YOUR SAFETY IS OUR TOP PRIORITY 

In Gen3sis S.A.S we give special attention to the protection of your Personal Data, so below we would like to inform our Customers, Users and Visitors, those relevant issues on the Processing of Personal Data that we perform, in accordance with the provisions of Law No. 1581 of 2012, Decree No. 1377 of 2013, Chapter XXV of Decree No. 1074 of 2015 and Law No. 1266 of 2008, as applicable, as well as other laws in force. 1581 of 2012, Decree No. 1377 of 2013, Chapter XXV of Decree No. 1074 of 2015 and Law No. 1266 of 2008, as applicable, as well as other laws in force regarding the protection of Personal Data or those that replace, modify or complement them.

In this PRIVACY POLICY AND TREATMENT OF PERSONAL DATA (hereinafter, the “Policy”) we include information of interest such as: the type of data we collect and treat; the purposes of the Treatment, your rights as Holder of the personal data; the mechanisms you have to assert your rights as holder; among other topics. This policy is addressed to Users, Customers, Visitors, Employees and third parties whose data are processed by Gen3sis S.A.S, which is specified in the annexes of this Policy.

We ask you to read this Policy carefully before accepting the processing of your data and/or making use of our services.

1. YOUR PERSONAL DATA.

To access the information and/or services of Gen3sis S.A.S.’s interaction spaces, and to be able to interact in them, you must voluntarily and freely provide your true, non-sensitive personal identification data, such as: name, surnames, identification, age, gender, telephone, physical and electronic address, country, city and other necessary data that are requested in the registration process and/or in the contact channels or tools.

INFORMATION SECURITY.

Gen3sis S.A.S strives to protect its users as well as ourselves from unauthorized access or any unauthorized modification, disclosure or destruction of the information we possess.

Data transmission over the Internet or any wireless network cannot be guaranteed to be 100% secure. As a result, while we try to protect your personal information, we cannot ensure or guarantee the total and effective security of any information you transmit to Gen3sis S.A.S, so you do so at your own risk.

In the quest to achieve the highest possible security, we:

Encrypt all our services using the SSL security protocol.
We have multiple controls over our information systems that allow us to maintain greater security of your information.

We supervise and implement the most modern practices and protocols in the collection, storage and processing of information, including our physical security measures, to protect ourselves against unauthorized access to systems.

We restrict access to the personal information we hold about our customers and/or users to employees and contractors who need to know such information to process it for us, and who are subject to strict contractual confidentiality obligations and may be sanctioned or dismissed if they fail to comply with these obligations.

STORAGE OF YOUR PERSONAL DATA.

3.1. The personal data of all our customers and/or users will be stored in a database that is behind a firewall for greater security. The server where the database resides is physically protected in a secure location. Only authorized personnel can access it and therefore the personal data of our customers and/or users.

RECEIPT OF YOUR INFORMATION / USE OF YOUR INFORMATION.

4.1. The private information of users and/or customers is in principle intended for the provision of the service for which they are linked.

4.2. When you register to be able to participate and/or use any of the different interaction spaces of Gen3sis S.A.S, you may be asked for basic information such as name, surname, occupation, age, address, date of birth, telephone number, among others, in the process.

4.3. When you send a request for consultation, assistance and/or claim, we may ask you for personal information.

4.4. We may ask you for personal information at other times, you are free to provide it or not.

4.5. We may automatically receive and record information in our server logs from your browser, including your IP address, your computer name, the type and version of your web browser, referral addresses among others. We may also record the visits you make to our website or the use you make of the applications we use and to which you enter and which are owned by Gen3sis S.A.S

4.6. In general, we will not disclose your personal information to unaffiliated third parties without your express consent.

4.7. There may be circumstances in which we may have to disclose personal information about a user and/or customer. These reasons are: The employment of other companies to perform functions on our behalf, such as fulfilling orders, providing customer service, sending email and correspondence, processing credit card payments, or other functions necessary for our business activity.

4.8. The obligations included in these practices regarding the care or handling that Gen3sis S.A.S must give to the personal information of its customers and/or users do not apply when the information is required by a public or administrative entity in the exercise of its legal functions or by court order.

