1. IDENTIFICATION OF THE DATA CONTROLLER

In compliance with Law 1581 of 2012, Decree 1377 of 2013, and other applicable provisions
regarding the protection of personal data, we hereby inform you that the entity responsible for the
processing of personal data is:

• Company name: SOLDEXEL S.A.S.
• Tax ID No. 900.106.777-5
• Registered office:Bogotá D.C., Colombia.
• Address:Avenida 1.ª de Mayo No. 27-50, Barrio Santander
• Website:www.soldexel.com
• PBX:(57-1) 756 1886
• Contact emails by stakeholder group:
➢Customers:ventas@soldexel.com
➢Suppliers:compras@soldexel.com
➢Employees:rhumanos@soldexel.com

2. PRESENTATION

The purpose of this policy is to establish the guidelines and directives governing the
processing of personal data collected, stored, used, processed,
transmitted, or deleted bySOLDEXEL S.A.S., within the framework of its
commercial, contractual, labor, and legal activities.
SOLDEXEL S.A.S., as the data controller, guarantees the protection of the rights
of data subjects, in accordance with the principles established in Colombian legislation on
habeas data. This policy applies to the personal data of:

• Current and potential customers
• Suppliers and contractors
• Employees and former employees
• Shareholders and partners
• Job applicants
• Website users
• Any third party who has provided personal information to the company

3. PRINCIPLES APPLICABLE TO PROCESSING

The processing of personal data atSOLDEXEL S.A.S.is carried out in accordance with the
following principles:
• Legality: The processing complies with the provisions of current legislation.
• Purpose: The data is collected for legitimate, specific, explicit
and informed purposes.
• Freedom: Processing is only carried out with the prior, express, and
informed consent of the data subject.
• Accuracy or quality: The information must be accurate, complete, up-to-date,
verifiable, and understandable.
• Transparency: The data subject's right to know how their data is being used is guaranteed at
any time.
• Access and restricted circulation: Only authorized personnel access the data, under
principles of necessity and confidentiality.
• Security: Administrative, technical, and human measures are applied to protect the
data.
• Confidentiality: All persons involved in the processing are obliged to
guarantee the confidentiality of the information.

4. PURPOSE OF PROCESSING

Personal data will be processed solely for legitimate, contractual, employment-related,
commercial, administrative, and legal purposes, as applicable, such as:
• Management of contractual, commercial, and employment relationships.
• Compliance with legal, regulatory, and contractual obligations.
• Selection, hiring, and management of human talent.
• Institutional communication and sending of relevant information.
• Accounting, fiscal, and tax administration.
• Compliance with the provisions of the Transparency and Business Ethics Program,
and other corporate management systems.

Processing activities include, among others, the collection, storage,
updating, use, circulation, transmission, and deletion of data.

4. SCOPE OF APPLICATION.

This policy applies to the processing of personal data carried outby SOLDEXEL S.A.S.,
regardless of the means of collection (physical or digital), and with respect to all data subjects
with whom it has a contractual, commercial, employment, or any other type of relationship,
whose data is contained in its databases.

5. AUTHORIZATION OF THE DATA SUBJECT

SOLDEXEL S.A.S.may obtain authorization for the processing of personal data
by written, digital, or oral means, or through unequivocal conduct on the part of the data subject,
provided that such means allow for verification of the authorization and guarantee that it is prior, express, and
informed.
In all cases, the organization will ensure the traceability, preservation, and custody of the
supports that evidence consent, in accordance with the principles of transparency,
demonstrated responsibility, and respect for the rights of the owner.

6. TRANSMISSION AND TRANSFER OF DATA TO THIRD PARTIES

The personal data stored may be shared with third parties, only
when:
• There is prior and express authorization from the owner.
• It is necessary for compliance with legal or contractual obligations.
• The processing is delegated to a third party under contract that ensures adequate conditions
of security, confidentiality, and compliance with ethical principles
In all cases, it will be verified that the recipients comply with standards compatible with
this policy and the company's Transparency and Business Ethics Program.

7. CHANNELS FOR QUERIES AND COMPLAINTS

Data subjects may exercise their rights of access, updating, rectification, erasure, or revocation of authorization through the following channels:

•Email:servicioalcliente@soldexel.com
•Telephone:(57-1) 756 1886
•Address:Av. 1.º de Mayo No. 27-50, Bogotá D.C.

All requests will be addressed within the legal deadlines established by Law
1581 of 2012.

8. POLICY VALIDITY

This policy comes into effect on December 1, 2021, and will remain in force
as long as there is a legal or contractual relationship with the data subjects or as long as it is
necessary for the fulfillment of the purposes described. Any modifications will be
published in a timely manner and communicated to the interested parties.