PERSONAL DATA PROCESSING POLICY

considerations
In compliance with the provisions of Statutory Law 1581 of 2012 and its Regulatory Decree 1377 of 2013, Juice Holding SAS adopts this policy for the processing of personal data, which will be informed to all owners of the data collected or that in the future will be obtained in the exercise of the commercial or labor activities carried out by the company.

Juice Holding SAS as the entity responsible and/or in charge of processing personal data, generated the following policy for the processing of personal data of its clients and users that guarantees the rights of privacy, intimacy, and good name, in the processing of personal data, consequently, all its actions will be governed by the principles:

Principle of Legality : Data processing is a regulated activity that must be subject to what is established in the law and other provisions that develop it.

Purpose Principle : the processing must obey a legitimate purpose in accordance with the Constitution and the Law, which must be informed to the owner. Regarding the collection of personal data, Juice Holding SAS will limit itself to those data that are pertinent and adequate for the purpose for which they were collected or requested.

Principle of Liberty : processing may only be carried out with the prior, express, and informed consent of the owner. Personal data may not be obtained or disclosed without prior authorization, or in the absence of a legal or judicial mandate that waives consent.

Quality Principle : the information subject to processing must be true, complete, accurate, up-to-date, verifiable and understandable. The processing of partial, incomplete, fractional or misleading data is prohibited.

Transparency Principle : In the treatment, the right of the owner to obtain from the person responsible for the treatment or from the person in charge of the treatment, at any time and without restrictions, information about the existence of data that concerns him/her must be guaranteed.

Principle of Restricted Access and Circulation : processing is subject to the limits arising from the nature of the personal data, the provisions of the law and the Constitution. In this regard, processing may only be carried out by persons authorized by the owner and/or by persons provided for by law. Personal data, except for public information, may not be made available on the Internet or other means of dissemination or mass communication, unless access is technically controllable to provide restricted knowledge only to the owners or authorized third parties in accordance with the law.

Security Principle : the information subject to processing must be handled with the technical, human and administrative measures necessary to ensure the security of the records, avoiding their adulteration, loss, consultation, use or unauthorized or fraudulent access.

Confidentiality Principle : Juice Holding SAS is obliged to guarantee the confidentiality of the information, even after its relationship with any of the tasks that comprise the treatment has ended, and may only provide or communicate personal data when this corresponds to the development of the activities authorized by law.

Treatment and Purposes
The Personal Data processed by Juice Holding SAS must be strictly and solely subject to the purposes indicated below. Likewise, the Managers or third parties who have access to the Personal Data by virtue of Law or contract, will maintain the Processing within the following purposes:

Manage all the information necessary for compliance with the tax obligations and commercial, corporate and accounting records of Juice Holding SAS
Comply with the internal processes of Juice Holding SAS regarding the administration of suppliers, contractors and employees.
Comply with service contracts entered into with clients.
Provide services in accordance with the particular needs of Juice Holding SAS clients, in order to comply with the service contracts entered into, including, but not limited to, the verification of affiliations and rights of individuals to whom Juice Holding SAS clients will provide their services.
Other purposes determined by those responsible for the processes of obtaining Personal Data for Processing and which are communicated to the Owners at the time of collecting the personal data.
The process of archiving, updating systems, protecting and safeguarding information and databases of Juice Holding SAS
Processes within the company, for development or operational purposes and/or system administration.
The transmission of data to third parties with whom contracts have been entered into for this purpose, for commercial, administrative, marketing and/or operational purposes.
Maintain and process by computer or other means, any type of information related to the client’s business in order to provide the relevant services and products.
Other purposes determined by those responsible for the processes of obtaining Personal Data for Processing, in order to comply with legal and regulatory obligations, as well as the Firm’s policies.
Carry out the relevant procedures for the development of the pre-contractual, contractual and post-contractual stages of any of the products and services offered, as well as comply with Colombian or foreign law and the orders of judicial or administrative authorities.
Manage procedures (requests, complaints, claims), perform risk analysis, conduct satisfaction surveys regarding the company’s goods and services.
Provide contact information and relevant documents to the sales force and/or distribution network, telemarketing, market research and any third party with which the company has a contractual relationship of any kind.
To disclose, transfer and/or transmit personal data within and outside the country, to third parties as a result of a contract, law or lawful link that requires it or to implement services offered by Juice Holding SAS
Carry out, through any means directly or through third parties, programming and provision of technical service, sales, purchases, billing, portfolio management, product performance monitoring, collection, business intelligence, marketing, promotion or advertising activities, service improvement, collection monitoring, verification, consultation and control, enabling payment methods as well as any other related to our current and future products and services, for the fulfillment of contractual obligations and the corporate purpose of the company.
For the sending and receiving of elements or advertising material according to the requirements of the required functions and sustainability of the company’s business.
Control and prevent fraud in any of its forms.
Data Controller and Data Processor.
The person responsible for the processing of personal data and other information of the Holders is Juice Holding SAS, with address and domicile at Cr 4 7-17 130001 Cartagena de Indias Bolívar Colombia; email: info@kingsconsulting.co

