Privacy Policy of Perez & Co.

Perez & Co. Estrategias Legales SAS, identified with TIN No. 901.896.069-0 (hereinafter, “Perez & Co.”) is committed to protecting the Personal Data of its clients, suppliers, candidates, employees, and any other person whose data is subject to processing. This policy establishes the guidelines for the responsible handling of personal information in accordance with Law 1581 of 2012, Decree 1377 of 2013, and other applicable regulations. The Processing will be governed by the principles of legality, purpose, freedom, veracity, transparency, restricted access and circulation, security, and confidentiality.

 

1. Identification of the Data Controller

The controller responsible for the Processing of Personal Data is Perez & Co. Estrategias Legales SAS, located at Calle 69 #8-18, 2nd floor, Bogotá, Colombia, email contact@pcolegal.co, and telephone number +57 3025536624.

 

2. Definitions

• • • Database: Organized set of data.
    • Personal Data: Information linked or that can be associated with a specific or identifiable natural person.
    • Sensitive Data: Information that affects the privacy of the data subject or whose improper use may generate discrimination, such as that which reveals racial or ethnic origin, political orientation, religious or philosophical beliefs, membership in unions, social organizations, human rights organizations or that promote interests of any political party or that guarantee the rights and guarantees of opposition political parties, as well as data relating to health, sexual life, and biometric data.
    • Data Subject(s): Natural person whose personal data is subject to processing.
    • Processing: Any operation on Personal Data, such as collection, storage, use, circulation, or deletion.

 

3. Processing

Personal Data is collected, stored, organized, used, circulated, transmitted, transferred, updated, rectified, deleted, eliminated, and managed according to the purposes. The Processing of Personal Data may be carried out through physical, automated, or digital means, depending on the type and method of collection of personal information (for example, through digital platforms, websites, cookies). Based on this, Perez & Co. may contact the Data Subject by telephone through calls and/or text messages such as SMS and/or MMS, or through digital means (instant messaging applications and social networks, such as WhatsApp), either directly or through third parties.

 

1. 1. • Processing of Sensitive Data

The Processing of Sensitive Data will be carried out only with the express consent of the Data Subject, without conditioning, in any case, any activity to the delivery of Sensitive Data.Sensitive Data will be processed with the highest security standards, and access to such data will be limited only to authorized personnel. Perez & Co. will inform the Data Subject that they are not obligated to authorize the processing of this type of data, specifying in advance which data will be subject to processing and the purposes.

 

1. 1. • Processing of Personal Data of Minors

The processing of Personal Data of minors will be carried out respecting their fundamental rights, subject to compliance with the conditions set by personal data protection regulations and other applicable norms, and only with the express consent of their parents or legal representatives.

4. Purposes

Perez & Co. will process Personal Data for the following purposes:

 

1. 1. • Clients and prospects:

o Comply with legal and contractual obligations.
o Develop the corporate purpose of Perez & Co.
o Execute contracted services, including managing inquiries and requests.
o Manage billing and collection.
o Promote, advertise, and/or provide information about services and products of our own and third parties.
o Develop and manage marketing strategies and campaigns.
o Conduct surveys, market analysis, and service quality studies.
o Perform validations for fraud prevention, risk of money laundering, terrorist financing, bribery, related crimes, including verification and consultation in both national and international lists and databases.
o Consult databases of credit bureaus or other operators for information on the performance as a debtor of the Data Subject or their representative, their payment capacity, the viability to enter or remain in a commercial relationship.
o Report to credit bureaus or data operators on the compliance or non-compliance with credit obligations.
o Address requests and complaints.

 

1. 1. • Suppliers:

o Manage commercial relationships and make payments.
o Comply with contractual and legal obligations.
o Perform validations for fraud prevention, risk of money laundering, terrorist financing, bribery, related crimes, including verification and consultation in both national and international lists and databases.
o Consult databases of credit bureaus or other operators for information on the performance as a debtor of the Data Subject or their representative, their payment capacity, the viability to enter or remain in a commercial relationship.
o Promote, advertise, and/or provide information about services and products of our own and third parties.
o Address requests and complaints.

