VirtualWork.agency Personal Data Protection and Processing Policy

INTRODUCTION

VIRTUALWORK.AGENCY. is a brand of PROSERCOL ASESORES LTDA NIT 900269400-3, a leading company in Colombia whose main activity is to connect employers with technical or professional assistants through a virtual platform made up of a web page and a mobile application , so that consumers enter, find out about the services displayed and can carry out the transaction of contracting them, electronically, and in general all kinds of complementary activities.

VIRTUALWORK.AGENCY., in order to strictly comply with the current regulations for the protection of Personal Data, in accordance with the provisions of Law 1581 of 2012, Decree 1074 of 2015 and other provisions that modify, add or complement presents the following PERSONAL DATA PROTECTION AND PROCESSING POLICY (hereinafter "Processing Policy") with the purpose of protecting the personal information provided by the Holders that are related to VIRTUALWORK. AGENCY. such as partners, suppliers, customers, employees, collaborators and any other natural person from whom VIRTUALWORK.AGENCY. obtains, collects, processes or treats personal data, whether said treatment is carried out by VIRTUALWORK.AGENCY. or by third parties who do it on behalf of it.

The Treatment Policy aims to protect the constitutional right of Habeas Data that all people have to know, update, and rectify the information that has been collected and stored in the different databases of < b>VIRTUALWORK.AGENCY., and by virtue of compliance with said right, it only collects and Processes Personal Data, when it has been previously authorized by its Owner, implementing for this purpose, clear measures on confidentiality and privacy of Personal information. Likewise, it details the general corporate guidelines that are taken into account in order to protect the Personal Data of the Owners, the purposes of Information Processing, the area responsible for dealing with complaints and claims, and the procedures that must be exhausted. to know how to update, rectify and delete the information and the respective channels so that they can exercise them.</ span>

DEFINITIONS

Personal data: Any information concerning or linked to specific or determinable natural persons.< /span>

Personal data holder: Natural person whose dacough are subject to treatment. In the context of this personal data processing policy, the owners may be: (i) subscribers/clients of the platform; (ii) Contractors/Virtual Work Agency; (iii) suppliers (iv) all those people not linked to VIRTUALWORK.AGENCY. whose personal data is processed.

Personal database: Organized set of personal data that is processed by a natural or legal person.

Sensitive data: It is that personal data that affects the privacy of the Holder and whose incorrect use could generate discrimination. They are considered sensitive data, among others, health data, data on sexual orientation, racial and ethnic origin, political opinions, religious, philosophical or moral convictions.

Private data: This is personal data that, due to its intimate or reserved nature, is relevant to the Holder.

Semi-private data: It is personal data that is known and of interest both to the owner and to a certain sector of people or to society in general, so it is not of an intimate, reserved or public nature.</span >

Public data: It is that personal data classified as such according to the Constitution and the law, and that has not been classified as private or semi-private personal data.

Habeas data: It is the right of the Holder of the personal data to demand from the administrators of the same the access, inclusion, exclusion, correction, addition, updating and rectification of the data, as well as the limitation in disclosure, publication or assignment.

Authorization: Prior, express and informed consent of the Holder to carry out the processing of personal data.

Privacy notice: Verbal or written communication addressed to the Holders of the personal data that are being processed by the company, in which they are informed about the existence of the personal data processing policies that will be applied to them , the form of acgive in to them, and the purposes for which your personal data will be used.

Responsible for treatment: A natural or legal person of a public or private nature that by itself or in association with another or others decides on the processing of personal data. In this case, VIRTUALWORK.AGENCY. will be the controller.

VIRTUALWORK.AGENCY.< /p>

Address: Cra. 18 # 33-30, Bogotá D.C.

Email: info@VirtualWork.agency< /p>

Phone: (57) 3506666847</p >

Processor: Natural or legal person, public or private, that by itself or in association with others, processes personal data on behalf of the controller.

Treation: Any operation or set of operations on personal data, such as the collection, storage, use, circulation or deletion.

Database custodian: Natural person, within the company, who keeps personal databases.

Transmission: Processing of Personal Data that implies the communication to a third party of the same, within or outside the territory of the Republic of Colombia, when said communication is intended to carry out a Treatment by the Manager on behalf and on behalf of the person in charge, to fulfill the purposes of the latter.</ p>

Transfer: The Transfer of Personal Data takes place when the person in charge and/or Person in Charge of the Processing of Personal Data sends the information or personal data to a receiver, who in turn is responsible for the treatment and is within or outside the country.

Personal data breach: It is the crime defined in article 269 of the Penal Code. Which establishes: “ Anyone who, without being empowered to do so, for their own benefit or that of a third party, obtains, compiles, steals, offers, sells, exchanges, sends, buys, intercepts, discloses, modifies or uses personal codes , personal data contained in files, archives, databases or similar means, will incur a prison sentence of forty-eight (48) to ninety-six (96) months and a fine of 100 to 1000 current legal monthly minimum wages.”

