POLICY FOR THE PROTECTION AND TREATMENT OF PERSONAL DATA OF FLUVIP

This document contains the Policy for the Protection and Treatment of Personal Data (hereinafter the 'Policy') of employees, customers, suppliers, contractors and/or collaborators, and in general, whoever is on a (Hereinafter referred to as the 'Holders') of the company FLUVIP (hereinafter 'FLUVIP'), domiciled in each of the cities where it has local operations as registered on the website, with the email contact [email protected]

Acceptance of proposals, conclusion of contracts, completion of formats, access to the services offered through the website www.FLUVIP.com (hereinafter the Platform), entry to the company premises and/or the precise acceptance or unequivocal nature of this policy, implies the acceptance of the Policyholders for the Treatment and Protection of Personal Data and their authorization for the uses and other treatments described here.

1. DEFINITIONS

For the purposes of this Policy, the following definitions apply:

Personal data:

Any information linked to or associated with one or more specific or determinable natural persons.

Public data:

Data that is not semi-private, private or sensitive. This includes data on the marital status of persons, their profession or trade, and their status as a trader or public servant. By their nature, public data may be contained, inter alia, in public records and documents.

Private Data:

Information that by its nature intimate or reserved is only relevant for the Holder.

Sensitive personal data:

Data that affects the privacy of the owner or whose misuse has the potential to generate discrimination.

Semiprivate personal data:

Data that does not have an intimate, reserved, or public nature and whose knowledge or disclosure may interest not only its owner, but a group of people or society in general. In this case, for your Treatment requires the precise authorization of the Holder of the information. For example: data of a financial nature, data relating to relations with social security entities

Database

Organized set of personal data that is subject to Treatment. For the purpose of this document, it is understood as Database that contains information of Personal Data of the Holders.

Holder:

Natural person whose personal data are subject to Treatment. For the purposes of this document, the term 'Holders' refers to FLUVIP employees, customers, suppliers, contractors and/or collaborators, as well as to any person whose data is stored in a FLUVIP database.

Influencer:

Person or profile that, because of its level of followers, engagement and possibility of generating interactions in Social Networks, has great ability to communicate to a specific audience and therefore is in charge of publishing Advertisements of Advertiser Products.

Employee

A natural person who is linked by means of a labor contract to FLUVIP, or to a third party contractor who provides services to FLUVIP.

Client or Advertiser:

Natural person who is linked by signing contracts to purchase FLUVIP products and/or services.

Suppliers:

Natural person that provides or supplies products and/or services to FLUVIP.

Contractors and/or collaborators:

Natural person who has commercial and/or collaboration relationship with FLUVIP.

FLUVIP Platform:

Portal www.FLUVIP.com that is made available to the Influencer and its Advertisers so that they register and access their Services. The Platform offers its visitors a description of the Services and gives the possibility that each Advertiser select options that fit their needs and thus facilitate the choice of its Influencer.

Services:

It refers to the provision of intermediation services and Influencer Marketing by FLUVIP.

Influencer Marketing:

A form of marketing through which strategies of promotion, marketing and advertising of products, services and ideas are structured, through people and profiles that have the elements to become potential advisors to a specific audience.

Responsible for the Treatment:

A natural or legal person of a public or private nature, acting on her own or with others, decides on the Database and/or the Treatment of the data. For the purposes of this Policy, it is understood as Responsible for Treatment to FLUVIP.

Responsible for the Treatment:

Natural or juridical person, public or private, that by itself or in association with others, carries out the Treatment of personal data on behalf of the Responsible of the Treatment, that is FLUVIP.

Treatment:

Any operation or set of operations on Personal Data, such as collection, storage, use, circulation or suppression.

Transfer:

The data transfer takes place when the Person in charge of the Treatment of Personal Data, sends the Personal Data to a receiver, who in turn is Responsible for the Treatment and is inside or outside the country where they were received.

Transmission:

Treatment of Personal Data that implies the communication of the same, when it is intended to carry out a Treatment by the Manager and on behalf of the Responsible.

2. AUTHORIZATION

The authorization of the Personal Data Holders or of whom is legitimized is an indispensable requirement for FLUVIP to collect, store, consult, use, process and in general, Treatment of your personal information. This authorization will be granted by the Holder in written form, oral or through unequivocal conduct of the Holder that allow a reasonable conclusion that granted the authorization. It will be understood that the Licensee has granted the authorization expressly and unequivocally when browsing, registering or using the services of the Platform. FLUVIP will take appropriate measures to keep a copy or evidence, or to document the existence, of the authorization for future consultation.

