressed to the Customer Service Area, via email puppies_pet@outlook.com, or by phone 3008458733 addressed to the Customer Service Area, with the identification of the holder, the description of the facts that give rise to the claim, the address and accompanying the documents that you want to assert. If the claim is incomplete, the interested party will be required within five (5) days after receipt of the claim to correct the faults. After two (2) months from the date of the request, without the applicant submitting the required information, it will be understood that the claim has been withdrawn. (ii) In the event that the person receiving the claim is not competent to resolve it, it will be forwarded to the appropriate person within a maximum term of two (2) business days and the interested party will be informed of the situation. (iii) Once the complete claim is received, it will be cataloged with a label «claim in process» and the reason for it, within a term not exceeding two (2) business days. Said label will remain until the claim is decided. (iv) 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 deal with 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 dealt with, which in no case may exceed eight (8) business days