Ways of collecting personal data: VIRTUALWORK.AGENCY. may know, collect, store, manage the information of the owner of the information in accordance with the data use policy contained in this document through of the following means: (i) Registration and use of the mobile application VIRTUALWORK.AGENCY.; (ii) Registration and use of the VIRTUALWORK.AGENCY. website; (iii) subscription of any type of contract, alliance and/or agreement with VIRTUALWORK.AGENCY.; (iv) Registration as a provider of VIRTUALWORK.AGENCY.</span >

GUIDING PRINCIPLES FOR THE PROCESSING OF PERSONAL DATA< /p>

According to the provisions of Title II of Statutory Law 1581 of 2012, the protection of personal data will be governed by the harmonious and comprehensive application of the following principles:

Principle of legality in the processing of personal data: The processing of personal data referred to in Statutory Law 1581 of 2012 is a regulated activity that must be subject to what is established in it and in the other provisions that develop it.

Purpose principle: The processing of personal data must obey a legitimate purpose in accordance with the Constitution and the law, which must be informed to the Owner.

Principle of freedom: The processing of personal data can only be exercised with the prior, express and informed consent of the Owner. Personal data may not be obtained or disclosed without prior authorization, or in the absence of a legal or judicial mandate that relieves consent.

Principle of accuracy or quality: The information subject to treatment must be truthful, complete, exact, up-to-date, verifiable and understandable. The Treatment of partial, incomplete, fractional or misleading data is prohibited.

Transparency principle: In the Processing of personal data, the Holder's right to obtain information about the existence of data that concerns him or her, at any time and without restrictions, must be guaranteed from the person in charge of the treatment or the Person in Charge of the treatment. .

Principle of security: The information subject to treatment by the person in charge of the treatment or in charge of the treatment referred to in Statutory Law 1581 of 2012, must be handled with the technical, human and administrative measures that are necessary to provide security to the records avoiding their adulteration, loss, consultation, use or unauthorized or fraudulent access.</ span>

Principle of confidentiality: All persons involved in the processing of personal data that are not of a public nature are obliged to guarantee the confidentiality of the information, even after the end of their relationship with any of the tasks included in the treatment, being able to only carry out supply or communication of personal data when this corresponds to the development of the activities authorized in Statutory Law 1581 of 2012 and in the terms thereof.

Principle of restricted access and circulation: The treatment is subject to the limits derived from the nature of personal data, the provisions of Statutory Law 1581 of 2012 and the Constitution. In this sense, the treatment can only be done by persons authorized by the Owner and/or by the persons provided for in the aforementioned law.

OWNERS RIGHTS

In compliance with the fundamental guarantees enshrined in the Constitution and the law, and without prejudice to the provisions of the other regulations that regulate the matter, the Owners of the personal data may freely and unlimitedly exercise the following rights:

Right of access to your information personal object of treatment.

Right to update of the personal data being processed.< /p>

Right to rectification of the personal data being processed.< /p>

Right to object to personal data being processed

Right to request deletion of personal data when the constitutional and legal principles, rights and guarantees are not respected in the treatment.

Right to request proof of the authorization granted for the treatment.

Right to revoke consent for the processing of personal data.< /p>

Right to file complaints and claims before the Superintendence of Industry and Commerce for violations of the provisions of Statutory Law 1581 of 2012 and other regulations that modify, add or complement it.

Right to be informed by the person in charge and/or in charge of the use and treatment that will be given to the personal data, as well as the modifications and updates of the protection policies, security measures and purposes.</ span>

WAY TO COLLECT THE DATA

Means of collecting the personal data of Users/Clients:

The collection of personal data of potential users and users of VIRTUALWORK.AGENCY., will be carried out in the following ways:

Through the automatic storage of the data of the users who access the platform of VIRTUALWORK.AGENCY. by the use of cookies. Some of the data that can be stored automatically are URLs, browser used, IP address, among others.

By exchanging emails.</ p>

By sending messages through instant messaging platforms.

Through access to company websites.</ span>

Through access to the application, creating the username and password.

Through phone calls.</p >

Through events performed by VIRTUALWORK.AGENCY.

By transmission or transfer by Strategic Allies.</ span>

Way to collect data from Workers or candidates

The collection of personal data of employees will be carried out in the following ways:

Through the candidates' academic resumes.< /span>

Through the employment or service provision contract.< /span>

Through the academic resumes of employees.< /span>

<pclass="MsoNormal" style="margin-bottom: 18pt; line-height: normal; background: #FFFFFF;">Through the input format to VIRTUALWORK.AGENCY. or job application format.

Across the platformSeller center

By using check-in lists for employees at company facilities.

