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PERSONAL DATA PROCESSING POLICY VIERNES ESTRATEGIA AUDIOVISUAL

VIERNES ESTRATEGIA AUDIOVISUAL S.A.S. adopts this Personal Data Processing Policy in compliance with Law 1582 of 2012, the Political Constitution, Regulatory Decree 1377 of 2013, and the Unified Regulatory Decree 1074 of 2015. This policy governs the collection, use, circulation, and other activities involved in the processing of personal data.

As a private entity responsible for processing personal data, we establish general guidelines for information protection.
In this regard, VIERNES ESTRATEGIA AUDIOVISUAL S.A.S. guarantees the rights to privacy, intimacy, and a good name in the processing of personal data of employees, suppliers, and clients.

I. IDENTIFICATION OF THE DATA CONTROLLER
The company responsible for processing personal data is VIERNES ESTRATEGIA AUDIOVISUAL S.A.S., an audiovisual content producer identified with NIT 900.757.168-2, located at Carrera 21 # 34-19 in Palmira, Valle del Cauca. Website: https://viernes-studio.com Phone: +57 2 284 4004.

II. SCOPE

This Data Processing Policy applies to all personal data held by VIERNES ESTRATEGIA AUDIOVISUAL S.A.S. in its physical or electronic databases of clients, suppliers, employees, and others as required by its social purpose.

III. DEFINITIONS
Authorization: Prior, express, and informed consent from the Data Subject to process personal data.

Database: An organized set of personal data that is subject to processing.

Personal Data: Any information linked or that can be associated with one or more individuals.

Data Processor: A natural or legal person, public or private, that processes personal data on behalf of the Data Controller.

Data Controller: A natural or legal person, public or private, who decides on the database and/or the processing of the data.

Data Subject: An individual whose personal data is subject to processing.

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

IV. PRINCIPLES
VIERNES ESTRATEGIA AUDIOVISUAL S.A.S. will govern its data protection policy according to the law, under the following principles:

Legality: Data processing is a regulated activity that must comply with established laws.

Purpose: Data processing will have a legitimate purpose by the Political Constitution of Colombia and the Law, which must be informed to the Data Subject.

Freedom: Data processing can only be carried out with the Data Subject’s prior, express, and informed consent.

Veracity or Quality: The data processed must be truthful, complete, accurate, updated, verifiable, and understandable.

Transparency: The Data Subject has the right to obtain information about their data at any time.

Restricted Access and Circulation: Processing is subject to limits derived from the nature of personal data, the law, and the Constitution.

Security: Data must be handled with the necessary technical, human, and administrative measures to ensure the security of the records.

Confidentiality: All employees who manage, handle, or access company data are obligated to ensure the confidentiality of the information.

V. DATA PROCESSING AND PURPOSES

1. For Employees: VIERNES ESTRATEGIA AUDIOVISUAL S.A.S. collects, stores, consults, transmits, circulates, and processes the personal data of employees to execute employment contracts and comply with legal and regulatory requirements. This also includes information on job candidates, former employees, temporary workers, and beneficiaries.

2. For Clients and Suppliers: VIERNES ESTRATEGIA AUDIOVISUAL S.A.S. collects, stores, uses, and processes information provided by clients and suppliers as part of the onboarding and contractual process.


VI. RIGHTS OF DATA SUBJECTS

Data subjects have the following rights:

• To know, update, and rectify their data.

• To request proof of authorization.

• To be informed about the use of their data.

• To file complaints with the Superintendency of Industry and Commerce.

• To revoke authorization and/or request data deletion.

• To access their personal data for free.

VII. AUTHORIZATION OF THE DATA SUBJECT

VIERNES ESTRATEGIA AUDIOVISUAL S.A.S. requires the prior, express, and informed consent of data subjects for the use of their personal data, obtained through appropriate forms and contracts.