4.9. The Information provided by customers, visitors and/or Users may be used by Gen3sis S.A.S in accordance with what is established in these practices and in order to:

(i) Provide information, services and products required

(ii) Inform about new products or services that are related or not to the one contracted or acquired by the customer

(iii) Comply with obligations contracted with our customers

(iv) Inform about changes in our products or services

(v) Evaluate the quality of care and service

(vi) Conduct internal studies on consumption habits

(vii) Send to physical mail, electronic mail, cell phone or mobile device, – via text messages (SMS and/or MMS) commercial, advertising or promotional information about products and/or services, events and/or promotions of commercial or non-commercial type of these, in order to promote, invite, direct, execute, inform and in general, carry out campaigns, promotions or contests of a commercial or advertising nature.

(viii) Share, including the transfer and transmission of your personal data to third countries for purposes related to the operation.

4.11. In the event of a sale of the majority of the company’s assets, customer and/or user information may be transferred to the buyer as part of the business establishment.

COOKIES.

Gen3sis S.A.S and its website https://gen3sis.co use cookies to personalize and facilitate the USER’s navigation through its website as much as possible. Cookies are associated only with an anonymous USER and his/her computer and do not provide references that allow deducing personal data of the USER.

The USER may configure his/her browser to notify and reject the installation of cookies sent by Gen3sis S.A.S, without this affecting the possibility of the USER to access the information and contents.

LINKS

In the event that links, links or hyperlinks to other Internet sites are arranged on the website, Gen3sis S.A.S will not exercise any type of control over such sites and contents. In no case will Gen3sis S.A.S assume any responsibility for the contents of any link belonging to a third party website, nor will it guarantee the technical availability, quality, reliability, accuracy, breadth, truthfulness, validity and constitutionality of any material or information contained in any of such links, links or hyperlinks or other Internet sites. Likewise, the inclusion of these external connections will not imply any type of association, merger or participation with the connected entities.

KNOWLEDGE, UPDATE AND RECTIFICATION OF PERSONAL INFORMATION OF USERS.

At any time, customers and/or users may request Gen3sis S.A.S as responsible for personal data, to provide information about them, update them, rectify them, as well as include new data if desired, delete them or exclude them from the database unless the data is absolutely necessary for the provision of the service to which the customer and/or user is registered and/or subscribed and wants to remain in it, otherwise, it will be totally disassociated and/or deactivated from it.

If the user and/or customer wishes to exercise their rights and therefore update, rectify, delete among others, they must send an email to: juan.gomez@gen3sis.net

RIGHTS OF CUSTOMERS AND/OR USERS (1581 OF 2012, ARTICLE 8).

To know, update and rectify their personal data before those Responsible for the Treatment or Processors of the Treatment. This right may be exercised, among others, against partial, inaccurate, incomplete, fractioned data that induce to error, or those whose Treatment is expressly prohibited or has not been authorized.

Request proof of the authorization granted to the Person Responsible for the Treatment except when expressly excepted as a requirement for the Treatment, in accordance with the provisions of Article 10 of this law.

To be informed by the Person Responsible for the Treatment or the Person in Charge of the Treatment, upon request, regarding the use that has been given to their personal data.
To file complaints before the Superintendence of Industry and Commerce for infractions to the provisions of this law and the other norms that modify it, add to it or complement it.
Revoke the authorization and/or request the deletion of the data when the Treatment does not respect the principles, rights and constitutional and legal guarantees. The revocation and/or deletion shall proceed when the Superintendence of Industry and Commerce has determined that in the Treatment the Responsible or in Charge has incurred in conducts contrary to this law and to the Constitution.
Access free of charge to their personal data that have been subject to Treatment.

VALIDITY.

The client and/or User accepts and acknowledges that this authorization will be in force from the moment it was accepted and during the time that Gen3sis S.A.S Exercises the activities proper to its corporate purpose.

CUSTOMER SERVICE.