In the development of job interviews.< /p>

By sending information from companies that have the quality of headhunters and the owners have provided the data.

Using EPS affiliation formats, ARLs.</span >

By affiliation to the web platforms offered by PROSERCOL ASESORES LTDA

Way to collect data from the VIRTUALWORK AGENCY

Through access to company websites.</ span>

Through access to the application, creating the username and password.

Through physical forms.</ p>

Supplier Collection Form

The collection of personal data from suppliers will be carried out in the following ways:

Through service offerings.</ p>

Through the email exchange.

Through the cooperation agreement.</ p>

Through the service provision contract.

Through service portfolios.</p >

Through meetings or telephone communications.< /p>

Partner Collection Form

Collection of members' personal data</ span>

The collection of personal data from members will be carried out in the following ways:

Through the subscription of actions.< /p>

Through meetings of the governing bodies or general shareholders' meetings and their respective calls.

Through the exchange of emails or other means of communication with shareholders.

PURPOSES OF PROCESSING PERSONAL DATA</ p>

The Personal Data collected by VIRTUALWORK.AGENCY. is included in a Database to which authorized personnel of VIRTUALWORK.AGENCY. have access. b> in the exercise of their functions, noting that in no case is the Treatment of information authorized for purposes other than those described here, and that they be communicated to the Owner directly at the latest at the time of collection.< /p>

Purpose of processing Users' personal data

Collect or collect personal data and incorporate and store it in our database.

Sort, catalog, classify, divide or separate the information provided.

Use the data provided in communication campaigns, disclosure and promotion or offer of products, activities and/or services developed as part of the company's internal strategies.

Keep company historical records and maintain contact with data subjects.

Verify, check or validate the supplied data.

Study and analyze the information provided for the monitoring and improvement of products, service and attention.

Deliver the information collected to third parties with whom the company contracts the storage and administration of personal data, under the security and confidentiality standards to which VIRTUALWORK.AGENCY. is required under the relevant laws.</p >

Transfer personal data to any country or server in another country.

Communicate and allow access to the personal data provided to third-party providers of general support services and to natural or legal persons who are shareholders of VIRTUALWORK.AGENCY.< span style="font-size: 12pt; font-family: 'Times New Roman', serif;">

Collect, have, manage and use information to control and prevent fraud, control and prevent money laundering and financing of terrorism.

Celebration, execution and management of business proposals and contracts object of the services provided.

Perform, in accordance with the law, reports to credit bureaus for non-compliance with the financial obligations derived from the relationshipcommercial.

Sending communications through any channel including, but not limited to, social networks, text messages, push notifications, email, phone calls, etc., related to the corporate purpose of VIRTUALWORK.AGENCY. such as marketing activities and/or any request made by the owner to VIRTUALWORK.AGENCY, among others.

Provide the services offered and/or contracted appropriately and with excellent quality.

Create and manage the user account.

Provide maintenance, development and/or control of the commercial relationship between the user and VIRTUALWORK.AGENCY.

Provide users with the necessary information, through the website and/or contact platform, about the products of the offerors, to formalize the relationship of consumption of said products.</span >

Carry out processes within the company, for purposes of operational development and/or system administration.

Provide the company's services and monitor them according to the particular needs of the user, in order to provide the appropriate services and products to meet their specific needs.

Keep a historical record of the information, for the purpose of user satisfaction, developing analyzes of interests and needs; thus providing a better service.

Carry out market strategies by studying user behavior regarding offers and thereby improve content, customizing presentation and service.

Development of commercial prospecting and market segmentation.

Carry out satisfaction surveys and offer or recognize benefits of our loyalty program and after-sales service, to qualify the service and attention through the channels provided for thelo.

Carry out the necessary activities to manage requests, complaints and claims from users of the company or third parties; and direct them to the areas responsible for issuing the corresponding responses.

Submit reports to the inspection, surveillance and control authorities, and process the requirements made by administrative or judicial entities.

Accounting, economic, tax and administrative management of users.</ span>

Retention of the information by the terms established in the Law, especially that referring to the information of the books and papers of the merchant that must be stored for a period of ten (10) years, as provided Article 28 of Law 962 of 2005.

Transfer or Transmission of Personal Data nationally or internationally to third parties with whom VIRTUALWORK.AGENCY. develops activities in compliance with its corporate purpose. Likewise, Transmission or Transfer may be made to the strategic allies of the company so that they carry out marketing, advertising and promotion activities associated with the corporate purpose; all in accordance with the provisions of Colombian regulations.

Send information to those in charge of the Treatment to facilitate and improve the quality of the service of VIRTUALWORK.AGENCY.

Request collection authorization from the entities defined and authorized to do so.

Transfer and transmit your personal data to third-party business partners of VIRTUALWORK.AGENCY. that offer their products and services on the VIRTUALWORK.AGENCY.</b Platform >, in order to make efficient contact between the Owner and the business partner, under the terms of article 53 of Law 1480 of 2011.

