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PRIVACY POLICY OF AMUSNET COLOMBIA S.A.S.

1. About the Privacy Policy

1.1. Amusnet Colombia S.A.S., a company incorporated in the Republic of Colombia, registered within the Bogotá Chamber of Commerce under Registration Number 03783355, having Tax Identification Number (NIT) 9018017382, with registered address at Carrera 15#106-32 Oficina PH 3 in the city of Bogota D.C., Colombia, e-mail: [email protected] (hereinafter referred to as the “Amusnet Colombia” or the “Company”) is a data controller and as a data controller complies with the rules and requirements of the Colombian legislation on personal data protection.

1.2. The present Privacy Policy aims to inform you about how Amusnet Colombia processes the personal data related to the persons specified below, for what purposes Amusnet Colombia collects and processes personal data, what are the grounds for processing personal data, the term of processing personal data, what are the rights of data subjects in relation to this processing, as well as other information aimed at ensuring transparent and conscientious processing of personal data by Amusnet Colombia.

 

2. What types of information do we collect and why?

Amusnet Colombia processes personal data necessary for the lawful and ordinary course of its business. This includes, among others, identification, contact and employment-related information of suppliers, clients and contractors, as well as financial and transactional information required for accounting, tax, and regulatory purposes.

Personal data is collected and processed for the following specific purposes:

The processing of personal data is carried out under the legal bases established in Statutory Law 1581 of 2012, Decree 1377 of 2013, and any other rules that modify, add to, or replace them, including the consent of the data subject, the performance of contractual obligations, compliance with legal duties, and the Company’s legitimate interests.

We process personal data related to the following persons (“You”):

2.1. Legal representatives, proxies, subcontractors, associates, and employees of our suppliers and business partners ("Contractors"), as well as personal data of data subjects of legal representatives, proxies, subcontractors, associates, and employees which may become our business partners.

2.2. Visitors of our Website and users of its information resources;

2.3. Persons making inquiries, requests, and other messages to us by mail, e-mail, telephone, and other means of communication;

2.4. The processing of personal data about the abovementioned data subjects is necessary for Amusnet Colombia for the conclusion, execution, and/or termination of contracts; identification of beneficial owners of legal entities – our suppliers and business partners, in view of our internal policies and rules. Without processing of the said personal data, Amusnet Colombia cannot enter into contracts with its Contractors or fulfill its obligations under them.

2.5. Company’s employees and job applicants.

 

3. Categories of Personal Data Processed

Amusnet Colombia collects and processes personal data according to the nature of its relationship with each category of data subjects, as described below:

3.1. Contractors

The personal data that may be collected and processed by Amusnet Colombia within our relations with Contractors might be the following:

3.2. Website visitors

When you visit our Website, we may process personal data relating to you through the use of cookies or similar technologies. For more information, please see our Cookie Policy.

When you make requests, inquiries, and other communications to us, we may process your personal data, such as names and contact details, which you have provided to us voluntarily for the purposes of carrying out communication with you and to respond to your inquiry.

3.3. People making inquiries, requests, and other communications

When you contact us by e-mail, telephone, or other means, Amusnet Colombia processes the personal data you voluntarily provide (such as name, position, contact details, and the content of your inquiry) solely for the purpose of responding to your request, maintaining correspondence, and keeping records of communications, in accordance with legal obligations and internal procedures.

3.4. Company’s employees and job applicants

Amusnet Colombia processes personal data of its employees and job applicants for purposes related to the management of the employment relationship, payroll and benefits administration, compliance with labour, tax and social security obligations, and workplace safety. The processing of job applicants’ data is limited to recruitment and selection processes, in accordance with internal procedures and applicable labour regulations,and the terms set forth in Amusnet Colombia’s Privacy Notice for Job Applicants.

 

4. For what purposes do Amusnet Colombia process your Personal Data?

Amusnet Colombia processes personal data for the following purposes:

4.1. Processing of personal data necessary for taking actions before concluding a contract, as well as for concluding, performing, and terminating a contract with Contractors

4.2. Processing of personal data needed for compliance with a legal obligation

4.3. Processing of personal data based on legitimate interest

 

5. То whom may Amusnet Colombia disclose your Personal Data?

Amusnet Colombia may use third parties to support certain contractual activities or with regard to the performance of a legal obligation. These third parties may act either as independent data controllers or as data processors acting on behalf of Amusnet Colombia, in accordance with the purposes described in this Policy and under the obligations established by Colombian data protection law.

Amusnet Colombia does not provide personal data to third parties before the requirements for disclosure of personal data to third parties provided for in the applicable legislation are met.

