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PERSONAL DATA PROCESSING POLICY

ADF AMERICAS CORP

1. PURPOSE AND SCOPE

This Policy establishes the guidelines for the collection, storage, use, circulation, updating, transmission, transfer, and deletion of personal data processed by ADF AMERICAS CORP (hereinafter, the “Company”), through its physical and digital channels, including its website, contact forms, social media, email communications, and/or instant messaging.

ADF AMERICAS CORP acts as the Data Controller of personal data and guarantees compliance with the constitutional right of Habeas Data, as well as with the applicable regulations in Colombia, especially Law 1581 of 2012 and Decree 1377 of 2013.

2. IDENTIFICATION OF THE DATA CONTROLLER

Data Controller: ADF AMERICAS CORP

EIN: 862617534

Address: 100 NW 6TH ST MIAMI, FL, 33136 USA

Email: partnerships@adfamericas.com

3. DEFINITIONS

For the purposes of this Policy, the definitions established in Law 1581 of 2012 shall apply, including:

Authorization: Prior, express, and informed consent of the Data Subject for the processing of their personal data.

Personal Data: Information linked or associated with an identified or identifiable natural person.

Sensitive Data: Data that affects the privacy of the Data Subject or whose misuse may result in discrimination.

Data Processor: A person or entity that processes personal data on behalf of the Data Controller.

Data Controller: A person or entity that decides on the database and/or the processing of personal data.

Data Subject: A natural person whose personal data is subject to processing.

Processing: Any operation performed on personal data, such as collection, storage, use, circulation, or deletion.

Transfer: Sending data to a recipient who also acts as a Data Controller.

Transmission: Communication of data to a Data Processor so that it processes the data on behalf of the Data Controller.

4. PRINCIPLES FOR DATA PROCESSING

ADF AMERICAS CORP applies the principles of legality, purpose limitation, freedom, accuracy or quality, transparency, restricted access and circulation, security, and confidentiality, in accordance with Law 1581 of 2012 of Colombia and in alignment with Habeas Data standards across Latin American countries.

5. PERSONAL DATA COLLECTED

ADF AMERICAS CORP may collect and process, among others, the following data:

  • Identification Data: First name, last name, type and identification number (when applicable).
  • Contact Data: Phone number, email address, city, address (when applicable).
  • Business Data: Corporate name, tax ID (NIT), position, commercial information related to quotations or contracts.
  • Request Information: Inquiries, quotations, messages, and communication history.
  • Technical Data (Web): IP address, browser type, cookies, visited pages, and browsing metrics (when applicable).

6. PURPOSES OF PROCESSING

6.1. Clients and Prospects

  • Respond to information requests, quotations, and inquiries.
  • Manage the commercial relationship and service provision.
  • Send information about products, services, promotions, and marketing campaigns, when authorized.
  • Follow up on quotations, orders, deliveries, and after-sales processes.
  • Issue invoices, accounting documents, and administrative records.
  • Handle petitions, complaints, claims, and suggestions (PQRS).
  • Comply with legal obligations and requests from competent authorities.

6.2. Suppliers and Partners

  • Manage purchasing processes, service orders, invoicing, and payments.
  • Verify compliance with contractual obligations.
  • Coordinate logistical, operational, and support processes.
  • Support administrative, accounting, and legal processes.

6.3. Analytics and Digital Security

  • Improve user experience and navigation across digital channels.
  • Measure channel performance using analytics tools (when implemented).
  • Prevent fraud, unauthorized access, and strengthen information security.

7. DATA SUBJECT AUTHORIZATION

ADF AMERICAS CORP will request prior, express, and informed authorization for the processing of personal data, which may be obtained through physical or digital means, including forms, emails, instant messaging, and/or consent checkboxes.

The Data Subject may revoke authorization and/or request deletion of their data when there is no legal or contractual obligation preventing it.

8. RIGHTS OF DATA SUBJECTS

The Data Subject has the right to:

  • Know, update, and rectify their personal data.
  • Request proof of the granted authorization.
  • Be informed about the use given to their data.
  • File complaints before the Superintendence of Industry and Commerce (SIC).
  • Revoke authorization and/or request deletion of data, when applicable.
  • Access their personal data free of charge.

9. PROCEDURE TO EXERCISE RIGHTS (INQUIRIES AND CLAIMS)

Rights may be exercised through:

Email: partnerships@adfamericas.com

9.1. Inquiries

Inquiries will be addressed within the legally established timeframes. If an extension is required, the Data Subject will be informed in a timely manner.

9.2. Claims

The claim must include at least:

  • Identification of the Data Subject.
  • Clear description of the facts.
  • The data to be corrected, updated, or deleted.
  • Physical address or email address for response.
  • Supporting documents, if applicable.

10. INFORMATION SECURITY

ADF AMERICAS CORP implements reasonable technical, human, and administrative measures to protect personal data against loss, unauthorized access, alteration, or misuse.

11. DATA TRANSMISSION AND TRANSFER

Personal data may be shared with third-party Data Processors when necessary to fulfill the purposes described herein, always ensuring adequate levels of protection in accordance with the law.

In the case of international transfers, applicable legal provisions shall be observed.

12. PROCESSING OF SENSITIVE DATA AND MINORS’ DATA

As a general rule, ADF AMERICAS CORP does not request sensitive data. When strictly necessary, the purpose will be informed and express authorization will be requested.

The processing of data of children and adolescents will only be carried out with the authorization of their legal representative and in compliance with the best interests of the minor.

13. EFFECTIVE DATE

This Policy becomes effective upon publication and may be updated at any time. Any modifications will be communicated through the most appropriate means, and the current version will remain available.