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PROCESSING OF PERSONAL DATA

PURPOSE

To set out the criteria for the collection, storage, use, circulation and deletion of personal data provided by customers, suppliers and interested parties through the various communication channels, such as: the website, email, suggestion boxes, chat, telephone calls and any other means that PANACA S.A.S and its associated companies may determine for accessing personal data.

SCOPE

This policy applies to all personal information held in the databases of PANACA S.A.S and its associated companies, which act as the data controller for personal data.

DATA CONTROLLER

PARQUE NACIONAL DE LA CULTURA AGROPECUARIA S.A.S, a duly incorporated company, tax ID (NIT) 801.001.634-1, with its registered office at Km 7, Vereda Kerman, in the municipality of Quimbaya – Quindío, Republic of Colombia, website www.panaca.co, email hola@panaca.co, telephone 3137219211.

PROCESSING AND PURPOSE

The processing and purpose that PARQUE NACIONAL DE LA CULTURA AGROPECUARIA S.A.S and its associated companies will apply to the information collected is as follows:

1. The purpose of using personal data
• To send invitations to events and offer new products and services.
• To handle requests, complaints and claims.
• To carry out satisfaction surveys about the goods and services offered by PANACA S.A.S.
• To supply contact information to the sales force and/or distribution network, telemarketing, market research and any third party with which PANACA S.A.S has a contractual relationship for carrying out such activities (market research, telemarketing, etc.).
• To contact the data subject by electronic means – SMS or chat – to send news about loyalty campaigns or service improvements.
• Billing and payments. The collection, storage, use and circulation of personal data provided by customers and interested parties through the various communication channels — the website, email, suggestion boxes, chat, telephone calls and any other means PANACA S.A.S may determine — will be processed in accordance with the procedure set out in this document.

2. Processing of personal data:
• Customers' personal data: data provided by customers of PANACA S.A.S and its associated companies will be treated as confidential and will be stored and safeguarded in our database, to which only the technology department has access.
• Employees' personal data: data provided by employees during recruitment and hiring will be kept in a physical and digital file for each employee, which will be handed to the records management department for storage and safekeeping. Only the human resources department has access to the employee database.
Once the employment relationship ends, the physical and/or digital file will move to the inactive files section and will be kept in accordance with legal requirements, in the custody of the records management department, for any procedures or certificates that may be required.
• Suppliers' personal data: data will only be requested from suppliers in order to quote for products and/or services, perform a contract or purchase a product and/or service.

RIGHTS OF DATA SUBJECTS

As the subject of your personal data, you have the right to:

a) Access, free of charge, the data you have provided that has been processed.
b) Know, update and correct your information where data is partial, inaccurate, incomplete, fragmented or misleading, or where its processing is prohibited or has not been authorised.
c) Request proof of the authorisation given.
d) File complaints with the Superintendency of Industry and Commerce (SIC) for breaches of the applicable regulations.
e) Withdraw your authorisation and/or request the deletion of your data, provided there is no legal or contractual duty preventing its removal.
f) Decline to answer questions about sensitive data. Answers concerning sensitive data or data about children and adolescents are optional.

HANDLING OF REQUESTS, ENQUIRIES AND CLAIMS

The Customer Service department is responsible for handling data subjects' requests to exercise their rights. Requests, enquiries and claims can be made through various channels:

- In person (customer to staff member). - Suggestion box.
- Email hola@panaca.co
- Website.
- Social media.
- Satisfaction surveys.

PROCEDURE FOR EXERCISING THE RIGHT OF HABEAS DATA

In compliance with personal data protection rules, PANACA S.A.S sets out below the procedure and minimum requirements for exercising your rights. To file and process your request, please provide the following information:

• Full name and surnames.
• Contact details (postal and/or email address and contact telephone numbers).
• How you would like to receive a reply to your request.
• The reason(s) and fact(s) giving rise to the claim, with a brief description of the right you wish to exercise.

The maximum period allowed by law to resolve your claim is fifteen (15) working days from the day after it is received. Where it is not possible to deal with the claim within that period, PARQUE NACIONAL DE LA CULTURA AGROPECUARIA S.A.S will inform you of the reasons for the delay and the date on which your claim will be dealt with, which may in no case exceed eight (8) working days after the first period expires. Once the periods set out in Law 1581 of 2012 and the regulations that develop or supplement it have elapsed, any data subject who is refused, in whole or in part, the exercise of the rights of access, updating, correction, deletion and withdrawal may refer the matter to the Superintendency of Industry and Commerce (SIC) — office for the protection of personal data.

EFFECTIVE DATE

This personal data processing policy takes effect from 1 July 2013. The databases in which personal data is recorded will remain in force for as long as the information is held and used for the purposes described in this policy. Once those purposes have been met, and provided there is no legal or contractual duty to retain your information, your data will be deleted from our database.

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