POLICY FOR THE TREATMENT OF
PERSONAL DATA

NAVAL CAT INTERNATIONAL
S.A.S.

NIT. 900.194.047

Zona Franca Rionegro Bga 207

Rionegro – Antioquia

INTRODUCTION

NAVAL CAT INTERNACIONAL
S.A.S., as Responsible for the Processing of Personal Data, has established this Personal Data Protection Policy to guarantee the trust, security and quality of the information during the Processing of Personal Data, in accordance with the authorization of the Data Controllers and the General Regime for the Protection of Personal Data of Colombia («RGPD»). NAVAL CAT INTERNACIONAL S.A.S. is committed with the privacy and the protection of the data of the persons who are part of its Stakeholders, among others, customers, collaborators, workers and/or suppliers, («Stakeholders») and in general, with the data of the persons with respect to whom it collects and processes Personal Data.

NAVAL CAT INTERNACIONAL S.A.S. in its interest to make explicit its Policy regarding the protection of Personal Data, by means of this Policy for the Treatment of Personal Data («Policy») establishes the guidelines that govern the Treatment of Personal Data under its administration.

The foregoing, in compliance with the General Regime for the Protection of Personal Data in Colombia, formed by the Statutory Law 1581 of 2012 and the Single Regulatory Decree 1074 of 2015, and the rules that regulate, modify and/or complement them.

SCOPE

This Policy applies to all the Personal Data registered in the Databases under the responsibility or administration of NAVAL CAT INTERNACIONAL S.A.S., who acts as Responsible for the Processing of the Personal Data. Likewise, the guidelines set forth in this Policy shall be complied with during the Processing of all the Personal Data carried out by all the collaborators or persons in charge who carry out the Processing of the Personal Data on behalf of NAVAL CAT INTERNACIONAL S.A.S. Therefore, in this Policy there are guidelines on the following matters:

1. Relevant terms
2. Responsibility
3. Principles that guide NAVAL CAT INTERNACIONAL S.A.S. during the Processing of Personal Data.
4. Personal Data being Processed
5. Collection of Personal Data
6. How is the Personal Data processed?
7. Purposes for which the Personal Data is Processed 
8. Sensitive Data
9. Unsolicited Personal Data
10. Who has access to Personal Data?
11. Security Commitment
12. Updating of Personal Data and Processing of Unauthorized Personal Data
13. For how long is the Personal Data processed? 
14. Rights of the Data Controllers
15. Responsible for answering queries and claims
16. Consultations, complaints or claims by the holders to exercise their rights.
17. Validity of the Policy and the Databases