Purpose of data processing of workers and collaborators

Carry out audits and manage systems and databases.</ span>

Contact workersores and collaborators to send information regarding the contractual and obligatory relationship they have with VIRTUALWORK.AGENCY.

Know, store and process all the information provided by workers and collaborators in one or several databases, in the format that it deems most convenient.

Compliance with the obligations contracted in its capacity as data controller with the owner of the information, in relation to the payment of salaries, social benefits and other remuneration enshrined in the employment contract or as provided law and contract.

Development of occupational health and safety prevention and promotion programs based on medical and occupational health information from the moment of admission, as well as during the execution and completion of assigned activities .

Development of education, training and training programs according to the position of the worker and/or collaborator.

Execute the contracts that have been concluded with the workers and collaborators.

Manage, maintain, develop and control the existing contractual relationship between VIRTUALWORK.AGENCY. and workers and collaborators, respond to their requests for information, as well as manage their claims , processing your requests to terminate the contract and/or to revoke the authorization for the processing of personal data.

Manage queries made by workers and collaborators.</span >

Manage information associated with the eventual commission of acts or circumstances that imply the development of ethical or disciplinary control procedures in accordance with the provisions of the applicable internal regulations and other applicable regulatory provisions.< span style="font-size: 12pt; font-family: 'Times New Roman', serif;">

The generation of backup copies and files of the information on the equipment provided by VIRTUALWORK.AGENCY..

Order, catalog, classify, divide or separate the information provided by workers and collaborators.

Offer corporate wellness programs and plan business activities for workers and collaborators and their beneficiaries.

To meet the legal demands and information requirements of the administrative, social security and judicial authorities that regulate, supervise or monitor the activities and operations of VIRTUALWORK.AGENCY.,</b >prior compliance with due process.

To comply with the Internal Work Regulations, as well as the internal policies of VIRTUALWORK.AGENCY.

To verify the information contained in the resume provided to VIRTUALWORK.AGENCY.

Prevent fraud or inappropriate use of information, programs, facilities and/or equipment to which workers and/or collaborators have access by virtue of the employment relationship.

Register the information of the family group of the workers and collaborators of VIRTUALWORK.AGENCY. for the fulfillment of the duties that the Law indicates, as well as to make them participate in the activities welfare or benefits provided by VIRTUALWORK.AGENCY.

Perform access control to VIRTUALWORK.AGENCY facilities.

Collect data for the fulfillment of the duties that, as Responsible for information and personal data, correspond to VIRTUALWORK.AGENCY.

Collect information deposited in credit bureaus.< /p>

Meet legal obligations, such as those related to the prevention of money laundering and financing of terrorism.

Verify, corroborate, verify, validate, investigate or compare the information provided by workers and collaborators, with any information legitimately available.

For the issuance of labor certifications torequest of workers and collaborators and/or any competent authority.</p >

To contact caregivers of workers and collaborators in case of emergency.

Classify, store and archive the personal data of workers and collaborators.

Retention of the information by the terms established in the Law, especially that referring to the information of the books and papers of the merchant that must be stored for a period of ten (10) years, as provided Article 28 of Law 962 of 2005.

To inform clients and suppliers of the work teams at VIRTUALWORK.AGENCY.

Verify, compare and evaluate the work and personal skills of workers and collaborators.

I send job offers.

Sending communications through any channel, on the occasion of marketing activities and contractual assistance.

Ensuring the safety of goods and people in private environments of VIRTUALWORK.AGENCY..

Record and use the recordings of closed circuit television cameras or images, to carry out investigations or disciplinary or criminal sanctions, as the case may be.

Validation of entry and exit information from the physical facilities of VIRTUALWORK.AGENCY.

Establish a biometric identification system in your security scheme.

Transfer and transmission of data nationally or internationally, if appropriate, for purposes related to the operation of VIRTUALWORK.AGENCY., in accordance with the provisions of law and always guaranteeing compliancento the requirements established in Colombian regulations.

Purpose of processing candidate data

Classify, store and archive the personal data of the candidates of the selection processes.

Verify and obtain references of natural and/or legal persons, provided by candidates in resumes, forms, among others.

Deliver or transmit the information to third parties in charge of the selection processes.

Verify, compare and evaluate the job and personal skills of candidates against the selection criteria.

Compliance with the legal duties to which the company is obliged.

Sending job offers.

Sending communications through any channel, on the occasion of marketing activities and pre-contractual assistance.

Ensuring the safety of goods and people in private environments of VIRTUALWORK.AGENCY.

Record and use the recordings of closed circuit television cameras or images, to carry out investigations or impose disciplinary and/or criminal sanctions, as the case may be.

Validation of entry and exit information from physical facilities.< /span>

Establish a biometric identification system in your security scheme.