For inquiries, claims, complaints or for the exercise of the rights of the user or customer, you may contact Gen3sis S.A.S at juan.gomez@gen3sis.net or call 350 6199798 during office hours.

Once the User and/or Customer submits a request of those mentioned above, Gen3sis S.A.S will have up to ten (10) business days. In any case, Gen3sis S.A.S may be subject to the terms established by law.

RESPONSIBLE FOR THE TREATMENT OF MY DATA

Juan Gómez

Colombia

E-mail: juan.gomez@gen3sis.net

Phone: 350 6199798

Gen3sis S.A.S may unilaterally change its privacy policy and use of personal data. We will not limit your rights derived from this Privacy Policy and use of personal data without your express consent. We will publish any modification of this Privacy Policy and use of personal data on this page. In addition, we will keep previous versions of this Privacy Policy and use of personal data.

Our Services and Products are not directed to children and adolescents, so they are requested to refrain from proceeding with the registration and/or service in case you are a person under eighteen (18) years of age.

HOW TO ACCESS, RECTIFY AND UPDATE YOUR PERSONAL DATA OR REQUEST THE SUPPRESSION OF THE SAME?

You have the right to access your personal data and the details of its treatment, as well as to rectify and update it in case it is inaccurate or to request its deletion when you consider that it is excessive or unnecessary for the purposes that justified its obtaining or to oppose the treatment of the same for specific purposes.

To exercise this right, you must take into account the following:

The department in charge of matters related to data protection is the Commercial Management of Gen3sis S.A.S, which is located at Cr 20 N° 76-60 Bogotá, Colombia.

The e-mail address: juan.gomez@gen3sis.net

For more information, please call 350 6199798 or visit our website https://www.gen3sis.net

POLICIES AND PROCEDURES ON PERSONAL DATA PROTECTION

CHAPTER I

GENERAL PROVISIONS

ARTICLE 1. APPLICABLE LEGISLATION.

These policies were elaborated taking into account the provisions contained in articles 15 and 20 of the Political Constitution, Law 1581 of 2012 “By which general provisions for the protection of personal data are dictated”.

ARTICLE 2. SCOPE OF APPLICATION.

These policies apply to the processing of personal data collected and handled by Gen3sis S.A.S

ARTICLE 3. DATABASES.

The policies and procedures contained in this manual apply to the databases of each existing and future business unit, which may consist of, but not necessarily limited to, the following: Customer Service, Billing, Collections, Accounting, Marketing, Subscriptions, Advertising, Electronic Media whose period of validity is the same as the duration of the company Gen3sis S.A.S registered with the Chamber of Commerce of Bogotá.

ARTICLE 4. PURPOSE.

This manual complies with the provisions of literal k) of Article 17 of Law 1581 of 2012, which regulates the duties that assist those responsible for the processing of personal data, including that of adopting an internal manual of policies and procedures to ensure adequate compliance with the law and in particular, for the attention of inquiries and complaints.

It also has the purpose of regulating the procedures for collection, management and processing of personal data carried out by Gen3sis S.A.S, in order to guarantee and protect the fundamental right of habeas data within the framework of the provisions of the same law.

ARTICLE 5. PRINCIPLES.

The principles established below constitute the general parameters that will be respected by Gen3sis S.A.S in the processes of collection, use and processing of personal data.

Principle of purpose: The Processing of personal data collected by Gen3sis S.A.S must obey a legitimate purpose of which the Holder must be informed.

Principle of freedom: The Processing can only be carried out with the prior, express and informed consent of the Holder. Personal data may not be obtained or disclosed without prior authorization, or in the absence of legal or judicial mandate that relieves consent.

Principle of veracity or quality: The information subject to Treatment must be truthful, complete, exact, updated, verifiable and understandable. The Treatment of partial, incomplete, fractioned or misleading data is prohibited.

Principle of transparency: In the Treatment, the right of the Holder to obtain from Gen3sis S.A.S at any time and without restrictions, information about the existence of data concerning him/her must be guaranteed.

Principle of restricted access and circulation: Personal data, except public information, may not be available on the Internet or other means of mass disclosure or communication, unless access is technically controllable to provide restricted knowledge only to the Holders or authorized third parties.