Rights of Data Subjects.
Pursuant to current legislation, the holders of the information have the right to know, update, rectify their information, and/or revoke the authorization for its processing. In particular, in accordance with article 8 of Law 1581 of 2012, the following are the rights of the Holders:

Know, update and rectify your personal data.
Request proof of the authorization granted.
Be informed, upon request, regarding the use that has been given to your personal data.
Submit complaints to the Superintendency of Industry and Commerce for violations of the provisions of the law.
Revoke authorization and/or request deletion of data.
Access free of charge to your personal data that has been subject to processing.
Procedures for exercising the rights of Personal Data Holders.
Procedure for exercising your rights. If you wish to exercise your rights, the Data Controller must send an email or physical mail to the contact addresses established in this Processing Policy. The procedure to be followed for such communications will be as indicated below:

1. Requests and Queries Regarding Personal Data.

When the data owner or his/her successors wish to consult the information stored in the Juice Holding SAS database, the request will be answered within a maximum period of ten (10) business days in compliance with the provisions of Law 1581 of 2012. When it is not possible to respond to the query within this period, the Owner will be informed, the reasons for the delay will be expressed and the date on which his/her query will be answered will be indicated, which may not exceed five (5) business days following the expiration of the first period.

2. Revocation of authorization, withdrawal or deletion from the Database and claims regarding Personal Data.

When the data owner or his/her successors consider that the information contained in the databases should be corrected, updated or deleted, or when they notice the alleged non-compliance of any of the duties contained in Law 1581 of 2012, they may file a claim with Juice Holding SAS, which will be processed under the following rules:
1. The claim will be made through a request addressed to Juice Holding SAS, with the identification of the Owners, the description of the facts that give rise to the claim, the address, and the documents that they wish to assert will be attached. If the claim is incomplete, Juice Holding SAS may require the interested party within five (5) days following receipt of the claim to correct the deficiencies. After two (2) months from the date of the request, without the applicant submitting the required information, it will be understood that he/she has withdrawn the claim. In the event that Juice Holding SAS is not competent to resolve the claim, it will forward it to the appropriate party within a maximum period of two (2) business days and will inform the Owner of the situation, thereby relieving it of any claim or responsibility for the use, rectification or deletion of the data.
2. Once the complete claim has been received, when it cannot be resolved expeditiously and as long as it is technically possible, a legend stating “claim in process” and the reason for it will be included in the database, within a period of no more than two (2) business days. This legend must be maintained until the claim is decided.
3. The maximum period for addressing the claim will be fifteen (15) business days counted from the day following the date of its receipt. When it is not possible to address the claim within this period, the Holder will be informed of the reasons for the delay and the date on which his claim will be addressed, which in no case may exceed eight (8) business days following the expiration of the first term. The withdrawal or deletion will not proceed when there is a contractual or legal obligation to remain in the Juice Holding SAS database, such as, for example, for the fulfillment of accounting, tax, commercial or legal duties.

Validity
This Policy is effective as of August 1, 2024. Personal Data that is stored, used or transmitted will remain in our Database, based on the criteria of temporality and necessity, for as long as necessary for the purposes mentioned in this Policy, for which it was collected.