Transfer and transmission of national or international dataonally to become appropriate, for the purposes related to the operation of VIRTUALWORK.AGENCY., in accordance with the provisions of the law and always guaranteeing compliance with the requirements established in Colombian regulations.</ span>

Virtual Work Agency data processing purpose

Keep entry and exit records for each work shift VIRTUALWORK.AGENCY.

Perform economic, accounting, fiscal and administrative management records, for the management of collections and payments, billing and compliance with financial obligations.

Advance processes within the company, for purposes of operational development and/or system administration.

Provide permanent training to the Virtual Work Agency shopkeeper on the use of the platform provided by VIRTUALWORK.AGENCY. for use by the Virtual Work Agency.

Keep control of the number of existing Virtual Work Agency shopkeepers within the platform provided by VIRTUALWORK.AGENCY. for use by the Virtual Work Agency.

Perform internal statistics management, in order to monitor the service.

Verify and obtain references of natural or legal persons provided by users.

Creation of an account on the platform provided by VIRTUALWORK.AGENCY. for use by Virtual Work Agency shopkeepers.

Collect or collect personal data and incorporate and store it in our database.

Sort, catalog, classify, divide or separate the information provided.

Use the data provided in communication campaigns, disseminationion and promotion or offer of products, activities or services developed as part of internal strategies of VIRTUALWORK.AGENCY.

Use them for internal administrative or commercial purposes such as: credit studies, commercial references of experience, market research, statistical analysis, conducting satisfaction surveys, offering or recognizing benefits of our program of loyalty.

Keep historical records of VIRTUALWORK.AGENCY. and maintain contact with the Virtual Work Agency shopkeepers.

Verify, check or validate the supplied data.

Study and analyze the information provided for the monitoring and improvement of products, service and attention.

Deliver the information collected to third parties with whom VIRTUALWORK.AGENCY. contracts the storage and administration of personal data, under the security and confidentiality standards to which VIRTUALWORK.AGENCY. is bound by the relevant laws.</ span>

Transmit and/or Transfer personal data to third parties located in any country or server in another country.

Communicate and allow access to the personal data provided, to third-party providers of general support services and to the natural or legal persons who are shareholders of VIRTUALWORK.AGENCY.

Collect, have, manage and use information to control and prevent fraud, control and prevent money laundering and financing of terrorism.

Sending communications through any channel including, but not limited to, social networks, text messages, push notifications, email, telephone calls, etc., related to the corporate purpose of VIRTUALWORK.AGENCY . such as marketing activities and/or any request made by the owner to VIRTUALWORK.AGENCY, among others. Transfer and transmission of data nationally or internationally, if appropriate, for purposes related to the operation of VIRTUALWORK. AGENCY., in accordance with the provisions of the law and always guaranteeing compliance with the requirements established in Colombian regulations.

Purpose of the processing of personal data of Suppliers

The collection and processing of the personal data of the suppliers will be done in order to contact and contract the products or services that VIRTUALWORK.AGENCY. requires for the normal functioning of its operation, in the same way it will have the following purposes:

Collect or collect personal data and incorporate and store them in the VIRTUALWORK.AGENCY database.

Request or perform consultancies, audits, advice or services related to suppliers.

Compliance with the company's internal processes regarding the management of suppliers and contractors.

Advance processes within the company, for purposes of operational development and/or system administration.

Make tax returns or manage tax and collection information.< /span>

Keep a record of supplier information.

Make reports before the inspection, surveillance and control authorities and/or respond to the requirements of administrative entities.

Carry out the registration and control of input and output of VIRTUALWORK.AGENCY installations.

Verify the information provided by suppliers, to control and prevent fraud.

Manage administrative procedures to develop any other activity in compliance with the relationship between suppliers and VIRTUALWORK.AGENCY.

CPreservation of the information by the terms established in the Law, especially that referring to the information of the books and papers of the merchant that must be stored for a period of ten (10) years, as provided in article 28 of Law 962 of 2005.

Transfer or transmission of data nationally or internationally, if appropriate, for purposes related to the operation of VIRTUALWORK.AGENCY., in accordance with the provisions of law and always guaranteeing compliance with the requirements established in Colombian regulations.

Sort, catalog, classify, divide or separate the information provided.

Use the data provided in communication campaigns, dissemination, promotion or offer of products, activities or services developed as part of internal strategies of VIRTUALWORK.AGENCY.

Use the data for internal administrative or commercial purposes such as: credit studies, preparation and presentation of quotes, invoices, commercial references of experience, market research, statistical analysis, satisfaction surveys.

Maintain contact with suppliers.</p >

Verify, check or validate the supplied data.

Study and analyze the information provided for the monitoring and improvement of the service and attention.

Collect, have, manage and use the information received to link as a provider.