Security principle: The information subject to Treatment by Gen3sis S.A.S, shall be protected by means of the use of technical, human and administrative measures that are necessary to grant security to the records avoiding their adulteration, loss, consultation, use or unauthorized or fraudulent access.

Principle of confidentiality: All persons involved in the Processing of personal data are obliged to guarantee the confidentiality of the information, even after the end of their relationship with any of the tasks that comprise the Processing.

CHAPTER II

AUTHORIZATION

ARTICLE 6. AUTHORIZATION.

The collection, storage, use, circulation or deletion of personal data by Gen3sis S.A.S requires the free, prior, express and informed consent of the owner thereof. Juan Gómez, in his capacity as responsible for the processing of personal data, has arranged the necessary mechanisms to obtain the authorization of the holders, guaranteeing in any case that it is possible to verify the granting of such authorization.

ARTICLE 7. FORM AND MECHANISMS TO GRANT THE AUTHORIZATION.

The authorization may be recorded in a physical document, electronic or any other format that allows guaranteeing its subsequent consultation. The authorization will be issued by Gen3sis S.A.S and will be made available to the holder prior to the processing of his/her personal data, in accordance with the provisions of Law 1581 of 2102.

The consented authorization procedure guarantees that the holder of the personal data has been informed of both the fact that his/her personal information will be collected and used for specific and known purposes, and that he/she has the option to know any alteration to the same and the specific use that has been given to them. The above in order for the holder to make informed decisions regarding his/her personal data and control the use of his/her personal information. The authorization is a declaration that informs the holder of the personal data:

Who collects it (responsible or in charge)
What is collected (data collected)
For what purpose the data is collected (purposes of the treatment)
How to exercise rights of access, correction, updating or deletion of personal data provided
If sensitive data is collected

ARTICLE 8. PRIVACY NOTICE:

The Privacy Notice is the physical, electronic or any other format document, which is made available to the Holder for the processing of his/her personal data. Through this document, the Holder is informed of the information related to the existence of the information treatment policies that will be applicable to him/her, the way to access them and the characteristics of the treatment that is intended to be given to personal data.

ARTICLE 9. PRIVACY NOTICE AND INFORMATION PROCESSING POLICIES.

Gen3sis S.A.S will keep the model of the privacy notice that was transmitted to the Holders while the processing of personal data is carried out and the obligations derived from it persist. For the storage of the model, Gen3sis S.A.S may use computer, electronic or any other technology.

CHAPTER III

RIGHTS AND DUTIES

ARTICLE 13. RIGHTS OF THE HOLDERS OF THE INFORMATION.

In accordance with the provisions of Article 8 of Law 1581 of 2012, the holder of personal data has the following rights:

a) To know, update and rectify their personal data before Gen3sis S.A.S, in its capacity as responsible for the treatment.
b) Request proof of the authorization granted to Gen3sis S.A.S, in its capacity as Responsible for the Treatment.
c) To be informed by Gen3sis S.A.S upon request, regarding the use that has been given to their personal data.
d) To file complaints before the Superintendence of Industry and Commerce for infringements of the provisions of Law 1581 of 2012, once the consultation or complaint procedure has been exhausted before the Person Responsible for the Treatment.
e) Revoke the authorization and/or request the deletion of the data when the Treatment does not respect the constitutional and legal principles, rights and guarantees.
f) Access free of charge to their personal data that has been subject to Treatment.

ARTICLE 14. DUTIES IN RELATION TO THE TREATMENT OF PERSONAL DATA.

Gen3sis S.A.S will keep in mind, at all times, that personal data is the property of the people to whom it refers and that only they can decide on it. In this sense, it will use them only for those purposes for which it is duly authorized, and respecting in all cases Law 1581 of 2012 on personal data protection.

In accordance with the provisions of Article 17 of Law 1581 of 2012, Gen3sis S.A.

In accordance with the provisions of Article 17 of Law 1581 of 2012, Gen3sis S.A.S commits to permanently comply with the following duties in relation to the processing of personal data:

▪ Guarantee to the Data Subject, at all times, the full and effective exercise of the right of habeas data.