The authorization of the Holder is not necessary when it is:

Delivery of information required by a public or administrative entity in the exercise of its legal functions or by court order.
Treatment of Public Data.
Cases of medical or health emergency.
Treatment of information authorized by law for historical, statistical or scientific purposes.

3. PERSONAL DATA

3.1. TYPES OF PERSONAL DATA RECOVERED BY FLUVIP

FLUVIP will give Treatment to the Personal Data that are necessary to carry out the commercial activities inherent to its social object, as well as to maintain and to strengthen the commercial, contractual, consumer and labor relations with the Holders of the same.

In particular, FLUVIP will collect the following personal data, among others that may be necessary for these purposes:

3.1.1. INFLUENCERS:

Likewise, if the Influencers have made it public in their social networks, FLUVIP will have access to data related to membership in trade unions, social organizations, human rights, religious, political, as well as data of preference, identity and sexual orientation of the person.

3.1.2. EMPLOYEES:

Name, surname, type of identification, identification number, date and place of issue, marital status, sex, signature, nationality, family and/or beneficiary data, other identification documents, place and date of birth or death, Photographs, location data related to commercial or professional activity, personal location data related to private activity, data related to health status, socioeconomic data, wealth data, data related to economic activity, data related to employment history, data Related to the educational level, training and/or academic history, general data related to health insurance and pensions, personal data of access to the FLUVIP information system, judicial and/or disciplinary records and any other information that may be necessary To achieve the purposes described.

3.1.3. CUSTOMERS:

Name, surname, type of identification, identification number, date and place of issue, sex, signature, nationality, place and date of birth or death, age, location data related to commercial or professional activity, related personal location data With private activity, socio-economic data, tax information data, patrimonial data, data related to economic activity, and any other information that is necessary to achieve the described purposes.

3.1.4. SUPPLIERS, CONTRACTORS AND/OR CONTRIBUTORS:

Name, surname, type of identification, Identification number, date and place of issue, sex, signature, nationality, place and date of birth or death, age, location data related to commercial or professional activity, personal location data related to private activity, financial data, credit and Or economic rights, socio-economic data, tax information data, economic data, data related to economic activity, and any other information that is necessary to achieve the purposes described. METHOD OF COLLECTION The data may be provided explicitly to FLUVIP through income or link formats, collected personally through its employees, service providers or representatives, obtained through consultation with third parties that administer Databases, or implicitly collected from the analysis operations Of target groups, acquisition of the products or services that are offered by FLUVIP, or the behaviors of the Holders such as claims, requests for information, surveys, proposals, offers, visits to FLUVIP facilities, participation in projects, programs and Events, among others.

3.3. SENSITIVE DATA

For the treatment of sensitive data, the Holders are informed that they are not obliged to provide such data or to authorize its treatment. Once these data have been provided and given the corresponding consent, the data will be collected and processed only for the purposes described in this Privacy Policy.

3.4. COOKIES

FLUVIP uses cookies and other tools that automatically collect information from people when they use the FLUVIP Website, understanding that entering and browsing the Website is an unambiguous authorization behavior. The type of information that can be collected in this way includes: Information about the Uniform Resource Locator (URL), information about the browser used by the Holder, details of the pages visited by the Holder, IP address, clicks, hyperlinks, name User, profile photo, queries, among others.

3.5. OTHER SOURCES OF COLLECTION

FLUVIP may receive personal information from the Holder through other sources such as Public Databases and information of third parties to which the Holder has granted authorization to share his information.

3.6. SCOPE

This Policy applies to the databases for which FLUVIP is responsible. Therefore, this Policy does not cover the treatment by third parties of:

Information collected on pages, platforms and/or applications that do not control FLUVIP.
Information collected by the third party sites accessed through any link on the FLUVIP Website.

