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This privacy notice (the “Notice”) sets out the terms and conditions, in virtue of which, INVEST NEW S. A. S , business society identified with the N. I. T. 901.932.624-3 and with registered offices in the city of Bogotá D. C. (“INVEST NEW S. A. S” or the “Company”), will carry out the processing of personal data from individuals interested in (i) the purchase of the units and/or real estate projects managed, designed, marketed, and built and/or supervised by GROUP DACARI;
(i) purchase the services and/or products offered by the Company; and (ii) in general, potential clients, customers, former customers, suppliers, contractors, candidates, employees, employees, former and collaborators of the Company (collectively, the “Holders” or individually considered as the “Holder”).
This Notice shall be governed in accordance with the provisions of the colombian law applicable to the processing of personal data of the Holders and in accordance with what is established in the Manual of Policies and Procedures for Protecting Personal Data and Privacy of GROUP DACARI., which is available to the query of the Holder, at any time, on the website of the Company: WWW.INVIERTENUEVO.CO (the “Manual”).
1. TREATMENT AND PURPOSE

I. The treatment that will INVEST NEW S. A. S with respect to personal data of the Holders will be directed to the collection, storage, use, circulation, update and/or deletion of information, under the following purposes: to Carry out the relevant procedures for the development of the object of the alliance or agreement entered into between the Company and the Holder, in execution of the business activities arising from the corporate object of the Company.
II. Referral of information to the Holders related to the corporate purpose of the Company, management accounting, fiscal and administrative, verification of legal requirements, technical and/or financial.
III. Advertising and marketing, offering of products and services.
IV. Commercial relations, invitation to events or receptions, social and/or administrative.
V. Make commercial campaigns and marketing activities.
VI. Manage paperwork, requests, complaints, and grievances.
VII. Conduct satisfaction surveys with respect to the goods and services offered by the company.
VIII. Contact the Owner via telephone or electronic means to conduct surveys, studies and/or confirmation of the personal data which are necessary for the performance of a contractual relationship.
IX. Contact the Owner via the electronic media, social networks – SMS or live chat to send news related to loyalty campaigns or improved service.
X. Contact the Owner through email for the shipping of extracts, account statements, or invoices in relation to the obligations arising from the contract concluded between the parties.
XI. To comply with the obligations assumed by INVESTING NEW S. A. S with the

Owner, human resources and payroll management, in connection with the payment of wages, social benefits and other compensation established in the contract of employment or as required by law.
XII. Offer wellness programs and corporate planning activities business for the Owner and their beneficiaries (children, spouse or permanent partner).
XIII. Do background checks criminal, judicial, disciplinary, financial and business Owner in lists public or private.
XIV. Attend to the requirements of agencies of control and surveillance.
XV. Access and consult the personal data in the power of credit and financial information, and gather information relevant to the credit behavior of the Owner. For the processing of personal data in accordance with this purpose, the Company expressly inform the user about such treatment.
XVI. Sharing the personal data of the Owner with financial institutions in those cases in which the Holder wishes to hire a service with those aimed at the acquisition of units and/or real estate projects built, managed, designed, marketed and/or supervised by INVESTING NEW S. A. S.
XVII. Transfer the Holder's personal data to any third party suppliers of goods or services, and commercial partners of the Company as necessary for the purposes of fulfilling the obligations deriving from existing relationships with the Owners. The Owner authorizes a voluntary basis, prior and express to the Company, to disclose, transfer, and/or transmit your personal data within and outside the country, to a third party as a result of the conclusion of a contract, a covenant, a bond is lawful or statutory provision so requires.
XVIII. Other activities related to the development of the corporate object of the Company and resulting in the development of the relationship that you have with the Owner.
2. RIGHTS OF THE HOLDER

As the Owner of your personal data, you have the right to:
I. free Access to the database provided that they have been the object of treatment.
II. Know, update and rectify your information from partial data, inaccurate, incomplete, fractioned, deceptive, or those whose treatment is prohibited or has not been authorized.
III. Request proof of the authorization granted.
IV. Submit before the Superintendence of Industry and Commerce (SIC) complaints for violations of the provisions of current regulations.
V. to Revoke the authorization and/or request deletion of data, provided that there is a legal duty or a contract that prevents remove them.
To refrain from answering questions about sensitive data. You will have an optional answers, dealing with sensitive data or data of children and adolescents.