▪ Preserve the information under the necessary security conditions to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access.

▪ Carry out in a timely manner, within the terms provided in Articles 14 and 15 of Law 1581 of 2012, the updating, rectification or deletion of the data.

▪ Process the consultations and claims made by the Data Subjects within the terms indicated in Article 14 of Law 1581 of 2012.

▪ Insert in the database the legend “information under judicial discussion” once notified by the competent authority about judicial processes related to the quality or details of the personal data.

▪ Refrain from circulating information that is being disputed by the Data Subject and whose blocking has been ordered by the Superintendence of Industry and Commerce.

▪ Allow access to the information only to people who can have access to it.

▪ Inform the Superintendence of Industry and Commerce when violations of security codes occur and there are risks in the administration of the Data Subjects’ information.

▪ Comply with the instructions and requirements issued by the Superintendence of Industry and Commerce.

CHAPTER IV

ACCESS, CONSULTATION AND CLAIM PROCEDURES

ARTICLE 15. RIGHT OF ACCESS:

The power of disposition or decision that the data subject has over the information that concerns them, necessarily entails the right to access and know if their personal information is being processed, as well as the scope, conditions and generalities of said processing. In this way, Gen3sis S.A.S must guarantee the data subject their right of access in three ways:

The first implies that the data subject can know the effective existence of the processing to which their personal data is subjected.

The second, that the data subject can have access to their personal data that are in possession of the responsible party.

The third assumes the right to know the essential circumstances of the processing, which translates into the duty of Gen3sis S.A.S to inform the data subject about the type of personal data processed and each and every one of the purposes that justify the processing.

Gen3sis S.A.S will guarantee the right of access when, upon prior accreditation of the identity of the data subject or the legal representation of their representative, it makes available to them, free of charge, the details of the personal data through electronic means that allow direct access by the Data Subject to them. Such access must be offered without time limit and must allow the data subject the possibility of knowing and updating them online.

ARTICLE 16 CONSULTATIONS.

In accordance with the provisions of Article 14 of Law 1581 of 2012, data subjects or their successors may consult the personal information of the Data Subject that is stored in any database. Consequently, Gen3sis S.A.S will guarantee the right of consultation, providing to the data subjects all the information contained in the individual record or that is linked to the identification of the Data Subject.

For the attention of personal data consultation requests, Gen3sis S.A.S guarantees:

* Enable electronic communication means or others deemed pertinent.

* Establish forms, systems and other simplified methods, which must be informed in the privacy notice.

* Use the customer service or claims services that are in operation.

* In any case, regardless of the mechanism implemented for handling consultation 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 address the consultation within said term, the interested party will be informed before the expiration of the ten (10) days, expressing the reasons for the delay and indicating the date on which their consultation will be addressed, which in no case may exceed five (5) business days following the expiration of the first term.

ARTICLE 17. CLAIMS

In accordance with the provisions of Article 14 of Law 1581 of 2012, the Data Subject or their successors who consider that the information contained in a database should be subject to correction, updating or deletion, or when they notice the alleged breach of any of the duties contained in Law 1581 of 2012, may file a claim before the Data Controller, which will be processed under the following rules:

1. The Data Subject may submit the claim in the formats that Gen3sis S.A.S presents on its website for this purpose. If the received claim does not have complete information that allows it to be processed, that is, with the identification of the Data Subject, the description of the facts giving rise to the claim, the address, and accompanying the documents that they want to assert, the interested party will be required within five (5) days following its receipt to rectify the failures. After two (2) months from the date of the requirement without the applicant presenting the required information, it will be understood that they have withdrawn the claim. If for any circumstance Gen3sis S.A.S receives a claim that should not actually be directed against it, it will transfer it to whom it corresponds within a maximum term of two (2) business days and will inform the interested party of the situation.
2. Once the complete claim is received, a legend saying “claim in process” and the reason for it will be included in the database maintained by Gen3sis S.A.S, within a term not exceeding two (2) business days. Said legend must be maintained until the claim is decided.