4. PURPOSES AND TREATMENT

4.1. GENERAL PURPOSES

The purposes for which FLUVIP will treat the Personal Data and, which will apply in a general way to all the Holders, are:

A) To fulfill the corporate purpose of FLUVIP.
B) Manage, administer and use all the information necessary to fulfill FLUVIP's legal and contractual obligations, as well as tax, commercial, corporate and accounting obligations.
C) Execute contracts signed with FLUVIP.
D) Provide support in external and internal audit processes.
E) Send information to governmental or judicial entities at the express request of the same.
F) Collect data for the fulfillment of the duties that as responsible for the information and personal data belongs to FLUVIP.
G) Socialize policies, projects, programs and organizational changes.
H) To seek the satisfaction of the holders regarding the products and services offered by FLUVIP.
I) Provide better benefits, products and services to the Holders.
J) Customize the experience of the Holders on the FLUVIP Website.
K) Perform processes within FLUVIP, for development or operational purposes and/or system administration.
L) Maintain communication with the Holder.
M) Respond to questions, complaints, complaints or comments from the Holders.
N) Send commercial and/or corporate information, as well as invitations to events and/or activities that FLUVIP organizes.
O) The other purposes determined by those responsible for the process of obtaining Personal Data for Treatment, in order to comply with legal and regulatory obligations, as well as FLUVIP policies.

In addition, the specific purposes applicable to the different Holders of the FLUVIP databases are:

4.1.1. INFLUENCERS

(I) Identify the appropriate Influencer for the success of the advertising campaign. The Influencer is a person or a Profile that, because of its level of followers, engagement and possibility of generating interactions in Social Networks, has great ability to communicate to a specific audience and therefore is in charge of publishing the Announcements of Products of the Advertiser.
(Ii) Provide the Influence Marketing service, through which strategies for the promotion, marketing and advertising of products, services and ideas are structured through people and profiles that have the elements to become potential Influencers to a specific audience. This hearing refers to the potential and current followers of the Influencers and, therefore, the public to whom the Products will be recommended through the Ads.

4.1.2. EMPLOYEES

(I) To keep and manage the information of the employment relationship with the Holder.
(Ii) Verify conflicts of interest in new employees of FLUVIP and its subsidiaries, as well as their inabilities and incompatibilities.
(Iii) Keep a record of disciplinary sanctions imposed on employees of FLUVIP.
(Iv) Conduct Security Studies.
(V) Promote employee welfare activities.

4.1.3. CUSTOMERS

(I) Send and receive messages for commercial, advertising, and/or customer service purposes.
(Ii) Maintain contact with customers and potential customers for the sending of information related to the contractual and commercial relationship.
(Iii) Provide effective customer service.
(Iv) Report on change of products and/or services.
(V) Carry out billing activities, fraud prevention and money laundering consultations, verification of personal, commercial and labor references, consultation with the risk information centers or consultation of web pages and lists issued by different private entities And/or governmental, national or foreign, criminal and disciplinary records in which FLUVIP deems necessary.
(Vi) Perform collections management (written, telephone or personal), collection, control, behavior, payment habits, as well as any other related to our products, services and reporting to the risk information centers.

4.1.4. SUPPLIERS, CONTRACTORS AND/OR CONTRIBUTORS

(I) Make the respective payments to suppliers and maintain commercial relationships.
(Ii) Carry out financial studies and verification in databases of credit risk, financial risk, financing

4.2. TREATMENT OF PERSONAL DATA

FLUVIP will treat the Personal Data of the Holders to fulfill the purposes described in this Policy as applicable, to each of the Holders. Within these treatments, and in an expressive but not exhaustive manner, FLUVIP may perform the following:

A) Communication with the Holders for contractual, informational or commercial purposes.
B) Establish communication between FLUVIP and the Holders for any purpose related to the purposes set forth in this policy, whether through calls, text messages, emails and/or physical.
C) To offer or inform the Holder about products and/or services of FLUVIP that may be of interest to him, as well as to provide general information by means of electronic mails as part of a novelty, communication, bulletin, news or Newsletter.
D) If applicable, use the information to process complaints, complaints, suggestions regarding the services offered by FLUVIP.
E) To carry out or implement the acquisition or offer of products or services by FLUVIP.
F) Collect information about the device being used to view or use the Website, such as IP address or the type of Internet browser or operating system used and link it with personal information to ensure that the Web page provides the best experience online.
G) Evaluate the use of the Website (anonymously and integrally), as well as to make statistics of the activities of the Holders, such as hours of visits, frequency of visits and website transferred to the Web Page, in a way that will personalize the experience of the Headlines in the Web Page.
H) Invite and contact the Holders to participate in conferences, workshops, and any other event developed by FLUVIP.
I) Audit, study and analyze the information of the Databases to design commercial strategies and increase and/or improve the products and services offered by FLUVIP.
J) Supply the information and Personal Data of the Holders to subsidiaries, affiliates or affiliates of FLUVIP, commercial allies or other companies or persons that FLUVIP orders to perform the information processing and comply with the purposes described in this Policy.
K) When the information must be disclosed to comply with laws, regulations or legal processes, to ensure compliance with the terms and conditions, to stop or prevent fraud, attacks on the security of FLUVIP or Of others, to prevent technical problems or to protect the rights of others as required by the terms and conditions or the law.
L) Combine Personal Data with information obtained from other allies or companies or send it to them to implement joint trading strategies.
M) For the cases in which it applies, consult, store and use the financial information obtained from third party Database administrators, with prior authorization by the Holder for such consultation.
N) The others described in this policy or permitted by Law, As well as those necessary to fulfill the purposes described in this document.