3. DUTIES OF RESPONSIBLE AND IN CHARGE OF THE TREATMENT

GROUP DACARI will strictly adhere to the following duties in accordance with the quality having regard to the processing of personal data of the Holders in each particular case:

DUTIES OF THE RESPONSIBLE
TREATMENT DUTIES OF THE
TREATMENT MANAGER
Ensure to the Owner the full and effective exercise
the right of habeas data. Ensure to the Owner the full and effective exercise
the right of habeas data.
Request and retain a copy of the authorization
granted by the Owner. To keep the information under conditions of
security best.
Inform the Holder about the purpose of the
collection and your rights. Perform timely update,
rectification or deletion of the data.
To keep the information under safety conditions are ideal. Update to the information reported by the
responsible within five (5) business days of its receipt.
To ensure that the information provided to the clerk to be truthful, complete, accurate, up-to-date, verifiable and
understandable.
To process the requests and claims within the terms of the law.
Update the information, communicating promptly with the manager all the news regarding the data, previously supplied to it, and to adopt measures so that the information is
keep up-to-date.

Take the Manual fulfillment of the law.

to

guarantee

the
Correct the information when it is incorrect
and report to the manager. Register in the database the legend
“grievance procedure” in terms of the law.

Only provide the manager with data whose treatment is authorized. Insert in the database the legend “a discussion of the court” once it has been notified by the competent authority on judicial processes
related to the quality of the personal data.
Require the manager with respect to the security and privacy of the information of the Holder. To refrain from circulating information that is being disputed by the Owner and which lock has been ordered by the
Superintendence of Industry and Commerce.
To process the requests and claims within the terms of the law and of the Manual. Allow access to information only to persons who may have access to it.
Take the Manual fulfillment of the law. to ensure the Comply with the instructions and requirements
issued by the Superintendence of Industry and Commerce.
Inform the Holder about the use of their
personal data.
To inform the processor when
specific information is located in


DUTIES OF THE RESPONSIBLE
TREATMENT DUTIES OF THE MANAGER
TREATMENT
discussion on the part of the Holder, once it has been
filed a claim and you have not finished the processing of the respective order.
Inform the data protection authority (Superintendencia de Industria y Comercio) when there are violations of safety codes and there is a risk for the information
of the Holders.
Comply with the instructions and requirements
issued by the Superintendence of Industry and Commerce.

In case of convergence of the qualities of the controller and processor in GROUP DACARI, you will be required the fulfillment of the duties provided for each one of these.
4. CUSTOMER SERVICE CHANNELS TO THE HOLDER OF THE DATA

GROUP DACARI set as channels of communication and attention to their Holders the following:
Physical address: AV EL POBLADO # 1 – 50
Phone: (+57) 3212707244
Cell: (+57) 3008202343
E-mail: info@inviertenuevo.co
Web page: www.inviertenuevo.co

5. PROCEDURE FOR TREATMENT OF PQRS

Reception PQRS – data Processing: Any request by the Owner of the data, to learn, correct, update and/or remove your personal data or to revoke the authorization in the cases established in the Law 1581 of 2012, received by mail or e-mail box is routed like this:
I. Received the request through the designated mailbox info@inviertenuevo.co
II. It will check if the application is complete; otherwise, if it is incomplete, you need to contact the Owner within a period not exceeding five (5) business days, via email, by phone and/or correspondence; and indicate the procedure that you must follow in order to make effective the application, and will be logged in the database with the observation, “claim incomplete”.
III. The request will be routed to the appropriate area (depending on the subject of the PQRS)
IV. All claims and/or PQRS will be answered in a maximum term to meet the claim of fifteen (15) days counted from the day following the date of your receipt and completeness.
V. If the cause of the PQRS that is invoked is the violation of a right (the right VIOLATED), you need to redirect the Legal area of INVESTING NEW S. A. S, in order to treat, fix, solution and response that will be returned through the mail info@inviertenuevo.co

VI. You must notify the Holder of the solution of your PQRS through the channel chosen by the Owner.


6. VALIDITY

This Notice applies from the date of publication, and shall be in effect during the time in which it INVESTS NEW S. A. S run the purposes described in the present document and may be changed at any time in order to adapt to new practices that develop legislative or jurisprudential developments in the field.

Any update to the Notice will be made available to the Holders on the website of INVEST NEW S. A. S available in: www.inviertenuevo.co or in any other means deemed appropriate, indicating the date of entry into force of the corresponding amendment or update, as applicable.