 

1. 1. • Candidates, employees, and former employees:

o Comply with legal, pre-contractual, contractual, and post-contractual obligations.
o Develop the corporate purpose of Perez & Co.
o Conduct identity checks and eligibility for the position.
o Verify employment history, qualifications, experience, and references.
o Conduct recruitment and selection, including interviews, evaluations, and psychometric profiles, shortlisting, job offers, and benefits (where applicable).
o For business analysis and improvements.
o Review and monitor the use of provided work tools, including technological ones such as computer equipment.
o Conduct investigations for disciplinary processes.
o Training and conducting organizational surveys.
o Perform validations for fraud prevention, risk of money laundering, terrorist financing, bribery, related crimes, including verification and consultation in both national and international lists and databases.
o Manage requests, complaints, or claims.

 

5. Rights of the Data Subject

Data Subjects have the right to:

1. 1. • Know, update, and rectify their personal data. This right may be exercised, among others, against partial, inaccurate, incomplete, fractioned data that may lead to error, or those whose processing is prohibited or has not been authorized.
      • Request proof of the authorization granted, except when expressly exempted for processing in accordance with applicable regulations.
      • Be informed about the use given to their personal data.
      • Revoke the authorization or request the deletion of the data when constitutional and legal principles are not respected.
      • File complaints with the Superintendence of Industry and Commerce for violations of the law and other regulations that modify, add to, or complement it.
      • Access their personal data subject to processing free of charge.
      • Withdraw their consent, provided there is no legal or contractual duty to remain in a database.
      • Revoke their authorization and/or request the deletion of their data when the processing does not respect legal and constitutional principles, rights, and guarantees.

 6. Procedure for Exercising Rights

To exercise their rights, Data Subjects can contact the responsible area of Perez & Co. via email at contact@pcolegal.co, or by written request at Calle 69 #8-18, 2nd floor, Bogotá, Colombia, telephone number +57 3025536624.

 

The request will be reviewed to verify the identity of the Data Subject. If the request is submitted by a person other than the Data Subject and it is not demonstrated that they are acting on behalf of the Data Subject in accordance with current laws, the request will not be processed. For this process, the presentation of the Data Subject’s original identification document may be required, as well as special powers of attorney, general powers of attorney, or other relevant documents as the case may be.

 

The request for the exercise of the Data Subject’s rights must include: i) the name and identification document number of the Data Subject; ii) contact information, including physical and/or electronic address and telephone numbers; iii) Documents that prove the identity of the Data Subject or, where applicable, the legal representation of the applicant; iv) Clear and precise description of the personal data/facts regarding which the Data Subject seeks to exercise their rights; v) Description of the objective pursued (update, correction, revocation, deletion, or compliance with duties).

 

Requests will be addressed within a maximum period of ten (10) business days. If it is not possible to respond within this period, the Data Subject will be informed of the reasons for the delay.

 

7. Transfer and Transmission

Perez & Co. may communicate, transmit, or transfer the Personal Data provided by the Data Subjects to third parties, both within and outside the national territory, in compliance with the provisions established by applicable law. The personal information of the Data Subjects may be shared with companies affiliated with Perez & Co., whether located within or outside the country, as well as with business partners and strategic allies that maintain a current contractual relationship to comply with the purposes authorized by the Data Subjects. Likewise, the data may be transmitted to third parties that require the information for processing in accordance with the purposes established in this policy. Specifically, but not limited to, Perez & Co. may carry out the transfer and/or transmission of the information, according to the particular needs of each case, to entities located in countries that have been declared as having an adequate level of protection by the European Commission and/or the Superintendence of Industry and Commerce (SIC), and any other country expressly authorized by the Data Subjects.

 

8. Information Security

Perez & Co. implements necessary technical, human, and administrative measures to guarantee the security and confidentiality of personal data, preventing its adulteration, loss, consultation, unauthorized or fraudulent use or access.

9. Validity

This privacy policy has been in effect since November 28, 2024. Personal Data will be stored for the time necessary to fulfill the purposes mentioned in this policy and as permitted by applicable law. Once the purpose of the processing has been fulfilled or when the data subject requests its deletion and there is no legal or contractual duty to preserve it, the data will be deleted.

 

10. Modifications to the Privacy Policy

Perez & Co. reserves the right to modify this policy at any time. Any changes will be communicated in a timely manner through the Perez & Co. website.