4.4. SUPPLY OF PERSONAL DATA TO THIRD PARTIES

FLUVIP will only supply or give access to third parties to the personal information of the Holders when it is appropriate or necessary according to the purposes described in this policy.

Likewise, in case it is necessary to provide the Holders with third parties in charge to perform the treatment on behalf of FLUVIP, the Holder authorizes FLUVIP to provide its information with those third parties and, among others, with:

A) Advertising agencies that support FLUVIP to comply and analyze the effectiveness of its products and/or services.
B) Third parties that must deliver to the Holder some ordered product or service, such as a postal or messenger service.
C) To the police or governmental authorities in cases that they have followed the due process of law to request that they share the information of the Holder.
D) Third parties who wish to send the Holder information about their products and services only in cases in which they have given their prior consent to do so by the Holder.
E) Third party service providers, Outsourcing companies, mission or temporary staff.
F) Suppliers of web analytical tools, such as Google.
G) Companies, organizations or individuals outside FLUVIP, if it is considered that disclosure of such information is necessary for legal reasons.

Other reasons that may lead us to share information with third parties may be:

A) Reinforce the applicable terms of use of the FLUVIP Website.
B) Conduct investigations of possible violations of applicable laws.
C) Detect, prevent and protect FLUVIP against fraud and any technical or security vulnerabilities.
D) Comply with applicable laws and regulations, and work together for any legal investigation and to comply with governmental requirements.

FLUVIP may also supply or transfer the information to entities resulting from a split and/or total or partial merger of the business, consolidations, change of control, reorganization or liquidation of all or part of the business. With the authorization granted to FLUVIP for the treatment of its data, the Holder expressly states that the authorization granted will continue in force in the event that FLUVIP will merge, be split or transformed, whereby the authorization will be understood to be granted to the company resulting from the split, Fusion or transformation.

5. RIGHTS OF THE HOLDER

Holders have the following rights with respect to their Data: a) Know, update and rectify their Personal Data b) Request proof of authorization granted c) Be informed, upon request, regarding the use that has given to their Personal Data d) To submit to the Competent Authority complaints for infractions to the law of protection of personal data, according to the applicable law) To revoke the authorization and/or to request the suppression of the data f) Free access to his Personal Data that have been object of Treatment.

6. CONTACT DATA FOR CONSULTATIONS, CORRECTIONS AND CLAIMS

FLUVIP can be contacted at the following email: [email protected] and at the following telephone number (57 1) 703-3229.

7. PROCEDURE FOR CONSULTATIONS, CORRECTIONS AND CLAIMS

The following are the actions that may be presented by the Holders or their Assignees in relation to the consultations corrections and claims that relate to the data of the Registered Holders in the FLUVIP Databases:

7.1. CONSULTATIONS:

The inquiries and requests of the Holders or their successors in title shall be served within a maximum term of ten (10) business days from the date of receipt thereof. When it is not possible to attend the consultation within this term, the interested party will be informed in the address of notification that he/she has included in the respective consultation, stating the reasons for the delay and indicating the date in which his/her consultation will be attended, which in no case can exceed five (5) business days following the expiration of the first term. The answer to the queries that the Holders or their successors in title may be delivered by any physical or electronic means.