The maximum term to address the claim will be ten (10) business days counted from the day following the date of its receipt. When it is not possible to address it within said term, the interested party will be informed before the expiration of the aforementioned period of the reasons for the delay and the date on which their claim will be addressed, which in no case may exceed five (5) business days following the expiration of the first term.

RECTIFICATION AND UPDATING OF DATA.

Gen3sis S.A.S has the obligation to rectify and update at the request of the data subject, their information that turns out to be incomplete or inaccurate, in accordance with the procedure and terms indicated above. In this regard, the following will be taken into account:

In requests for rectification and updating of personal data, the data subject must indicate the corrections to be made and provide the documentation that supports their request.

Gen3sis S.A.S has full freedom to enable mechanisms that facilitate the exercise of this right, as long as these benefit the data subject. Consequently, electronic means or others deemed pertinent may be enabled.

Gen3sis S.A.S may establish forms, systems and other simplified methods, which must be informed in the privacy notice and which will be made available to interested parties on the website.

Gen3sis S.A.S will use the customer service or customer care services that it has in operation, as long as the response times are not longer than those indicated by Article 15 of Law 1581 of 2012.

Whenever Gen3sis S.A.S makes available a new tool to facilitate the exercise of their rights by the data subjects or modifies existing ones, it will inform through the respective section on its website.

Paragraph 2.

DATA DELETION.

The data subject has the right, at all times, to request Gen3sis S.A.S to delete (eliminate) their personal data when:

* They consider that the data is not being processed in accordance with the principles, duties and obligations provided in Law 1581 of 2012.

* They have ceased to be necessary or relevant for the purpose for which they were collected.

* The period necessary for the fulfillment of the purposes for which they were collected has been exceeded.

This deletion implies the total or partial elimination of personal information in accordance with what is requested by the data subject in the records, files, databases or processing carried out by Gen3sis S.A.S

It is important to keep in mind that the right of cancellation is not absolute and the responsible party may deny its exercise when:

• The request for deletion of the information will not proceed when the data subject has a legal or contractual duty to remain in the database.
• The deletion of data hinders judicial or administrative actions related 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 data subject; to carry out an action in the public interest, or to comply with an obligation legally acquired by the data subject.

If the cancellation of personal data is appropriate, Gen3sis S.A.S must operationally perform the deletion in such a way that the elimination does not allow the recovery of the information.

CHAPTER V

SECURITY OF INFORMATION

ARTICLE 20. SECURITY MEASURES.

In development of the security principle established in Law 1581 of 2012, Gen3sis S.A.S. shall adopt the technical, human and administrative measures necessary to grant security to the records avoiding their adulteration, loss, consultation, unauthorized or fraudulent use or access.

ARTICLE 21. IMPLEMENTATION OF SECURITY MEASURES.

Gen3sis S.A.S. shall maintain security protocols of mandatory compliance for personnel with access to personal data and information systems.

The procedure shall consider, at least, the following aspects:

– Scope of application of the procedure with detailed specification of the protected resources.

– Measures, norms, procedures, rules and standards aimed at ensuring the level of security required by Law 1581 of 2012.

– Roles and obligations of personnel.

– Structure of personal databases and description of the information systems that process them.

– Procedure for notification, management and response to incidents.

– Procedures for backing up and recovering data.

– Periodic controls to be carried out to verify compliance with the provisions of the security procedure to be implemented.

– Measures to be adopted when a medium or document is to be transported, discarded or reused.

– The procedure should be kept up to date at all times and should be reviewed whenever there are relevant changes in the information system or in its organization.

– The content of the procedure shall at all times comply with the provisions in force regarding the security of personal data.

CHAPTER VI

FINAL PROVISIONS

ARTICLE 22.

Gen3sis S.A.S appoints Juan Gómez, G3 Director; to fulfill the function of personal data protection and to process the requests of the owners, for the exercise of the rights of access, consultation, rectification, updating, suppression and revocation referred to in Law 1581 of 2012.

ARTICLE 23.

EFFECTIVENESS. This manual shall be effective as of January 01, 2024.