Privacy and personal data protection policy of LTM3 SAS

Below is the Privacy Policy and Protection of Personal Data (hereinafter the Privacy Policy) applicable to people who provide their personal data (hereinafter the “Owner”) to the company LTM3 SAS (hereinafter “LTM3”) , which will be included in the LTM3 databases and will be submitted to Treatment by said company.

1. Responsible for the Treatment:

• LTM3 S.A.S., a company domiciled in the city of Bogotá D.C., constituted by a Private Document of the Shareholders’ Meeting of May 31, 2010, registered in the Chamber of Commerce of Bogotá D.C. on June 4, 2010, with Commercial Registration number 01997626 and NIT No. 900.361992-4.

2. Scope of the Privacy Policy:

• This Privacy Policy will apply to all Databases and / or files that contain Personal Data that are subject to Treatment by LTM3, in the events in which it is considered as responsible and / or responsible for the Treatment of Personal Data of natural persons, in accordance with the provisions of Statutory Law 1581 of 2012, Decree 1377 of 2013 and other regulations that from now on modify and / or add them.

3. Definitions:

3.1. Personal Data: Any information linked or that may be associated with one or more specific or determinable natural persons (hereinafter “Personal Data” or “Personal Information”).

3.2. Database: Any organized set of Personal Data that is subject to Treatment.

3.3. Treatment: Any operation or set of operations on Personal Data, such as the collection, storage, use, circulation or deletion.

3.4. Person in charge of the Treatment: Natural or legal person, public or private, that by itself or in association with others, performs the Treatment of Personal Data on behalf of the Person Responsible for the Treatment.

3.5. Responsible for the Treatment: Natural or legal person, public or private, that by itself or in association with others, decides on the Database and / or the Data Processing.

3.6. Holder: Natural person whose Personal Data is subject to Treatment.

3.7. Data Transmission: Treatment of Personal Data that implies the communication of the same within or outside the territory of the Republic of Colombia when it is intended to carry out a Treatment by the Manager on behalf of the Responsible.

3.8. Data Transfer: The data transfer takes place when the Responsible and / or Person in Charge of the Processing of personal data, located in Colombia, sends the information or personal data to a recipient, who in turn is Responsible for the Processing and is within or out of the country

3.9. Sensitive Data: Sensitive data is understood as those that affect the privacy of the owner or whose improper use may affect the privacy of the Holder or the potential to generate discrimination.

3.10. Public Data: Those data that are not semi-private, private or sensitive. Public data are considered, among others, data relating to the marital status of the people, their profession or trade and their status as merchant or public servant.

4. Treatment of Personal Data by LTM3:

• LTM3, in the development of its corporate purpose and economic activity, acts as Responsible and / or Responsible for the Processing of personal data found in its databases. Consequently, it collects, stores, uses, transmits, transfers and deletes personal data of natural persons with whom it has or has had some kind of relationship, whatever its nature (civil, commercial and / or labor); These include but are not limited to suppliers, contractors, workers, creditors, tenants, guest users, debtors, customers and shareholders.

5. Use of the Privacy and Information Protection Policy:

5.1. LTM3 informs all the owners of the Personal Data that are provided to it, either electronically or manually, that the Treatment of the same will be subject to this Privacy Policy. Consequently, if a Holder does not agree with this Privacy Policy, they may not provide any information that must be registered in one of the LTM3 Databases.

5.2. LTM3 is committed to the security and good use of the personal data that is provided to it and, consequently, it is obliged to give them the appropriate uses such as to maintain the required confidentiality against them in accordance with the provisions of this Privacy Policy and in the existing legislation on the subject.

5.3. Personal Information may be transferred to its subsidiaries, affiliates and subordinates, as well as real estate operators, third parties and judicial or administrative authorities, whether natural or legal persons, Colombian or foreign, in those events in which the transfer or transmission of data is necessary to carry out the uses and activities authorized by the Holders in accordance with the corporate purpose of LTM3. In all events, said information will be kept under strict confidentiality and will be subjected to a rigorous Treatment, respecting the rights and guarantees of its Holders.

5.4. In all events, LTM3 may collect information that is in the public domain to complement the databases. Such information will be given the same treatment indicated in this Privacy Policy.

6. Effects of Authorization:

• For all intents and purposes, it is understood that the express and informed authorization granted by the Holders in favor of LTM3 for the Processing of their Personal Data, whatever their means (written, oral or through unequivocal conduct), implies the understanding and full acceptance of all the content of this Privacy Policy.

7. Personal Information Collected:

• The Personal Information that LTM3 may collect and submit to Treatment includes but is not limited to the following:

a) Full Name of the Information Holder;

b) Identification

c) Date of birth;

d) Nationality;

e) Address;

f) Contact address;

g) Contact phones;

h) Email; i) Bank Accounts;

j) Financial Information;

k) Tax Information;

l) Labor Information;

m) Information on experience and experience in the field;

n) Socio-economic information;

o) Information on economic activities

p) Bank and / or commercial reference information

8. Purposes and Uses of Information:

• The personal data that is provided to LTM3 will be treated according to the following purposes for the use of the information, as it applies to each Holder:

a) Analysis of the Personal Information by LTM3, its affiliates and / or subcontracted third parties for internal company purposes;

b) Treat the information in physical and digital media, ensuring the correct registration and use of the LTM3 web pages and their related ones;

c) Include and treat the information acquired by virtue of the relationship between the Owners and LTM3, whatever their legal nature (labor, civil, commercial);