Collect, have, manage and use the information received to control and prevent fraud, control and prevent money laundering and financing of terrorism.

Celebration, execution and management of business proposals and contracts object of the services provided.

Make reports to risk centers in accordance with the law for non-compliance with the financial obligations derived from the commercial relationship.

Perform operations and procedures related to the generation and payment of invoices, issuance of certifications, accounting, etc.

Compliance with legal duties and obligations.</ p>

Sending communications through any channel related to the corporate purpose of VIRTUALWORK.AGENCY., including, but not limited to, marketing activities and/or any request made by the headline to VIRTUALWORK.AGENCY.</p >

All other administrative and commercial uses that are established in the contracts or that derive from its activity.

Purpose of the treatment of the personal data of the Partners

Collect or collect personal data and incorporate and store them in the VIRTUALWORK.AGENCY database.

Sort, catalog, classify, divide or separate the information provided;

Use the data provided in communication campaigns, dissemination, promotion or offer of products, activities or services developed as part of internal strategies of VIRTUALWORK.AGENCY.

Use the data for internal administrative or commercial purposes such as: credit studies, preparation and presentation of quotes, invoices, commercial references of experience, market research, statistical analysis, satisfaction surveys.

Keep company historical records and maintain contact with data subjects.

Verify, check or validate the supplied data.

Study and analyze the information provided for the monitoring and improvement of the service and attention.

Collect, have, manage and use the information received by the owner of the information to link as a client or supplier.

Collect, have, manage and use the information to control and prevent fraud, control and prevent money laundering and financing of terrorism.

Celebration, execution and management of business proposals and contracts object of the services provided.

Make reports to risk centers in accordance with the law for non-compliance with the financial obligations derived from the commercial relationship.

Carry out operations and procedures related to the generation and payment of invoices, issuance of certifications, accounting, etc.

compliance with legal duties and obligations.</ p>

Sending communications through any channel including, but not limited to, social networks, text messages, push notifications, email, phone calls, etc., related to the corporate purpose of VIRTUALWORK.AGENCY. such as marketing activities and/or any request made by the owner to VIRTUALWORK.AGENCY, among others.

Transfer and transmission of data nationally or internationally, if appropriate, for purposes related to the operation of VIRTUALWORK.AGENCY., in accordance with the provisions of law and always guaranteeing compliance with the requirements established in Colombian regulations.

Purpose of the treatment of the personal data of Members

The collection and processing of personal data of the partners of VIRTUALWORK.AGENCY. will be private and will be carried out in order to allow the exercise of rights and duties related to such condition, as well as to carry out the following purposes:

Carry out the registration of economic, accounting, fiscal, and administrative management.

Issuing certificates related to the ownership of the shares, as well as issuing share certificates and others necessary for the proper development of the corporate purpose, prior authorization from them.

Carry out Processes within the Institution, for purposes of operational development and/or system administration.

Perform any other purpose necessary for the development of the rights and duties inherent to their capacity as shareholders.

Retention of the information by the terms established in the Law, especially that referring to the information of the books and papers of the merchant that must be stored for a period of ten (10) years, as provided Article 28 of Law 962 of 2005.

Transfer or transmission of data nationally or internationally, if appropriate, for purposes related to the operation of VIRTUALWORK.AGENCY., in accordance with the provisions of law and always guaranteeing compliance with the requirements established in Colombian regulations.

For other purposes or treatment, prior, express and informed authorization will be requested from the Owner.

AUTHORIZATION AND CONSENT OF THE HOLDER

The consent and authorization by the Holder of the information is a constitutional and legal requirement that must be met by the persons responsible for the processing of personal data. The consent must comply with the following assumptions:

Previous: Authorization must be given by the Information Owner prior to any type of Personal Data Processing.

Express: The authorization must be granted unequivocally, clearly and specifically.< /span>

Informed: The Owner must clearly understand what it is forYour personal data will be processed and the purposes that may derive from their Treatment.

All visitors to the VIRTUALWORK.AGENCY. Platforms must register and authorize the processing of personal data in order to use the services offered. Therefore, in each of the systems there is a box that says "Privacy Policy and Treatment of Personal Data" which must be read and accepted in order to continue using the services of VIRTUALWORK.AGENCY.< /b>

Obtaining Data Collected Before the Validity of Decree 1377 of 2013

In order to obtain or collect Personal Data of the Holders obtained before the validity of Decree 1377 of 2013, authorization will be sought through efficient communication mechanisms. Efficient communication mechanisms are understood as those that the Company uses in the ordinary course of its interaction with the Holders, such as emails, telephone calls, among others.

ACCESS CHANNELS AND MECHANISMS PROVIDED BY VIRTUALWORK.AGENCY.</ span>

VIRTUALWORK.AGENCY. will enable access channels for Headlines.