7.2. RETIFICATIONS AND COMPLAINTS:

The Holder or his assignees who consider that the information contained in the FLUVIP Databases must be corrected, updated or deleted, or when they notice the alleged breach of any of the duties contained in the law, may file a complaint with FLUVIP so:

1. The claim shall be made through a request addressed to the area in charge, in accordance with the provisions of Number Six of this Privacy Policy, with the identification of the Holder, the description of the facts that give rise to the claim, the address, and Accompanying the documents that you want to assert. If the claim is incomplete, the interested party will be required within five (5) days of receipt of the claim to remedy the faults. After two (2) months from the date of the request, without the applicant submitting the requested information, it will be understood that he has withdrawn from the claim.
In the event that the person receiving the complaint is not competent to resolve it, it will transfer to whom it corresponds in a maximum term of two (2) business days and inform the interested party.
2. Once received the complete claim, a legend that says 'claim in process' and the reason for it, in a term not greater than two (2) business days will be included in the database. This legend must be maintained until the claim is decided.
3. The maximum term to resolve the claim shall be fifteen (15) working days from the day following the date of receipt. When it is not possible to deal with the claim within that term, the interested party will be informed of the reasons for the delay and the date on which the claim will be dealt with, which in no case may exceed eight (8) business days following the expiration of the first finished. The response to rectifications or claims that the Holders or their successors in title may be delivered by any physical or electronic means.

7.3. REVOCATION OF THE AUTHORIZATION

The Owners of the Personal Data can revoke the consent to the treatment of their Personal Data at any time, as long as it is not impeded by the legal or contractual provision. For this, the Holder must follow the same procedure established for Rectifications and Claims.

It should be borne in mind that there are two ways in which revocation of consent can be given: (i) It may be on the totality of the consented purposes, in this sense FLUVIP and/or Treatment Managers must stop treating completely the (Ii) may occur on certain types of treatment, such as for advertising purposes or marketing studies.

Due to the above, it will be necessary that the holder at the time of raising the request for revocation, indicates in this one if the revocation that it intends to realize is total or partial. In the second case, indicate with which Treatment the Holder is not satisfied. In case the Holder does not indicate clearly, it will be understood that the request is total.

The mechanisms or procedure that FLUVIP establishes to deal with the requests for revocation can not exceed the deadlines established to deal with the claims.

7.4. PROCEDIBILITY REQUIREMENT

The Holder or assignee may only file a complaint with the Competent Authority once it has exhausted the process of consultation, claim or revocation of the authorization before the area in charge, in accordance with the provisions of Number Six of this Privacy Policy.

8. SAFETY MEASURES FOR THE PROTECTION OF PERSONAL DATA AND OTHER INFORMATION

FLUVIP will take reasonable precautions to keep personal information secure and to require any third party to handle or process Personal Data on behalf of FLUVIP to do the same. Access to personal information is restricted to prevent unauthorized access, modification or improper use, and will be allowed to be treated only by persons linked to FLUVIP or specifically instructed to do so.

9. PERIOD OF VALIDITY OF THE DATABASES

The Databases to which FLUVIP Treatment, as well as the duly authorized Personal Data incorporated in them, will be in force for the period necessary to fulfill its purposes. Once this period has expired, FLUVIP will proceed to delete the database or delete the data of the holders, as appropriate.

10. INTERNATIONAL TRANSFERS AND TRANSMISSIONS OF DATA

10.1. TRANSFER

FLUVIP may have to transfer personal information from Holders to Holders in different countries. By accepting this Policy for the Treatment of Personal Data, the Holder authorizes and expressly consents to such Transfer, to any country or territory.

10.2. TRANSMISSIONS

With the authorization granted by any of the means provided for this purpose, the Holder authorizes FLUVIP to perform national and international transmissions of Personal Data to a Manager, to allow the Manager to perform the Treatment on behalf of FLUVIP. These transmissions shall not require the Holder to be informed or have an express additional consent.

11. MODIFICATIONS TO THE POLICY OF THE TREATMENT OF PERSONAL DATA

Any change or substantial modification of this Policy for the Treatment of Personal Data will be communicated in a timely manner to the Holders through the publication on the FLUVIP Website.

12. INFORMATION AND INFORMATION ON MINORS OF AGE

FLUVIP will only use, store and process personal data of minors with the express consent of their parents or legal representatives. In the case of the data of minors children or dependent on employees or collaborators, the purpose of such treatment will be to plan and carry out activities related to the personal and family welfare of the same. For these purposes, FLUVIP will take into account the respect and prevalence of the rights of the minors, their superior interest and their fundamental rights.

13. EFFECTIVENESS AND MODIFICATIONS OF THE POLICY FOR THE TREATMENT OF PERSONAL DATA

This Policy for the Treatment of Personal Data is effective as of May 22, 2017. Any change or substantial modification of the present Policy for the Treatment of Personal Data will be communicated in a timely manner to the Holders by publication on the Website Of FLUVIP.