d) Contact the Holder in the event that some type of problem or inconvenience is generated with the Personal Information;

e) Contact the Holder to offer new products and / or services, show advertising or promotions of interest offered by LTM3;

f) Contact the Holder to participate (either as an assistant or as a contractor or supplier) in new products and / or services promoted by LTM3 and / or its customers;

g) Send to the Holders emails as part of a news or Newsletter. In each e-mail sent there is the possibility of requesting not to be registered in this list of emails to stop receiving them. For this, the Holder must notify by physical writing or by e-mail to the email [email protected]

h) Send to the Holder information about products and / or services based on the information obtained from their consumption habits;

i) Carry out marketing communications, promotions and direct marketing campaigns by any means, whether virtual or physical. If the owner prefers it, he can request that he be excluded from the lists for sending promotional or advertising information;

j) Prevent and detect fraud, as well as other illegal activities;

Paragraph: It is clarified that in relation to the information of third parties related to bank and / or commercial references that suppliers, contractors, workers, creditors, tenants, users, guests, debtors, customers and shareholders provide will only be used for the purpose of corroborating references and the person in charge of granting them guarantees that he has the right to give us this information for such purposes, so he will keep LTM3 harmless about any third party claim in relation to the use of such information for the corroboration of references.

9. Rights of the holders of Personal Information:

• The holders of the Personal Information provided to LTM3 will have the following rights:

a) The right to know, update and rectify your Personal Information for free;

b) The right to request proof of the existence of the authorization granted to LTM3;

c) The right to be informed regarding the use that has been given to your Personal Information;

d) The power to revoke the authorization and request the deletion of the data when no use is made in accordance with the authorized uses and purposes;

e) The right to submit inquiries and complaints regarding Personal Information.

10. Confidentiality of Personal Information:

a) The Personal Information provided by the Owners will be used only by LTM3, its affiliates and authorized third parties for such purposes, in accordance with the provisions of both the authorization and the Privacy Policy. Personal Information will not be used, in any event, for purposes other than those for which it was provided, which is why LTM3 will seek to protect the privacy of Personal Information and keep it under the necessary security conditions to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access, as well as respect for the rights of the Holders of the same.

b) If under any circumstance a competent authority requests the disclosure of Personal Information, LTM3 will notify its Holder of such situation.

c) The present obligation of confidentiality of Personal Information will have an unlimited duration, that is, that the obligation subsists in time.

11. Treatment of Personal Information of Minors:

11.1 In application of the provisions of Article 7 of Law 1581 of 2012 and article 12 of Decree 1377 of 2013, LTM3 will proceed to carry out the Treatment of Personal Information of children and adolescents, respecting the best interests of the themselves and ensuring, in all cases, respect for their fundamental rights and minimum guarantees.

11.2 In all the events in which it is required to treat the Personal Information of minors, LTM3 will obtain the corresponding Authorization from the legal representative of the child or adolescent; prior exercise of the minor of his right to be heard, opinion that will be valued taking into account the maturity, autonomy and capacity of the minor to understand the content of the authorization and the Treatment of his Personal Data.

12. Procedure for Consultation, Rectification and Claims:

12.1 Consultation: The consultations and requests of the Holders will be attended within a maximum term of ten (10) business days, counted from the date of receipt thereof. In case it is not possible to resolve the query within this term, the Holder will be informed of said situation at the notification address that has been included in the respective query, and the term of response may be extended for up to five (5) days additional skills. The answer to the queries or claims that the Holders present may be delivered by any physical or electronic means.

12.2 Rectifications and Claims: When the Holder of the Information or its successors consider that their information is corrected, updated or deleted, or when they notice an alleged breach by LTM3 of their duties regarding the Protection of Personal Data contained in the legislation applicable and in this Privacy Policy, they may submit a claim as follows:

to. Written request must be submitted against the specific requirement;

b. If the claim is incomplete, LTM3 will require the interested party within five (5) days following the receipt of the request to complete and correct his request:

i. If two (2) months have elapsed from the date of the request without the applicant’s response, the claim will be deemed withdrawn.

ii. If the person who receives the claim is not competent to resolve it, they will transfer it to whoever it is to resolve it within a maximum period of two (2) business days and inform the applicant of that fact.

c. If the claim is received in full or has been subsequently completed, a “legend” must be included within the following two (2) business days in the database that indicates “CLAIM IN PROCESS”.

d. LTM3 will resolve the claim within a maximum term of fifteen (15) business days from the day following its receipt. In case it is not possible to resolve the query within this term, the Holder will be informed of the delay, the reasons and the date of response at the notification address that has been included in the respective claim. In any case, the response term may not exceed eight (8) business days following the expiration of the first term. The response to the claims submitted by the Holders may be made by any physical or electronic means.

13. Contact:

• In the event of any doubt or concern about this Privacy Policy or the Treatment and use of Personal Information, please direct your inquiries, requests, complaints or claims to:

to. The email [email protected].

b. Written request to the Administrative Department LTM3, in Carrera 10 No. 80-36, Bogotá, D.C.

14. Modifications of the Privacy Policy:

• LTM3 is fully empowered to modify this Privacy Policy. Any change will be informed either by electronic or physical means to the Personal Information Holders. The granting of the authorization, as well as the registration on the Website will be understood as an express manifestation of the acceptance of the Privacy Policy.

15. Validity:

• This Privacy Policy is effective as of June 10, 2013.


Santiago Arias Echeverry

General Manager

8010 Urban Living