Recipients of personal data may be third-party legal and individuals, such as:

Some of the above recipients may be located outside the Republic of Colombia. In such cases, any international transfer of personal data will be carried out in compliance with Article 26 of Statutory Law 1581 of 2012 and other applicable regulations.

Amusnet Colombia ensures that all third parties receiving personal data are bound by confidentiality and data protection obligations consistent with this Policy and the applicable legislation.

 

6. What technical and organizational measures for data protection do we apply?

In accordance with applicable law, Amusnet Colombia implements all necessary technical and organizational measures to protect personal data from accidental loss and unauthorized access, use, alteration, or disclosure. The Company has adopted and ensured the implementation of internal policies and procedures designed to protect information from loss, misuse, and improper disclosure.

In addition, Amusnet Colombia implements information security measures, including, but not limited to, access control, strict physical protection, and robust practices for collecting, storing, and processing information, such as encryption, pseudonymization, and anonymization of the collected personal data.

Amusnet Colombia regularly reviews and updates its information security measures to ensure an appropriate level of protection in accordance with technological developments, the nature of the data processed, and the potential risks.

 

7. When do we delete your Personal Data?

Amusnet Colombia stores personal data within the statutory time limits, and if there are not explicitly defined statutory time limits, within the time limits set by the Company in order to achieve the purposes of the personal data processing listed above. The Company deletes personal data after the expiration of the statutory deadlines for their storage and/or achieving the purposes of data processing, but in any case, not before the final settlement of all our financial relations.

Amusnet Colombia stores personal data for the following periods:

The personal data may also be processed for a longer period than the above-mentioned terms, if such processing is necessary to achieve the purposes set out therein or to protect the rights and/or legitimate interests of Amusnet Colombia, or if the applicable legislation provides for the processing of such data for a longer period.

Amusnet Colombia retains personal data only for the period necessary to fulfil the purposes for which it was collected or to comply with applicable legal or contractual obligations, after which the data will be securely deleted or anonymized, in accordance with Article 4 of Statutory Law 1581 of 2012.

 

8. Do we transfer personal data outside Colombia?

Amusnet Colombia may transfer personal data outside the Republic of Colombia when such transfer is required for the ordinary course of its business activities or for the execution of contractual, legal, or commercial obligations.

Any international transfer of personal data will be carried out in accordance with Article 26 of Statutory Law 1581 of 2012, its regulatory decrees, and other applicable regulations.

Amusnet Colombia guarantees that all international data transfers are conducted under adequate security, confidentiality, and protection standards consistent with Colombian legislation.

 

9. What are Your rights in relation to the protection of your Personal Data?

9.1. In order to fulfill the obligations of Amusnet Colombia as a Data Controller, it is important for the Company to process and maintain your Personal Data accurate and up-to-date; if necessary, you may request an update of your Personal Data, correction, and/or supplementation, for which purpose you should send an application/request to the Company in compliance with the terms and conditions provided for in the legislation on Personal Data protection.

9.2. You have certain rights related to the processing of your Personal Data provided in Statutory Law 1581 of 2012 (“Data Protection Law”), including:

9.3. Please note that Amusnet Colombia does not use your Personal Data for profiling or automated decision making.

9.4. The terms and conditions for exercising your rights related to the protection of Personal Data are regulated in detail in the Data Protection Law. You may exercise your rights by making a written request to Amusnet Colombia on the contact details provided in this Notice in accordance with the requirements of applicable law. If necessary, Amusnet Colombia will provide you with full assistance in exercising the rights granted to you.

 

10. Data Controller:

Amusnet Colombia S.A.S. is the Data Controller under this Policy. Any matters related to the processing of personal data shall be addressed through the channels indicated in this document.

Address: Carrera 15#106-32 Oficina PH 3 in the city of Bogota D.C., Colombia
E-mail: [email protected]

If you wish to receive additional information on how Amusnet Colombia processes your personal data or you have questions related to the operation and application of the present Transparency Notice in the processing of Personal Data of employment applicants, you can contact us at the following e-mail address: [email protected].

Amusnet Colombia will address inquiries, requests, and claims related to the processing of personal data in accordance with Articles 14 and 15 of Statutory Law 1581 of 2012, and other applicable Colombian data protection regulations.

If deemed necessary, you may also contact the Superintendence of Industry and Commerce (SIC), as the national supervisory authority for data protection in Colombia.

 

11. Changes to the present Personal Data Protection Policy

This Data Protection Policy may be amended over time, and the changes made to it shall become effective promptly after being announced on the Company’s website.

 

 

Approved version on 09.01.2026