All communications, queries, complaints and/or claims should be addressed to the Personal Data Base Protection Officer or to the COSTUMER CARE/CUSTOMER SERVICE AREA of < b>VIRTUALWORK.AGENCY., by any of the following means:</span >

Users

Electronic attention: The Owner of the data may make the request through the Help Center available on the VirtualWork.agency contact platform.

Written attention: The Owner of the data must make his formal request at the address Cra. 18 # 33-30, Bogotá D.C. Colombia, providing sufficient prior proof of identity.

SIC Facilitates: The Holder has the possibility of going to the channel provided by the Superintendency of Industry and Commerce.

Virtual Work Agency</ p>

Electronic attention: The Owner of the data may make the request through the Help Center available on the platform commercially named “https://virtualwork.agency”.

Face-to-face assistance: The Data Owner must make their formal request at any Virtual Work Agency Hub.

Providers

Written attention: The Owner of the data must make his formal request to the address: Cra. 18 # 33-30 from Bogotá, Colombia.

Electronic attention: The Holder may make his request to the following email: suppliers@VirtualWork.agency

Allies

Electronic attention: The Owner of the data may make the request through the Help Center available on the platform commercially called "Virtual Work agency and its Allies".

Written attention: The Owner of the data must make his formal request to the address: : Cra. 18 # 33-30 from Bogotá, Colombia.

Verbal assistance: The Partner may communicate with the Virtual Work Agency advisor in charge of their relationship with VIRTUALWORK.AGENCY.

Employees and former employees</ p>

Written attention: The Owner of the data must make his formal request to the address: Cra. 18 # 33-30 from Bogotá, Colombia.

Electronic attention: The Holder may make his request to the following emails rh@VirtualWork.agency. .

Candidates

Written attention: The Owner of the data must make his formal request to the address: Cra. 18 # 33-30 from Bogotá, Colombia.

Visitors

Written attention: The Owner of the data must make his formal request to the address: Cra. 18 # 33-30 from Bogotá, Colombia.

LEGAL PROCEDURE FOR QUESTIONS, COMPLAINTS AND CLAIMS</ p>

Queries, complaints or claims may be submitted through a document with the characteristics described in each of the cases or through the query, complaint and claim form that can be consulted at </span >www.VirtualWork.agency in the Help Center option.</ p>

Queries

In the case of the right to request information and/or queries, VIRTUALWORK.AGENCY. will respond within a maximum term of ten (10) business days from the day following the date of receipt of the request or query.

When it is not possible to attend the query within said term, the interested party will be informed, indicating the reasons for the delay and indicating the date on which it will be attended, which in no case may exceed five (5 ) business days following the expiration of the first term. The query document should contain the following:

Area of ​​VIRTUALWORK.AGENCY. to which it is addressed (Customer care/Customer Service)

The Holder's name and identification number.

Copy of identity document of the holder</p >

In the event that the successor in title of the Holder requests the query, they must attach to the query:

VIRTUALWORK.AGENCY area. to whom it is addressed (Costumer care/Customer service)

The Holder's name and identification number.

Copy of the Successor's Identity Document.</ p>

Copy Civil Registry of Death of the Holder.< /p>

Document proving the quality of the work.

Copy of the Holder's identity document.</ p>

Full description of the query.</p >

Address and contact details of theconsultant.

If it is the legal representative and/or proxy of the Holder, it must present:

Area of ​​VIRTUALWORK.AGENCY. to which it is addressed (Customer care/Customer Service)

The Holder's name and identification number.

Copy Identity document of the legal representative</ p>

Document that proves the quality in which it works (power of attorney, certification).

Copy of the Holder's identity document.</ p>

In the event that the proxy is a minor, they must present the identity card and/or the civil registry and the document that proves the status of representative or custodian of the minor.< span style="font-size: 12pt; font-family: 'Times New Roman', serif;">

Full description of the query.</p >

Address and contact details of the consultant.< /p>

Complaints and/or claims

When the Holder considers that his information should be corrected, updated or deleted or when he notices an alleged breach of any of his rights, the maximum term to address the complaint or claim will be fifteen (15 ) business days counted from the day following the date of receipt of the document.

When it is not possible to attend the claim within said term, the interested party will be informed of the reasons for the delay and the date on which it will be attended, which in no case may exceed eight (8) days. working days following the expiration of the first term. If the claim is incomplete, the interested party will be required within five (5) days after receipt of the complaint and/or claim to correct the faults. After two (2) months from the date of the request without the applicant submitting the required information, it will be understoodwithdrawn the complaint or claim. The complaint or claim document must contain:

Area of ​​VIRTUALWORK.AGENCY. to which it is directed (Constumer Care/Customer Service)

The Holder's name and identification number.

Copy of identity document of the holder</p >

In the event that the successor in title of the Holder files the complaint and/or claim, they must attach:

Area of ​​VIRTUALWORK.AGENCY. to which it is addressed (Constumer Care/Customer Service)

The Holder's name and identification number.

Copy of identity document of the holder</p >

Copy of the Successor's Identity Document </p >

Copy Civil Registry of Death of the Holder.< /p>

Full description of the query.</p >

Address and contact details of the consultant.< /p>

Document proving the quality of the work.

If it is a legal representative and/or proxy:< /span>

Area of ​​VIRTUALWORK.AGENCY. to which it is addressed (Constumer Care)

The name and identification number of the Holder.

Copy of identity document of the holder</p >

Copy Identity document of the legal representative</ p>

Document that proves the quality in which it works (power of attorney, certification).

In the event that the proxy is a minor, they must present the identity card and/or the civil registry and the document that proves the status of representative or custodian of the minor.< span style="font-size: 12pt; font-family: 'Times New Roman', serif;">

Description of the facts giving rise to the claim and/or complaint.

The object pursued.

Address and contact details of the claimant.< /p>

PROCESSING OF SENSITIVE PERSONAL DATA

VIRTUALWORK.AGENCY. will not collect, store or process sensitive data, unless strictly necessary. If this situation arises, it will not carry out any treatment without the prior, informed and express authorization of the Owner of the information, except in cases where the granting of the same is not required by law and any of the following exceptions occur:</ span>

When the treatment is necessary to safeguard the vital interest of the Owner and the latter is physically or legally incapacitated.

When the treatment is carried out in the course of legitimate activities and with due guarantees by a foundation, NGO, association or any other non-profit organization, whose purpose is political, philosophical, religious or trade union, provided that they refer exclusively to its members or to people who maintain regular contact by reason of its purpose, in which cases, the data may not be provided to third parties without the authorization of the Owner.

When the treatment refers to data that is necessary for the recognition, exercise or defense of a right in a judicial process.

When the treatment has a historical, statistical or scientific purpose. In this event, measures leading to the suppression of the identity of the Holders must be adopted.

When it is carried out in compliance with a public or administrative order in the exercise of its legal functions or by court order.

The answers to the questions about sensitive data are optional, therefore, they will not be mandatory. In any case, VIRTUALWORK.AGENCY. will strictly observe the legal limitations to the Treatment of Sensitive Data. VIRTUALWORK.AGENCY., will not condition, in any case, any activity to the delivery of Sensitive Data. Sensitive Data will be treated with the greatest diligence possible and with the highest security standards. Limited access to Sensitive Data will be a guiding principle to safeguard their privacy and, therefore, only authorized personnel may have access to this type of information

The processing of sensitive data may not be carried out for purposes other than those expressly authorized by the Owner

NATIONAL OR INTERNATIONAL TRANSMISSION AND/OR TRANSFER< /p>

VIRTUALWORK.AGENCY. may share personal data information with those third parties that are necessary for the development of its activities and corporate purpose, always protecting the rights and information of the owner of the data.

The Transmission or Transfer of Personal Data that is carried out will observe the rules established for this purpose by the applicable regulations and the control authority, especially the following:

In the case of national transmissions or transfers of personal data, VIRTUALWORK.AGENCY. will ensure compliance with the requirements of current data protection legislation and the measures of protection by the manager or new manager, as the case may be.</p >

If it is an international transfer, you mustTo ensure that the receiving country of the personal data provides adequate levels of protection, in the manner established by the Control Authority in Colombia, so that it issues the declaration of conformity referred to in the first paragraph of article 26 of the Law 1581 of 2012. When the receiving country does not comply with the appropriate data protection standards, the transmission or transfer will be prohibited unless one of the following legal exceptions is configured:

That the Holder has given express and unequivocal authorization for the transfer or transmission of data.

Exchange of medical data when required by the treatment of the Holder for reasons of health and public hygiene.

Bank or stock transfers, in accordance with the applicable legislation.

Transfers agreed within the framework of international treaties to which Colombia is a party, based on the principle of reciprocity

Transfers necessary for the execution of a contract between the Holder and the data controller, or the execution of pre-contractual measures as long as they have authorization from the Holder.

VALIDITY

This Policy is effective as of June 17, 2020.

The Personal Data that is stored, used or transmitted will remain in the databases of VIRTUALWORK.AGENCY. for the time necessary to fulfill the purposes set forth in this manual or to enable the Company to comply with its legal duties.

However, the information will be reviewed every year to verify the veracity of the data and the purpose of continuing with its treatment. If necessary, VIRTUALWORK.AGENCY. reserves the right to modify this Policy unilaterally; Notwithstanding this, in the event of any substantial change to the Policy, the Owners will be notified.

Call Our Store

+57 319 650 6000

info@virtualwork.agency

Working hours of our store:

On weekdays:

Saturday:

Sunday:

from 8:00 to 21:00

from 9:00 to 20:00

from 10:00 to 19:00